I don’t know about FFII, but this site and its efforts are run voluntarily.

Probably the worst time right now for a hedge fond lobbyist.

This is the consultation document:
http://ec.europa.eu/internal_market/consultations/docs/hedgefunds/consultation_paper_en.pdf
with the questions.

Or more relevant to us
http://ec.europa.eu/yourvoice/ipm/forms/dispatch?form=InfsoNis
which runs till 9 January.

Interactive Policy Making(IPM), the software for the consultation form, is btw. an open source software developed by the EU Commission IDABC.

My recommendation on ENISA: rewind the institution. It is totally useless and just a lobby proxy, consultancy without any effects. This is why the Commission proposed to merge it into the new telecom regulation agency. But as no one liked the new telecom regulation agency, enisa survived for now. The estonian case is the typical lobby sermon and the only sphere where it is debated is among enisa lobbyists.

Now there are certain questions:

“Electronic networks and services constitute the nervous system of our society and the economy, and recent large scale cross-border cyber attacks, for example in Estonia, have highlighted our dependence on them. In this context, what are the major challenges for network and information security to be considered at the national, EU and international level, in particular with regard to resilience of electronic communication networks and information infrastructures?”

“Given the importance of electronic networks and services for society and the economy, what should be the three key priorities for policy to address the evolving challenges to network and information security at the EU and the international level? ”

“Member States have a key role and overall responsibility in guaranteeing the security and continuity of critical services for citizens and businesses. In this context, what should be the focus of future EU policy in order to: •enhance cooperation at the EU level between national competent bodies; and •achieve a holistic, all-encompassing approach to network and information security; •reinforce the synergy between measures focusing on prevention and resilience (“first pillar”) and measures supporting judicial and law enforcement cooperation (“third pillar”)? (optional)”

“The security and resilience of the Internet is a joint responsibility of all stakeholders, including operators, service providers, hardware and software providers, end-users, public bodies and national governments. This responsibility is shared across geographical boundaries, in particular when responding to large-scale cyber attacks. In this context, what role should the EU play to strengthen the preparedness of the key stakeholders?”

“Because of the global nature of the Internet, each and every country has a degree of inter-dependence with other countries, not least when responding to large-scale cyber attacks. How can we support trans-national cooperation in the EU to cope with evolving network and information security challenges? ”

“What instruments are needed at EU level to tackle the challenges and support the policy priorities in the field of network and information security? In particular, what instruments or mechanisms are needed to enhance preparedness to handle large scale cyber disruptions and to ensure high levels of security and resilience of electronic networks and infrastructures? ”

etc.

So how to respond? The best way is to collect all these questions and let a response text to the consultation just mature over time.

this one
http://ec.europa.eu/yourvoice/consultations/index_en.htm

http://www.yourvoice.com.au/au/

Consider for instance OOXML. It started with the attitude, I am dead, go and kill me. The best way to combat a party is to force them to play evil and expose that. You build a little Tiananmen Square for them. One person against the tanks. It doesn’t matter if the person gets rolled over as long as you record it on tape. One person killed, then comes the next one. For a campaigner you need to be professional and not get outraged over the violent acts. In fact these acts are very useful to built your case and make it real fun.

Sometimes you don’t have to “win”, you rather stage a “phyrric victory” or artificially escalate a situation.

European ICT policy urgently needs more public involvement and input. You are too negative here. You should monitor the site YourVoice and the sub pages and direct your readers to upcoming consultations.

But of course there should be more participation in EU consultations which relate to ICT.

Just because these organisations respond to the consultation this doesn’t translate in them beeing influential.

Once you get into such a debate there is nothing or little to lose but a lot to gain.

Maybe you should blog more about ICT consultations:
http://ec.europa.eu/yourvoice/consultations/index_en.htm

There is nothing wrong with lobbyists who write comments, it is their job. Whether an American company and American citizens are well advised to lobby European institutions in an aggressive way is another issue.

It is certainly high time to reclaim European institutions and get a Foreign Lobby Transparency ACT as they have it in the US.