Opinion of the Economic and Social Committee on the 'Proposal for a Council Decision on a Community Action Programme promoting non-governmental organizations primarily active in the field of environmental protection`

(96/C 204/01)

On 2 February 1996, the Council decided to consult the Economic and Social Committee, under Article 130s of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for Protection of the Environment, Public Health and Consumer Affairs, which was responsible for preparing the Committee's work on the subject, adopted its Opinion on 2 April 1996. The Rapporteur was Mr Boisserée.

At its 335th Plenary Session (meeting of 24 April 1996), the Economic and Social Committee adopted the following Opinion by ninety-one votes in favour and two votes against, with four abstentions.

1. Subject of the proposal for a Council Decision

1.1. The Commission's proposal for a Council Decision aims to create a formal framework (Action Programme) for promoting non-governmental organizations in the field of environmental protection. Both the Council and European Parliament had earlier called for such a framework to support the aid measures taken by the Community. This commitment, which was enshrined in the joint declaration of 28 June 1982, is now to be applicable to environmental NGOs.

1.2. The Commission proposes that the 1996 budget funding in support of environmental NGOs should remain at ECU 8,4 million.

1.3. The proposal for a decision defines:

- the scope of the Action Programme;

- the aims to be supported by the Action Programme;

- the beneficiaries;

- the arrangements for disbursing funds and monitoring expenditure.

1.4. The Decision lays down the general framework for the granting of funds under the Action Programme; a detailed programme is to be published each year.

1.5. The Action Programme will initially run till the turn of the century. Provision is made for the Council to adopt new decisions for the period starting in January 2000.

2. Summary

In the past, Commission support for European environmental NGOs has proved to be both necessary and appropriate; it has also been consistent with the objectives of the fifth Action Programme on the Environment (sustainable and environmentally-friendly development), as endorsed by the ESC. Since the proposed Decision aims to continue these support activities, the Committee approves the document in principle subject to the following comments:

3. General comments

3.1. Link between the financial aid programme on the one hand and cooperation between the Commission and environmental NGOs on the other

The financial aid programme is the sole aspect of overall relations between NGOs and European Union bodies covered by the proposal. European-wide environmental organizations have for a long time now been calling for the institutionalization of cooperation - particularly in respect of participation, information and financial support - by bringing it within the context of a formal framework (e.g. Council Decision) after consultations with the organizations in question. This is in keeping with the principle of involvement of 'environmental policy actors` in the 'sustainable and environmentally-compatible development` advocated in the European Communities' fifth Action Programme on the Environment (). This principle of cooperation was firmly supported by the Economic and Social Committee in its Opinion on the fifth Action Programme ().

The Economic and Social Committee, which makes the promotion of non-official environmental action one of its main areas of concern, would draw attention to this link, though without rejecting the draft Decision which is the subject of this Opinion.

3.2. Funding

The Economic and Social Committee calls upon the Commission to review the funding of the programme insofar as its scope is to be extended.

According to point 9.1 of Section II of the Financial Statement, funding will be available for the 'Consultative Forum` (Point (i) of the fourth paragraph of Chapter 9 of the fifth Action Programme) as well as 'other meetings at national and regional levels`. These funding objectives go beyond the activities of NGOs proper and should therefore be removed from the Financial Statement.

3.3. Scope

The ESC considers that the draft Decision should provide a clearer definition of aid beneficiaries - something which is especially important given the limited funds available.

Aid should be concentrated on non-governmental organizations which are primarily active in the field of environmental protection (as the title of the draft Decision states) at European level. The organizations in question should have their headquarters in a Member State of the European Union. Actions or programmes carried out jointly with organizations active at national level should also be eligible for financial support. In the view of the ESC it is not sufficient to publish details of this in the Commission's annual programme.

The use to which financial support is to be put is also unclear. The provision of information and the mobilization of the population are undoubtedly important activities of environmental NGOs but efforts should not be confined solely to these areas or to the preparation of studies and documentation. It should therefore be made clear that the 'target groups` of recognized environmental NGOs should include the bodies and authorities of the European Union and Member States. Consultations connected with the preparation of Community regulations and European provisions in the field of environment policy, including environmental problems occurring in other policy areas, should also receive financial support.

3.4. Co-financing procedures

The detailed provisions for the financial support of activities of environmental NGOs need to be reviewed. On 11 July 1995 the Commission presented, in parallel with the proposed draft Decision, a proposal for a Regulation on the co-financing of operations carried out with European non-governmental development organizations (NGOs) (). The rules for financial support under this Regulation are more generous than those of the present environmental NGOs Directive and the gap cannot be accounted for by the different aid objectives. There are differences, for example, between the duration of institutional funding (contribution to administrative expenditure) and the procedure for approving the release of funds. Development aid and environmental activities are equally worthy of financial support and should be treated equally.

4. Specific comments on individual provisions of the proposal for a Decision

4.1. Articles 1 and 2

A precise definition of aid measures in accordance with the comments under 3.3 is called for.

4.2. Article 6

4.2.1. According to Article 6(1), the rate of Community assistance for environmental NGO action is not normally to exceed 40 % of costs. If this ceiling is adopted, a large proportion of activities will not get off the ground since such organizations have only limited internal resources (members' contributions, etc.). The framework for the provision of aid in support of environmental NGOs in particular should therefore be more flexible [see by comparison the proposal regarding NGOs specializing in the field of development aid () and point 5.4 of the ESC's Opinion on the financial instrument LIFE of 25 October 1995 ()].

4.2.2. The proposal in Article 6(2) whereby the administrative subsidy would last in principle for not more than three years, will cause insurmountable problems for NGOs unless the exception became the rule. No time limit is set in this area for non-governmental development organizations (cf. also point 3.4).

4.2.3. As far as Article 6(3) is concerned, it should be noted that publication of the annual programme, and approval of the aid grants relating thereto, would frequently be so late that the activities could not be carried out in the year of application. The procedure for approving subsequent changes to projects (which might be unavoidable for technical reasons) should also be simplified.

4.3. Article 7

The wording of Article 7(2) does not correspond with the title of the draft Decision (non-governmental organizations primarily active in the field of environmental protection). The wording given under point 3.3 above should be taken over.

4.4. Annex (operational activities)

The definitions (A-C) should be brought in line with the proposed improvement in point 3.3 in the description of environmental NGOs and the activities of these organizations. The same applies to point 9.1 of Section II of the Financial Statement.

Done at Brussels, 24 April 1996.

The President

of the Economic and Social Committee

Carlos FERRER

() OJ No C 138, 17. 5. 1993.

() OJ No C 18, 22. 1. 1993, p. 141.

() COM(95) 294 final.

() OJ No C 82, 19. 3. 1996, p. 18.

() OJ No C 18, 22. 1. 1996.