Tasmanian Government Framework for Community Engagement discussion paper: TasCOSS submission

Submission to

Tasmanian Government Framework for Community Engagement discussion paper 26 April 2013

About TasCOSS TasCOSS is the peak body for the Tasmanian community services sector. Its membership comprises individuals and organisations active in the provision of community services to low income, vulnerable and disadvantaged Tasmanians.

TasCOSS represents the interests of its members and their clients to government, regulators, the media and the public. Through our advocacy and policy development, we draw attention to the causes of poverty and disadvantage and promote the adoption of effective solutions to address these issues.

phone 03 6231 0755 fax 03 6223 6136 postal PO Box 1126 Sandy Bay Tas 7006 www.tascoss.org.au

Authorised by Tony Reidy, Chief Executive For enquiries Wynne Russell, Policy and Research Analyst

Thank you for the opportunity to comment on the Tasmanian Government Framework for Community Engagement. TasCOSS applauds the Tasmanian Government’s recognition of the need for consistent best-practice community engagement across all arms of government, and strongly supports the development of a whole-of-government framework to inform and guide such processes. We appreciate the wide-ranging and stimulating discussions that we have held with the DPAC staff developing the framework, and are impressed by the commitment of the drafters to offering up both philosophical and practical arguments for the importance of good engagement theory and practice.

Our comments at this stage focus on a few broad issues. Some of these pertain to the conceptualisation of the Framework itself; others pertain to the way in which a Framework is presented to its intended implementers—the full range of Tasmanian government agencies and bodies.

The Framework Philosophical/theoretical rationale: TasCOSS agrees with the arguments advanced in the discussion paper for the importance of effective community engagement to achieving effective, durable policies and programs; however, we would suggest that more emphasis could be placed on the importance of effective community engagement in achieving equitable outcomes as well—something that can only occur if the engagement processes themselves are equitable.

Engagement with individuals and communities whose voices are often not heard: TasCOSS notes that engagement with low-income and disadvantaged Tasmanians often poses a particular challenge for Government agencies. The discussion paper correctly observes that some members of the community, as well as distinct communities within the state, may require support and encouragement to make the most of engagement opportunities; a final Framework would benefit from a recognition that by the same token, Government agencies have a special responsibility to go the extra distance in reaching out to such Tasmanians, rather than judging them to have failed for not engaging, as the discussion paper in some cases unconsciously suggests. TasCOSS would also like to highlight the important roles that local community service organisations have in enabling and channelling participation within government consultations for those Tasmanians whom Government finds challenging to engage.

Accepting responsibility for outcomes, not just processes: While understanding the difficulties that effective engagement poses, TasCOSS argues strongly that Government agencies must face up to their responsibility for seeing that effective engagement occurs, and that a Framework must emphasise this responsibility unequivocally. For instance, TasCOSS notes with concern the subsection “Frustrations” on p. 14. This subsection opens with a list of frustrations that can be felt by community members around the way in which Government engages, triggered by a wide range of issues pertaining to poor practice engagement (poor timing, inadequate information, etc). The section then goes on to say “For all these reasons, communities may not engage when they are given the chance and then may criticise the decision when it is made. When this happens, the engagement process may be criticised, when sometimes it is actually the decision itself that communities may have an issue with” (italics ours). This logic manifestly places responsibility in the wrong place: criticism about enagement processes in fact usually stems from poor engagement.

Principles and standards: The discussion paper observes that motivating principles such as accountability etc. “may be developed into standards” (italics ours). TasCOSS would argue

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that principles must be developed into standards if engagement is to occur consistently across government agencies. TasOCSS would also like to flag that ‘timeliness’ is an important principle to add. In order for consultation responses to be thorough and considered, respondents (whether they are individuals, community service organisations or peak bodies representing communities) need time to fully consider consultation questions and, where needed, consult with others, before submitting a considered response. This takes time and needs to be built into the structure of any consultation framework.

Levels of engagement: TasCOSS notes with interest the ladder chart detailing possible levels of community engagement on p. 11. We suggest that it will be useful for future community engagement activities to include this ladder chart, and to spell out at which rung the activity sits. (In fact, it would have been useful for respondents to the discussion paper to know at which rung the engagement process for developing the Framework sits. ) Such a measure will not only inform engagement participants, but also facilitate evaluations of how effectively the Tasmanian Government as a whole is moving towards the higher levels of engagement.

Triggers for engagement: TasCOSS would argue that the subsection “When doesn’t the Government engage?” (p. 7) is confusingly light on detail, and consequently sends mixed messages to the reader. A final Framework will require clearer guidelines surrounding the triggers for engagement.

Monitoring and evaluation: The discussion paper asks “How do we know if we’ve got it right?” While the indicators outlined—repeat engagement, acceptance of process, etc.— are of course relevant, engagement processes also should be included in continuous evaluation around the trust/satisfaction/engagement nexus. Evaluators should be asking: Do people feel that they can influence government policy and practice? Do they trust government to consult effectively and to develop and deliver effective policies and programs? Are they satisfied with consultation, policies, and programs? Would they reengage with consultation processes?

More broadly, TasCOSS has already argued strongly that the Tasmanian Government would benefit from the institution of regular broad-scale community surveys that would measure satisfaction with government policies and practices, identify important and emerging issues and needs, and help shape future policies and visions for the state. Such surveys act as a form of meta-engagement that can inform policy at its earliest stages, potentially making engagement on particular policies and projects easier.

Presentation Need for more detail: Throughout, readers of a final Framework would benefit from more detail on how theory turns into practice. For instance, the ladder chart of Levels of Community Engagement would benefit from examples of each type; similarly, the discussion of how principles and value statements translate into action would be well illustrated by including the Scottish Government’s National Standards for Community Engagement in the text, rather than relegating them to an appendix.

Implementation strategy outline: Although a Framework may be released before a final implementation strategy, any accompanying paper should contain at least an outline of an implementation strategy to ensure that readers have some idea of what implementing the Framework may mean for them in practice. In particular, an implementation strategy must

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address the question of building capacity around effective engagement in all Government agencies.

Organisation: This discussion paper contains many excellent ideas, but its organisation is sometimes confusing. A strong structural edit of the paper accompanying a final Framework will help ensure that even the busiest reader can clearly understand the arguments of why effective community engagement is not only a basic responsibility, but also a powerful tool for effective policy and practice for any government body.

Thank you for accepting our submission. We are happy to provide any additional information necessary.

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