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 vital subject and it states that the Public Consultation should open up a "wide-ranging public" (p.4) and "Community-wide" (p.19) debate 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: "In order to achieve the goal of a genuine single market, what new measures should be taken at EU and MS level?" The respondent is not asked her or his opinion of the goal, the goal is a given. The neutrality of the questionnaire is throughout impaired in a similar 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) Question 9 : "How can a common European energy strategy best address climate change, balancing the objectives of environmental protection, competitiveness, and security of supply?" (support for these objectives is assumed) ...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. Moreover, policy options other than those of the Green Paper are absent from the responses presented in the questionnaire. A major example is that, at no point, does the questionnaire offer energy demand reduction as a strategic policy option. (....?) 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. To sum up, the automated part of the Consultation (i.e. the IPM questionnaire), by reason of its manipulative questions and narrow range of responses, leaves room only for a form of interactivity that is guided from the top down. It appears designed to manufacture support for the Green Paper's policy options. Those Europeans who wish to exercise their right to argue for other positions than those of the Green Paper must draft their own responses, preferably in only one of the EU's twenty languages. The inequality of access to free expression in the Consultation, between supporters of the Commission's views, and supporters of alternative options, is flagrant. The European Tribune is an open 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
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 vital subject and it states that the Public Consultation should open up a "wide-ranging public" (p.4) and "Community-wide" (p.19) debate 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:
"In order to achieve the goal of a genuine single market, what new measures should be taken at EU and MS level?"
The respondent is not asked her or his opinion of the goal, the goal is a given.
The neutrality of the questionnaire is throughout impaired in a similar 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)
Question 9 : "How can a common European energy strategy best address climate change, balancing the objectives of environmental protection, competitiveness, and security of supply?" (support for these objectives is assumed)
...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.
Moreover, policy options other than those of the Green Paper are absent from the responses presented in the questionnaire. A major example is that, at no point, does the questionnaire offer energy demand reduction as a strategic policy option. (....?)
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.
To sum up, the automated part of the Consultation (i.e. the IPM questionnaire), by reason of its manipulative questions and narrow range of responses, leaves room only for a form of interactivity that is guided from the top down. It appears designed to manufacture support for the Green Paper's policy options. Those Europeans who wish to exercise their right to argue for other positions than those of the Green Paper must draft their own responses, preferably in only one of the EU's twenty languages. The inequality of access to free expression in the Consultation, between supporters of the Commission's views, and supporters of alternative options, is flagrant.
The European Tribune is an open 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
Is there a good example you can see in the questionnaire of excluded options, speaking technically?
My suggestion:
Moreover, policy options other than those of the Green Paper are absent from the responses presented in the questionnaire. A major example is that, at no point, does the questionnaire offer a return to centralised forms of control of the sector, whether on a national or a pan-European basis. That may not be the Commission's preference, but a neutral questionnaire should acknowledge that the option exists and allow people to express their preference for it. Similarly, at no point does the questionnaire allow respondents to express a preference for demand reduction mechanisms (whether directed through taxes or quotas, or incited via education or "good practice").
A bit wordy, so feel free to cut... In the long run, we're all dead. John Maynard Keynes
...A major example is that, at no point, does the questionnaire offer a return to centralised forms of control of the sector, whether on a regional, national or a pan-European basis. Or, alternatively, the option of a decentralised sector with serious limitations and selection among the players. These may not be the Commission's preference, but a neutral questionnaire should acknowledge that these options exist and allow people to express their preference for such alternatives.
I know people, not homeless nor jobless, who can literally not afford to heat throughout the winter when prices climb. This is not like being unable to afford a car, we talk basic needs with no room for sparing. So between the Commission's "reasonably priced" talk and general demands for increased energy tax "that should hurt", I'd argue against the principle of one price for all, e.g. for social subsidies. These exist. They inevitably change what "reasonably priced" can mean.
Reply on the main question follows. *Lunatic*, n. One whose delusions are out of fashion.
Question 2 or 14 would be a good pick for a glaring omission, but a single one. The choices for Question 3 would be an example of leaving out just about anything sensible (from my viewpoint), but the problem is already with the framed question. Question 12 would be a good pick for too narrow a focus, e.g. only electricity generation, but the offered choices aren't all that bad.
As a general point, perhabs the complete supply-sider approach should be further highlighted by marking the complete omission of transport policy. *Lunatic*, n. One whose delusions are out of fashion.
Moreover, policy options other than those of the Green Paper are absent from the responses presented in the questionnaire. A major example is that, at no point, does the questionnaire offer a return to centralised forms of control of the sector, whether on a regional, national or pan-European basis. Or, alternatively, the option of a decentralised sector with serious limitations and selection among the players. These may not be the Commission's preference, but a neutral questionnaire should acknowledge that these options exist and allow people to express their preference for such alternatives. Similarly, at no point does the questionnaire allow respondents to express a preference for demand reduction mechanisms (whether directed through taxes or quotas, or incited via education or "good practice"). In the same order of ideas, transport policy, despite the evident relation of transport systems to energy consumption, is not evoked. Entire questions offer a narrowly-focussed range of responses that evacuate essential items. An example is Question 2, concerning the development of a single European grid, in which the only options proposed concern management rules, no mention being made of planning, financial, construction, and environmental issues which must inevitably be faced in the creation of a single grid.
Entire questions offer a narrowly-focussed range of responses that evacuate essential items. An example is Question 2, concerning the development of a single European grid, in which the only options proposed concern management rules, no mention being made of planning, financial, construction, and environmental issues which must inevitably be faced in the creation of a single grid.
Or, alternatively, the option of a decentralised sector with serious limitations and selection among the players.
I'm not sure I understand that sentence (at least the selection bit).
I like the paragraph as a whole, but this sentence is confusing to me. In the long run, we're all dead. John Maynard Keynes
By selection, I meant preferring one type of production to another. Wrong choice of words, maybe "different treatment of" instead of "selection among" would work. *Lunatic*, n. One whose delusions are out of fashion.
Moreover, policy options other than those of the Green Paper are absent from the responses presented in the questionnaire. A major example is that, at no point, does the questionnaire offer a return to centralised forms of control of the sector, whether on a regional, national or pan-European basis. Public financing of the sector is not contemplated. Neither is any explicit public policy to favor some technological choices over others. Alternatively, the option of a decentralised sector with serious limitation on the size of actors is also ignored. All these options may not be the Commission's preference, but a neutral questionnaire should acknowledge that they exist and are backed by significant constituencies, and should allow people to express their preference for such alternatives. at no point does the questionnaire allow respondents to express a preference for demand reduction mechanisms (whether directed through taxes or quotas, or incited via education or "good practice"). similarly, transport and land occupancy policies, despite their evident impact on energy use patterns, are not even evoked. Entire questions offer a narrowly-focussed range of responses that evacuate essential items. An example is Question 2, concerning the development of a single European grid, in which the only options proposed concern management rules, no mention being made of planning, financial, construction, and environmental issues which must inevitably be faced in the creation of a single grid.
Now, I'll do something more on languages if I get the goods over the weekend. If not, it's ready to go as it is, imo.
