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๐Ÿ’ฐ Carbon Pricing
Making the RecommendationLesson 4 of 56 min readPMR Assessment Guide Attachment 7

Writing the Recommendation Paper

Writing the Recommendation Paper

The recommendation paper is where analysis becomes actionable advice. This lesson provides practical guidance on writing effective carbon pricing recommendations that move decision-makers to action.

Purpose of the Recommendation Paper

A recommendation paper:

  • Presents a clear recommendation with supporting rationale
  • Enables decision-makers to make informed choices
  • Documents the basis for the decision (for accountability and future reference)
  • Provides sufficient detail for implementation to begin
  • Anticipates and addresses likely concerns

The recommendation paper is not the place to showcase everything you know. It is a decision document. Include what decision-makers need to decide, no more.

Structure of a Recommendation Paper

A typical structure:

1. Purpose What decision is being requested?

2. Background Brief context. Why is this coming forward now?

3. Recommendation State the recommendation clearly and early. Do not bury it.

4. Key considerations The main arguments for and against.

5. Analysis Summary of technical analysis supporting the recommendation.

6. Stakeholder views What do affected parties think?

7. Implementation How would this be implemented?

8. Risks and mitigation What could go wrong? How would we manage it?

9. Next steps What happens after the decision?

The Recommendation Statement

The recommendation should be:

Specific: What exactly are you recommending?

Actionable: What should the decision-maker do?

Clear: No ambiguity about what you are proposing.

Weak recommendation: "It is recommended that the government consider carbon pricing options."

Strong recommendation: "It is recommended that Cabinet approve the implementation of a carbon tax at $25 per ton CO2e, effective January 1, 2027, rising $10 per year to $65 per ton by 2031, with revenue allocated as follows: 50% to household dividends, 30% to income tax reductions, and 20% to a transition fund for affected workers."

The Purpose Section

Keep it brief. One paragraph is usually enough.

Include:

  • What decision is being requested
  • What authority is needed (Cabinet approval, legislative change, regulatory amendment)
  • Any deadline or urgency

Example: "This paper seeks Cabinet approval to introduce carbon pricing legislation in the 2027 session. Decision is needed by [date] to allow time for bill drafting and stakeholder consultation before session begins."

The Background Section

Provide just enough context for the decision:

Include:

  • Why carbon pricing is being considered
  • Key commitments or targets
  • Previous decisions or consultations
  • Timeline of how this came to this point

Exclude:

  • Lengthy history of climate policy
  • Technical details that belong in analysis section
  • Advocacy for carbon pricing generally

Key Considerations

This is where you present the main arguments, for and against:

For the recommendation:

  • Meets emissions targets
  • Cost-effective approach
  • Generates revenue for priorities
  • Aligns with international peers
  • Supported by key stakeholders

Against the recommendation (and responses):

  • Concern: Impacts competitiveness
  • Response: Addressed through free allocation and border adjustment
  • Concern: Regressive impacts
  • Response: Revenue recycling makes net impact progressive

Some recommendation papers present multiple options:

When to present options:

  • Decision-makers have asked for options
  • There are genuinely different legitimate approaches
  • Political judgment is needed on key trade-offs

How to present options:

  • Present each option objectively
  • Show pros and cons of each
  • Indicate which you recommend and why
  • Make comparison easy

Common approaches:

Option A: Conservative approach (lower price, slower increase) Option B: Moderate approach (recommended) Option C: Ambitious approach (higher price, faster increase)

Each with clear trade-offs between cost and environmental ambition.

Pitfall to avoid: Presenting a "straw man" option that makes your preferred option look good by comparison.

The Analysis Summary

Summarize technical analysis. Detailed analysis belongs in appendices.

Include:

  • Key findings relevant to the decision
  • Main numbers (emissions impact, revenue, costs)
  • Important uncertainties
  • Reference to full technical analysis

Format:

  • Use bullets and tables for clarity
  • Round numbers appropriately
  • Contextualize (is this a lot?)
MetricProjected impact
Emissions reduction by 203020-25% below baseline
Revenue (Year 1)$3.5-4.0 billion
GDP impact-0.3% to -0.5%
Household impact (bottom quintile, before recycling)+2.1% expenditure
Household impact (bottom quintile, after dividends)-0.5% (net benefit)

Stakeholder Views

Decision-makers need to know how stakeholders will react:

Include:

  • Which stakeholders were consulted
  • Summary of supportive views
  • Summary of concerns raised
  • How concerns are addressed in the recommendation

Be balanced: Fairly represent opposing views. Decision-makers will hear from opponents, so it is better to address concerns proactively.

Implementation Section

Show that the recommendation can actually be implemented:

Include:

  • Timeline for implementation
  • Legislative or regulatory requirements
  • Administrative capacity needs
  • Key implementation challenges and solutions
  • Phasing approach

Example timeline:

  • Q1 2027: Cabinet approval
  • Q2-Q3 2027: Legislation drafted
  • Q4 2027: Parliamentary passage
  • 2028: Implementation preparation
  • January 2029: System operational

Risks and Mitigation

Acknowledge what could go wrong:

Risk categories:

  • Implementation risks (delays, cost overruns)
  • Economic risks (recession, price spikes)
  • Political risks (opposition, backlash)
  • Technical risks (MRV failures, evasion)

For each risk:

  • Likelihood and impact
  • Mitigation measures
  • Residual risk

Be honest: Do not minimize risks. Decision-makers appreciate candor.

Next Steps

Be specific about what happens after approval:

Immediate actions:

  • Draft legislation
  • Begin stakeholder engagement
  • Establish implementation team

Key milestones:

  • Legislation to Parliament by [date]
  • Regulations finalized by [date]
  • System operational by [date]

Reporting back:

  • Implementation update to Cabinet by [date]

Writing Style

Be direct: "It is recommended that..." not "It might be considered that..."

Be concise: Every sentence should add value.

Use active voice: "The carbon tax will reduce emissions" not "Emissions will be reduced by the carbon tax."

Avoid jargon: Define technical terms or use plain language alternatives.

Use parallel structure: Consistent formatting makes documents easier to scan.

A recommendation paper is like a legal brief. It presents your best case clearly and concisely. It anticipates counterarguments and addresses them. It respects the decision-maker's time while providing everything needed to decide.

Common Mistakes

Burying the recommendation: Put it early, not at the end after pages of background.

Too much detail: Decision-makers do not need to know everything. Technical details go in appendices.

Advocacy tone: Present evidence and analysis, not passion and rhetoric.

Ignoring opposition: Address concerns; do not pretend they do not exist.

Vague recommendations: Be specific about what you are proposing.

Missing next steps: Decision-makers need to know what happens after they decide.

Quality Assurance

Before submitting:

Technical review: Has the analysis been checked?

Policy review: Does this align with other government policies?

Legal review: Are there legal issues?

Communications review: How will this be communicated if approved?

Editorial review: Is it clear, well-organized, and error-free?

Looking Ahead

A well-written recommendation paper increases the chances of approval. But getting to that approval also requires managing the political process. The final lesson examines political economy and stakeholder buy-in.

Knowledge Check

1.What should a recommendation paper include?

2.How should the recommendation be stated?

3.Why should opposing views be addressed in a recommendation paper?

4.What is a common mistake in writing recommendation papers?

5.Why is an implementation section important?