3 October 2000

Fern’s comments on “a comprehensive strategy to integrate environmental and sustainable development into EC development policy”.

General comments:

·         Fern welcomes the possibility given to environmental NGOs to comment on the draft annotated outline on “a comprehensive strategy to integrate environment and sustainable development into EC development policy”. DG Development’s consultation process with NGOs is more open than that of most other DGs, creating the basis for improved dialogue in the future. This consultation should continue and ideally be expanded to environmental and social NGOs in the South.

·         Fern believes that environmental integration into all EC policies is absolutely fundamental to create a healthy and sustainable society within Europe and  -because of Europe’s footprint-, outside Europe as well. The EC’s draft development policy is therefore very disappointing as it does not integrate environment into development and does not acknowledge the importance of a healthy environment for sustainable economic and development cooperation[1]. It is unclear to us how this strategy will influence the EC’s development policy.

·         The impact of other EC policies, such as agriculture and EU trade policies, arguably have a larger impact on countries in the South than EC development policies. The Council therefore rightly states that it is essential to ensure coherence “when integrating the environment and sustainable development into economic and development co-operation and other policies of the Community and the Member States which affect developing countries”. This paper does not stress the need for environmental integration into other policies affecting development co-operation.

·         Capacity building in the South to ensure partner countries can and will integrate environmental issues into their policies and practices via an all inclusive stakeholder process, including NGOs, local communities and indigenous peoples is essential. Unfortunately there are several countries in the South (and North) where such a stakeholder process is not possible as in some countries civil society is not allowed to express its views. Clear examples are Burma and the DR Congo; but also in countries like Malaysia and Cameroon discussions on fundamental issues such as land rights or access to resources are taboo. It is therefore essential that the EC implements its commitment to democratisation by initiating direct dialogue with civil society actors thereby providing partner governments with a positive example of partnership with civil society and by ensuring the development and implementation of plans and projects is based on an all-stakeholder participation.

Specific comments on the outline paper:

Under point 3:

• This section should recognize the fact that the largest -and often- negative environmental and social impacts come from large projects such as transport or other infrastructure projects. As the EC is one of the largest donors in the world and the size of its grants is relatively large, there is a greater potential for negative impacts.

Under point 4:

• Not only environmental but also social costs should be quantified. Indeed in the forestry sector there are case studies that demonstrate that the social costs of destroying a forest -by forcing people to buy food and materials- for the most marginalized groups are often large. These costs are seldom acknowledged.

• The Commission delegations should engage in dialogue and partnerships not only with government representatives, multilateral organisations and northern NGOs but also with local NGOs, Indigenous Peoples Organisations and community representatives. This partnership should span the whole process of development cooperation from policy dialogue, through programming and project implementation to evaluation and monitoring. This will enable the Commission to better quantify the environment and social costs of economic and development co-operation; facilitating integration of environment concerns in future development plans.

• 4.1.2 (1) Trade. The EU's Sustainability Impact Assessment clearly shows that the outcome of a new trade round as envisaged by the EU is less positive for developing and least developed countries than for the EU itself. The report states that welfare losses might be experienced and significant social and environmental impacts may occur. The SIA although a worthy exercise that should be applied to all of the trade negotiations of the EU is still weak. The methodological basis for the SIA is still strongly biased towards the economic aspects and the other two pillars of sustainability, namely environmental and social aspects, need to be further developed. Furthermore the criteria used for the analysis are often inappropriate to measure the full impact on developing countries and environment indicators are end of cycle[2].

• 4.1.2 (1) It should be clearly stated that Multilateral Environment Agreements are on an equal footing to the WTO trade agreements and other bilateral and regional trade agreements currently under negotiations. Furthermore it should be made clear that national and international environmental legislation is not treated as technical barrier to trade. A recent APEC study on non tariff measures in the forestry sector lists many environmental protection measures such as forest certification and labelling schemes and required recycled content as potential technical barriers to trade.

• 4.1.2 (1) It is clear from the EC's SIA and other trade reports including the WTO's report on trade and environment that many countries lack effective environmental and social policies. This results in trade liberalisation often having a negative environmental and social impact. Actions to help developing countries implement these legislations and policies are necessary especially as EC development cooperation is increasingly becoming more economic and trade related.

• 4.1.2 (2). Regional integration is one of the main priorities of the Cotonou agreement and is seen as the first step towards new FTAs (free trade agreements) between the EU and ACP countries. Even if there are social and environmental clauses in these agreements that provide the basis for greater environment and social protection in the FTAs, the EU-Mexico agreement shows these clauses are insufficient to strengthen the sustainable management of natural resources and protect human rights. The integration of environment into economic and development co-operation should not be made subservient to trade priorities.

• 4.1.2 (4) Transport. The construction of roads is, according to CIFOR[3], one of the most important underlying causes of forest loss. It is therefore  imperative for this sector that full and proper environmental and social impact assessments are carried out prior to the approval of new infrastructure programmes. The environment strategy should make a clear requirement for EIAs and SIAs especially for infrastructure as one of the focal areas of EC development co-operation.

•  4.1.2 (6) Institutional capacity building. Support to civil society organisations is important, as is direct communication with these groups. Proper consultation with these groups in the development and implementation of all projects is essential. In this context it is important that the Council Resolution on Indigenous Peoples is mentioned and in particular its emphasis on the right for self determination in development co-operation for Indigenous Peoples.

• 4.2. A clear link should be made between relief aid and broader development co-operation. Often there is insufficient communication between different departments in charge of these two different types of aid. Environmental integration should be part of both.  Proper integration of environmental concerns in relief and rehabilitation efforts will facilitate the transition to sustainable development. Ways to implement this in practice should be further discussed with relief agencies and ECHO.

Under point 5

• What are PRSP and CDFs ?

• Environment integration needs to go further than programming and should be implemented in mainstream development projects and also be included in the evaluation and monitoring work of the EC.

Under point 7

• It would be useful to create an expert group on forests. Not only because forests are a cross cutting issue but also because of the importance of forests, for forest peoples ­often the most marginalized groups-, the global environment, for trade and consumption (one of the largest sectors after oil). Fern would be happy to participate in this group. A first step could be the synchronisation of the European Tropical Forest Advisory Group meetings and the NGO Forest Movement Europe meetings. If these annual meetings were held at the same time and place then a dialogue could be fostered between EC and member states officials and NGO representatives.

Under point 8

• 8.1. Links should be made to the Communication on Forests in developing countries: the EC approach and the Indigenous Peoples Resolution

• 8.2. Fern hopes that the cross-sectoral evaluation on environmental performance will be participatory and comments from civil society in the relevant countries will be sought.

·         8.3.  Fern agrees that information needs to be vastly improved. Why then states the Commission’s website on environment 'Base de données CRIS- SCR ONLY for EC personal' in relation to the projects funded by the EC? Information needed includes: a continuously updated database on all projects funded (including aims, results problems encountered and solutions found), all the EIAs carried out, all the full project evaluations carried out.

Response to the four questions outlined

Question 1:

Under Policy issues:

The UN Millenium Declaration rightly states that the current unsustainable patterns of production and consumption must be changed. Consumption needs therefore to be addressed as an issue; specifically the impact of increased consumption in the EU on the sustainable management of natural resources in countries in the South. As the GDP of countries in the South grows, so will their consumption levels. To allow people in the South an equal consumption level as people in the North, the latter will have to reduce their consumption levels, i.e. pulp and paper consumption is estimated to have to go to down by 60% in most European countries.[4]

The Council paper only mentions integrating the environment into the forthcoming report on policy coherence. It should mention the need to integrate environment directly into the development action plan and the Council's proposal for a joint overall policy statement to be adopted in November. The Commission should ensure that environment integration is stressed and suggestions for its implementation are made as part of the Parliament's report on EC development policy.

Under Programming issues

Fern is pleased to see that environmental issues will be integrated into programming but it cannot stop there. The rest of the project cycle must be included. EIAs should become mandatory in the project inception phase and there is a need to ensure an environment component in EC projects/programmes in the field. Evaluation and monitoring activities should analyse the projects impact on the environment.

Under Institutional issues

Partnership with civil society actors in particular southern NGOs and local communities is a vital component to the successful integration of environment into development co-operation.

Question 2.

Most NGOs Fern works with in the South are environmental or social NGOs. The basis of their work lies in the protection of their environment, often combined with the protection of their land and customary rights. Fern is not a development NGO and does not implement projects, but rather supports NGOs in the South in their struggles for the recognition of their rights and the protection of their environment. We help them gain access to decision makers in Europe and in particular the Commission and the Parliament.

Question 3.

All indicators are quantitative and should be complemented with qualitative indicators. They are also weak and should be significantly strengthened. To give just a few examples:

Under 1: “coherence among EC policies with external effects and consideration of environmental issues in this context”  should be linked with the requirement for a Sustainability Impact Assessment for all trade agreements (result) and one of the indicators should be whether trade measures are changed because of the outcome of the SIA or whether mitigating measures have been taken.

Under 3: every country and regional report should give a description of the environmental and social situation, e.g. state of biodiversity, legal status and real status of protected areas, deforestation rate, land right disputes and legal land right situation, as well as measures taken to improve the environmental situation and to involve all stakeholders.

Under 5: That staff has followed a training does not mean that they are actually capable of integrating environment. Qualitative indicators should be added such as officials prove that staff is actually capable of integrating environment in development policies.

Furthermore the number and quality of EIAs and SIAs carried out on all projects should be added as an indicator.

As mentioned before by Fern as well as some of the Commission’s consultants, it would be an improvement if the Commission produced an annually environmental report to show progress (or lack) thereof made towards environmental integration.

4. Fern sees its role in the integration process in four different ways

·         Organising NGO consultation meetings with NGOs in the North, and the South, organising joint NGO position papers on relevant issues.

·         Facilitating visits from people from the South to Brussels to discuss policy, projects and/or programming issues.

·         Provide discussion meetings or organise seminars with NGO experts on certain topical issues such as the impact of globalisation on poverty, illegal logging, trade liberalisation and the impact on forests.

·         Publicise good and bad developments in the integration process via Fern’s newsletter EU Forest Watch and email lists.