Scoping Meetings:
summary of outcomes
1.
section |
appendix 2
Outcomes of Consultation: Submissions
from Interested Persons
Section contents
1.
Methodology of analysis, report content
and themes
13
Background
14
Purpose of the IP report
14
Organisations granted Interested Person status
14
Submission format
15
Methodology
15
Project team
15
Methodological approach
16
Registration of submissions
16
Data analysis methods
16
Format and language in the IP report
20
Outline of the IP report
20
IP report content
21
IP report themes
22
Royal Commission on Genetic Modification | Report Appendix 2
Report Appendix 2 | Royal Commission on Genetic M odification
Section 1: Methodology of Analysis
p14 |
1. Methodology of analysis,
report content and themes
Background
Purpose of the IP report
The analysis of written submissions by Interested Persons stands as a subsidiary
report within the volumes constituting the complete report of the Royal
Commission. It is referred to here as the "IP report". It provides a summary and
analysis of the issues raised in 107 written submissions from organisations
accorded Interested Person status as part of the Commission's process. Each of the
written submissions has been given full consideration, and this report reflects the
key points raised in those submissions. The report does not provide an in-depth
analysis of every point raised in the submissions.
The purpose of the IP report was to provide a summary of issues raised by
submitters to assist the Commissioners in their deliberations and to provide a
public record of the key issues raised in the submissions from Interested Persons.
The report was prepared relatively early on in the Commission process and
formed one of first analyses of key issues identified by submitters.
Organisations granted Interested Person status
In total, 107 written submissions were received from 117 organisations that had
been accorded Interested Person status. In some instances, several organisations
grouped together to provide a joint submission; and in other instances,
organisations that were given Interested Person status chose not to provide a
written submission.
To fulfil the legal requirements for Interested Person status, an applicant had to
satisfy the Commission that "he has an interest in the inquiry apart from any
interest in common with the public". Further detail on the requirements for
Interested Person status and the process by which this status was granted are
described in Appendix 1 (see "Processes of the Commission: Formal Hearings: the
process").
Royal Commission on Genetic M odification | Report Appendix 2
Section 1: M ethodo logy of Analy sis
| H1 | p15
Submission format
Interested Persons wishing to make submissions were invited to respond using a
standardised document based on the Warrant that set out the matters that the
Commission had been appointed "to receive representations upon, inquire into,
investigate, and report upon". The Warrant for the Commission is contained in
Appendix 1 (see "Operational detail: Terms of reference").
The "Call for Submissions" documents (Forms 3 and 4) were provided on the
Commission's website so that submitters would respond in the standardised format
(preferably electronically). If requested, submitters were also emailed a copy of the
Call for Submissions document or provided with hard copy. All submissions from
Interested Persons were placed on the Commission's website 10 working days
before the submitter presented oral evidence to the Commission at the Formal
Hearings.
In most instances submitters followed the format set by the Commission in
responding to the Warrant. They provided written submissions, usually
accompanied by witness briefs, and sometimes by background documents. Some
submitters responded only to selected Warrant items on which they wished to
comment. In a few instances submitters preferred to provide their views in a
different format, such as a letter or list of key points, and did not follow the
Warrant format.
This IP report has analysed the "submission" only. The witness brief material has
been used only where the submitter stated in the submission that the response to
the particular Warrant item was contained in the witness brief. Oral presentations
made by submitters at a later stage in the Commission process and the results of
cross-examination of witnesses do not form part of the IP report.
Methodology
Project team
The project team for the IP report comprised a team of independent submission
analysts employed by the Commission secretariat, assisted by the Centre for
Research Evaluation and Social Assessment (CRESA), a Wellington-based social
science research company. CRESA provided input on methodological design,
frequency and cross-tabulation analysis of data, and quality assurance review of the
IP report. The independent analysts undertook the summary and analysis of the
submissions and wrote the IP report.
Report Appendix 2 | Royal Commission on Genetic M odification
Section 1: Methodology of Analysis
p16 |
Methodological approach
The methodology used to analyse the 107 submissions involved both qualitative
and quantitative data analysis methods. As the submitters were a "specially
selected" group of interested persons, the data does not represent a statistically
valid or random sample. Comments provided in the IP report are therefore not
representative of the population at large.
The development of the methodology for the analysis began at the end of October
2000 and the first draft of the IP report was provided to the Commissioners on 22
December 2000.
Registration of submissions
All of the 107 submissions were given a specific identifier number when received
by the Commission. The numbering system involved a code of one to three digits
preceded by "IP" (standing for "Interested Person"). This system allowed
differentiation between submissions received from Interested Persons and
submissions received through the public submission process. Submissions are
referred to throughout the IP report using the name of the submitter and the
associated IP number. Details of the nomenclature for all Interested Persons are
listed in Table 1 (see "Introduction to Appendix 2").
Copies of the submissions were distributed to the Commissioners and the analyst
team. A master copy of the submissions was kept at the Commission's secretariat
offices. Copies of the submissions were also placed on the Commission's website.
Data analysis methods
The first stage of analysis involved a qualitative approach whereby the analyst read
through each submission and summarised the key points raised under each of the
Warrant items and recorded the summary points on a form specially prepared for
that exercise. Quotations that clearly illustrated points being made by submitters
were also recorded. Other records noted included: if the submitter wanted the
submission material to be kept confidential and not publicly released; which
Warrant items the submission focused on; whether there was explicit Maori
commentary; whether there was Maori witness input; whether the submission was
in Maori (Te Reo); and what was the submitters' stance on genetic modification.
Once the qualitative review of the submissions was completed, the second phase
was a quantitative analysis of the key issues raised. The quantitative analysis was
designed so that the results could be analysed using the SPSS package (Statistical
Package for the Social Sciences). This package performed frequency and cross-
tabulation analysis of the data. Frequencies provided information on how many
Royal Commission on Genetic M odification | Report Appendix 2
Section 1: M ethodo logy of Analy sis
| H1 | p17
submitters mentioned a particular issue; cross-tabulation analysis allowed
relationships between different groups of data to be identified.
A coding system was developed to categorise the issues for quantitative analysis.
Usually the coding of issues was relatively straightforward: a record of whether or
not a submitter had mentioned a specific issue or had made "substantive comment"
on an issue. In some instances, the analysts made an assessment across the whole
submission to assign the code: for example, to determine the submitter's overall
stance on genetic modification or orientation on strategic options. These issues are
marked with an asterisk (*) in the list below.
The specific items for each submitter that were coded for quantitative analysis
included:
*
IP number
*
primary sectoral focus (eg, economic/production, environment, health,
cultural/ethical, or other)
*
industry grouping (eg, industry networks/associations, research organisations,
other advocacy networks/associations, private companies, religious/spiritual
groups, Maori, organics groups, consumer networks/associations,
government bodies, occupational/professional groups, or other groups)
*
stance on genetic modification* (eg, whether submitters were `strongly for'
or `tended to be or' genetic modification, `neither for nor against', or
whether they `tended to be against' or were `strongly against' genetic
modification)
*
strategic options orientation* (eg, where submitters might be located on a
continuum of strategic options for genetic modification ranging from a
position where submitters would embrace all aspects of genetic modification
within a lightly controlled regulatory framework through to a position
where a submitter wanted no genetic modification, genetically modified
organisms or products permitted in New Zealand)
*
view on adequacy of current statutory/regulatory process
*
problems with current statutory/regulatory process
*
improvements to legislation
*
improvements to Environmental Risk Management Authority (ERMA)
*
improvements to regulatory process
*
opportunities for genetic modification use in New Zealand
*
opportunities from avoidance of genetic modification use in New Zealand
Report Appendix 2 | Royal Commission on Genetic M odification
Section 1: Methodology of Analysis
p18 |
*
on the basis of current information, whether use of genetic modification
might ever be acceptable*
*
circumstances under which genetic modification use might be acceptable*
*
circumstances under which genetic modification would not be acceptable*
*
whether there is (or is no) evidence that genetic modification poses risks or
whether it is predominantly safe
*
international obligations affecting genetic modification practices
*
adequacy of current liability laws for genetic modification
*
main issues raised relating to liability
*
adequacy of current treatment of intellectual property issues relating to
genetic modification
*
main issues raised relating to intellectual property
*
uses of genetic modification that submitters identify (in New Zealand or
overseas)
*
issues that the submitter has concerns about in relation to genetic
modification* (such things as public health safety risks, food safety risks,
economic, cultural, religious, ethical and environmental implications, public
education and uncertainties around risks and benefits)
*
what potential benefits submitters might see from genetic modification use
*
extent of commentary on Maori issues in the submission
*
extent of commentary on Treaty of Waitangi issues in the submission
*
whether there was a Maori witness input
*
key Maori issues raised
*
key issues on which the submitter made substantial comment*
*
whether New Zealand can combine genetic modification, genetic
modification-free uses and organic uses*
*
on which Warrant items the submitter made substantial comment*.
Once the coding was completed the data was analysed by CRESA using the SPSS
package and the results were provided to the Commission analysts for use in
writing up the IP report.
IP report write-up
In writing up the report of the Interested Person submissions, the aim was to
identify patterns of opinion on the specific matters set out in the Warrant and, in
Royal Commission on Genetic M odification | Report Appendix 2
Section 1: M ethodo logy of Analy sis
| H1 | p19
particular, to identify:
*
where common views were expressed
*
where divergent views were expressed
*
strength of opinion around issues expressed
*
matters which submitters considered are unresolved
*
profiles of who held what view
*
quotations to help illustrate key points of view.
The IP report used material from the quantitative analysis of issues, from the
qualitative data captured in the first template and, in some instances, from going
back to the original submission. Some submitters presented highly detailed
material: this was not reported in depth, and only key points were extracted. The
full texts of the submissions from the Interested Persons are publicly available on
the Commission's website (http://www.gmcommission.govt.nz) until at least
June 2002.
The report makes extensive use of quotations from individual submissions by
Interested Persons. It therefore differs from the type of report on public policy
issues that emphasises common themes emerging from submissions received. Such
reports tend to quote individual submitters only if theirs is the only submission
making a particular point or taking a particular stance. They generally record
direct quotes only if a submitter's view succinctly crystallises a position or if it
provides a good summation of a position that is representative of that of several
submitters.
In this instance, the IP report was prepared as a working document to assist the
Commissioners in their deliberations on evidence presented. A decision was made
to identify and isolate particular views expressed by individual submitters.
Submitters' views were specifically referenced to Warrant items, the result of
which was to clarify their positions on particular issues associated with those
Warrant items but to make it less easy to compare and contrast submitters
according to overall positions throughout their submissions.
The approach adopted for the summary and analysis of submissions by Interested
Persons was therefore largely dictated by the format in which the evidence was
presented (ie, the specific Warrant items) and by the perceived requirements of the
Commissioners.
The report does not purport to record all the issues relevant to each of the matters
raised by the Warrant items. Most submitters did not comment on all aspects of
every issue. The report summaries and analyses the information that submitters
placed before the Commission as being representative of their views.
Report Appendix 2 | Royal Commission on Genetic M odification
Section 1: Methodology of Analysis
p20 |
Format and language in the IP report
An explanation of the format of quotations has been provided previously (see
"Introduction to Appendix 2: Quotations, abbreviations and macrons"), together
with the nomenclature of Interested Persons in Table 1. A key point is that
differing formats for quotations do not imply differing values attached to those
quotations.
Similarly, use of words such as "commented", "noted", "made the point",
"expressed the view", "suggested" etc in reporting the opinions of submitters do
not indicate any differences in acceptance.
The IP report summarises and analyses the views of submissions by Interested
Persons. It reports the issues identified by submitters: it does not take a position on
them.
Outline of the IP report
The IP report has been prepared in sections that correspond to the Warrant items.
Warrant item (j), which dealt with four main areas of public interest, was dealt with
as four separate sections preceded by an introduction to the topic. Where there
was overlap between the Warrant items, the sections have been grouped together
or combined. Thus, strategic matters were grouped:
*
strategy: an introduction; strategic options (Warrant item (1)), strategic
issues (Warrant item (k)) and strategic outcomes (Warrant item (m))
Two Warrant items on international matters in relation to genetic modification
were combined and two on legislative matters, thus:
*
statutory and regulatory processes: changes considered desirable to the
current legislative, regulatory, policy or institutional arrangements (Warrant
item (2)) and adequacy of the current statutory and regulatory processes
(Warrant item (n))
*
international obligations and implications: international legal obligations
(Warrant item (d)) and international implications of measures that New
Zealand might take (Warrant item (l))
Within the three sections listed above submitters tended to provide similar
material across the related Warrant items. This was particularly so for strategic
matters where submitters tended not to clearly distinguish between strategic
options, issues and outcomes. In other instances, submitters addressed only one of
the Warrant items and made cross-references under the other related Warrant
item(s) to that material.
Royal Commission on Genetic M odification | Report Appendix 2
Section 1: M ethodo logy of Analy sis
| H1 | p21
Most sections have an introduction explaining the Warrant item and then
providing a profile of the submitters who responded to that Warrant item. Some
overlap of material occurs across the sections because many of the issues are
closely related and similar concerns or issues arise under the different Warrant
items.
IP report content
The content of the IP report was largely dictated by the scope and depth of
submissions presented by Interested Persons. The majority of the submissions
were extensive and specifically focused on Warrant items. However, submitters
clearly saw some Warrant items of more significance that others. In addition, many
submitters took the opportunity to present wide-ranging views both within and
outside specific Warrant items.
Assessments were made to provide an indication of where submitters' principal
interests and major concerns were. Where submitters made "substantial comment"
(ie, comments of some length or substance) on a particular issue or a particular
Warrant item this was recorded and identified. The assessment covered 14 areas
where submitters evinced a particular interest and focus (such as social, personal,
economic and legal issues) and 16 separate Warrant items.
These assessments showed that the issues attracting most comment were economic,
regulatory, health issues, risk assessment and environmental issues. The Warrant
items attracting most substantial comments were: strategic options, statutory and
regulatory issues, issues of public interest (including health, economic,
environmental, cultural and ethical issues) and legislative changes. Assessment
along these lines showed both the Warrant items that were the major thrust of
each submitter's case and the major issues that the submitters saw as important.
They showed, for example, that submitters' views on economic issues were not
confined to Warrant item (j) on economic issues of public interest. Many economic
arguments could be found throughout the Warrant items dealing with strategic
options and legislative changes. They also showed that spiritual concerns were an
area of public interest that was not specifically identified in the Warrant.
Statistics for assessment of substantial comment on issues were:
*
economic issues (53 submitters)
*
regulatory issues (45 submitters)
*
health issues (41 submitters)
*
risk, risk assessment and management (40 submitters)
Report Appendix 2 | Royal Commission on Genetic M odification
Section 1: Methodology of Analysis
p22 |
*
environmental issues (35 submitters)
*
intellectual property issues (29 submitters)
*
Treaty of Waitangi issues (22 submitters)
*
liability issues (21 submitters)
*
Maori cultural issues (21 submitters)
*
ethical issues (20 submitters)
*
social issues (six submitters)
*
spiritual issues (four submitters)
*
other cultural issues (four submitters)
*
insurance and underwriting (one submitter).
Statistics for assessment of substantial comment on Warrant items were:
*
Warrant item (1): strategic options (78 submitters)
*
Warrant item (2): legislative changes (56 submitters)
*
Warrant item (a): where, how and for what purpose (57 submitters)
*
Warrant item (b): evidence and uncertainty (35 submitters)
*
Warrant item (c): risks and benefits (48 submitters)
*
Warrant item (d): international obligations (23 submitters)
*
Warrant item (e): liability issues (33 submitters)
*
Warrant item (f): intellectual property issues (38 submitters)
*
Warrant item (g): Treaty of Waitangi issues (35 submitters)
*
Warrant item (h): global developments (38 submitters)
*
Warrant item (i): opportunities from use or avoidance (43 submitters)
*
Warrant item (j): areas of public interest (58 submitters)
*
Warrant item (k): strategic issues (39 submitters)
*
Warrant item (l): international obligations (17 submitters)
*
Warrant item (m): strategic outcomes (37 submitters)
*
Warrant item (n): adequacy of statutory and regulatory processes (62
submitters).
IP report themes
Major themes became apparent for each of the Warrant items discussed and are
usually summarised at the beginning of each section. In keeping with the many
Royal Commission on Genetic M odification | Report Appendix 2
Section 1: M ethodo logy of Analy sis
| H1 | p23
aspects of genetic modification technology and the continuum of opinion about
its use, these key themes were wide ranging. For example, they included:
*
New Zealand's international reputation
*
the role of the Treaty of Waitangi
*
tikanga principles
*
protection of Maori traditional knowledge
*
differing philosophical approaches to liability.
Some themes crossed many individual Warrant items, for example:
*
the public's right to choose and opportunity to exercise choice
*
the need for reliable information and more education on genetic
modification.
The total body of written submissions by 107 Interested Persons provides a
notable source of information on the wide range of issues raised by the subject of
genetic modification, genetically modified organisms and products. As stated
previously, the total resource of submissions is publicly available on the
Commission's website (http://www.gmcommission.govt.nz), at least until June
2002.