Section 2 provides that a governor-general shall represent the Queen in Australia. The governor-general is appointed by the monarch on the advice of the prime minister of Australia. In practice, the governor-general carries out all the functions usually performed by a head of state, without reference to the Queen; though the governor-general is the Queen's representative, he or she is not the monarch's delegate or agent. Under the conventions of the Westminster system, the governor-general's powers are almost always exercised on the advice of the prime minister or other ministers of the Crown. The governor-general may use the reserve powers of the Crown as prescribed by the constitution, though these are rarely exercised. One notable example of their use was by Governor-General Sir John Kerr during the Australian constitutional crisis of 1975. The question of whether the Queen or the governor-general is Australia's head of state became a political one in the years prior to the Australian republic referendum in 1999. Among arguments advanced in that campaign some were for retaining the office of governor-general as the monarch's (nominal) representative, and others were for a popularly elected head of state. Republicans included in their campaign the idea that the Queen is head of state and not Australian and, as such, should be replaced with an Australian citizen; this was summed up in their slogan "a mate for head of state". Opponents of the move to make Australia a republic claim in response that Australia already has an Australian as head of state in the governor-general, who, since 1965, has invariably been an Australian citizen. The governor-general in 2004, Major General Michael Jeffery, said at the time: "Her Majesty is Australia's head of state but I am her representative and to all intents and purposes I carry out the full role." However, the following year, he declined to name the Queen as head of state, instead saying in response to a direct question, "the Queen is the monarch and I represent her and I carry out all the functions of head of state." The governor-general normally represents Australia internationally, making and receiving state visits, but the Queen also carries out some official duties representing Australia outside Australia, such as in the United Kingdom. Within Australia, newspapers, ministers, constitutional scholars and the general public have not always been consistent in references to either the monarch or the governor-general as the head of state. Sir David Smith's lecture reviewing the state of opinion in Australia, published as "Papers on Parliament No. 27", March 1996, ended by quoting some remarks made the year before by Sir Gerard Brennan, Chief Justice of Australia, on the oaths of allegiance and office:  Reviewing the position in 2000, former Justice of the High Court of Australia, Michael Kirby concluded that the governor-general would increasingly take over as virtual head of state of Australia and the office would continue to evolve as an Australian peculiarity; and that while most Australians would continue to feel republican in their hearts, many would continue to have a vague lingering affection for the monarch, and some feel a measure of respect for the idea of the Crown as "a notion above the transient allegiances of party politics with its vital but often banal concerns."