Contributing to government submission processes can be a valuable way for individuals to have a say on issues they care about. This article outlines some of the steps you can take to make your submissions powerful.
Robyn Gulliver has been engaged with government submission processes on a wide range of topics at local, State and Federal levels. She has managed the submission process on behalf of government and analysed submissions from individuals and other stakeholders as well as writing her own submissions on issues she feels passionate and cares about. Her experience over the years has led to observations and insights about what the common characteristics of powerful submissions are.
While submission processes and legal ramifications of comments made in submissions can vary at different governance levels and locations, these tips are based on experience of commonalities across them all. Please note these tips are particularly focused on submissions by individuals.
How do submissions work?
Public input into plans, policies, inquiries and other legal processes or documents are called ‘submissions’, usually managed through what is called a public consultation process. Not all policies and plans will be opened up for public submissions. When they are invited, submissions offer the public, public interest groups and other stakeholders such as businesses or associations the chance to share their concerns, knowledge and recommendations on the issue at hand.
Submissions are usually written and can be provided in any format or style. Some submissions will be made publicly available. Submissions benefit both the public and decision-makers. They provide an evidence base for public interest organisations, policy makers and others to use in advocating for their cause, amending plans or conducting inquiries.
What happens after submissions are received?
Once the submission period closes, all submissions are compiled ready for analysis. This analysis is undertaken generally either by government staff or consultants.
The submission analysis process differs according to the topic, government entity and level of public interest surrounding the topic. Where few submissions are received, comments can be directly incorporated into the relevant documents directly by staff.
Where many submissions are received, a more detailed analysis is required. In this case, the process usually follows these steps:
- Reading of all submissions individually (excluding bulk campaign submissions – these may be reviewed via automated text reading software)
- Compilation of key ‘themes’; the most common concerns and actionable statements made across all submissions
- Separating out themes according to general issues (e.g., climate change) and specific issues related to the plan or policy under submission
- Drafting a report summarising key general themes and listing actionable statements related to specific issues in the plan or policy
- Provision of other data (such as spreadsheets of responses, all copies of the submissions etc) to the relevant groups/powerholders
Following this process, decision-makers will then amend the particular plan or policy according to the submissions and other factors. The updated plan or policy will then be released.
What sort of submissions can individuals write?
There are three broad types of submissions that individuals can write.
- A letter or email entirely written by the individual
- A ‘campaign’ submission, drafted by an organisation which is then uploaded onto a webpage where individuals can either simply ‘sign’ (by typing in their email address, so example), or personalise by adding in extra information into the template text
- A survey response, where the questions are provided by the government department inviting submissions and individuals are able to give direct responses
The type of submission format you choose will not matter in most submission analysis processes. All submissions will be read, either manually or through automated software for large numbers of campaign submissions.
Personalising a campaign submission by adding extra statements or changing words in the template text makes it more likely that the submission will be read. For example, when there are thousands of campaign submissions software is often used to detect which submissions have variations (usually around 5-25% of the total), each of which are then read.
What information is most powerful in a submission from an individual?
While there are many inclusions that can improve the likelihood of your submission influencing decision-makers, one inclusion stands out above all:
Include clearly stated, concise, actionable recommendations that are directly relevant to the submission topic.
In my experience, many submissions – particularly those written by individuals – focus on what they don’t like about the particular plan or topic of concern. They often include many statements about the submitter’s concerns, fears or worries. However, these statements will be very unlikely to influence decision makers. This is because as much as it is meaningful to tell your story or share your fears in a submission, in all likelihood powerholders will not read any of these types of comments.
Instead, analysts will sort through all comments made and focus specifically on those that are actionable: i.e., statements that clearly state how the plan needs to be changed. Stories and fears, while valid and meaningful in other contexts, are not actionable in the submission context.
As a result, your submission points will be more likely to be conveyed to the powerholder if they are written as actionable recommendations.
What does an actionable recommendation look like?
It might be helpful to imagine that you are reading your submission to a friend who has no background in the particular issue and then ask yourself: will they understand exactly what it is that I want them to do? If not, how can I change it into an actionable recommendation?
Examples of actionable recommendations
The following table provides a list of examples I have seen in previous submissions (note topics have been altered for privacy), and suggestions for converting the original statements into actionable recommendations:
|Original statement in submission||Problem for the individual analysing submissions||Example of actionable recommendation|
|Make the right choice!||What exactly is the right choice?||Add in the plan a legislated commitment to increase funding for the NDIS by 15% by 2025.|
|I have planted trees for 20 years and seen how our species are declining.||What is actionable about this statement?||Add in the plan a legislated commitment to plant 500,000 trees in urban areas across Australia by 2030|
|I was shocked to see how much carbon emissions Australia is responsible for.||What is actionable about this statement?||Add in the plan the legislated commitment to reduce carbon emissions by 50% by 2030|
|I am very concerned to see that the government is recommending scrapping planning rules stopping high rises.||What is actionable about this statement?||Commit to and legislate rules restricting high rises over 2 stories in areas designed as urban land.|
|Don’t take away our chance to reduce waste.||What is actionable about this statement?||Keep and increase funding for the existing plans which regulate how we manage waste|
|Please try to make some good decisions for people with disabilities instead of ignoring them.||What are the good decisions you would like to see?||Develop best practice guidelines for detailed consultation with people with disability and their advocates.|
|What bird would want to be on this list of soon to go extinct?||What is actionable about this statement?||Create, regulate, fund and implement a plan that will protect this bird and the habitat on which it depends.|
|Voters are watching and waiting for you to take action.||What specific actions do you want to see?||Raise the age of criminal responsibility from 10 to 12 years old by the end of 2022|
|Climate change is threatening our grandchildren’s future.||What is actionable about this statement?||Include climate change as the primary threat to be addressed via regulatory mechanisms in the plan.|
|Minister, please do the job you are paid to do.||What component of the Minister’s areas of responsibility do you want actioned?||Vote against the legislation proposing the expansion of the cashless welfare card bill.|
|The Independent Review of The Plan showed how we need to make greater efforts||What specific areas should be actioned from the Review?||Implement the recommendations of the Independent Review of The Plan by 2025 and commit to fully funding every single recommendation.|
|Shop owners will not be able to access their shops if the existing road is closed off like The Plan shows||What should be in the plan to ensure that shop owners will still be able to access their shops?||Amend the Plan so that shop owners retain permanent access to their shops via the existing road.|
|Our country is an embarrassment to the world||What is actionable about this statement?||Include a legislated commitment to halt all coal exports by 2030.|
|Professor X wrote in paper Y that funding for the NDIS is the lowest in the Z international grouping.||What does this research mean for this plan?||Incorporate Professor X’s research into the policy document recommending increased funding to the top 10% of countries.|
Information highlighting your expertise and/or experience related to the topic
Submission by individuals that include their direct expertise on the subject material may also have an enhanced ability to influence decision makers. For example, you may wish to include information such as:
- The length of time you have been active on that particular issue
- Organisations or government departments that you have worked with or supported that are also active on the particular issue
- Your experience working on the issue and how this is linked to your actionable recommendations
How can a very quick submission still have an impact?
Copy statements from organisations providing draft submission templates
Many NGOs draft submissions on topics relevant to their area of interest. These submissions are often very well researched, backed up by strong evidence and written in powerful language with actionable recommendations. You may choose to copy these submissions entirely or pick and choose text which suits your submission points. There are a number of benefits for doing this:
- You can include actionable recommendations without doing many hours of research
- Your inclusion of these statements lends greater support to the organisation’s submission
- Replication of statements makes it easier for the analyst to group recommendations. The more frequently a particular recommendation is made, the more likely it is that the powerholder will actually read it.
Use pre-written campaign submissions or submission templates
- Do an online search for a pre-written campaign submission. Add in sentences with clear, actionable statements; these do not need to be directly related to the plan of concern. For example, any submission on an environmental plan could request a legislated zero emissions target by 2030. Any plan on Indigenous issues could request the signing of a Treaty between Indigenous people and the Australian Commonwealth.
- Do an online search for a template submission. Copy and paste into a word document, and email through to the submission email provided, or copy into a survey response
- Template submission unavailable? Do an online search for an organisation working on that particular issue and look on their home page or about page for any information about what they seek to achieve in their work. Copy and amend these to suit, paste onto a word document and email through to the submission email provided, or copy into a survey response
Just do it!
It is, of course, easy to be cynical as examples abound of public concerns voiced through submissions seemingly being ignored. However, the submission process is a precious component of our democracy and offers individuals the opportunity to engage in public policy and have their voices heard.
Engaging in a submission process can be an important early step in a community campaign – if a good result doesn’t eventuate you have the choice to escalate pressure on powerholders with a range of other tactics.
Every submission is meaningful. Even if you only have 10 minutes and know little about the topic at hand, you have the opportunity to request that a decision-maker know that you want your concerns addressed. Even writing one clear sentence (with an actionable recommendation!) will ensure your voice is heard.
- Making a Submission, Parliament of Australia
- Making a Submission to a Committee Inquiry, Parliament of Australia
- The Change Toolkit – Chapter 7 – Writing Effective Submissions, Federation of Community Legal Centres
- Lobbying & Advocacy: Start Here