Fri Sep 15th, 2006 at 09:04:31 AM EST
Here's the final draft of our letter of complaint to the European Commission about the Energy Green Paper Consultation. I suggest it should be sent as an open letter, addressed to both Energy Commissioner Piebalgs and Communication Commissioner Wallström.
Please don't hesitate to comment or make further suggestions.
Update [2006-9-15 10:58:10 by afew]:This has now been sent to the two Commissioners and to MEPs on the European Parliament Industry, Research and Energy Committee. A French version is now ready to go to French MEPs. If you want to send either the English or French version to MEP(s), let me know by posting here or by e-mail, and I'll send you the PDF file(s). Other language versions welcome, if anyone can work on them...
***Back to the diaries. ET cooperative work in action!
Dear Commissioner Piebalgs,
Dear Commissioner Wallström,
The Transport and Energy 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 available in the questionnaire.
- A major example is that the questionnaire does not 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 mandated through taxes or quotas, or encouraged via education or best practice).
- Similarly, transport and land occupancy policies, despite their evident impact on energy use patterns, are not even mentioned.
Entire questions offer a narrowly-focused range of responses that neglect essential items. An example is Question 2, concerning the development of a single European grid, in which management rules alone are proposed as options, while no mention is made of planning, financial, construction, and environmental issues which must inevitably be faced in the creation of a single grid.
Only at the end of the questionnaire, in Section G, are broader policy questions broached and then only in a superficial way. 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, appears designed to manufacture support for the policy options in the Green Paper. 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. It is not made clear that such a response will even be entertained, though on enquiry we were told that it would be. There is a flagrant inequality of free expression between supporters of the Commission's views and supporters of alternative options in the Consultation. This is especially striking in comparison with our experience with the DG-TREN Biofuels Consultation where open responses were encouraged.
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.
We seem to have agreed that the best way of signing this letter is to have individual signatories, referenced as European Tribune Collaborative Editors. It would be good to have a wide cross-section of EU citizens from different countries. If you'd like to volunteer, you don't need to post personal details here. Use my e-mail address :
afew at europe dot com
to send :
- your name;
- country of residence
An open letter may have more impact :
- in making the case better known to a larger number;
- in raising the stakes (however slightly!) for the recipients, so they are less likely to ignore the letter.
Signatories (and others) might like to send a copy of the letter to their MEP.
Any suggestions of other ways of making this known?
Can anyone make a PDF of the finished, signed letter, so we can not only attach it to an e-mail but also print it easily?
Follow-up on the Biofuels Consultation
There have been a couple of high-level "endorsements" of our position in the news recently. Sven linked to this statement by Sir Peter Crane, director of the Royal Botanical Gardens, Kew, warning of the environmental dangers of extensive development of production of first-generation biofuels. The CEO of Volkswagen also warned that first-generation biofuels were not sustainable. DoDo reported that the German government was threatening to oblige car manufacturers to work on reducing fuel consumption, which was an option we put forward in the consultation.
All well and good, but it doesn't mean there won't be backing for first-generation biofuels from the top.
We sent an e-mail thanking the team that works on the Biofuels Consultation for doing the job properly. Yesterday I received this reply:
Dear Mr [afew], thank you for these comments. Getting e-mails like this certainly helps to keep us motivated. We've been pleased with the results of the consultation, a lot of thought has gone into many of the responses. Now we're working on the progress report and possible proposal for amendment of the directive. I can't promise you will like the results (I am sure that on at least some points you will not) but I can certainly say that they will be influenced by what people have said.
No idea what the "some points" might be. Except that I'm sure (I know from local examples in the region where I live) that there will be "pork" handed out to agri-interests to run biofuels operations.