Communication from the Commission to the Council, the European Parliament, the European Economic and Social Committee and the Committee of the Regions concerning the evaluation of the Multiannual Community Action Plan on promoting safer use of the Internet and new online technologies by combating illegal and harmful content primarily in the area of the protection of children and minors
Date: 2003-11-03
Institutions: European Commission
Subjects: EU action, Internet, action programme, child protection, data protection, new technology

COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 03.11.2003
COM(2003) 653 final

COMMUNICATION FROM THE COMMISSION
TO THE COUNCIL, THE EUROPEAN PARLIAMENT,
THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE
AND THE COMMITTEE OF THE REGIONS

concerning the evaluation of the Multiannual Community Action Plan on promoting
safer use of the Internet and new online technologies by combating illegal and harmful
content primarily in the area of the protection of children and minors

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE
EUROPEAN PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL
COMMITTEE AND THE COMMITTEE OF THE REGIONS

concerning the evaluation of the Multiannual Community Action Plan on promoting
safer use of the Internet and new online technologies by combating illegal and harmful
content primarily in the area of the protection of children and minors

(Text with EEA relevance)

Introduction

This Communication concerns the  evaluation  of  the Safer  Internet Action Plan 1999  -  2002
referred to in this communication as "the programme".

The  objective  of  the  programme,  as  specified  in  the  European  Parliament  and  Council
Decision1,  was  promoting  safer  use  of  the  Internet  and  encouraging,  at  European  level,  an
environment favourable to the development of the Internet industry.

The  programme  covered  the  four-year  period  from  January  1999  to  December  2002  with  a
reference  budget  of  25  million  euro.  The  programme  was  implemented  through  three  main
action lines:

(cid:1)  creating  a  safer  environment  (creating  a  European  network  of  hot-lines  and  encouraging

self-regulation and codes of conduct);

(cid:1)  developing filtering and rating systems;

(cid:1)  encouraging awareness actions.

During  the  years  1999  –  2002,  37  projects  were  co-financed,  involving  over  130  different
organisations. Two service contracts were concluded for advice to self-regulatory bodies and
for exchange of information about best practices2.

The Decision was amended by Decision No. 1151/2003/EC of the European Parliament and
of the Council of 16 June 20033 extending the duration of the programme until 31 December
2004, increasing the indicative budget by 13.3 million euro and making a number of changes
to the title and scope of the programme and to its implementing actions.

The  Decision  as  amended  provides  in  article  6(4)  that  at  the  end  of  four  years,  the
Commission  shall  submit  to the  European  Parliament,  the  Council,  the  European  Economic
and Social Committee and the Committee of the Regions, once the committee referred to in
Article  5  has  examined  it,  an  evaluation  report  on  the  results  obtained  in  implementing  the

1

2

3

Decision no 276/1999/EC of the European Parliament and of the Council of 25 January 1999 adopting a
Multiannual Community Action Plan on promoting  safer  use of the Internet by combating illegal and
harmful content on global networks (OJ L 33, 6.2.1999, p. 1).
see the www.selfregulation.info and www.saferinternet.org Web sites.
OJ L 162, 1.7.2003, p. 1.

2

                                                
action  plan.  The  Commission  may  present,  on  the  basis  of  those  results,  proposals  for
adjusting the orientation of the action plan.

The  evaluation  was  carried  out  by  Technopolis  Ltd  (UK)  contracted  on  the  basis  of  public
invitations  to  tender  issued  by  DG  Information  Society  in  July  20024.  The  evaluation  was
conducted  in  the  period  January  to  June  2003.  The  evaluation  report  is  annexed  to  this
Communication.

Evaluation objectives

The  evaluation  assessed  the  following  specific  issues:  relevance  of  the  programme's
objectives,  priorities  and  means  of  implementation,  the  effectiveness  and  impact  of  the
programme,  its  efficiency  and  cost  effectiveness,  its  utility  and  sustainability,  causal  links
from resources used through to activities and  presumed impacts  (the  intervention  logic)  and
lessons to be learnt for possible future interventions of a similar type.

Key evaluation findings

The  evaluators  recognised  the  positive  impact  of  the  current  programme,  particularly  in
fostering networking and providing a wealth of information about the problems of safer use of
the Internet and their solutions.

The extension to the programme for 2003 - 2004 takes into account many of the conclusions
which  arose  from  the  evaluation.  The  reorientation  of  the  Action  Plan  in  this  extension  is
firmly supported by the results of the evaluation, particularly the concentration on additional
forms  of  content,  such  as  racism,  and  the  introduction  of  actions  targeted  at  new  forms  of
communication such as peer-to-peer and 3G mobile phone technology.

Detailed findings

More specifically it was concluded that:

Stakeholders  agree  that  the  programme's  original  objectives,  priorities  and  means  of
implementation still apply, and that the action lines are appropriate mechanisms for the
fulfilment of the objectives.

The evaluators conclude that the European networking of the hotlines is extremely important.
The  programme  has  done  a  good  job  in  producing  a  number  of  filtering  software  products
although take-up of rating needs to be increased and not all stakeholders agree that filtering is
the  best  approach  to  child  protection.  Awareness-raising  remains  an  important  focus.  The
developments  in  relevant  societal,  regulatory  and  technical  areas  have  been  taken  into
account. The programme is  actively integrating itself with other  community activities at  the
policy level.

At the policy level, the programme has been successful in putting the issues of developing a
safer Internet firmly on the agenda of the EU and the Member States. The foresight of the
European  Commission  in  identifying  these  issues  early  on  in  the  development  of  the
Internet should be recognised.

4

OJ S 133-103748, 11.7.2002.

3

                                                
At action-line level, the Commission has instigated the development of a network of hotlines
in  Europe  with  associated  members  in  the  US  and  Australia,  funded  research  into  tackling
awareness-raising with a variety of end users, stimulated the development of filtering, taking
into  consideration  the  cultural  and  linguistic  diversity  of  Europe  and  supported  the
development  of  an  international  rating  system.  The  impact  of  some  projects,  particularly
filtering, will still take time to assess properly.

The EC style of project bringing together a range of organisations from different cultures and
national  backgrounds  is  particularly  useful  on  this  type  of  programme  and  produces
networking and knowledge oriented impacts.

The  programme  has  been  successful  in  linking  up  stakeholders  to  produce  a  'community  of
actors', although there should be greater involvement of industry as well as self-regulation
organisations and consumer groups.

Recommendations

The  evaluation  report  makes  a  number  of  recommendations  under  the  following  headings:
Relevance;  Effectiveness  and  Impact;  Efficiency  and  Effectiveness;  and  Utility  and
Sustainability; here follows the Commission’s reactions to the main recommendations

Relevance

1  Recommendations:  Extend  emphasis/objectives  to  encompass  new  and  emerging
communication technologies that will in particular influence children's use of the Internet (e.g.
3G  mobile  telephones).  Review  the  Action  Line  on  filtering  and  rating.  Continue  to  move
towards networks of nodes for awareness-raising in the Member States.

Commission comment: Dealt with in the 2003 - 2004 second phase of the programme. This
specifically extends the programme's coverage to include new technologies such as 3G mobile
telephones , moves the focus of funding in the area of content filtering towards benchmarking
of filtering software and services so as to provide objective information for end users, and sets
up a European network of nodes for awareness-raising.

2  Recommendation:  The  problems  associated  with  trying  to  achieve  a  safer  Internet  are
global.  The  Commission  should  continue  to  engage  with  actors  external  to  the  European
Union.

Commission  comment:  The  Commission  will  use  the  Safer  Internet  Forum  in  the  2003  -
2004  second  phase  of  the  programme  as  a  platform  for  contacts  external  to  the  European
Union. Network co-ordinators will have international relations among their tasks.

Effectiveness and Impact:

3. Recommendation: The programme should encourage wider involvement of ISPs and other
relevant industry players.

Commission comment: The Commission agrees. Hotlines already have strong industry input.
The  current  awareness  projects  which  are  using  a  "node"  approach  have  been  successful  in
attracting  industry  support,  and  this  approach  will  be  generalised  through  networking

4

awareness actions in the next round of projects in 2003 - 2004. The Safer Internet Forum will
include among its members ISP and other relevant industry players.

4. Recommendation: A wealth of information and material has already been produced within
the projects and should be made widely available.

Commission comment: The Safer Internet Action Plan official web site provides information
of the programme and links to the main projects web sites. Additionally, the saferinternet.org
Web  site  gives  "one-stop"  access  to  the  project  results.  This  will  continue  as  a  task  for  the
awareness network co-ordinator.

5. Recommendation: Consideration should be given to reviewing the existing instruments in
light of the dynamic nature of creating a safer Internet.

Commission  comment:  The  main  representation  which  the  evaluators  received  about  the
current instruments came from non-governmental organisations (NGOs), and were directed at
the co-funding rule. Co-funding is required for good reasons: it increases the project's budget
resources, it demonstrates the commitment of the contractor and the support the contractor has
in its local community (where the co-funding is raised from other sources than the contractor's
own resources) and it is an indicator of the sustainability of a project.

6. Recommendation: The programme should focus where it is likely to have the most impact
which is at the European/International level through networking and multipliers.

Commission comment: Agreed, this is the thinking behind the approach taken in the 2003 -
2004 phase of the programme.

Efficiency and Effectiveness:

7.  Recommendation:  The  European  Commission  should  review 
procedures in order to harmonise the approach with the types of projects to be funded.

the  administrative

Commission  comment:  The  Commission  is  bound  to  use  the  instruments  provided  and  to
administer them in accordance with the legal basis decided by the Community legislator. The
procedures  are  designed  to  ensure  proper  monitoring  of  projects  and  use  of  the  European
taxpayer's money.

8.  Recommendation:  The  Action  Plan  should  address  how  it  is  going  to  reconcile  funding
new hotlines in Candidate countries as well as existing hotlines on the same budget.

Commission comment: The budget for hotlines in 2003 - 2004 has been increased, in a way
that it should permit  continuation  of funding of the  existing hotlines  and  the  launch  of  new
ones in acceding countries.

9. Recommendation: There  should  continue  to  be  a  market  watch  on  issues  relating  to  the
law, regulation and codes of conduct.

Commission comment: These issues will be covered under the Safer Internet Forum

5

Utility and sustainability

10. Recommendation: The Commission should substantially review the implementation and
support mechanisms proposed for any future actions in this area. Specifically, the Action Plan
needs  to  address  issues  of  the  sustainability  of  the  hotlines  and  have  a  more  appropriate
funding model for them particularly in light of enlargement.

Commission comment: The Commission is particularly conscious of the need to ensure that
the  investment  already  made  in  safer  use  of  the  Internet  continues  to  bear  fruit  and  that
maximum European value-added is obtained in any further action in this area by encouraging
networking of initiatives in Member States.

CONCLUSION

The Commission takes note of the findings and recommendations of the evaluation report on
the  programme.  In  the  light  of  the  Commission’s  responses,  it  invites  the  European
Parliament, the Council, the European Economic and Social Committee and the Committee of
the Regions to:

(1) 

(2) 

Continue  their  support  for  the  role  of  the  programme  in  promoting  safer  use  of  the
Internet and new online technologies during 2003 - 2004;

Continue  an active debate on combating illegal  and  harmful  content  primarily  in  the
area of the protection of children and minors.

6

ANNEX

Final Evaluation of

the Safer Internet Action Plan

Final report

Conducted for the European Commission

Technopolis Ltd

June 2003

7

1.

1.1

EXECUTIVE SUMMARY

5:

Background

This document is the final report of the final evaluation of the Safer Internet Action
Plan  (IAP).  The  analysis,  conclusions  and  recommendations  put  forward  by  the
evaluators are based on information gathered from source documents of the Internet
Action Plan and its projects, telephone interviews with key stakeholders, attendance
at  a  number  of  key  IAP  events  and  a  survey  of  the  project  participants.  Nine  case
studies were also conducted. These covered eight projects (the brief was to undertake
six, but the structure of the hotlines meant that it was more interesting to look at the
“umbrella” hotline project and in addition, a selection of those hotlines funded under
the  umbrella  or  associated  with  it)  and  3  analogous  projects  external  to  the
programme.

The evaluation findings will largely be used for accountability purposes, with a focus
on  the  achievement  of  the  Safer  Internet  Action  Plan  objectives  as  set  out  in  the
Decision and in the 1999-2002 work programme, its impact and cost-effectiveness.

The specific issues to be evaluated were set out as follows :

relevance of the Action's objectives, priorities and means of implementation

the effectiveness and impact of the Action

its efficiency and cost effectiveness

its utility and sustainability

causal  links  from  resources  used  through  to  activities  and  presumed  impacts  (the
intervention logic)

lessons to be learnt for possible future interventions of a similar type.

The study aimed to come up with meaningful conclusions on the overall performance
of  the  programme  with  regard  to  all  the  relevant  points.  Taking  into  account  the
important  activities  of  the  European  Commission  in  this  field,  it  aimed  to  provide
solid  and  pragmatic  policy  recommendations  on  the  basis  of  the  findings  of  the
evaluation and the input of all the stakeholders involved in the project.

1.2

The Safer Internet Action Plan

The aim of  the Safer  Internet Action  Plan was  to ensure  the  implementation  of  the
various European Union initiatives dealing with illicit or inappropriate content on the
Internet..To  this  end,  the  Action  was  designed  to  support  non-regulatory  initiatives
for promoting safer use of the Internet.

The Decision establishing the Action set out a number of measures grouped into four
Action Lines

5

Full report available at http://europa.eu.int/iap

8

                                                
1.

Creating a safer environment

creating a European network of hotlines

encouraging self-regulation and codes of conduct

2.

Developing filtering and rating systems

demonstrating the benefits of filtering and rating

facilitating international agreements on rating systems

3.

Encouraging awareness actions

preparing the ground for awareness actions

encouraging implementation of full-scale awareness actions

4.

Support actions

assessing legal implications

coordination with similar international initiatives

The  overall  funding  for  the  Safer  Internet  Action  Plan  was  €25  million  over  the
period 1999-2002.

Within the Action Lines, the programme had three main types of activity

(cid:1)  Support for projects, generally in the form of financial support of a proportion of
the  costs,  usually  involving  some  element  of  transnational  partnership.  The
duration of the projects varied but was generally between one and two years.

(cid:1)  Service  contracts  –  100%  funded  activities  in  support  of  the  Action  Plan  let  to

external organisations.

(cid:1)  Support Actions aimed  at the  overall  objectives  and  mainly  promoted  or  carried

out by the Commission itself.

The  projects  naturally  represent  most  of  the  expenditure  under  the  Safer  Internet
Action Plan.

1.3

Main conclusions and recommendations

The results of the evaluation are presented in full in Chapter Five of the report. The
following gives an overview of the main conclusions and recommendations.

During  the  course  of  this  evaluation,  the  process  of  approving  the  extension  to  the
Safer Internet Action Plan has been under way. This was approved by the European
Parliament (voting on 11 March 2003)  and the  Council  (voting  on  26  May  2003)6.
The extended Safer Internet Action Plan includes measures to encourage exchange of

6

OJ L 162, 1.7.2003, p. 1.

9

                                                
information  and  co-ordination  with  the  relevant  actors  at  national  level,  and  has
special provisions for accession countries. Actors in the  field of self-regulation will
be brought together through a Safer Internet Forum, modelled on the EU cyber-crime
forum.  The  extended  Action  Plan  covers  many  different  types  of  illegal  content  or
conduct including racist material, and takes account of new online technologies such
as  mobile  and  broadband  content,  online  games,  peer-to-peer  file  transfer  and  all
forms  of  real-time  communications  such  as  chat  rooms  and  instant  messages.  The
networks of hotlines continue to be key instruments of the programme, alongside the
benchmarking of filtering software and the development of awareness nodes.

This extension to the Safer Internet Action Plan already takes into account many of
the conclusions which arose from the evaluation, and thus have not been reiterated in
our  recommendations,  which  focus  rather  on  other  issues  or  on  any  future  action
following the current extension. However, the reorientation of the Action Planned in
this  extension  is  firmly  supported  by  the  results  of  the  evaluation,  particularly  the
concentration on additional forms of content, such as racism, and the introduction of
actions targeted at new forms of communication such as peer-to-peer and 3G.

1.3.1

Relevance

Conclusions

(cid:1)  There was general consensus from stakeholders and participants that the Action’s
original objectives, priorities and means of implementation still apply and in some
cases are more of an issue now than at the start of the Action Plan.

The Action Lines were considered to be appropriate mechanisms for the fulfilment of
the objectives.

(cid:1)  There was a wide range of opinions from stakeholders and participants as to what
should (and could) be covered by the Action Plan given the resources available to
it.

(cid:1)  The  European  networking  of  the  hotlines  was  considered  to  be  extremely

important by those interviewed.

(cid:1)  In terms of filtering software, the Action Plan has done a good job in producing a
number  of  products.  However,  there  were  some  views  that  this  was  a  limited
approach  to  the  problem  and  also  that  they  have  not  yet  had  enough  uptake,
particularly the rating.

(cid:1)  There was broad agreement that awareness-raising remains an important focus for
the  Action  Plan  but  that  the  focus  of  awareness-raising  activities  should  be  on
education.

(cid:1)  The  developments  in  relevant  societal,  regulatory  and  technical  areas  have  been

taken into account through the projects funded under the Action Lines.

(cid:1)  In  terms  of  complementarity,  the  programme  is  actively  integrating  itself  with

other community activities at the policy level.

10

(cid:1)  Stakeholders  stress  that  the  problems  associated  with  trying  to  achieve  a  safer
Internet  are  global  and  there  should  be  continued  effort  to  engage  with
markets/providers external to Europe.

Recommendations

Continue to monitor and react to the fast changing environment ahead of the game.

Extend  emphasis/objectives  to  encompass  new  and  emerging  communication
technologies  that  will  in  particular  influence  children’s  use  of  the  Internet  (e.g.  3G
mobile telephones).

Recognise  the  global  nature  of  the  provider  base/problem  and  continue  to  engage
with actors external to the European Union including the Candidate countries, Russia
and the Ukraine.

Review the Action Line on filtering and rating.

Continue  to  move towards networks of nodes for  awareness-raising  in  the  Member
States.

1.3.2

Effectiveness and Impact

Conclusions

There was consensus  from the stakeholders  that  the  Safer  Internet  Action  Plan  had
contributed  significantly  to  putting  the  issue  on  the  Agenda.  In  simple  terms  a
number of actions exist that did not exist earlier.

The  respondents  highlighted  a  number  of  specific  impacts  that  have  occurred  as  a
consequence  of  the  Safer  Internet  Action  Plan,  the  majority  being  network  and
knowledge oriented.

In  the  case  of  hotlines,  although  the  establishment  of  the  network  was  already
happening under the Daphne programme, the proliferation of new hotlines has been
achieved in almost all Member States (with the exception of Portugal and currently
Luxembourg).

Although filtering was already happening in the US, Europe had very few examples
at the start of the Action Plan. There  are  now  multilingual,  multicultural,  European
filtering  solutions.  For  rating  there  was  no  standard  classification  such  as  ICRA
which includes over 40 different content categories.

However, wide spread implementation of filtering and  rating remains an  issue. The
Action Plan has successfully produced a number of outputs that need to be translated
into impacts. This is not a static area and new solutions may be required in the future
to meet the challenges of new technologies – however, there is scope for these types
of activities to be done through shared cost R&D projects.

If the  Action  Plan had  a weakness  in  its  implementation,  stakeholders  felt  that  this
was the involvement of industry. Also the communication across the different Action
Lines appeared to be weak.

11

The EC style of project which brings together a range of organisations from different
cultures and national backgrounds is particularly useful on this type of programme as
it  allows  shared  experience  and  good  practice  as  well  as  assisting  those  countries
with lower Internet penetration to anticipate future problems and legislate for them.
There  also  needs  to  be  more  involvement  of  self-regulation  standards  in  Member
States and consumer groups.

A  wide  range  of  different  stakeholders  have  been  effectively  targeted  by  the  Safer
Internet Action Plan:

–  At  the  policy  level,  the  Action  Plan  has  been  successful  in  putting  the  issues  of
developing  a  safer  Internet  firmly  on  the  agenda  of  the  EU  and  the  Member
States.

–  At industry level, the Action Plan has successfully involved a number of ISPs and
content  providers  in  being  more  responsible  for  a  safer  Internet.  However  there
are still countries where ISPs have little involvement.

–  At the legal and advisory level, the Action Plan  has linked up with stakeholders
through the projects and through national committees. There are numerous active
links with national police forces and with agencies such as Interpol and Europol.

At  the  intermediary  and  multiplier  level,  the  Action  Plan  has  been  successful  in
linking up these organisations with the other stakeholders to produce a ‘community
of  actors’.  The  programme  is  experiencing  a  much  wider  input  from  national
stakeholders than previously noted at the intermediate evaluation stage.

Recommendations

The  programme  should  continue  to  encourage  the  involvement  of  ISPs  and  other
relevant  industry  players,  particularly  in  EU  Member  States  (and  Candidate
countries) where there is currently little participation.

The programme should take note of the wealth of information and material that has
already  been  produced  within  the  projects  and  other  actions  and  make  it  widely
available.

Consideration  should  be  given  to  reviewing  the  existing  instruments  in  light  of  the
dynamic nature of creating a safer Internet.

The programme should focus where it is likely to have the most impact which is at
the European/International level through networking and multipliers.

1.3.3

Efficiency and effectiveness

Conclusions

(cid:1)  The funding model for the projects is not well adapted to the types of projects that
have  been  funded  under  the  Safer  Internet  Action  Plan.  The  three  main  Action
Lines  have  very  distinct  delivery  mechanisms  that  do  not  fit  with  the  typical
model of R&D funding.

12

(cid:1)  The value of the review process was considered to be high by the majority of the
indication  from  project
participants  responding.  However, 
participants  that  the  reviewers  appeared  to  be  ill  prepared  at  the  start  of  the
programme – although this seems to have improved.

there  was  an 

(cid:1)  From the case study interviews there appears to be some issues with large project
consortium  in  terms  of  efficiency.  This  particularly  related  to  awareness-funded
projects.

(cid:1)  However, the experience of the projects in forming transnational partnerships was
generally favourable. Many of them were working with organisations they already
knew, but a significant number of new contacts were made. A particular feature of
the Action Plan has been the bringing together of disparate organisations such as
child protection NGOs and software development houses and ISPs – organisations
with very different aims and cultures.

(cid:1)  In terms of value for money, the stakeholder interviews indicated that the hotlines
are seen to have been a good investment. The filtering projects are less universally
supported  –  the  final  judgement  can  only  be  made  once  the  issue  of  take-up  is
clear, which is not yet the case. For the awareness projects the judgement is even
more  fragmented  and  varies  from  project  to  project.  In  terms  of  the  external
project reviews, the general view has been favourable. Again, the real value will
be in terms of the impact of the work, which has not yet been realised.

Recommendations

The European Commission should review the administrative procedures  in order to
harmonise the approach with the types of projects to be funded.

The Action Plan should address how it is going to reconcile funding new hotlines in
Candidate countries as well as existing hotlines on the same budget.

There should continue to be a market watch on issues relating to the law, regulation
and codes of conduct.

1.3.4

Utility and sustainability

Conclusions

(cid:1)  The rationale underpinning the action is still relevant:

– 

– 

There continue to be new technological developments in communication,
new platforms and more methods of exchanging illicit information.

Governments, both national and International are  continuing to promote
the  wider  uptake  of  the  Internet  as  key  to  economic  growth  and  to
society.  Therefore  more  adults  and  children  will  have  access  to  the
Internet.

There is not a consistent approach to the creation of a Safer Internet at the Member
State level and coordination of activities also varies enormously.

13

Evidence  suggests  that  many  of  the  hotlines  would  have  gone  ahead  regardless  of
funding from the European Commission, although they would have been set up more
slowly.  However,  the  international  networking  of  hotlines  is  crucial  to  their
effectiveness.

The foresight of the European Commission in identifying these issues early on in the
development  of  the  Internet  should  be  recognised.  They  have  instigated  the
development of a network of hotlines in Europe with associated members in the US
and  Australia,  they  have  funded  research  into  tackling  awareness-raising  with  a
variety  of  end  users,  they  have  stimulated  the  development  of  filtering,  taking  into
consideration the cultural and linguistic diversity of Europe and have supported the
development of an International rating system.

The  issue  needs  to  be  addressed  at  an  international  level,  as  well  as  by  Member
States. There is therefore a clear justification for continuing the activity begun under
the Safer Internet Action Plan.  However,  this  does not mean that it has to fund the
same issues or use the same instruments.

Recommendations

The  Commission  should  substantially  review  the  implementation  and  support
mechanisms proposed for any future actions in this area.

Specifically,  the  Action  Plan  needs  to  address  issues  of  the  sustainability  of  the
hotlines and have a more appropriate funding model for them particularly in light of
enlargement.

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