Publications Other Resources Submissions Protocol: Revised September 2021

Submissions Protocol: Revised September 2021

FINDING OPPORTUNITIES TO WRITE SUBMISSIONS

See Appendix 1

How to initiate a potential submission:

·     Track state and federal enquiries and identify those of relevance      

·     Discuss with either SIGs, State committees or REAC when a submission opportunity is identified

·     Communicate with either SIG’s, State committees, REAC or ED so all are aware when submissions are undertaken and who is leading and writing

·     Communicate with suggested relevant experts who might be required to assist, edit and sign-off the submission.

Upcoming and current submissions could be listed in the DEA monthly newsletter (Environmental Defenders Office – EDO does this).

WHO WILL WRITE THE SUBMISSION? (More usual approach)

·     Special Interest Group members (SIG)

·     State Committee members

·     DEA members with a specific skill or interest in the area

·     DEA members who would like to contribute time or become more involved with DEA

·     Students are encouraged to write submissions with guidance from SIGs and State committees

Note – DEA has limited resources, and not every government enquiry can be addressed. Those who may be approached should have the space and opportunity to decline.

WHY IS THIS SUBMISSION IMPORTANT?

For DEA

·     Relevant to DEA’s strategic aims.

·     A tool and resource for DEA’s advocacy and education as it will eventually be published on our web-site.

·     The submission process occasionally provides an opportunity for DEA’s experts to speak before a committee of parliamentarians at a public hearing.

·     Once submitted, DEA’s comments and recommendations are forever on public record (Hansard). Accuracy in content, formatting, grammar and expression are all important.

For members

·     Support members’ knowledge and expertise in a niche area.

TERMS OF REFERENCE (TOR)

Once a submission of interest has been identified, the Terms of Reference will dictate the scope of the submission. It is important to address the TOR specifically. Material not relevant will likely not be read, thus wasting time and effort. It is better to be concise and clear than include too much information. One or two pages may be appropriate in some cases. If the author wants to submit recommendations outside the TOR, it may be possible to apply to the responsible committee to have the TOR expanded. Framing a submission strictly in accordance with the terms of reference or legislative requirements increases its relevance by addressing the issues in the same way that the decision maker has to. DEA obviously does not have to comment on all TORs.

Submissions assist government inquiries, committees and Royal Commissions help make decisions on governance and approvals. You should frame your submission as arguments or recommendations for a particular course of action, presenting evidence and health information to support your arguments. Submissions should not be a lecture-type treatise on a particular health topic. If a lengthy presentation of the evidence of health harms is appropriate, it can be added to the submission as an Appendix.

CLOSING DATE

Inquiries generally allow 4-6 weeks for the submission process. Aim to finish the submission as early as possible to allow for review and re-writes of sections.

Extensions of one (sometimes two) week past the closure date are sometimes accepted if a request if made to the committee.

STANDARDISATION OF CONTENT

  • Include the link to the report or document which you are addressing
  • Standard introductory paragraph about DEA (see Appendix 2)
  • Introduction and key concerns
  • Recommendations
  • Discussion
  • Summary and/or conclusion
  • Standardised referencing (see previous submissions); superscripts with either footnotes or endnotes
  • Standardised formatting
  • Aboriginal and Torres Strait Islander Guide to Terminology

Generic comments on health impacts e.g., of climate change/coal mines, etc. can be taken from other DEA work such as previous submissions or fact sheets and copy/pasted in the text.

REVIEW PROCESS

First draft to be reviewed no later than 10 days before due, allowing time for re-writes

Peer review by at least one, preferably two other DEA members who did not help write e.g.

·     SIG member or

·     State committee member – preferably with an interest or expertise in the area

·     REAC member

·     Submissions can be referred to non-DEA external experts for review if appropriate.

·     When sending draft to reviewers, ensure that the link to the Inquiry is at the beginning so that they can easily access the Inquiry’s TORs and the Discussion Paper or Report.

 Send submission to Kylie for formatting, no later than 5 days before due, including

·     the correct and full title of the submission,

·     relevant website link and closing date

·     who the authors are

·     who the reviewers are (debate over whether these should be publicised)

·     a short description of the purpose of the submission to add to the website entry

Further edits and changes can be made on the formatted version

SUBMISSION PROCESS

Submission sent to government office:

Often now the submission can be made via a boxed questionnaire on the Inquiry site. However, the usual formatted multi-paged version is still acceptable on-line.

Please note: Once a submission is published on a government website, it is covered by Parliamentary Privilege. This means that the writers and DEA have legal immunity i.e. cannot be sued or prosecuted for anything that has been written or said at a parliamentary inquiry. For some submissions, this can be an important protection, particularly when we are writing outside our specific field of expertise. For this reason, submissions should not be available on the DEA website (which is a public site) until after they have been published on the relevant government website.

DEA administration will provide the following information when submitting:

·     Ask for acknowledgement of receipt           

·     Give name, email and telephone number of main author and an invitation to contact for further comment

·     Give address, email and telephone number of DEA administration

·      This information is often sought when completing an electronic version.

Write a short 100-200-word precis of the submission for Kylie to include as a description of the submission for the DEA website.

Send submission to Carmela

Unless accompanied by media release/publicity, the hard work of submissions is unacknowledged and underutilised and may well be wasted.

·     Write a summary of the submission for Carmela as part of the submission process

·     Provide Carmela with enough succinct information to write a Press Release if required, and for posting on social media

TRACKING RESULTS OF INQUIRIES (especially for Inquiries of high importance)

·     Make sure at least one of the authors is registered for tracking.

·     You will need to create a MyParliament account to have your e-mail registered for notifications and progress of the enquiry

·     Have a prepared media statement ready for when final decision is made by the committee. Be prepared for a range of decisions in the committee’s final report.

Appendix 1:

Government websites distribute mailing lists for information on upcoming enquiries arising in state and federal parliaments. If interested, sign up and subscribe on the government’s website.

Federal government:

Inquiries

Business consultations

Energy ministers – you can join the mailing list by signing up at this site

Australian Energy Market Commission (AEMC) newsletter – subscription at this site

State governments:

NSW                 https://www.parliament.nsw.gov.au/committees/inquiries/pages/inquiries.aspx

Victoria            https://www.parliament.vic.gov.au/committees or https://engage.vic.gov.au/ 

SA                    https://www.parliament.sa.gov.au/committees

WA                   https://www.parliament.wa.gov.au/Parliament/commit.nsf/WCurrentInquiryName

Qld                   https://www.parliament.qld.gov.au/work-of-committees/inquiries

NT                    https://parliament.nt.gov.au/committees/inquiries

Tasmania         https://www.parliament.tas.gov.au/

ACT                  https://www.yoursay.act.gov.au/

Environmental Defenders Office:

National           https://www.edo.org.au/have-your-say/

NSW                https://www.edo.org.au/edo-have-your-say-nsw/

SA                    https://www.edo.org.au/edo-have-your-say-south-australia/

WA                   https://www.edo.org.au/edo-have-your-say-western-australia/

Qld                   https://www.edo.org.au/edo-have-your-say-queensland/

NT                    https://www.edo.org.au/edo-have-your-say-nt/

Tasmania         https://www.edo.org.au/edo-have-your-say-tasmania/

ACT                  https://www.edo.org.au/edo-have-your-say-act/

Appendix 2:

DEA is an independent, non-government organisation of medical doctors and students in all Australian States and Territories. Our voluntary members work across all specialties in community, hospital, and private practices to prevent and address the diseases – local, national, and global – caused by damage to our natural environment. We are a public health voice in the sphere of environmental health with a primary focus on the harms to health from pollution, environmental degradation and climate change.

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