There’s a passage in the preface of Jeffrey L. Pressman and Aaron Wildavsky’s classic Implementation: How Great Expectations in Washington Are Dashed in Oakland which strikes me as particularly important:

Policies imply theories. Whether stated explicitly or not, policies point to a chain of causation between initial conditions and future consequences. If X, then Y.

Public policy requires more than just the simple identification of a problem that should be addressed through government action. Instead, good policy requires a firm understanding of the causal connection between specific policy measures and the desirable end goal. Without that connection, a policy cannot ever hope to achieve its aims - except perhaps by happy accident - and there is a good chance it will backfire.

This, anyway, is what comes to mind when reading some of the submissions to the Senate Inquiry on Ready-to-Drink Alcohol Beverages. Those submissions that are pro-regulation and pro-alcopop excise increase (certainly, not all are) do very well at identifying binge drinking as a problem that they would like government to address. They are also very good at coming up with some possible policies. But they fail Pressman and Wildavsky’s test - they fail to establish a causal connection between those specific policies and their goals.

The submission of the Australian Psychological Society is a good example of policy recommendations without proper regard to causality. Certainly, it is full of possible measures the government could implement as part of their anti-binge drinking campaign. Sporting sponsorship and general advertising by alcohol companies should immediately cease. Happy hours should be banned. Liquor licences should be regulated more heavily, further trading hours limitations imposed, and retail competition restricted.

But the actual submission of the APS is more concerned with simply trying to establish that binge drinking is a problem that the government should tackle. They outline the harm alcohol consumption can do to individuals, they discuss extensively the ’social cost’ of alcohol consumption and describe patterns of licit and illicit substance abuse in young people. But none of that establishes that the trading hours of bars and pubs should be limited - why, of all infinite array of policies that could have been recommended, did the APS recommend these ones?

The APS’s lack of rigour is particularly disappointing because psychologists could have some valuable insights into the efficacy of the policies they propose. For instance, what psychological impact does advertising have on individuals who are undecided about whether they should purchase alcohol? Is there a body of theoretical or empirical evidence that sheds light on the possible consequences of the policies they recommend? Rather, the APS prefers to adopt the simple Yes Minister adage: “Something must be done. This is something. Therefore it must be done.”

Indeed, it is disturbing that Australian governments themselves have failed to articulate the justifications for most of their anti binge drinking policies.

The Victorian government has not explained just how locking individuals out of bars, clubs and pubs at 2am will decrease violence - the spectre of hundreds of drunk revellers being suddenly unable to enter any licenced venue and jostling for taxis doesn’t inspire much hope. But even if these objections to the lockout had been dealt with by the government, what exactly is the link between the hour of the evening with violent incidents? Certainly, late at night, people are likely to be drunk and possibly violent. But if the 2am lockout compresses the times in which alcohol is consumed, it may bring violent incidents forward to earlier in the night. The chain of causality between policy and aim is so loose for the 2am lockout that there are hundreds of ways the policy could go wrong. (I discussed this point in my Sunday Age column a few weeks ago.)

Similarly, if the alcopop excise increase is an honest attempt to tackle binge drinking (and considering its importance to the federal budget, that is by no means clear) then it is a woefully under thought-out policy. The submission from the Independent Distillers Australia is most powerful when it quotes a number of comments off a Facebook group discussing the easy substitution between types of alcohol beverages after the excise increase:

I work in a bottle shop and this is the best example I can find as to why this tax is a really dumb idea: 1 carton of JD cans = $119; A 4pack of JD = $22; 1 700mL bottle of JD = $33. This means you can almost buy 4 bottles for the price of 1 carton. I know which option I’ll choose.

So a 6 pack of Smirnoff double blacks is now $30, and a bottle of vodka is around $30… three times the amount of alcohol for the same price, I’m smashing myself on a bottle of vodka!

If the government is genuine in its enthusiasm for their policy, they have failed to consider its possible consequences. Here too the chain of causality is extraordinarily weak - the federal government appears to have assumed that faced with higher prices for alcopops, consumers will substitute onto other less harmful goods, or abandon drinking entirely. (The theory that alcopops are a ‘gateway’ drink into harder material is, to my mind, an even worse justification for the excise increase. Would it be better to have a relatively soft gateway drink available, or make jumping into spirits at a young age more attractive?)

Unsurprisingly, the early evidence suggests that consumers have quickly migrated onto potentially more harmful straight spirits. If moving people off canned Beam-&-Cokes to just Jim Beam was the policy aim, it could be considered a highly successful. But it wasn’t. As state and federal governments (and the many interest groups like the APS who have been advocating major new regulations) have failed to develop a theory of how their policies would achieve their goals, they leave themselves susceptible to counterproductive results like these.