Fri Sep 8th, 2006 at 12:02:24 PM EST
Here's a draft of a letter to Energy Commissioner Andris Piebalgs -- (here's his About page) -- expressing our objections to the Energy Green Paper Consultation mechanism.
Dear Commissioner Piebalgs,
The Commission you head is currently running a Public Consultation on the Green Paper, A European Strategy for Sustainable, Competitive and Secure Energy.
The Green Paper presents a certain number of major policy directions on this most vital of subjects. And it states, p. 4 :
"The Spring European Council and the European Parliament are invited to react to this Paper, which should also spark a wide-ranging public debate."
Or, again, p.19 :
"The Community needs a real Community-wide debate on the different energy sources..."
The Public Consultation may therefore be expected 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.
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, precisely, 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 go on 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...
Almost the entire questionnaire is constructed in this way, with restrictive, leading, and manipulative questions, the effect of which is to create apparent consent for the policy choices set out in the Green Paper. A polling institute which made use of questions of this kind would quickly be challenged over them and would lose credibility.
Only at the end of the questionnaire, in Section G, are broader policy questions broached, in a summary manner. It is 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. However, 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 definition of (?) energy policy a vital and urgent matter about which all citizens should be well informed and in which they should be involved. Top-down policy-making runs the risk of failing to obtain genuine consent and adhesion from citizens at a time of change. In this context, it is regrettable that the Public Consultation on the Energy Green Paper should, by its restrictive and manipulative nature, conform to the sorry image of Brussels policy-making taking place in a world far removed from that of ordinary citizens.
I suggest Communication Commissioner Wallström should be copied into this.
Update [2006-9-7 3:14:7 by afew]: Wallström's Commission is also running a Consultation on Communications, closing date 30th September. Criticism we get together on this Energy Consultation could form the basis of a contribution to that Consultation.
I also took a look at the EC's Minimum Standards on Consultation (pdf). I expected it to lay out clear rules and guidelines for the Commission, but it's often vague. It spends time summarising a discussion within the Commission (I suppose) about this. I got the feeling (is it surprising?) that there was a fair amount of resistance from within to the idea of greater openness in communication and consultation. So a lot of page space goes into defining how the Commission should decide who is an organism for the purposes of a consultation (I think, to put it baldly, that people in the EC were looking to hang on to their habit of co-opting who they wanted for policy input, in other words, listening to Brussels lobbyists).
This might interest us (p.17) :
Openness and accountability are thus important principles for the conduct of
organisations when they are seeking to contribute to EU policy development. It must
c Which interests they represent
how inclusive that representation is.
Interested parties that wish to submit comments on a policy proposal by the Commission must therefore be ready to provide the Commission and the public at large with the information described above. This information should be made available either through the CONECCS database (where organisations are eligible21 for this
database and wish to be included on a voluntary basis) or through other measures, e.g. special information sheets. If this information is not provided, submissions will be considered as individual contributions.
On this basis, the Biofuels Consultation may have been generous in classifying us as an NGO. Any thoughts?
Crits and redrafting of the letter welcome. Where I put (?) it means I didn't know what to put.