APPENDIX 5
Memorandum submitted by UK Platform, EC
NGO Network/British Overseas NGOs for Development (BOND)
ABOUT THE
UK PLATFORM OF
THE EC-NGO NETWORK
1. The UK Platform of the EC-NGO Network
is an organisation of c.110 UK development and humanitarian Non-Governmental
Organisations (NGOs) which are engaged with the development and
humanitarian policy and practice of the European Union. The UK
Platform works with the EU-wide Liaison Committee of Development
NGOs (LC/CLONG), which provides a central forum for liaison and
consultation between European development NGOs and the institutions
of the European Union. The UK Platform seeks to promote policies
and procedures which address the practical needs of member NGOs
and their Southern partners, and enable the EU to play an improved
role in global development. A full membership list is attached.[2]
2. The UK Platform has recently merged with
British Overseas NGOs for Development (BOND), the main umbrella
organisation for UK NGOs. This is expected to provide a stronger
voice for UK NGOs to engage with UK and EU development policy-makers
in a coherent way, and to ensure that the views of development
NGOs are more fully represented.
SUMMARY AND
OVERVIEW
3. The UK Platform welcomes the opportunity
provided by the International Development Committee inquiry to
comment on the EC Development Policy Statement and the Reform
of the Management of EC External Assistance. We believe that both
initiatives have the potential to radically improve the significant
problems affecting European Commission development policy and
implementation.
4. The UK Platform believes that the EC,
which is the world's second largest multilateral donor, spending
£3.3 billion a year on official development assistance, has
enormous strengths and the potential to play a leading role in
global efforts to eradicate poverty. Given its founding principles,
and its commitment to democracy and human rights, the EU has a
special and valuable role to play in promoting sustainable and
equitable social, economic and political development.
5. Sadly, this potential has not been realised.
The share of EC official development assistance going to Less
Developed Countries (LDCs) fell from 75 per cent in 1986 to 51
per cent in 1997, as political considerations have impinged on
developmental priorities. This has been exacerbated by a proliferation
of external assistance instruments and budget lines, and the absence
of a single coherent development policy.
6. The lack of an explicit statement explaining
what the EC is seeking to achieve in its development policy has
made it impossible to assess whether it is meeting its objectives.
This is exacerbated by a lack of consistent monitoring and evaluation
of the impact of EC aid, and can lead to sweeping criticisms of
Commission practice which are not always rooted in objective analysis.
Reform of Commission development policy, programmes, and mechanisms
must be based on an objective assessment of existing Commission
practice.
7. The Commission's development policy should
be rooted in the Amsterdam Treaty, which states that European
Community development co-operation shall foster: "the sustainable
economic and social development of the developing countries",
the campaign against poverty, the "smooth and gradual integration"
of developing countries into the global economy, and shall contribute
to the general objectives of "developing and consolidating
democracy and the rule of law, and to that of respecting human
rights and fundamental freedoms". It should also be based
on the international agreements made in Rio, Vienna, Cairo, Copenhagen,
Beijing, Istanbul and Rome.
8. Both the Development Policy Statement
and the Reform of the Management of External Assistance proposals
are admirably frank in their admission of the problems which have
led to the Commission's under-performance, many of which have
been previously identified by Member States, NGOs, and others.
However, not all the recommendations for the future of EC developmental
co-operation logically arise from these criticisms, nor from the
primary objective of poverty eradication. Specific criticisms
and recommendations in this regard follow in the next section
of the memorandum.
9. The reform process must be transparent
and open to all stakeholders. NGOs have been critical of the lack
of consultation with Southern governments and civil society organisations,
and hope that the Commission will allow sufficient time for such
consultation to take place.
10. Member States need to recognise the
opportunity for reform, and work with those in the Commission
seeking to take the reform process forward. Commission reform
will require substantial investment in improving the quality of
systems and staffing. The Department for International Development
(DFID) has a great deal of expertise and experience to contribute
in this area.
EC DEVELOPMENT POLICY
STATEMENT
Introduction
11. The production of a single statement
of European Commission Development Policy is an initiative which
is warmly welcomed by the UK NGO community. The EU has committed
itself to poverty reduction, and therefore needs to take action
in development co-operation and trade and foreign policy which
will support that commitment. This Policy has the potential to
provide the framework necessary for the EC to play a leading role
in the eradication of global poverty. However, the Development
Policy Statement does not propose a convincing, coherent, or comprehensive
policy and strategy to meet this commitment. UK NGOs believe that
considerable revision is necessary for the Statement to provide
the basis for a strategy which could be effectively implemented
and would meet stated EU commitments.
Status and timing
12. The production of an overall EC Development
Policy is well-timed, coinciding as it does with the growing international
consensus around the International Development Targets (IDTs)
and the coordination of global development assistance. However,
the current paper does not meet the aim of an "integrated
and strategic statement on development policy" agreed at
the EU Development Council of May 1999. The Council requested
an "overall profile" of the EC's development co-operation,
"a general framework for prioritising objectives, policies
and fields of action", which contributes to "increased
complementarity" between the Community and Member States,
and "ensures total coherence between development co-operation
and the common foreign and security policy as well as external
economic policy".
13. If the document is designed to frame
a strategy, several elements are clearly missing: specific objectives,
activities to achieve them, targets and indicators to measure
the impact, the role of the players and clarification of the responsibilities
and finally, an Action Plan.
Vision
14. The Statement fails to set out a clear
vision of the state of global development, and this inevitably
weakens the analysis of the EC's specific role in addressing the
issues. It surveys a range of trends in development thinking without
drawing clear conclusions or developing a clear link between the
identified problems, and the consequent need for actions to address
them. It fails to fully develop an analysis of a rights-based
approach to development based on international agreements.
15. It also fails to build successfully
on, or adequately refer to, the new EU/ACP partnership agreement,
which in many respects has provided a more coherent basis for
EU development policy than that put forward in the Statement.
Objectives
16. UK NGOs welcome the adoption of poverty
eradication as a central objective of EU development policy. It
should be noted, however, that the statement fluctuates between
poverty eradication, poverty reduction, and combating poverty,
each of which have different practical meanings.
17. The analysis of the differential impact
of poverty (in different countries, and on different groups, eg
women) is weak, and there is almost no explanation of the causes
of poverty. The Statement puts forward "three ways of enhancing
and measuring the poverty focus of Community aid" (section
3.1.3), but their various merits are not analysed in a way which
could be used to guide the allocation of resources.
18. The commitment to poverty eradication
is undermined by a series of caveats and "escape clauses",
which raise further doubts about the implementation of this objective.
In particular, the phrase "Improving the primary poverty
focus is clearly limited by the setting of the political priorities
and the consequences for the distribution of the financial resources
to the regions" is unacceptable. Poverty eradication should
be addressed by, not balanced against, the EC's external relations
with the rest of the world.
19. The emphasis on the integration of developing
countries into the world economy is problematic. Developing countries
are already integrated into the global economy (through the supply
of raw products, migrant workers, Export Processing Zones, etc)
but on highly unequal terms. In order to promote economic development
which truly addresses poverty, the terms of this engagement need
to be made more equitable.
Development and Trade—Coherence
20. NGOs welcome the explicit link between
development and trade policies and the need for consistency and
coherence. However, the central need for coherence between development
and trade policies is again undermined by caveats—the EU
is obliged to "check that the objectives of its development
policy are taken into account when the implementation of other
policies are likely to affect developing countries" (section
2.2.2). It is not clear how the EU's declared commitment to policy
coherence will be implemented in practice. Unless this is spelt
out, there is nothing to prevent political and other priorities
overriding development considerations whenever the two are perceived
to be in conflict. The "check-list" approach to coherence
will not ensure that EU and global trade policies do not undermine
development efforts—rather, development objectives should
be central to Commission trade policies, and mechanisms should
be put in place to ensure this.
21. No analysis is provided of how the EU
will ensure that the WTO and IMF are more open and responsive
to the needs of LDCs and low income countries (LICs).
Priority activities
22. We welcome the statement (section 4.3)
that "the [priority] areas chosen must contribute to the
objective of poverty eradication". The recent introduction
of an additional sector (capacity-building, good governance, and
the rule of law) is welcome. However, the fact remains that the
priority fields do not seem to flow logically from the central
objectives proposed by the Commission. Their expected impact on
poverty is not explained, and no implementation strategy is proposed.
This creates a suspicion that these areas have been selected because
they are existing Commission competencies, rather than for their
ability to truly address poverty. NGOs question whether the recommendation
that this "sectoral concentration should be fully reflected
in Community programmes within a time span of four years"
can be practically implemented.
Cross-cutting issues
23. Cross-cutting principles (such as the
mainstreaming of gender policies) are mentioned, but no proposals
are given as to how this will occur. The statement on gender equality
does not reflect the Commission's own gender policy. The IDC's
own valuable inquiry into "Women and Development" provides
useful recommendations in this regard.
Civil society participation
24. The commitment to involve civil society
actors in the design and implementation of development policy
is to be welcomed, and reflects the proposals to increase the
participation of civil society in the new EU-ACP Agreement. However,
the heterogeneous nature of civil society is not properly examined,
nor are the different roles of civil society in Europe and in
the South, and of different actors (Churches, NGOs, trades unions,
women's associations, etc).
Implementation
25. The relationship between the Policy
and other Commission initiatives, such as the Reform White Paper,
is spelt out clearly, and a significant improvement on the original
version of the Statement. The proposals for the reform of the
Common Service for External Relations (SCR) should also help implementation.
The Commission has developed a clear analysis of some of the major
problems affecting implementation (section 2.3).
26. However, the overall capacity of the
Commission to implement the policy remains questionable, and is
not addressed by the Statement. Although decentralisation of decision-making
to Delegations is welcome in theory, the weakness of these institutions,
and their lack of relations with civil society in their respective
countries, make this problematic.
27. UK NGOs call for the production
of a time-limited Action Plan, which sets out specific objectives,
targets and goals, and clear lines of responsibility (between
the Commission and Member States, and different sections of the
Commission), against which the implementation of the Policy can
be measured.
REFORM OF
THE MANAGEMENT
OF EXTERNAL
ASSISTANCE
Problem identification
28. The UK Platform of the EC-NGO Network
welcomes the fact that the Commission has recognised the critical
problems affecting the implementation of EC Development Assistance,
and has taken this step to tackle the major difficulties in the
organisation of its services. Many of the problems identified
reflect longstanding criticisms made by NGOs and other civil society
organisations.
29. However, the paper is in some respects
unduly sweeping in its criticism of the Commission's performance.
Whilst the administration of aid is not always effective, there
are nevertheless excellent examples of EC aid implementation,
eg the HIV/AIDS and reproductive health awareness programme in
southern Africa. Where the Commission employs expert, qualified
and innovative staff, quality programmes tend to result. The
sharing of lessons learned from these aspects of EC development
cooperation should therefore be encouraged. It is also important
that reform is based on a rational analysis of current practice,
both good and bad. The OECD Development Assistance Committee
(DAC) evaluation of EU Aid, and the global evaluations of ACP,
ALA and MED development assistance, are important evidence in
this area.
Objectives
30. The reform proposals claim to cover
all aspects of EC external assistance, yet there is an overwhelming
emphasis on the political aspects of this, and very little mention
of development objectives. For example, it is noted (pg.8) that
"In external relations the key objective is to ensure a stable
and enlarged Europe with a stronger voice in the world".
There is no reference to the Amsterdam Treaty's primary objectives
of combating poverty, and fostering support to the world's most
disadvantaged countries, which should be equally important objectives
for these reforms to address. There is no mention of poverty at
all, nor the Commission's objective of tackling the International
Development Targets. The reform proposals are therefore not immediately
coherent with the Development Policy Statement, which raises concerns
about the implementation of both initiatives.
31. EC Development Cooperation should be
implemented without the influence of political considerations.
It should therefore be made clear that all development cooperation
functions are now clearly located in DG Development and the new
External Relations Common Service (SCR), with none remaining in
DG RELEX.
Reorganisation
32. The grouping of all the relevant development
cooperation and humanitarian aid services under the Commissioner
for Development and Humanitarian Aid, should enable more effective
implementation of the relief—rehabilitation—development
continuum.
33. At present, the division of responsibilities
between DG DEV and SCR breaks the cycle of project assessment
and implementation, and hampers the Commission's capacity to oversee
and implement development projects. Proposals to reintegrate the
project cycle should allow for more efficient aid programmes and
projects. However, we have concerns about the lack of clarity
in the proposals about the precise relationship between DG Development
and the reformed External Relations Service (SCR), and what this
implies for the link between policy, programming and implementation.
Shifting the divide to another point in the process may improve
some aspects of aid delivery but it also carries the serious risk
that other links are weakened. This will need to be closely monitored.
34. The proposals are based on an exclusively
project-based approach. Many donors are shifting towards budgetary
support for particular sectors, eg DFID's support of the Ugandan
Government's strategy to develop basic education. Such an approach
places the partner government at the centre of policy development,
and reduces the need for Commission staff. The EC should learn
from good practice in Member States and elsewhere in this area.
35. The decision to de-concentrate and decentralise
decision-making and administration, and in doing so to reinforce
the authority and flexibility of operation of EU Delegations in
aid administration, is to be welcomed. Significant questions remain
regarding the capacity of Delegations, in particular their ability
to adequately engage with a wide range of development actors in
their respective countries, particularly with civil society organisations.
Delegations will need to be significantly strengthened, and
their approach made much more inclusive and transparent, in order
to fulfil this role effectively.
36. NGOs welcome the proposed shift away
from the use of Technical Assistance Offices (TAOs), which have
generally proved expensive and inefficient, towards more decentralised
solutions. Such reforms will nevertheless need to ensure that
political and policy oversight of all Commission external assistance
is maintained in Brussels, to maintain coherence with overall
development policy.
Staffing
37. NGOs welcome the emphasis placed on
the critical problem of understaffing in the Commission's External
Relations operations. Without significant investment in improving
the quality and quantity of appropriate staffing, no amount of
reorganisation will be sufficient to resolve the existing problems.
38. The proposals make no reference to the
type of staff required, although this will be crucial to the effective
implementation of the proposed reforms. This strengthening
needs to provide Delegations with the appropriate staff required—not
more bureaucrats, but instead social development advisors with
skills in participatory development, able to develop gender-sensitive
programmes in co-ordination with Southern governments, IFIs, other
donors, NGOs, and civil society organisations.
EC-NGO Relations
39. We welcome the principle of reintegrating
the administration of budget lines for NGOs in one Unit. However,
we believe NGOs have a great deal to contribute to wider EC policy
dialogue and project implementation, and this proposal should
not lead to NGOs being excluded from dialogue and communication
with the rest of the Commission.
40. We view with concern that no decision
has yet been taken on the organisation of services with regard
to NGOs. A prolonged period of indecision is very likely to have
serious negative repercussions for NGO-Commission co-operation.
Consultation
41. Although reform in some areas is urgent,
the Commission must ensure that proper consultation takes place
on the reform proposals, which will have a far-reaching impact.
It should allow more time for stakeholders such as Southern
governments and civil society organisations to be consulted.
UK Platform, EC NGO Network/British Overseas NGOs
for Development (BOND)
June 2000
2 Not printed. Back
| 
