We are approaching you on behalf of the European ECO-Forum, the pan-European coalition of environmental citizens organisations, set up to strengthen and promote the "Environment for Europe" process started in 1991.

On the 21-23 May you will participate in the 5^th Ministerial Conference "Environment for Europe" (EfE) in Kyiv, Ukraine. At this conference, all UN-ECE countries can sign on to three important Protocols, that will help to create more transparency about the movements of dangerous substances in our society, organise strategic environmental decision-making with regards to plans and programmes on the national levels, and environmental liability in cases of transboundary impacts of accidents. These are three more products of what has been an important pan-European process of cooperation of environmental authorities and environmental organisations.

In the spirit of this cooperation, at this conference also a discussion will take place on environmental policy integration, organised by the European ECO-Forum, between environmental non-governmental organisations and you as Ministers. The conference will hopefully agree on concrete international cooperation and assistance programs that will give a boost to environmental protection in the region.

The European ECO-Forum, at a conference bringing together representatives of environmental citizens organisations of 28 countries, as well as European organisations including the European Environmental Bureau, and in contact with many more in Europe, have agreed on the "Bratislava Declaration" in December last year. We hope you have had a chance to read our views on what the Kyiv Conference should accomplish. You will recognise that we expect the Environmental Ministers of the pan-European region to show the political leadership that is needed to confront and tackle the serious environmental problems our region is facing.

1. Work towards a pan-European regional strategy to phase out unsustainable production and consumption patterns, to be ready one year after the Kyiv conference, at the next EfE meeting, and with a period of implementation of 10 years. An important element of this strategy shall be the systematic promotion of environmental policy integration, including the broader use of price mechanisms to support policy integration, the removal of trade-distorting, environmentally harmful subsidies, increasing market access to environmental goods and services, including by public procurement, extended producer responsibility, as well as specific objectives for sectoral policies, in particular transport, energy and agriculture. In market economies, it is important that corporate interests cooperate fully and are accountable to the public (par 25). In contrast to what is said in the current draft declaration, we do not believe that voluntary agreements should be promoted as contributing to sector integration as we fail to see evidence of substantial achievements as compared with legislation and market instruments (par. 18).

2. Environmentally sound management of natural resources is of importance not only for the sake of biodiversity. Recognise that it forms an essential part of sustainable development, which includes building social cohesion, reduction of poverty and promoting peace and human security (par. 24).

3. As climate change is one of the main challenges for the world, and in particular for the industrialised countries, it is essential that the Kyoto Protocol is ratified and implemented by, among others, all UNECE countries (par. 23). It is a disgrace that some UNECE countries reject to do this, showing an irresponsible attitude to future generations.

4. As education is an essential part of mobilising and empowering the public for the protection of nature, environmental policies, and sustainable development, and as we are convinced that current practice can be dramatically improved in most if not all countries, we advocate agreement on the development of a region-wide Strategy for Education for Sustainable Development by 2005, in cooperation with Education Ministers and other interested bodies. (par. 43). The initiative should come from you as environmental ministers and the work should be done under the UNECE CEP with its extended mandate

5. As a concrete step in abolishing financial incentives that work in the opposite direction, reconfirm the decision of the EfE Ministerial Conference in Aarhus in 1998, "to progressively reduce and where possible remove energy price subsidies which counteract an efficient use of energy and/or have harmful effects on the environment by 2005". The Kyiv conference will discuss and hopefully endorse recommendations on reforming energy subsidies, but without agreement on a deadline, as was done in Aarhus, the European ECO-Forum has little confidence that much will happen in practice (par. 35).

6. In view of the uncertainty of the impacts of the use of genetically modified organisms in agricultural practices, to agree on a moratorium for the use of such organisms in agriculture in the region, and the distribution of products which involved GMO use, until there is undisputed evidence about lack of potential threats to the environment or effective measures to prevent such threats (par. 40).

7. In addition to signing the Protocol on Strategic Environmental Assessment, to agree to start work immediately on proposals to further include decision-making on policies and legislation (par. 28).

8. In addition to signing the PRTR Protocol, to agree to start work immediately on the inclusion of further substances and activities in the Protocol, as well as the possible expansion of the situations to which the Protocols apply, in particular on storage and on-site transfers." (par. 41).

9. In view of the continuing grave concerns about nuclear installations, both for the risks for major accidents and the ongoing increase of the legacy to future generation of nuclear waste, we pledge to phase out them out as soon as possible (par. 52).

10. We call upon all governments to sign the Protocol on Civil Liability, apply its provisions to the maximum extent possible pending its entry into force and review the Protocol at a later stage to broaden its scope of application as appropriate (par. 29).

11. We strongly support the EfE process to continue on a pan-European level and to be the platform for regional and sub-regional initiatives, including several that are now running in parallel (par. 54) and support the option of annual Ministerial meetings, creating an ongoing momentum for improvement of the environment in Europe (par. 55). We call upon Governments to continue with the upward line of the environmental citizens organizations and other civil society groups involvement in the Environment for Europe process. In particular we call for an observer position in the Executive Committee of the Working Group of Senior Officials and the CEP Bureau, the systematic inclusion of ECOs in the preparatory work, no formal or informal working sessions that are not open to ECOs, and the continuation of this policy at the Ministerial conferences themselves.

12. For changing consumption and production patterns, legislation, financial incentives, research and technology development are important. But in particular for consumption patterns, there is an ethical dimension as well. This was recognised by the first EfE conference but this notion was not given a follow up. The regional strategies we mention in points 1 and 4 should include promotion of an ethical behaviour towards nature and the environment we are living in. Given the limits to the use of natural resources we face, this should base on solidarity, within and beyond borders, including with future generations. Issues should include the promotion of cultural diversity, re-localisation of the economy, and consider regulation of advertisement to prevent it to promote unsustainable life-styles.

13. In the framework of the need to phase out nuclear energy use, we propose the establishment of international decommissioning support funds for the highest risk reactors in Armenia and Russia as is done for EU Accession Countries.

14. We welcome the intentions to continue and intensify, as part of a pan-European effort to improve the environmental situation in the entire region, the work started under the Environmental Action Programme (EAP) for CEE, and refocus it to the countries that are not part of the current enlargement process of the EU. As regards to the possible approval of a Environmental Strategy for Eastern Europe, Caucasus and Central Asia, we want to inform you that environmental citizens organisations in Belarus, Russia, Caucasus and Central Asia generally support the idea, but are concerned about the lack of progress in developing and agreeing it in concrete terms. They also insist that this Strategy should be seen as part of wider pan-European sustainable development process. On the other hand a majority of organisations in Ukraine and Moldova do not support this initiative.

15. We are aware of the new expectations that governments and the European Commission have with respect to the New RECs (par. 57 and 59). These should not undermine the basic mission of these centres, as agreed at previous EfE Ministerial Conferences, which is supporting public participation and civil society development. Organisations in the some of the countries concerned are of the opinion that much improvement is needed with regards to that basic mission, and that this should have priority. For them, shifting the focus of these new RECs at this moment is therefore not a good idea at all.

We are looking forward to your consideration of this letter and our further cooperation.

Sincerely yours,
Victoria Elias
Chairperson
On behalf of the European ECO-Forum Co-ordination Board