Source: EURLEX
Language: en
Format: md

COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 9.10.2001
COM(2001) 337 final/2

VOLUME I

CORRIGENDUM

Annule et remplace la page 2
du volume I du document
COM(2001) 337 du 22.6.2001.

**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**

**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.** **INTRODUCTION**

This Report is made by the Commission to the European Parliament and the Council in
accordance with Article 12 of Council Decision 97/872 (“the Council Decision”) on the
Action Programme promoting European environmental non-governmental organisations
primarily active in the field of environmental protection (“the Action Programme”). It is made
in the light of the experience gained by the Commission in the implementation of the Action
Programme during the first three years, 1998-2000, and the experience gained by the
beneficiaries (non-governmental organisations – “NGOs” [1] ) during the same period.

In order to collect information on the Action Programme in a systematic way, a survey was
produced, which was disseminated to all the services of the Environment DG (the Programme
co-ordinator) and to external stakeholders (present and previous beneficiaries [2] ). The aim of
the survey was twofold:

–
To compile information on how the provisions of the Programme and their
implementation had been perceived in the past by the Commission and the NGOs in
order to produce a Report for the Parliament and the Council in accordance with
Article 12 of the Council Decision.

–
To compile information on how the provisions of the Programme could be amended
to better fit the needs of the Commission and the stakeholders in case of a renewal of
the Programme. This would then require a Draft Proposal for a new Council
Decision (in co-decision procedure with the European Parliament).

The general objective of the Programme is to promote the activities of NGOs, which are
primarily active in the field of environmental protection at a European level by contributing to
the development and implementation of Community environmental policy and legislation.
The financial contributions granted under this financial instrument (covering both ‘running
costs’ and activities) are meant to enable environmental NGOs to carry out a number of
activities for the benefit of Europe’s environment and society as a whole. These NGO
activities include, among others, bringing the citizens closer to the European Union by
making EU policies comprehensible and relevant to everybody as well as the provision of
channels for feedback to the Commission of citizens’ views and concerns. Furthermore, NGO
activities contribute to the policy making process by their participation in different experts’
groups and committees and by their provision of expertise input according to their different

1 As defined in the Discussion Paper “The Commission and non-governmental organisations: Building a
Stronger Partnership” under point 1.2. “Common characteristics of a non-governmental organisation”,
COM (2000) 11, adopted on 18 January 2000.
2 Official Journal of the Communities 1999/C 32/14, 2000/C 43/04, 2000/C 293/14.

2

areas of competence. Awareness raising, by making the general public and decision-makers
aware of current and upcoming environmental problems, is also an important activity under
the Action Programme, as well as the building and strengthening of civil society [3] – mainly
within the EU, but also beyond its borders.

Three years have now passed since the Council Decision was adopted on 16 December 1997,
and the Programme co-ordinator (the Environment DG) and the NGOs have now had their say
on the implementation of the Programme during 1998-2000.

The survey contributions have been compiled and analysed by the Commission and the
findings are presented below in accordance with the structure of the Council Decision, article
by article, followed by a chapter on General Implementation and a Conclusion.

Budget line B4-3060, under which the Action Programme is financed, has been evaluated by
an external contractor during the second part of 2000. The study, which forms part of the
Environment DG's programme of evaluations within the framework of the SEM 2000
initiative [4], has examined the use of B4-3060 over the period 1996-1999 with a view to
assessing – and ultimately improving – the deployment of its funds. The findings of this study
(the parts, which are relevant to the implementation and performance of the Action
Programme [5] ) have been duly taken into account in this Report.

**2.** **SURVEY RESULTS**

**Article 1** of the Council Decision provides the objective of the Programme and defines
eligible groups - their field of activity, status and geographical scope. The general objective of
the Programme is, as stated above, to promote activities of NGOs, which are “primarily active
in the field of environmental protection at a European level by contributing to the
development and implementation of Community environmental policy and legislation”.
Eligible NGOs are those who are independent, non-profit-making with an environmental
objective aimed at the public good.

**2.1.** **Eligible groups**

The identification of organisations “primarily active in the field of environmental protection”
has not caused any major problems during the first three years of the Programme
implementation. In cases of doubt, the Programme co-ordinator and its evaluation team have
always consulted the applicant’s official statute, in which the main objective of the
organisation is outlined.

The majority of the survey replies show that both the NGOs and the Commission are in
favour of keeping the present definition. The main arguments given against expanding the
scope of eligible organisations are the limited funds available under the Action Programme,
the few available sources within the Commission for providing financial support to European
environmental NGOs, the increasing difficulty European NGOs experience in receiving funds

3 For the purpose of this Report, “civil society” is restricted to non-profit activities carried out by citizens
(the third sector).
4 In 1995, on the initiative of Commissioners Anita Gradin (Financial Control and Fraud Prevention) and
Erkki Liikanen (Budget and Administration), the Commission launched a comprehensive initiative
called SEM 2000 (Sound and Efficient Management) to change the Institution’s financial and
administrative culture. SEM 2000 applies to all Commission services.
5 A little less than 40% of budget line B4-3060 has been allocated to the Action Programme annually.

3

at national and local level, and the fact that other groups (social, development, health,
consumer and animal welfare groups, etc) are eligible for funding under other instruments.

But in one of the Commission survey contributions it is argued that NGOs active in
Environment & Health issues - a priority area of the Environment DG - are often disqualified
for funding. This should be corrected, they state.

It should be noted that some of the present beneficiaries of the Action Programme already
have activities in the field of Environment & Health as part of their annual work programmes.
But the main objective of these organisations – clearly defined in their statutes – is still to be
‘primarily active in the field of environmental protection’. An inclusion of Health
organisations would change the profile of the Programme, as this would mean accepting
applications from organisations, which are only partly active in the environmental field (such
as Health organisations). This would, of course, also open the door for other NGOs, which are
only partly working with environmental protection, such as civil protection groups, consumer
groups, etc.

The present situation, in which European environmental NGOs are invited to present their
annual work programmes - putting _all_ their activities, including salaries, rents, printing costs,
etc - in one budget with a view to obtaining a subsidy would then have to be abandoned, as
Health organisations could only present _parts_ of their work programmes, i.e. their activities in
the environmental field. The rest would clearly fall under the domain of ‘social affairs’.

**2.1.1.** **Geographical scope**

Only environmental NGOs active “at a European level” (Article 1 of the Council Decision)
are presently eligible for funding under the Action Programme. This provision is further
specified in the Programme Co-ordinator’s ‘Information Dossier’, which is provided to all
applicants together with the application forms (Annex I of this Report). According to this, the
Commission invites “European non-governmental organisations whose activities cover all or
some of the Member States and countries neighbouring the European Union” to submit
applications with a view to obtaining a financial contribution. To be operating “at a European
level” means, according to the Information Dossier, that both the structure and the activities
of a successful applicant should in principle cover several European countries.

The definition of the geographical scope has given rise to more questions from applicants
(and sometimes internally) during the period of 1998-2000 than the definition of eligible
fields of activities, but has caused few problems in the actual selection process.

However, greater concern has been raised by external actors (outside the scope of the survey)
regarding the geographical _balance_ of the organisations selected for funding under this
scheme, pointing to the fact that the majority of the beneficiaries in 1998-2000 have been
located in Western Europe. Reference to this has also been made within the survey. “A more
regional balanced distribution would be needed to secure the implementation of EU policies
in all regions within the EU”, an NGO stressed in its survey contribution, as some
environmental problems and issues connected to sustainable development (water, agriculture,
soil, etc) differ from region to region. A similar concern was also voiced by one of the
Commission survey replies, which requested the explicit mentioning of the Mediterranean

4

area as ‘eligible’ in this context. This concern was also emphasised by the results of the
evaluation of budget line B4-3060 [6] :

“Although quotas are not recommended, the EC needs to respect diversity and heterogeneity
of the NGO community. DG ENV should keep striking the balance between geographical
(north/south/east), topics (waste, water, etc.), small/large, European/transboundary,
policy/”operational” NGOs”. (Page 193)

It should be noted in this context that a number of European environmental NGOs, which are
presently beneficiaries of the Action Programme, have chosen to locate their headquarters in
Brussels for the proximity to the European institutions and other important actors in the
Environment. This does not mean that they are Belgian organisations. All NGOs selected
under the Action Programme have activities in all – or several of the EU Member States,
including neighbouring countries.

**2.1.1.1.** **Expansion of the geographical scope**

In view of a possible renewal of the Programme, the present geographical scope may have to
be reconsidered in light of the Enlargement process and the changes in Europe as a whole (for
example, in the Balkans).

The survey results clearly show that, in general, the Commission and the EU environmental
NGOs are in favour of including Candidate Countries’ NGOs under the Action Programme –
as long as the provisions for being active at a European, multinational level stays (that is,
local and national NGOs should still be ineligible) and that an increase of the present budget
can be secured. Present and previous beneficiaries of the Programme argue that they are
already carrying a heavier financial burden due to increased activities related to Enlargement
and for increasing their membership with organisations from the CEECs, which usually have

very scarce resources.

The Council Decision as it stands today does not explicitly exclude applications from
Candidate Countries’ NGOs, but the requirement for being active (as well as having member
organisations) in all – or some – of the EU Member States and neighbouring countries has
excluded most of them during the period of 1998-2000.

It should further be noted that the competition between EU-based, multinational organisations
with many years of experience in this field is already very tough for the limited funds
available under the Action Programme. This makes it even more difficult for fairly new
organisations with less ‘know-how’ and less comprehensive work programmes to receive
support – an aspect, which was also highlighted by the external evaluation of Budget Line
B4-3060 (page 152):

“the choice of larger NGOs working on a European level may mean there is a greater distance
between the NGOs and the European citizens or between the Brussels based office and NGOs
part of the same network operating at a national level. There are also fears that the new
orientations will discourage small (but not necessarily incompetent) organisations while
favouring highly-professionalised and well-organised competitors, regardless of which has the
better ideas. This is particularly damaging for transboundary projects, covering a small
number of member states, for which it is difficult to obtain funding at national level.”

6 The Evaluation of the Budget Line B4 3060 “Environmental Awareness and Subsidies”, A study for the
European Commission (DG ENV.3), Contract n° B4-3060/2000/191820/MAR/H5.

5

**2.2.** **Eligible activities**

**Article 2**, which should be read in conjunction with the Annex to the Council Decision (see
also 2.6.6 of this Report), defines what activities are eligible under the Action Programme. In
response to Point 2 of this article - on the provision of financial assistance for activities,
which are of Community interest and which “contribute significantly to the further
development and implementation of Community environmental policy and legislation” – the
major group of NGOs (the Green Group of Seven) have compiled a ‘non-exhaustive list’ of
policy areas, in which they argue to have had an impact (Annex II of this Report). Other
consulted NGOs have provided similar lists, relevant to their own area of competence.

Evidence of accomplishments of this kind is, of course, quite difficult to give as the impact on
political processes is not always easy to measure. The results of lobbying activities may come
after many years of struggle and at that point, it may not be possible to identify what actors
were crucial for what part of the outcome – and what other external and/or synergetic
circumstances had an important impact on the final result. For applications from ‘newcomers’
under the Action Programme this is even more difficult, as the Commission’s evaluators (it is
the experts of the Environment DG’s technical units, who evaluate NGO applications in line
with their area of expertise) must try and establish what potential impact the activities of an
‘untried’ organisation could have.

However, the Commission services, which frequently consult with NGOs (in committees and
experts’ groups, in ad hoc and regular meetings, as well as in international fora, on a wide
range of different issues) usually perceive NGO input as very helpful and important to the
policy-making process. This conclusion is shared by the external contractor, who carried out
the evaluation of budget line B4-3060:

“Strengthening the relationship between the Commission and NGOs can help both parties to
be more successful in achieving their respective goals. NGOs are a major partner of the
consultative process, and dialogue between the EC and NGOs is an important complement to
the institutional process of policy-shaping.” _(Page 137)_

In a couple of Commission survey replies, it has been suggested that Article 2 should more
strictly identify activities, which are related to the Environment DG’s on-going policies and
priorities. This should also apply to ‘gender mainstreaming’ and women’s activities in the
field of environmental protection, where the present link between Community environmental
legislation and women is very weak. Some also argue that the Commission should be in a
position to require successful applicants to _add_ activities to their work programmes in line
with Community environmental policy and legislation (standardisation work has been given
as an example).

**2.3.** **Selection criteria**

**Article 3**, which should be read in conjunction with the ‘Information Dossier’, details the
Programme’s selection criteria. Although the criteria may seem fairly clear – the Commission
wishes to target organisations with a wide geographical scope, a high multiplier effect, with
solid and financially feasible activities in line with Community environmental policies, in
order to reach and involve as many European citizens and actors in the Environment (local
and regional authorities, business and industry, other interest groups, etc) as possible – they
have not always been easy to apply in practice. How do you assess “a lasting multiplier effect
at a European level” or “a contribution to a multinational approach” – especially for an
applicant, which is new to the Commission evaluators?

6

In the survey, one of the consulted NGOs requested the Commission to clarify what “a sound
cost-benefit ratio” means in this context and how this ratio is measured. But in reality, there
are no fixed indictors to measure any of the above mentioned criteria. On a related theme, one
of the Commission services called for more transparency, in general, in the selection
procedure – stressing the need for making crystal-clear the reasons for exclusion. The latter
furthermore stressed that the present situation, in which quite a small number of beneficiaries
were selected for funding with relatively large amounts of money (more or less the same
organisations every year), should be justified. In the Evaluation of the Budget Line B4-3060,
a similar concern was raised:

“The key question is whether one achieves, through the selection of NGOs receiving Activity
Funding, the involvement of the wider public in policymaking. Therefore it has been argued
that the EC should seek a balance between NGOs’ knowledge of the European system and
their capacity to express people’s concerns and views. The latter is especially relevant since
the 6EAP will probably give a lot of importance to mobilising the citizens. In order to achieve
this the selection criteria could for instance be adapted to avoid institutionalisation by rotating
NGOs to be funded and not repeat funding to the same NGO in consecutive years. This would
give others, that may be more grassroots level organisations the opportunity to build up their
capacity concerning EU environmental policy and express the view of their constituencies.”
_(Page 175)_

It goes without saying that the more times you apply under this instrument – the better you get
in knowing the procedure and what it takes to become a successful applicant. It should
furthermore be noted that many of the organisations, which have been selected for funding
several years in a row, have successively worked up a relationship with different Commission
services (as well as with other EU institutions).

NGOs have pointed out that some of the selection criteria, which the Commission has added
in the ‘Information Dossier’, are not very clear. In fact, one of the consulted NGOs argues
that the “commitment to publicise as widely as possible the current environmental policy of
the European Union, including the Community Programme of policy and action in relation to
the environment and sustainable development” could be interpreted as a requirement for
passive and uncritical distribution of EU information. This organisation would like to see a
clearer reference to the helping of Europe citizens to a better _understanding_ of Community
environmental laws and programmes as well as the encouragement to actively comment on
them.

From the above observations it would seem that the present selection criteria are imprecise
and would have to be re-defined in a new Programme. It has furthermore been made quite
clear during the period 1998-2000, that making reference to the selection criteria in rejection
letters to unsuccessful applicants has, so far, not been very efficient. Many of the refused
NGOs have come back, requesting clarifications and more details. As there are no fixed
indicators how to measure this, all evaluations are in this respect somewhat subjective.

**2.4.** **Activity Funding**

**Article 4** defines the specific features of the Action Programme – financial assistance, which
is given for both activities and administrative costs of a selected NGO (sometimes referred to
as “activity funding”). The consultation with the NGOs revealed no wish to change this in
favour of another funding model. Instead, they requested the Commission to urgently address
the bureaucratic procedures and rigorous control systems involved in this exercise, which they
find disproportionate to the sums involved. In addition, they wish to make the Programme

7

compatible with project funding (see 3.1). The Commission, on the other hand, is in favour of
a model, which would limit the Programme to cover only the audited expenses of the
beneficiaries, as the inclusion of projects/activities, involving third parties, could have a
negative effect on transparency and accountability of reporting.

A ‘business as usual’ approach would hardly be possible. A proposed expansion of the
Programme to include Candidate Countries’ NGOs and NGOs of the Balkans, an increase of
the budget and limited human resources, as well as new measures introduced by the White
Paper on Reforming the Commission, would require a Programme, which takes these aspects
into account. A fixed auditing scheme would also have to be foreseen – a measure, which is
emphasised by the outcome of the Evaluation of the Budget Line B4-3060 (page 182-183):

“Audits examined in the sample clearly show that the network structure of the largest NGOs
can potentially facilitate the channelling of funds to other parts or levels of the organisation.
This poses difficulties for the transparency and accountability of reporting. -…- What is to
some extent excusable for small NGOs, which received subsidies once in the period and are
not necessarily aware of EC procedure, is certainly not for big NGOs, which receive funds
almost every year and know EU financial rules. Rigorous and transparent accounting is all the
more important for large subsidies. Towards this end the EC should impose better guarantees,
in terms of accounting rules.”

**2.5.** **Coherence, consistency and complementarity**

**Article 5** obliges the Commission to ensure coherence, consistency and complementarity
between the Action Programme and other Community programmes and initiatives.

By the nature of the selection procedure, as identified in the ‘Information Dossier’, the
Commission has mainly focused on coherence and consistency with the Fifth Environmental
Action Programme (5EAP) and its overall provisions for the integration of environmental
concerns into all major policy areas and the principle of ‘shared responsibility’ (which means
that all areas of activity, which cause environmental problems, should form part of the
solution to them). In 1998-2000, financial assistance under the Action Programme (“activity
funding”) has been granted only to NGOs whose activities meet the principles underlying the
5EAP. In short, these organisations have actively addressed the priority areas of the 5EAP manufacturing industry, transport, energy, agriculture and tourism - and have actively sought
co-operation with other actors in the Environment (local and regional authorities, business
and industry, the general public, other NGOs, etc) in the pursuit of sustainable development.

But as for ‘complementarity’ (as opposed to ‘overlaps’), Article 5 has been quite difficult to
adhere to. Although the application forms for funding under the Action Programme oblige
potential candidates to account for all other funding received from EU institutions, there is no
centralised way in which the Programme co-ordinator could possibly eliminate the risk of
overlapping funding [7] .

The ‘self-imposed’ rule of not accepting project funding applications from beneficiaries of
‘activity funding’ under the Action Programme (see 3.1) has, at least, stopped the
Environment DG from funding overlapping activities.

7 The establishment of a Contracts Data Base is presently being discussed by the Commission and such a
data base might be introduced during the implementation of a new Action Programme.

8

**2.6.** **Time frame, budget and the calculation of contributions**

**Article 6** defines the Programme length, the available budget, the rate of overall Commission
assistance and the possibility of accepting in-kind costs – up to a level of 10% of total eligible
costs, when assessing environmental NGOs’ revenue and costs.

This article has attracted more attention and longer survey replies than any other article of the
Council Decision, as it provides – together with the eligibility criteria (Article 1) – the very
basis for the Action Programme.

**2.6.1.** **Programme length**

In addition to the overwhelming majority for a renewal of the Programme displayed by both
NGO and Commission survey replies, there is also a strong desire to increase the Programme
duration from 4 years to, at least, 5 years. This would secure the continuation of NGO
activities at the European level by providing sufficient time for the NGOs to plan their
medium and – to some extent – long term strategic priorities. A decision to extend the
Programme period would also take into account the considerable work and time needed for
the legislative process to put all elements of a new Programme in place.

–
A proposal for a renewed Programme of five years, covering the period 2002-2006,
would have the benefit of following the current budget and major political
agreements already made within the EU, as well as following the same time period as
for all pre-accession funds.

–
It would also be aligned with the [Proposal for a Sixth Environment Action
Programme] [8], which sets the political framework for the next five to ten years.

**2.6.1.1.** **Multi-annual funding**

The possibility of introducing a multi-annual funding scheme has been discussed both within
and outside the scope of the survey and has quite a large number of advocates both among the
NGOs and within the Commission. Such a Programme would save administration work and
time both for the Commission (and thus reduce the overhead costs of running the Programme)
and the NGOs, as well as ensuring continuity. But it would also have other implications. A
multi-annual scheme would imply a variable annual budget, as the Commission would be
obliged to commit the full amount the first year. The Commission could, of course, elaborate
a 2 or 3 year payment schedule combined with an enhanced monitoring/assessment system,
based on interim reporting. If the Commission is not satisfied with the interim reports, it could
stop the contract and de-commit the money, but the appropriations would be lost.

Bearing in mind the limited funds available to the co-ordinating DG (the Environment DG) on
budget line B4-3060 (around 7 Million EUROS per year) for covering a wide range of
different information and communication activities (that is, not just NGO funding), a multiannual NGO funding scheme with, for example, two-year contracts, would require almost the
whole budget allocation of B4-3060 for the first year of implementation just to cover the
subsidies of the main NGOs.

8 Communication from the Commission to the Council, the European Parliament, the Economic and
Social Committee and the Committee of the Regions on the sixth environment action programme of the
European Community, ‘Environment 2010: Our future, Our choice’, COM (2001) 31.

9

**2.6.2.** **Available budget**

It is quite clear that the competition for the limited funds available under the Action
Programme has increased considerably during the period 1998-2000. In 2000, the
Commission received 66 applications (for a total amount of 8,424,406 EURO) compared to
1999 when it received 44 applications (for a total amount of 5,375,999 EURO). This
represents a 50% increase in the number of files and a 56.7% increase of the amount
requested. 18 were subsequently selected for funding in 2000 at a total of 2.56 Million EURO.

But besides the increased competition, the demands placed on the NGOs during the period
1998-2000 have also increased. The consulted NGOs highlight three main areas – in order to
support their request for a substantial increase of the budget - in their survey replies:

–
**European Governance** . In the Commission Communication Strategic objectives
2000-2005 “Shaping the new Europe”, the Commission has set itself the task of
promoting new forms of European Governance. This means, in short, giving people a
greater say in the way Europe is run and the building of new forms of partnership
between different levels of governance in Europe to make the institutions work more
effectively and transparently. In the Communication, the Commission also
acknowledges that “European citizens have little sense of ownership over the
structures that govern their lives”. The NGOs thus highlight that they play an
increasing role in bridging this gap and in assisting the EU institutions to reach
European citizens – a task, which requires additional funds.

–
**EU Enlargement.** All European environmental networks have increased their
membership, as NGOs from the Candidate Countries have joined. This has increased
the need for additional activities and co-ordination, which – in terms of costs – can
seldom be balanced by newcomers’ contributions as many of them still have very

scarce resources.

–
**Integration Process.** The integration of environmental protection and sustainable
development into all policy areas of the EU is a key demand of the EC Treaty (cf.
“Cardiff process”). This means, in short, that environmental NGOs today deal with
nearly all aspects of European policy. While welcoming this development, the NGOs
stress that the integration aspect has put an increased demand on the NGOs for a
widened expertise as they are now contacted by almost all DGs for input – and this
entails costs both for additional staff and preparation.

The reference amount for the present Programme is 10.6 Million EURO for the full
Programme Period (1998-2001). In light of the above – the increased competition for funding,
an increased workload placed on the NGOs and the fact that the first Candidate Countries are
programmed to join as full EU Members between 2003-2005 – an increase from today’s
average of 2.65 Million EURO per year may have to be considered.

**2.6.3.** **The rate of overall financial assistance**

Article 6 provides for an overall Community assistance, which should not – in principle –
exceed 50% of the budgeted activities and the administrative costs of a successful applicant.
This article has not been an easy one to adhere to for the NGOs during the period of
1998-2000 – in fact, many of them have had difficulties in finding the 50% of ‘matching
funds’, which is required.

10

One of the Commission survey contributions stresses that the phrase “in principle” leaves
room for interpretation and that it should be made clear when the 50% could be exceeded. An
example of a case where they believe that the 50% ‘cap’ should be lifted is for funding NGOs
involved in European standardisation work - as these groups would have difficulty finding
50% of ‘matching funds’ for this kind of activity.

In the survey replies, the major NGOs (G7) make reference to the discussions, which took
place before the Action Programme was adopted, highlighting the fact that the Commission
and the European Parliament agreed to go for a 60% ‘ceiling’ - but then the Council decided
unanimously to reduce it to 50%.

All NGOs (including the G7) are in favour of trying to raise the ceiling again - to 60, 75 or
even 100%. The ones in favour of a 100% ceiling stress that this is not to say that the
Commission should be obliged to give support of 100% to selected NGOs, but it would give
the Commission “the opportunity and obligation to look at the real situation, which NGOs
face and to understand their opportunities as well as their constraints better.” Other NGOs
argue that a 60% ‘cap’ would suffice, to allow for more flexibility for environmental groups
without compromising their integrity.

A flexible percentage up to 100% would in theory have been feasible up to
13 December 2000 [9] . But such a funding policy would, no doubt, raise questions of integrity
and independence. It could furthermore be argued that instead of making a 100%
contribution, the Commission could equally well launch a Call for Tenders for a business
contract, by which the Commission could specify in detail what it is looking for as well as be
the ‘owner’ of the end result. The question of independence has also been raised by the
external evaluator of budget line B4-3060:

“The sustainability of most European NGOs is generally weak. Most NGOs receiving
Activity Funding are extremely dependent on the EC and receive little from their members to
whom they should be finally accountable as they are supposed to represent them.” _(The_
_Evaluation of the Budget Line B4-3060, page 106)_, and

“core-funding to NGOs is indispensable to the EC to feed the policy process: expertise,
information channel, participation, etc. But, in no circumstance should NGOs take those
subsidies for granted and consider that they will continue endlessly. As a general rule NGOs
should in future secure more financial independence, requesting higher contribution from
their network of members.” _(The Evaluation of the Budget Line B4-3060, page 184)_

Any decision on a ceiling for financial assistance under this Programme would have to take
into account such aspects as the inclusion or exclusion of ‘in kind’ contributions, transfers of
funds to partners/subcontractors, and the eligibility or ineligibility of Candidate Countries
NGOs and NGOs of the Balkans.

**2.6.4.** **In-kind contributions**

Voluntary work is the core of all NGO activities, and consulted NGOs are thus in favour of
keeping it as one of the provisions of a new Programme. In the present Action Programme,
unpaid work or donations in kind, if properly documented, may be taken into account, up to a

9 According to the new norms for internal control (Action 78 du Livre Blanc) adopted on
13 December 2000, all Commission grants must henceforth involve co-financing. Financing up to 100%
is thus no longer an option.

11

level of 10% of total eligible costs, when assessing environmental NGOs’ revenue and costs
(Article 6, point 3 of the Council Decision). If possible, many of the consulted NGOs would
like to see this level increased.

“The restrictions on unpaid work or donations in kind are crippling for small, effective NGOs,
especially in the way in which they are interpreted. As noted for _(Question 13 of the Survey)_,
it is very difficult for bodies working at the EU or European scale to secure local or national
funds, and commercial sponsorship now tends to favour local causes. One of the few areas in
which it is still possible to secure significant support is by donations in kind, staff
secondments, donated time etc.” _(NGO survey contribution)_

But according to the financial service of the Programme co-ordinator, unpaid work or
donations in kind usually create more problems than they solve, as they are difficult to
account for and therefore do not provide a sound basis for eligible costs. They would instead
suggest a stricter definition of eligible costs and allow a higher EU contribution rate (See
2.6.3).

**2.6.5.** **Programme management**

**Article 7** provides details on the timing of the Call for Proposals (the announcement must be
made in the Official Journal before 31 January every year) and the deadline for the
Commission’s decision of organisations to be financed (31 May).

All consulted NGOs unanimously state that it would make much more sense for the
Commission to launch the Call for Proposals in the early autumn of the year _preceding_ the
grant year, and to announce the list of beneficiaries before the start of the grant year. This
would mean that the annual work programmes presented by the NGOs in their applications
would actually be funded by the grant from the Commission (thanks to an alignment with the
calendar year). As it stands now, the Commission decision is not taken until the end of May,
which usually means that funds do not arrive until August or September of the year for which
the subsidy is intended. This can create quite serious cash-flow problems for NGOs.

Such an alignment with the calendar year would also be welcomed by the Programme coordinator.

**Article 8** defines the Commission’s obligation of ensuring the success of activities carried out
by NGOs under this Programme. This involves keeping a proper monitoring system, which
allows for the Commission to make on-the-spot checks and gives it the right and duty to
recover sums, which have been improperly used. The article also defines the obligations of
beneficiaries to keep supporting documents regarding expenditure incurred during the cofinanced year for a period of five years following the last payment.

Consulted NGOs argue that the current system is too focused on accounting reports and
inspections, and too little on the evaluation of the impact of NGO activities. The control
system is too rigorous and does not correspond to the relatively small amounts of money that
are allocated to the NGOs. A reflection should be made on how to reduce the administrative
burden on the Commission in the management of this Programme, they argue.

However, in this context it should be noted that Action 81 “Strengthening the role of the DG’s
control function” (A White Paper on Reforming the Commission – Part II, Action Plan) rather
provides an _increase_ of systematic ex-post evaluations than a decrease:

12

“An Audit Capability will be created in each DG…. This function will undertake an
independent review of the use made of the budget by the DG, and undertake systems,
programme and performance reviews, and ex-post checks on activities in the field.”

The need for improved ex-post evaluations is further stressed by the results of the study of
budget line B4-3060:

“However, _ex-post_ evaluation in case of …Activity Funding is still deficient, due to lack of
staff time invested. _Ex-post_ evaluation is not currently regarded as a priority. Co-operation
with technical units should be more systematic and could be significantly improved.” (Page
131)

**Article 9** provides the measures that the Commission may take against a beneficiary in case
of irregularities or failure to respect the details of the contract. The article also provides the
obligation of the beneficiary to repay any undue payment.

No grave irregularities have been detected during the examined period 1998-2000. But in
light of ex post evaluations (final reports and internal audits), NGOs have been requested to
reimburse any discovered surpluses or ‘ineligible costs’. The calculation of eligible costs has
sometimes caused disagreement between the Commission and NGOs – quite often related to
‘in-kind contributions’ (Point 2.6.4.) – but issued reimbursement orders have always been
duly paid by the beneficiaries.

Very little has been said by the NGOs on Article 9. One NGO has requested the Commission
to respect the provisions of the Vademecum on Grant Management on allowing beneficiaries
to carry over any surplus of maximum 5% of the total income to the following grant year.

**Article 10** defines the monitoring obligation of any co-financed activity by the Commission.
In order to comply with this provision, the Commission makes random visits to selected NGO
meetings, workshops, conferences and other activities during the Programme period to see
that proposed activities are really carried out. Furthermore, the beneficiaries must provide – at
the end of the contract period – evidence of all activities carried out under this period. These
could be, for example, copies of magazines, newsletters, press releases, reports, books,
CD-ROMs, videocassettes, etc.

“Overall the rate of achievement in the activity funding sample examined is fairly good and
activities are in general well accounted for. In general, beneficiary NGOs have accomplished
most of foreseen activities and final reports clearly specify the output of their work.” _(The_
_Evaluation of the Budget Line B4-3060, page 104)_

Under its Audit Programme, the Programme co-ordinator also carries out annual audits on cofinanced NGO programmes, chosen at random from the list of beneficiaries.

Article 10 has given rise to no particular concern of the NGOs or the Commission.

**Article 11** obliges the Commission to publicise the results of the selection of beneficiaries
under the Action Programme. This article has been well adhered to during the period
1998-2000, and the results have been duly published in both the Official Journal of the
Communities as well as on the Environment DG’s web site. No comments have been made to
this article in the survey replies by either the Commission or the consulted NGOs. But an
earlier Call for Proposals and an earlier decision by the Commission on what organisations to
co-finance (as suggested in the survey) would, consequently, result in an earlier publication of
the beneficiaries – more in line with the calendar year.

13

**Article 12** defines the obligation of the Commission to report to the Parliament and the
Council on the implementation of this Programme. No comments have been made to this
article in the survey replies by either the Commission or the consulted NGOs.

**2.6.6.** **Annex – definition of areas of eligible activities**

With reference to **the Annex**, the NGO survey replies displayed an overwhelming call for it
to be reconsidered - or even deleted. This detailed, quantified description of eligible activities
creates a difficult framework for the “programme of activities”, as there are numerous
overlaps. In an oral consultation session on 16 October 2000, the NGOs described their
difficulties in placing their activities in any one group. Most activities undertaken by the
NGOs cover all – or many of - the indicated priority areas and therefore the Annex does not
help in drawing up the work programme. It should be stressed that the Annex has caused the
same difficulties for the Programme co-ordinator in evaluating applications under this
Programme, as it has been almost impossible to measure and place the activities proposed by
the NGOs under any one heading.

It has furthermore been requested in Commission survey contributions that “eligible
activities” should be more strictly related to the Environment DG’s on-going policies and
priorities.

**3.** **GENERAL IMPLEMENTATION**

From the survey results it is clear that few of the articles of the present Council Decision have
been perceived as ‘difficult to understand’ or as too ‘theoretical’. Where there have been
discussions between the Commission and the beneficiaries, they have been related to the
Programme co-ordinator’s interpretation and implementation of the articles.

**3.1.** **Incompatibility with project funding**

The rule introduced by the Programme co-ordinator not to accept project funding applications
from those organisations, which are receiving ‘activity funding’ under the Action Programme,
has been heavily criticised by some of the NGOs. The Programme co-ordinator introduced the
rule of “one NGO, one budget” in 1998 in order to secure the financial management of the
Programme, to increase transparency and to adhere to budgetary constraints. The experience
gained by the Commission in the years preceding the introduction of the rule (when ‘activity
funding’ and ‘project funding’ were still regarded as compatible) led to the decision to invite
European environmental NGOs to present _all_ of their activities in one budget once a year,
which then excluded them from applying for project funding and ‘ad hoc’ funding. Prior to
the introduction of the ‘exclusion rule’, funds for different NGO projects had been granted in
a decentralised way, which led to a situation where the sound financial management of funds
was no longer secured. The Commission ran the risk of funding overlapping activities and the
justification for this concern was later confirmed.

The NGOs, on the other hand, argue that the accounting systems of the NGOs have improved
and there is no reason to believe that beneficiaries of both ‘activity funding’ and ‘project
funding’ could not account for these sources separately and in an adequate and transparent
way. This is already being done, they say, as many beneficiaries of the Action Programme
also receive funding from other DGs and still manage to keep the different accounts
separated.

14

They furthermore argue that the ‘exclusion rule’ goes against the Vademecum on Grant
Management as the latter does not exclude ‘core funding’ beneficiaries from applying for
project grants, which is true.

However, it should be noted that the Action Programme is not a ‘core funding’ instrument in
a strict sense, as it covers both running costs and activities of a selected NGO. That is why it
is referred to as “activity funding” (see 2.4).

And as the Vademecum provides minimal Commission standards for grant management – and
thus allows individual DGs to impose stricter rules – the Programme co-ordinator has taken
this stance with reference to the above reasons.

A few Commission survey contributions have revealed that they are in favour of abolishing
the ‘incompatibility rule’ as they argue that it causes “managerial difficulties”. What happens
is that national members of co-financed European NGOs submit project applications in order
to avoid this rule - although the projects may be more closely connected to the activities of the
umbrella organisation than its national members and could be better run at a European level.

**3.2.** **Late payments**

A regular complaint by the beneficiaries of the Action Programme is related to late payments
(not only related to the timing of the Call for Proposals as described in 2.6.5.).

After the completion of a contract, NGOs are requested to provide a Final Report (accounting
for activities carried out, expenditure incurred and income received during the funded period).
This Report is usually due at the end of March. One of the reasons why final payments are
sometimes late is due to the fact that the Commission receives the final reports for the past
year during the same period as it is evaluating the applications for funding in the present year.
All Final Reports are scrutinised for any deviations to the agreed contract and the final
instalment depends on the outcome of this evaluation.

This evaluation process – covering both activities and the financial side of all completed NGO
programmes – is quite time consuming and demands the attention of a number of officials. It
is correct that the Commission during the period 1998-2000 has not always been able to
adhere to the 60 days delay foreseen in the contract.

In this context, it should be noted that the deadline set for the Final Reports has not always
been respected by the NGOs.

**3.3.** **Transfer of funds**

Another NGO concern is the strict rules governing what is actually recognised as ‘matching
funds’. The beneficiaries of the Action Programme are umbrella organisations or European
co-ordination offices for a number of national, regional and local member organisations.
These members implement activities in the framework of the (co-financed) work programme
of the European organisation. They then raise matching funds for the contribution, which
comes from the Commission. But if the matching funds are not transferred to a bank account
in the name of the Action Programme beneficiary (that is, the European organisation), it is not
taken into account.

15

This is, however, regulated by the Vademecum on Grant Management under 1.2 General
terms and conditions applicable to European Community operating grant agreements (Part B
on Financial Provisions, Article 7 – Eligible costs): “To be considered eligible, costs must … - have actually been incurred, be recorded in the **beneficiary** ’s accounts and tax
documents, and be identifiable and controllable.”

**4.** **CONCLUSIONS**

The collective experience gained by both the Commission and consulted NGOs (including all
present and previous beneficiaries), as outlined in the survey replies, indicates that the
Programme should be renewed, preferably for a period of 5 years – but with certain
modifications, such as an expansion of the geographical scope in order to include Candidate
Countries’ NGOs and NGOs of the Balkans. The evaluation of budget line B4-3060 (under
the SEM 2000 initiative), which comprises an in-depth analysis of the efficiency and
justification of this financial instrument, has been duly taken into account and the results of
this study support the conclusions of this Report for a renewal:

“Notwithstanding some inevitable failures, the completion rate of expected activities is good
overall. The usefulness of Activity Funding is evident as it better enables European NGOs to
participate in and contribute to the decision making process.” _(The Evaluation of the Budget_
_Line B4-3060, page 10)_

A renewal of the Action Programme is also supported by the [Proposal for a Sixth
Environment Action Programme], which provides for a continuation of NGO funding to
environmental NGOs in order to facilitate participation in the dialogue process.

The strategic approach of the [Proposal for a Sixth Environment Action Programme]
recognises the need for empowering citizens, and the measures proposed include extensive
and wide-ranging dialogue with stakeholders in environmental policy-making. The
Programme also foresees co-operation with environmental NGOs in the Candidate Countries
in order to raise awareness.

16

**ANNEX I**

# **Community action programme promoting non-governmental** **organisations primarily active in the field of environmental protection** **Recommendations for the presentation of proposals**

The European Commission published a Call for the submission of proposals under the
above-described programme in the Official Journal no. **C 319 of 6.11.99** . The following
recommendations are designed to help potential candidates in deciding whether to apply
and in formulating their applications.

**1.Context and objectives**

Under the terms of Council Decision No. 97/872/EC of 16.12.97 (see Annex D), the
Commission invites European non-governmental organisations whose activities cover all
or some of the Member States and countries neighbouring the European Union to present
proposals with a view to obtaining a financial contribution. This contribution would be
towards costs inherent in carrying out the activities provided for in their annual work
programme (maximum 12 months). Applicant organisations should be operating at a
European level. This means that their structure and activities should in principle cover
several European countries.

Application for funding under this Call for Proposals excludes any other application for
funding to the Environment Directorate-General.

Financial assistance under this Call for Proposals (subject to the availability of funds)
may be provided for activities which are of Community interest, contribute significantly
to the further development and implementation of Community environmental policy and
legislation and meet the principles underlying the Fifth Environmental Action
Programme.

The areas of activity eligible for Community financial assistance are defined in the
Annex to the Council Decision, which also indicates the proportion of funding which will
be assigned to each area of activity.

Beneficiaries will be selected on the basis of the criteria set out in this call for the
submission of proposals and the availability of funds. Moreover, the decisions taken will
concern 2001 and in no way represent a commitment for subsequent years.

**2. Eligibility criteria**

Consideration will be given only to proposals from organisations:

–
which are independent and non-profit-making, primarily active in the field of
environmental protection, with an environmental objective aimed at the public good;

–
which are active at a European level, (i.e. not simply at national level)

–
which have an administrative and financial management structure,

17

–
whose financial resources are not exclusively made up of subsidies from European
Union institutions.

**3. Selection criteria**

When the proposals are examined, the beneficiaries will be selected on the basis of the
following criteria:

– A sound cost-benefit ratio

–
a lasting multiplier effect at European level,

–
an effective and balanced co-operation among any partners with regard to: planning
of activities, carrying out of activities and financial participation,

–
a contribution to a multinational approach and in particular to cross-border
cooperation within the Union, and, if appropriate, extending beyond its frontiers with
neighbouring countries,

–
the capacity to promote dialogue and co-operation between the partners identified in
the Fifth Action Programme such as NGOs, small and medium-sized enterprises, local
and regional authorities, etc. in order to encourage lasting changes in the behaviour of
the parties concerned,

–
the extent of representativity within the movement concerned,

–
the capacity to favour a multisectoral approach to the environment,

–
the quality of co-operation and dialogue between the association and its members
through regular exchanges of information,

–
the capacity to demonstrate the financial feasibility of the annual programme of
activities by means of a realistic, reasonable and balanced budget,

–
the commitment to publicise as widely as possible the current environmental policy
of the European Union, including the Community programme of policy and action in
relation to the environment and sustainable development.

**4. Financial conditions**

Annex B sets out the financial conditions applicable to all types of financial assistance
given by Environment Directorate-General of the Commission. They are to be read in
conjunction with the conditions set out in the Council Decision establishing the action
programme for promoting environmental NGOs which provides that the Commission
may finance in principle up to 50% of the budgeted activities and administrative costs. If
the application is successful the Commission will co-finance a percentage of the total
eligible expenditure in accordance with the attached financial conditions (Annex B).

These conditions will form an integral part of the agreement concluded with each
beneficiary.

18

Applicants’ attention is drawn in particular to the following provision of the Council
Decision:

“In order to be able to receive a grant in excess of ECU 150,000 an NGO’s accounts for
the preceding two years must be certified by a registered auditor, and the accounts for the
period in which the grant is used must also be certified by a registered auditor. To receive
a grant of less than ECU 150,000 an NGO’s accounts must be available in a form
recognised by the Commission for the preceding two years and maintained in this form
for the period in which the grant is used.”

This means in practice that each applicant must be prepared to make its accounts
available in the required form to the Commission at very short notice once their
application has been shortlisted for funding.

**5. Presentation of a request**

The request must be drawn up in one of the official languages of the European Union,
preferably English or French, to facilitate processing the volume of requests expected,
and accompanied by an official letter explicitly requesting the subsidy. It should include
Annex A to this document, duly filled by machine (not handwritten), as well as full
details of the applicant’s bank account.

Applications should include a description of the activities of the organisation in Point 2
of Annex A. Please enclose a detailed and accurate programme of anticipated activities
for the organisation’s 2000 financial year. This should cover all activities such as:
participation in co-ordination actions between member associations, annual meetings,
information measures for members (newsletters), preparation of reports, publications etc.

Each activity will be the subject of a separate descriptive sheet including a description of
the activity in question, its objectives and target audience, indicative timetable and the
anticipated results. When drawing up applications, applicants should bear in mind the
schema set out in the annex to the Council Decision, which defines the areas of activity
eligible for Community financial assistance and indicates the proportion of funding
which will be assigned to each area.

Although the financial assistance will be granted only on the basis of the programme
planned for 2000, please also enclose a summary of activities carried out during the
previous year for guidance.

**6. Procedure for the submission and appraisal of requests**

Proposals must be submitted (postmarked) by 17 [th] January 2000 at the latest to the
following address:

European Commission
Environment Directorate-General

Saturnino Munoz Gómez

Head of Unit ENV.5

TRMF 00/74

Rue de la Loi 200

B-1049 Brussels
Tel. (0032) 2/2999332

19

All the documents required for a proposal must be sent in triplicate to the above address.
They should be presented in A4 form.

The complete proposal must be sent, in the form indicated in point 5, by registered letter.
Faxes, delivery by hand, incomplete or insufficiently detailed dossiers or dossiers sent in
several parts will not be accepted.

The procedure for the appraisal of a request is as follows:

–
receipt, recording and acknowledgement of receipt by the Commission,

–
examination by the services of the Commission,

– formulation of the final decision and communication of the result to the
applicant.

The decision of the Commission is final.

The entire procedure is strictly confidential. In the event of approval by the Commission,
a single contract covering all the activities to be co-financed (expressed in EURO) will
be concluded between the Commission and the party submitting the proposal.

Applicants should note that due to the volume of applications expected the evaluation
process will probably take several months. However, it should be completed by
31 May 2000. The expected volume of applications also means that the Commission
must be very strict in applying the selection criteria and in eliminating applications which
are not presented according to the specifications set out above. Please read carefully all
information supplied and check that you have fulfilled all the requirements. Any
omissions or mistakes could lead to your application being refused.

– ANNEXES:

A. Administrative information

–
B. Legal and Financial conditions

– C. Model of Contract

– D. Text of the Council Decision 97/872 of 16.12.1997. Official Journal L354 of

30.12.1997.

20

21

# **ANNEX A ACTIVITY FUNDING**

**Standard form for request of subsidy** _**(to be completed if possible in English or French)**_

**1. A** **DMINISTRATIVE INFORMATION RELATIVE TO THE** **APPLICANT**

10 The eventual approval of applicants by Member States may constitute an alternative to the request
for this information. p/ghu/docs/kitzmanen.doc (Rev. 3 of 10 Nov. 1998 at 12.00 hrs)

22

**1.5 Subsidies, contracts or community loans obtained directly or indirectly in the course of the**
**three preceding accounting periods from any European Community institution.**

**For each subsidy, contract or loan indicate:**

**-the Community programme concerned:**

**-the title of the project and reference n° of the contract:**

**-the year of attribution by the Commission:**

**-the amount of the subsidy, contract or loan:**

23

**1.6 Requests for subsidies presented (or which will be presented) in the course of the current**
**year to the European institutions.**

**For each subsidy/contract, indicate:**

**-the Community programme concerned:**

**-the title of the project:**

**-the amount of the contract or subsidy:**

# 2. Detailed description of the activities of the organisation to be subsidised

(the information given here will serve as the technical annex to the contract in case of agreement
to the proposal, all information essential to the realisation of the activities of the organisation
must be included). _to be drafted, if possible, in either English or French_ .

24

11 The dates of the start and end of work determine the period of eligibility of any expenditure.
12 All expenditure incurred after this date will not be eligible except where express authorisation has
been approved by the competent services.

25

|3. Provisional budget of the activities of the organisation to be subsidised (the information included here will serve as the financial annex to the contract in the case that the proposition is accepted). To be drafted if possible in English or French|Col2|Col3|Col4|
|---|---|---|---|
|3.1 Summary of the provisional budget for which the subsidy is requested, a precise breakdown of costs and the method of calculation established with the aid of the following<br>tables must be attached to this summary. The provisional budget must be balanced between receipts / expenditures;<br>The applicant certifies that the expenditure mentioned here is necessary for the implementation of the activities of the organisation to be subsidised and will be both effectively<br>incurred and registered in the organisation’s official accounts (art. 10.1.5 of the general conditions)|3.1 Summary of the provisional budget for which the subsidy is requested, a precise breakdown of costs and the method of calculation established with the aid of the following<br>tables must be attached to this summary. The provisional budget must be balanced between receipts / expenditures;<br>The applicant certifies that the expenditure mentioned here is necessary for the implementation of the activities of the organisation to be subsidised and will be both effectively<br>incurred and registered in the organisation’s official accounts (art. 10.1.5 of the general conditions)|3.1 Summary of the provisional budget for which the subsidy is requested, a precise breakdown of costs and the method of calculation established with the aid of the following<br>tables must be attached to this summary. The provisional budget must be balanced between receipts / expenditures;<br>The applicant certifies that the expenditure mentioned here is necessary for the implementation of the activities of the organisation to be subsidised and will be both effectively<br>incurred and registered in the organisation’s official accounts (art. 10.1.5 of the general conditions)|3.1 Summary of the provisional budget for which the subsidy is requested, a precise breakdown of costs and the method of calculation established with the aid of the following<br>tables must be attached to this summary. The provisional budget must be balanced between receipts / expenditures;<br>The applicant certifies that the expenditure mentioned here is necessary for the implementation of the activities of the organisation to be subsidised and will be both effectively<br>incurred and registered in the organisation’s official accounts (art. 10.1.5 of the general conditions)|
|Part A eligible expenditure/costs<br>a) Costs of personnel assigned to the activities of the organisation<br>b) Travel and subsistance costs of personnel participating in the<br>activities of the organisation<br>c) Equipment costs (depreciation only)<br>d) Durable equipment and stationary costs<br>e) Printing, publication, translation, interpretation costs (including<br>subscription, CD rom, distribution…)<br>f) Sub-contracting and/or transfer of funds to partners<br>g) Other direct costs if applicable (heating, lighting, rent etc. please<br>specify) :|(in<br>Euros)<br>…….|Part B Financing Plan<br>a) direct receipts resulting from the activities of the organisation<br>b) contribution of the applicant<br>c) contributions from other organisations (please specify)<br>**d) contribution requested from the Commission by the present application**<br>e) estimation of bank interests generated by the requested subsidy during the<br>execution period of the activities of the organisation<br>f) other contributions, if applicable, by the Commission to the same activities of<br>the organisation (please specify )|(in Euros)|
|TOTAL ELIGIBLE COSTS||TOTAL||
|Estimation, if applicable, of “in kind” contributions (1)||Estimation, if applicable, of “in-kind” contributions13||
|TOTAL||TOTAL||

13 Relates to contributions which do not generate invoices, eg :voluntary work, or free use of materials or premises.

26

**3.2 Breakdown of eligible costs by category**

**A.** **Personnel costs (ref:financial conditions art. 10.2 annexed** )

|Name|Function|Status14|Monthly salary<br>cost15|Duration<br>(in months)|TOTAL|
|---|---|---|---|---|---|
|||||||
|TOTAL I.1||||||

**B.** **Travel and subsistance costs**

|Destination of<br>the mission|Travel costs|Hotel<br>Costs|Other|Number<br>of days|TOTAL|
|---|---|---|---|---|---|
|||||||
|Total||||||

**C.** **Costs of purchase of durable equipment (depreciation)** **[16]** **(REF.ART.10.2 of**
**the financial conditions)**

|Type of equipment|Unit cost|Quantity|Eligible cost<br>(depreciation)|TOTAL|
|---|---|---|---|---|
||||||
|Total|||||

**D.** **Costs of purchase of office supplies and materials (if not included in indirect**

|costs)|Col2|Col3|Col4|
|---|---|---|---|
|_Nature of costs_|_Quantity_|_Unit cost_|_Total cost_|
|||||
|_Total_||||

14 Permanent personnel or personnel recruited for the duration of the project
15 Monthly gross salary including social security charges, excluding all other expenses.
16 Please attach the method used for the calculation of depreciation to this request

27

**E.** **Costs of printing, publication, translation, interpretation (including**
**subscription fees, CD Rom, distribution, ….)**

|Nature of costs|Quantity|Unit cost|Total cost|
|---|---|---|---|
|||||
|_Total_||||

**F.** **Subcontracting and/or transfer of funds to partner(s) (art 10.2 financial**
**conditions).**

Please indicate _:_

–
The precise name and address of any sub-contractor/partner _[17]_

–
The precise nature of the tasks that will be entrusted to that person/organisation

–
The amount and the method of calculation (fully detailed estimate) .

**TOTAL**

**G.** **Other direct costs not specified in other categories mentioned above (heating,**
**lighting, rent etc. please specify)**

|Nature of costs|Quantity|Unit cost|Total Cost|
|---|---|---|---|
|||||
|_Total_||||

**GRAND TOTAL**

17 These documents must enable the relevant services to establish the eligibility of the expenditure.

28

**3.3 Details of other sources of financing, if applicable (to the exclusion of**
**community subsidies),**

(Please complete the following information for each co-financing
company/association/organisation)

� Company or organisation’s name (complete legal name) :

� Address:

� Person responsible in the co-financing organisation (name, title or grade, tel, fax, e-mail):

� Amount which the co-financing organisation agrees to commit to the activities of the organisation
under consideration:

� Comments if the co-financing decision is not yet definite:

Declaration of the applicant :

**I, the undersigned, confirm that the information contained in the present request is correct**

**Name:**

**Title or function, representing :**

**tel:**

**fax:**

**e-mail:**

**signature:**

**date:**

29

**ANNEX B**

**General terms and conditions applicable to grant agreements of the European**
**Communities**

30

**PART** **A** **-** **LEGAL** **AND**

**ADMINISTRATIVE PROVISIONS**

**Article 1 - Performance**

1.1 Subject to cases of _force_
_majeure_, the beneficiary shall do
everything to ensure that the operation is
carried out in accordance with the
conditions and arrangements specified in
Annex I to the agreement.

1.2 Any unforeseeable and
insurmountable eventuality shall be
considered a case of _force majeure_ .

**Article 2 - Liability**

2.1 The European Communities may
not, under any circumstances or for any
reason whatsoever, be held liable in the
event of complaints deriving from the
agreement concerning damage or injury
sustained by the staff or property of the
beneficiary while the operation is being
carried out. Consequently, no claim for
compensation or repayment
accompanying such a complaint shall be
accepted by the European Communities.

2.2 Except in case of _force majeure_,
the beneficiary shall be required to
indemnify the European Communities
for any damage resulting from the
operation or from failure to carry it out
properly.

2.3 The beneficiary shall assume
sole liability towards third parties,
including for damage of any kind caused
to them by the operation.

**Article 3 - Termination of the**

**agreement**

3.1 The beneficiary may terminate the
agreement at any time by serving two
months’ formal written notice, without
being required to pay compensation. In
this event, the beneficiary shall be

entitled to payment of the grant only for
the part of the operation carried out.

3.2 The Commission may terminate
the agreement should the beneficiary,
for no valid economic or technical

reason, fail to honour one of the
obligations under the agreement and,
after being given notice by registered
letter to comply with these obligations,
has still failed to do so one month after
receiving that letter.
In that event the Commission shall pay
only the costs actually borne by the
beneficiary at the time of termination,
and no costs related to contracts already
concluded but for performance after the
date of termination.

3.3 The Commission may terminate
the agreement, without giving notice and
without paying compensation of any
kind, where the beneficiary:

is declared bankrupt, is wound up or is the
subject of any similar proceeding;

makes false or incomplete statements to obtain
the grant provided for in the agreement.

In that event the Commission may
demand full or partial repayment of
amounts already paid under the
agreement.

3.4 Termination of the agreement for
financial irregularities shall be without
prejudice to the application of other
administrative measures or penalties
which may be imposed in accordance
with Council Regulation (EC, Euratom)
No 2988/95 of 18 December 1995 on the
protection of the European
Communities’ financial interests.

**Article 4 - Confidentiality**

The Commission and the beneficiary
undertake to preserve the confidentiality
of any document, information or other
material communicated to them in

31

confidence whose disclosure could harm
the other party.

**Article 5 - Publicity**

5.1 Unless the Commission requests
otherwise, any notice or publication by
the beneficiary about the operation,
including at a conference or seminar,
must specify that the action has received
funding from the European
Communities.

Any notice or publication by the
beneficiary, in whatever form and by
whatever medium, including the
Internet, must specify that it reflects the
author’s views and that the Commission
is not liable for any use that may be
made of the information contained in
that notice or publication.

5.2 The Commission shall be
authorised to publish, in whatever form
and by whatever medium, including the
Internet, the following information:

–
the name of the beneficiary,
except where this may
jeopardise the beneficiary’s
security,

–
the purpose of the grant,

–
the amount granted and the
proportion of the total cost of
the operation accounted for by
the funding,

–
the geographical location of the
operation,

– whether the action has been
publicised before.

**Article 6 - Ownership/use of results**

6.1 Unless provided otherwise in the
agreement or its annexes, ownership,
title and industrial and intellectual
property rights in the results of the
operation and the reports and other

documents relating to it shall vest in the
beneficiary.

6.2 Notwithstanding the provisions
of the first paragraph, the beneficiary
grants the Commission the right to use
freely and as it sees fit the results
deriving from the operation, subject to
any confidentiality arrangements agreed
between them and the industrial and
intellectual property rights already
existing.

**Article 7 - Evaluation of the operation**

Where the Commission undertakes an
interim or _ex post_ evaluation, the
beneficiary undertakes to provide it
and/or the persons designated by it with
any document or information, which
will assist with this evaluation.

**Article 8 - Amendment of the**

**agreement**

8.1 Any amendment of the
agreement, including its annexes, must
be set out in a written agreement to be
concluded in the same way as the
original agreement. The parties shall not
be bound by any oral agreement on such

matters.

8.2 Where the change does not affect
the basic purpose of the operation and
the financial impact is limited to a
transfer between headings of the budget
involving an increase of less than l0% of
a heading for eligible costs, the
beneficiary may apply the change and
shall inform the Commission without
delay.

8.3 Any transfer between budget
headings involving more than 10% of
the amount of the heading to be credited
shall be subject to the prior written
agreement of the Commission.

32

**Article 9 - Jurisdiction**

The beneficiary may bring a complaint
against decisions by the Commission
concerning the application or
interpretation of the provisions of the
agreement, including its annexes, before
the Court of First Instance of the
European Communities and, in the event
of appeal, the Court of Justice of the
European communities.

**PART B-FINANCIAL PROVISIONS**

**Article 10 - Eligible costs**

10.1 To be considered eligible for the
operation, costs must satisfy the
following criteria:

–
be directly linked to the subject
matter of the agreement and be
provided for in the agreement
(Annex III);

–
be necessary for carrying out
the operation covered by the
agreement;

–
be reasonable and comply with
the principles of sound
financial management, and in
particular of value for money
and cost-effectiveness;

–
have been incurred during the
lifetime of the operation as
defined in the agreement;

–
have actually been incurred, be
recorded in the beneficiary’s
accounts or tax documents and

be identifiable and controllable.

10.2 The following direct costs shall
be eligible:

–
the cost of staff assigned to the
project, corresponding to real
salaries plus social security
charges (and other costs

making up remuneration),
excluding staff expenditure,
office expenses and other
indirect administrative
expenditure to be charged
against indirect costs. Time
spent on the project shall be
recorded on timesheets filled in
by the staff throughout the
project and certified at least
once a month by the project
head.

– travel and subsistence costs for
staff taking part in the
operation, at the rates and under
the terms normally applied by
the beneficiary;

–
purchase costs for equipment
(new or used), provided that
these correspond to normal
market costs and that the value

of the items concerned is

written off in accordance with
the tax and accounting rules
applicable to the beneficiary.
Only the proportion of
depreciation of the item
corresponding to the duration
of the operation may be taken
into account by the
Commission, except where the
nature and/or use of the item
justifies different treatment by
the Commission;

– the costs of consumables and
supplies (insofar as these are
identifiable and are not
assigned to another item of the
budget in the agreement);

–
expenditure on subcontracting,
provided that the Commission
has given advance written
agreement for subcontracting.
In this case the beneficiary shall
ensure that the terms applicable
to it under the agreement are

33

also applicable to the
subcontractors;

–
costs deriving directly from the
requirements of the agreement
(dissemination of information,
specific evaluation of the
operation, translation,
reproduction, etc.), including,
where appropriate, financial
service costs (in particular the
cost of financial guarantees),
but not including exchange
risks unless these are expressly
provided for in the agreement;

–
a “contingency reserve” of no
more than 5% of eligible direct

costs.

10.3 As a rule, a fixed percentage of
the total amount of eligible direct costs
shall be eligible as indirect costs.

– Indirect costs shall be
eligible provided they do not
include costs assigned to
another item of the budget in
the agreement.

– Indirect costs shall not be
eligible where the grant
agreement concerns the
financing of an operation
conducted by a body which is
already receiving an operating
subsidy from the Commission.

10.4 The following costs shall not be
considered eligible:

–
capital investment costs;

–
provisions for possible future
losses or debts;

–
interest owed;

–
debts;

–
doubtful debts;

–
exchange losses, except where
the agreement makes explicit
provision for them;

– contributions in kind.
(However, contributions in kind
may be taken into account
when the maximum amount of
the grant is set);

– inordinate or ill-considered

costs;

–
travel expenses, living expenses
and any form of remuneration
paid to permanent staff
employed by the European
Institutions;

–
expenditure incurred outside
the agreed period of eligibility;

–
salaries of staff employed by a
public authority.

**Article 11 - Statements of costs and**

**repayment arrangements**

11.1 The beneficiary shall, within the
agreed deadline, present a final
statement of all expenditure and revenue
actually incurred in the course of the
operation, accompanied by an
exhaustive list of the supporting
documents used to produce the
statement. These documents must be
certified by the authorised representative
of the beneficiary.

The beneficiary shall be required to
present interim statements of eligible
costs only if the agreement expressly
provides for this.

11.2 On the basis of an examination

of the final statement, and without
prejudice to the provisions of Article 13
of this annex, the Commission shall pay
the balance of the grant as provided in
the agreement. Under no circumstances

34

may the total amount paid by the
Commission to the beneficiary exceed
the maximum amount of the grant set in
the agreement, even if the total real costs
exceed the estimated total budget as set
in Annex III to the agreement.

11.3 The maximum amount of the
grant to be paid by the Commission shall
be reduced proportionately if
examination of the final statement in
relation to the total budget as estimated
in the agreement reveals that:

–
the beneficiary has obtained
interest on the part of the grant
paid as an advance;

– total revenue exceeds total
expenditure;

– revenue generated by the
operation exceeds the total
revenue shown in the budget
estimate;

–
eligible real costs are less than
shown in the budget estimate.

11.4 The amount of the grant to be
paid by the Commission shall be
reduced by means of:

– a reduction in the balance of the
grant payable on completion of
the operation;

–
a request for repayment of
overpayments made to the
beneficiary, if the total amount
already paid by the
Commission exceeds the final
amount actually due.

**Article 12 - Interest on late payment**

12.1 The Commission undertakes to
pay the amounts due under this
agreement within sixty days of the date
of the event, giving rise to payment up

to the date on which the sum is debited

to the Commission’s account.

12.2 At any time during the sixty days
following the date of the event giving
rise to payment, the Commission may
suspend this payment period by
informing the beneficiary that the
request for payment is not admissible,
either because the debt is not due or
because the necessary supporting
documents have not been produced or
because the Commission considers it
necessary to carry out further checks.
The sixty-day period shall begin to run
again from the date on which a correctly
presented request for payment is
registered.

12.3 On expiry of the time limit
specified in the first paragraph and
without prejudice to the second
paragraph, the beneficiary may, within
two months of receiving the late
payment, claim interest at the rate
applied by the European Monetary
Institute to its operations in euros plus
one and a half percentage points.

**Article 13 - Technical and financial**

**control**

13.1 The beneficiary undertakes to
allow Commission staff and persons
authorised by the Commission
appropriate access to the sites or
premises where the operation is being
carried out and to all documents
concerning the technical and financial
management of the operation. Access by
persons authorised by the Commission
may be subject to confidentiality
arrangements to be agreed between the
Commission and the beneficiary.

13.2 The beneficiary agrees to the
Commission and the Court of Auditors
of the European Communities verifying
the use to which the grant is put in
accordance with the Financial
Regulation of 21 December 1977

35

applicable to the general budget of the
European Communities, as amended,
throughout the duration of the agreement
and for five years after the date of
completion of the operation.

13.3 The beneficiary undertakes to
ensure that any subcontractors accept the
same obligation.

13.4 Controls by the Commission or
the Court of Auditors of the European
Communities may be carried out on the
basis of documents or on the spot and
shall consist of an examination of the
accounts and of all supporting
documents relating to the costs of the
operation.

**Article 14 - Repayment of the grant**

14.1 In the cases referred to in

Articles 3.1, 3.2 and 11 of this annex,
the beneficiary undertakes to repay to
the Commission, in the manner and
within the time limits set by the
Commission, any amounts which have
been paid in excess of the real eligible
costs of the operation.

14.2 In the event of termination of the
agreement in the cases specified in
Article 3.3 of this annex, the
Commission may request full or partial
repayment of sums paid to the
beneficiary. The Commission shall
determine the manner and the time
limits for such full or partial repayment.

14.3 Should the beneficiary fail to
repay such amounts within the time limit
set by the Commission, the Commission
may increase the sums due by adding
penalty interest at the rate applied by the
European Central Bank to its operations
in euros plus one and a half percentage
points.

14.4 Bank charges involved in the
repayment of sums due to the

Commission shall be borne entirely by
the beneficiary.

14.5 The recovery decision drawn up
by the Commission and transmitted to
the beneficiary owing a repayment to the
Commission shall be enforceable within
the meaning of Article 192 of the
EC Treaty, Article 92 of the ECSC
Treaty and Article 164 of the Euratom
Treaty.

14.6 Amounts to be repaid to the
Commission may be set off against
amounts due to the beneficiary under
any heading.

36

**1.2 Financial Guarantee**

(For the application of options 1 or 2 of Article 4.1 of the grant agreement, model letters of
guarantee will be inserted here by DG XIX, in agreement with the Legal Service and
Financial Control.)

37

**ANNEX C**

**GRANT AGREEMENT**

**between**

**The European Community/European Atomic Energy Community/European Coal and**
**Steel Community (“the Community”)**, represented by the Commission of the European
Communities ( **“the Commission”** ), itself represented by,

of the one part,

and _**[full legal name of beneficiary] [acronym]**_ with its registered office at ( _address [of registered_
_office - for companies and associations; of main office - for public bodies and universities], VAT_
_number and official registration number where appropriate_ ],

(“the beneficiary”), represented by ( _name and position of the signatory [in the case of legal_
_persons, the person duly authorised to act legally on behalf of the beneficiary body in relations with_
_third parties: Chairman, Director-General, Rector, Head of administrative or financial department])_

on the other part,

have agreed as follows:

**Article 1 - Subject matter**

1.1 The Commission has decided to award a grant on the terms and conditions set out in
this agreement and its annexes, which the beneficiary hereby declares it has taken note of and
accepts, for the operation entitled: “”(“the operation”).

1.2 The beneficiary accepts the grant and undertakes to carry out the operation under its
own responsibility.

A detailed description of the operation is given in Annex I, which is an integral part of this
agreement.

1.3 The operation shall be carried out mainly at []

**Article 2 - Duration**

2.1 The operation shall last for [ _insert number_ ] months from [first day of [month]after the
agreement has been signed by the last of the contracting parties _or insert date_ ] ("starting
date").

2.2 The agreement shall end on [ _insert date_ ] ("date of completion").

2.3 The beneficiary undertakes to keep all supporting documents justifying payments
made under this agreement for a period of five years for inspection purposes.

38

**Article 3 - Financing the operation**

3.1 The eligible real costs to be paid directly by the beneficiary are estimated at €. The
detailed budget of the operation is set out in Annex III, which is an integral part of this
agreement, and comprises only costs eligible for Community funding, as defined in Annex II.

[A flat rate of [no more than] 7% of the total amount of eligible direct costs shall count as eligible
indirect costs.] [18] [The terms are set out in Article 10.3 of Annex II]

–
The total cost of the operation does not include contributions in kind by the
beneficiary, which are specified separately in Annex III.

–
However, as contributions in kind were taken into account by the Commission when
it set its contribution to the operation, the beneficiary undertakes to supply these
contributions on the terms laid down in this agreement. Failure to honour this
undertaking may entail termination of the agreement as specified in Article 3 of
Annex II.] [19]

3.2 The Commission shall provide a maximum amount of € equivalent to % of the eligible
real costs (see Art. 3.3).

3.3 Should the actual eligible costs on completion of the operation, be lower than the
estimated total cost specified in paragraph 1, the Commission’s contribution will be limited to
the amount calculated by applying the above percentage to eligible costs. The beneficiary
undertakes to repay to the Commission any sums already paid in excess of this amount.

3.4 The beneficiary agrees that the grant may in no circumstances give rise to profits and
that it must be restricted to the amount required to balance revenue and expenditure for the
operation.

3.5 The beneficiary accepts that the grant does not constitute a claim on the Commission
and may not therefore be assigned to another body or transferred to a third party in any way.

**Article 4 - Payment arrangements**

4.1 The Commission shall pay the grant to the beneficiary as follows:

–
€ [ ] [ % of the amount specified in Article 3.2] by way of an advance within 60 days
of receipt and acceptance of this signed agreement and upon production of an invoice

[and a financial guarantee for an equivalent amount];

–
EUR [.....] [...% of the amount specified in Article 3(2)] within 60 days of receipt and
acceptance of an interim report and [an interim financial statement of the operation and]a
request for payment; **]**

–
The balance within 60 days of receipt and approval of the documents referred to in
point 5 and **a request for final payment** .

18 Standard clause for overheads.
19 Paragraph to be inserted where the beneficiary makes contributions in kind.

39

4.2 Payments due from the Commission shall be made to the following bank account of
the beneficiary:

–

[Insert details of beneficiary's bank account]

4.3 The Commission shall make payments in Euro. Real costs shall be converted into
Euros at the rate published in the C series of the Official Journal for the first working day of
the month in which payment is effective.

–
Exchange losses are not covered by this agreement and shall be borne by the
beneficiary.

**Article 5 - Reports and other documents**

Following completion of the operation, the beneficiary undertakes to forward to the
Commission within three months of the date referred to in Article 2.2 of this agreement:

–
A certified copy of the final statement of expenditure and revenue actually incurred in
connection with the project, presented in the same form as the initial estimate, as well as an
exhaustive list of the supporting documents used to draw up the final financial statement.
These documents must be certified by the authorised representative of the beneficiary;

–
3 copies (including at least one printed on paper) of the final report on the use made of the
above-mentioned grant.

**Article 6 - General administrative provisions**

Any information supplied in connection with this agreement shall be in writing and shall be
sent to the following addresses:

For the **Commission**

European Commission
Directorate-General [..]
Attention…

[Address]

For the **beneficiary**

[..]

**Article 7 - Final provisions**

7.1 The following documents are annexed to this agreement and are an integral part of it:

– Annex I: Description of the operation

– Annex II: General terms and conditions applicable to grant agreements of the
European Communities

– Annex III: Budget for the operation

40

7.2 Should the provisions of the annexes and those of the agreement differ, the provisions
of the agreement shall apply. Annex II shall take precedence over the other annexes.

**Article 8 - Specific terms and conditions applying to the operation**

Done at Brussels, in duplicate,

For the **beneficiary** For the **Commission**

[name of legal representative specified on the first [name of the authorising officer by
page] delegation or subdelegation]

[signature] [signature]

[date]

41

**ANNEX II**

# The Revision of the Action Program Promoting European Environmental NGOs

**General Comments by:**

**BirdLife International (European Office)**

**Climate Network Europe**

**European Environmental Bureau**

**European Federation for Transport and Environment**

**Friends of the Earth Europe**

**International Friends of Nature**

**World Wide Fund for Nature (European Policy Office**

Brussels, October 2000

42

# **Contribution to the Community environmental policy and legislation**

The Green-8 (BirdLife, CNE, EEB, FoEE, Greenpeace, NFI, T&E, WWF) have been involved in
numerous policy areas to the further development and implementation of the Community
environmental policy and legislation. Among these are [20] :

# **Type of activities**

–
Raising awareness of EU decision makers (Commission, European Parliament, Council)

–
Raising awareness among internal networks and partners (NGOs and civil society
organisations)

–
Analysis and provision of expertise to the EU institutions

–
Representation to the EU institutions

–
Co-ordination and development of policy positions

–
Identification of key policy issues

–
Information to the internal networks on main EU policies and their development.

20 This list gives only a first impression and is by no means complete. It would be much longer if one would list
all relevant activities of all environmental networks or groups.

43

# **Fields of work**

**Trade, Economics and Environment**

–
EC Trade policy and EU regional
trade agreements effects on
sustainable development in
developing countries related to
sustainable management of
natural resources

–
Definition and promotion of
Strategic Impact Assessment in
the implementation of the EC
trade policy

– Involvement in the EuroMediterranean Partnership and
MFTZ: civil forum (Stuttgart)
and parliament hearing

–
Participation to the Commission
initiative Contact group with DG
trade

– WTO: Trade and Environment

– Communication on Environment
and Employment

–
EU Employment strategy

**EU Development policy and External**
**Affairs**

– Communication on A new EC
development policy

–
Integration of environment into
EC development co-operation,
north south relations.

– Communication on environment
integration into the EC
development policy

– Communication on Tropical
Forest conservation in
developing countries.

–
Communication on Climate change in
developing countries

– Communication on Coherence

– Promoting EC co-operation
development policy

–
Participation in the Group inter sector
NGOs for co-ordination on the EC
communication on Partnership with
NGOs.

–
Participation to the EC working group
on "Grant management" conducted by
the Secretariat general.

– RIO + 10 conference: Joint initiative
with EPE, European Movement,
UNEP, ETUC, GLOBE,
ICDA,ICLEI,WBCSD

–
Co-operation with development NGO
networks to work with the working
group of the Development Council.

– Internal co-ordination of network
policy work on EU Development
policy

–
Balkan Sustainability Pact (Regional
Environmental Reconstruction
Programme)

**Mediterranean policy**

–
Euro Mediterranean Partnership

–
SMAP: Assessment and proposals for
strengthening its environmental
components

–
Environmental integration within the
Euro Mediterranean strategic
partnership.

– Effects of EU foreign direct
investment

44

– Co-ordination of the internal
networks policy work in the
Mediterranean.

–
Monitoring the development of
the Mediterranean Free Trade

Zone

**Water**

–
EU freshwater policy

– Greening EU funding for
hydrologic projects in the EU
Member States and CEECs

– Water Framework Directive:
adoption and implementation

–
Promotion of water pricing.

–
Communication on Water pricing
(input to EC conference and EU
debate, discussion paper)

–
Commission proposal on a list of
priority substances and selection
of priority hazardous substances

– Mine waste/mine waste
management and its impact in the
freshwater environment.

– Conservation and wise use of

wetlands

–
Organisation of seminars on EU
freshwater policy and the
implementation of the Water
Framework Directive.

– Internal co-ordination of
European freshwater policy
work.

**Habitats,** **bio-diversity** **and**
**biotechnology**

–
Promotion of the implementation
of the Habitats Directive

– Promotion of the establishment of the
Natura 2000 ecological network

– Observer to the Habitats Scientific
Working Group

–
Secretariat of the European Habitats
Forum (International Conservation
NGOs)

– Implementation of EC nature
conservation legislation in CEECs.

–
EC Biodiversity Action plan on
natural resources

–
Role of the EEA and the European
Topic Centre for nature conservation.

–
Environmental liability

–
Internal co-ordination of the policy
work related to habitats and species.

– Revision of the 90/220 directive on

the deliberate release of GMOs into

the environment

–
Publication "Important Bird Areas

**Agriculture and land use**

– Reform of the CAP

–
Agenda 2000

–
Cross compliance (Common rules
Regulation 1259/1999)

– Rural development Regulation
1257/1999

– Integrated rural sustainable
development

– Principles for rural sustainable
development

– Reform of CAP in 2006

–
Agriculture and trade (WTO)

45

–
Capacity building in CEECs and
Mediterranean countries on EU
agriculture and rural
development policy

– Putting Urban and Spatial
Development stronger on the
Agenda

– Internal co-ordination of the
policy work related to
agriculture.

– Participation in DG AGRI
advisory Committees

**Forests**

– EU forest certification

discussions

–
EU rural development Regulation
on forest

–
Revision of the EC Regulations
on forest fires and air pollution

–
Impact of enlargement policy on
forest

–
Eco-labelling (tissue paper and
furniture)

–
Public procurement Regulation

–
EC Biodiversity Action Plan for
implementation of the
Convention of Biological
Diversity and forest

–
Pan-European process (Helsinki
process)

–
Forest protected areas (Natura
2000)

– Climate change and forest
(negotiations on Sinks)

–
Monitoring implementation of
EU forest policy

– EU Forest and cork Advisory
Committee

–
FBI Committee (DG Enterprise)

–
Coordination for European Forest
NGOs.

**Fisheries**

–
Integration of environmental policy in
the Common Fisheries policy

–
Common Fisheries Policy review
(tax, quotas, etc)

–
Biodiversity Action Plan on Fisheries

– Reform of the Fisheries subsidies
including fuel tax and state aids

–
Structural Funds (FIFG) Regulation

– Evaluation of the operational
programmes for the implementation
of the Structural Funds for Fisheries
(FIFG)

– Access to information on subsidies:

Transparency

–
Subsidies reform in FAO, OECD and
WTO

–
Internal co-ordination of the policy
work related to marine and fisheries

issues.

**Climate change and energy**

–
Promotion of co-generated heat and
power (Co-generation), the most
efficient and environmentally friendly
of all conventional power production
technologies

–
Support to the Commission White
Paper on Renewable Electricity

46

– "Monti Directive" on minimum
taxes on energy products

–
Promote the agreement of a
Directive on Renewable
Electricity with the aim of
doubling the share of renewables
by 2010

–
Definition of a European-wide
policy for reducing residential
and office space heat
consumption

–
Increasing energy efficiency and
reduction of greenhouse gas
emissions post Kyoto in selected
sectors of European countries
(not only EU) together with
Utrecht University and the
Fraunhofer Institute.

– Promotion of fuel cells in both
transport and the stationary
power (and heat) production

sector

–
Promote solar thermal electricity
implementation as a supplement
to decentralised photovoltaic
technologies.

– Participation in global
partnership in the transport sector
– probably on mass production of
a car with a maximum of petrol
consumption of no more than 3
liter per 100 km.

–
Promotion of a clean energy label
based on third party certification;

–
Green electricity and later other
green energy products

–
Promotion of Climate change
policy work in developing
countries.

–
Energy Consultative Committee
of DG TREN

– European Climate Change
Programme working groups
(attendance at all and co-ordination of
the NGO participation

–
Green Paper on an EU emission
trading programme

– Directive on renewable energy
sources in the internal electricity
market

– Communication for an energy
efficiency action plan for the EU

– Guidelines on state aid for
environmental protection

–
Green Paper on security of energy
supply for the EU

–
Dilemma Report (DG TREN)

–
SAVE and ALTENER (DG TREN)
(response to cuts)

–
Input to the EU ad hoc group on
climate change

–
Paper on the safety of nuclear power
plants in the accession countries

**Transport, traffic and tourism**

– Commissions communication on

environment and aviation

–
Common Transport Policy review

–
TENS guidelines

–
Air quality - for example the auto-oil
programme and the daughter
directives

–
Building up an effective EU Noise
Policy

–
Advisory input - for example, expert
contribution to the GNSS advisory
forum

47

– Sustainable urban transport
Green paper

–
Road to rail, a project on
encouraging the transfer of goods
from the roads onto the rails - not
a Commission project, but
closely related to the
Community's stated goal of
saving the railways and
improving the railways

– Sustainable Tourism Policy,
Tourism and Employment

**Sustainability Processes, Dialogues and**
**Instruments**

–
Papers and presentations on the
assessment of the 5 [th] EAP.

– 6 [th] Environmental Action

Program

– Europe’s environmental
responsibility and impact of EU
policies on the world’s carrying
capacity.

–
Commission’s 5 year programme
priorities.

–
Integration Strategy

– Sustainable development
Strategy

– Transparency and Public
Participation – Aarhus
Convention

–
Access to Justice, Chart of
Fundamental Rights

–
Environment for Europe

–
Promoting the use of Structural
Funds, Cohesion Funds and PreAccession Aid for Sustainable
Development (EU legislation and
implementation on national level)

– Transatlantic Environmental
Dialogue

–
CSD, Agenda 21

–
Precautionary Principle

– OECD Liaison

**EU Institutional Issues**

– Reform of EC Institutions

– Greening the Treaty, part III:
proposals for the 2000
Intergovernmental Conference (treaty
of Nice)

–
Greening the EU budget

–
Enlargement policy and Environment

–
Agenda 2000

**Business and Industry**

–
Strategic Environmental Assessment

– Public Procurement

–
Environmental Liability White Paper

–
Reducing the Environmental Impact
of Industry

–
Participation and Contribution to the
European Forum for Recycling

–
Ecological Product Policy

–
Developing European Eco-Labels

– Phase-out of Hazardous Chemicals

– Waste Prevention and Sound

Management

–
Technical standards, setting up an
environmental standardisation bureau

48