186 – Submissions to government

There are many opportunities for Australians to attempt to influence government through making submissions to government inquiries and reviews. Relatively few people go to the bother of writing submissions, but I often have a go, especially when it relates to environmental policy. What have I learnt about the process?

As well as being a regular submitter, I have a little bit of experience of being on the other side of the process. I was a member of a four-person Ministerial Taskforce reviewing salinity policy in Western Australia in 2001 (Frost et al., 2001). We took written submissions and held public hearings.

I’ve learnt not to have high expectations that one’s carefully crafted submission will have a noticeable impact on policy.

If what you say is similar to many other submissions, then the fact that you put in a submission will probably not make much difference. Its value is in reinforcing points that others are also making.

On the other hand, if your submission is different to or in opposition to most other submissions, you have more chance of it standing out, but also more chance of it being dismissed as being out of line with popular opinion. It’s not necessarily the case that sound logic and evidence can outweigh the majority view.

Another reason why it might not have much impact is information overload. Whoever has to read the submissions has to get through a huge amount of information very quickly. Any ideas that are a bit challenging risk getting put aside because there isn’t time to give them the thought they would need. There are no rules saying that every submission has to be fairly dealt with and responded to in detail. I suspect that many get only a cursory look.

My feeling is that some inquiries adopt a fairly cynical attitude to submissions, using them selectively to bolster a more-or-less pre-determined position.

Those comments probably seem more negative than is warranted. Many inquiries do make sincere efforts to get to the bottom of things, especially those with a panel that is relatively independent of the thing being inquired into.

The real challenge comes later. Even if your submission does make a substantial difference to the content and recommendations of the inquiry’s report, there is no guarantee that policy makers will respond accordingly. For example, in 2006 the Australian Government’s Senate Committee inquiring into salinity got very enthusiastic about our Salinity Investment Framework III (SIF3). Their report, “Living with salinity – a report on progress” includes a three-page section on SIF3, plus

“Recommendation 22: The Committee recommends that the Australian Government in cooperation with the states and territories keep a watching brief on the development of the Salinity Investment Framework 3 (SIF3), with a view to potentially implementing it (or a modified version of it) across the country. It is recommended that the framework be applied within the context of the new (post-2008) program(s).”

Of course, it didn’t happen. For one thing, salinity was completely dropped from the political agenda in 2008. But even the more general successor to SIF3, the Investment Framework for Environmental Resources (INFFER) has not been applied by the new program, Caring for our Country.

I was initially surprised to learn how easy it is for government to ignore the recommendations of inquiries, even its own inquiries! For example, I am on record as being a strong critic of the National Action Plan for Salinity and Water Quality (Pannell and Roberts, 2010). In my judgment, it was a very poorly conceived program that spent a lot of public money and achieved very little (PD174). There were four government reviews of the program conducted during its life (two by the Australian National Audit Office, one by a Senate committee and one by a House of Representatives committee), and many of my concerns about the program were raised in one or more of the inquiry reports. But the program continued on with no fundamental changes. The responsible departments were not held to account. They could get away with glib assurances that they would take the recommendations into account, but then continue on as before.

So why bother? There are several reasons why I persist in putting in submissions to almost every inquiry that is related to my research.

The main reason is that, even though change to an existing program seems to be almost impossible (unless there is some sort of public scandal), change can occur on a longer time scale. One can detect that many of the new features of Caring for our Country were attempts to address concerns about previous programs raised by the Australian National Audit Office. Not all concerns were addressed, and some of the new features introduced new concerns, but at least there was some attempt.

Another thing is that it provides another channel for communication. I accept that any particular act of communication is likely to have limited impacts, but over the long term I’m hopeful that lots of communication can add up to something that has an influence.

Finally, it doesn’t cost much time to put in a submission. They have to be pretty brief if you want them to be read, and given the other issues I’ve raised here, it isn’t worth labouring over them too much. So I usually do one, but do it quickly.

These thoughts are on my mind because last Thursday I put in a submission to the current review of the Caring for our Country program.

David Pannell, The University of Western Australia

Further Reading

Frost, F.M., Hamilton, B., Lloyd, M. and Pannell, D.J. (2001). Salinity: A New Balance, The report of the Salinity Taskforce established to review salinity management in Western Australia, Salinity Taskforce, Perth, 78 pp. Full report (732K pdf)

Pannell, D.J. and Roberts, A.M. (2010). The National Action Plan for Salinity and Water Quality: A retrospective assessment, Australian Journal of Agricultural and Resource Economics, 54, 437-456. Journal web site here

Leave a Reply

Your email address will not be published. Required fields are marked *

Please solve this to show you\'re a real person *