Dear Commissioner Piebalgs, Your Directorate is currently running a Public Consultation on the Green Paper, A European Strategy for Sustainable, Competitive and Secure Energy. The Green Paper presents a number of major policy directions on this most vital of subjects and it states that the Public Consultation should open up a “wide-ranging public” (p.4) and “Community-wide” debate (p.19) on them. We therefore expected the Public Consultation to further and facilitate this wide-ranging debate, in the spirit of the Report on European Governance and the White Paper on a European Communication Policy. We were disappointed to see that, apart from a one-day public hearing in Brussels, the consultation mechanism consists of an Interactive Policy-Making online questionnaire with multiple-choice answers. What is immediately striking about it is that the policy suggestions of the Green Paper are not offered as subjects for debate, or even as polling options (with choices such as : Agree strongly, Agree, Disagree, Disagree strongly, etc…), but are stated as axiomatic.In Section A, Question 1, for example, we read: The respondent is not asked her or his opinion of the goal, the goal is a given. One of the answers presented (arrowed in red) appears to offer a contrary option to the goal of a single market, but it is impossible to choose that answer while respecting the logic of the question. It follows that the respondent is logically led to make choices that support the apparently self-evident aim of “a genuine single market”. The questions continue in the same way: Question 2 : “In order to develop a single European grid…” (pre-supposed aim) Question 3 : “Apart from ensuring a properly functioning market…” (pre-supposed condition) Question 4 : “How can it be ensured that all Europeans enjoy access to energy at reasonable prices?” (pre-supposed strategic goal) and so on. Most of the questions in the questionnaire are restrictive, leading, and manipulative. The effect is to force respondents into apparent consent to the policy choices set out in the Green Paper. A polling institute which made use of questions of this kind would quickly be challenged and discredited. Only at the end of the questionnaire, in Section G, are broader policy questions broached but in a summary manner. We find it difficult to understand why these questions of general policy were not placed at the beginning of the questionnaire, and why they were not given fuller treatment. The Consultation web page does not offer respondents the option of writing their own contributions and sending them in. It may be objected that they are free to use the “Any other comments” boxes in the questionnaire to state their opinions but encouragement to do so is limited: for comments of any length, it is necessary to prepare the text elsewhere and paste it into the comment window, taking care to respect the questionnaire’s chapter headings. The Consultation adds a further restriction: “Please note that replying in English will facilitate our analysis of your answers.” This poses a considerable obstacle for non-English-speakers, and appears contrary to constant EU policy on multi-lingualism. How can all European citizens, faced with limits of this kind, be said to be free to join in the debate? If the Consultation mechanism lacks the means to handle EU languages suitably, then the EU is not taking seriously the goal of listening to citizens, and is not funding communication and consultation procedures sufficiently. The European Tribune is an online forum for civic debate, with a strong focus on European issues. We consider the formulation of a European energy policy a vital and urgent matter about which all European citizens should be well informed and in which they should be actively involved. Top-down policy-making runs the risk of failing to obtain genuine consent and adhesion from citizens in times of change, and to cause political apathy. In this context, we regret that the Public Consultation on the Energy Green Paper should, through its pre-decided character, counteract the desired image of truly cooperative and democratic policy-making in the European Union. Yours, etc
Dear Commissioner Piebalgs,
Your Directorate is currently running a Public Consultation on the Green Paper, A European Strategy for Sustainable, Competitive and Secure Energy.
The Green Paper presents a number of major policy directions on this most vital of subjects and it states that the Public Consultation should open up a “wide-ranging public” (p.4) and “Community-wide” debate (p.19) on them. We therefore expected the Public Consultation to further and facilitate this wide-ranging debate, in the spirit of the Report on European Governance and the White Paper on a European Communication Policy.
We were disappointed to see that, apart from a one-day public hearing in Brussels, the consultation mechanism consists of an Interactive Policy-Making online questionnaire with multiple-choice answers. What is immediately striking about it is that the policy suggestions of the Green Paper are not offered as subjects for debate, or even as polling options (with choices such as : Agree strongly, Agree, Disagree, Disagree strongly, etc…), but are stated as axiomatic.In Section A, Question 1, for example, we read:
The respondent is not asked her or his opinion of the goal, the goal is a given. One of the answers presented (arrowed in red) appears to offer a contrary option to the goal of a single market, but it is impossible to choose that answer while respecting the logic of the question. It follows that the respondent is logically led to make choices that support the apparently self-evident aim of “a genuine single market”.
The questions continue in the same way:
Question 2 : “In order to develop a single European grid…” (pre-supposed aim)
Question 3 : “Apart from ensuring a properly functioning market…” (pre-supposed condition)
Question 4 : “How can it be ensured that all Europeans enjoy access to energy at reasonable prices?” (pre-supposed strategic goal)
and so on.
Most of the questions in the questionnaire are restrictive, leading, and manipulative. The effect is to force respondents into apparent consent to the policy choices set out in the Green Paper. A polling institute which made use of questions of this kind would quickly be challenged and discredited.
Only at the end of the questionnaire, in Section G, are broader policy questions broached but in a summary manner. We find it difficult to understand why these questions of general policy were not placed at the beginning of the questionnaire, and why they were not given fuller treatment.
The Consultation web page does not offer respondents the option of writing their own contributions and sending them in. It may be objected that they are free to use the “Any other comments” boxes in the questionnaire to state their opinions but encouragement to do so is limited: for comments of any length, it is necessary to prepare the text elsewhere and paste it into the comment window, taking care to respect the questionnaire’s chapter headings.
The Consultation adds a further restriction: “Please note that replying in English will facilitate our analysis of your answers.” This poses a considerable obstacle for non-English-speakers, and appears contrary to constant EU policy on multi-lingualism. How can all European citizens, faced with limits of this kind, be said to be free to join in the debate?
If the Consultation mechanism lacks the means to handle EU languages suitably, then the EU is not taking seriously the goal of listening to citizens, and is not funding communication and consultation procedures sufficiently.
The European Tribune is an online forum for civic debate, with a strong focus on European issues. We consider the formulation of a European energy policy a vital and urgent matter about which all European citizens should be well informed and in which they should be actively involved. Top-down policy-making runs the risk of failing to obtain genuine consent and adhesion from citizens in times of change, and to cause political apathy. In this context, we regret that the Public Consultation on the Energy Green Paper should, through its pre-decided character, counteract the desired image of truly cooperative and democratic policy-making in the European Union.
Yours, etc
So I'm not sure this is the best example anymore.
Maybe we could delete that specific part, and keep the rest as a cover letter which complains about the loaded questions and the English.
Then, if we can draft it, we add an annex with substance on the various questions In the long run, we're all dead. John Maynard Keynes
Then, if we can draft it, we add an annex with substance on the various questions
If you're right then obviously we must change this.
Please look at the queries below.
Note that I approve of the independence of regulators - to apply neutrally macroeconomic policies defined by the political world. I approve of the ECB's independence, and I also approve the goals which were set for it, which are sound and consistent with the instruments they have.
There is currently no understandable goal in the energy sector beyond preventing the French government and others from defining energy policies at the national level. In the long run, we're all dead. John Maynard Keynes
Remaining queries concern:
* whether to do (appended or not) a full take-down of the questionnaire;
whether to add a paragraph pointing out that alternative policy options are largely excluded from the questionnaire;
pointing out that translation work on the questionnaire seems poor (with possibly appended examples);
what to think of "minimum standards" on what kind of org can participate as an org in consultations.
If we send multiple copies as individuals, that's different.
The European Tribune is an online forum for civic debate, with a strong focus on European issues.
That's one possibility (we may need one of those anyway), but probably the best thing here is multiple copies or, better, multiple signing by individuals from as many countries as possible. With reference to European Tribune, certainly. (Contributor, contributing editor, etc).
May need to list both nationality and residence. Nothing is 'mere'. — Richard P. Feynman
"Wish" to be included as an org? We ask to be considered as an org?
I wouldn't like to get a response from Piebalg's office saying "Nice try, but we don't have to listen to you."
Multiple signatures is probably the way to go, referencing ET all the same, of course.
