The Future of the Environmental Action Program for Central and Eastern Europe (EAP) - What NGOs can propose for the Kiev Ministerial Conference?

The Environmental Action Plan for Central and Eastern Europe was initiated and implemented in the framework of the Environment for Europe process, in the idea of the international and inter-sectoral cooperation on environmental policies in the CEE region. During the 9 years of its existence, the EAP Task Force played an effective role in promoting environmental policy reforms and capacity building in economies in transition. Financial strategies were developed with input from GEF, WB and EBRD. In all CEE countries, National Environmental Action Plans (NEAPs) have been prepared and Local Environmental Action Plans (LEAPs) have been initiated with a particular focus on Agenda 21. However, we are very much concerned about the low awareness among NGOs of CEE about the EAP Task Force's activities in their countries.

We, the undersigned NGO representatives, recommend that Governments, EU institutions, civil society and NGOs, IFIs, and UN bodies work together to implement actions at regional, national and European levels, in the fields of:

Realization of a new form of environmental policy framework, with the transformation of the now terminated EAP for CEE in a new platform, with much more public involvement, more realistic approaches, more clear funding mechanisms, more tangible results in the reality not only on papers.

Based on existing policy tools, creation and implementation of sustainable development strategies, policies and programs with the effective involvement of large groups of the society, ensuring a real public participation in policy deign, decision-making and policy implementation. The integration of environmental concerns in economic, social, and cultural strategies should be done with respect to the needs of our days, not damaging the rights of future generations.

Promotion of a sound development in CEE, not undermining traditional lifestyles, traditional rural societies, but helping them to get their role in our new Europe. The profit oriented and development driven society should give a chance for the "extensive" rural lifestyles with a coexistence with nature, widespread in many regions of CEE.

Counterbalance infrastructure development, urbanization, and other signs of development with a strong biodiversity conservation and nature and landscape protection scheme with a funding mechanism able to deliver real results, stopping the actual decline. Biodiversity conservation and sustainable use of biological resources should be the base of any activity in the sectors of agriculture, forestry, fisheries, tourism etc. Find solutions for the maintenance of the rich biodiversity of CEE, and help not to repeat the mistakes of the west.

With respect to the following themes, we recommend the following actions:

  1. Improve the enforcement of environmental legislation in CEE countries, by ensuring sufficient human, technical and financial capacities at all levels, and monitor the process of implementation of environmental policy and financial strategies,
  2. Establish new and effective models of partnership between governments and NGOs,
  3. Strengthen strategy-formulation and project development capacities in governmental and non-governmental sectors,
  4. Strengthen REC's capacity as the Secretariat for a new platform for environmental policy development and information management structure,
  5. Improve visibility, information dissemination and awareness raising on EAP activities and results, make it more transparent and clear for stakeholders,
  6. Redesign NEAPs with clearer priorities, schedules, financial obligations and methods and clear criteria to select cost-effective projects, and realize and disseminate analysis of god and bad practices in environmental policy formulation and implementation,
  7. Strengthen and extend co-operation with NGOs, involve businesses in the environmental activities, strengthen environmental management of enterprises, NGO-business partnerships and co-operation, and improve NGO funding.
  8. Work on harmonization of environmental policy between EU, accession and non-accession countries and implement these policies at national level.
  9. Promote experience exchange, cooperation on management of shared resources, pollution control, between CEE and EECCA in order to strengthen understanding of environmental values, problems, strategies, cost effectiveness etc. The know-haw accumulated in CEE in the period of transition, possible to be transferred in EECCA can cover issues like dealing with problems of involvement in policy formulation, partnership building between NGOs and Governments, real public participation, effective communication, networking, "business plans" for NGOs, media work, collection, processing and dissemination of relevant information, database management etc. In our world with so many conflicts, the cooperation in the environmental field should be a platform for building peace and mutual understanding.

The Future of the Environmental Action Program for Central and Eastern Europe (EAP) - What NGOs can propose for the Kiev Ministerial Conference?

Europe, EU, borders, cooperation. From my window I can see some Ukrainian hills and mountains spreading beyond Tisa River. As a result of the EU enlargement, my city will be soon on the end of the EU territories. Soon this river will become part of the formal boundary delineating countries outside EU. The borders are politically unavoidable, they are parts of our political-territorial human behavior, although they separate similar human populations and similar ecosystems. Borders, those temporary demarcation lines should be soft demarcations. The cooperation between people from both sides of any border should be easy in reality. We should not feel that we are in separate worlds, on the right or on the wrong side of a demarcation line. Riversides, both are parts of the same river, mountains here and there make up the same chain - the Carpathians, people here and there are both Europeans. We share our environment and resources like the Danube Delta and the Black Sea, and we need to collaborate towards their conservation. The cooperation between people across any border should be easy provided that there is a mutual desire to understand and respect each other, and a willingness to work together.

The Environment for Europe process. In early 1990s, in Europe was a strong feeling of being together again. This was the time when the "Environment for Europe" (EfE) process was started. Since, it has produced real cooperation on a territory larger than Europe. EfE has been a real work-together of various stakeholders, from small NGOs, local authorities and Governments to EU institutions, IFIs, and UN bodies. It is a platform for permanent debate on programs, conferences, conventions, strategies, background papers, and much more. From an environmental and human perspective it is rewarding to appreciate EfE's role in policy reform and cooperation between so many people. For an environmentalist, it is nice to see that all this work is done in the idea of environmental policy reforms, for a better protection of our environment. Even more important, from the point of view of each human being, it is the chance to notice that cooperation between so different people it is possible and fruitful, even if some conflicts are inevitable when pushing this or that idea on a limited agenda. In our world with so many conflicts, the cooperation in the environmental field should be a platform for building peace and mutual understanding.

NGOs' previous knowledge about/participation in the EAP, and EAP TF. The European Eco-Forum - a Pan-European coalition of more then 200 NGOs from the UNECE region - monitors the EfE process and has taken an active part in the EAP Task Force work from its very beginning. In anticipation of the Ministerial Conference in Kiev, we are analyzing the past, present and future of the EfE process, and are working to elaborate our vision and recommendations to the Ministers. A meeting was held in Bratislava, Slovakia, 2003 December 6th, titled "The Future of the Environmental Action Program for Central and Eastern Europe (EAP) - What NGOs can propose for the Kiev Ministerial Conference?" followed in December 7-8 by the "Eco-Forum Strategy Meeting".

The aim of the first meeting was to initiate a dialogue between CEE NGOs to result in a common strategy and position to be presented at the EfE. The following major issues were on the agenda:

  1. an overview of the EAP and progress on its implementation after 9 years of work,
  2. changes in the environmental policy of the CEE countries,
  3. the effectiveness and role in promoting positive changes, of the "Environment for Europe" process, EAP Task Force and REC,
  4. the influence that the separation in country-groups has on the EAP in CEE,
  5. the future of the EAP in the CEE region: How should the regional activity of EAP be co-ordinated? Should it be done by Regional Environmental Center (as it is now)? What should be the main priorities for future capacity building on environmental policy in CEE? How to involve in the most effective way major groups in environmental policy design and implementation in the CEE? Is the exchange of information and experience between CEE and the EECCA necessary? If so, how should it be organised? How can CEE countries contribute to the elaboration of the Environmental Strategy for the EECCA countries?
  6. future steps for the preparation of the CEE environmental NGOs position on EAP issues for the Kiev Ministerial Conference.
Here is a summary of the main points as captured in the minutes of the Bratislava meeting.

During the 9 years of its existence, the EAP Task Force played an effective role in promoting environmental policy reforms and capacity building in economies in transition. Financial strategies were developed with input from GEF, WB and EBRD.

Participants have agreed that to strengthen EAP Task Force's activity in economies in transition, it is necessary to:

  1. establish new models of partnership between governments and NGOs,
  2. monitor the process of implementation of environmental policy and financial strategies,
  3. strengthen REC's capacity as EAP Task Force Secretariat for CEE,
  4. improve information dissemination and awareness raising on EAP activities and results, make it more transparent and clear for stakeholders,
  5. strengthen and extend co-operation with NGOs,
  6. involve businesses in the environmental activities,
  7. promote experience exchange between CEE and NIS to strengthen understanding of environmental values, problems, strategies, cost effectiveness etc.
  8. Additional issues discussed in Bratislava CEE NGO EAP workshop (December 6), and after that in Eco-Forum Strategy Meeting (December 7-8, 2002) related to the environmental management of enterprises, NGO-business partnerships and co-operation, and NGO funding.
Regarding NEAPs, NGOs from Poland, and Romania, present at the meeting stated that they were not involved in their preparation. One Slovakian NGO was involved in the NEAP implementation. In Estonia, "NGOs know nothing about EAP. At the same time, they know about NEAP."

Additional issues discussed in Bratislava CEE NGO EAP workshop (December 6), and after that in Eco-Forum Strategy Meeting (December 7-8, 2002) related to the environmental management of enterprises, NGO-business partnerships and co-operation, and NGO funding. A representative of a Slovakian NGO noted that in his country a co-operation between different stakeholders will be evident: "From January 2003, business will have to pay 1% of their taxes to the NGOs. This decision was initiated by NGOs and political parties. The overall sum will be approximately 1-2 billion crones." In Hungary, private persons can direct 1 % of their taxes to an NGO of choice. As far as Poland is concerned, the "Linkage between private and public is not clear. Public is afraid of corruption. The management of enterprises had to be significantly improved. Environmental legislation has moved forward. Success is obvious. Enterprises have adopted ISO 14000. Eco-Fund is very active and is dealing with project efficiency. There is a functioning system where everybody can pay money for NGO activities to reduce taxes." Regarding environmental funds, it was stated that there are none functional in Romania and Slovakia, while in Poland, even if it is national, "It belongs to the Ministry of Finance and its activity is not transparent. A special meeting was held in September 2002, to analyse haw this fund can support NGO activities." In Bulgaria, "Big enterprises have to pay low taxes for the environmental fund. Old enterprises have no money to improve the environmental management. It is an urgent need to improve environmental legislation. This legislation will have some changes next year (2003)."

The NGOs from Poland, Slovakia and Romania, represented at the meeting were not involved in the preparation of the NEAPs. A Slovakian NGO was involved in the NEAP implementation. In Estonia, "NGOs know nothing about EAP. At the same time, they know about NEAP. In 1998-2001, a second NEAP was prepared. NGOs were involved in its elaboration and further implementation. Environmental legislation is approaching the EU legislation." Here is a part of a declaration from a Polish NGO representative: "I thought that the initiative for NEAPs, improving environmental management of enterprises and improving national environmental legislation in Poland comes from Brussels. Now, I realise that some activities came from EAP TF as well. It was not obvious before the workshop. REC helped CEE realise that there is a place for CEE to participate in EfE." Another Polish opinion was really critical: "We see improvements in everything, changes in awareness raising for example. At the same time, there are new problems, which we need to address: transport, new sources of pollution, consumption habits, wrong relations between environmental problems and financing. EAP can't solve them, it helps to solve easy problems, for instance, closing of factories. Now we have to make tough decisions: no improvements in transport, consumption, agriculture. This EAP TF is not effective. REC can do nothing. It was good at the beginnings. Now, the role is lower. It can facilitate something, but it is difficult for it to find real solutions. An NGO representative from Slovakia stated: "EAP TF is not visible. NGOs are not involved in its activities. It should be more transparent, more obvious and clear for stakeholders." A representative from Estonia said, "Good contacts with REC are established, but there is no influence on EAP in the country." In this context, a Bulgarian opinion was: "We need some structure to strengthen our government attempts to fulfil environmental tasks.", and a Romanian one is: "EAP TF should continue co-ordination, even though people do not know much about it, but more about the results."

In Romania, the improvement of the environmental legislation is mostly (or only) a result of the EU accession process. "We can see improvements in the environmental legislation mainly because 97 % of the national legislation has already been harmonised with the EU legislation." The environmental management of enterprises will need to be changed to comply with the accession requirements. The Romanian NEAP, emphasises the need for a cost-effective environment protection programme, but no clear priorities are given, no clear schedule, no financial obligations are mentioned. Plans and projects are mentioned, but without clear criteria and priorities. The low standard of the Romanian NEAP was mentioned, and the idea that EAP TF should invest into project elaboration capacity. In Romania, REC has organised the elaboration of a list of priority projects, which are needed for the improvement of the country's environmental performance. Regional EAPs are under preparation with special focus on industrial, agricultural and mining sectors. Eight LEAPs will be prepared together with the REC. The project preparation capacity of NGOs has been improved, but still, NGOs have to face a very high level of bureaucracy related mostly to EU funds.

Regarding the future of the EAP and EAP TF in CEE and the co-operation between CEE and NIS, there was general agreement that EAP TF activities must be continued, but with new priorities, and a better commitment to achieve real results. A representative of the NIS (from Ukraine) stated that in his region "EAP TF is not an issue."

The following part of the Bratislava Declaration is related to the EAP: "We welcome the effective role that Environmental Action Program (EAP) for Central and Eastern Europe (CEE) and the EAP Task Force played in promoting environmental policy and capacity building in economies in transition. In all CEE countries, National Environmental Action Plans (NEAPs) have been prepared and Local Environmental Action Plans (LEAPs) have been initiated with a particular focus on Agenda 21. Following the EAP methodology in many CEE countries Regional Environmental Action Plans (REAPs) are now being prepared together with criteria for selecting new regions.

In all CEE countries financial strategies were developed to facilitate financing of environmental projects. We recall that the activity of the EAP Task Force for EECCA has been focused on identifying obstacles to and opportunities for financing of environmental investment projects and building mechanisms to finance environmental projects with various degrees of success in different countries.

However, we are very much concerned about the low awareness among NGOs of CEE and EECCA about the EAP Task Force's activities in their countries.

We consider that the work on the implementation of the EAP in CEE region should continue. We insist on improving the efficiency of this work. For this purpose, the EAP Task Force needs to continue its work in CEE and EECCA, taking into account new environmental problems such as new sources of pollution, consumption habits, public participation, misfits between environmental problems and financing, the need to harmonise environmental policy between EU, accession and non-accession countries and to implement it at national level.

We are aware of the process of EECCA Environment strategy elaboration and have had on-going discussions on its elements and background documents. NGOs of the region express a wide range of opinions on the developing Strategy and procedures. We will continue the discussion and further formulate our position and proposals in preparation to Kyiv.

We propose the creation of multi-stakeholder bodies to assist in the process at national level. We welcome the NGO initiative to assess national environmental policies in their countries and invite the REC and New RECs to support this activity in the spirit of co-operation with the ECO-Forum and civil society."

The Bratislava Declaration emphasised: "(à), we are very much concerned about the low awareness among NGOs of CEE and EECCA about the EAP Task Force activities in their countries."

On behalf of the European Eco-Forum EAP Issue Group, I have coordinated an all-inclusive and transparent process of electronic consultation of CEE environmental NGOs. The request to contribute to a common strategy and position was distributed via e-mail to more than 1.500 CEE environmental NGOs in 15 countries. As far as the EAP and EAP TF are concerned, the electronic consultation has echoed the results of the Bratislava meeting: "We have heard about it, but have never been involved in it. (Slovenia, electronic consultation)". Here is a part of a declaration in Bratislava, from a Polish NGO representative: "I thought that the initiative for NEAPs, improving environmental management of enterprises and improving national environmental legislation in Poland comes from Brussels. Now, I realise that some activities came from EAP TF as well. It was not obvious before the workshop. REC helped CEE realise that there is a place for CEE to participate in EfE." Another one is here: "As an NGO, through our activities, conference visits, contacts with other NGOs and other organizations, and Internet and e-mail communication, we have a basic knowledge of EAP's background and goals. However, we have never been involved in any kind of activities on EAP and we have insufficient good quality information about the work of the EAP TF. (Bosnia and Herzegovina, electronic consultation)" Considering that environmental NGOs are among the most interested and active actors of the society, one might conclude that public involvement and ownership in the EAP process in CEE are insignificant. The process should be based on transparency and community involvement, without which sustainable development and environmental protection are meaningless. It is not easy and it is not cheap to build ownership and public participation, but without these items the chances of a real success are very low or even zero.

The general awareness about the EAP is very low, even between the important environmental NGOs. From the smaller local NGOs very frequently you can hear that they don't know about EAP, also the interest to find out about some papers, strategies, with very general statements and unclear reasons where, by whom and why they were wrote. The wording frequently is something like here, in the text elaborated by Man and Krkonose, from Czech Republic: "It is not within my or my NGO capacity to comment on this. (à) Neither me, nor my NGO had been informed about this initiative (EAP)".

The NGOs which are well informed in environmental policy developments (very few NGOs, or more exactly persons from NGOs), are able to see that the EAP in CEE will be finished, so why to invest time in analyzing something which is going to be terminated? Most of the NGOs staff which I know are working hardly on project writing and implementation on a day by day basis, and there is not much time and energy to discuss something which is without a clear future, without financial basis for future activities in which NGOs can be involved.

Nowadays, with the EU enlargement, the focus of the environmental NGOs from the CEE region is oriented to the problems and opportunities produced by these major changes. Resources like time, manpower, money and energy, also the interests are oriented towards the EU. A frustration of the relevant environmental NGOs is that in the EAP they were not really involved, so they don't feel the ownership on the process, being not involved they don't know very clearly what it is about, and in this case they don't take the risk to formulate opinions, which (if mistakes appear) can damage their image as reliable information sources.

In the time of this electronic consultation many irrelevant information has been sent by different NGOs, not focalized at all to the theme of the EAP or environmental policies, but important themes for the specific organizations. On specific local themes lots of information has been gathered, like on Tisza River pollution in Hungary by the cyanide spill from Baia Mare, Romania, but these political and numerical data are not very relevant in this context.

In plus, we should consider that most of the relevant environmental NGOs are working in other areas than environmental policies, having specific themes like bird protection, or bats, or plants, or wolves, or a specific area, a lake, a mountain, or are interested in environmental education, in organic agriculture etc, but the EAP is too general for most of them. To be able to formulate a coherent statement about the environmental policy of a country or about the environmental policy in Central and Eastern Europe, you should be involved from a long time and up to date in different environmental policy areas, from biodiversity conservation and nature protection to energy, infrastructure, urban and rural development, to water management, education, politics etc. This case is not frequent.

NGOs vision on the effectiveness of environmental policy reforms and environmental policy implementation in Central and Eastern Europe. The EAP implementation in CEE has lead to policy reforms, institution strengthening and the promotion of environmental investments in the economies in transition. Some good examples, although of varying quality and degree of success across countries, are the elaboration of National Environmental Action Plans (NEAPs), the initiation of Local EAP (LEAPs) with a focus on Agenda 21, and of financial strategies that facilitate funding of environmental projects in all CEE Countries. These were a good exercise for the development of a strategic thinking and allocation of scarce resources for the most important, urgent and cost-effective projects.

The downside of EAP is the amount of work put into producing papers: strategies, agreements, background papers, conventions etc., while their implementation is very poor. We are still very far from the real needs, even from the basic ones. The NGO opinions received through the electronic consultation mentioned EU as the most important driving force behind the environmental policy reforms in the CEE countries. At the same time, questions are raised with respect to the ability of countries to implement this legislation. Law enforcement is weak and public participation is more fictitious than reality. In a comment from Bosnia and Herzegovina was stated that "(à), it is a general rule in our country that the implementation of prepared documents goes very slowly. The main obstacles to implementation are insufficient human, technical and financial capacities at all levels." Implementation requires more resources. From capacity building to law enforcement, from communication to awareness raising and public involvement, all these are in a deep need for money. And we can agree that without implementation all the papers are not much worth.

An issue that comes to the front in the several responses received from various NGOs through the electronic consultation is the crucial need to implement the many environmental laws adopted perhaps in a hurry by countries in the process of accession to the EU. This was emphasized by the DEA Klub, Citizens' Anti-Toxics Action from Slovenia who also warned against inadequate control and corruption that facilitate the movement of 'dirty industries' from Western Europe to the East.

From the viewpoint expressed in the electronic consultation, here are the ideas of DEA Klub, Citizens' Anti-Toxics Action, from Slovenia: "Slovenia has adopted most of EU legislation. The same will sooner or latter happen to all other CEE countries. However, the goal shouldn't only adoption of EU legislation, but ability of the countries to implement this legislation in real life. Not only implementation, but the same standard of control and law enforcement as in developed EU countries should be required and realized together with new regulations. There are cases where the new regulations with very high standards that would be very difficult and expansive to achieve are used as argument against local communities or NGOs while introducing problematic investments in our countries. For example, there are many proposals in Slovenia and other EE countries to build incinerators that will never operate under same conditions in countries stronger from the point of view of democracy ad economy, due to the lower investment and lack of money for maintaining the filters etc. Environmental policy in developing countries as Slovenia should avoid historical problematic practices as incineration of waste. The lack of adequate control, corruption and connections of the officials with the industries and weak law enforcement will enable such companies to avoid penalties in the case of their bad environmental performance and cheaper operations. Moving dirty industries together with the incinerators to the East means changing path of Slovenia and other EE countries development towards junk place for developed parts of EU. (à) It is good that formally, we have adopted and closed all chapters on environment. It is bad that NGO involvement is weak, specially on the strategic phase. For example, our NGO that is HCWH (Health Care Without Harm) focal point in Slovenia asked to be involved in Medical Waste Strategy Commission at the Ministry of Environment, but was refused. In the same Commission there were some representatives not only from some scientific institutions but from the business as well. NGOs and public are not involved in regulation preparation. We have some weird system of inspection, which is totally ineffective towards polluters. Sometimes the polluters even control themselves and the data reported to the Ministry are from the companies' own laboratories. The inspection and penalties are not adequate."

The Center for Environmentally Sustainable Development, Sarajevo, has underlined the progress made by the government of Bosnia and Herzegovina in various aspects of environmental law and policy. Though, however fortunate these developments are, they don't have an impact until implemented. Our colleagues from Sarajevo have pointed out the main obstacles to implementation, namely insufficient human, technical and financial capacities at all levels.

Here is the opinion expressed on behalf of the Center for Environmentally Sustainable Development, Sarajevo: "In the past several years, the government of BiH has initiated a lot of projects concerning environmental reforms in the country. Some of them, and the most important ones are:

  1. establishment of Environmental Steering Committee, for inter-entity co-operation on environmental issues,
  2. preparation of a new set of Environmental Laws (Framework Environmental Law, Law on Nature Protection, Law on Waste, Law on Air, Law on Water Protection), harmonized for both entities and in accordance with EU laws and directives. The laws are adopted in Republic of Srpska, while still waiting for adoption on the House of People in the BiH Federation,
  3. preparation of the Solid Waste Management Strategy, studies on Water Sector Institutional Strengthening, Environmental Protection Assessment from Industrial, Medical and other Hazardous Waste in BiH, Urgent Strengthening of Environmental Institutions in BiH,
  4. drawing up of BiH's NEAP (now in its final phase),
  5. drawing up PRSP - Poverty Reduction Strategy Paper (in progress) with a chapter on environment,
  6. activities on establishment of Environmental Protection Agency BiH at the state level,
  7. and other smaller, but not less important activities.
Without doubt, these are very positive happenings in our country, which will hopefully lead to a better future regarding the environmental protection. It is still early to talk about the effects of these reforms, because many of them are either in the progress phase, or are just recently completed. What can be said now is that in the following period, the government will have to work on elaboration of implementing bylaws that are needed for efficient implementation of the new framework lows.

However, it is a general rule in our country that the implementation of prepared documents goes very slowly. The main obstacles to implementation are insufficient human, technical and financial capacities at all levels. Project Urgent Strengthening of Environmental Institutions in BiH, financed by WB/METAP and prepared by Hydro-Engineering Institute Sarajevo provides an analysis of basic needs related to human and technical capacities required for successful implementation of environmental reforms in the country.

The main criticism should be directed to the preparation of the development strategy for BiH with the accent on poverty reduction (PRSP document). In this document, that will create the framework for economic and social development of the country, of 400 pages, only 15 are devoted to environment, which is more than insufficient to adequately address the problem. In the country where economic development is based on over-exploitation of natural resources, more attention should be paid to this aspect in such an important document.

Concerning the reforms in CEE, much progress is done toward European integration. We believe that many CEE countries have the same problems of implementation of projects and reforms, so more should be done in this direction."

From the Focal Center for Biodiversity, from Romania, we have received comments on the "Mediu", the Romanian environmental NGOs mailing list. Here is mentioned that the Romanian environmental legislation is growing because of the EU pressure, in the framework of accession. Even if the legislation is in place, the law enforcement is the problem. "Many of these laws are sterile ones, so the each strategy remain an illusion, an environmental theatre with an elaborated ballet, but nothing more." It is mentioned that we have an low capacity to elaborate projects and to implement them. "We have a complicated environmental and financial legislation, which is not helping project implementation but is a difficult obstacle. A new procedure of acquisition appeared. For example, in the project in which I'm involved, if the toner is finished, I should complete a dossier. Yes, yes. A folder with a description of necessities, price offers, justification of acquisition, the scope etc. etc, so I lose time with such papers permanently. (à) I remain convinced after reading this strategy, and also others, that they are not more then talking in the wind. Fallow for example which part of the national environment conservation strategy (the green booklet with many mistakes, even errors in scientific names - unpermitable in my opinion) were accomplished."

NGOs' proposals for future areas of activity in environmental policy in the CEE region. Regarding the future of the EAP in the CEE, the Bratislava Declaration concluded: "We consider that the work on implementation of the EAP in CEE region should continue. We insist on improving the efficiency of this work. For this purpose, the EAP Task Force needs to continue its work in CEE and EECCA, taking into account new environmental problems such as new sources of pollution, consumption habits, public participation, misfits between environmental problems and financing, the need to harmonise environmental policy between EU, accession and non-accession countries and to implement it at national level." Contrary to this, from the Tbilisi Meeting resulted that "the EAP in CEE will be terminated". The main reason for this is that most CEE countries will soon become EU Member States having to enforce the environmental acquis and there will not be much room for something like EAP. For some other countries, in SEE, the REReP will remain functional, and new horizons are emerging in the direction of Turkey. It was agreed that the focus of the EfE process will be oriented to the EECCA. In this general political framework, NGOs should orient their strategies in the direction where they can see chances to have a role, which they can fulfill.

Some of the proposals received for future areas of activity in environmental policy in CEE countries and the CEE region as a whole are: "Implementing the zero waste, clean production, and the right to know as the main points of sustainable development (Slovenia, electronic consultation)." "The top priority is elaboration and adoption of implementing bylaws that are needed for efficient implementation of the new framework environmental lows. From the current standpoint, for BiH the second priority activity would be to establish a state level Environmental Protection Agency. At present, BiH has no institutions at state level that deal with environmental issues which is very limiting in the international relations. The other important issue is implementation of the project Urgent Strengthening of Environmental Institutions in BiH, which address reorganization of environmental sector and development of environmental monitoring system, which is very weak and dispersed, and does not respond to the current and future needs. In the CEE region, the focus should be on more intensive co-operation between the countries in the region all with the aim of approaching the EU standards. (Bosnia and Herzegovina, electronic consultation)."

In April 2002, the Environmental Strategy for the NIS was launched by EECCA (=NIS), and was later presented as an East-West Partnership at the WSSD. On this topic, in Bratislava was questioned whether or not this strategy model would apply to the CEE. Some comments were pessimistic: "The process of the development of the strategy is not satisfactory now. There are 7 objectives, but only 6 background documents. They are poorly done. It is a poor summary of several ideas. What should be done with those papers? Russian Government does not work on this document in reality. Several governments of other countries don't work on the strategy either. It is only initiated by some experts and the results are not good." From another, more optimistic point of view, "Only governments should be responsible? It is their responsibility to invite experts to (à) realize this Strategy."

In the electronic consultation, we have also received many ideas not directly related to the EAP, but some of them raise important questions for the essence and meaning of NGOs in the CEE. The Mass-Media and Environment, one of the main environmental NGOs from Albania has brought to attention the crisis in which most NGOs find themselves in that country. Foreign organizations come into the country with money for specific projects 'to help Albania', while the local NGOs barely survive. To make things worse, almost all Albanian deputies and leaders of government have their own 'pet' NGO. In the words of our colleagues: "in the morning they are governmental and in the afternoon "non-governmental", in the morning they discuss with the donors and suggest them to send money to his NGO, in afternoon they take this money and manage it without control of government".

Here are some issues received from the Mass-Media and Environment, Albania. "First, I think that Albanian NGOs are in crisis. They can't exist financially. Donors leave Albania, and only few re rested, government don't support them, private companies don't like to give money to environmental NGOs. From the other side, the Albanian low let each foreigner to open an NGO in Albania. They have good links with big donors, abroad (including CE or different governmental projects of European Countries). So, they came in Albania with money of Project in their pockets "to help Albania", meanwhile the Albanian environmental movement is paralysed. Almost all Albanian deputies and leaders in government have their "non-governmental" NGO. So, in the morning they are governmental and in the afternoon "non-governmental", in the morning they discuss with the donors like leader and suggest them to send money to his NGO, in afternoon they take this money and manage it without control of government, this is their main business. It is only one way to exist like an NGO: Don't respect the moral and the ethic of an NGO, be servile of leaders, don't oppose them and don't make critics, collaborate with them with money in cash. So, finally, with which kind of Albanian NGO you would like to collaborate?"

View about Macedonian environmental policy and the current environmental situation in the Republic of Macedonia

The Republic of Macedonia, like other Central and East European countries in transition, has started the process of reform towards a market economy. As part of the economic development program, the Republic of Macedonia is shaping its environmental policies and identifying priority actions to protect human health and the environment and to utilize its natural resources in a sustainable manner. These policies and actions are consistent with the 'Environmental Action Programme for Central and Eastern Europe' (EAP), the document adopted at the Ministerial Conference in Lucerne in 1993.

In meeting its goals towards protecting the environment, the Government of the Republic of Macedonia in 1996 had prepared the National Environmental Action Plan (NEAP) with the support of the World Bank group.

While it has been almost seven years since the NEAP was prepared, it seems we face the same environmental problems. This is due to the fact that not much it had been implemented from the NEAP in Macedonia.

Environmental programs so far have been modest and there is need for an effective environmental management system through implementation of regulations and strengthening of institutions. In spite of lower production levels, industries continue to be the major polluters. Old inefficient production technologies, inadequate waste control equipment, and weak environmental enforcement are the primary causes for industrial pollution. Some of the crucial environmental issues in the country are poor air quality in some urban areas, polluted surface water due to discharge of untreated wastewater, and inadequate solid and hazardous waste management system.

A number of institutions are responsible for environmental monitoring; however, coordination between these agencies is poor. Also, not all parameters typically used to index pollution are measured due to lack of resources, unavailability of chemicals for analysis, and obsolete equipment. The cause effect relationship between health and pollution is not clearly known, except for a few urban areas.

Although a number of NGOs exist, environmental monitoring data are not widely distributed. As a result, public awareness on environmental issues is lacking.

Expenditures from the budget on environment is less than 0.2% in the last couple of years and are not expected to increase significantly in the near future. Thus, enforcement should be strengthened to provide incentives to polluters for clean up the environment. The private sector, wherever possible, should be encouraged to participate. For the private sector to be involved, environmental liabilities due to past practices should be established. This emphasizes the need for environmental audits and environmental impact assessments. Also, municipalities and public utilities should be able to raise tariffs to meet costs, in accordance with the Convention on Accommodated Tariff Systems of the World Trade Organization.

In order to create an efficient environmental management system, alterations of the present institutional structure are imperative. Environmental quality data should be publicly available and NGOs should be encouraged to disseminate information on the environment as much as possible.

Poor air quality in some urban surroundings is a major environmental concern. The main reason for air pollution is emissions from industry and automobiles. The large industrial polluters are known and their emissions should be controlled as soon as possible for health reasons through regulatory pressures and economic operations. The country should develop an action plan to phase-out lead in the gasoline, which will include policy measures, steps taken by the petroleum industry, and methods to build public awareness on the harmful effects of lead. The Republic of Macedonia is a signatory to the Montreal Protocol, which commits the country to phase-out the use of Ozone Depleting Substances (ODS). A plan is now being developed to phase-out the current use of 500 tons of ODS. The most significant problems regarding water pollution are due to discharges from the mining sector, industrial plants and livestock farms, as well as from municipal water from larger settlements. There are only three municipal wastewater treatment plants in the country and only 6% of wastewater in the country is treated which results in water (ground and surface) pollution. To address wastewater problems, regulations should specify pre-treatment for industries and the water quality problem should be considered with water resource issues at a local level. A local approach to building or upgrading wastewater treatment facilities, modernization of water supply and irrigation systems, management improvements and rational utilization of water resources should be pursued.

Inadequate solid and hazardous waste management is also a major concern in the country. Currently, there are no regulations on waste handling and as a result there is indiscriminate dumping of wastes, especially industrial wastes, which are a health hazard. As a first step, appropriate regulations that specify collection, transportation, and disposal of wastes should be developed and the role of institutions to monitor waste management should be outlined. The private sector should be encouraged to participate in the collection and transportation of wastes.

It is generally accepted that issues related to agricultural and forestland management are important environmental problems. Regular survey of soil fertility, controlled use and treatment of agricultural and animal waste, and of the secondary waste is necessary in Macedonia. To ensure sustainable agricultural development, policies that encourage land preservation should be implemented and training to farmers and land conservation lists should be provided. Land use plans should be developed with a participatory approach to prevent further urbanization of arable land.

Preservation and improvement of the forest resource base is a long-term target of the country. However, the current practice of using timber from within a national park as a revenue source to maintain the park has to be discontinued. Sustainable forest management plans have to be prepared which should include preservation and aforestation programs. Revegetation of barren lands and rehabilitation of erosive regions and production and utilization of medicinal and other forest products should be highlighted. Hunting management should be improved and hunting plans respected, in order to sustain hunting game populations.

Although the country possesses a significant biodiversity potential, monitoring is inadequate. The existing institutions for biodiversity protection are weak and the biodiversity are not utilized in a sustainable manner. The recommendations comprise adopting a program for biodiversity conservation, joining international biodiversity programs, and adopting a program for environmentally sustainable tourism. A program to increase public awareness on the need for protection of rare and endangered species is especially important.

Vlatko Andonovski
MAKMONTANA - Association for the development of
mountain regions in the Republic of Macedonia
P.O. Box 235
1000 Skopje
Republic of Macedonia
tel: ++ 389 70 332113
fax: ++ 389 2 379748
e-mail: silva@unet.com.mk

My statement about Polish ecological politics and the general situation of environmental non-profit organizations in Poland

Many people think that considerable progress towards environmental protection in Poland has been accomplished during the last 14 years, but as an activist from an ecological NGO in Poland, I would say that the situation has been getting worse. During the first years after the collapse of socialism in Poland, people were enthusiastic that finally they could express their opinions, organize meetings, and influence politics. New laws were created and obsolete, dangerous, and troublesome factories were closed, which resulted in an apparent improvement in the environment (i.e. less sewage and less pollution). Many active ecological groups were established, people became interested in social movements, and many Western foundations wanted to support ecological programs. With new, well-constructed laws, a large potential in human recourses, and money from the West, the future seemed to be rosy!

The question is, why is it that just a few years later, we face the same or an even worse ecological crises today? For starters, most Western foundations moved their programs to the East. In addition, people in Poland are bored with protests and demonstrations. Currently, they want to join Western wealth and to be Europeans, mostly in a material sense. On this front, I do not have to explain what excessive consumption, more cars, more roads, etc., mean to nature.

My feeling is that governmental policy is often created to facilitate economic development even at the cost of nature. Such is the case with the need to build new highways. In order to decrease costs, laws are changed so that highway construction is possible in protected areas. Further, a larger bureaucracy (sometimes to a paranoid scale), leads to stronger control of the ecological movement. For example, all ecological non-profits now must register as new associations or make changes in their mission statements for the National Register. This registration process takes a considerable amount of time; our NGO had to wait one year just to change a few points, which severely disrupted our work.

Also, the image of ecological activists created in the mainstream media has nothing to do with journalistic independence. NGOs that have something important to say face a lot of trouble. When official policy means economic development but some groups have other opinions, the easiest way to avoid the discussion is to eliminate the opponent. This is not accidental and in some ways understandable, but it demonstrates the real attitude toward the respect of law, democracy, and social involvement.

I could write extensively about ideas for the future and how to influence authorities, create a better image, work with the media, build new networks, and so on. However, we know from our experience that the best way to convince the public that we have to protect wild nature is just to work hard, be professional, organize good and sensible actions, invite valuable people to our projects, be patient, and be stubborn. Some people will appreciate this and we do not have the illusion that it will be based purely on altruism.

Our opinion is that the system of hyper-consumption and Euro-centrism should be changed, but at the same time we are aware that we have to base our activities in a manner that is acceptable to European philosophies. The first step is to show how much people can lose when they destroy precious areas and how much they could gain from protecting nature. Poland is now oriented toward the EU, so there is a need to build ecological networks that will help to convince the Polish government that they have to protect nature because European community wants it. In other words, we need to create strong international pressure.

My NGO had not heard about the EAP initiative previously, but we appreciate it and hope it will be good tool to work more effectively.

Joanna Matusiak
Workshop for all Beings
Ul. Jasna 17
43-360 Bystra Poland

Possibilities of cooperation between CEE and NIS, according to the NGOs Geographically (and not only) CEE is situated between West and East and therefore, it is best placed to understand them both and be a bridge linking these entities. REC and the CEE civil society have accumulated extensive knowledge and experience during the EAP implementation. As I have mentioned at the 14th EAP Task Force Meeting in February 2003 Tbilisi, the CEE environmental NGOs are able to transfer valuable know-how to the EECCA Countries within the framework of the East-West Partnership and refocusing EfE towards EECCA. The CEE sub-region is not yet a wealthy area, to be able to allocate funds in order to help the environmental improvement in EECCA, but the know-haw accumulated in CEE in the period of transition, is at least at the same value as a lot of money. This assistance could cover areas pertaining to dealing with problems of involvement in policy formulation, partnership building between NGOs and Governments, real public participation, effective communication, networking, "business plans" for NGOs, media work, collection, processing and dissemination of relevant information, database management, implementation of the much discussed Environmental Strategy for EECCA etc. CEE environmental NGOs can help their partners from EECCA, Turkey and the Balkans, to be able to work as catalysers in the society, as organizers of public debate on environmental issues, and promoters of our common interest to have a better environment.

When the discussion about EAP in CEE was started in the preparation process for Kiev, the NGOs were not totally aware that the EAP in CEE will be terminated. Now, it seems that this will be the case. In the Environmental for Europe process, now reoriented to the EECCA, the CEE NGOs can participate, helping the EECCA environmental NGOs to not make the same mistakes like in CEE in the transition period.

The most general idea is related to the exchanging of information. "BiH has established co-operation with NIS through the EC DABLAS project. However, BiH and other CEE countries that rose from the same socialistic origin are closer to EU and can be a link between EU and NIS, transfer the knoweledge and technologies from EU already applied and proved to be efficient in CEE. The possibilities for co-operation are much greater in areas like: remediation of polluted areas from common socialistic past, mining waters, democratization of decision-making process related to investment and transparency of natural resource management, capacity building for introduction of cleaner production, management of communal infrastructure etc. (Bosnia and Herzegovina, electronic consultation)" Related to the CEE-NIS environmental NGO cooperation, in the electronic consultation the NGO Man and Krkonose Mountains, from the Czech Republic, stated: "a very general question; cooperation is taking place on different levels and depends on financial sources."

The information accumulated in CEE, about the environment protection in a society under transformation from a centralized to a market economy, is so valuable, that we, the Europeans, can not afford to louse it, or to don't use it in a proper way. As was agreed in Tbilisi, we should establish a "platform" for the transfer of knowledge, but the way to do it is still open for debateà

Peter Lengyel,
Eco-Forum EAP Issue Group, CEE Project Coordinator
(Biologist, Scientific Secretary and Program Manager of
UNESCO Pro Natura, Bucharest, Romania,
Member Organization of IUCN, The World Conservation Union.)
office phone: ++40-21-311-26-44
mobile ++40-744-196-102, ++40-722-459-119
e-mail: pronatura@ccs.ro