Extracts from pages 2 to 5 of Making a Submission, by Halina Strnad, Convener of the Submissions Committee, Humanist Society of Victoria (Melbourne: Council of Australian Humanist Societies, 1995).
Making a Submission
This information is compiled from several sources: instructions issued by Standing Committees of the Parliament; guidelines issued by other authorities conducting public inquiries; books on lobbying and, not least, the valuable advice given by the late Senator Olive Zakharov — the recipient of many submissions to the Senate — who was active as a member of the submissions committee of the HSV.
1.1. Submissions are a major form of lobbying and influencing government policy. Their quality reflects on the standards of the submitter.
1.2. Submissions should not be made for the sake of it, but only if a valid point can be made.
1.3. Public inquiries, mostly and essentially, gather public opinions. Opinions may be of two types: informed and uninformed. The informed opinion carries much greater weight. Every effort should be made to research the issue and, whenever possible, to enclose reputable references.
2. TOPICS, MATERIAL AND ORGANISATION
Topics may be selected in the following ways:
2.1.a. by writing to authorities and Standing Committees of the Parliament which deal with issues of interest to Humanists (education, law reform, bioethics, social welfare and justice, population control etc.) expressing the wish to participate in public debates and inquiries and asking to be placed on their mailing list for this purpose;
2.1.b. and/or by scanning the daily press for advertised ‘calls for submission’. . . .
2.1.c. by identifying topical issues on which there is a widespread concern or interest or where the Humanist view should be presented.
2.2. Authority for the submission. The selection for a topic for a submission should be a matter of consensus among at least the executive if not the committee, to avoid the “pushing of private barrows”. The content should reflect the organisation’s policy or point of view.
2.3. A convenor and a subcommittee should be appointed for making submissions. HS members with relevant expertise should be invited/co-opted to find data and references on the subject.
2.4. Most desirably, the content of a submission should arise from the combined wisdom of as many members as can and wish to contribute. Such discussion groups are a valuable learning time for all participants.
2.5. Public inquiries often have short deadlines. This might present difficulties in terms of notifying a date for discussion in the monthly bulletin or organising wider membership involvement.
2.6. An established view or item in HS policy can be reiterated (without discussion) in submissions to various bodies and levels of government and in the context of different inquiries. For instance, our statements on religious instructions or on female genital mutilation were used in the context of responses to inquiries (State and Federal) into education, multiculturalism, law reform, “Schools of the Future” etc. (see para.3.2.)
3. REQUIREMENTS FOR SUBMISSIONS
3.1. In answer to a call for submission, observe the terms of reference. A small step outside these may be acceptable: a marked departure might result in rejection of the submission.
3.2. The submission may cover all points raised in the terms of reference or just a selection of them.
3.3. If a Discussion/Issues Paper is provided, the questions or paragraphs are usually numbered. Quote these numbers in your response.
3.4. Submitters to inquiries should observe the deadline or ask for an official extension of time. Belated entries are often rejected.
3.5. If any of the material is of a confidential nature, this should be indicated. It will then not be issued to the public.
3.6. A submission to a Parliamentary Committee becomes a committee document. You may be advised that: “In accordance with the rules (the Standing Orders) you may not withdraw alter, publish or otherwise disclose your submission without first receiving the Committee’s approval. However, provided that it is presented in a different form, you may use or publish the information your submission contains.” Thus summaries listing main points of submission may be published in bulletins. (. . . ) Not all authorities impose such restrictions.
3.7. It is required that: “The submission should be signed by the author either on his/her own behalf or on behalf of an organisation. Those signing submissions on behalf of an organisation should indicate in what level the submission has been authorised (e.g. sub-committee, executive committee, president, chairman, state branch, regional group etc.)”. (From Notes on the preparation of submissions, Parliament of Australia, A.C.T.)
3.8. Submissions should be typed on A4 paper. Some authorities also specify the type of computer disc on which submissions can be made.
3.9. The front page of the submission should set these identification details:
• the name, address and telephone number (if available) of the person or organisation making the submission,
• the inquiry or subject with which the submission deals,
• if made by an organisation — a brief outline of its objects. (. . .)
4. ADVICE ON COMPOSING SUBMISSIONS
4.1. There are no official limits to the length of a submission but guidelines advise brevity and conciseness.
4.2. If the submission is a lengthy one, i.e. more than six pages, include a summary and highlight the main points.
4.3. In the body of a submission points should not be just asserted but should be argued well, with support of references and footnotes.
4.4. References should preferably be first-hand sources: press or other second-hand reports may be seen as poor or distorted evidence.
4.5. Copies of any documents relied on should be attached to the submission unless they are published documents available to the public (official reports etc.). Identify such documents and state where they are available.
4.6. Details should be kept out of the body of the submission to avoid overwhelming the reader with volume. They should be put in appendices.
4.7. Accuracy of names, dates, quotations or references is essential.
4.8. Structure the submission into sections, e.g. General Remarks, Specific Comments, etc. with underlined titles for sections and subsections.
4.9. Attention should be given to spacing lines and paragraphs for ease of reading, and to the overall aesthetics of presentation.
4.10. Views, suggestions and proposals should be stated — each in a separate paragraph. Numbering of paragraphs may be helpful if discussion or comments are likely to arise.
4.11. Long, convoluted sentences and verbosity are to be avoided. Clear statements in plain English make a favourable impression.
4.12. Provide a list of enclosures, if any.
Additional comments on Making a Submission
1. Best opened with a positive statement e.g: “We congratulate the Government/Senate/Department for consulting the public” or “putting this important social issue up for public debate”, or “We welcome this opportunity to express our views on this vital issue”. Then proceed with criticism or rebuke. This creates a more receptive attitude at the receiving end.
2. Use expressions such as: “we believe that . . ., in our view. . . , we observe that . . . , we suggest that. . . , etc., to avoid seeming to be dogmatic. Definite, unqualified statements do have a place but not all the time.
1. Terms of reference, any previous of our statements on this issue and current information and references need to be presented to the discussion group.
2. It is not always possible to discuss all questions or issues raised in the discussion paper, hence the need to select those that are within the range of HSV’s interests. Comments will range from pearls of wisdom and insight to nonsense
3. Need to have a strong chairperson to prevent chaos and to establish majority view which should prevail (unless meeting “stacked”)
4. A co-opted person with relevant expertise might offer a monograph with eye-glazing detail. References should be supplied and the HSV should not imply that it has any very specific expertise.