Opinion of the Economic and Social Committee on the "Proposal for a decision of the European Parliament and of the Council laying down a Community Action Programme promoting non-governmental organisations primarily active in the field of environmental protection"
Date: 2001-10-18
Institutions: European Economic and Social Committee
Subjects: EU programme, action programme, environmental protection, non-governmental organisation

C 36/108

EN

Official Journal of the European Communities

8.2.2002

Opinion of the Economic and Social Committee on the ‘Proposal for a decision of the European
Parliament and of the Council laying down a Community Action Programme promoting non-
governmental organisations primarily active in the field of environmental protection’

(2002/C 36/21)

On 11 July 2001 the Council decided to consult the Economic and Social Committee, under Article 175
of the Treaty establishing the European Community, on the above-mentioned proposal.

The Economic and Social Committee appointed Mrs Sa´nchez Miguel as rapporteur-general to prepare its
work on this matter.

At its 385th plenary session on 17 and 18 October 2001 (meeting of 18 October 2001), the Economic
and Social Committee adopted the following opinion by 66 votes, with 22 against and 10 abstentions.

1.

Introduction

From 1 January 1998 until it expires on 31 December
1.1.
2001,
a Community programme promoting European
environmental NGOs has been in operation. Its purpose is to
provide financial support for activities which contribute to the
development and application of Community environmental
policy and legislation on the basis of Council Decision
97/872/EC.

Hence it is necessary:

European governance, the requirements of the integration
process (of environmental protection and sustainable develop-
ment into all the EU’s other policies) and the requirements of
the enlargement process. Furthermore, taking into account the
survey carried out among recipient NGOs and the opinion of
the departments responsible for supervising the programmes,
which found shortcomings in the publication, development
and management of the programme, the Commission pro-
poses replacing the previous Decision by a new one. This will
encompass:

— the systematic involvement of European environmental
NGOs in framing and applying Community policy;

— to assess its importance, in accordance with the Com-

— a period of 5 years to adjust to the EU’s budgets and

mission’s policy;

political agreements;

— to see whether the approach is adequate and incorporates

— calls for proposals and decisionmaking to be aligned on

the Commission’s new guidelines and objectives;

the calendar year;

— to evaluate its operation, with a view to continuing
and/or changing this line of approach, i.e. the funding of
environmental NGOs’ activities.

— an expanded geographical scope in the light of enlarge-
ment and of the association process for the countries of
south-east Europe;

1.2.
The ‘Report from the Commission to the Council and
the European Parliament on the experience gained in the
application of Council Decision 97/872 of 16 December
1997, on the Action Programme promoting European non-
governmental organisations primarily active in the field of
environmental protection’ (1) expresses the Commission’s satis-
faction with the activities, which are properly accounted for,
and with the presentation of the final reports, which clearly
specify the results of the work carried out (evaluation of budget
line B4-3060). Overall, therefore, this programme has lived up
to expectations during its period of operation.

1.3.
The Commission now considers that NGOs should
play a highly important role in relation to the new forms of

(1) COM(2001) 337 final (volume I).

— a simplified selection, monitoring and evaluation system
based on result/impact-oriented indicators which main-
tains a balance between geographical areas, small and
large NGOs, specialists and generalists, etc.;

— a fixed auditing scheme that ensures sound, transparent

and strict management of taxpayers’ money.

2. General comments

2.1.
European NGOs have shown that they are able to play
the role assigned to them by the Commission in relation to
both the promotion of new forms of European governance
and the framing and application of EU environmental policies,
as set out in the section ‘The challenge of new Governance’

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in the explanatory memorandum (1). Hence there is every
justification for a Community action programme to promote
NGOs primarily active in environmental protection.

2.2.
The proposed period of five years (2002-2006), with
an interim evaluation in 2004, along with the features of
this new programme, will make for maximum operational
effectiveness in promoting the work of these NGOs. It will also
make for more supervision, rigour and transparency in the use
of Community funds.

2.3.
The budget of EUR 32 million for the action pro-
gramme represents a significant increase over the previous
budget. Taking into account that subsidies for the activities of
environmental NGOs have increased year after year at the
expense of subsidies for awareness-raising projects, the distri-
bution between the proposed action programme and other
budget lines should not unbalance the financial support for
the activities of other organisations involved with Community
policy priorities: tackling climate change, nature and biodi-
versity, environment and health, and the sustainable use of
natural resources and management of wastes (Sixth Environ-
ment Action Programme).

2.3.1.
It should be pointed out that environmental NGOs
are not well established in some fields, basically those con-
cerned with economic and productive activity, and that other
social organisations (trade unions, employers’, farmers’ and
consumers’ associations) are better equipped to act in certain
matters (climate change, environment and health, waste man-
agement, etc.).

2.4.
At all events, the policy of financing (a) environmental
activities in general and (b) the specific activities of organis-
ations primarily committed to protecting the environment and
developing and applying Community policy, has proved its
worth.

3. Specific comments

3.1.
One of the criteria laid down in the decision — in
Article 2 b) especially — is that an NGO must have a structure
and activities covering at least three European countries.
Although this criterion reinforces the transnational character
of
limits the number of potential
beneficiaries as it is an acknowledged fact that 80 % of the
beneficiaries are always the same.

these organisations,

it

3.1.1.
The Committee would recommend that one of the
programme’s objectives should be to encourage permanent
or temporary forms of association between environmental
organisations to achieve Community policy objectives over
and above those of the programmes for financing activities
(LIFE, civil protection and environmental emergencies, etc.).

3.1.2.
Furthermore, and despite the fact that the present
action programme excludes the applicant countries so as to
avoid overlaps in its funding, the European Environmental
Networks include them. This, together with permanent or
temporary associations with other NGOs, could facilitate their
integration into the Community sphere.

3.2.
The third step of the selection and award process
(Article 5) comprises a comparative assessment of eligible
applications against three criteria set out in section 2 of the
annex:

— extent to which the application meets the objectives of

the programme;

— management and product quality;

— outreach, effectiveness, efficiency.

3.2.1.
The three key elements for an assessment of this last
point — ‘general visibility’ of the organisation and its activities,
external relations, and ‘appreciation as tracked in the public
domain (including the media)’ — leave a wide margin for
discretion, which may affect the objectives laid down in the
programme.

3.2.2.

To reduce the margin of discretion it is necessary:

— to focus exclusively on the ‘visibility of activities’ and not
on the applicant organisation so as to encourage new
organisations or new forms of association;

— to delimit clearly the idea of ‘appreciation in the media’
so as to avoid the image of NGOs being the ultimate
determinant of financial support.

3.3.
Article 6 lays down the percentages of annual subsidy,
between 70 % and 80 % depending on the case, and abolishes
‘in kind’ contributions as expenditure which counts towards a
subsidy, in accordance with the arguments put forward by the
Commission in point 2.6.4 of its report (2), on account of the
EU’s financial control regulations.

(1) COM(2001) 337 final — 2001/0139(COD) (volume II).

(2) COM(2001) 337 final (volume I).

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Official Journal of the European Communities

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3.3.1.
The smaller and less ‘professionalised’ NGOs regard
the restrictions on unpaid work and in kind gifts as ‘unbear-
able’. By not taking this aspect into account at all, the formula
presented in the document would strengthen the ‘professional’
environmental organisations to the detriment of NGOs which
survive on the voluntary work of their members and the
support of civil society through contributions which are not
necessarily monetary.

Europe’ (1), along with protection of the environment and
sustainable development — which are the objectives of
Community policy despite the ever present economic difficult-
ies — it is necessary to encourage and finance the activities
and environmental commitment of other NGOs representing
European citizens in their capacity as workers, entrepreneurs,
farmers or consumers and whose role in carrying through
environmental policies is vitally important.

3.3.2.
It is therefore reasonable to seek for formulas which,
although they may complicate management, allow in kind
contributions to be incorporated in some form into the
expenditure eligible for subsidy. This would make the appli-
cation of
the regulations more flexible when there is a
demonstrable need to maintain the voluntary element in
NGOs.

3.4.
In the event that irregularities, mismanagement or
fraud are detected, one or several administrative measures or
penalties can be imposed in proportion to the severity of the
case.

3.4.1.
Because of the seriousness of one of the measures,
namely exclusion from the relevant dialogue mechanisms of
the Commission, it would be advisable, to avoid arbitrariness
or improper use of this penalty, to delimit clearly under what
circumstances an NGO may be prevented from taking part in
democratic processes of consultation and participation.

4. Special comment

4.1.1.
For instance, meeting Europe’s Kyoto commitments
to reduce greenhouse gas emissions, reducing the use and
danger of chemicals and implementing the framework directive
on water are unthinkable without the cooperation and action
of workers and employers at the workplace. At present,
the failure to utilise organisations representing workers and
employers to boost the awareness and environmental commit-
ment of their members is a major shortcoming.

4.1.2.
The same can be said of the highly important role of
farming organisations in reducing and eliminating the use of
pesticides and consumers’ organisations in implementing the
policies for reducing and recycling urban waste.

A study should be made of

4.1.3.
the possibility of
developing a Community action programme, parallel and
supplementary to the programme under consideration here,
enabling permanent and regular support for the activities of
social organisations whose help is essential for implementing
European environmental policy, although they are not primar-
ily active in environmental protection.

4.1.
It should be noted that, in order to achieve these new
forms of governance set out in the Commission Communi-
cation on Strategic Objectives 2000-2005 ‘Shaping the new

(1) COM(2000) 154 final (OJ C 81 of 21.3.2000) and CES 1198/2000

(OJ C 14 of 16.1.2001).

Brussels, 18 October 2001.

The President

of the Economic and Social Committee

Göke FRERICHS