Wednesday, 6 November 2013

Submissions on carbon tax now being published

Update 14 November -  Submissions on carbon tax now being published

Classified as: reflective journal - advocacy

I received an email from a public servant apologising for the delay in responding to my queries yesterday. The submissions are being progressively posted here and hopefully will all (including mine) be up later today.

Just to make it clear, I am not trying to blame public servants for this failure of process. No doubt they have been doing their best. Partly I imagine the problems would have arisen because it's been a very rushed process.

I've posted before about the limitations of Tony Abbott's so-called 'mandate' to remove the carbon price and associated mechanisms. There's also an article on ABC fact check about this.  In one way it's obvious - there's no legal or enforceable mandate - but it also points to the need for informed debate.

Now that the submissions are finally going up, perhaps they will help with that debate.  Melissa Sweet of Croakey expressed concern on twitter that there were few from public health. It is concerning but perhaps there may be more today.

From a human perspective, the debate about climate change is all about health ultimately - the health and wellbeing of current and future generations. But looking beyond just our own human needs (as far as that's possible*) it's also about the health and survival of our beautiful world, and other species.

So let the debate roll on! There is a National Day of Climate Action this Sunday 17 November - hope to see you there. Check the link for details in your city.

*(I understand that there is a philosophical question whether, as beings embodied as  'human', we can ever see anything from other than a human perspective, but won't get into that here.) 

Update 12 November 2013 - "Why call for 'public comment' and then keep it secret?"

The submissions on the carbon tax repeal have still not been published and the bill is due to debated tomorrow (Wednesday 13 November).

Why call for public comment and then keep it secret? 

I have submitted in many similar processes and  I don't recall anything like this ever happening.

Normally the process is that submissions are published on the website as they are received. I have rung the information line on the website to ask what was happening about the submissions and was told that they can't give me any information. So I asked if I could speak to one of the public servants handling the submissions and was told that they weren't answering phone enquiries, but that I could email them.

So I emailed my enquiry, and - as happened when I emailed my submission - there was no reply.

So I rang the Environment Minister's office and was told they couldn't say anything because the process was being handled by the Department. When I asked why the Department wasn't publishing the submissions, the staff member I spoke to suggested the public servants might be too busy or over-whelmed.

I've been a public servant and I would say that's unlikely. My guess is there's a block somewhere - for example the public servants may have been told they can't publish the submissions until the Minister has signed off on the process, and the Minister is not signing. That way, no-one's forbidden to do anything, they just don't get permission.

Or maybe the senior public servants are second guessing the Minister and deciding that he doesn't want the submissions published, although I think that's more unlikely. Either way, there's a block happening and we the public aren't allowed to see the submissions, even though the legislation is about to be debated.

I don't know if Opposition MPs have been allowed to see the submissions, but I doubt it. Not seeing the submissions limits their ability to represent people's views in the debate also.

Maybe the government is banking on people being tired of politics and just not caring, but to me this process shows a lack of accountability and a disregard for democratic process.

More  earlier post and a copy of my short  submission is below. You can also read some longer and thoughtful public health responses to the proposed legislation at Croakey.


... climate change is a major public health issue that potentially threatens the health and wellbeing of current and future generations of Australians. The government has a responsibility to treat it seriously as such, rather than as an adversarial political ‘winner take all’ issue.

So I put in a submission to Repealing the Carbon Tax - Call for Public Comment

Excuse me quoting myself, but the comment above from the end of my submission probably sums up my key line of  thought (after I'd corrected a small typo in the original!).

A copy of the full submission is below. It's quite short because I didn't have much time to do it. I have to admit I also wondered if it was worth doing, given that the government appears intent on its course of action - but eventually decided I should at least try.

Submissions closed on Monday, but so far none have been put on the website, so I don't know how many were made or what they said. I haven't even yet received an acknowledgement for mine.

Federal parliament sits next week, and repealing the "carbon tax" legislation is meant to be one of the first pieces of business. The government won't have much time to look at the submissions, and the public will have even less, since they are not even up on the website yet.

This does make me a bit cynical about whether the whole thing is a token exercise, and whether Mr Abbott really cares at all about what we think.

Copy of my submission:

Submission to the Carbon Tax Repeal Consultation,
Carbon Tax Repeal Taskforce
Department of the Environment
GPO Box 787 Canberra ACT 2601

Valerie Kay,
PhD candidate,
School of Public Health and Preventative Medicine, Monash University

Please note that the views expressed in this submission are my own and do not purport to represent the views of Monash University or the School of Public Health and Preventative Medicine

Thank you for providing an opportunity to make a submission on the carbon tax repeal legislation. Please note that the “carbon tax” should be more properly called a “carbon price”.
This submission addresses broad technical issues with the legislation in particular:
The bills do not specify how Australia intends to meet its obligations under the United Nations Framework Convention on Climate Change (the Convention),although the government has stated that it intends to meet those obligations
The measures by which Australia intends to meet its obligations (which presumably are the proposed “Direct Action”) have not been presented to the Australian public in a form which would enable a reasoned assessment or endorsement
The bills have been presented in a way which ismisleading, in particular through the use of the words “carbon tax”.
Research by Crosby Textor (please see end of this submission for more information on sources) for the Liberal National party coalition (LNP) following the recent federal election found that very few voters spontaneously nominated the carbon price as a reason for voting for the LNP. A significant number of voters only identified the so-called “carbon tax” when prompted, and as part of a general concern over cost of living.
In fact, the voters for whom cost of living increases would normally be a major concern – low income earners – weregenerally over-compensated for cost of living increases related to the carbon price under the previous government’s legislation.  
It appears possible therefore that vulnerable voters may have been misled about the carbon price legislation – they may have believed that it was increasing their costs of living when in fact it was reducing them.
The government has not presented the Australian people with clear information showing the current and future impact of the carbon price and associated mechanisms on Australia’s carbon emissions.
There are a number of speculative figures being circulated but as far as I am aware there is no clear summary of current and likely future impacts of the carbon price and associated mechanisms, such as the Clean Energy Finance Corporation,and its investment in alternative energy.
There is certainly some evidence that emissions from the electricity sector may be declining but there has been no clear analysis available to the public of how much of this is attributable to the carbon price and associated mechanisms, nor what is likely to happen under different future scenarios.
Experts on climate change and health, including Australia’s recognised authority, Professor Tony McMichael, and his colleagues at ANU, and international experts as summarised in The Lancet (14 May 2009) have drawn attention to the risks of climate change for population health in Australia.
The government’s stated intention to meet its obligations under the Convention shows that the government accepts that there is potential for profound risks to human health and wellbeing through climate change.
In democratic societies it is generally assumed that governments have a responsibility to protect the health and wellbeing of the people. A so-called ‘mandate’ achieved by winning a majority of the popular vote cannot be understood as exempting a government from this responsibility.
In these circumstances, where:
The government has not explained how it will meet its obligations under the Convention in the absence of a carbon price and the associated mechanisms
A significant number of voters potentially may have been misinformed about the carbon price and its impacts onthe cost of living
There has been no clear public information on the current and likely future impact of the carbon price and associated mechanisms on Australia’s carbon emissions
It can be argued that the government is defaulting on its responsibilities to:
properly inform the Australian Parliament and the Australian population on the likely outcomes of its proposed legislation and
protect the current and future health and wellbeing of the Australian population.
In these circumstances I urge the government to reconsider the proposed legislation.
Further I urge the government to reconsider specifically its proposal to abolish the Climate Change Authority and bring its work under the direct responsibility of the Minister. Climate change has already been overly politicised. To remove the independent authority under these circumstances simply risks politicising it even further, and is an unconscionable decision.
In summary, climate change is a major public health issues that potentially threatens the health and wellbeing of current and future generations of Australians. The government has a responsibility to treat it seriously as such, rather than as an adversarial political ‘winner take all’ issue.
As part of my PhD studies I am maintaining a blog. Further information about the references and key sources for this submission may be found there, in particular at the following pages:
Election reflections: has Tony Abbott really got a mandate on the carbon price? Where to for climate and health?
@WePublicHealth - LNP fails us all on climate and health

I am happy to provide any further information on this submission. Please feel free to contact me on the details provided on the submission cover page.



Anonymous said...

They probably received 100s of submissions, and have to process them all while organising the repeal legislation at the same time. Perhaps you should just be patient instead of assuming bad faith?

Val Kay said...

Because as I said I've participated in similar processes before and I've never seen one conducted like this. Also as I pointed out, submissions are usually published in the order received - it's not necessary to process them all before publishing any.

Val Kay said...

The key point I should make however is that I'm not trying to blame the public servants - the responsibility for poor process lies with the government.

Clearly it's been very rushed, as you (anonymous) allude to in your comment above, which is the responsibility of the government. Possibly not enough PS resources were dedicated to it also, but I don't know about that.