Further supplementary memorandum submitted
by Small International NGOs Group
Thank you for the invitation to make a further
submission to the International Development Committee (IDC). We
hope that this will be the continuation of an ongoing dialogue
with both the IDC and DFID.
We are encouraged by DFID's increased willingness
to consult with civil society; this we feel is all the more reason
to address those areas that can make a positive contribution to
DFID's own objectives as well as our own. Our wish to engage DFID
in a longer-term consultation process is a means to an end: better
and more effective development. In the response to our initial
report DFID stated that it was considering how Policy Division
could consult effectively with UK civil society. As a diversified
group of CSOs we believe that we have a committed group which
can work with the Policy Division on this issue.
We have attempted in tabular form to contrast
our submission with DFID's reply (Refer Appendix A). In doing
so, we do not intend to repeat our earlier submission or the points
in this table, but wish to emphasise the main areas where we think
we can add value—areas in which SNGOs have special expertise
enabling us to make a positive contribution to international development.
We have confined the points in this submission
to those that relate to SNGOs, but would welcome the opportunity
to explore some of the other issues raised at a later date.
STATEMENT
We have stated that DFID does not fully recognise
our collective contribution (Serial 2.) to which the reply has
been to state that the existence of CSCF bears testament to that
recognition. The CSCF is a relatively small funding mechanism
with a narrow remit. However, we feel that we can enhance the
broader dialogue on development policy and practice. It is towards
this end that we made the original submission. For example the
DFID Departmental Report 2004 (page 105 5.53) quotes the Development
Awareness work with faith groups and other organisations. This
process could be enhanced to a real consultative partnership rather
than a way to disseminate information on what DFID is doing.
DIVERSE APPROACHES
DFID may recognise the need for a broad approach
(Serial 5) but this is not necessarily the same as a differentiated,
contextualised approach to development practice. The DFID Departmental
Report 2004 quotes (page 21 box 1c) the objective to develop evidence-based,
innovative approaches to international development. We wish to
stress the importance of enabling poor people to articulate their
aspirations, and define the means for addressing them. We believe
that we are ideally positioned to ensure that this process takes
place and many SNGOs have examples of innovative approaches which
DFID could use to enhance its own innovative approaches.
We note in the Departmental Report (page 159)
the Diversity Action Plan. There are many small NGOs in the UK
based on the work of people from many different countries and
ethnic background. Their experience could be a factor of great
benefit to DFID in its aim of diversity.
CONSULTATION
We have already acknowledged DFID's willingness
to consult with civil society (Serial 7) and stated our wish to
establish the due processes whereby consultation with civil society
can be institutionalised. We would like to move forward towards
greater regular consultation in future and believe that we could
present a good model for consultation with DFID. It is important
to note that BOND represents all NGOs (Serial 9), not just small
NGOs, and therefore its actions are sector specific. We feel that
the specific value we as small NGOs can add needs a separate mechanism
affiliated to BOND but with direct links to DFID to maximise the
benefit from the consultation.
RIGHTS-BASED
DEVELOPMENT
We recognise the importance of a rights-based
approach to development (Serial 15)—confined primarily to
the CSCF—whereas we would like to see this applied globally
throughout DFID's operations. At the same time, we are concerned
that rights are interpreted very narrowly, which becomes very
restrictive in practice. We have no argument with the definition
given in DFID's response (Serial 17) and, indeed, would regard
its implementation as best practice. Our contention is that this
must be part of a development process rather than a new funding
dictate, if it is to be community-based and community-owned.
RECOMMENDATIONS
We were not simply referring to the size of
organisation (Serial 21) but to the quality of development work
in general. Our point is that SNGOs do excellent work; this is
not given sufficient recognition, because the tendency is for
our work to focus on the local, rather than effecting change at
the regional or even national levels. This is because we wish
to work, at least initially, from the community-level upwards
(and because levels of funding do not allow it). We were not wishing
to confine this statement to CSCF-supported projects. One of our
strengths is that our contacts could for example help DFID realise
its objective, as stated in the Departmental Report (page 95 Box
5f) to involve civil society in participating in the monitoring
and evaluation of PRSPs.
We do not feel that there is a reciprocal consultation
mechanism (Serial 22). If one were in place we feel that we could
add real value to DFID's efforts to encourage civil society involvement.
We do not dispute that DFID policies are developed
with poor people in mind (Serial 23) but this is not synonymous
with developing policies with, and for, poor people. This is by
no means an easy task and a challenge for all organisations working
with the poor. Our point is that we can make a contribution to
getting this right.
We would be happy to participate in a formal
review of DFID's policy and practice (Serial 24) and would consider
that an exercise of this nature would be extremely beneficial.
We have been deliberately brief in this submission
and would welcome the opportunity to discuss these points in greater
detail. Most of them are substantive and fundamental issues which
predicate good development policy and practice.
June 2004
APPENDIX A
COMPARISON BETWEEN STATEMENTS IN "SMALL
NGOS PAPER (EV 49)" AND DFID'S RESPONSE (Ev 56)
| Serial | NGO Statement
| DFID Response | |
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| 1. | | SUBMISSION BY SMALL INTERNATIONAL NGOS
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| | 2. Although the paper was submitted by NGOs, we have used the term Civil Society Organisation (CSO) in our response, since so much of DFID's engagement nowadays is with a range of organisations extending beyond the NGO community and including faith groups, trade unions and membership organisations.
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| 2. | 2. Statement
| Conclusions | |
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| DFID has achieved a great deal, but it fails to recognise the value of the contribution of small international NGOs to international development.5. RecommendationsRecognition be given to the small international NGO sector for its past, present and future contribution to development.
| We believe that the small international CSO sector already gets recognition for it's contribution to development—the continued existence of the Civil Society Challenge Fund is testament to that.
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| 3. | 2. Statement
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| DFID's reluctance to accept development alternatives that do not fit its predetermined model.
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| 4. | 2. Statement
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| There are also major inconsistencies between DFID's declared commitment to addressing global poverty, and its policy and practices.
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| 5. | 3.1 Diverse Approaches
| 3.1 A Broad Approach |
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| The nature of government is to seek simple, universally applicable, systematic models of development. . . . this runs contrary to what poor people need and want.
| DFID recognises the need for a broad approach to addressing poverty issues in different contexts and countries.
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| 6. | 3.5 Involvement of the UK PublicSmall international NGOs representing specific communities can link defined constituencies in the UK with grass-roots organisations in the developing world.
| DIVERSITY AND DEVELOPMENT EDUCATION5. We do recognise that small CSOs can make a valid contribution to mobilising support for development in the UK. UK Black and Minority Ethnic (BME) organisations have a strong tradition of concern with development issues.3.5 Involvement of the UK publicWe agree that it can be helpful to link defined constituencies in the UK with the developing world. DFID has engaged with faith groups in various ways in delivery of its objectives over many years.
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| 7. | 4.1 The consultative capacity of small NGOs
| 3.6 Appropriate Advocacy |
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| Small international NGOs have a wealth of knowledge that could support and strengthen DFID's strategic goals; but it is not being tapped presently.
| DFID recognises that issue-specific groups can often be effective advocates for change and we have supported a number of these through the Civil Society Challenge Fund.4.1 and 4.2 Consultation and InformationConsultation with stakeholders is a very important part of DFID's policy
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| | formulation. Although in our view the most important stakeholders are the poor in developing countries, it is untrue to say that DFID fails systematically to include small UK NGOs in consultation processes.
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| 8. | 4.2 Lack of Consultation and InformationConsultation, when it does occur, is ad hoc and appears, when policy is involved, to be after the fact.
| DFID POLICY DIVISION REORGANISATION7. This does present a challenge for small CSOs, and we have been considering what liaison arrangements we can put in place to assist this process.4.1 and 4.2 Consultation and InformationWe recognise that relationships and networks have been affected by the reorganisation of our Policy Division, and are currently considering how our newly structured Division can consult effectively with UK civil society.
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| 9. | 4.2 Lack of Consultation and InformationDFID makes little effort to address this problem and does not consult systematically outside the five large NGOs.
| DFID POLICY DIVISION REORGANISATIONAs the submission by the NGOs recognises, it would be unrealistic to expect consultation with individual organisations, but we are looking at manageable ways in which we can have a dialogue.4.1 and 4.2 Consultation and InformationWe consult with small UK CSOs for example through the Development Education Association (DEA) and BOND.We did think that BOND were an effective conduit for consultation and dissemination of information to small CSOs, but we will talk to BOND about the points raised in the submission from the "small" international CSOs.
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| 10. | 4.2 Lack of Consultation and InformationSmall international NGOs could be organised to facilitate dialogue along thematic or sectoral lines and BOND might well prove to be an effective conduit for such dialogue.
| 4.1 and 4.2 Consultation and InformationThere have also been a number of consultations around specific themes. The consultation documents can be found on our website.
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| 11. | 4.2 Lack of Consultation and InformationThere is also a marked lack of visibility and access to important information held by DFID that is of interest to small international NGOs.
| 4.1 and 4.2 Consultation and InformationThe remark about visibility of data is surprising. As well as publicising information about annual funding decisions on our website, DFID have for some years provided information about the CSCF to BOND whose members have always seemed appreciative of the information provided and the way in which it has been presented at annual workshops.
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| 12. | 4.3 The Role of contractorsThe use of private sector contractors to vet proposals has led to growing dissatisfaction.
| LENGTH OF TIME TAKEN TO DEAL WITH GRANT APPLICATIONS. COMPETENCE OF ASSESSORSOur external consultants are very experienced in the field of international development. In selecting the teams, we took care to make sure that all the assessors either originate from developing countries or have spent substantial periods living and working overseas.
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| | 4.3 The role of contractorsA number of DFID programmes use outside contractors to administer their funding arrangements. Contractors are carefully selected based on the background and experience of their staff, most of them having a wealth of experience in relevant sectors.
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| 13. | 4.3 The Role of contractorsThe increasing conditionality of donor aid linked to privatisation has led to social outcomes that do not represent the interests of the poor, either in the scope of their activities or in the manner in which they are implemented.
| DIVERSITY AND DEVELOPMENT EDUCATIONCSCF decisions are based on the quality of the proposals as measured against Fund criteria, especially the projected benefit of the intervention to poor people. In practice though, we find we have a very good spread of support across a range of large, medium and small civil society organisations.
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| 14. | 4.4 Privatisation and Water DevelopmentWater privatisation is largely donor sponsored and the release of aid funds is often conditional on the privatisation of water. Water privatisation in SSA has always required a foreign investor, therefore the international dimension of privatisation requires extra vigilance, particularly since water provision is a "natural monopoly".
| 4.4 Privatisation and Water DevelopmentDFID recognises the role for the private sector in the provision of safe water supplies and appropriate sanitation, since the private sector can provide additional resources and more efficient management practices. However, we are seeking to ensure that private sector participation is encouraged through partnership with government and civil society organisations.
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| 15. | 4.5 Rights-Based DevelopmentThe rights-based objectives of the CSCF are not reflected in much of DFID's work abroad.
| 3.1 A Broad ApproachWe primarily support projects that strengthen the capacity of poor people to understand and demand their rights—civil, political, economic and social—and to improve their economic and social well-being. But we are not dogmatic about this, recognising that some rights-based projects necessarily include an element of service delivery.
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| 16. | 4.5 Rights-Based DevelopmentDFID emphasises that principles contained in its public policy documents are not binding on its staff and have no operational status. Instead, they are meant to publicise DFID's overall approach to development and, as such, are aspirational strategic documents that shape overall priorities for UK official overseas development assistance.
| 4.5 Rights-Based DevelopmentDFID's approach to working with civil society has been set out in a number of published documents, but it might be helpful to go back to our strategy paper Realising Human Rights for Poor People which was published in October 2000 (available on our website). This outlines what DFID means by a rights based approach.
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| 17. | 4.5 Rights-Based DevelopmentDFID's understanding of rights can be too narrow to meet the diverse needs of the poor.
| 4.5 Rights-Based DevelopmentThe human rights approach to development means empowering people to take their own decisions, rather than being the passive objects of choices made on their behalf. A rights perspective means incorporating the empowerment of poor people into our approach to tackling poverty. It means ensuring that poor people's voices are heard when decisions which affect their lives are made.
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| 18. | 4.5 Rights-Based Development"The CSCF above all else is for improving the lives of poor people" (Para 3.11 of the CSCF Guidelines for Applicants dated 6 May 2002) while "initiatives which consist primarily of service delivery . . . will not be eligible" (Para 3.7). Yet access to clean water and a sustainable livelihood are fundamental and indispensable human rights.
| 3.1 A Broad ApproachCountry offices will develop their individual approaches to funding of CSOs. We recognise that where appropriate, this may include elements of service delivery. But our country offices will not support service delivery projects that replace or cut across the services that should be delivered by governments.
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| 19. | 4.5 Rights-Based DevelopmentFor consistency, the UK Government should be advocating the rights based approach within international development fora, in its multilateral lending programmes and in the policies and programmes of multilateral institutions. DFID should adopt a binding policy on indigenous peoples.
| 4.5 Rights-Based DevelopmentIt is not possible to develop a universal blueprint for working with civil society, but DFID's general approach focuses on participation: enabling people to realise their rights to participate in, and access information relating to the decision-making processes which affect their lives. Different strategies and mechanisms will be developed for particular country contexts.
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| 20. | 4.6 Scale and Cost EfficienciesDFID's policy is to support civil society—trade unions, faith groups and community organisations. This is to be applauded but the allocation of funds should not be based on percentages and the type of organisations, but on the quality of the projects proposed.
| DIVERSITY AND DEVELOPMENT EDUCATION4. We make no distinction about the size of a CSO when appraising the quality of project proposals, other than considering an organisation's financial capacity to handle DFID funding.4.6 Scale and Cost efficienciesAllocation of funds through the CSCF is based on quality of proposals.
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| 21. | 5. RecommendationsDFID be invited to release data of value to small international NGOs, probably via their web site.
| ConclusionsWe shall ask BOND what additional information—over and above that already available—might be of use to CSOs.
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| 22. | 5. RecommendationsA reciprocal consultation mechanism be established between DFID and small international NGOs by which both sides can listen and learn, probably using BOND.
| ConclusionsA reciprocal consultation mechanism is already available through BOND. We shall consider what additional consultations with Policy Division might be possible.
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| 23. | 5. RecommendationsDFID's vision be broadened to acknowledge that there are diverse paths to be followed in addressing global poverty and that, in the end, development is primarily about people, not policies.
| ConclusionsDFID agrees that there are diverse paths to poverty reduction. Our policies are developed with poor people in mind, and we intend to keep that broader vision in mind as we develop future programmes.
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| 24. | 5. RecommendationsWe would like to request that the IDC undertake a formal review of DFID's policy and practice in relation to small NGOs.
| ConclusionsDFID would be happy to participate in any formal review of our policy and practice in relation to small CSOs, or to provide any additional information the International Development Committee may require.
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