Is the Commission a “lawmaker”? On the right of initiative, institutional transparency and public participation in decision-making: ClientEarth - Common Market Law Review View Is the Commission a “lawmaker”? On the right of initiative, institutional transparency and public participation in decision-making: ClientEarth by - Common Market Law Review Is the Commission a “lawmaker”? On the right of initiative, institutional transparency and public participation in decision-making: ClientEarth 56 3 Common Market Law Review