What Makes a Good Submission?

Some comments on

Submission to the Queensland Government on the

Review of Tobacco and Other Smoking Products Act 2001

Policy Name

“Environmental Tobacco Smoke Kills”

This submission received a high distinction mark for its content (i.e. the evidence,
persuasiveness of argument, etc).

Name and background of your client

This student has very succinctly described the history of the Queensland Cancer Fund
(QCF) in one paragraph. This information undoubtedly came from the home page of
the QCF. It simply states its activities (raising funds and supplying facilities) and
what its aims are (promoting cancer treatment and raising public awareness). It also
mentions what methods it uses to achieve its aims – help lines and education
programs etc. This is all that is needed in this section.

The issue you are addressing

The next paragraph simply states what problem the submission is addressing: the ill
effects of environmental tobacco smoke (ETS) in public places. It provides some
basic facts to show why passive smoking or ETS is a health problem. The reader is
then introduced to the argument that there is a link between these two things – ETS
and poor health outcomes – without going into the argument in detail. This is left to
the body of the submission. Crucially, here it also mentions what policy solution
the submission proposes. This has to be very clear to the reader at the beginning
of the submission. What is your submission actually asking the government to
do? This is only mentioned at this point of the submission; detailed discussion is left
to the body of the submission.

The Central Argument

Historical background to the issue

This section starts under the heading “Key Developments”. This paragraph puts the
issue in historical context, in other words it informs the reader about the bad effects of
smoking- even for non-smokers. If you were doing your submission on banning
plastic bags, you might like to talk about when this issue first came to prominence,
and when policy proposals were being discussed to use alternative forms of packaging
etc.

The Body (main section of the submission)

The tone of the language it uses is important. Under the section “The Silent Killer”, it
says that it is “worst of all, smoking is the leading preventable cause of premature
death and illness in the state but the Government still haven’t acted”. It is mildly
critical of government, but at the same time is making it clear that it believes policy
change is required.

This section presents the arguments in introducing permanent non smoking

legislation. Evidence is presented to show that the practices of banning smoking have
been successful elsewhere and must be adopted in Queensland.

Again, discussion of the problem is followed by discussion of the policy solution

and benefits being proposed.

The submission provides evidence to show that smoking bans have positive effects.
One of the submission’s strongest points is how it shows the societal effects of the
problem. For instance, it mentions the cost of smoking on the public health
system and the value of smoke free environments. It also says that litigation
costs are high and that funds devoted to healthcare could be better spent
elsewhere, and there is cost to society as a whole. In other words, there is a
public interest at stake.

This section provides further evidence as to why ETS is not acceptable and how
smoking has detrimental effects on workers and clients who may not be smoking
themselves. They may be working in smoke filled locations such as pubs.

It is notable that each paragraph is generally devoted to one particular argument in

favour of the policy change. Importantly, it also effectively argues that only the
policy being proposed will be effective. Try to follow this practice with your
submission because you need to show why your policy is better than other policy
proposals to deal with the problem. Why are other policy proposals unlikely to
be effective?

Another very strong feature of the submission is how it deals with the arguments of its
competitors. It argues that opponents of banning smoking from restaurants and bars
have vested commercial interests to protect, a particularly effective point, since no
government wants to be seen to be protecting business interests at the public’s
expense. It counters the argument that smoking bans are bad for these businesses by
pointing out that in Ontario, these types of businesses are attracting more non-
smokers as well as retaining smoking customers. It also provides a local example of a
bowls club which successfully banned smoking in 2001 and increased its patronage.

It is also particularly important for you to try to pre-empt and rebut your
opponents’ arguments. In other words, if you are doing the obesity topic and you
are arguing for restricting the use of junk food advertising, then you need to think of
what arguments the take away food companies will make (even better, do some
research and see what they are saying!) and counter them, and vice-versa if you are
representing the IASO.

Conclusion

Like the introduction, the conclusion is very succinct. It simply sums up the
evidence, and concludes that a particular course of policy action is needed if the
problem of passive smoking is to be solved.

Other Factors that make this submission so good

Another factor is the fact that there are virtually no spelling or grammatical mistakes.
Make sure that your submission reads well, that it has been proofread and spell-
checked several times.

The referencing is also excellent. If you want a guide as to how to reference for your
business submission, simply follow this one. Note that web addresses are listed
only in the reference list, and not in the body of the submission.

A Note of Caution

The headings used in this submission should not be copied exactly because they are
specific to this particular submission, and this particular subject area. You will need
to come up with your own headings and structure for your own submission. This is
an excellent submission, but the headings and its structure were not its standout
points.

Its strongest points were its clarity, persuasiveness, the evidence it provides, the fact
that it pre-empts and rebuts arguments of its competitors, and how it frames its
arguments around what is in the “public interest”, not commercial interests, or private
interests of groups. It tries to convince government that the QCF’s views are in the
public interest. All successful interest groups must do this.