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Consultation: Letter to Piebalgs

by afew 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.

Yours, etc


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 be apparent: 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.

Display:
From FFII on the software patent consultations, see here and here for how the consultation procedure "worked".


14 July 2006   
P-3390/06
WRITTEN QUESTION by Eva Lichtenberger (Verts/ALE) to the Commission

Subject: Data processing and consultation procedure on the `Future of patent
policy in Europe'

From 16 January 2006 to 12 April 2006, the European Commission carried out a
public consultation on the future of patent policy. The preliminary findings of
this consultation were been released on 5 July 2006. It appears that the
Commission conducted a parallel consultation under the name of `SME panel'. The
following website: http://www.eic.org.tr/Eng/duyuru_detay.aspx?ID=636 refers to
a document transmitted by DG MARKT and DG ENTR to the network of European Info
Centres (EIC) which says: `DG MARKT-D2 launched some weeks ago an online
consultation on patent systems. Nevertheless, taking into account the subject's
complexity and the difficulties faced in obtaining answers directly from SMEs,
DG MARKT considered that the SME Panel tool would be very useful because it
would support and complete the results already obtained in the online
consultation. [...] The SMEs which are targeted with the questionnaire are:
current patent holders, those who hold a patentable invention but who, for a
particular reason have not sought the patent, SMEs who have been sued by patent
holders for patent infringement, any other SMEs who have had to deal with the
patent system'.

The public consultation was open to any SME without restricting criteria such
as the ones mentioned above. Is it statistically exact to draw a graph where
both sets of data are merged -- as is the case in the table `Sectors of industry
-- Companies and industry associations' replies' on page 6 of the preliminary
findings?

Does the Commission think that it is statistically correct to process different
answers that have been received in two separate consultations carried out under
different preconditions? What was the motivation for drawing a second sample
from `patent oriented' SMEs in addition to the public consultation, and for
subsequently merging these two results?

In Ireland at least one EIC received funds for that purpose (see
http://www.eic.ie/ipm/smepanels.htm): `The Irish EIC Network has been given
funding by the European Commission to run a series of SME Panels throughout
Ireland to collect the views of SMEs on specific areas of EU policy'. What was
the total budget for that project and which budget line was utilised?

I disagree about funding, the commission is funding quite well, but not in the interest of citizens, only a  few selected friends.

by Laurent GUERBY on Wed Sep 6th, 2006 at 04:11:31 PM EST
Thanks for the links. Not for the first time, I think you take some of us for starry-eyed innocents... The important thing is to get together an energy policy statement, and make it known. This (a complaint about how the Commission is still not consulting citizens adequately) is just a necessary step on the road.

I didn't make any serious point about about funding. I ironised along the lines: if you're this bad it must be that they don't give you enough money to do things properly... ;) As I've now added above, I think Wallström should be copied in, it's her department to see that consultations are properly organized.

by afew (afew(a in a circle)eurotrib_dot_com) on Wed Sep 6th, 2006 at 04:43:34 PM EST
[ Parent ]
We're all nice and innocent, aren't we? :)
by Laurent GUERBY on Wed Sep 6th, 2006 at 06:31:54 PM EST
[ Parent ]
Where you mention the language restriction, you might also want to give examples of how the various non-english versions are bad translations of the English and distrot the meaning of the questions and options in important ways.

If this is going to be copied to Wallstrom, and I think it should be, the connection between the quality of the consultation and the public's perception of the EU and its efforts to communicate with the citizens should be emphasised more.

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Wed Sep 6th, 2006 at 04:50:59 PM EST
If we do so, the letter will be considerably longer, but why not? In which case I'll repeat my previous request for people to compare the questionnaire in their language with the English version and give an opinion of the accuracy of translation.

The FFII pages Laurent links to in the above comment suggest individuals who have a problem with their language version of documents (absent or poor quality) should make their own individual complaints. (See Complaint Procedure).

They also sent an Open Letter to Barroso at the same time as the Commissioner in charge of the Patents Consultation (McCreevy) and Wallström.

by afew (afew(a in a circle)eurotrib_dot_com) on Wed Sep 6th, 2006 at 05:15:24 PM EST
[ Parent ]
You find my review of the Hungarian and German versions in the thread where you asked for this.

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Wed Sep 6th, 2006 at 05:43:48 PM EST
[ Parent ]
Yes, thanks, DoDo -- you did two languages. It would be good to have more -- Spanish, Italian, Dutch, Swedish...? I'll add an appeal in the diary.
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:17:55 AM EST
[ Parent ]
I'll do at least Spanish later.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 06:18:04 AM EST
[ Parent ]
Where is this thread you speak of, oh mighty one? If it is in this diary, I didn't see it... I can attempt Dutch, if someone else hasn't yet.

You are into this until your fingertips and I'm really, really lost at what has been going on. I'm only now catching up with what happened on the Biofuels Consultation...

by Nomad on Thu Sep 7th, 2006 at 05:01:30 PM EST
[ Parent ]
It's already in the archive, apparently.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 05:07:26 PM EST
[ Parent ]
This has history? Teaches me to dart off for 6 weeks...
by Nomad on Thu Sep 7th, 2006 at 05:24:16 PM EST
[ Parent ]
If you could look at the Dutch one, that would be great, o moose-tamer.

The Consultation page is here. Open and compare an English version and a Dutch version of the online questionnaire. Tell us what you think of the quality of the Dutch translation. Do the questions and answers mean the same thing, or is it sloppily (possibly ignorantly) done?

by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 01:25:03 AM EST
[ Parent ]
"If we do so, the letter will be considerably longer"

Er... Why wouldn't the letter include a link to a part of ET where all those points could be explained in details (2/3 screen pages) ?

After all that's also the usefulness of web (I do suppose he has a computer ?)...

"What can I do, What can I write, Against the fall of Night". A.E. Housman

by margouillat (hemidactylus(dot)frenatus(at)wanadoo(dot)fr) on Wed Sep 6th, 2006 at 07:28:27 PM EST
[ Parent ]
Because the consensus at the time (and my feeling too) was that the deconstruction was OK for ET, and was useful as a basis for comment and discussion, but was too abrasive for a fairly formal complaint.
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:10:49 AM EST
[ Parent ]
Methinks the text is alright, except for the last paragraph. That could be read by EU types as if it was written by Eurosceptics.

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Wed Sep 6th, 2006 at 05:52:04 PM EST
There could be a reference to other consultations that were better done (e.g. biofuels?)

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Wed Sep 6th, 2006 at 06:02:03 PM EST
[ Parent ]
Agreed, also perhaps something more emotional would be in order (same text, different ending => my words are cheap, replace them with whatever you like).

The European Tribune is an online forum for civic debate, with a strong focus on European issues. We consider 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, we are saddened that the Public Consultation on the Energy Green Paper falls short of living up to its great expectations, and strongly hope that this will not further feed the Eurosceptic image of Brussels policy-making taking place in a world far removed from that of ordinary citizens.

by Alex in Toulouse on Thu Sep 7th, 2006 at 06:42:39 AM EST
[ Parent ]
Something like that. I also suggest to write "European citizens" or "EU citizens" instead of just "citizens".

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Thu Sep 7th, 2006 at 08:30:06 AM EST
[ Parent ]
the Public Consultation on the Energy Green Paper falls short of living up to its great expectations
We could say "the expectations raised by the Commission's communication strategy".

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 09:22:37 AM EST
[ Parent ]
Further: our expectations.

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Thu Sep 7th, 2006 at 09:46:24 AM EST
[ Parent ]
True, but wouldn't we want to imply that more than just us will be disappointed?

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 09:57:53 AM EST
[ Parent ]
My opinion is the way the Commission deals with the public is enough to turn a Europtimist into a Eurosceptic.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 06:45:10 AM EST
[ Parent ]
Almost enough, I hope.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 06:46:24 AM EST
[ Parent ]
Let your rage take control and join the dark side, young Colman.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 06:48:23 AM EST
[ Parent ]
Which side is that? I've lost track.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 06:49:35 AM EST
[ Parent ]
The Commission might be like Palpatine, playing both sides.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 06:50:18 AM EST
[ Parent ]
Ask the free software community people the first time they have to deal with the european "legislative" process. And when they've seen the "constitution" was just making things worse... Bunch of europtimist leftists turned to nonist.
by Laurent GUERBY on Thu Sep 7th, 2006 at 07:07:19 AM EST
[ Parent ]
You just have to look at our own debates around the EU. This is clearly a pro-EU community, but hardly optimistic.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 07:11:04 AM EST
[ Parent ]

This is clearly a pro-EU community

It is? It's favorable to the ideals of Europe as a supra-national community, but it's hardly pro-EU. I feel a bit lonely at times.

In the long run, we're all dead. John Maynard Keynes

by Jerome a Paris (etg@eurotrib.com) on Thu Sep 7th, 2006 at 07:37:56 AM EST
[ Parent ]
Ah no, not this again...

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Thu Sep 7th, 2006 at 08:26:55 AM EST
[ Parent ]
Bunch of europtimist leftists turned to nonist

The free-software crowd?
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 07:12:30 AM EST
[ Parent ]
Sure, but the goal here is to get some hearing without being put into the wrong box by the readers of our letter, not to snark openly among ourselves.

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Thu Sep 7th, 2006 at 08:28:53 AM EST
[ Parent ]
Excellent start. It's coherent, it makes the points we want, and it's well written.

I'd be tempted to go into more detail on the question you've extracted, and discuss each of the choices they offer, to give them an inkling of our substantial objections.

(I'll provide text in a future comment)

In the long run, we're all dead. John Maynard Keynes

by Jerome a Paris (etg@eurotrib.com) on Wed Sep 6th, 2006 at 05:59:00 PM EST
On the basis of my consultation replies, some criticisms from me too:

All: no consideration of demand reduction in the questions or answers. No consideration of social issues (beyond the "reasonably priced" line, which pre-assumes an economic theory).

Question 2: beyond presupposing the goal of a single European grid (not that I say it is undesirable), the answers assume only management duties, no grid planning and construction.

Question 3: apart from again assuming the goal of an energy market, and single market, and that such a market would facilitate investment, it allows only for private or PPP investment, it doesn't give regulation (e.g. ordering companies to invest) as an option, and the question ignores the strong connection to other goals, e.g. the issue of getting investment in desirable fields (say, regenerative energy, or non-import-dependent energy).

Question 8: Why should diversification be a goal unto itself? What should be part of the diversity is more important, and the necessary diversity is a function of what are the main components.

Question 9: a "balancing" of certain goals (environmental protection, competitiveness and security of supply) is pre-assumed.

Question 11: too general: only asks about where to pour the money, not what to do with it, no question about possible policy tools (for example the feed-in-law vs. certificates debate).

Question 13: option "Incorporate climate change, energy efficiency and renewable energy sources into EU external relations" doesn't specify what policy is meant, yet citizens (and politicians and industry people) could be of very different minds regarding pro-active (export of technology as aid) and restrictive (import restrictions etc.) policies.

Question 14: both the desirability and feasibility of diversifying gas supply is pre-assumed, and supply of different kinds of energy are treated as similar.

Questions 16 and 17: beyond narrowness of choices, the questions fail to distinguish between internal and external policy at EU and member state levels.

Question 18: the readers' support for the goals of the Lisbon Process is pre-assumed, and the question makes it appear as if the goal of the energy strategy is merely to support the Lisbon Process, not a separate policy with goals that could differ.

*Lunatic*, n.
One whose delusions are out of fashion.

by DoDo on Wed Sep 6th, 2006 at 06:41:55 PM EST
[ Parent ]
I only focused on the one question that afew used in his letter, as posted below. you make many good points, which should form the core of our own "position paper", but that should be a different document than the one draftged by afew, i think (unless we manage to build up something clean quickly)

In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Wed Sep 6th, 2006 at 07:00:50 PM EST
[ Parent ]
D'oh, I misread your comment (must have taken "they" to mean all the questions).

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Wed Sep 6th, 2006 at 07:09:22 PM EST
[ Parent ]
That's an important point, Jérôme : this is not a position paper and we shouldn't (imo) get into too much discussion of the actual options offered or conspicuously not. (Though I'll come back to that). What I tried to do here was make a reasonably concise complaint about procedure: that the questionnaire is restrictive or manipulative in putting the answers into the questions.

However, it's true that the conspicuous absence of other options is a point that could and no doubt should be made. It's allied to the point I made about the second option in the featured Q.1 -- there is another option there, but it goes against the pre-determined sense of the question, so it goes against logic to choose it.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:27:01 AM EST
[ Parent ]
reinfoced (sic) separation of network operation from production and supply (unbundling)

That question completely excludes the option of re-bundling network operation from production and supply. This may not be the direction things have evolved in recent years, but the option should certainly be offered in a public consultation that purports to be neutral, and Europeans should be allowed to argue for choices different from those of the Commission.

That question can hardly be separated from that of regulating the existence of spare capacity, its size, who provides it, and how it is paid for.

reinforced powers and independence of national regulatory authorities

Again, this presupposes that Europe's energy policy will be based on indirect regulation rather than on national (or other) monopolies which require a different kind of relationship with the State This may be the facts on the ground, but the point of this consultation should not be necessarily to endorse the current policy choices, but to have a debate on the full range of possible solutions. Secondly, as with the question above, it totally excludes the choice of less independence, which is known to be preferred by some - they should be allowed to participate to this consultation as well.

harmonised grid access conditions (European Grid Code)

This question should probably be developped to include a discussion of the mechanisms to build the interconnection capacities that would be required for any harmonised grid code to make any sense. Should such capacities be built? Who should pay for them? What environmental safeguards should be put in place?

Create a European Energy Regulator

This question makes no sense until the goals, means and powers of such regulator are defined. Creating an institution whose role is not defined is pointless at best, and reckless if this is seen as a carte blanche for policies that have not been approved by,  or explained to Europeans to be implemented by a small committee.

Create a body of transmission system operators at the European level

This already exists (link to be provided). This question seems to be an open ended invitation to give it more formal roles and powers, without the content of these activities being discussed. Again, it appears to be a request for carte blanche action behind the scenes.

In the long run, we're all dead. John Maynard Keynes

by Jerome a Paris (etg@eurotrib.com) on Wed Sep 6th, 2006 at 06:58:13 PM EST
Subject to my comment above (difference between our Consultation contribution and this letter of procedural complaint), I think some of these may be used: the paragraph on the European grid, for example.

But let's note that most of the Green Paper itself excludes other options than those the Commission wants to push through, and it's in commenting the GP that many of these points (and DoDo's) should be made.

However, it is a valid procedural point to say that the Consultation mechanism excludes options other than those of the Commission.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 02:05:24 AM EST
[ Parent ]
Where I put (?) it means I didn't know what to put.

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.

I would lose "the definiton of".  I support you all the way, afew.


Don't fight forces, use them R. Buckminster Fuller.

by rg (leopold dot lepster at google mail dot com) on Wed Sep 6th, 2006 at 07:33:24 PM EST
Thanks, rg. I wasn't sure about the entire last paragraph, in fact. Perhaps more light will come from the discussion... Hell there, more light? Mehr licht..?
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:32:24 AM EST
[ Parent ]
Er, hello, not hell... duh...
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:56:26 AM EST
[ Parent ]
Outstanding work.

The only corrections I would propose concern the first paragraph:

Instead of starting off with two full sentence quotes from the Green Paper, I would avoid quoting passages immediately, as the under-secretary of the under-secretary of the commissioner, who'll first read this, may end up thinking it's a line by line analysis of their text, which will be boring to read, and give it little attention.

I would say to you starry-eyed innocents that the goals of this letter are, in this very order:

  1. captivate attention
  2. once attention obtained, make our points heard

So in the aim of achieving 1), I think you should modify paragraph 1 along the lines of:

///////

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.

It also states that the Public Consultation should open up a wide-ranging public debate (p.4) and a Community-wide debate (p.19).

However etc etc

by Alex in Toulouse on Thu Sep 7th, 2006 at 06:36:53 AM EST
Good job! Comments below.

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.

Piebalgs is heading a Directorate General, not the Commission. Although, technically, the Director General might also be said to head the DG, in this case especially as there are two Commissioners for one DG (energy and transport). It's better to say "Your Directorate General" or something of the kind. Although I don't know if the DG Energy & Transport is running this Public Consultation...

Anyway, it's a nitpick, but you need to re-phrase this.

The point about replying in English I can sort of understand. The normal Commission staff isn't made up out of translators. Asking people who can write in English to do so keeps costs down a little. Still, the Commission is supposed to have three working languages (also French and German). So it's strange why these are not included. I imagine the French and German governments will also be pissed off about this if it becomes routine.

I agree with DoDo and Alex in Toulouse that the last paragraph comes off a bit Eurosceptic. Here's another attempt at rephrasing it:

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.
by nanne (zwaerdenmaecker@gmail.com) on Thu Sep 7th, 2006 at 10:58:40 AM EST
Thanks for the input. You're right, Piebalg's one of the two heads of DG-TREN -- which is in fact running the consultation. However, his title is "Energy Commissioner". I'll change the first sentence, though, as you suggest.

The language question: of course I understand how it may keep costs down. The point is that that is not EU policy on languages, or on communication/consultation. The EC (Report on Governance, WP on Communication) is supposed to be improving its offer on communication, reaching out more and listening more. It cannot follow a (supposedly) more ambitious policy, and limit the languages used "to save money". (That's a word to Wallström rather more than to Piebalgs.) (My personal belief is that, if it's done to save money at all, it's done to avoid spending on a procedure that irks the Commissioner and his staff, and that they have no intention of carrying out other than minimally, or even sub-minimally).

This is not a minor point: the gridlock on the "Constitution" text shows that the EU has lost touch with citizens. The Energy Consultation is an example of how the Commission is not yet ready to recognize the problem.

The final paragraph: I agree with the points that have been raised. As it stands, it is open to misinterpretation. Thanks for your suggestions.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 11:31:07 AM EST
[ Parent ]
Is there a current best version of the letter? I'm just now getting around to looking at it properly!
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 11:33:41 AM EST
[ Parent ]
As an experiment, I've set up the following writeboard, which is a simple on-line collaborative editor, it's got a current version of the letter.

  DG-TREN Letter
  http://123.writeboard.com/52ba421d56bc6d403/login
  Password: wiffle

by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 11:47:19 AM EST
[ Parent ]
What's wrong with wiki?

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 11:55:18 AM EST
[ Parent ]
Other than we're not really in the habit of using it...

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 11:55:49 AM EST
[ Parent ]
This seems lighter-weight. It seems worth a quick experiment.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:11:15 PM EST
[ Parent ]
It allows quick easy-to-see comparison of different drafts, which is good.
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 12:17:26 PM EST
[ Parent ]
Great! That's a useful online tool, and your redrafting tightens up the whole text.
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 12:09:04 PM EST
[ Parent ]
It looks useful for this sort of quick group edit: I just find the wikis a bit cumbersome.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:10:17 PM EST
[ Parent ]
Does Scoop support <object> or <iframe>? That would allow the current draft to be embedded in a comment or diary.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 12:19:22 PM EST
[ Parent ]
It could, though I'd have to think about the implications of that. However, it wouldn't help in this case because it's password protected.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:20:45 PM EST
[ Parent ]
Embedding youtube videos in diaries would be cool.

Is the allowed HTML set independently for comments and diaries?

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 12:25:33 PM EST
[ Parent ]
Maybe I could create a YouTube macro that would do the job.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:26:58 PM EST
[ Parent ]
How about the possibility of embedding an ETWiki page?

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 12:29:32 PM EST
[ Parent ]
Had a quick look, this is quite nice for writing collective papers. I tried a minor edit (moved "p.19" forward by one word, to put it before "debate", and put that in bold to show what I did).

It would be an even greater tool if edits could be voted on, could be closed/open (as +/- expansion zones) ...

by Alex in Toulouse on Thu Sep 7th, 2006 at 12:31:05 PM EST
[ Parent ]
I don't think it'll work very well past quiet small documents but it looks good for them.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:34:36 PM EST
[ Parent ]
No. Because, though there are points here and there (like the last paragraph) that could be redrafted now, there have been more substantial suggestions -- such as going through more questions and pointing out how manipulative they are, how they exclude options other than the Commission's, etc. Plus also a fuller development suggested on languages, by pointing out that the questionnaire is shoddily translated into other languages than English. This I need some more confirmation on from other-language speakers.

Since the resulting redraft is likely to be considerably longer than Draft One, I'm waiting to see clear on these points.

Take it I'll change "your Commission" in line 1 (as nanne suggests), and will use various redrafts proposed here to rewrite the final paragraph.

What do you think? Would you systematically pull apart  the entire questionnaire, question by question?

How would you handle the language question?

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 11:55:15 AM EST
[ Parent ]
You could systematically pull apart the entire questionnaire, and attach a cover letter to it. Or think of the pulling-apart as an appendix to the letter.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 11:57:17 AM EST
[ Parent ]
See draft version below, incorporating some of the changes from above and my own edits. You can see diffs on the writeboard referenced above.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:01:01 PM EST
[ Parent ]

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:

x

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

by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 11:59:53 AM EST
Actually, the item we are flagging (Reinforced powers for national regulatory authorities) is compatible with their objectives - the idea is to make governments powerless in the energy sector by making an independent entity in charge of the regulation in each country (and then of course make these independent entities coordinate under the aegis of the Commission).

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

by Jerome a Paris (etg@eurotrib.com) on Thu Sep 7th, 2006 at 12:21:40 PM EST
[ Parent ]
I'm not sure I understand the last statement:
Then, if we can draft it, we add an annex with substance on the various questions
Are we intending to send our response with this letter or separately and do we intend spending a lot of time criticising an on-line consultation we're not going to use?
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:24:07 PM EST
[ Parent ]
I think a softer version of Afew's earlier diary would suffice, it was complete enough. Plus there's the criticism of the various translations.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 12:26:35 PM EST
[ Parent ]
Meaning "independence" is to be read as in "independence of the ECB", ie governments can't meddle?

If you're right then obviously we must change this.

Please look at the queries below.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 12:28:41 PM EST
[ Parent ]
Yes, exactly, independence of the ECB.

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

by Jerome a Paris (etg@eurotrib.com) on Thu Sep 7th, 2006 at 12:45:10 PM EST
[ Parent ]
I have no pits to nick.

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.
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 12:22:30 PM EST
[ Parent ]
* whether to do (appended or not) a full take-down of the questionnaire;
No, we have better things to do with our time.
whether to add a paragraph pointing out that alternative policy options are largely excluded from the questionnaire;
Yup.
pointing out that translation work on the questionnaire seems poor (with possibly appended examples);
Yup.
what to think of "minimum standards" on what kind of org can participate as an org in consultations.
Not exactly sure what you meant here?
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:26:02 PM EST
[ Parent ]
There's an update at the foot of the diary.
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 12:30:10 PM EST
[ Parent ]
I think the relevant paragraph comes under "other measures" for the minimum standards thing.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:32:09 PM EST
[ Parent ]
Agreed.

  • no detailed deconstruction
  • yes to one paragraph on excluded options (maybe replacing the current one on the question) using some of the materail I provided above
  • yes t a sentence on the translation work, with appended examples)
  • yes to a paragraph on orgs - after the description of ET, to wish that we be included as an org.


In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Thu Sep 7th, 2006 at 12:50:18 PM EST
[ Parent ]
No to paragraph on orgs. Side issue that's not relevant to this letter. We just assume that we're an organisation rather than an individual.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:54:52 PM EST
[ Parent ]
It is relevant if we send it in the name of European Tribune.

If we send multiple copies as individuals, that's different.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 12:59:00 PM EST
[ Parent ]
We assume we are an org, but explain who we are.

In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Thu Sep 7th, 2006 at 01:04:40 PM EST
[ Parent ]
Precisely.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 01:05:06 PM EST
[ Parent ]
Presumably as in
The European Tribune is an online forum for civic debate, with a strong focus on European issues.
Otherwise, who are we?

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 01:09:42 PM EST
[ Parent ]
Then we append what they call a "special information sheet"?

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).

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:15:22 PM EST
[ Parent ]
from as many countries as possible

May need to list both nationality and residence.

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 01:16:28 PM EST
[ Parent ]
Necessary and useful, because we can provide a range of nationalities and countries of residence in the EU. Makes for representativity.
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:42:06 PM EST
[ Parent ]
In fact, the use of an image isn't necessary in this letter, and if my reading of the option is mistaken, we can pull that.

"Wish" to be included as an org? We ask to be considered as an org?

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 12:55:44 PM EST
[ Parent ]
We just assume we will be considered as an organisation?
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:57:08 PM EST
[ Parent ]
We were considered as an organisation by the DG Transport, so we have a precedent that not worrying about it is the right thing to do...

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 12:58:16 PM EST
[ Parent ]
This is a substantial complaint we're making (unlike Biofuels) and we're sending it to the top.

I wouldn't like to get a response from Piebalg's office saying "Nice try, but we don't have to listen to you."

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:01:13 PM EST
[ Parent ]
Then sign it with multiple names on behalf of European Tribune. It's not a response to a consultation in any case, it's a response to how the consultation is being run. If you raise the issue directly you run a high risk that we will not be considered an organisation.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 01:04:28 PM EST
[ Parent ]
My intention was to raise the issue here, not in the letter.

Multiple signatures is probably the way to go, referencing ET all the same, of course.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 01:17:49 PM EST
[ Parent ]
What about a reference praising the biofuels consultation in comparison?

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Thu Sep 7th, 2006 at 05:36:45 PM EST
[ Parent ]
Good idea!
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 05:50:21 PM EST
[ Parent ]
On this basis, the Biofuels Consultation may have been generous in classifying us as an NGO. Any thoughts?
I think this whole site makes our contributions open and accountable. Even our deliberations and the various drafts of our contribution are in the open...

Otherwise... Time to register as a non-profit organisation?

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 12:34:26 PM EST

Time to register as a non-profit organisation?

Are you all waiting for me to do all these things? I can't and I won't. But I'll support it.


In the long run, we're all dead. John Maynard Keynes

by Jerome a Paris (etg@eurotrib.com) on Thu Sep 7th, 2006 at 12:47:00 PM EST
[ Parent ]
Er... who other than Booman or you can register ET as a nonprofit organisation? You do own the trademark to it, don't you?

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Sep 7th, 2006 at 12:49:23 PM EST
[ Parent ]
I don't think it's necessary until someone says it is. In fact, it's just not necessary.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:49:51 PM EST
[ Parent ]
That way lies diversion of resources we don't have. Let's not go there.
by Colman (colman at eurotrib.com) on Thu Sep 7th, 2006 at 12:55:49 PM EST
[ Parent ]
I've done some redrafting of the letter, see writeboard (PW wiffle). You'll see (...?) at the end of a new paragraph on options excluded from the poll. I know Jérôme and DoDo have already chipped in on this, but it would be good to have one or two clear examples of questions that blatantly exclude one or more policy options. Can anyone offer what they think is the best example of this? (Don't hesitate to edit in writeboard!)

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


by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 06:17:39 AM EST
I added a single sentence at the end of the before-last paragraph.

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Fri Sep 8th, 2006 at 12:45:54 PM EST
[ Parent ]
What do you think of my request for the paragraph on excluded options? You mentioned "social issues" in your comment above. Could you expand on that?

Is there a good example you can see in the questionnaire of excluded options, speaking technically?

by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 12:59:15 PM EST
[ Parent ]

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. (....?)

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

by Jerome a Paris (etg@eurotrib.com) on Fri Sep 8th, 2006 at 01:31:44 PM EST
[ Parent ]
Heh, while I would add to it...

...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.


*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Fri Sep 8th, 2006 at 02:48:46 PM EST
[ Parent ]
You mentioned "social issues" in your comment above. Could you expand on that?

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.

by DoDo on Fri Sep 8th, 2006 at 02:41:34 PM EST
[ Parent ]
Well... hard choice to pick a single one.

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.

by DoDo on Fri Sep 8th, 2006 at 03:04:42 PM EST
[ Parent ]
Thanks to both you and Jérôme for these suggestions.
by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 03:25:27 PM EST
[ Parent ]
Here's what I've done with it:

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.

by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 04:06:27 PM EST
[ Parent ]

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 Jerome a Paris (etg@eurotrib.com) on Fri Sep 8th, 2006 at 04:30:29 PM EST
[ Parent ]
That's because you're the centralised man, and I'm the feed-in-law advocate :-)

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.

by DoDo on Fri Sep 8th, 2006 at 04:40:24 PM EST
[ Parent ]
Speaking of selection, I think a specific sentence relating to public funding of the sector should be mentioned. That's somewhat linked to your selection comment as well as to my centralisation one.

In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Fri Sep 8th, 2006 at 04:51:00 PM EST
[ Parent ]
Also linked to the single grid question.
by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 04:53:16 PM EST
[ Parent ]
OK, DoDo will no doubt explain, since I lifted it from him... ;)
by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 04:41:01 PM EST
[ Parent ]

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.


In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Fri Sep 8th, 2006 at 05:11:21 PM EST
[ Parent ]
Merged and edited for idiom.
by Colman (colman at eurotrib.com) on Fri Sep 8th, 2006 at 05:30:44 PM EST
[ Parent ]
Fine. I made a minor edit.

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.

by afew (afew(a in a circle)eurotrib_dot_com) on Sat Sep 9th, 2006 at 01:13:57 AM EST
[ Parent ]
Are we nearly done with this? We really need to move on to a substantial response to the green paper!
by Colman (colman at eurotrib.com) on Fri Sep 8th, 2006 at 12:03:20 PM EST
We can always dump it.
by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 12:30:25 PM EST
[ Parent ]
Dump it? Why? I didn't mean it quite like that, just it's an (important) side issue we're spending  a lot of time on.

I suggest that we pick a cut-off date, call whatever we have then "done" and send it off.

by Colman (colman at eurotrib.com) on Fri Sep 8th, 2006 at 12:36:44 PM EST
[ Parent ]
Consensus was we should make a point on translation with appended examples. I'll do it if I get enough stuff. Right now I have French (me), German and Hungarian (DoDo). I'm hoping Nomad will do Dutch and Migeru Spanish.

Next I asked for input on a good example of how the questionnaire excludes important policy options, from someone more clued-up than me.

I don't see this as a side issue. It's just as important to make a point about democracy in the EU as it is to talk about energy policy, and ET has everything to gain by moving forward on this ground.

by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 12:45:57 PM EST
[ Parent ]
Fine. Forget I said anything.
by Colman (colman at eurotrib.com) on Fri Sep 8th, 2006 at 12:51:02 PM EST
[ Parent ]
As a cut-off date, I suggest Monday. There's no point in sending it before, anyway, with the weekend having already begun.
by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 12:54:18 PM EST
[ Parent ]
Absolutely. I've just done some edits.
by Colman (colman at eurotrib.com) on Fri Sep 8th, 2006 at 12:57:37 PM EST
[ Parent ]
Thanks. All good.
by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 01:02:34 PM EST
[ Parent ]
Will be at it this evening (Saturday). Right now, the weather is too sunny here, and I'm already online for too long. You woudn't want me to lose my carefully built up godly tan too soon, would you?
by Nomad on Sat Sep 9th, 2006 at 05:54:58 AM EST
[ Parent ]
Good Lord no. I think you mean godlike? (Godly means holy, saintly -- but I'm sure that's true of you too...) Perhaps, during the weeks of wandering in the northern forests, you were picked out by the Norse gods to channel the ethos of one of them? Thor? Baldr?
by afew (afew(a in a circle)eurotrib_dot_com) on Sat Sep 9th, 2006 at 07:27:34 AM EST
[ Parent ]
Loki.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Sat Sep 9th, 2006 at 07:31:59 AM EST
[ Parent ]
I was polite enough not to suggest that...
by afew (afew(a in a circle)eurotrib_dot_com) on Sat Sep 9th, 2006 at 07:45:21 AM EST
[ Parent ]
Well, you know me.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Sat Sep 9th, 2006 at 07:48:19 AM EST
[ Parent ]
Charming. I would that earlier attribute to Sven...
by Nomad on Sun Sep 10th, 2006 at 06:35:58 AM EST
[ Parent ]


Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Sun Sep 10th, 2006 at 06:52:31 AM EST
[ Parent ]
Feeling filthy again. No wonder this became an issue here. What a horrid, leading questionnaire. If I had made one like that during my editor years, it would've been shot down by the chiefs.

There are a few dodgy translation which don't sit comfortable - generally concerning translations of "market", "market-oriented" and "stakeholder". But that's 1) a field I'm not spectacularly knowledgeable about in the English language and 2) these are terms which are quite difficult to translate succinctly in Dutch anyway.

Aside from those minor translation issues and of course the ridiculous misleading options, the Dutch translation from the English is - as far as I can judge it - all right. No big fouls that I can see. The Dutch version is a bit wordy and pompous at places, but that way it does bring justice to the phrasing and meaning of the English original. It's however, obviously, a translation. In case this was written originally in Dutch the wording would likely have been more accessible.

Which brings me to the accessibility of this questionnaire. Aside the obstruction in language, and a preference in English, some of the options offered in the questionnaire are part of a terminology that may not be understandable for everyone. Using myself as an example here: I've zero clue on what is meant with the options offered in question 2:

Security Rules
Balancing Rules
Congestation Management
Etc

Nice - but what does it mean for the common Nomad?? These links are not clickable to a definition, no examples are given. All I get as background information is.... the Green Paper website. That surely helps.

Do I need to have a degree in economics before I can participate in the questionnaire? I think not.

Lastly, afew, my round of compliments (yet again) for such a nice piece of work. Although even our limited effort may not be result in turning the GP consultation completely mood, by sending it to the top I hope to deliver a strong signal that all is not well in Brussels with communicating to EU citizens who demand a transparant, accessible governance in Europe. You've my name on the list, if you need it. Also, do we already have the official European Tribune e-mail address as kcurie suggested in your other diary?

by Nomad on Sun Sep 10th, 2006 at 07:14:12 AM EST
[ Parent ]
The Spanish version is ok. It avoids false friends and literal translations and doesn't read clumsy at all.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Sun Sep 10th, 2006 at 07:26:45 AM EST
[ Parent ]
OK, thanks to both you and Nomad.

I don't think, on this basis, that it's worth taking the language aspect any further. So we can go with the text as it stands, unless there are any new suggestions.

by afew (afew(a in a circle)eurotrib_dot_com) on Sun Sep 10th, 2006 at 09:26:01 AM EST
[ Parent ]
Excellent. Include my name of course. If you need titles, we could all be "Contributing Editors, European Tribune"

If you need an Europeean Tribune email, use the one at the bottom of the site: etg@eurotrib.com. It goes to me (and, if Colman has exercised his option to do so, which I think he did not, to him as well).

In the long run, we're all dead. John Maynard Keynes

by Jerome a Paris (etg@eurotrib.com) on Sun Sep 10th, 2006 at 03:17:08 PM EST
[ Parent ]
Afew should give an e-mail address to collect endorsements (Name, country of residence, country of nationality) or confirmed that his published e-mail address should be used.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Sun Sep 10th, 2006 at 03:22:15 PM EST
[ Parent ]
I'll put up a diary with the final draft and a call for signatories. Real names can be handled by my e-mail account, afew at europe dot com. I think it would be good to use the ET mail account for the actual sending. Individuals might, however, wish to communicate the letter to their MEP.

I also received, this evening (!) a reply from the Biofuels Consultation to our mail thanking them for running a proper consultation. I'll post it tomorrow with the final draft.

by afew (afew(a in a circle)eurotrib_dot_com) on Sun Sep 10th, 2006 at 03:38:55 PM EST
[ Parent ]
In other words, I don't find your comment helpful.

To draft an open letter of complaint to two commissioners seems to me to be a useful thing to do, and one which can increase our "visibility".

The drafting of the response to the GP can start without this being finished. Who's going to start it off?

by afew (afew(a in a circle)eurotrib_dot_com) on Fri Sep 8th, 2006 at 12:35:43 PM EST
[ Parent ]
is a revealing example of how distributed editing works and doesn't work.

Converting ET discussion into action is highly commendable, and the enthusiastic PNing of the text is clearly vital for what may be a public document, or at least one that talks to these bureaucrats in terms that they accept and understand.

The part that doesn't work so well, as pointed out, is that our tools for group editing are cumbersome and time consuming. Finding a better solution is imperative. ETWiki and Colman's widget are two possibilities: what other suggestions?

And a small detail: would it help to have available a list of real ET names and addresses with which to sign documents? I presume the gnomes already have access to these. For any document, before it is forwarded out into the big wide world, there would be an individual opt-in to include your real name as co-signatory. These real names need not appear in drafts of any document posted here - but added before dispatch.

You can't be me, I'm taken

by Sven Triloqvist on Sat Sep 9th, 2006 at 04:58:06 AM EST
Sorry, Sven, I thought I'd aleady replied to this, but I must have buggered summat up somewhere.

An integrated collaborative authoring tool would be nice to have. Writeboard is quite handy, though, and saves us from having to post full alternative drafts in comments here.

When you open an account here, you are not asked your name and bricks address. Neither am I sure everyone would be eager to have these data in a list on the site server. Before sending this letter, we'll call for signatories -- since the consensus at the moment seems to be multiple signatures from individual EU citizens who are also ET collaborators. I'm not sure how we'll then manage the real names (i.e. show them here or not; that will depend on individual wishes, I should think); addresses may be kept to country of residence.

by afew (afew(a in a circle)eurotrib_dot_com) on Sun Sep 10th, 2006 at 09:31:30 AM EST
[ Parent ]


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