Memorandum submitted by British Overseas
NGOs for Development (BOND)
GENERAL OVERVIEW
1. BOND is a network of over 230 development
non-governmental organisations (NGOs) in the UK. BOND's membership
reflects the huge diversity of UK civil society's response to
international poverty and injustice. This submission represents
a collective statement of BOND members. It cannot be taken to
represent the views of any individual organisation. It should
be read as a complement to the submissions made by individual
BOND members.
2. As the UK NGO platform of the Liaison
Committee of European Development NGOs, BOND welcomes the Select
Committee's continuing interest in and close scrutiny of EU aid
effectiveness. With this submission, BOND aims to assess how the
EC reform process is enhancing the EC's capacities to meet its
agreed development objectives, namely, "to reduce and, eventually,
to eradicate poverty" through support for "sustainable
economic and social and environmental development, promotion of
the gradual integration of the developing countries into the world
economy and a determination to combat inequality". Specifically,
this submission aims to provide a critical analysis of the EC
reform process focusing on its impact on the implementation and
formulation of EC Development Policy. Admittedly, it is still
difficult at this stage to assess whether the reforms will succeed
in their objective or not.
3. The EU states that its Development Policy
"is grounded on the principle of sustainable, equitable and
participatory human and social development" adding that the
promotion of "human rights, democracy, the rule of law and
good governance are an integral part of it. By spending over 9
billion (£5.5 billion) per year in official development assistance
in over 140 countries worldwide, the European Community (EC) is
the world's second largest multilateral donor. It therefore has
the potential to make a substantial and significant contribution
towards sustainable and equitable rights-centred development and
poverty reduction. The EU's clear position on mainstreaming the
"horizontal aspects"—"the promotion of human
rights, equality between men and women, children's rights and
the environmental dimension" within all its development co-operation
activities greatly enhances this potential. The EU however is
not delivering to the poorest countries in the world and the disbursement
of EU aid is still too slow. The current reform of the management
of the EC's external assistance will be fundamental to enhancing
the quality and effectiveness of its Development Policy. As such,
it will require close monitoring and evaluation.
4. So far, the reforms have brought about
many positive changes. The Development Policy Statement[1]
has identified poverty reduction as the central aim of EC development
assistance. This is expanded in the Commission's rolling Programme
of Action[2]
setting out both working methods and a time frame for implementation.
The devolution of administrative and decision-making authority
to the Commission's Delegations in third countries is also positively
viewed by NGOs. We also consider the setting up of EuropeAid,
developed from the Service Commun Relex (SCR), as a major turning
point. Likewise, the new inclusive framework for the programming
of EU aid based on country and regional strategies drawn up in
collaboration with beneficiary governments and non-state actors
including NGOs is a welcome improvement. Finally, we believe the
Annual Report on "The European Community's Development Policy"
to be an invaluable tool for monitoring the Community's progress
in implementing its Development Policy and accompanying thematic
policies and programmes.
EC DEVELOPMENT POLICY
IMPLEMENTATION
EuropeAid
5. EuropeAid is the main implementing body
of EU Development Policy. Since its creation in January 2001,
EuropeAid has contributed to addressing key shortcomings in EU
aid effectiveness previously identified by the Select Committee.
These include strengthening multi-annual aid programming, the
integration of the operations cycle from project identification
through to the full implementation of programmes and projects,
as well as putting in place urgent measures to eliminate old and
dormant commitments.
6. To date EuropeAid has managed to decrease
old commitments by 52 per cent. Dormant commitments have also
been reduced by almost one third. Likewise, commitments made under
the European Development Fund were almost halved. Furthermore,
EuropeAid has reduced the time lag between commitments and payments,
a major factor hampering EU aid effectiveness. For those budget
lines managed by EuropeAid, the level of commitments made by the
end of September 2001 was 22 per cent higher than the previous
year. Payments also increased by
230 million (£141.7 million) significantly reducing
the gap.
7. Ten months since it was set up, EuropeAid
comprises almost 1000 staff. Further expansion is envisaged with
170 positions still to be filled and an additional 248 staff to
be recruited when all of the 49 Technical Assistance Offices'
functions will be eventually absorbed by EuropeAid at the end
of 2001.
8. Given EuropeAid's key role in implementing
EC Development Policy, it is of paramount importance that the
right balance between quality and effectiveness of aid management
is struck. Most of EuropeAid's staff were re-deployed from DG
Development, DG External Relations and the old SCR. With over
a 1,000 staff, it is clear that EuropeAid is more than adequately
staffed, however, NGOs are concerned about the quality and expertise
of this staff. The Commission needs to ensure that personnel working
in EuropeAid are trained in participatory, people-centred development
and that they are committed to the principle of poverty eradication.
In particular, we would like to draw the Committee's attention
to the absence of a gender balance in EuropeAid's present organisational
structure as well as the lack of adequate financial or human resources
to implement gender mainstreaming. This is unacceptable given
EC policy on gender[3].
9. There is also a need to enhance expertise
in the areas of democracy and governance. Here too, despite its
stated policy, the Commission is not fully mainstreaming the promotion
of human rights and democracy in all development co-operation
programmes. In addition, there is a need to increase support
to programmes which aim to strengthen local democracy, particularly
in the urban areas of developing countries.
10. Overall, NGOs feel that there is a real
danger that the strong focus on the effectiveness and speed of
aid delivery might detract attention from the quality of projects
and programmes selected and the development expertise of the personnel
recruited.
11. EuropeAid is responsible for drafting
the Annual Report on the implementation of EC Development Policy.
NGOs, MPs, MEPs and Ministers alike have long called for the Commission
to produce yearly reports in line with other multilateral donors.
Despite this being a step in the right direction, we have been
quite disappointed by the first Annual Report, presented by the
Commission to the Development Council on 8 November 2001. The
Commission has described it as a "year 0" report: covering
the pre-reform period from December 1999 to December 2000. Notwithstanding,
we are concerned by the structure of the report, which does not
allow for an honest assessment of activities against strategic
objectives, focusing on hurdles as well as achievements. Despite
focusing on mainstreaming activities in cross-cutting areas such
as gender, the environment and human rights, the report still
lacks transparency.
12. We recommend that more emphasis be placed
on assessing the coherence of EU policies on trade, agriculture
and security with development objectives. Future Annual Reports
should also make reference to the output targets for aid allocations
to activities in human and social development within the EU's
regional co-operation agreements set by the European Parliament.
We believe that these provide a valid benchmark for gauging the
level of EU support to poverty reduction activities and should
thus be reflected in the Commission's annual reporting exercise.
An equal emphasis should be placed on developing a set of performance
indicators for measuring the impact of EU aid on poverty eradication
in these regions. We urge the Select Committee to take note
of these issues on the Annual Report in their recommendations
to the European Commission.
Deconcentration to EC Delegations
13. The Commission is committed to reforming
its decision-making structures and to "deconcentrate"
administrative and decision-making authority to its Delegations
in third countries. They aim to deconcentrate the management of
its external assistance to a total of 86 Delegations by the end
of 2003. Twenty-two Delegations will be deconcentrated by the
end of the current year. Another 30 will follow in 2002 and the
remainder in 2003. EuropeAid is responsible for co-ordinating
deconcentration.
14. The process in itself is extremely positive
and welcomed by NGOs. We believe that the streamlining of management
and decision-making procedures within EC Delegations is crucial
to improving EU aid effectiveness in-country. EC Delegations are
known to be chronically understaffed and under-performing. One
example, is the lack of gender policy implementation by Delegations.
Evidence from Delegations in Bangladesh, South Africa, and Nicaragua
suggests that gender policies are not widely implemented or seen
as top priorities. Delegation staff do not feel they have access
to training to improve their skills in mainstreaming gender. Despite
this, the European Commission has been under significant pressure
to devolve authority to the Delegations quickly. After spending
most of 2001 preparing the ground, the deconcentration of the
first batch of Delegations is scheduled to start in January 2002.
15. Under the new structure, Delegations
will have greater responsibility for the overall development project
cycle. This brings the clear opportunity to make EC development
co-operation more responsive to locally felt needs, but it also
means the Delegations will need to be considerably strengthened
in terms of staffing and capacity to achieve these goals. We
ask the Select Committee to highlight the importance of pre-posting
training for officials relocating to the deconcentrated Delegations.
We suggest that this include awareness raising and training in
implementing the EU Development Policy with particular reference
to the horizontal aspects, namely, "the promotion of human
rights, equality between men and women, children's rights and
the environmental dimension".
16. We fear that, in the absence of a pilot
phase and given the pressure on the Commission to deconcentrate,
the process might be unnecessarily rushed and inadequately financed.
Redeployment of personnel from Brussels and external recruitment
are conditional on the availability of necessary financial resources
in the 2003 and 2004 EU budgets. A lack of such resources will
inevitably cripple deconcentration. NGOs have an important part
to play in ensuring ongoing monitoring and evaluation in close
collaboration with Southern partners. We urge elected representatives
both in the UK and in the European Parliament to carefully monitor
deconcentration guaranteeing quality control and making the necessary
adjustments to budgets and strategies throughout the process.
EC-NGO Relations
17. NGOs welcome the positive outcomes that
the reforms have had so far, namely the introduction of a Call
for Proposals system and the clearing of the backlog of applications.
It seems that issues on existing co-financing project contracts
(under budget line B7-6000) are now being dealt with more quickly
than before the reforms. Despite these improvements, NGOs have
lamented a continuing lack of transparency in all parts of the
project cycle and overwhelming bureaucracy surrounding the financing
of activities under budget line B7-6000.
18. The co-financing programme has been
of paramount importance to NGOs. This was overhauled with the
introduction of the new General Conditions. The revision of the
General Conditions was applauded by NGOs for breathing new life
into EC-NGO funding relations. The new system however has been
fairly disappointing. The reform process has entailed a suspension
of NGO co-financing since November 1999. Under the new General
Conditions, NGOs were promised two Calls for Proposals per year
and a maximum limit of six months for the EC to process applications.
This has not been the case. There has only been one Call over
the past two years whose results we are now receiving. The subsequent
Call, due any day we are told, has also been delayed over several
months. Unacceptable delays between submission of proposals and
receiving a rejection or an approval also continue. Many of BOND
member agencies have had to wait for up to a year before hearing
back from the Commission. Furthermore, since the SCR was set up
two years ago, EC personnel responsible for the NGO co-financing
programme has been relocated twice, the latest move having shifted
the NGO unit to EuropeAid. This has created significant confusion,
inefficiency and the loss of innumerable NGO dossiers.
19. It seems from feedback from NGOs that
many good projects are turned down on the basis of bureaucratic
technicalities rather than the effectiveness of the project design
in meeting the perceived needs and EC development objectives.
However, there does not seem to be a formal effective channel
for feedback from the Commission to NGOs. Similarly, it would
have been helpful for the Commission to have engaged in consultation
with NGOs regarding the priorities for the 2001 Call.
20. We feel that the separation of EuropeAid
from DG Development has negatively affected EC-NGO dialogue. We
are very concerned by the fact that the Commission seems to increasingly
view NGOs as mere implementers rather than development actors
in their own right. As a result, we feel that it has been resisting
an open and frank dialogue with civil society on EC Development
Policy formulation and implementation. This has been epitomised
by EuropeAid, which seems to act independently, of and sometimes
in contradiction to, the EC Development Policy. The recent rejection
of proposals under the human rights and the co-financing budget
lines regardless of their strong impact on poverty eradication
is an example of this.
21. In light of the current international
situation, NGOs feel that increased spending on the humanitarian
crisis in Afghanistan and the surrounding region should not be
at the expense of humanitarian or development funding for other
poor countries, particularly in South Asia and Sub-Saharan Africa.
Even less should funding to shore up support for the "coalition
against terrorism" be at the expense of the least developed
countries.
22. Overall, the continuing problems under
the EC-NGO co-financing programme have been very distressing for
NGOs and their partners in the South. Although expectations were
raised, it is felt that NGOs have not reaped the benefits of the
reform. On the contrary, so far the re-structuring seems to have
had a negative impact on the poverty eradication programmes implemented
by NGOs and their partners in developing countries. We urge
the Committee to take up the issues made in paragraphs 14 to 17
in their inquiry since now is the time to address these shortcomings
whilst the reforms are still settling.
RESOURCING DEVELOPMENT
OBJECTIVES
EU Budget
23. According to the new principle of Activity-Based
Management the EC should take decisions about policy priorities
and the corresponding resources together allowing for "resources
to be allocated to policy priorities and decisions about policy
priorities to be fully informed by related resource requirements"[4].
Despite this, we would like to draw the Committee's attention
to the mismatch between development priorities and funding highlighted
in the Commission's preliminary draft budget for 2002 (see pie
chart). Despite committing to poverty eradication through achieving
the internationally agreed Millennium Development Goals, the Commission's
funding pattern for 2002 continues to be significantly skewed
towards the near abroad and penalises budget lines aimed at combating
poverty. The Commission suggested slashing priority areas such
as food security and human rights, as well as allocations to Asia
and NGO co-financing. Conversely, budget lines that are not pertinent
to poverty eradication were either untouched or increased by the
Commission. Most of the proposed cuts were only reversed after
concerted efforts by NGOs and the intervention of the European
Parliament.
24. European NGOs have challenged the allocation
of funds to non poverty-related lines covering for instance co-operation
with industrialised countries, migration, nuclear energy as well
as pre-accession aid to Turkey, Cyprus and Malta under category
4 of the budget. Clearly, more work needs to be done in order
to streamline funds allocated under the development budget chapter
to the sole aim of the elimination of poverty in line with EC
Development Policy.
25. Mindful of the importance of the harmonisation
of the development budget, we are concerned that the rationalisation
of legal bases and the merger of budget lines (reduced from 64
to 55 in 2001) is overly driven by administrative concerns and
too little by development priorities. Historically, smaller sectoral
budget lines have been managed efficiently and have supported
innovative, small-scale actions greatly contributing to EC development
initiatives.
26. In the interest of greater coherence
and integration in the EC development programme, we support the
inclusion of the European Development Fund (EDF) into the Community
budget. The current separate arrangement for Africa, Caribbean
and Pacific (ACP) countries undermines the accountability and
transparency in the delivery of EU aid for poverty eradication
to some of the least developed countries in the world. Moreover,
if the EDF were brought into the EC budget, financial oversight
over EDF expenditure would be considerably strengthened and the
number of procedures that apply to EC aid would be reduced. BOND
recommends that the Select Committee give careful consideration
to this matter in its deliberations.
27. Another area of weakness has been the
complex, bureaucratic and burdensome financial control procedures
governing aid disbursement. To address this issue and to try to
ensure that EC aid expenditure can be compared to that of other
DAC members the European Parliament amended the 2001 budget to
require the Commission to produce output targets. The idea behind
these is to measure the impact of spending across policy areas
so that it becomes clearer how much the EC spends on basic education,
primary health or sanitation versus expenditure on infrastructure
projects. The Commission has failed to make the required internal
reforms during this year and the Parliament has therefore required
that this be carried out in 2002. NGOs are concerned about
the Commission's reluctance to comply with the agreed output targets,
as this is crucial information for being able to ascertain the
poverty focus and therefore the effectiveness of EC aid to help
achieve the Millennium Development Goals.
28. A concrete example of a potential mismatch
between objectives and resources may be that illustrated by the
Communicable Diseases Programme of Action adopted in February
2001. Not all of it requires resources drawn from development.
Parts of the plan relate to the regulatory environment and the
degree to which the EC can mobilise research and development resources.
However, that part of the plan that is around improving the impact
of existing interventions may be hard to realize within the current
budget allocation. If ACP countries do not prioritise this area
of activity as an area for Community support, the Commission,
with only 25 million in the 2002 PDB as amended following the
European Parliament's first reading, will find that it cannot
make much progress in this area.
EU Aid Programming
29. BOND welcomes recent improvements in
the programming of EU aid. The new Framework for Country Strategy
Papers (CSPs) is an invaluable instrument for promoting greater
coherence, or a better "policy mix", between external
assistance and other EU policies (trade, CFSP, etc.) in a given
country or region. The setting up of the inter-service Quality
Support Group (iQSG) is also a positive development. Since its
creation in September 2000, the iQSG has established guidelines
for the development of CSPs and has launched a series of seminars
for the relevant EC personnel. To date, the Group has made recommendations
on 37 CSPs for ACP countries under the Cotonou Agreement, and
for 12 countries in Asia, the Balkans, the Southern Mediterranean
and the New Independent States. By the end of 2001, the iQSG is
expected to present a thematic and qualitative analysis of all
completed strategies making proposals for further improving the
programming process.
30. However, despite the Commission's rhetoric
on the inclusiveness of the new country strategies, reports from
the South have shown that there was little or no civil society
participation in the drawing up of the first CSPs. Furthermore,
despite the alleged transparency of the process, NGOs have found
it almost impossible to access information on CSPs. It appears
that the strategies reviewed by the quality support group revealed
a significant concentration in the areas of transport and macro-economic
support. Given CSPs only allow for a maximum of two focus areas,
these results are worrying. A way in which the EC may offset this,
in order to deliver funding for a more comprehensive development
strategy, is through the use of its thematic budget lines. Improved
donor co-ordination on the ground, prioritised by the reform process,
will also be of paramount importance. We ask the Select Committee
to call on the EC for greater transparency in the drafting of
CSPs, for the publication of final drafts, and to underline the
importance of participation by civil society organisations in
order for the programming exercise to be truly owned by poor people
in beneficiary countries.
DEVELOPMENT POLICY
FORMULATION
31. BOND welcomes the reduction in the number
of Commissioners with responsibilities over development from four
to two. This reorganisation has enhanced the coherence of development
and humanitarian policy formulation. On paper, Poul Nielson, Commissioner
for Development and Humanitarian Aid, is now responsible for the
entire portfolio toward developing countries including the ACP,
Asia, Latin America, Southern Africa and the Mediterranean. The
External Relations DG's geographical remit largely overlaps with
DG Development's, excluding ACP countries. EuropeAid is entirely
responsible for implementing EC Development Policy although policy
formulation and programming remain the responsibility of the DGs
for Development and External Relations. EuropeAid, however, is
not headed by Commissioner Nielson but by a Board of Commissioners
chaired by Chris Patten and including Commissioners for Trade
and Enlargement. Poul Nielson is also a member of the Board as
EuropeAid's Chief Executive Officer. Although this set-up is an
improvement from the previous arrangement on the SCR, which was
under the aegis of DG External Relations, we believe that EuropeAid's
governance structure still poses structural problems by blurring
the political boundaries between DG Development and DG External
Relations with regard to development policy formulation.
32. According to the Commission, the Commissioner
for External Relations is responsible for developing the policy
for EuropeAid whereas the Commissioner for Development is responsible
for its implementation. It is unclear how these responsibilities
reflect the Commissioners' political portfolios. NGOs have been
increasingly concerned by the gradual reduction in size of DG
Development, which now has less than 200 staff. DG External relations
and EuropeAid together instead comprise well over 1000 officials.
The dwarfing of DG Development has gone hand in hand with the
loss of political clout by its Commissioner. International events
over the past year have amply demonstrated that although Nielson
is responsible for Development Policy, the responsibility for
EU policy towards developing countries is firmly in the hands
of Commissioner Patten. Despite the rhetoric, DG Development's
responsibilities have been greatly diminished except for EU aid
programming under the Cotonou Agreement. The deconcentration of
authority to EC Delegations in-country will exacerbate this further.
33. In this context it is not unthinkable
that a future Commission might deem a separate Directorate General
for Development as superfluous. The Commission's internal auditors
have recently prepared a report that criticises the Commission's
current external relations structure and suggests that there should
be three divisions in future: foreign policy, trade and development.
It is an open question as to whether it is DG Development that
goes or EuropeAid but it is very likely that one of the two of
them will disappear. The disappearance of DG Development would
seriously undermine the Community's approach to development co-operation,
as set out in the Treaty of the Union, making aid policies susceptible
to becoming mere instruments of foreign policy jeopardising the
focus on poverty eradication.
34. The persistence by the EC in allocating
funds to the near abroad is symptomatic of this. Looking at the
top ten recipients of EC aid according to the DAC we see that
not one is a least developed country, not one is in sub Saharan
Africa and not one is in Asia. The Commission needs to address
this imbalance urgently if it is to convince observers that its
aid is not subject to shifting political priorities.
35. Another example is the new strategic
framework for the European Union's relations with Asia over the
next decade, recently formulated by DG External Relations. Sadly,
despite the fact that the majority of the world's destitute people
live in Asia, the strategy's main focus is on strengthening the
EU's political and economic presence across the region. Poverty
eradication is only one of six priority areas, not the overarching
objective. Furthermore, in the light of recent international events
and the EU's commitment to the fight against terror, NGOs fear
that development objectives may once again be subordinated to
political considerations and that aid may be allocated to Afghanistan
and the surrounding region at the expense of other poor regions
in the world.
36. BOND calls for this trend to be reversed
and for political representatives and other Member States to ensure
that a political entity charged with Development Policy formulation
and implementation be maintained. Having a credible and well
resourced DG Development acting as a political advocate within
the Commission, will be essential to ensure that poverty eradication
is maintained as the overarching objective of EC Development Policy.
Without this strong independent voice, the EC's Development Policy
is unlikely to have the political backing to make it a reality.
37. Despite the recognised effectiveness
of EU Member States' bilateral aid programmes, particularly the
UK's, we believe that a common European approach to development
co-operation remains necessary given the EU's increasing clout
as a Global Player. While foreign policy aims to defend and promote
the EU's security, economic and commercial interests in the world,
development policy must be based on the needs of the poorest countries.
CONCLUSIONS
38. In conclusion, BOND believes that the
current reform offers a window of opportunity to improve the quality
and effectiveness of EC external assistance in the long term.
At present however, the impact on EC Development Policy implementation
and formulation is quite mixed. Albeit, it is too early to reach
any final conclusions on whether the reforms will eventually achieve
their objectives. Nevertheless, BOND feels that it is absolutely
crucial for NGOs, local beneficiaries and elected representatives
to keep a close eye on the unfolding reform process. Despite the
Commission's efforts to increase transparency and accountability,
we feel that there is still work to be done in these areas within
the framework of the reform. This inquiry should be part of an
ongoing process of scrutiny by the UK Parliament to assess the
EC's performance against its development objectives, with particular
emphasis on poverty eradication. We look to the Select Committee
to take on a "watchdog" role and exert political pressure
on the Commission in order to make sure that it addresses its
shortcomings.
SUMMARY OF
KEY RECOMMENDATIONS
BOND recommends that the Select Committee:
1. Makes reference in its deliberations
to the need for the highest quality and expertise of EuropeAid
staff, particularly in the areas of gender, governance and participatory
development.
2. Stresses the importance of the Annual
Report on "The European Community's Development Policy"
making reference to BOND's specific recommendations on the content
of the Report.
3. Highlights the need for comprehensive
and poverty-focused pre-posting training for officials relocating
to deconcentrated Delegations.
4. Carefully monitors deconcentration in
order to guarantee quality control allowing for the necessary
adjustments to budgets and strategies to be made throughout the
process.
5. Encourages the Commission to urgently
address the continuing severe shortcomings in its relations with
NGOs including speeding up EuropeAid's consideration of NGO proposals,
as well as putting in place better feedback and consultation procedures.
6. Challenges the continuing of funding
allocations away from the poorest countries and poverty-focused
budget lines in the Community's Budget.
7. Gives careful consideration to the case
for budgetisation of the EDF in its deliberations.
8. Encourages the Commission to comply with
the output targets set by the European Parliament in the EU Budget
for 2002.
9. Calls on the Commission to make aid programming
more transparent, for the final drafts of Country Strategy Papers
to be made readily available and to stress the importance of civil
society participation in the programming process.
10. Explores the extent to which EC Development
policy and practice continue to be influenced by the EU's security,
economic and commercial interests at the expense of poverty eradication.
11. Requests the Commission to ensure that
DG Development is adequately resourced and staffed in relation
to DG External Relations and EuropeAid and, most importantly,
that it is maintained in any future re-structuring of the Commission's
services.
12. Takes on a watchdog role and exerts
political pressure on the Commission in order to make sure that
it addresses the shortcomings outlined in this submission.
British Overseas NGOs for Development (BOND)
12 November 2001
1 The European Community's Development Policy-Statement
by the Council and the Commission, November 2000. Back
2
Commission Staff Working Paper, The European Community's development
policy: Programme of Action SEC (2001) 808, Brussels 21.5.2001. Back
3
Council Resolution no 12847/95 on Integrating of Gender Issues
in Development Co-operation, 20.12.1995. Back
4
Reforming the Commission, A White Paper-April 2000. Back
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