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Environmental NGO cooperation on the preparation of the Single Programming Document in Estonia 08.11.2004

Best Available Practices. Public Participation in Programming, Implementing and Monitoring EU Funds, lehekülg 28-31

Vaata kogu raamatu teksti // see the entire book: www.bankwatch.org


Estonia completed its first National Development Plan (NDP) in September 1999 with almost no public participation or NGO involvement. The second plan, the Single Programming Document - SPD for 2004-2006, had a better organised process with NGOs participating as social partners. National-level environmental NGOs organised under the umbrella of the Council of Environmental NGOs. Numerous joint analyses and comments were provided under the leadership of the Estonian Green Movement - both to the SPD analytical part as well as the programme complement. At certain stages, 1/3 of ENGO comments were accepted. A Strategic Environmental Assessment (SEA) was also carried out; ENGOs participated in the SEA preparation stage and issued joint comments.


In the fall of 2001, the Ministry of Finance began preparations for a new Single Programming Document (SPD), a key framework document for the utilisation of EU Structural Funds assistance in 2004-2006. Unlike the 1999 NDP programming process, the SPD was designed as more participative. Apart from governmental agencies, about 80 different social partners, such as NGOs, professional unions, local municipalities and universities, were identified to be consulted throughout the SPD process. As far as the environmental sector is concerned, eleven social partners were identified, including several ENGOs such as the Estonian Green Movement (a member of the Friends of the Earth), the Estonian Fund for Nature and the Estonian Ornithological Society.

The SPD’s strategic basis constituted the first document to which comments from social partners were requested (in February 2002). Ten ENGOs collaborated on the drafting of the ENGO comments, which were presented on behalf of the umbrella organisation, the Council of Environmental NGOs. ENGO comments dealt with a large number of sectors, including: environment, transport, energy, agriculture, tourism, forestry, food processing, services and human resources. Around twenty five social partners commented on the draft of the SPD strategic basis. Of these, ENGOs were among the very few that commented on nearly all the chapters of the document. One-third of ENGO comments were taken into account and incorporated into the SPD draft. Another positive issue was the fact that a summary of all comments, including the reasons for not incorporating certain comments, was published on the Ministry of Finance’s website.

This first stage of SPD programming in Estonia provides an example worth following and propagating in other countries. Unfortunately, although Estonian authorities proved that including social partners in the programming dialogue is possible and worthwhile, they did not manage to follow their own example through to the end of the process.

Indeed, during the summer of 2002, the SPD participative process took a downturn. The priorities for 2004-2006 Structural Funds assistance agreed in the early stage of the SPD programming process were suddenly altered and the entire process started from the beginning. The schedule for the entire programming process was regularly changed, introducing much confusion. ENGOs, however, continued to submit their comments even without being requested to do so. As in the beginning of the process, ENGOs cooperated under the umbrella organisation . the Council of Environmental NGOs . and kept submitting joint comments to influence the process to a greater extent. In the second half of 2002, ENGOs concentrated their attention on the SPD programme complement, which identified thirty one sub-sectors for SF assistance in 2004-2006 and described eligible activities. After pressure by ENGOs, a few vital areas, such as development of renewable energy, made their way onto the list of eligible subsectors. Also, due to ENGO pressure, NGOs were listed in many measures as eligible partners for implementation of SF projects.

After pressure from ENGOs and other partners, the Ministry of Finance launched a Strategic Environmental Assessment (SEA) process for the SPD. ENGOs provided comments to the SEA as well. Even though according to the good SEA practice, this assessment should be carried out in parallel to the SPD process, it was decided to finalise the SEA report several months before completing the SPD drafting. After ENGO lobbying (including meetings with the Prime Minister), the SEA process was prolonged until the end of the entire SPD process.


Drafting the SPD for 2004-2006 has been relatively participative. Especially the first part of the process included many characteristics of a proper social dialogue, e.g. thorough analysis of all comments together with justification if they were not included. Social partners were identified and most draft documents were provided on Ministry of Finance’s website. Despite the aforementioned problems and changing rules, ENGOs were able to maintain some influence on the process, demonstrating their keen interest in becoming involved by providing joint analyses and comments and uniting the voices of the ten largest national organisations.