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Democratising Cohesion Policy – Slovakia not ready to put EU funds spending in citizens’ hands


From 2014 Slovakia has the opportunity to use a new tool that would enable decisions related to EU funds deployment to be made more directly by communities and citizens. The European Commission has decided to enable the decentralisation of the post-2014 funds within the new Cohesion Policy so that local stakeholders can actively take part in its implementation, and ideally reap more meaningful benefits from the EU budget.

For this, the so-called Community Led Local Development (CLLD) tool has been introduced. Yet, with less than half a year to go until the new spending period begins, it appears that Slovakia is intent on passing up the chance to make the EU funds more democratic.

Slovak ministries simply do not trust the ability of municipalities and regional authorities to implement the EU funds efficiently and on time.

The Commission has based its initiative on the relatively positive outcomes that have resulted from the LEADER tool in the current spending period – LEADER introduced ‘bottom-up’ decision making in rural development funding as part of the Common Agricultural Policy. The approach has involved Local Action Groups (LAGs), composed of local municipalities, entrepreneurs, NGOs and active citizens, that contributed to the implementation of a small portion of the policy budget – in the 2007-2013 period, LEADER accounted for 3.13 percent of the Rural Development Programme budget, or EUR 79 million).

Relatively small beans so far, therefore, but the aspiration is that CLLD would become the successor of LEADER and kick on from it by being available to all operational programmes within the 2014-2020 programming period. Countries that opt to use this tool will permit more people to get involved in EU funds’ implementation as well as in the longer-term development planning of the regions in which they live.

Wait a minute, says Slovakia

Given the evidence to date, however, Slovakia has certain reservations about implementing CLLD – for various reasons.

First off, the Slovak ministries – responsible now for taking forward their respective operational programmes – have next to no awareness about the CLLD tool. And, of course, resistance tends to be at its greatest when it comes to unknown things. Moreover, faced with the pressure of getting EU money spent as quickly as possible, ministries retreat to their comfort zone – which means opting for proven methods of decision-making and ‘known’ types of projects.

A further problem is the reluctance of national ministries to delegate control over the EU funds to lower governance levels, let alone to bodies (such as the public) that exist totally outside of their institutional structure. Slovak ministries simply do not trust the ability of municipalities and regional authorities to implement the EU funds efficiently and on time.

Of course, there has been an array of cases where the involvement of regional authorities in policy implementation has been decidedly mixed, to say the least. Yet, more fundamentally, Slovakia has not come up with any tools or mechanisms for cross-sector planning, decision-making and managing of public funds.

Rigid departmentalism and lack of coordination are one of the reasons why public policies in Slovakia perform so badly when it comes to the achievement of objectives. A mechanism is lacking which would enable the ministries to interconnect parts of the operational programmes they manage, and to monitor and manage the use of CLLD together. This problem is significant as many strategic priorities for Slovakia are cross-sectoral in nature and the strict sectoral approach hinders their effective implementation.

A good example of this is climate adaptation with anti-flood measures which, in the case of ecosystem-based solutions, require the cooperation of the Ministry of Environment and its organisations that deal with water, biodiversity or climate, the Ministry of Interior Affairs that deals with the adaptation agenda, and the Ministry of Agriculture and Rural Development that has responsibility for agriculture, soil management and forestry. In this area, if coordination is lacking – and unfortunately it is – simple fast-track solutions with questionable adaptation effects, such as dam building, will be preferred.

Mixed messages from Brussels

The European Commission is also contributing to this frustrating scenario by sending out contradictory signals.

On the one hand, the Commission is set on introducing mechanisms such as CLLD that – at least in the Slovak context – are new and will not be implementable without an introductory pilot phase. While on the other hand, the Commission is also introducing conditions into the 2014-2020 budgetary period that will compel the member states to draw funds as fast as possible. The ‘performance reserve’ motivates states to ‘efficiently’ fulfil their obligations – if set spending milestones are met on time, member states receive a bit of extra funding.

What we are seeing as a result of this, then, is that the introduction of innovative forms of policy implementation are being thwarted, especially in areas where no effective regional policy exists, and where there is the most acute need for new tools such as the CLLD, global grants or other innovative approaches – e.g. for local economies, a decentralised energy economy, and support for new models of public services provision.

In all likelihood, therefore, in the new programming period, centralised ‘top-down’ decision-making will remain dominant – and the potential for local initiatives and regional development led directly by local stakeholders will be squeezed.

A further complicating layer

CLLD, the new tool which could complement LEADER, is enjoying significant attention in regions, though not exactly for the best reasons.

The potential to gain control over additional resources for regional development is igniting conflicts between local and regional authorities. The Association of Towns and Municipalities of Slovakia (ZMOS) strongly opposes the idea of regional authorities implementing the CLLD package. And as long as the regional stakeholders remain fragmented, the willingness of ministries to devolve decision-making power will be even smaller.

There is, too, a further issue at the devolved level: muddled understanding of the essence of bottom-up tools for funds implementation.

Experience from the current programming period shows that LEADER is being used as little more than an additional pot of money for filling the gaps in municipal budgets. Moreover, the new ‘integrated’ regional operational programme is being prepared with this in mind. It lacks any clear strategy, and so is likely to end up as a source of financing for a litany of disparate sectors such as roads, schools, health, social services, culture, tourism and waste – that is, a small chunk of money spread very thinly over many activities. The contribution of such a programme to goals that Slovakia has set, or to goals that have to be met as per EU level commitments, will be very hard to prove.

Questionable, too, is the actual contribution of LEADER to regional development – in many cases only cosmetic measures are financed under it. These include the renovations of civic squares, pavements, church renovation, playgrounds, bus stops or one-use promotion materials. These kind of investments are not spurring job creation or development of local economies despite the decisions to implement them coming from the local level. And a further compounding factor is that is very difficult to objectively evaluate the contribution of LEADER as no official evaluation procedures and criteria exist. Thus there are many questions hanging over the configuration of ‘local action groups’ and the assigning of EU allocations. It’s a situation that is creating ground for conflicts.

Some grounds for optimism

Nonetheless, there is some hope that the CLLD will be able to create a meaningful space for bottom-up, local decision-making in Slovakia. Thanks to a recent initiative from the Plenipotentiary for Civil Society and NGO representatives, Slovakia’s draft operational programme for ‘Efficient public governance’, under the auspices of the Ministry of Interior Affairs, contains a separate priority axis applying the CLLD.

Even if no other Slovak operational programme were to apply the CLLD, this axis could serve as valuable testing space for trying out new models of EU funds implementation that have democratic decision-making and participative spending of public funds at their core.

I can only hope that this modest space – now tentatively opening up and in combination with the future LEADER programme – will go to show that in Slovakia there is sufficient potential for the development of strong and stable regional economies based on direct input from active, engaged local citizens, organisations and entrepreneurs cooperating with municipalities. For the types of investments that are sorely needed: sustainable energy systems that meet local needs, the development of local agricultural markets and exchange networks for local produce, and the provision of social services by local specialized NGOs.

For now, though, despite the time spent and the opportunities available, the democratisation of public funds use in Slovakia remains very much in the balance. And the clock is ticking to January 1, 2014.

Is the Latvian success story over? Good public participation practices in EU funds planning in Latvia turns sour


Alda Ozola is a representative of the environmental NGO coalition in the Latvian Temporary EU funds Monitoring Committee for the 2014-2020 period.

According to Latvia’s Ministry of Finance, when it comes to the national level programming of the future EU money, they have a huge lack of capacity – thus ‘partnership’ is having to be sacrificed. Latvian NGOs, however, believe that EU funds programming for 2014-2020 is of major importance – after all it will determine the shape of public investments in the country for the next seven year period. In this context, partnership, involving a wide range of stakeholders, should not be compromised.

Why did NGOs initially have such high hope for EU funds partnership in Latvia this time around?

The first phase was indeed very promising. NGO representatives were included in the working groups for the National Development Plan (NDP), and there were public consultations and feedback about comments received from NGOs and social partners, and key moments surrounding the plan were reflected and discussed in the media.

Moreover, transparency was to the fore in the process, with all key draft documents and submitted comments on the draft NDP being published online – this publishing of comments was a first in Latvia for such a public process. However, there was less transparency when suggested activities had to be prioritised.

When preparations for the 2014-2020 EU funds programming started, there were again some very hopeful signs concerning partnership. In September 2012 there was a ‘temporary monitoring’ committee established, allowing NGOs and other stakeholders to participate.

Among other things, this Committee had the task of “overviewing the preparation of planning documents for EU funds”; during a meeting of the committee in May this year, participants were able to exchange views on key issues to be addressed within programming. Although this committee has the potential to become a solid platform for stakeholder participation, unfortunately it hasn’t lived up to NGO expectations, at least not yet.

A return to the old ways

There are further signs that the Ministry of Finance, that holds key responsibility for EU funds programming, is retreating to its old habits by approaching ‘partnership’ in a very formal way. The closer the deadline (October this year) for submitting the draft Partnership Agreement (PA) and Operational Programme (OP) to the European Commission, the less participatory the EU funds programming process is becoming.

For example, the Ministry of Finance organised a public consultation process on the draft PA and OP. The document itself was drafted without any public involvement, but the draft was made available on May 3 this year. There was one month given (deadline: June 3) for the public and other stakeholders (ministries etc.) to express their views and comments on the draft documents, with public consultation meetings due to follow.

After June 3 the Ministry of Finance sent questions to line ministries asking for their views on thematic concentration, but no meeting or any other feedback to NGOs or other bodies who submitted comments has taken place. There had been a commitment to publish all comments online, yet this was not carried out. At the same time the Ministry of Finance continues to insist that it is ensuring meaningful partnership as part of the process.

Latvian NGOs have thus felt frustrated about the lack of feedback to their comments. Even proactively contacting ministries failed to throw much light on the developing process or the updated documents. Therefore, when we learned that the Ministry of Finance would report to the Cabinet of Ministers on the progress of EU funds programming on July 2, NGOs decided to turn up too and express their deep concerns about the partnership debacle.

I personally informed the Cabinet about NGO concerns regarding partnership and asked the Cabinet to task the Ministry of Finance with ensuring timely and systematic engagement with civil society. The outcome for now is positive: the Ministry of Finance has pledged to publish all received comments and the justifications for taking or not taking them into account. The ministry has also committed to organise a consultation meeting with NGOs in July. While this is still only a commitment, it appears to be a fairly concrete one as it is set out in the Cabinet’s meeting notes.

The nuts and bolts – what needs to improve in Latvia’s EU funds programming now?

Other than the stop-start nature of the public consultation process itself, there are several priority issues that Latvian NGOs have put forward in a bid to improve content aspects of the EU funds programming. These are chiefly: allocating money for biodiversity protection, integrating environmental and climate aspects throughout all of Latvia’s EU funded programmes, providing support for social enterprises, and permitting NGOs to be eligible beneficiaries in some activities.

Among the most actively involved actors in the EU funds programming has been the Environmental Advisory Council, a coalition of 20 national environmental NGOs, and the Public participation consortium, representing NGOs active in the areas of civil society development, environmental protection, rural development, health, education and culture. Both of these platforms are represented in the ‘temporary monitoring’ Committee of EU funds for the 2014-2020 period, and also use other available opportunities to get involved in the programming process.

The Environmental Advisory Council has already approached DG Regio on several occasions this year to express concerns about the lack of proper consideration being given to environmental priorities and nature conservation issues during the programming process for EU Cohesion policy 2014-2020 in Latvia. The risk, according to the Council, is that some marginal activities, such as buying an expensive helicopter for rescue operations that can’t be justified with growing climate change impacts, could be supported, while certain core challenges in biodiversity conservation could easily be overlooked.

For one thing, the EU Biodiversity Strategy 2020 foresees that full implementation of the EU’s Birds and Habitats directives is ensured by 2015. To do this in Latvia, the first steps should include mapping and assessing biodiversity (species and habitats of EU importance), as well as restoration measures covering several hundred square kilometres – this of course requires a significant budget that is probably not available via national funds.

Therefore, without targeted EU funds support, there is no possibility to restore at least 15 percent of Latvia’s degraded ecosystems and ensure favourable conservation status for at least 40 percent of species and habitats, as stipulated in the EU Biodiversity Strategy 2020. Yet, none of these measures are proposed for inclusion in the priorities for funding by Latvia’s Ministry of Environment.

Moreover, according to the Latvian Fund for Nature, currently Latvia is not delivering the main goal set out in major policy documents – to ensure favourable conservation status. No habitat inventory has been carried out and the preliminary monitoring data confirms the expert conclusions that several Annex I habitats and species are not in a good state – and that the situation has worsened since 2007.

For example, 60-90 percent of the grassland habitats within Natura 2000 sites are in a bad conservation state, and no measures have been taken to improve the situation. Therefore proposed tourism infrastructure funding is not sufficiently justified from the point of view of the priorities in biological diversity and ecosystem protection. We have been pointing out that construction of new tourism infrastructure will create an unnecessary burden for the future, as the state is currently not even able to maintain the existing infrastructure.

While it can be said that tourism infrastructure is a tool to protect the habitats from degradation due to pressure from tourism, this measure in particular is not a priority in the current context as it does not directly provide for improved conservation status for habitats of EU importance.

The clock is ticking as we count down to the 2014-2020 funding period. Meeting some of Latvia’s top environmental needs – as well as our EU commitments – can only happen via meaningful public participation and partnership, even at this relatively late stage in the process.

The EU’s bank is less ambitious than the US in restricting energy from coal


Just as the world is abuzz with Obama’s new climate pledges, below the radar, the European Union’s house bank published draft guidelines for its future energy lending which are actually less ambitious than the US’ when it comes to coal.

Sidelining a reluctant Congress, Obama is going through the Environmental Protection Agency to introduce several important climate friendly measures, including allowing to run only coal plants (new and existing) which meet emissions performance standards of 440gCO2/kWh.

At the same time that most of the world’s media was busy covering these important US developments, the European Investment Bank, the bank of the EU, was bringing to the public a draft of its new energy policy, expected to be adopted by member states of the EU and the Commission, which compose the board of the bank, on July 23.

The criteria inserted by the EIB when it comes to coal are full of loopholes, for instance when “a plant contributes to the security of supply” or “to poverty alleviation and economic development”. Such broad and worn out concepts can end up justifying any kind of dirty energy investments.

See also

Video discussion: The draft energy policy of the European Investment Bank (recorded live on July 3, 2013):

New EIB Energy Policy: A Missed Opportunity
Press release | June 25, 2013

The EIB invests up to 70 billion euros annually in EU and non-EU countries, and a significant portion of this money goes to energy projects. Between 2007 and 2011, under the current energy lending policy, the EIB lent 62 billion euros to the energy sector, a third of which went to fossil fuels, according to Bankwatch calculations. 2 billion euros were lent to coal projects in this period: 9 coal plants received EIB financing, in Poland, Germany, Italy, Romania and Greece. Just this year, the EIB finalised a payment of over half a billion euros to the controversial lignite plant at Sostanj in Slovenia.

Some expected that the new energy policy might bring a wind of change at the bank. Many voices have been calling lately for an end of public support for fossil fuels and coal especially, among them the International Energy Agency, the World Bank, and EU Commissioner Connie Hedegaard. The EIB is one of the world’s biggest public lenders so one might expect it to be responsive to this trend. Additionally, the institution was created to further EU objectives, one of which is the decarbonisation of the European economy by 2050.

Against this background, the draft energy policy of the EIB is a disappointment.

The text envisages continued loans to coal projects, albeit under tighter criteria, such as emissions performance standards of 550gCO2/kWh (good that they are there, but they are less ambitious than the ones proposed this week for the US or with those in place in Canada already) and full compliance with EU Directives concerning power plants.

Yet the criteria inserted by the EIB when it comes to coal are full of loopholes. For instance, “an EPS exception” is set out in the policy for cases in which “a plant contributes to the security of supply” within the EU or when “it contributes to poverty alleviation and economic development” outside of the EU. Such broad and worn out concepts can end up justifying any kind of dirty energy investments. This is why, before the board of the bank approves the policy, it must make sure the technical criteria for coal projects are tightened and make emissions performance standards more ambitious.

Worrying is also the fact that the EIB plans on investing in all types of energy, from new renewables, to nuclear and shale gas. This means that the bank will spread out its financial resources among many different types of investments (including costly and controversial options such as carbon capture storage and shale gas) rather than concentrate on those types of investments that guarantee energy resilience and for which potential is immense: new renewables and energy efficiency.

In the policy, the EIB certainly commits to supporting these, but one is left to wonder whether some of the good effects of such investments would not be cancelled out by the bank’s own promotion of lignite or oil pipelines.

Finally, the EIB energy policy is important not only because it determines how tens of billions of euros will be spent over the next five or so years. It is important because, were it to make the right choices, it could build momentum for other institutions in the public sector (such as the European Bank for Reconstruction and Development, also reviewing its energy strategy at the moment) and in the private sphere to follow suit and push for clean energy solutions. But, given the looks of the draft policy, it is hard to imagine how the bank – or the EU for that matter – can be said to play such a leadership role on climate action.

[Campaign update] Kolubara landslide: Images of devastation, people waiting for compensation


People in the village Junkovac, near the Kolubara lignite mine, are relieved but still tense. They were threatened by a landslide, which has now slowed down, but still poses a risk for them if they don’t move. Yet, despite of being scared, they are not leaving their houses for fear of not receiving adequate compensation from the Kolubara mining company.

It started four weeks ago (Bankwatch reported): A hill nearby Junkovac started sliding down towards the village – apparently because of the pressure put on it by overburden from two mine fields that was dumped in the vicinity. Operations on one of the two fields (Field C) have been supported by the European Bank for Reconstruction and Development and the German KfW banking group.

I was there after the first two houses had collapsed and I’ve seen how a road has been swallowed by the landslide. Another three houses have collapsed since then.


One of the houses that were completely destroyed.


An entire road has been swallowed by the landslide.


Locals watching the clean up works 150 meters away from their house.

Read also

Kolubara mining waste causes landslide, wrecks homes in Serbia

Background, updates and more on the Kolubara lignite mine project

The people I spoke to were afraid and shocked, also because at first they only received informal advice, no concrete help from authorities. The state energy company EPS which operates the Kolubara mines and which is responsible for the management of the overburden was working with bulldozers to slow down the landslide. But strangely when I visited the village, there was no police on site, no emergency teams, just Kolubara machinery. One could not help the feeling that the company is just cleaning up its backyard, its territory.

Until last week when I visited Junkovac again, the landslide had steadily slowed down (but the earth is still moving). The landslide also does not head towards the village anymore. These are the good news.

But it was sad to see an entire street washed away and to be unable to find out what exactly happened to the people who lived there. They are gone, their houses are gone.

Approximately 40 houses in the village are still in danger and authorities are preparing to relocate and compensate eleven families soon – the rest should follow at a later time. Our local contact, who prefers to remain anonymous, told me the families received and signed an inventory of their property (prepared by the municipality). The document, however, did not include an estimation for the value of this property, so people are are waiting for more than two weeks now to receive a financial offer. Once the offer arrives, they can either accept and get paid or refuse and receive 50% of the offer and be advised to go to court, which could become a very costly and lengthy procedure.

It remains to be seen whether the offered compensation is appropriate. Except for one family (whose house was destroyed), all have decided to stay until then and not accept the offer of temporary relocation to Vreoci. Our contact said that others don’t want to leave for fear of being cheated. They prefer to stay, even though the landslide could change course again.

As financiers of EPS in general and specifically of parts of the work on those fields from which the overburden came, the EBRD and KfW should closely monitor this process and ensure the people in Junkovac are treated fairly.

Read more about the Kolubara lignite mine

As Croatia accedes to the EU, questions remain over whether EU billions can succeed for Croats


If there’s one thing we can be sure about Croatia’s accession to the European Union on July 1, it’s that the historic occasion will be greeted by rousing speeches and aspirational press releases issuing forth from both Zagreb and Brussels. Yet for the majority of Croats, this new dawn will be embraced much more coolly – opinion polls show that not much more than a third of the population is enthusiastic about joining the EU.

Is this mere ingratitude? After all, membership of the bloc will see substantial EU funding injections: EUR 655 million (1.5 percent of Croatian GDP) has been lined up for this year, with a further EUR 13.7 billion in the pipeline for the seven year period 2014-2020.

More likely, the prevailing scepticism can be explained by two things.

One, a recognition of the scale of the economic tailspin that Croatia has been in for the last five years (country-wide unemployment stands at around 20 percent, with more than half of young Croats jobless), a cycle that it shows little sign of escaping from, and; two, resignation that EU billions can be no panacea in a country where there is insufficient preparedness for absorbing the funds in a sustainable, genuinely transformative way. Indeed, on the latter point, there are valid fears that the new investment monies will go the way of so much previous international assistance to Croatia – into a black hole.

The legislative environment as it relates to future investment projects in Croatia does not look promising in this regard. Bear in mind we do not have a comprehensive national development strategy in place, a blueprint for developing in an efficient, effective way via the prioritisation of key targets and goals – ideally goals that would be imbued with respect for the country’s environment instead of simply ‘X more roads’.  

What we do have, as we stumble across the EU finishing line, is the new Law on Strategic Investments, recently approved by the government and expected to be shortly passed by the national parliament. This law appears solely designed to appease large investors and their long list of – potentially – white elephant projects.

Specifically, the new law will give preference to investments over 150 million kunas (the equivalent of EUR 20 million) under the patronage and approval of an advisory governmental body. The background to this is that for some time now many major ‘strategic investors’ have been turned off as soon as they got a whiff of the number of procedures and estimated approval times that Croatian bureaucracy has insisted on. Under the new law, approval times for large projects will be significantly speeded up.

Startlingly, the original draft of the new law insisted that environmental impact assessments would not be necessary for large projects if the relevant national authorities did not respond within 10 days of being approached – fortunately the European Commission threw out this approach to environmental safeguarding at the consultation stage. Nonetheless, such assessments will be fast-tracked under the new law.

What we’re seeing, then, is the wrong solution – some critics believe it can only further fuel corrupt practices – to an unarguable long-term problem: foot-dragging and endless paperwork related to investment decisions should instead have been tackled by systemic reforms to administration and through capacity building for officials so as to speed up permission processes in a regular, though still rigorous, way.

This new investment landscape will have a bearing on EU sponsored projects, though the threshold for prioritising these is reduced to EUR 10 million. However, the new regime clearly disadvantages smaller scale projects – under either the EUR 20 million national threshold or the EUR 10 million EU threshold. Their implementation will continue to be bogged down in the sourcing of endless documentation, while ‘big’ projects – with potentially much greater ecological and social footprints – enjoy a far easier ride.

Currently, for example, installing just a few basic photovoltaic appliances requires more than 30 different permits. Equally, a small municipality that intends to introduce a sustainable waste management system involving reuse and recycling – usually no more than EUR 5 million – would be stuck in the procedural loopholes of Croatian administration, while a larger municipality, perhaps wanting to take forward a large, unsustainable waste incinerator would be much less detained.

This is the nub of the problem. Relatively small-scale, community driven projects, aiming to tap the EU funds in order to boost jobs, cut fuel bills and do their bit for the EU’s fight against climate change, look set to be distinctly disadvantaged.

These kind of anomalies will hopefully be addressed during the upcoming public debate in Croatia over the selection of priority investments to be funded by EU money. How we will spend our new EU money is to be finally set in stone, according to the official timetable, by the end of November. Crucial in this regard will be the details of the partnership agreement required by the European Commission for the oversight of Croatia’s EU funds: will the Croatian public, local communities and NGOs be granted a voice around the decision-making table?

What is sure is that, having taken ten years to arrive at this point of EU entry, Croatia now cannot afford to squander its new EU billions on pointless, environmentally dubious investments when the country urgently needs – above all – job creation. Localised, green investments can and should play a big role in boosting new sustainable forms of employment.

Green agriculture spending culled in Estonia – NGOs demand proper use of future EU money


As negotiations on the EU budget for 2014-2020 grind on painfully towards a conclusion hopefully next month, and with key voting on the future shape of the common agricultural policy (CAP) due at the European Parliament this week, country level programming is underway for the future seven year budgetary period.

But as we hear from Bankwatch’s Estonian coordinator Triinu Vaab, it’s not just at the top Brussels level that major agri-business interests are flexing their muscles to take the ‘green-ness’ out of EU agricultural spending.

Several weeks ago the Estonian Council of Environmental NGOs sent a letter to Estonia’s minister of agriculture and minister of environment to express the groups’ deep unease with the way the Ministry of Agriculture had discarded the work of different experts during the compilation of Estonia’s Rural Development Plan (RDP) for 2014-2020. Here Triinu explains the background and the implications for Estonia’s agricultural sector. The interview was conducted by Bankwatch Mail editor Greig Aitken.

What’s the significance of RDP to the EU Funds for 2014-2020?

RDP 2014-2020 consists of rural development policy measures that are drawn from the legislative proposal for the new Rural Development Regulation. At the EU level, RDP is part of the common strategic framework – together with the European Reconstruction and Development Funds, European Social Funds, Cohesion Funds and Maritime and Fisheries Funds. At the member state level all of these funding lines comprise the partnership agreement between an individual member state and the European Commission.

For 2014-2020, the overall European Agricultural Fund for Rural Development pot stands at EUR 84.8 billion, out of which Estonia will receive EUR 721 million euros.

From the environmental perspective, most crucial is the designing of the ‘agri-environment-climate’ measure. However, other measures such as support for organic agriculture (especially providing sufficient funding), support for Natura 2000 areas, and the inclusion of environmental considerations in the design of investment measures are also important in order to secure sustainable rural development.

RDP mostly covers a wide variety of rural enterpreneuship and agricultural measures. For the 2014-2020 official priority areas are: transfer of knowledge, competitiveness, operation of the food chain, and environment and rural entrepreneurship. RDP is operationalised through different measures, chosen according to development needs and goals. In the coming period the plan is to put into force over 20 different measures and sub-measures.

It’s important, though, to stress: RDP can either drive rural development towards a more sustainable path or subsidise environmental destruction.

And the latter is what you now fear as a result of what you deem to be broken promises from the Estonian authorities?

Yes, given the progress that had been made, we (and other stakeholders) feel very let down.

Throughout 2012 and the first few months of this year, different working groups (with representatives from environmental NGOs, producers and state institutions) worked intensively on the design of the ‘agri-environment-climate’ measure. This includes several sub-measures, the most significant in terms of budget being the so-called environmentally friendly management.

This is a broad and shallow measure, but in order to avoid it becoming too ‘shallow’ it was agreed that farms would have to choose at least two activities from a list, including various buffer strips, delayed mowing time, reduced fertiliser application etc. Yet this list has now been abandoned, and thus the sub-measure has become effectively been ‘greenwashed’ – though of course it does still hold most of the budget for environment related measures.

The abandonment of the list of voluntary activities has never been officially explained, but unofficially the inclusion of Natura 2000 payments (and the pressure this exerts on the RDP budget) has been given as the excuse.

The Estonian Council of Environmental NGOs has supported Natura 2000 payments via the RDP 2014-2020 budget line since the start of putting RDP together, but the Ministry of Agriculture was initially against. However, the Ministry of Environment pushed hard to include Natura 2000 in RDP.

It now seems that this dilution of the agri-environmental measure is a form of ‘revenge’ for being forced to include the Natura 2000 payments in RDP. Since the Natura 2000 payments are relatively unspecific (although they are important for relevant farmers), the dilution of the agri-environment-climate measure will definitely do more harm than the inclusion of the Natura 2000 payments will do good.

As we were well aware that the RDP 2014-2020 budget is tight, the Estonian Council of Environmental NGOs did provide different specific proposals to address this situation during meetings in the Ministry of Agriculture, in working groups and by sending written comments.

For example, we proposed to use the possibilities present in the new draft Direct Payment regulation to support the farmers in Natura 2000 areas with funding from Pillar I. None of our suggestions seem to have been seriously examined.

We view the dumping of these provisions at the last minute as a betrayal of the members of the working groups. Other than environmental NGOs, the Estonian Farmers’ Federation (representing family farms), the Leader Forum and many other NGOs have been very frustrated by the process – though the Central Union of Estonian Farmers, representing agri-business, will be content.

Does the jettisoning of the green agriculture measures in this way break any national or EU rules as far as you know?

Whether what we’ve seen actually breaks any formal rules is still to be fully determined, but of course nothing can be finally said here since the most important rules (the CAP reform package) are still being debated and decided in the ongoing ‘Trilogue’ discussions, between representatives of the Commission, Council and Parliament.

Is Estonia’s RDF spending all finalised then?

The Ministry of Agriculture views the current draft as final. However, the document has been neither approved by the relevant steering committee nor signed off by the Cabinet.

And from the more formal point of view nothing can be said to be final now, since the CAP reform package, including the Rural Development Regulation that is the legal basis for RDP, has still to be approved by the European Council and European Parliament.

Is there a possibility for the situation to be resolved somehow, or for a compromise solution via the parliament?

The Rural Affairs Committee of the Estonian parliament held an open hearing about the new RDP on June 11. Various parties presented their frustration there. However, the process of RDP preparation is led by the Ministry of Agriculture and is to be approved by the Cabinet; the parliament has a limited say here.

Moreover, parliamentary oversight of governmental activities is currently rather limited in effect, since the government holds a parliamentary majority. Thus the key to the solution is still held by the minister of agriculture.

But you are planning to take a stand against these regressive, non-sustainable measures?

If the Ministry of Agriculture continues to insist that the previously agreed measures are not to be reintroduced and implemented, then the Estonian Council of Environmental NGOs will have to remove itself from the whole process of RDP compilation as all the work will have been in vain.

We cannot be in any way associated with this kind of greenwash, or the potential negative impacts for Estonian agriculture that it will usher in.