Dies ist eine HTML Version eines Anhanges der Informationsfreiheitsanfrage 'Structural Funds Partnership Principle'.













Why Bother with
Partnership?
Positive Examples of Partnership in 
European Funds from Central 
and Eastern Europe

2
Table of contents
Introductory Note
3
The Approach
4
List of Abbreviations
5
Executive Summary
6
Themes and Case Studies
10
 
Access to Information
10
 
Bottom-up and Coordinated Planning
15
 
Participation in Programming
26
 
Financing for Sustainability
40
 
Delegation in Committees
48
 
Participation of NGOs in Project Evaluation
61
 
Cooperation among NGOs
79
Information about SFteam
89

3
Introductory Note
Two and a half years after publishing “Structural Funds and Partnership”, SFteam 
made another attempt to examine how much progress had been made in the 
partnership between civil society and the authorities in CEE countries within the 
confi nes of the implementation of EU Regional/Cohesion policy and the use of EU 
funds. There had been a great deal of development in this period – both in positive 
and negative terms. However, we must admit that in spite of the growing number of 
positive cases and signs, there is still time left before we can learn all the lessons 
on how to work together.
The political development in some countries has verifi ed our anxiety about the 
attitudes of governments and politicians towards the broader involvement of civil 
society in decision-making. Some optimism, however, may spring from the fact that 
there are positive cases of cooperation even under these hard conditions. Such 
cases are still in progress and we are planning to continue to follow them.
SFteam’s mission is to promote and support processes leading to the utilization 
of structural funds with the aim of maintaining sustainable development. We are 
convinced that the involvement of non-profi t civil organizations in decision-making 
and partnership is the essential requirement for such processes. Since we are at 
the beginning of the programming of the next fi nancial period for EU funds (2014 – 
2020), we believe that our publication will help all our colleagues in CEE countries as 
well as our partners at the institutions and other stakeholders to set up meaningful 
and fruitful processes in their countries.
SFteam is a network of non-profi t organizations from Bulgaria, the Czech Republic, 
Hungary, Latvia, the Netherlands, Poland, Romania, and Slovakia. I would hereby 
like to express my gratitude to our partners, and also thank for the data, with the 
help of which I could compile this publication.
Sofi a, 29th April 2011
Petko Kovachev

4
The Approach
The partner organizations of SFteam in Central and Eastern Europe (in Bulgaria, 
the Czech Republic, Hungary, Latvia, Poland, Romania, and Slovakia) participated 
in the research. 
At the fi rst stage, the team discussed the basic issues – goal, themes, organisation 
of work, and created the work plan.
The partners searched for cases not only from the experience of their own 
organisations, but also looked at examples of partnership practice in a broader 
range of environmental and other NGO communities in their countries and provided 
a description of the cases they were aware of. Although there have not been many 
such cases so far, we expect that good practices will grow in number with the 
progress of operational programmes.
Each partner prepared case studies, based on which the editor then compiled short 
introductory texts on each theme. Apart from these cases, further information was 
collected and used about other activities related to participation of NGOs in EU 
funds - from the editor’s own experience, SFteam partners and desk research. 

5
List of Abbreviations
CAP
Common Agricultural Policy
CBA 
cost-benefi t analysis
CEE 
Central and Eastern Europe
CF 
Cohesion Fund
CRESC 
Regional Steering Committee (RO)
CSO 
Civil Society Organisation
CSUEUF 
Coalition for Sustainable Use of EU funds (BG) 
EAB 
Environmental Advisory Board (LT)
EC 
European Commission
EE 
energy effi ciency
EIA 
environmental impact assessment
EP 
European Parliament
ERDF 
European Regional Development Fund
ESF 
European Social Fund
EU 
European Union
IA 
impact assessment
JROP 
Joint Regional Operational Programme
LAG 
Local Action Group (LEADER approach)
MA 
Managing Authority
MC 
Monitoring Committee
MOEW 
Ministry of Environment and Waters
NDP 
National Development Plan
NGOs 
Non Governmental Organizations
NSC 
National Society of Conservationists
NSRF 
National Strategic Reference Framework
NTNP 
National Thematic Network for Partnership (PL)
OP 
Operational Programme
RES 
Renewable Energy Source
ROP 
Regional Operational Programme
SCF 
Structural and Cohesion Funds
SEA 
strategic environmental assessment
SF 
Structural Funds
SFteam 
Structural Funds Team for Sustainable Future
SNER 
systems for nomination and election of representatives
UMIS 
Unifi ed Management Information System 
WFD 
Water Framework Directive
WG 
working group

6
Executive Summary
The third report of the SFteam on implementation of the partnership principle with 
regard to the use of EU funds in CEE countries comes in the middle of the fi nancial 
period 2007 – 2013, thus provides relevant information on the implementation of 
this important tool for EU policies. It may also serve as a guide for groups which 
monitor EU fi nancial assistance on local, national or international levels.
In the fi rst two reports (20041, 20092), our experiences regarding the application 
of the partnership principle are summarised and used to shed light on practices 
that were found controversial or problematic. With the present report in general, 
we decided to take a positive approach and show examples of good practice and 
its benefi ts. Still it is to be admitted that there are hardly any cases that could be 
considered a hundred percent positive; one could always identify points or factors 
worth improving. Nonetheless, we hope that this collection of cases will give some 
incentive for the adaptation of good practice examples to national conditions and for 
the implementation of partnership in a broader sense.
As described in our previous report, 
“the demand for the implementation of a partnership principle in programmes 
originates from several sources. One of them is the reformation of the 
European administration, which has, for 8 years, been a priority of the 
European Commission . The European Commission3 laid the EU under 
an obligation to cooperate more closely with regional and local authorities, 
and (besides these formal constructs) also with the wider civil society. This 
cooperation is not intended to be one way and communication among 
concerned parties should not be established merely for the implementation of 
European policies, which have been already agreed.“

Two years after publishing this report, we could conclude that the partnership 
principle was playing a more important role in programming, implementation and 
monitoring of EU funds. No doubt, there is still a lot to be done in making partnership 
a steady practice at all levels of governance and self-governance in our countries. 
But we found some promising results of joint stakeholders activities in Poland, 
Bulgaria, Hungary, Latvia, the Czech Republic, Romania and Slovakia. And even 
further ones could not be included in the current report for various reasons. There 
are cases in progress that may result in even better schemes of public involvement, 
thus securing a higher impact of the use of public money.
1
 Partnerships for Sustainable Development?, National Society of Conservationists, Budapest, 2004
2
 Structural Funds and Partnership, Center for Community Organizing, Prague, 2009
3
 See the White Book of the EC on European Control of Public Issues, 2001.

Examples of good practice that can already be highlighted in the middle of the 
7
fi nancial period include the initiative of the Marshal’s Offi ce of the Lodz region 
(Lodzkie voivodship) to introduce a model for participation of NGOs in regional annual 
action plans, which was subsequently recommended by the Polish government to 
be implemented in all regions as a good practice (see theme 3). Another case, also 
from Poland, is the establishment of the National Thematic Network for Partnership 
(NTNP) in June 2010 by the Coordinating Committee for the National Strategic 
Framework 2007-2013. The aim of the Network is to provide concrete support for 
the members of Monitoring Committees (MCs), especially to those which represent 
socio-economic partners. The aim of the support is to make their activities more 
effective and eliminate problems related to the implementation of structural funds in 
Poland. (see theme 2)
Authorities in the Czech Republic and Hungary also devoted some resources to 
support the involvement of NGOs in issues related to EU funds.
After 12 years of campaigning, there has been some positive progress in the 
well-known case of Kresna gorge in Bulgaria. Following the initiative of Bulgarian 
authorities, the long-tunnel option for the NATURA 2000 zone of the gorge has been 
accepted and a special monitoring committee for the project (Struma motorway, part 
of TEN-T corridor No 4) is going to be established.
Of course, we see the existing weaknesses and problems hindering broader and 
deeper partnership in CEE, too. While civil society is under pressure by the crisis 
on the one hand, on the other hand, government initiatives for a “strong state” have 
gained momentum, including the more centralised management of the shrinking 
fi nancial resources. But hard times are also the best ones to motivate civil groups 
for leadership and be active in proposing positive solutions for the problems. 
It is not surprising that most of the partnership schemes described in the cases 
were initiated and promoted by civil society. We are aiming to acknowledge our 
colleagues’ efforts in all countries of the region to introduce innovative practices for 
meaningful partnership for better and sustainable use of EU funds. Such practices 
would also easily serve the general transition towards post-crisis states and the EU 
in general.
Even with this promising background, we still have to voice our concerns regarding 
attempts of authorities which would ruin existing good practices. One such example 
is that of the Ministry of Environment and Waters in Bulgaria which, by disregarding 
the established internal election system of environmental NGOs, would open the 
door for the participation of “NGOs” representing corporate or political interests.

8
To make the examples of good practice more useful, we combined them in seven 
thematic groups:
 
Access to information;
 
Bottom-up and coordinated planning;
 
Participation in programming;
 
Financing for sustainability;
 
Delegation in committees;
 
Participation of NGOs in project evaluation;
 
Cooperation among NGOs.
Each theme starts with an introduction that summarises the fi ndings from the 
experience of the SFteam members.
The following messages may be gathered from the case studies:

The partnership between NGOs and institutions is still mainly a result 
of civil initiatives, but there are examples of good cases on activities 
initiated by various authorities, too.

Effective, formally organised schemes for partnership often result 
from single issue projects or programmes, not from long theoretical 
debates.

Partnership principle is not yet effectively implemented in the 
development phase of regional policy. This is a crucial problem, as EU 
funds should be planned on the basis of or alongside regional plans 
and strategies. This is to be a great opportunity to spread partnership 
on local and regional levels, to promote real decentralisation in the 
planning of needs and funds that would support solutions for them.

Within the partnership initiatives, NGOs, (or CSOs in a broader 
sense) may provide very good expertise in a number of areas related 
to EU funding:

independent monitoring and control;

qualifi ed experts in regional planning, programming of OPs, project 
and programme evaluation;

various services under outsourcing schemes (e.g. social issues);

managing projects in specifi c areas, e.g., nature protection;

moderating dialogue and communication with communities 
concerned, etc.

For a fruitful partnership, it is crucial that all partners be treated equally 
– providing information in time and in full scale, equal opportunities 
for comments and other input, taking these alternative proposals as 
seriously as the ones that come from institutions, etc. 

It is worth discussing further whether a more balanced structure of 
9
working groups, monitoring committees or other bodies with more 
representatives of stakeholders (e.g. 50:50 percent) would improve 
the work on EU funds in our countries.
The rest of the fi ndings, conclusions and recommendations of the SFteam can be 
found in the presented themes and case studies.
Let me again refer back to the previous SFteam report: 
“Partnership principle became one of the key principles of EU cohesion 
policy. Based on this principle, the partners take part in programming, 
implementation, monitoring, and evaluation of cohesion policy on more levels 
(regional, national and multinational) and by involving more participants 
(local/regional authorities, private organizations and organizations of civil 
society). Partnership principle again gained importance when the fi nancial 
and operational framework for regional policy for the 2007–2013 period was 
established. It also includes organizations and civil societies, ecological 
partners, non-governmental partners, and authorities responsible for equality 
between women and men.” 4 

The cases SFteam partners observed in 2010 – 2011 fully reaffi rm this conclusion.
Nowadays CEE countries face the next challenge: to organise and conduct the 
programming of EU funding for their second full fi nancial cycle (2014 – 2020) on the 
basis of lessons learnt in the last 7 years. Having in mind the vast number of recent 
problems, partly resulting from the global crisis and further economic challenges, 
like the energy crisis between the EU and Russia, the nuclear disaster in Japan and 
revision of the EU Common Agriculture Policy among others, partners of SFteam 
are confi dent that effective and meaningful partnership would bring strong impetus 
for the development of the regions towards an effective use of resources, thus 
paving the path for sustainability.
4
See also paragraph 11 of General Regulation (EC) No 1083/2006.

10
Themes and Case Studies
Theme 1: Access to Information
Access to information is one of the most crucial tools for civil society to understand 
whether authorities and businesses are making good or bad investments and 
their potential impact on citizens and their lives. Timely access to information is a 
precondition of meaningful public participation. Not surprisingly, EU is a member 
of Aarhus Convention on Access to Information, Public Participation in Decision-
making and Access to Justice in Environmental Matters. The EU’s own legislation 
on Access to information5  existed even before the Convention itself was signed, 
ratifi ed and put in force.
In the domain of EU funds, access to information is essential. The EU Regional 
policy and related structural and Cohesion funds support projects with diverse, 
but defi nitely signifi cant impact on the local, regional or national public. Therefore, 
using the procedures for access to information, citizens and NGOs could analyse 
independently potential benefi ts and losses, and to propose better alternatives at 
an early stage. 
Although SFteam found only one clear example of good access to information 
(Slovakia), virtually all cases in this brochure include this topic in one way or 
another. Moreover, the practice of NGOs that monitor EU funds countrywide show 
that there is a growing number of good initiatives and practices, initiated by different 
stakeholders. The problematic point is to turn those into a long-term steady practice 
elsewhere.
The Slovak case seems to be an average one for CEE countries. Although authorities 
are obliged by law to publish most of the documents regarding implementation and 
control of EU funds, there are many obstacles preventing access to information 
about EU funded projects and the processes of monitoring and implementation. 
Current development in the country shows the progress towards more transparency 
through a greater level of active publishing of information. However, barriers still 
exist that prevent access to information by citizens.
The situation is more or less the same in Bulgaria, where the Law on access to public 
information and the respective chapters of the Law on environmental protection 
(dealing with the Aarhus convention) provides very good opportunities for citizens.
5
  COUNCIL DIRECTIVE 90/313/EEC of 7 June 1990 on the freedom of access to information on the 
environment

However, under the disguise of the Law on classifi ed information, institutions are 
11
trying to keep information they feel would be used against them away from the 
greater public.
In mid-2010, the Unifi ed Management Information System (UMIS) was launched in 
Bulgaria and subsequently its public window was also activated. It is a good step 
towards the transparency of EU-funded projects.
SCFs in Hungary are also managed by a UMIS system (called EMIR). Several of its 
functions are publicly accessible through the website of the National Development 
Agency, the central coordinating government institution of EU funds. E.g., JELEK 
system, based on GIS, UMIS and offi cial social and economic statistical data, makes 
it possible to create reports about the use of EU funds since 2004 on a territorial and 
funding scheme basis. The data analysed and presented there include the number 
of project proposals submitted and awarded, as well as the amount of funding 
applied for and granted. The system also gives access to the description of each 
funded project. Another function provides a search opportunity in the database of 
fi nanced projects. Here, along with basic information about the projects (benefi ciary, 
name of project, amount, timeline), a short description of contracted activities and, 
in some cases, even the names of the members of the project evaluation committee 
are published.
Whether you have regional cooperation between civil society and institutions in 
Poland or Hungary, participation in programming (Bulgaria), or campaigns against 
bad infrastructure projects, funded with EU money, NGOs deserve information to 
make their impact valuable. It is not easy to summarise various types of cooperation 
or lack of it between civil groups and institutions, it would take pages to do so. The 
variety of relations regarding EU funds and access to information, however, helps to 
set up a short list of achievements, problems and recommendations.
On the basis of our long-term work and experience, we may summarise the following 
achievements, problems and recommendations for improving the working of EU 
funds with the public.
Achievements:

legislation on access to information exists in all new MC’s;

Aarhus Convention is in force;

there are experienced civil groups and individuals; which are, in all 
countries, supported by lawyers with good qualifi cations in the access 
to information;

12

NGOs are able to cooperate with EU institutions when governments/
regional authorities deny information;

the media are in constant search for cases that are lost and justice is 
prevented due to  non-access to information;

the costs of meeting requests for public information are typically low.6  
In some countries, NGOs even enjoy some allowance in this regard. 
The costs of court cases against information denial are also generally 
low in most countries.
Problems:

governments often do not provide „passive“ information (obligatory 
publications, registers, etc.);

too broad defi nitions of terms like „national security“, „business and/
or trade confi dentiality“ attempt to hide sensitive information on 
environmental, social and fi nancial problems;

often the rule of overriding public interest is not used;

institutions do their best to delay information in order to cover some 
occurring problems.
Recommendations:

institutions should make an effort to fulfi l their obligations to provide 
as much passive information as possible;

clear and straightforward defi nitions should be provided for national 
security, business and trade confi dentiality;

the rule of overriding public interest should be obligatory  in all court 
cases against the denial of information;

no confi dentiality should exist for public utilities and national/regional 
monopolies, funded by public money;

there should be a rule not to use EU money for programmes/projects 
that deny access to information.
6
It is only in some isolated cases that data owners abuse their position by imposing extreme costs.

Case Study (Slovakia):
13
Access to Information on the Implemen-
tation of EU Funds in Slovakia

Background
Effective public control depends on detailed information about the activities 
and decisions carried out by public authorities and projects fi nanced by funds. 
Although authorities are obliged by law to publish most of the documents regarding 
implementation and control of EU funds, there are many obstacles to gain 
access to information about EU funded projects and the process of monitoring 
and implementation of EU funds. Current development in Slovakia shows the 
progress towards more transparency through a greater level of active publishing of 
information. Even with these steps, barriers exist preventing access to information 
for citizens, which are summarized in this case study.
Publishing of Information 
Low accessibility of information is one of the key issues that hinder the monitoring 
of the implementation of EU funds. Civic control of funds is often hampered by 
the lack of information about the projects, the activities and decisions of ministries, 
monitoring and evaluation committees. Slovak citizens have two ways of obtaining 
information that is not published on the web of the OPs:
 
A. Through requests for information.
 
B. Through the central registry of contracts.
A. Information requests:
In accordance with the Law on free access to information, passed in 2000, state 
bodies, self-governing bodies and other public institutions are obliged to provide 
any information at their disposal when requested, with the exception of classifi ed 
information (state or trade secret or copyrights). Information can be requested by 
any citizen without stating their purpose.

14
Thanks to this mechanism, citizens and NGOs are able to obtain detailed information 
about approved projects, which would otherwise be inaccessible to them. In practice, 
there are, however, various problems in obtaining information. Offi cial bodies in 
some cases refuse to provide information referring to trade secrets and copyrights, 
or stating that they don’t have the information in the form and structure required.
B. Publishing of State Contracts:
In 2010, as an effort to increase transparency of the utilisation of public fi nance, an 
obligation for all public bodies and institutions to publish all their contracts related 
to public procurement was put into practice by a series of act amendments. This 
dramatically improved accessibility of information on EU funds.
 A central registry of contracts was launched in January 2011. Citizens may fi nd 
prompt information on what amount and under what conditions is being spent, for 
example, on technical assistance. The validity of all contracts is dependent on being 
published in the register. This also refers to contracts with fi nancial contribution from 
EU funds. The contract between the provider and the benefi ciary has a standard 
form and doesn’t include any detailed information about the project. However, one 
of the appendices, the so-called “subject of support” contains information on the 
goals and targets of the project, the activities, the impact and output indicators, as 
well as the budget overview.
Conclusions
Compared to the level of information provision before 2010 (the majority of MAs 
published only the project title, the applicant and the amount applied for), the reform 
presents a great progress. There is still need for some information necessary to 
evaluate the quality and effi ciency of projects thoroughly. The information needed 
includes: the project summary which is a part of the project application, and contains 
the justifi cation of the project, the description of activities, outputs and results, as 
well as a detailed budget.

 Theme 2: Bottom-up and coordinated planning
15
This chapter consists of two closely related sub themes: “Coordination between 
local/regional and national priorities, cooperation between these levels” and 
“Bottom-up planning of programmes/participation in programming”. The cases for 
both themes came from Poland, which is another reason to treat them in one 
chapter.
Coordination between Local /
Regional and National Priorities, 
Cooperation between these Levels

Coordination between local and regional priorities on the one hand and national 
ones on the other hand is not well developed in the new Member states. Having a 
long-lasting tradition of centralization in political life and the economy, some time 
would be needed to accomplish the total decentralisation of decision-making and 
realize meaningful coordination between local/regional and national priorities.
Well managed cooperation between the two (or three) levels of territorial 
administration (and therefore, appropriate defi nition and implementation of their 
priorities) is a key to a good regional policy. Regional policy is the one, in which 
local and regional priorities are defi ned, strategised, prioritised and implemented. 
Financial planning and sources are also done on this level.
A recent study in Bulgaria shows that there hasn’t been any coherent approach 
between regional policy planning and programming of EU funds. This situation 
led to a lot of confusion, preventing bottom-up approach and resulting in many 
problems between Managing Authorities, Monitoring Committees and local/regional 
authorities all having their own plans, expectations and political games.
Our team hasn’t been able to fi nd many examples of good cooperation between 
these two (or three) levels. The case chosen from Poland shows, however, that it 
is possible to organise positive and feasible partnership initiatives/schemes across 
programmes, in particular, EU-funded ones.

16
The National Thematic Network for Partnership (NTNP) was established in June 
2010 by the Coordinating Committee for the National Strategic Framework 2007-
2013. The Network will be in force till the end of the current programming period. 
The aim of the Network is to provide concrete support for the members of Monitoring 
Committees (MCs), especially those, which represent socio-economic partners. The 
aim of the support is to make their activities more effective and eliminate problems 
connected with the implementation of structural funds in Poland. The term “socio-
economic partners” includes employers’ and employees’ unions, non-governmental 
organizations and representatives of academic institutions. They make up about 
30% of the members of the Polish MCs.
The NTNP focuses on all stakeholders in the Monitoring Committees and is aimed 
to promote partnership among the members of the MCs, working out tools for 
partnership, opening room for a wider discussion on structural funds, increasing 
effectiveness of all stakeholders, monitoring the legislation on regional development, 
etc. 
Started as an answer to the problem of the low sense of infl uence on real decision-
making among the civic and social representatives of MCs, the NTNP got the 
support of the Coordinating Committee of the NSRF and the Polish Ministry for 
Regional Development
. The costs of the Network are covered from the Technical 
Assistance Operational Program 
2007-2013.
A very important side effect of the Network is that it is likely to strengthen the entire 
civil society in Poland indirectly, where (as in all ex-communist countries) the lack 
of trust in relations between different groups and institutions can still be recognised. 
One of the advantages of the Network is that it provides six practicable instruments:

a national annual conference;

regional meetings – held every 2/3 months in one of the 16 Polish 
regions;

analysis and expertise (thematic studies);

competition for the monitoring committee with best partnership 
practices

horizontal exchange of information using the Knowledge Base, 
administered by the Ministry for Regional Development;

various educational activities, depending on needs.

NGOs and other stakeholders are awaiting the results of this experiment. 150 out of 
17
about 800 people are already involved in the Network and the ambitious plan is to 
involve all members of the MCs and their alternates, as well.
Recommendations
Ultimately, SFteam calls on all governments to synchronise the processes of 
developing regional policies in their countries with the programming of EU funds 
both on framework and operational levels. The principles of the recommended 
synchronisation are:

strong regional policy oriented towards sustainable development of 
regions and communities;

decentralisation of responsibilities, rights and obligations in developing 
regional policies;

bottom-up planning of both regional development and funding (incl. 
EU funding) as much as appropriate;

continuous coordination.

18
Case Study (Poland):
National Thematic Network for
Partnership – Bottom-up Initiative
to Enhance Partnership across
EU-funded Programmes
The National Thematic Network for Partnership
 was established in June 2010 by 
the Coordinating Committee for the National Strategic Framework 2007-2013. 
The Network is to be in force till the end of the current programming period. The 
aim of the Network is to provide concrete support for the members of Monitoring 
Committees (MCs), especially those which represent socio-economic partners. The 
aim of the support is to make their activities more effective and eliminate problems 
connected to the implementation of structural funds in Poland. The term ‘socio-
economic partners’ includes employers’ and employees’ unions, non-governmental 
organizations and representatives of academic institutions. They make up about 
30% of the members of the Polish MCs.
The operational objectives of the Network are as follows:

popularisation of the idea of partnership among members of 
Monitoring Committees,

working out a system of instruments for implementing the partnership 
principle,

providing opportunity for a wider discussion of important and urgent 
issues related to structural funds,

increasing the effectiveness of the participation of socio-economic 
partners, the government, regional and local authorities in MCs,

strengthening the relations between social and civil partners in order 
to avoid neglecting important civil and social needs,

raising public acceptance of the decisions of the MCs and the activities 
of the institutions in the context of cohesion policy,

monitoring legislation on regional development, especially the 
elements concerning partnership,

working out recommendations.

The National Thematic Network for Partnership was established as an answer to the 
19
problem of low sense of infl uence on real decision-making among civic and social 
representatives of MCs. The Working Group for Civil Society within the Coordinating 
Committee of National Strategic Reference Framework
 decided to address this 
issue. The Polish Ministry for Regional Development gave its strong support for the 
establishment of the Network. It is to be mentioned that the costs of maintaining 
the Network are covered by the Ministry by the Technical Assistance Operational 
Program 2007-2013.
The Network also strives to strengthen the entire civil society in Poland indirectly. In 
a country with a communist heritage, the lack of trust in relations between different 
groups can still be felt. 
The fi rst step for the solution of this problem came in the form of a training course 
organized by the Working group and the Ministry for Regional Development 
in 2009. About 10% of the civil and social partners – members of the MCs – 
participated in this event. The conference set a precedent. It was the fi rst meeting 
of the representatives of NGOs, employers’ and employees’ unions as well as 
representatives of the academic circles from all over Poland, where they had an 
opportunity to talk and share experiences. The meeting focused on important issues 
for the entire Operational Program 2007-2013. At the end of the conference, the 
opinions of the participants were summed up as recommendations in the following 
fi elds: 

civil society,

selection criteria of projects,

evaluation,

equal treatment/gender policy.
However, the most important recommendation was the idea of establishing the 
National Thematic Network for Partnership.
Authors of the recommendations declared their willingness to cooperate more 
deeply in supporting partnership in the implementation of public policies. Their 
previous experience showed that partnership between public administration and civil 
institutions was effective only by means of wide consultation, respect for partners, 
autonomy, as well as inclusion in the system of decision making. That is why the 
objective behind the creation of the Network was the provision of an instrument 
of permanent exchange of information and experiences, as well as promotion of 
good practices that strengthen the role of socio-economic partners in programming, 
implementation and evaluation of public policies, especially structural funds on 
every level of implementation.

20
In order to carry these out, the Network has six instruments:

a national annual conference on various aspects of partnership (the 
fi rst took place in October 2010, the second is planned for the fi rst 
half of 2011),

regional meetings – held every 2/3 months in one of the 16 Polish 
regions, meetings are dedicated to actual diffi culties in the work of 
members of MCs, training, workshops and exchange of experiences 
(the fi rst was held in November 2010 in Lodz, 4 more are scheduled 
for 2011),

analysis and expertise – possibility to order thematic studies,

competition for monitoring committees to identify the best application 
of the partnership principle,

horizontal exchange of information - using the Knowledge Base 
administrated by the Ministry for Regional Development,

other educational activities, depending on needs.
The Network is still in its start-up phase. So far about 150 people attended the 
Network meetings. They gradually tap into the information system. There are an 
estimated 800 members of the MCs and their alternates which represent socio-
economic partners. At the same time, some people are members of several 
committees.
It seems that the greatest potential lies in the regional meetings that the Network 
organises. Each of these is attended by up to 80 people. Meetings are devoted to 
current problems with the implementation of European funds in a particular region, 
partnership principle, issues of gender mainstreaming and equal opportunities, 
sustainable development and civil dialogue.
Each regional meeting is open to all socio-economic partners from all committees 
in Poland, but also to representatives of public administration, especially from the 
particular region. The meetings concentrate on raising awareness as well as on 
information exchange between participants. The idea of the meetings is to develop 
solutions and recommendations for problematic issues, both on a general level and 
for a particular program.
The National Thematic Network for the Partnership is an example of real-life 
implementation of partnership and good governance principles. This type of 
mechanism should be used more widely, because it builds trust between the 
partners in dialogue and is an investment in social capital. Regarding threats to 
the successful functioning of the network: one could be the insuffi cient use by the 
socio-economic partners of the opportunities created, while another one could be 
the tendency of authorities to limit its role. The practical results of the Network’s 
operation can be evaluated during the year 2011.  

21
Bottom-up Planning of Programmes and 
Participation in Programming
The bottom-up planning of programmes seems to be a desired, but not yet 
implemented tool for programming of operational programmes in new Member 
countries. In spite the fact that some attempts were made in this direction (e.g. 
partially in Bulgaria), the main approach still in use by governments is top-down. It is 
the central governments that organise processes, and very often they are preparing 
the legislative framework for programming without any consultation.
The stakeholders (local and regional authorities, NGOs, business associations, 
etc.) are often involved at the stage of working groups that are to prepare the drafts 
of the OPs. The case of Bulgaria between 2005-07 shows that all stakeholders 
other than the central authorities were placed in front of a fait accompli with the 
preliminary work of the ministries that they were not able to infl uence signifi cantly.
However, there is a good case of participation in programming of the European 
Social Fund in the Lodzkie Region in Poland.
The detailed plan of spending, the fi nancial breakdown between fi elds of intervention, 
their forms and amounts are decided in advance for every year. Goals and indicators 
of the Operational Program Human Capital give the overall framework. This program 
manages the entire ESF allocation in Poland. Each of the sixteen Polish regions has 
its own Monitoring Subcommittee, which is in charge of the regional component 
of the annual Action Plan of the OP Human Capital. A Monitoring Subcommittee 
consists of representatives of both regional and government authorities as well as 
representatives of socio-economic partners. This category includes NGOs, trade 
unions, employers’ organizations and academic institutions. The actual participation 
of these different groups varies across regions and primarily depends on the attitude 
of the Marshal’s Offi ce.
After a few years of neglecting the impact of socio-economic partners in the region, 
in 2009 about 30 NGOs participated in a consultative meeting on the draft Action 
plan. They were listened to by the representatives of Marshal’s Offi ce, the Regional 
Employment Offi ce and the Managing Authority. The proposals of the NGOs were 
accepted almost fully, thus, opening a meaningful future cooperation for 2010 and 
beyond.

22
Probably the best outcome of the case is that the Managing Authority of the OP 
Human Capital reviewed the process in Lodzkie positively and recommended this 
working method for Action Plans across all regions. But the cooperation among 
national and regional NGOs and the approach of administration when civil partners 
are taken seriously, are also to be sought after as good examples.
Recommendations

Cooperation among national and regional NGOs is useful in order 
to channel information about planning processes among each other. 
Their cooperation also has a potential to take joint and coordinated 
action for common priorities at various levels.

Planning and programming should be carried out in a bottom-up 
approach, where national plans rely on sub-regional and regional 
planning which follow EU and national level guidelines and principles. 
Adherence to national sustainable development strategies is a must. 

Case Study (Poland):
23
Programming the European Social Fund 
in the Lodzkie Region (Poland) – an 
Example of  Participatory Process
The European Social Fund in Poland is implemented both on central and regional 
levels. The detailed plan of spending, the fi nancial breakdown between fi elds  of 
intervention, its forms and amounts are decided in advance for every year. Goals 
and indicators of the Operational Program Human Capital provide the overall 
framework. This program governs the entire ESF allocation in Poland. Planning on 
the regional level must take into account the regional socio-economic circumstances, 
e.g., unemployment rates or access to education on all levels. There are special 
instruments for this annual programming called Action Plans. They are prepared by 
the Monitoring Committee. In case of the regional component, each of the sixteen 
Polish regions established its own Monitoring Subcommittee.
This body is responsible for the Action Plans for the particular region. The decisions 
of the subcommittees need to be accepted by the central Monitoring Committee. 
Final decisions regarding the Action Plans are adopted in late autumn each year. 
The work on their development takes months. 
The Intermediate Authority responsible for the implementation of the regional 
component of the OP Human Capital in each (self-governed) region is the 
Marshal’s Offi ce (provincial government). Thus, the Marshal (provincial governor) 
is the Chairman of the Monitoring Subcommittee. The Monitoring Subcommittee 
consists of representatives of both the regional and government authorities as well 
as representatives of socio-economic partners. This category includes NGOs, trade 
unions, employers’ organizations and academic institutions. The actual participation 
of these different groups varies across regions and primarily depends on the attitude 
of the Marshal’s Offi ce. 
The system of programming the regional component of Human Capital evolved 
in an interesting way in the Lodzkie region. In the fi rst few years of the Program’s 
implementation, regional authorities restrained the socio-economic partners’ impact 
on the fi nal shape of the annual Action Plan. In fact, consultation was limited to a 
few hours of discussion during the Subcommittee meeting. In addition, the MS had

24
to work under time pressure because the Marshal’s Offi ce had little time to negotiate 
the proposal with the Managing Authority.
In October 2009, representatives of the Regional NGO Council in Lodzkie, who 
participate in the Subcommittee held a consultation meeting on the draft of the 
Action Plan for 2010. The Council received organizational and fi nancial  support 
from the Polish Federation of NGOs. About 30 NGOs from the region attended 
the meeting. The draft Action Plan was presented by representatives of two offi ces 
responsible for the implementation of the regional component of the OP Human 
Capital (Marshal’s Offi ce and the Regional Employment Offi ce).  Representatives 
of the Managing Authority and the Federation of NGOs were invited to the meeting 
as advisors and observers. The purpose of the meeting was to conduct a real 
public consultation, based on discussion and dialogue. Representatives of the non-
governmental sector actively discussed and presented a number of proposals. Most 
of them concerned the importance of the points for meeting strategic criteria used 
in competitions for grants. Three days after the Monitoring Subcommittee meeting, 
all the recommendations were formally accepted by non-governmental members 
and included into the fi nal version of the document that was sent to the Managing 
Authority. 
This meeting set a precedent. It allowed both parties to see and understand the 
conditions under which both of them operate. The following year, the Marshal’s 
Offi ce began working on the Action Plan already in spring. In April, the consultative 
conference was organized. It was attended by around 100 people. Among others, 
the Deputy Marshal, the Deputy Director of the Managing Authority, the Chairman 
of the Regional NGOs Council in Lodzkie and a representative of the Federation 
participated. As previously, a lively discussion took place. In 2010, a working group 
was established by the Subcommittee to work on an Action Plan. Consultation of 
different kinds (in writing, through a website, in meetings) went on from spring to late 
autumn and satisfi ed every partner in the process.
The example of Lodzkie showed how much could be achieved through the combined 
forces of national and regional NGO federations. The other important factor is the 
high activity and initiative of NGO representatives in committees. And last but not 
least, administration must devote time and attention to treat civic partners seriously. 
Consultation carried out this way doesn’t result in decision paralysis. This argument 
is often used as a reason for the limited use of such methods. The added value 
of the process is the building of social capital, leading even towards trust in state 
institutions.

The Managing Authority of OP Human Capital positively reviewed the process in 
25
Lodzkie and recommended this working method on Action Plans across all regions.
The experience gained in the region has also been used by the National Thematic 
Network for Partnership. The Network is currently (January 2011) working on the 
standardization of the schedule for the development of the annual regional Action 
Plan for ESF. The model was prepared on the basis of the process in Lodzkie.
The approach applied in Lodzkie to the development of the Action Plan, especially 
the process of opening it to different groups and their representatives, is an example 
of good practice.  Making the discussion on the Action Plan broader and the inclusion 
of many stakeholders interested in the region’s development, not only members of 
the Subcommittee, result in better procedures and requirements that fi t  potential 
benefi ciaries.  The disadvantage of the method could be a possible threat of some 
institutions or people having more infl uence on the fi nal shape of the Action Plan 
than others, as well as the dependence of the success on the activity and interest of 
the members of the Monitoring Subcommittee. 

26
Theme 3: Participation in Programming
Environmental NGOs from new member countries had been prepared for the 
programming for 2007 – 2013 well in advance. The leading among them were 
mainly national groups of the CEE Bankwatch Network and FOE-Europe, as well 
as some powerful local groups of the environmental and social movement (eg. in 
Romania). Often these groups formed coalitions (Bulgaria, Latvia, Hungary) and 
join their capacity and expertise for better participation in the programming. In 
Latvia there was also strong cooperation between NGOs working on environmental, 
education, gender and social issues. They informed each other about key positions 
and challenges in each sector and attempted to coordinate their demands. This 
approach of coordinating demands prevented NGOs from different sectors to come 
up with contradicting proposals, but instead reinforced each others’ demands.
Meaningful and democratic public participation hasn’t had long-lasting traditions 
in CEE countries. The countries also vary in their legislative basis regarding 
participation and in some countries (e.g., Romania) the procedures for civil 
participation are not well established. Even in countries with advanced legislation, 
there was general fear within the authorities to open the programming of EU funds 
for a broad participation of the representatives of civil society.
Nevertheless, in spite of the general problems with programming in most of the 
countries, it seems that participation in the process concluded with a number of 
positive examples and lessons learned.
The most important one is that NGOs – being only generally prepared for 
participation in an otherwise unfamiliar process driven by different and sometimes 
contradictory interests – achieved everything mainly on account of their self-
organisation and their own initiatives. Whether it was pressure on offi cials to accept 
civil representatives (Bulgaria), protests (Romania), advocacy work (Hungary), 
participation in formal consultation meetings (Poland) or a mixture of all these and 
even further approaches – civil groups managed to fulfi ll achievements due to their 
own active and continuous hard work. In general, even many institutional players 
recognised these achievements as of common benefi t.
Some of these achievements are:

improvement of the governmental internet tool for public consultation 
(Hungary);

model case for participation of NGOs in regional annual action plans, 
later on recommended by the authorities to be implemented by all 
regions as good practice (Poland);


NGOs and Ministry of Environment supported each others’ ideas 
27
(Latvia);

special information website with time-line of the programming process 
and important deadlines, draft documents, meetings comments from 
line ministries, NGOs and the European Commission (Latvia);

miscellaneous achievements in the development of OPs (Bulgaria, 
Romania), etc.
One defi nite success was that more and broader information than ever was 
disclosed to and discussed with CSOs and other stakeholders. We hope that 
institutions learnt their lesson: timely disclosure of information during the debates 
on strategic documents, plans and programmes helps to fi nd better solutions and 
make things work.
Not all of these achievements are perfect or stable throughout the years; at the 
end of the day the new programming process for post-2014 EU funding will prove 
their stability or otherwise. However, it is clear that good organisation and good 
arguments by civil society could bring about better and more open procedures and 
could improve the contents of the programmes.
It is very important to point out that in some countries (Bulgaria, Hungary) NGOs 
organised their own system for the internal and independent election of the 
representatives of civil society in the working groups and/or committees. Though 
some of the responsible institutions in different countries did not make use of the 
system in selecting representatives of NGOs, it is proven that this is one of the best 
practical achievements of civil society elsewhere.
The fact that consultation in some countries or between some institutions and CSOs 
went beyond formalities also presents the way the work could be done easier, faster 
and without trouble or hesitation by most of the parties.
The main diffi culty for non-governmental stakeholders in participation seems to 
be the unclear approach of the programming. There were cases of processes 
and procedures organised top-down and bottom-up (and in various mixtures) 
that confused communities and NGOs. In fact, it is very natural that some of the 
activities are done one way, while others the other way. One cannot plan the national 
transport system bottom-up. By the same token, the top-down planning of local and 
regional goals would be almost disastrous. Therefore, a preliminary schedule for 
the organisation of the different processes within the frame of the programming, 
made available to all participants in due time would improve the meaningful input 
of all parties.

28
A problem still exists with the inclusion of representatives of civil society (except for 
trade unions and employees’ associations) within the “social and economic partners” 
category. Poland is a single positive example, while other CEE governments are 
reluctant to take this step in favour of civil society.
A long-lasting problem is rooted in the internal and external limitations of the NGO 
sector. This theme would require a study on its own. However, it is to be mentioned 
here that any participatory process (and the programming of EU funds is not an 
exception) brings a major risk when pushing NGOs towards being providers of 
services and consultants, thus diminishing and marginalising their role as watchdogs 
and keepers of public interest, even though both processes and functions are 
essential. This risk is recognised by some authorities (e.g., in Bulgaria). The solution 
must be found before this risk turns into reality.
The experience on cross-sectoral communication and coordination between NGOs 
gained in Latvia is used nowadays in Bulgaria, where a wide network of various 
NGOs and civil coalitions joined forces to participate in the programming for 2014 
– 2020 fi nancial period.

Case Study (Romania):
29
Successful Intervention of the 
Representatives of NGOs in the 
Regional Operational Program ax 1.1 
in the Region of Central 
Transylvania, Romania
In the framework of the Regional Operational Program (ROP) ax 1.1, approximately 
14 million Euros were allocated to the town of Târgu Mureş to support the 
implementation of the Integrated Urban Development Plan (IUDP), which was to be 
elaborated in cooperation with local stakeholders. As a result of the intervention of 
the representatives of NGOs in the Regional Steering Committee (CRESC), public 
participation in the elaboration of the IUDP was signifi cantly improved. 
The budget of the ROP ax 1.1. was established to give fi nancial support for the 
specifi c needs of towns for their development. The condition for the allocation of the 
money was the realization of an integrated development plan, which also represented 
the long term vision of the development of the town. For the establishment of a long 
term vision, the participation of the public at large is absolutely necessary, because 
the development plan has to be acknowledged by the population, not only by the 
actual administration of the town.
Romania has no long tradition of public participation and the procedures are not 
well established. Therefore, in this case the town administration (the town hall) 
considered the opportunity of submitting a project just as a usual possibility and 
decided to allocate the available sum to the construction of a road through the 
town forest, a project which had been opposed by environmental organizations for 
years. This proposal was communicated to the Regional Development Agency, and 
the representatives of the NGOs from Mures County were informed about it at the 
meeting of the Regional Steering Committee (CRESC).

30
The representatives of the NGOs in CRESC informed the NGOs about the proposal 
of the town hall and the NGOs protested against the project. The representatives of 
the NGOs in CRESC informed all parties involved about the controversial nature 
of the project and that it was not a suitable proposal for this type of fi nancing line, 
which was supposed to be based on the principle of wide consensus. Subsequently, 
the town hall withdrew this proposal and submitted a different one.
The participation of the representatives of NGOs in the Steering Committee 
(CRESC) can be very useful. It is our recommendation for Romanian NGOs in the 
future to fi ght to become members in the CRESC in all regions, because this way 
they can represent the interests of environmental NGOs, and may have an infl uence 
on the development of their region.  

Case Study (Bulgaria):
31
Participation in Programming: from 
First Attempts (2005) towards 
Meaningful Impact (2011)

In late 2004 some 10-15 environmental NGOs in Bulgaria got together to form a 
coalition for participation in the programming of EU Structural funds for the 2007 – 
2013 fi nancial period. They started a campaign for the inclusion of civil society and 
managed to take part in three out of the eight working groups, two WGs on OPs and 
the WG on NSRF, as well as in the WG on the National Plan for Rural Development. 
The participation in the programming led to a number of small successes and a lot 
more lessons were learned. Recently, a new study made by NGOs shows how the 
lessons learnt could be used during the programming of Structural funds for the 
2014 – 2020 period.
The  fi rst meaningful attempt by the Bulgarian government to include various 
stakeholders in the programming process opened new possibilities for environmental 
groups in Bulgaria. Though environmental NGOs are not offi cially  recognised  as 
“social partners” (are neither trade-unions or associations of employers), some of 
the most active ones managed to organise themselves in a coalition and took part 
in the programming process that happened in 2005 – 2007. NGOs were active in:

the working group for NSRF;

the working groups for OP Environment, OP Transport and the 
National Plan for Rural Areas;

public meetings, the so-called Forums, which are a set of meetings 
of all the WGs aimed at making the whole programming a coherent 
process. The Forum-approach was fi nancially supported by the Swiss 
government.)
The process itself was well structured from the beginning, with different stages, and 
discussions after every stage among WGs, and cross-institutional communication 
was urged unlike in most other cases... The implementation, however, was very 
poor due to:

32

the lack of knowledge and experience about the process;

the lack of knowledge and experience about the essence and 
requirements of the EU Cohesion Policy;

national elections and change of government in the middle of 2005; 

problems among the institutions and within institutions; 

incorrect political implications, etc.
In a working environment that may barely be called normal, participating NGOs tried 
to focus on several issues, both on participation and on the aspect of problematic 
contents.
There seemed to be quite many options for participation, not all of them democratic 
enough. For example, some ministries invited NGOs to participate on their own, 
bypassing the election procedure of environmental NGOs. There were even cases 
when a single person was supposed to decide whom to invite. Nevertheless, there 
were also positive examples (the WG on NSRF, the WG on OP Environment), where 
the respective institutions not only formally ensured a slot for environmental NGOs, 
but also actively made use of their expertise in formal and informal ways.
In the case of the WG of OP Environment, the representatives of NGOs supported 
actively the proposals of the Ministry of Environment and Waters (MOEW) to focus 
funding on infrastructure (such as waste water treatment and waste management 
projects) under the “heavy directives” (WFD, Waste Directive) in order to be able to 
meet the requirements of Chapter 22 of Bulgaria’s Accession Treaty.
At the same time, NGOs were the strongest proponents of the prioritisation of 
biodiversity (protected areas and NATURA 2000), that wasn’t in the focus of others. 
But as a result of the work of NGOs throughout the negotiations, biodiversity 
was  fi nally accepted as one of the three main priority areas (“axes”) of the OP 
Environment.
NGOs opposed several other proposals, which were fi nally removed from the OP 
Environment with semi-public support of the MOEW. These were the prioritisation 
of mining waste, advocated very heavily by the mining industry (market distortions) 
and the inclusion of support for renewable energy sources (RES) and energy 
effi ciency (EE) in the OP, which was fi nally included in the OP Competitiveness by 
the Ministry of Economy and Energy).

Unfortunately, due to the defi ciencies of the process and the pressure of time (the 
33
end of 2006-beginning of 2007), NGOs were neglected at the last stage of the 
programming. This led to some problems, like the inclusion of non-agreed projects 
in the list of major projects by the OP Environment, and problems with the SEA of 
the OPs).
Since the end of 2009, a group of NGOs, including CSUEUFB, OSI Bulgaria, Civil 
Activity Forum and other social and childcare NGOs got together with the idea to 
prepare themselves for participation in the upcoming programming of EU funds for 
the 2014 – 2020 fi nancial period. As part of the preparatory work, a study analysing 
the programming process for the 2007 – 2013 period was envisaged.
The study7  made by a team of experts at NGOs and freelancers, led by OSI Bulgaria, 
concludes that the process was a big failure. First of all, there was no coherency 
between regional policy planning (municipal, regional and NUTS 2 strategies) and 
programming. This led to a number of discrepancies and contradictions between 
the strategic documents and the OPs. Some of the recommendations also focus on 
meaningful public participation, which would allow them not only to “participate”, but 
to bring positive impact on the results.
The study also proposes an algorithm for better programming as such. Based on 
this, the Coalition and the broader network of NGOs work on implementing the 
ideas on civil participation in programming.
7
Konstantinov, Dragomir. (ed.) Challenges to the new programming of EU funds in Bulgaria after 2013 
based on the analysis of the experience in 2007 – 2013, Sofi a, March, 2011. available at: http://www.
osf.bg/downloads/File/Fonds_after%202013_FINAL.pdf in Bulgarian

34
Case Study (Hungary):
Participation in Programming – 
Consultation on Project Proposals
Since 2007, the National Development Agency in Hungary used to publish each call 
for proposals for EU funds for public comments on the web, on one single website 
(www.nfu.hu), prior to the opening of the call. This practice is the result of long-
term NGO advocacy and, despite its defi ciencies, one also has to acknowledge its 
novelty and progressive features.
In 2007, the National Development Agency (government institution managing 
EU funds) restructured its website and introduced a registration system for those 
interested in EU funds issues. Registration was simple and accessible to anyone 
with an internet access; the minimum information required was a name and an email 
address. Giving the title, position, name, type and contact details of the organization 
or the private person were optional. Those registered got regular notices about 
documents newly opened for public consultation. Registration, however, was a 
tool of convenience for the user only because anyone could fi nd and access the 
documents published for consultation.
In 2007, the fi rst year of the new EU budgetary period, dozens of calls for proposals 
were expected to be opened. After four years of varying transparency and public 
consultation practices on programming documents, in 2007, the government 
decided to publish the calls for proposals for EU funds on the National Development 
Agency’s website for public consultation, prior to opening the call. The information 
about a call usually included: the draft call itself, application guide, draft budget 
form, project assessment and evaluation criteria. The Agency published Excel 
questionnaires with sections dedicated to certain parts of the call (guide, form, 
aims, benefi ciaries,  fi nancial or selection criteria, budget etc.) to be fi lled in with 
comments. The Agency also allocated an email address to each call to receive 
and easily manage the comments from the public. Public consultation on a call 
was usually open for about one or two weeks (not much but still something). After 
concluding the debate, the Agency published a fi le with the comments received and 
the responses of drafting experts. With the high number of calls published, it would 
require a lengthy research to assess the level and scale of comments incorporated 
or neglected.

In 2008, the National Development Agency gave a new function and meaning to 
35
online registration; the documents open for public consultation could be commented 
on through an online forum which required prior registration. This had the advantage 
that those commenting could also refl ect on each others’ comments, while the 
necessary registration probably made them “moderate” themselves as well. (One 
could still anticipate that there was some internal moderation, too.) Unfortunately, 
along with the introduction of this online forum-based consultation system, the 
possibility of submitting comments through email was abolished (or not evident at 
least). The same system continued operating ever since, with a single opportunity 
to submit comments to calls for proposals through the online forum.
Another important feature of the online consultation was that one could and had 
to chose from a pop-up menu on which document or chapter (just like in the 
questionnaire above) of the call they wanted to comment on. This probably made 
it easier for the drafting team to handle the comments on the one hand, but on 
the other hand, it also limited the possibilities of commenting (e.g., no space for 
comments on the general content or aim of the call).
One could think that the opening of calls for public consultation would result in 
unmanageable amounts of comments. However, this was usually not the case. It 
was probably due both to the high number of calls and the limited capacities of civil 
society and the general public that they mostly commented on the few calls only 
that were of major interest to them. Still, it was crucial to have the opportunity there.
Even if the internet is spreading more and more, there are still quite many (smaller 
organisations especially) who don’t have access to it. There are even more, 
who are hesitant to use the newest technologies such as commenting on online 
forums. Therefore, decision-makers should consider offering the possibility of 
email commenting along with the online forum for a further couple of years. Also, 
partnership would be more intense if the conditions and proposals for major projects 
were also subject to public consultation.

36
Case Study (Latvia):
NGO Participation in the Programming 
Process of EU Funds for 2007-2013, 
Latvia 

Environmental NGOs in Latvia were actively and systematically involved in the 
programming process of EU funds for the 2007-2013 period. National NGOs 
cooperated in order to elaborate key demands and positions, coordinated their 
position with NGOs from other sectors and then discussed proposals with the 
Ministry of Finance and the Ministry of Environment. NGOs used participation 
opportunities that were provided but also acted proactively and organized advocacy 
meetings, roundtables and seminars. Most of this activity took place in 2005 and 
2006 with the aim to infl uence the National Strategic Reference Framework, three 
operational programmes and their complements. 
NGO Cooperation Platforms and Networking 
Environmental NGOs started to get prepared for the EU funds programming process 
in early 2005. NGOs started with learning about the EU funds programming process 
in general, refl ected on lessons learned from the 2004-2006 national programming 
period and then organized several meetings to build capacity. Inspired by the 
experience of functioning NGO coalitions in other CEE countries and the international 
NGO coalition on the sustainable use of EU funds, the Latvian environmental 
NGOs established the national NGO coalition focused on environmental issues in 
May 2005. There were about 8-10 environmental NGOs involved in the work of 
the coalition actively and a few more NGOs were subscribed to receive regular 
updates from the mailing list. Environmental NGOs met regularly and elaborated 
their demands and positions on various issues.
During the programming process, there was also close cooperation between NGOs 
across various sectors. NGOs working on environmental, education, gender and 
social issues informed each other about key positions and challenges in each sector 
and attempted to coordinate their demands. Several times these NGOs organized 
joint advocacy meetings with the Ministry of Finance. This approach of coordinating 
demands prevented NGOs from different sectors to come up with contradicting 
proposals but instead, reinforced each others’ demands.

In addition to national networks, international networking also played a crucial role. 
37
The environmental NGO coalition used position papers prepared by the international 
coalition on the sustainable use of EU funds. Several position papers were translated 
into Latvian and international NGO demands were adapted to the Latvian situation. 
Three members of the Latvian NGO coalition, namely, Green Liberty, Latvian Green 
Movement and WWF Latvia were directly involved in international networking. 
Having better understanding of programming related processes within the European 
Commission, equipped with the arguments of the international NGO coalition and 
knowing the situation on home grounds were preconditions that allowed successful 
involvement in national programming.
NGO Focus and Key Demands 
Key NGO demands were formulated around fi nancing for nature protection 
measures, sustainable tourism, renewable energy and energy effi ciency measures, 
support for implementation of requirements of EU Water framework directive 
requirements and supporting waste hierarchy as well as putting forward demands 
for horizontal integration of sustainable development. NGOs also advocated for the 
inclusion of various soft measures such as trainings, capacity buildings, monitoring 
and similar support activities to foster the implementation of EU requirements in 
the fi eld of environment. On the other hand, environmental NGOs also observed 
whether environmentally harmful infrastructure projects were programmed and 
voiced their concerns about some of them. Thus, NGOs focused their efforts on 
commenting the NSRF as well as the OP “Infrastructure and services”.
Representatives of the national NGO coalition organised meetings with offi cials of 
the Ministry of Finance, distributed information and prepared comments on the draft 
documents. On several occasions, the Ministry of Finance even took the initiative to 
invite offi cials from Ministry of Environment also to these meetings with the NGOs in 
order to be able to discuss various issues on the spot. At times, the NGOs proposed 
new activities and sought support from the Ministry of Environment, while on 
several occasions the Ministry of Environment sought the support of environmental 
NGOs to reinforce measures that the ministry proposed. This process, however, 
makes it diffi cult to make statistics on how many NGO comments were taken into 
account, because participation had a nature of constant interaction between NGO 
representatives and ministries. Direct meetings and exchange of opinions took 
place throughout 2005 and 2006 until the end of the active programming process.
There is however also criticism about the lack of advocacy on allowing NGOs to 
be benefi ciaries in many programmed activities. Indeed, during the programming

38
process environmental NGOs did not have particular focus on ensuring that NGOs 
could be benefi ciaries. This appeared to be a problem during the implementation 
phase, when NGOs were not eligible as applicants in many activities. This should 
be taken as a lesson learned for upcoming programming.
Structures for Involvement and Procedures
The success of NGO involvement was partly due to the opportunities provided 
by the structures of participation such as proper information tools, participation 
procedures such as the public consultation process on draft documents and the 
strategic environmental impact assessment. However, the openness and willingness 
to cooperate on the part of the Ministry of Finance and the Ministry of Environment 
was perhaps more important.
The Ministry of Finance, which was responsible for the programming process, 
provided structural support for the involvement of NGOs. At the start of the 
programming process, a special website was created (www.esfondi.lv), where all 
information related to the programming of EU funds was published – the time-line 
of the programming process and important deadlines, draft documents, meeting 
comments from line ministries, NGOs and the European Commission. The 
publication of the programming time-line was of particular importance – clarifying 
it for NGOs and allowing time for the preparation of planning and allocating the 
necessary capacities. This website still continues to function and has been extended 
to include documents for monitoring and implementation and other EU funds related 
information and links can be found.
As for meetings between NGOs and ministries, those were demand-oriented, i.e., 
NGOs proposed to have consultation meetings and the Ministry of Finance was 
responsive towards NGO requirements for information and advocacy meetings. 
Also the fact that the offi cial consultation process (on NSRS, OPs and strategic 
environmental assessment) went beyond formalities, i.e., all received comments 
were listed in one document (including comments from NGOs) and then later 
separate consultation meetings were organised with those who submitted comments 
to discuss the comments one by one. This highlights the commitment of the ministry 
towards meaningful participation. 

Conclusions 
39

NGO networking and coordination of opinions, inputs and capacity 
building measures were of crucial importance. Systematic 
communication among environmental NGOs, as well as informational 
support from the international NGO community and national NGO 
networking across sectors allowed for better quality and coordinated 
input into programming.

Openness of ministries and their support of NGO participation. Apart 
from the offi cial process, many consultation meetings were organised 
where NGO comments and demands were discussed in detail. It was 
also of high importance to have all draft documents available and to 
have a clear time-line.

40
Theme 4: Financing for Sustainability
The questions about funding for civil society and for nature have always been 
related to the sustainability of a society and/or a certain territory. Therefore, we 
agreed to put the cases and conclusions we extract from them into a joint chapter 
with two subchapters: “Nature protection” and “Financing of NGOs”. We do believe 
that the best way to protect nature on local and regional levels is to provide support 
for a variety of local actors (NGOs, associations of businesses, SMEs, etc.) that are 
directly involved in activities with the sustainable forms of business and development 
and awareness-raising. We also believe that the capacity-building of NGOs and the 
support for partnership practices are essential to enable the representation of socio-
environmental interests and values in decision-making at all levels of governance 
and administration.
Nature Protection
The protection of nature is one of the important EU policies. It has received growing 
attention as a horizontal issue within the Cohesion and Common Agriculture policies. 
Offi cially more money – directly or indirectly – is devoted to nature protection 
throughout the EU funds and other EU fi nancial programmes.
Ironically, most of the problems with EU funding are related to the clash between 
investment projects, funded with EU money and the protection of valuable and 
unique nature areas, including ones from the NATURA 2000 network, Ramsar 
wetlands, Kresna gorge (Bulgaria), Rospuda valley (Poland), Saaremaa bridge 
(Estonia) and many others from CEE countries are already household names, well 
known in the whole of Europe for the monumental clashes between EU-funded 
projects and the protection of nature of European importance.
While governments always declare their deep empathy for the protection of nature, 
the reality is different. The incorporation of the protection of biodiversity as a priority 
in the OP Environment in countries like Bulgaria happened mainly due to the EU 
policy and heavy pressure from NGOs. Otherwise, environmental infrastructure 
(“more concrete on the ground”) and past pollution (“state pays”) are always on the 
front line of investments.
One good example came from Romania where NGOs helped the local community 
to incorporate values of the nature protection into the rural development plan of Niraj 

valley micro-region. NGOs also mediated development of relations between the 
41
micro-regional association from the Niraj valley and a very experienced LEADER 
group from the neighbouring Hungary. They organized mutual visits that helped the 
representatives of the Niraj micro-regional association to understand the importance 
of the protection of nature.
Unfortunately, the use of LEADER for making the protection of nature and local 
economy more coherent is very limited. This is one of the easiest ways to promote 
sustainability on community level with cheaper soft measures.
Still we could fi nd some good examples of using LEADER in Hungary and Slovenia. 
In Hungary, NATURAMA  Alliance comprises LEADER groups with nature protection 
areas and aim to preserve natural, cultural and human values. The Alliance was 
established in 2009, and it promotes environmentally conscious rural lifestyle. It 
also attempts to combine tradition and innovation in economic development in a 
harmonious, sound way. Members of NATURAMA8 cooperate closely, including 
international exchange. They have organized two photo competitions (on waste 
and on natural and cultural values), meet regularly and are developing joint projects 
(eg. a complex soft tourism project involving local farmers and entrepreneurs etc. 
as suppliers).
Another opportunity for NGOs to work for nature protection is participation in projects, 
under specifi c “nature protection” axes within different OPs. Such opportunities exist 
in all countries. 
In Bulgaria, a consortium of NGOs and consulting companies won a tender recently 
for mapping the NATURA 2000 network. The alternative consortium also included 
an NGO among the partners.
In Hungary, The Environment and Energy OP contains several priorities promoting 
nature protection:
a) Priority 3 is aimed at the “Sound management of natural assets” and includes 
measures like

alleviation of harmful impacts of linear infrastructure to nature 
(preservation or regeneration of habitats);

Preservation or regeneration of botanical gardens and protected 
historical gardens;

Infrastructure development of habitat-preserving agriculture and 
forestry;
8
The members of NATURAMA are: Az Éltető Balaton-felvidékért Egyesület, A Felső-Homokhátság 
Vidékfejlesztési Egyesület, a Borsod-Torna-Gömör Egyesület, „A BAKONYÉRT” Vidékfejlesztési 
Akciócsoport Egyesület, a Szigetköz-Mosoni-sík LEADER Egyesület, az Alpokalja-Ikvamente Leader 
Egyesület és a DIPO Duna-Ipoly Határmenti Együttműködés Helyi Közössége Közhasznú Egyesület.

42
b) Priority 6 (“Sustainable lifestyle and consumption”) contains a measure 
on developing environmental information technology in public administration 
(e-environment protection).
A still unexploited tool for nature protection with participatory approach within the 
broad frame of EU funds use is regional planning. Recently, a growing number of 
NGOs in Bulgaria (environmental, social, healthcare, rural development, etc.) are in 
dialogue with the offi ce of the Minister for EU funds on how to exploit this option in 
the upcoming programming period.

Case Study (Romania):
43
Rural Development Plan with 
Special Consideration for 
Nature Protection Criteria in the 
Niraj Valley Micro-region – Romania 

Short description of the case: In the Niraj valley micro-region, as in many micro-
regions in Romania, the local community receives several inputs during the 
planning process and during the elaboration of development strategy, in many 
cases the main objective being economic growth, without paying attention to the 
environmental aspects. In Niraj valley the local community, the LEADER LAG group, 
by working together with the environmental organization Focus Eco Center, paid 
special attention to the conservation nature, with the key element of their strategy 
being sustainable agriculture and eco-agro tourism.
Detailed Explanation of the Partnership
The micro-regional association and the LEADER LAG group started to elaborate 
the development strategy for the Niraj micro-region. The elaboration of the 
strategy was a requirement for obtaining funds from LEADER program and as 
well from other EU programs. At the beginning, the central idea was economic 
development, and the existing NATURA2000 sites were considered somehow a 
problem due to their restricted nature.
The representatives of Focus Eco Center participated in several workshops and 
explained to the local stakeholders the added value which was represented by 
the existing natural values and the great chance what could be offered by these 
protected areas. At the  same time, the representatives of Focus Eco Center 
mediated a relation between the micro-regional association from the Niraj valley 
and the very experienced LEADER group, Pannonia Kincse from Hungary. 
Mutual visits were organized and the representatives of the Niraj micro-regional 
association grabbed the importance of the protection of nature.
In the fi nal version of the strategy, the protection of nature became an important 
issue, and the proposed economic development was based on sustainable

44
principles. The development strategy was based on extensive and small scale 
agriculture, which would preserve the valuable landscape with its natural values and 
eco-agro tourism, which offers jobs for many small pension owners and an extra 
income for a large number of farmers. The recommendations of the environmental 
organization were highly appreciated and the representative of the Focus Eco 
Center was elected in the board of the Local Action Group.
Conclusions and Recommendations
Local communities in rural areas do not have enough information about the 
principles of sustainable development and about the importance of the preservation 
of natural values, and they understand development as economic growth, which 
puts natural values in danger. If local communities are supported, they are able to 
understand the importance of the preservation of natural values, and the above 
is a good example of how a rural local community can work together with an 
environmental organization in order to preserve natural values. 

45
Financing of NGOs
The work of the SFteam shows how hard it is to fi nd any single fi nancing scheme 
relying on Structural Funds that would be designed for NGOs and their programmes 
specifi cally. With “direct” we mean core funding for their everyday work and the 
coverage of running costs and salaries.
We mean here funds that would focus on support of NGOs in the following areas:

campaigns “pro-contra” some projects and programmes, co-funded 
by EU funds;

participation in activities, events, committees, working groups with 
regard to EU-funded programmes and projects;

organising workshops, roundtables and payments of fees for high-level 
seminars, organised by respective sectoral business or governmental 
agencies (some fees in Bulgaria go up to several hundred Euros);

quick funding for small (NGO, NGO + community, NGO + local 
authorities) projects, that are focused on easy, soft solutions of 
problems with impact on the local or regional communities and may 
be supported by EU funding;

NGOs work for other related EU regional priorities e.g., Danube 
programme, Black Sea partnership, Eastern partnership, etc.;

technical assistance for preparation of projects, etc.
Even though there are several schemes where NGOs are listed among potential 
benefi ciaries, these schemes usually do not take into account the operational and 
fi nancial characteristics of NGOs, therefore, they are often diffi cult to be accessed 
by NGOs.
Of course, such a tool must be very carefully designed and must protect both sides 
from allegations in confl icts of interest. It also should not put NGOs into dependence 
from institutions through selection criteria and selection process of the benefi ciaries.
NGOs could be benefi ciaries under some OPs or specifi c axes within OPs. But 
this makes them – as Bulgaria’s Minister of EU funds, Mr. Tomislav Donchev said 
– much more as “providers of services” and “consultants”, taking away civil groups 
from their initial mission of watchdogs and counterbalancing the institutions.

46
Some of the problems surrounding the funding of NGOs that need to be solved are:

Removing all bureaucratic obstacles in application and reporting. In 
Bulgaria, there are cases (e.g. in Rousse), when civil groups have to 
spend all the personnel fees available for the projects for the reporting 
costs!

CSOs, together with the government and various fi nancial institutions 
should set up schemes for achievable co-funding;

there should be some small grants for preparation of projects that 
involve several partners, especially ones from different countries.
A single case from Hungary gives an idea how NGOs could be supported within the 
frame of the existing OPs. Under the Hungarian Regional Operational Programme 
co-fi nancing budget lines for NGOs will be available. They will focus on:

development of civil society infrastructure;

activities or programs of environmental NGOs, in some cases in 
cooperation with municipalities.
Different ROPs offer different conditions and budgets for NGOs. The calls for 
proposals are not open yet and it is still to be seen how effective and successful this 
approach will be.
Nevertheless, this is an “early bird” case that appears as a result of concerted 
efforts of major regional NGOs facilitated by environmental NGOs, that made 
regional development agencies and Managing Authority of Regional Development 
Programmes accept the innovation.
All we expect is that projects to be implemented from these funds will contribute 
to the improvement of the quality of the environment and for a more transparent, 
effi cient use of EU funds in the interest of the public good.

Case Study (Hungary):
47
Financing of NGOs from SFs – Hungary
Between 2011 and 2013, the Regional Operational Programmes will offer EU co-
fi nanced budget lines for NGO activities in each region.
As a result of concerted efforts of major regional NGOs facilitated by environmental 
NGOs, regional development agencies and the Managing Authority of Regional 
Development Programmes supported the initiative of including budget lines for 
NGO activities in almost all Regional Operational Programmes. (The only exception 
is Central Hungary, where, due to the phasing-out status of the region different 
funding priorities and rules prevail and the call for proposal for NGO campaigns for 
“Sustainable Consumption Patterns” that were open in 2009-10 will not be opened 
again in 2011-13.) These opportunities are included in the 3-year implementation 
documents of operational programmes. The budgets and conditions differ from 
region to region. Total budget lines are between 715000 and 3 million Euros and 
the intensity of support is expected to be 90-95 %. Projects are expected not to 
be smaller than 35000 Euros approx. Measures include: development of civil 
society infrastructure and activities (North Great Plain, Northern Hungary, South 
Great Plain, Southern Transdanubia) or programs of environmental NGOs (Central 
Transdanubia, West Pannonia).
Apart from the above funds, there have also been some other calls for proposals 
within the framework of the Social Renewal OP (on networking, development of 
advocacy capacities, organizational development etc.) and the Environment and 
Energy OP (for awareness raising campaigns on sustainable consumption). These, 
however, were usually even larger projects requiring high administrative capacities. 
The new government intends to alleviate administrative burdens of project 
management; the results of this will be relevant later.
At the time of closing this report, it is not yet certain when the calls for proposals will 
be open. Still, the opportunity in itself is valuable.
Even though the measures and fundable activities differ among the above-mentioned 
Regional OP calls, projects to be implemented from these funds will contribute to 
the improvement of the quality of the environment and a more transparent, effi cient 
use of EU funds in the interest of the public.

48
Theme 5: Delegation in Committees
NGO delegation systems have over a decade long history in various state and 
regional committees and working groups. For example, such instruments were 
established in Bulgaria and Hungary in the mid-90s of the 20th century. They were 
used a long time before EU funds became an issue in CEE countries and helped to 
develop a culture of community among civil society organisations.
The systems of nominating and electing representatives (SNER) often result from 
initiations among NGOs, and are developed within the community. For example, 
in Bulgaria SNER was initiated, discussed, tested and approved during regular 
meetings of environmental NGOs that took place annually in the period between 
1998-2002. Several years ago, however, some of the NGOs which worked on the 
common problems were already discussing the need for a structured dialogue and 
participation within a growing number of formal bodies (working groups, consultative 
committees, etc.) initiated by the government. Few years after establishing BlueLink, 
the “internet arm” of Bulgarian civil society, it was approved as the bureau for the 
new online platform for nomination and election of representatives.
In a similar way, in Hungary the delegation system of environmental NGOs was 
discussed and approved at a national gathering in the mid 90s, which serves as an 
election body for representatives of NGOs since then. Through time, as the number 
of delegates grew and information fl ow accelerated, environmental NGOs realized 
that it was necessary to set up a Consultation Forum of delegates in order to be able 
to respond/react to urgent invitations to bodies and quickly changing processes. 
The framework of the Forum was introduced in 2004; its membership has been 
changing as delegates come and go. Each year, the Forum elects a fi ve-member 
presidency, the members of which hold the chair of the Forum on a rotating basis. 
The Forum meets at least four times a year and its operational background (minute-
taking, organization, etc.) is provided by a foundation elected for this task.
EU Funds and delegation
It is probably Hungary where monitoring committees have most NGO members; 
according to the government decree No. 255/2006 (XII.8), civil society 
organizations representing the horizontal aspects are involved in the Monitoring 
Committees. These are: one environmental NGO as well as the delegates of at 
least one civil society organization representing the Romany people, the people 
with disabilities and gender equality issues. As regards the latter three civil society 
groups, it is the national councils (advisory bodies to the government, including 
NGOs) who delegate representatives to monitoring committees. Therefore, the 
election system of environmental NGOs is unique.

The situation is slightly different in Bulgaria, where the election of NGOs is based on 
49
legislation, but the actual participation is decided by the respective Ministry, which 
coordinates each OP. For example, environmental NGOs are represented in the 
Monitoring Committees of OP Environment, OP Fishery and National Plan for Rural 
Areas, while other civil society groups are in MCs in some of the other OPs. Not all 
of their representatives are elected using the election platform; several are selected 
from a “short-list” of invited NGOs. Recently, NGOs from different sectors started a 
network for participation in the programming of the next fi nancial framework (2004 
– 2020) and the extended use of the platform is under discussion.
In addition, in all countries “social partners” (trade-unions and employers’ 
associations) are represented in OPs on the basis of the Regulations of EU on 
Cohesion Policy and national legislation.
A unique example came from Poland, where a Working Group for Civil Society within 
the Coordinating Committee of the NSRF is established with an aim of preparing 
proposals and recommendations for the Committee regarding the mechanisms of 
partnership in implementing NSRF.
The tasks of the WG are as follows:

formulating opinions and recommendations concerning the process 
of implementing horizontal policies ensuring consistent realization 
of the development policy – WG is concentrated on the partnership 
principle as a cross-cutting principle of the structural funds and 
European Union,

monitoring the alignment of operational programs with Polish 
Country’s Development Strategy, especially in the 4th priority 
“Creation of integrated civil community”,

monitoring the managing and control systems for different OPs,

monitoring the implementation of gender mainstreaming and 
sustainable development principles in OPs.
In Latvia the Environmental Advisory Board (EAB) is composed by representatives 
of 20 leading environmental NGOs. Representatives of NGOs are elected annually 
to the EAB, and any environmental NGO can apply for it. The Ministry of Environment 
of Latvia approached EAB at least once (2008) to nominate a representative of 
NGOs in the evaluation committee for large water infrastructure projects submitted 
for fi nancing for EU funds in the fi nancing period of 2007-2013. This body of NGOs 
is used as a platform for environmental NGOs to nominate NGO representatives to 
various bodies, i.e., monitoring committees, project evaluation committees, working 
groups, etc. In legislation related to the implementation of EU funds, such as Cabinet 

50
Regulations about implementation of specifi c activities, EAB is mentioned as the 
body to nominate representatives to monitor the implementation. 
Again, like in other countries, this initiative was started by NGOs, which came 
to the conclusion that if they wanted to be effective, they needed to fi nd a good 
tool in order to be able to infl uence matters. They started discussions with other 
stakeholders (trade-unions and employers’ associations) and at the end of the day 
a good mixture of representation of society came about. There are representatives 
of NGOs, trade-unions, businesses, academia, government and regional authorities 
in the working group. 
Conclusions, weaknesses, recommendations
The representation of civil society in various working groups and committees, 
related to the use of EU funds is one of the best developed cooperative practices. 
Despite that it was introduced as an obligatory practice by the EU, it seems that 
the understanding of the benefi ts such a practice may bring, is growing. More 
institutions and local authorities from more countries are willing to start partnership 
in practice. It took years for the institutions to recognise that the expertise of 
NGOs is not only big enough (sometime even bigger than that of the institutions 
themselves), but it could be focused on genuinely sustainable solutions for 
communities, regions or the country.
But, as both sides – institutions and NGOs in CEE countries – are at the beginning 
of the road to the sustainable use of EU funds use, there are a number of problems 
that need to be solved:

The political will for cooperation should be steady and untouched 
by the changes of government and should follow guiding principles 
set out by the EC. For example, the new government in Hungary 
(in offi ce since April 2010) replaced the decree on the operation and 
management of EU funds without proper public consultation and this 
new decree does not mention civil stakeholder groups specifi cally. 
At the same time the EC emphasizes the importance of broad public 
involvement and NGO participation; 

The presence of the representatives of NGOs in monitoring 
committees is mostly important as a source of information, since they 
have relatively little infl uence on the actual realization of programmes 
due to the low capacities and minority status among members, even 
if they have voting rights. This requires changes in decision-making to 
allow the meaningful participation of non-governmental stakeholders. 
Also, the role of MCs has to be strengthened; 


Low NGO capacity withholds them from using their rights even in 
51
situations where NGOs are allowed to participate. Often there are 
dozens of documents that need to be reviewed before each MC 
meeting or during written decision-making procedure. However, 
most of this work is done voluntarily and NGOs tend to focus only 
on issues that are likely to be problematic, thus probably missing out 
other important aspects of the implementation of EU funds. Low NGO 
capacity prevents meaningful participation. 

The community of NGOs should also make continuous efforts to 
improve their system of representation in EU funds management, 
self-control, even in the case of the absence of confl icts of interest. 
They also should organise themselves in a way to use the resources 
and knowledge they offer to the other stakeholders effectively.
But probably the biggest threat for NGOs is to turn them into providers of services 
and consultancy, thus diminishing their natural mission as watchdogs and protectors 
of public interest. This threat may be reduced by clear and just rules about access 
to resources for NGOs and separating EU funding for civil society from political and 
other pressure over them in case they may run unfavourable campaigns against 
some decisions of the government.
Defi nitely, the upcoming programming for 2014 – 2020 is a challenge that could 
provide answers to some of the questions. Both sides must use it for improving their 
efforts for a better utilization of EU funds in our countries.

52
Case Study (Hungary):
Delegation Processes - A 15-year-old 
Electoral System of Environmental and 
Nature Conservation NGOs in Hungary
The legitimate electoral system of NGOs working in the fi eld of environmental 
protection and nature conservation has a history of 15 years. It is based on the 
National Gathering, organized each year by a different organization since 1990. 
At the National Gathering, all registered green organizations have voting rights. 
Nominating candidates is an open process, while election is made by secret ballot. At 
present, this forum of organizations elects a delegate for about 50 bodies, including 
all the monitoring committees of EU funds. Its delegations are acknowledged by the 
government.
The National Gathering served as a forum for professional exchange initially; 
however, from 1996, it also took on the function of an electoral body because 
environmental NGOs fi rst got opportunities then to delegate representatives to 
various – advisory, grant-making, professional decision-making – bodies. This 
made it necessary to create internal Rules of Operation which includes regulations 
on the election process. Delegates are basically elected for two years; however, this 
is not a problem for monitoring committees, where the low turnover of delegates is 
preferred, because the NGO community usually grants trust to the delegate for the 
whole EU budgetary period. Delegates are also obliged to inform the environmental 
NGO community about their work through a general mailing list regularly. If they 
don’t perform, they can be recalled – however, this has not yet been the case so far.
With the progress of time, as the number of delegates grew and information fl ow 
accelerated, environmental NGOs realized it was necessary to set up a Consultation 
Forum for delegates in order to be able to respond / react to urgent invitations 
to bodies and quickly changing processes. The framework of the Forum was 
introduced in 2004; its membership has been changing as delegates come and go. 
Each year, the Forum elects its fi ve-member presidency, the members of which hold 
the chair of the Forum on a rotating basis. The Forum meets at least four times a 
year and its operational background (minute-taking, organizing etc.) is provided by 
a foundation elected for this task.

It is probably Hungary where monitoring committees have most NGO members; 
53
according to the government decree No. 255/2006 (XII.8), civil society organizations 
representing the horizontal aspects are involved in the Monitoring Committees. 
These are: one environmental NGO as well as the delegates of at least one civil 
society organization representing the Romany people, the people with disabilities 
and gender equality issues. As regards the latter three civil society groups, it is 
the national councils (advisory bodies to the government, including NGOs) who 
delegate representatives to monitoring committees. Therefore, the election system 
of environmental NGOs is unique.
This methodology is not necessarily fi t for each branch of civil society, but it is 
probably worth considering it. An NGO platform promoting the transparency of 
national programming also welcomed the description of these processes and 
spread it to the wider NGO community. The 15-year existence of the system proves 
its resilience and quick responsiveness. The internal rules of cooperation have been 
developed along natural internal needs and they observe democracy and equity in 
networking.
However, even the relatively high number of civil society representatives in monitoring 
committees raises several questions. 1) The new government (in offi ce since April 
2010) replaced the decree on the operation and management of EU funds without 
proper public consultation and this new decree does not mention the above four 
civil stakeholder groups specifi cally. However, thus far, these groups still have their 
seats, even if delegates have changed. 2) The presence of NGO representatives 
in monitoring committees is mostly important as a source of information but they 
have relatively little infl uence on the actual realization of programmes due to low 
capacities and minority status among members, despite their voting rights. 

54
Case Study (Bulgaria):
Participation of NGOs in OPs Monitor-
ing Committees: Broadening the System 
for NGOs Representation
Bulgarian environmental NGOs have more than 12 years of experience in selecting 
their representatives for various working groups, steering committees and inter-
institutional bodies. Though during the pre-accession funding period (2000 – 2006) 
in Bulgaria, representatives in Monitoring Committees for SAPARD and ISPA were 
not elected, but selected by the respective institutions, right after 2007 (the fi rst 
Structural funds period for Bulgaria), the use of the self-developed election system 
for NGOs went in use for the MCs. The use of the system is likely to be extended 
nowadays and more civil society groups are to benefi t from it.
The system for nomination and election of NGOs in various committees and working 
groups, organised by the governmental institutions, was created at the end of 90s 
of the 20th century. (1998 – 1999). It was discussed and agreed upon at a series 
of meetings of all environmental NGOs, thus became one of the fi rst of its kind for 
NGOs in CEE countries. The system has gone through improvements throughout 
the years. The secretariat was moved to BlueLink Foundation and the system 
became an online platform, open for any NGO which registers as participant.
Already in 2005, environmental NGOs started to use the system for election of 
their representatives for some of the working groups for operational programmes. 
Afterwards it was used for the election of representatives in some Monitoring 
committees of OPs (OP Environment, OP Transport, etc.). A discussion started in 
2010 among broader NGO community in Bulgaria (environmental, social, health, 
regional development, human rights, etc. NGOs) to use the system for the election 
of joint representatives for the programming process for 2014 – 2020 EU funds. 
A special project proposal was submitted for fi nancing that would help with the 
broadening and improvement of the system.
NGOs used the system for the fi rst time at the beginning of 2011 to exchange their 
representative (for the Monitoring Committee of OP Transport) due to the fact that 
the task was not fulfi lled appropriately.

There is a development in the institutional coverage of the use of the system. In 
55
the beginning only the Ministry for Environment and Water agreed to use it, while 
others used their own selection criteria. Now several other ministries are willing 
to use this approach, including the Ministry for Regional Development and Public 
Works, the Ministry of Agriculture and Forestry, etc. The other main goal of the 
NGO community is to spread the system on a regional level in order to guarantee 
meaningful participation in regional development policies, which are the core of 
cohesion policy.
There are good examples how the representatives of environmental NGOs in 
MCs in various OPs are working towards promoting the viewpoints of NGOs at the 
debates. The representatives in the OP Environment and OP Fishery in particular 
are very active in their work. They are providing NGOs with information about 
upcoming events (meetings of MCs, etc.), and documents and information about 
important decisions. They also request support, information and feedback from the 
community as well as direct actions (e.g. letters to the managing bodies).
Conclusions and Recommendations
The system for the nomination and election of NGOs representatives has been 
created as a unique but simple tool for the representation of NGOs in virtually all 
forms of partnership between civil society and public constructs. The decade of its 
use in Bulgaria shows that it is very useful also in cases where strong partnership 
is needed, such as regional policies and the use of EU funds.
Although the system for delegation of the representatives of NGOs is well defi ned, 
there are shortages that could be improved in order to make the work of NGO 
representatives in various committees more useful and effective.
Firstly, there is a need to improve the system itself. There are elements missing 
that civil society should defi ne and add to the system in order to guarantee that 
elected representatives could work effectively and in line with their mission and 
goals. It essentially needs:

to defi ne the way the representatives will report to the community;

to defi ne how the community would support its representatives in 
their work;

to defi ne the procedures for recalling the representative, who does 
not fulfi l continuously his/her tasks.

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Secondly, there is a need to broaden the use of the self-election system in both 
ways – by NGOs and by institutions. There are several best practices, but in fact 
it is civil society that should work to promote and purposely use the delegation 
system in order to “teach” the institutions its broader application. It is in particular 
important to promote the system.
Thirdly, NGOs should negotiate changes with the Government on the statute of 
their representatives. By now, most of the representatives in the MCs have only 
consultative rights (no voting rights), unlike the offi cial “social partners”, thus they 
are deprived of even the minimal power to infl uence decisions. Another associated 
problem is the so called “confi dentiality clause”. This problem should be solved 
also on a higher governmental level by negotiations and campaigning.

Case Study (Poland):
57
Working Group for Civil Society within 
the Coordinating Committee of the 
NSRF in Poland – Ensuring Eff ective 
Participation of NGOs and Socio-
economic Partners in the Committee 
Responsible for the Overall Coordina-
tion of EU Funds in the Country

The Working Group for Civil Society was formed within the structure of the 
Coordinating Committee (CC) for National Strategic Reference Framework 2007-
2013. The initiative has been taken on a national level. The Working Group 
concentrates its activity on the 1st horizontal strategic aim of the NSRF: “Improving 
the functioning standard of public institutions and development of partnership 
mechanism”.
The Working Group was established for preparing proposals and recommendations 
for the Committee regarding the mechanisms of partnership in implementing NSRF. 
It includes consultations and monitoring of the implementation of the sustainable 
development principle, as well as gender mainstreaming in Operational Programs 
(OP’s). Recommendations of the Group are provided to the Committee as draft 
resolutions and opinions.
The tasks of the WG are as follows:

formulating opinions and recommendations concerning the process 
of implementing horizontal policies ensuring consistent realization 
of the development policy – WG is a concentration of partnership 
as a cross-cutting principle of the structural funds and the European 
Union,

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monitoring the alignment of operational programs with Poland’s 
Development Strategy, especially in Priority 4: “Creation of an 
integrated civil community”,

monitoring the managing and control systems for different OPs,

monitoring the implementation of gender mainstreaming and 
sustainable development principles in OPs.
The WG was established by the Coordinating Committee on 14th April, 2008, 
as an initiative of representatives of all 5 non-governmental organizations – the 
members of CC. They came to the conclusion that if they wanted to be effective 
in the CC, they needed to fi nd a good tool in order to be able to infl uence matters. 
Participating in plenary sessions twice a year did not guarantee an active and 
effective representation of the civil sector.
NGOs started cooperation with representatives of other social partners in the CC. 
There are seven such organizations in Poland: four unions of employers and three 
unions of employees. They supported the idea of the WG and were interested in 
taking part in it. Subsequently, representatives of NGOs asked a few selected 
representatives of governmental and regional authorities for their support and 
participation in the Group. Everybody gave a positive answer. All of the socio-
economic partners, which were members of the Coordinating Committee, became 
part of the Group. Representatives of ministries and regional authorities joined the 
group as well. Overall, the Working Group comprises:

non-governmental organizations - Caritas Poland, Foundation in 
Support of Local Democracy, Foundation in Support of Business 
and Science, Polish National Federation of NGOs, Polish Scouting 
Association,

social partners (employees’ and employers’ unions) - Forum of Trade 
Unions, Independent Self-governing Trade Union “Solidarity”, The All 
Poland Alliance of Trade Unions, Business Centre Club, Employers of 
Poland, Polish Confederation of Private Employers Lewiatan, Polish 
Craft Association,

academic organizations - Central Council for Research and 
Development Units, Council for Higher Education, Polish Science 
Academy, The Conference of Rectors of Polish Academic Institutions,

governmental administration – Ministry for Regional Development (as 
Managing Authority for Human Capital OP and Coordinating Authority 
for NSRF), Ministry of Labour and Social Policy, Ministry of National 
Education,

regional authorities – Pomorskie, Opolskie, Lubuskie and 
Wielokopolskie Voivodships (regions) and the Common Committee 
for Regional and Local Government.

Twenty-fi ve institutions and organizations cooperate in the WG. Observers and 
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experts participate in sessions as well. They have the role of observers. Obviously, 
not every member of the Group has a similar level of involvement.
It was six months after establishing the Working Group for Civil Society, when 
the Committee actually accepted its fi rst recommendation. WG is fi nanced by the 
Technical Assistance OP. This fi nancing includes costs of the organization of the 
sessions, secretarial offi ce of the WG, reimbursement of travel costs for members 
from outside Warsaw and expert support if necessary.
The Working Group has been functioning for 2,5 years now. It is a stable solution, 
so its work will fi nish only with the end of the programming period 2007-2013. An 
internal set of rules was accepted during the fi rst session, where the election of the 
Chairman and Vice-chairman also took place. WG makes decisions by consensus. 
Its sessions take place according to need, but not less frequently than once every 
three months. The Group is managed by the Polish National Federation of NGOs 
as it was a leader in the process of establishing the Group. The Vice-chairman is 
the Director of the Department of Managing European Social Funds in the Ministry 
for Regional Development.
Results of the functioning of the WG are as follows:

closer cooperation between representatives of the different socio-
economic partners in the Coordinating Committee,

adoption of a resolution by the CC about the importance of civic 
consultations and civil dialogue in the implementation  of OP’s (2008),

organization of a 2-day session for members of MC’s from all over 
Poland, the  representatives of socio-economic partners (2009) – 
10% of the representatives participated in the session, preparing sets 
of recommendations in four fi elds: civil society, evaluation, project 
selection criteria, equal opportunities,

establishment of the National Thematic Network for the Partnership 
(2010),

two meetings of the Network: state conference and a 2-day regional 
session (2010),

a common proposal by the socio-economic partners in reply to the 
mid-term consultation initiated by the European Commission

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The Working Group functions dynamically and effectively. Members of the Group 
carry out their tasks voluntarily. In spite of limited capacities the results are visible. 
Factors contributing to the success of the Group are: 

cooperation with socio-economic partners and search for common 
aims,

expert and fi nancial involvement of the Ministry for Regional 
Development, the crucial institution in the fi eld of structural funds and 
planning and the implementation of the Cohesion Policy in Poland,

expertise and competences of the members of WG,

openness for nonstandard prepositions,

thinking about the common interest and moving beyond narrowly 
understood interests of their own environments by all members of 
the Group.
Unavoidably, the Working Group is facing challenges. Most important of there are:

the development and effective use of the National Thematic Network 
for Partnership,

securing the involvement of the Cohesion Policy in civil dialogue 
in the current programming period (being active in the process of 
the midterm review) as well as the next one (participation in the 
consultation of the Fifth Cohesion Report).
To summarize, the efforts put into the creation of the Working Group for Civil Society 
were worthwhile. The Group became a place for discussion and cooperation of 
representatives of very different circles and interests. In Poland, MCs, the Working 
Group and other similar working groups related to Monitoring Committees are the 
only institutions/bodies that can exert real infl uence on the decisions concerning 
public policies of the representatives of the Polish government, regional 
authorities as well as social and civil organizations and academics. Even if not all 
recommendations are taken on board, the Working Group is still a good example of 
effective cooperation.

Theme 6: Participation of NGOs in 
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Project Evaluation
It is a pleasant surprise for us to see interesting positive cases that uncover various 
aspects of cooperation between NGOs and institutions regarding the evaluation of 
projects. It seems that authorities (regardless of being central or local, specialised 
or general ones) throughout CEE become more open to the involvement of NGOs 
in such evaluation. At the same time, it is not an irreversible process; changes in 
governmental leadership may change the attitude towards NGOs due to unexpected 
and sometime far not better proposals.
The cases show that initiative for involvement of NGOs comes from both sides. 
In the case of Poland, it came due to interventions from NGOs that evolved in 
the creation of the special position of Environmental Manager. In other cases, the 
initiative comes from offi cials and is materialized in legislation or contracting, upon 
direct or random selection.
The most successful is the case from Poland, where the initiative of NGOs led to the 
establishment of a new system for evaluation of projects submitted to the Regional 
Operational Programme (ROP). Though it was established by the Marshal’s offi ce 
of the Dolnośląskie Voivodship, the initial case came from NGOs, which tried to 
prevent a river from a controversial project, envisaged to be funded by ROP. The 
cooperation among all parties involved – the conservation authority (RDE), the 
investor (Regional Water Management Authority), funding institution (Marshal’s 
Offi ce, Dept. of ROP), civic organization (FER) and individual experts, as well as 
the contractor for the works (Skanska) – was well managed. The decisions were 
consulted broadly and all parties searched for a solution to the situation. 
The success of this fi rst case led to a boom of cases assessed under the 
Environmental Manager scheme: some 700 – 800 applications were surveyed by 
the end of 2010.
In general, the system of Environmental Manager is a positive result at the meeting-
point of several factors. Citizen involvement was very important in indicating the 
particular and systematic problems. Positive approach and maturity of the NGOs 
and the regional administrations led to the structural constructive change which 
helped to avoid wasting public money on environmentally destructive projects, and 
prevented a lot of confl icts, which would have caused further direct and indirect 
economic and social costs.

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The participation of a representative of Latvian environmental NGOs in the project 
evaluation committee for large water infrastructure projects submitted for fi nancing 
from EU funds in the fi nancing period of 2007-2013 seems to be like representation in 
any other steering or monitoring body. But in this particular case, the representative 
of NGOs shares the same rights as all other members who represent the Ministry 
of Environment and the Union of Municipalities. This also carries equal obligations 
and even an interesting drawback we didn’t see in any other countries: the NGOs 
representative was obliged to obtain the status of a state offi cial.
Hungary presents us a case where a relatively good system of involvement of 
NGOs (in this case the National Society of Conservationists, NSC) was removed 
and replaced by “a rigid, though much more objective, system (...) which, however, 
is, as experience shows, for various reasons, unable to consider the real overall 
impacts of projects”.
NSC was contracted to help with the assessment of the submitted Regional 
Development Operational Programme (RDOP) project proposals regarding 
environmental sustainability as a sort of quality control. With the help of an expert 
team, they managed to assess about 1000 proposals per year only. About 10 
percent of the projects were proposed to be rejected, 20 percent to be amended. 
Some projects were rejected due to fi nancial reasons. The majority of the rest 
was supported by the Committee, but strict environmental conditions were set for 
contraction.
The benefi ts of the system are strongly linked to the outcome. As long as the 
Managing Authority kept sending back proposals with low level of environmental 
quality, the regional agencies and project owners themselves started to understand 
how important it was to consider “environmental sustainability” in their proposals. 
Although the new system introduced for the period between 2007 – 2013 is more 
objective and unifi ed for all OPs, experience shows that for various reasons, it 
is unable to consider the real overall impacts of projects. Even worse, instead of 
promoting an increased understanding of horizontal issues among project owners, 
it is counterproductive due to high administrative burdens. Later, unfortunately, 
the new government abolished the mandatory involvement of NGOs in project 
evaluation teams by a change in legislation.
The Slovak case represents the usual situation, when the participation of NGOs is 
restricted  to participation in Monitoring Committees. Despite this, according to our  

remains a relatively closed system, there are promising signs and initiatives in the 
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ESF that indicate change in the level and art of NGO participation in control and 
monitoring processes.”
There happens to be a change in the management of the OP Employment and 
Social Inclusion, so  important changes are likely to happen  in the fi eld of NGO 
participation also. From September 2010 on, NGOs have been involved more 
intensively in singular control processes of ESF fi nanced programmes under the 
control of the Ministry of Employment, Social and Family Affairs (MESFA).
There are a number of lessons to be learnt from these cases, as well as a few 
recommendations for stakeholders.

The information fl 
ow between environmental specialists and 
decision makers need to be improved. Blaming NGOs for their poor 
understanding of the specialist language and information among 
decision makers does not solve the problem. There is a clear need 
for structural changes.

One has to acknowledge that it is also in the interest of the investors 
and decision makers to investigate the environmental impacts of 
proposed projects on NATURA 2000 areas and on habitats and 
species protected by the European Directives in order to avoid 
confl icts with legislation.

Participation in project evaluation processes brings better 
understanding of how project evaluation works in practice, including 
on how well project evaluation criteria are formulated, how horizontal 
criteria are applied and to what extent they serve the purpose etc.

The involvement of NGO experts in project evaluation ensures 
impartiality and enhances professionalism and is therefore 
unavoidable, along clear and transparent guidelines. Also, for 
professional reasons, the evaluation of horizontal criteria (ie., 
environment, sustainability, equal opportunities) should take an 
integrative approach, with a focus on the performance of projects, 
instead of that of the project owner. 

The work of NGO representatives in project evaluation committees 
is often done on a completely voluntary basis. NGOs often lack 
capacity to participate in these kinds of activities, thus not all 
valuable knowledge and skills are utilized in this work. Sometimes 
environmental NGOs even refused to participate in the work of 
project evaluation committees due to the lack of capacity. Therefore, 
a special system for covering the costs (both human and direct) of 
such participation is needed. 

64

NGO representatives are not allowed to share information about 
project applications, thus, mostly they have to rely on their own 
knowledge and expertise. This situation seriously burdens the 
effi ciency of NGO participation. 

To create commonly acceptable solutions for NGO participation, 
systematic work on the institutional and organizational structure of the 
cooperation needs to be carried out both by authorities and NGOs. 

Case Study (Poland):
65
The Environmental Manager Prevents 
Harm and Confl ict
The Marshal’s Offi ce of the Dolnośląskie Voivodship (provincial government) 
implemented procedures that are quite unique in Poland. The main idea behind 
it was to prevent possible confl icts around particular investments supported by 
European Funding via the Regional Operational Programme at as early a stage as 
possible.
The process has many different roots in the Dolnośląskie Voivodship. One of 
the important events that led to this structural solution was an intervention by 
the representative of NGOs in the Steering Committee, concerning plans for the 
regulation of three small rivers. This was a case when problems could not be 
prevented and caused a lot of work and costs and cost a lot of time both on the part 
of the investor and the funding institution. 
The new structures of the ROPs replaced the Steering Committee with the 
Monitoring Committee. The Dolnośląskie Voivodship was the only one in Poland 
where the NGOs were represented in the Committee. This caused an intervention 
in The European Commission, which questioned the remaining voivodships about 
the NGO representative and in consequence, the other regions adapted the same 
structure for their committees. 
Meanwhile, the Marshal of the Dolnośląskie Voivodship proposed a systematic 
solution to the environmental aspects of the project application survey. The 
proposed solution was inspired by the British model and implemented the position of 
Environmental Manager. The Environmental Manager is responsible for consulting 
applications to the ROP with regional authorities responsible for the  environment 
and with NGOs. Formal procedure was designed to implement these consultations 
in a timely and structured manner. 
The procedure predicts action depending on the response from the consulted 
partners. The process takes 22, 24 or 34 days, depending on the number of concerns 
raised. When both consulting parties have concerns, and the Environmental 
Manager has doubts about their interpretation or when the consulting parties 
have different opinions and cannot agree in their statements, the Environmental 
Managers calls for external expertise. 

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The NGO representative in the Monitoring Committee cooperates with NGO-related 
experts from different environmental fi elds. They all receive the applications and 
share the responsibility to provide their opinions.  
Until the end of 2010, about 700-800 applications were surveyed. There were 
objections to a certain proportion of it, which were reported back to the applicants, 
who then adjusted their applications in the appropriate way. The application 
procedures assume possibility for a formal complaint. However, until now, there 
no such action was needed. All the confl icts were resolved at an early stage of the 
process. 
In many cases, experts feel the need for a fi eld visit or screening the existing 
documentation, such as EIA (Polish OOŚ) or Specifi cation of the Important Building 
Conditionings (Polish: SIWZ). With the large number of projects, there is still a 
possibility to let through a project by accident that does not fulfi l the environmental 
requirements, which would lead to a confl ict in the implementation phase. However, 
many potential damages have been avoided by redesigning of or resigning from the 
proposed actions. 
The case of the Włodzica river is an example where the threat of environmental 
damage was initially overlooked. Thanks to the active NGOs and a project of 
Natura2000 Watch, the project was terminated and redesigned. 
The Regional Water Management Authority in Wrocław planned the regulation of 
the Włodzica river in the town of Nowa Ruda, to prevent erosion and reduce the 
risk of fl ooding, as well as improving migration conditions for fi sh. Application WND-
RPDS.04.04.00-02-002/09 for about 19 million PLN (about 80% of the cost) was 
submitted to the Regional Operational Programme for the Dolnośląskie Voivodship 
2007-2013, under Priority 4, for the improvement of the natural environment and 
improvement of the ecological and fl ood safety in Lower Silesia  (“Environment 
and Ecological Safety”). The project was endorsed in June 2009, and approved by 
the public hearing held with the presence of environmental NGO representatives. 
However, when the work started, a local branch of the NGO „Workshop for all beings” 
reported potential damage to Natura 2000 habitats (Habitat Directive codes: 91E0-
5, 8220-3 and 6430). WWF Poland appealed to the Director of the Regional Water 
Management Authority for suspension of the works until clarifi cation of the issue. In 
July 2009, the Lower Silesian Foundation for Ecodevelopment, in accordance with 
the Parliamentary Bill of 13 April 2007 on the Prevention of Environmental Damage 
and Harm Repair, sent a notifying letter to the Regional Director for Environment 
(RDE) in Wrocław about the threat of environmental damage and petitioned for 

urgent intervention preventing the start of the planned work. In September, The 
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RDE arranged fi eld visit with experts and main stakeholders, which confi rmed the 
occurrence of natural habitats in the river bed and on the slopes. RDE put the 
investment on hold until agreement was reached on the preventive measures, 
methods to minimise negative impact and on post-investment monitoring. ROP 
Department of the Marshal’s Offi ce for Dolnośląskie Voivodship convened a 
clarifi cation meeting with interested parties. The appropriate solution was found and 
the works were carried out according to the modifi ed plan. 
The parties involved included the mayor of Nowa Ruda, the County Governor 
(Starosta) in Kłodzko, the Public Sanitary Inspector, the contractor for the works – 
Skanska corporation, the Local Authority Appeal Board in Wałbrzych - competent 
to cancel decisions taken at County and Town levels. The decision-making and 
consultation processes were organized properly, and in accordance with the 
procedures for planning of investments and the distribution of funding. However, 
the decision taken happened to be wrong. How was it possible? 
First, the decision of the County Governor and Public Sanitary Inspector were 
based on inadequate, and, in addition, misinterpreted information. The nature 
inventory of the town of Nowa Ruda was produced at a generalized level – as any 
such research – on which it was impossible to base individual decisions about the 
location of investments. Using these types of documents with such low level of detail 
for planning purposes is not justifi ed. The expertise commissioned for the purpose 
of the investment were: inventory of trees for the logging permit, ornithologists 
designation of trees not to be removed before the end of the breeding season, and 
an opinion from the angling association. These opinions, however well made, do not 
cover all circumstances. 
Based on the available documents, and lacking an EIA or at least a Report on the 
effect of the works on nature, the investor presented the case at the public hearing 
as having no harmful effect on nature, as being planned in the highly urbanised 
area, without any habitats of substantial importance. In spite of the fact that high 
quality experts of Natura 2000 were present at the hearing, they did not see the 
reason for objection and the project was approved. The start of the work was, 
by coincidence spotted by an environmentalist from the Workshop for all beings, 
who intervened notifying the Local Authority Appeal Board in Wałbrzych and the 
Foundation for EcoDevelopment (FER) running the Natura 2000 Wardens project. 
The intervention to the RDE in Wrocław on the basis of the Bill on prevention of 
environmental damage and harm repair caused a series of events, starting with the 
immediate suspension of the work.

68
At this stage, the involved parties were: the conservation authority (RDE), the 
investor (Regional Water Management Authority), the funding institution (Marshal’s 
Offi ce, Dept. of ROP), civic organization (FER) and individual experts, as well as 
the contractor for the works (Skanska). The cooperation was good within the group, 
with decisions consulted broadly and seeking for solutions to the situation. The 
RDE commissioned an expert and stimulated advice on how to redesign the project 
and implement compensatory measures. ROP Dept. called a forum to discuss the 
proposed solutions and come to an agreement. Finally, the new project was been 
approved and the work implemented successfully. It was required by the RDE that 
the effectiveness of the preventive measures be monitored in the 4-year post-
investment period by checking the habitat status over the Summer months.
The intervention by NGOs, supported by the Marshal’s Offi ce Dept. for ROP and the 
RDE in Wrocław helped to avoid damage to the natural environment. However, this 
case is an example showing some defi ciencies in existing systems and procedures.
The main issue seems to be a matter of using the available information. The 
information  fl ow between environmental specialists and decision makers calls 
for improvement. Blaming the poor understanding of the specialist language 
and information among decision makers does not solve the problem. Structural 
change is needed. One of the solutions may be taking the decision on whether 
to apply the Environmental Impact Assessment or the Decision on Environmental 
Conditionings away from the bodies, which do not necessarily have the required 
high profi le knowledge and skills. Or at least making the advice on this question 
by the appropriate specialists or institutions (preferably RDE) obligatory, and not 
an option “when in doubt”. In the case described here even the specialists fell into 
the same trap as local decision makers. The scientifi c inventory conclued that the 
habitats were in unfavourable condition. This was interpreted as a green light for 
investment, instead of realising the need for efforts to recover the habitats.  
Another improvement may be made in the role and standards of nature inventories. 
It is worth considering replacing or rather expanding the traditional approach of a 
once-upon-a-time inventory by a continuous data collection system. Such system 
should be based on a public database, preferably using the GIS technology, updated 
regularly, and at different levels of detail. The decentralized data centre should have 
a mechanism for the verifi cation of data, and an institutional base at conservation 
authorities, with the involvement of scientifi c institutions and voluntary providers of 
data. 

As for the aspect of decision makers, the legislation on Natura 2000 forbids to 
69
depreciate the status of species and habitats of EU importance. When the decision 
is wrong, and taken without proper assessment, there is no excuse and no legal 
way to avoid the responsibility of investor for the damage. So it is in the interest 
of both the investors and local decision makers to investigate the environmental 
consequences on Natura 2000 areas, and even outside these sites on habitats and 
species protected by European Directives. 
Finally, the system described here is the positive result at the meeting point of 
several factors. Citizen involvement was very important to indicate particular and 
systematic problems. Positive approach and maturity of the NGOs and regional 
administrations led to a structural constructive change, which helped to avoid the 
wasting of public money for environmentally destructive projects, and prevented a 
lot of confl icts, which would have caused further direct and indirect economic and 
social costs. 

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Case Study (Hungary):
Sustainability Assessment of Regional 
Development Projects
Between 2004 and 2006, the Managing Authority (MA) of the Regional Development 
Operational Programme commissioned the National Society of Conservationists 
(NSC) to cooperate in the assessment of the submitted RDOP project proposals 
regarding environmental sustainability. 
That time, project proposals were assessed and scored at regional levels; the 
Managing Authority, however, also assessed them against several criteria such as 
environment, equal opportunities, and fi nancial questions as a sort of quality control, 
by involving external experts or organizations, NSC for environmental criteria in 
specifi c. NSC commissioned several local experts to cooperate, so that people 
with adequate knowledge of the region in question could assess each project. The 
expert team has the opportunity to propose whether the project proposal should be 
accepted, rejected or sent back to the project owner for amendment. Based on the 
opinion of experts and regional development agencies, the Decision Preparation 
Committee made a fi nal suggestion for or against funding.
Within a year, NSC experts assessed about 1000 project proposals. About 10 
percent of the projects were proposed to be rejected, 20 percent to be amended. 
Some projects were rejected due to fi nancial reasons. The majority of the rest 
was supported by the Committee, but strict environmental conditions were set 
for contraction. Some of the project proposals were not adequate enough from 
an environmental perspective and were therefore rejected. In many cases, this 
happened because of the determined stance of the representative of the Ministry 
of Environment and Water. This gives a strong example of successful cooperation 
among NGOs and government offi ces.
The benefi ts of the above system are strongly linked to the outcome. The main 
advantage of the re-assessment and quality assurance system of project proposals 
was that as the Managing Authority regularly sent back project proposals with low 
environmental performance for amendment, regional agencies and project owners 
themselves also started to understand the importance of considering “environmental 
sustainability” more deeply and try to present it in the proposal; as it was revealed 
by the quality of the proposals. This was due to the fact that even the project guide  

on “environmental sustainability” tried to take an integrative approach. However, 
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critiques of the system considered it too costly and time-consuming to be applied 
to all projects of all OPs. Even though several offi cials and the NGO experts found 
the system benefi cial and proposed it for all operational programmes of the 2007 – 
2013 period, it was discontinued.
Instead, a rigid, though much more objective system applicable to all OPs was 
introduced to track the performance of projects on “environmental sustainability” and 
equal opportunities, which, however, is, as experience shows, for various reasons, 
unable to consider the real overall impacts of projects. (Even worse, instead of 
promoting an increased understanding of horizontal issues among project owners, it 
is counterproductive due to high administrative burdens.) Some level of involvement 
of NGO experts in decision-preparation was still ensured between 2007 and 2010. 
NGO experts, among others, had the opportunity to apply along strict criteria, for 
membership in a pool of experts. Members of each project evaluation committee 
were selected from this pool by drawing lots. (It is also a major step forward that 
the government published a searchable database of EU-funded projects, with basic 
information about each project, including the list of names of the members of the 
project evaluation committee.) However, the ruling government (in offi ce since April 
2010) changed the rules of procedures and abolished the mandatory involvement 
of NGO experts in project evaluation (i.e., decision preparation) teams, by the 
government decree 4/2011. (I. 28.).
An ideal solution would probably combine the two practices described above. The 
involvement of NGO experts is unavoidable, along clear, transparent guidelines in 
order to ensure impartiality and professionalism. Also, for professional reasons, the 
evaluation of horizontal criteria (i.e., environment, sustainability, equal opportunities) 
should take an integrative approach, with a focus on the performance of the projects 
instead of that of the project owner. 

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Case Study (Latvia):
Participation of Latvian NGOs in 
Project Evaluation
Representatives of environmental NGOs in Latvia are involved in the work of several 
project evaluation committees. One of them is the project evaluation committee 
for large water infrastructure projects submitted for fi nancing from EU funds in the 
fi nancing period of 2007 – 2013. For fi nancing in that activity, the so called “limited 
competition” rule was applied, i.e., only those municipalities that were shortlisted by 
the Ministry of Environment based on environmental criteria were entitled to apply 
for funding. NGO participation in this situation is liable to increase transparency of 
decision making. 
Description of Activity 
The aim of the activity “Development of water management infrastructure in 
agglomerations with more than 2000 residents” (activity No. 3.5.1.1. under national 
framework documents) is to improve the quality of water management and waste-
water treatment, as well as improve accessibility of water management services to 
inhabitants in certain inhabited areas. This activity was designed to allow towns and 
municipalities to meet EU requirements in the area of water management and waste-
water treatment. The total amount available for public fi nancing in the programming 
period 2007-2013 is 477,7 million EUR – most of which constitutes fi nancing from 
the Cohesion fund. The implementation of this activity is guided by the Cabinet 
Regulation, which describes general terms and conditions, the application process, 
project evaluation and the monitoring of the implementation, etc. As mentioned 
above, the Ministry of Environment prepared a list of municipalities that were 
entitled for this fi nancing – the list of municipalities was included in the annex of the 
Cabinet Regulation. The criteria for listing municipalities were based on the present 
quality of drinking water and waste-water treatment against the targets laid out by 
EU directives in the fi eld of water management. When the calls for applications were 
opened, the Ministry of Environment sent out letters to municipalities inviting them 
to apply for fi nancing. 
Project Proposal Evaluation Committee 
All project applications are evaluated using administrative and quality criteria by 
the project evaluation committee. Cabinet regulation on implementation of this 
activity prescribes that the project evaluation committee is created by the Ministry 

of Environment. This regulation further stipulates that the committee is composed 
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of representatives from the Ministry of Environment, the Union of Municipalities 
and environmental NGOs. The number of committee members is not pre-defi ned 
by the Cabinet Regulation and it may vary, but usually they have 6-8 members, 
out of which one is a representative of environmental NGOs. All members of the 
evaluation committee have the same rights. Thus, the NGO representative is 
equally taking part in the decision making process along with the representatives of 
other institutions.
In the evaluation process itself all members of the committee have access to all 
project documentation. Prior to the beginning of the evaluation process, each 
committee member is obliged to sign a declaration stating that he or she has no 
confl ict of interests and he or she will not disclose any information about project 
applications or applicants to third parties.
Each representative is asked to allocate the necessary time and review all project 
applications with a supporting document and then fi ll out a project evaluation form 
(an electronic fi le), where they can provide comments and assign scores where 
necessary.  It is mandatory for an application to comply with all administrative 
criteria, but as for the quality criteria, each application gets a certain score. During 
meetings committee members discuss contents of project applications, including all 
questions that are unclear and any other related issues. The committee can also 
ask the applicant to submit additional documents or explanations. All communication 
with the applicant is done in writing. The decisions of the committee are a basis for 
approval of project applications. All decisions are included in the offi cial  minutes 
of the committee meetings. The Committee seeks to make all its decisions by 
consensus.
Project applications include complicated fi nancial forms and might also involve 
some unclear legal issues, e.g., the ownership of water management infrastructure, 
licensing etc. The evaluation committee doesn’t always have the necessary 
knowledge, therefore, there are fi nancial and legal experts also involved in the 
evaluation process. The members of the project evaluation committee have access 
to experts’ analyses. 
Selection Process of NGO Representative to the Committee 
The Cabinet Regulation doesn’t specify how the representative of environmental 
NGOs is to be chosen – there is no mention of specifi c institutions or selection 
process. The Ministry of Environment approached the Environment Advisory Board

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(EAB) to nominate a NGO representative to the evaluation committee. The EAB 
is composed of representatives of 20 leading environmental NGOs, its meetings 
are open to anybody interested in environmental policy issues and therefore, it is 
de facto perceived as a platform of leading environmental NGOs in Latvia. NGO 
representatives are elected annually to the EAB and any environmental NGO 
can apply for it. Thus, the EAB is seen as a trusted and transparently functioning 
institution to nominate a representative to the project evaluation committee. 
The NGO representative was nominated by the EAB to work in the project 
evaluation committee in July, 2008. Basically, environmental NGOs could choose 
a representative whom they believed would represent environmental and public 
interest the best. The NGO representative is asked from time to time to report 
back about his or her work in the committee. The project evaluation committee 
will act as long as the particular activity of water management projects is under 
implementation. There were already several rounds of application – in 2008 and 
2010. The evaluation of project applications from last round is still continuing in the 
beginning of 2011. 
The drawback of the participation process seen by NGOs is that respective NGO 
representative who gets involved in the project evaluation committee, needs to 
become a civil servant. This status involves an obligation to submit an annual 
declaration of civil servants, declaring all positions, income, liabilities, properties, etc. 
This precondition was required by state legislation, ruling that NGO representatives 
who take part in decision making about public money should also ensure full 
transparency. Although this requirement is justifi ed from the transparency point 
of view, some NGO representatives have been critical about this requirement, 
because they see themselves as representatives of organized civil society, and not 
as state offi cial. In addition, it has to be highlighted that all the work of the NGO 
representative is done completely voluntarily, (or using the resources of the NGO), 
thus, becoming a civil servant is seen as a bureaucratic and time consuming burden. 
Conclusions 

Participation in the project evaluation process brings about a better 
understanding of how the project evaluation process works in practice, 
including on how well project evaluation criteria are established, how 
horizontal criteria are applied, etc. This knowledge could be used in 
the next programming period in order to improve the project selection 
and evaluation process.


The work of the NGO representative in the project evaluation 
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committee is done on a completely voluntary basis. NGOs often lack 
capacity to participate in this kind of activities, thus, not all valuable 
knowledge and skills may be utilized in this work. Sometimes 
environmental NGOs had even refused to participate in the work of 
project evaluation committees due to the lack of capacity. There might 
also be a risk of the lack of institutional memory, i.e., the knowledge 
acquired in this programming period may not be transferred to the 
new programming period if the NGO representative leaves. 

The NGO representatives are not allowed to share information 
about project applications. Thus, mostly they have to rely on their 
own knowledge and expertise. For example, the NGO representative 
is not allowed to disclose information to other members of the 
Environmental Advisory Board, even though the NGO delegate was 
nominated to the project evaluation committee by this Board. This 
situation seriously hampers the effi ciency of NGO participation. 

76
Case Study (Slovakia):
NGO Participation at the Control and 
Monitoring of the OP Employment and 
Social Inclusion

Background
Traditionally, the participation of the NGO sector in control and monitoring of the 
OPs in Slovakia was more or less on a formal level. Public participation in EU funds 
governance was guaranteed only in Monitoring Committees, while other processes 
were inaccessible to NGOs. This, together with inadequate access to information, 
created a strong barrier against the effective public control of the implementation of 
programmes. Although the implementation of the OPs fi nanced through ERDF still 
remains a relatively closed system, there are promising signs and initiatives in the 
ESF that indicate change in the level and art of NGO participation in the control and 
monitoring processes.
The change in the management of OP Employment and Social Inclusion (OP 
EaSI) has brought important changes in the fi eld of NGO participation. The new 
management sent a clear signal that they were willing to cooperate with NGOs 
active in the fi elds the OPs were addressing and that on more than just a formal 
level.
From September on, the NGOs have been involved more intensively in singular 
control processes of ESF fi nanced programmes under the control of the Ministry of 
Employment, Social and Family Affairs (MESFA).
NGO participation
 
A. Monitoring: 
In 2007, the former management of the MESFA didn’t respect the nominations 
for NGO representatives to  the monitoring committees (MC) approved by the 
Government Council for Non-governmental Non-profi t Organizations (Council). This 
resulted in a mere formal participation of the civic organizations in funds monitoring, 
while those NGOs that have been most active in the funds control were deprived of 
the opportunity to participate in the MC sessions.

In September 2010, the new management organized an informal meeting of MCs, 
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where the NGOs not offi cially represented in the MCs were also invited. The main 
topics discussed included the possibilities of future effective NGO participation 
in monitoring. Opening the work of the MC to other organizations involved in the 
topic is an innovative way of sharing information and enhancing public discussion 
in Slovakia. The remaining problem is the inappropriate representation of the 
civic sector in the MCs. However, the management of OP plans to approve the 
membership of those representatives who have been nominated by the Council in 
the fi rst place.
 
B. Evaluation and project selection:
In the majority of OPs, the processes of project evaluation and selection are seen as 
the most problematical part of programme implementation. Although this fact should 
be the reason to strengthen the public control of processes, NGOs do not have the 
possibility to participate in project evaluation and selection. 
In the past, there were cases when certain evaluators were repeatedly engaged 
in the evaluation processes without any clear mechanism for their selection. At 
present, the evaluators are being selected by poll, with NGO representatives present 
to oversee the equal opportunities. This is a direct step towards transparency.
NGO representatives also participate as observers at the sessions of the selection 
committees. This presents a certain guarantee that project selection will be objective 
and there will be no space for personal interventions (for example of Ministry 
offi cials) in the process.
However, the quality of project evaluation still remains to be the weak point. Formal 
control of project applications and evaluation are often carried out under time 
pressure. Evaluators have to assess large quantity of projects in a short period, 
which reduces the quality of evaluation, especially the assessment of past activities 
and experience of applicants and the quality of activities and methods proposed in 
the projects. Apart from that, there are no effective mechanisms for quality control 
of the work carried out by evaluators and no sanctions for low quality of work or 
contravening the rules.
Conclusions and Recommendations
This development presents a clear step towards active participation of NGOs at the 
control and monitoring processes. It is crucial to develop the cooperation with the   

78
with all managing authorities. Close attention should be paid to the thorough 
evaluation of experience through the OP EaSI and the dissemination of this good 
practice.
Another way of increasing the transparency of evaluation and selection in the OP is 
the involvement of NGO representatives as observers.
To create commonly acceptable solutions for NGO participation, systematic work on 
the institutional and organizational structure of the cooperation needs to be carried 
out both by authorities and NGOs. The formulation of a singular authority must be 
utilised to the maximum as its management has access to forums that are closed 
to NGOs and can infl uence top decision makers. This indirect infl uence needs to 
be combined with active advocacy with the aim to establish bilaterally convenient 
relations between MAs and NGOs.

Theme 7: Cooperation among NGOs
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Cooperation among NGOs on problematic projects, funded by EU money or for 
promotion of good practices to be supported by the EU Cohesion policy and CAP 
has over a decade long history. It was mainly environmental groups that started to 
cooperate on national and on international levels among themselves in order to 
save nature protection zones, wetlands, forests from highways or to fi ght  against 
problematic energy, waste, etc. projects for clean air or healthy living conditions. 
Later NGOs joined forces and started to propose alternatives – in the beginning for 
particular projects, then – for programmes and policies. NGOs also work together to 
improve conditions for public participation, access to information, etc.
Cooperation among NGOs is widespread in CEE countries due to the fact that most 
of them are small groups with sometimes very focused objectives and expertise and 
limited resources (fi nances and manpower). This process naturally covers the work 
(campaigning, advocacy) on EU funds, where NGOs from CEE have been involved 
since the mid-90’s in connection with some PHARE-funded projects.
With the process of pre-accession and then the accession to EU, more NGOs in 
new member countries became more active in the fi eld of EU funds and naturally 
increased cooperation among themselves. Today there are developed national 
coalitions that work on EU funding in almost all CEE countries as well as international 
networks such as the CEE Bankwatch Network. Some of the older networks e.g., 
Friends of the Earth – Europe, WWF and BirdLife also included work on EU funds 
in their portfolio, thus increasing cooperation among themselves and with NGOs in 
CEE countries.
One of the oldest and among the most famous cases for cooperation among NGOs 
with regards to a particular project is the “Save Kresna gorge” campaign of sixteen 
Bulgarian environmental and scientifi c organizations. It is about the protection of 
a precious natural site from destruction during the construction and operation of 
Struma motorway, part of the TEN-T corridor No 4. The campaign started in late 
1997, passed trough the whole pre-accession period (2000 – 2006) and is still going 
on. Throughout the years the NGOs involved set a huge number of precedents 
and good practices in cooperation, work with national and EU institutions and 
international NGO networks.
With the accession and the prioritising of the national network of highways, the 
work of the “Save Kresna gorge” coalition (16 NGOs) gained impetus. The NGOs 
managed to prove their positions on alternative routes for the motorway and the

80
fi nal agreement between the EC and the Bulgarian government, made in 2007 
was that an alternative route that does not destroy Kresna gorge NATURA 2000 
site should be chosen and developed. The Coalition has a very good working 
relationship with present governmental institutions (the Ministry for Regional 
Planning and Construction Works, Road Infrastructure Agency and to some 
extent the Ministry of Transport, Information Technologies and Communications) 
and are to work out the Steering Committee for the project and other important 
works (e.g., clarify EIA conditions, CBA, etc.).
Other NGOs’ coalitions in Bulgaria are working more or less the same way. 
Some of them (“For Nature” Coalition, etc. as well as a number of grassroots 
initiatives for the protection of different natural areas) are focused on concrete 
projects, related to EU funding and the protection of NATURA 2000 sites. 
They are also active in solving problems between nature protection and the 
development of wind and solar parks. Others, like the Coalition for Sustainable 
Use of EU Funds (CSUEUF) is focused on monitoring all the OPs and a set of 
associated problems.
In the Czech Republic, we have an example with two very structured platforms 
for NGOs. The Association of NGO’s in the Czech Republic was founded in 
2003, and involves nearly 900 NGOs from the country by now. The Association 
defends and promotes the common interests and needs of the entire non-profi t 
sector, creating a space for communication and partnership among NGOs 
and with other social actors (public administrations, parliaments, councils, 
employers, trade unions, political parties, etc. ). The NGO Association also helps 
its members and other NGOs to adapt to the conditions of the European Union. 
The Association of NGOs set a range of priorities as targets, which are currently 
regarded as the most signifi cant strengthening point of the partnership of NGOs 
and public bodies and prepare them for the use of European Union support 
programs in the next programming period 2014 and beyond.
The Governmental Council of Non-Governmental Organizations is a standing 
advisory, initiative and coordinating body of the Government of the Czech 
Republic in the area of non-profi t organizations. The Government Council for 
NGOs was established in 1992 as Council for Foundations, and in 1998, it was 
transformed to Council on Non-Governmental Organizations.
Members of the Council are nominated by the national government, but in fact 
the Council consist of the representatives of the Czech branches of main NGO 
networks. The Council is not an autonomous body of NGOs, but in fact it is an open

discussion forum for NGOs with wide authority. The Council has three working 
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committees: the Committee for Regions, the Committee for EU and the 
Committee for Legislation.
The Council shall perform, among others, monitoring, analysing and publishing 
of information on the status of NGOs within the EU and on participation in EU-
related decision making that affects NGOs and fi nancial resources for them, 
work with ministries and other administrative authorities responsible for the 
fi nancial management of EU sources in the Czech Republic to make NGOs 
eligible to apply for EU funds.
The case of Poland (see the case study from Poland in Theme 2, sub-theme 
1) gives an example how NGOs and other socio-economic partners, presented 
in the Monitoring Committees cooperate among themselves and with public 
institutions. The National Thematic Network for Partnership was established in 
June 2010 by the Coordinating Committee for the National Strategic Framework 
2007-2013. The Network will exist till the end of the current programming 
period. The aim of the Network is to provide concrete support to the members 
of Monitoring Committees (MCs), especially to those who represent socio-
economic partners. The support should make their activities more effective and 
eliminate problems related to the implementation of structural funds in Poland. 
The Network strives to strengthen the entire civil society in Poland indirectly, too. 
In a country with a communist inheritance, the lack of trust in working relations 
and communication between different groups still exist. Therefore, it is of crucial 
importance to have a platform, where representatives of different social/civil 
groups can discuss problems in an open and honest manner.
The Network has six instruments to operate:

a national annual conference on various aspects of partnership;

regional meetings – held every 2/3 months in one of the 16 Polish 
regions, meetings are dedicated to actual diffi culties in the work of 
members of MCs, training, workshops and exchange of experiences;

analysis and expertise – possibility to order thematic studies;

competition for the monitoring committee with the best partnership 
application ;

horizontal exchange of information - using the Knowledge Base 
administrated by the Ministry for Regional Development;

miscellaneous educational activities, depending on needs.

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So far about 150 people attended the meetings of the Network. They gradually 
join the information system. We estimate that there are about 800 members of 
the MCs and their alternates who represent socio-economic partners.
The experience from Bulgaria, the Czech Republic and Poland, as well as from 
the other countries shows that there is widespread cooperation among NGOs in 
the fi elds of EU funds. They vary from forming ad-hoc or permanent coalitions 
to joint civil-institutional platforms and initiatives. From local and national to 
international ones. Organised bottom-up or governmentally initiated.
All of them represent real life situations and needs – whether it be a fi ght  for 
the protection of natural, cultural or social heritage, or the need to involve 
stakeholders in decision-making for strategies and projects for their village, 
town, region, or monitoring the use of public (incl. EU-granted) funds.
From the other side, the support for NGOs in new member countries is getting 
limited as more donors believe that the conditions in CEE became more friendly 
to civil initiatives and citizens, socially responsible businesses and governments 
are willing to donate more for civil initiatives. Unfortunately this is not the case. 
The resource shortages are also among the reasons for cooperation – an 
attempt to use money and goods in the most effi cient way.
The cooperation also helps to build trust among partners and is an investment 
in social capital.
There are a number of problems however, that should be overcome:

there are always new and inexperienced partners, so open-
mindedness and a method for learning the ways of how to cooperate 
is needed;

there are always new situations, inspired by internal or external 
factors (e.g., EU legislation) that request new innovative forms of 
cooperation;

there is always the threat that some authorities would decide to limit 
the role of civil society, so there is always need to defend the right for 
public participation and other associated rights of civil society.
Many civil activists in CEE had the opportunity to see the rise of freedom in their 
countries, and although nothing can be perfect, they have learnt many lessons 
how to work together for improving the conditions of life and save nature.

Case Study (Bulgaria):
83
Cooperation among NGOs to 
Save Kresna Gorge
There are number of cases for cooperation between Bulgarian NGOs with 
regard to Pre-accession and Structural funds, but one is already remarkable 
and could be assessed as a pioneering approach for cooperation both among 
NGOs and between NGOs and institutions. The Strouma motorway (part of 
TEN-T Corridor 4) between Sofi a and the Bulgarian-Greek border (towards 
Thessaloniki) became the most famous campaign related to an EU-funded 
project since 1997. Now the project is moving ahead to some extent, aiming to 
get money from the OP Transport for both the 2007-13 and the 2014-20 fi nancial 
periods. After some fourteen years of strong campaigning to save Kresna gorge 
reserve and NATURA 2000 zone, the NGOs from “Save Kresna gorge coalition” 
launched a new phase of the campaign. Now they are working in cooperation 
with the Ministry for Regional Development and Public Works (MRDPW) and the 
Ministry of Transport, Information Technologies and Communications (MTITC) 
and other institutions, e.g., the Ministry of Environment and Waters (MOEW) and 
the Programming of EU funds Directorate within the Council of Ministers.
At an extensive meeting in 2007 with the participation of all involved institutions 
and NGOs with a moderation of EC representatives, agreement was made that 
the Kresna gorge section of the highway should be constructed following the 
alternative proposal initiated by the NGOs in their attempts to save the gorge. 
Both alternatives envisaged the protection of the gorge and the construction 
of a highway at the same time. Three years afterwards still no development 
was made. Moreover, the government decided to pass by the agreement and 
propose only sections outside the gorge for EU funding, thus foreshadowing 
future problems with bottlenecks and the salami approach.
As the EU commission did not accept to support such approach and in late 
2010 the MTITC and later on MRDPW took the initiative to invite NGOs for a set 
of meetings to move the project ahead. The present government is very much 
focused on the construction of highways and fast roads until 2020. Therefore, 
the institutions were open and asked NGOs to provide all the knowledge they 
have to support faster development of the project. Namely, NGOs are involved 
in:

84

Proposals and discussions around alternatives within the “Tunnels 
alternative”;

Clarifi cation of EIA conditions;

Setting up of the Steering committee. The steering Committee is 
one of the conditions to start Strouma highway project at all. It was 
proposed by NGOs and accepted by the EC and others before 2007. 
This form of an ongoing monitoring body for a single project is an 
innovation for Bulgaria.
Conclusions and Recommendations
The so far positive progress promises that both environmental and transport goals 
would be met and EU funds would be utilised properly. Nevertheless, as there is 
still a long way ahead, NGOs should continue their excellent cooperation on the 
case. Their position is strong enough due to several factors, namely:

The EU does not allow the motorway application to be submitted in 
sections (no “salami approach”);

The Bulgarian government aims to complete some seven major 
highways by 20209  including Strouma motorway by 201510 ;

From an economic point of view, Thessaloniki is the nearest big port 
to Sofi a and besides the highway, a new high-speed railroad should 
be constructed within the next 5 to 10 years.
NGOs from the “Save Kresna gorge coalition” should:

participate actively in the Steering Committee to be specially set for 
the project and work actively to insure the fulfi lment of all requirements 
of the EU and national environmental legislation until the whole 
motorway is completed and put in operation;

actively proposing solutions for the ongoing problems that would 
arise during the construction period;

monitoring potential problems outside Kresna gorge and propose 
solutions to the respective institutions;

communicate with international NGOs (Green 10, other  NGOs of 
MCs that have similar expertise) to ensure that up-to-date proposals 
and solutions are taken into account;

actively participate in the programming of Structural funds in Bulgaria 
for the period of 2014-2020 in order to guarantee that EU money will 
be spent on more sustainable transport projects.
9
The priorities for development of road infrastructure in Bulgaria by 2020 for roads of European and 
national importance. Ministry for Regional Development. Sofi a, 01.02.2011. available at: http://www.
mrrb.government.bg/index.php?lang=bg&do=actual&id=2752 
10
Velikov, Georgi. By 2020 - 7 highways and 7 fast roads. Sofi a, 24,01,2011.  Available at: http://www.
trud.bg/Article.asp?ArticleId=753738

Case Study (Czech Republic):
85
Advances of NGOs  and the 
Public Sector in the Czech Republic
In the Czech Republic, the non-governmental non-profi t sector is very young and 
is fi ghting various weaknesses. Czech NGOs simply work for better coordination 
among themselves in specifi c issues and trying to build fruitful partnerships with 
the public sector. One of these issues is the Structural funds.  
After a euphoric period at the beginning of the 90s, Czech NGOs go through 
hard times in the process of differentiation for professional and citizens’ bodies. 
After the admission of the Czech Republic to the EU, EU funds became the main 
source of fi nancing for the nongovernmental sector.  It started a new wave of 
founding NGOs, but a lot of these NGOs do not enjoy the wide support of the 
public.
Partnership is a frequently used term in the discourses on Structural funds and 
Cohesion policy. It is a helpful tool for improving the social and political impact 
of Structural funds. Discussion and partnership between NGOs, the public, and 
the government must be dealt with on different levels.
In the Czech Republic there are two platforms on which extensive discussion is 
going on between these sectors 
Governmental Council of Non-Governmental Organizations
The Governmental Council of Non-Governmental Organizations is a standing 
advisory, initiated by and a coordinating body of the Government of the Czech 
Republic for questions in the fi eld of non-profi t organizations. The Government 
Council for NGOs was established by a Government Resolution in 1992 as 
Council for Foundations, and transformed by a Government Resolution of 1998 to 
Council on Non-Governmental Organizations.
The Council collects, discusses and (through its Chairman/President by 
government) comments on materials related to NGOs and the creation of a suitable 
environment for their existence and activities. In addition to its other obligations, 
the Council shall perform the following tasks:

86

Initiates and coordinates the cooperation between ministries, 
administrative offi ces and local authorities in support of NGOs, 
including the subsidy policy of public budgets,

monitors, analyzes and publishes information on the status of NGOs 
within the European Union (EU) regarding participation in EU-related 
decision-making affecting NGOs and fi nancial resources, working 
with ministries and other administrative authorities responsible for 
the fi nancial management of EU resources in the Czech Republic, if 
NGOs are eligible to apply,

in cooperation with ministries, administrative offi ces, NGOs and other 
bodies and institutions ensures the availability and dissemination of 
information on NGOs and government policy measures which relate 
to NGOs, in particular, access and analyze information about grants 
from public funds for NGOs.
Members of the Council are nominated by the national government, but in fact 
the Council consist of representatives of the branches of main NGOs’ networks 
in the Czech Republic. The Council is not a democratic autonomous body of 
NGO’s, but in fact it is an open discussion forum for NGOs with wide authority.
The Council has three working committees: the Committee of Regions, the 
Committee for EU and the Committee for Legislation. The latter consists of 
experts and lawyers and is the most technical one among them in the whole 
structure of the Council.
The Committee for EU monitors the status of NGOs within the EU and fi nancial 
resources associated with CR in the EU membership. In doing so, the Committee 
cooperates with other ministries and agencies that implement the EU’s fi nancial 
resources in the country and prepares proposals for improving the use of funds 
by NGOs. The Committee has gained access to information on the use of 
assistance from Structural Funds, Cohesion Fund and other funds.
In last programming period, the committee played an important role in the 
nomination of representatives of NGOs to monitoring committees of particular 
OPs. The Committee prepares calls for interested representatives of NGOs and 
prepares an open evaluation process for candidates. The successful candidate 
becomes delegate of the Council. Delegates of the Council were accepted in all 
cases by the implementation authority of particular OPs.

The Committee of Regions is a platform for the meeting of the non-profi t 
87
sector, the government, local governments and the private sector. Its members 
are mainly representatives of NGOs and elected representatives of regional 
governments, representatives of the Union of the Czech and Moravian Production 
Cooperatives, the Ministry of Environment CR Economic Chamber, the Chamber 
of Agriculture, the Ministry of Interior and the Ministry for Regional Development. 
The Committee is particularly concerned with the institutionalization of relations 
between the voluntary sector and public administration at the regional level.
Weaknesses  
Strong side 
 
It is not an autonomous
Natural authority in the
body of th NGO sector.
NGO sector.
Motivation of some
Open discussion platform
Council members.
supported on
govermental level.
Low authority by some
Working structure
governmental bodies.
functions - Committee of
regions.
Dependence on
Support by secretary.
govermental structures.
The Committee of Regions supported the most important partnership agreement 
between the NGO sector and regional Governments. The Association of NGOs 
in the Czech Republic, with support of the Committee of Regions, prepared 
a memorandum of cooperation with the Association of Regions in the Czech 
Republic. Important discussions were lead about the practical aspects of this 
memorandum within this Committee. 
The Memorandum is followed by similar memoranda in most of the regions of 
the Czech Republic. These partnership agreements formulate principles for the 
cooperation of NGOs in particular regions with their governments, some of them 
promise structural support for the regional networking of NGOs. 

88
About the Association of NGOs in the Czech Republic
Another important body for communication between NGOs and the public sector 
is the Association of NGOs in the Czech Republic. It is the association of legal 
persons, which was founded in 2003 as a result of a long process of strengthening 
collaboration within the non-profi t sector, which began in the early 90 years. 
Members of the Association of NGOs are all regional multidisciplinary associations 
and some branch associations, as well as a number of nongovernmental 
organizations.
Its membership is nearly 900 NGOs, however, it defends and promotes the 
common interests and needs of the entire non-profi t sector, creating a space for 
communication and partnership among NGOs and with other social actors (public 
administrations, parliaments, councils, employers, trade unions, political parties, 
etc.). The NGO Association helps its members and other NGOs to adapt to the 
conditions of the European Union. 
The Association of NGOs in the Czech Republic is the largest association of this 
type in the country. It is based on a regional structure. However, it is not the only 
or main representative of the NGO sector in the Czech Republic.
The Association of NGOs has set a range of its priorities as targets, the most 
signifi cant of which now is the strengthening of the partnership of NGOs and public 
bodies, and the preparation of them (via seminars and workshops conducted) 
for the utilization of European Union support programs in the next programming 
period 2013 and beyond.
The Memorandum about partnership with the Association of Regions of the Czech 
Republic is the most visible institutional improvement in partnership in the Czech 
Republic.
Internet sources (in Czech): 
Governmental Council: 
http://www.vlada.cz/cz/ppov/rnno/zakladni-informace-767 
Association of NGOs in the Czech Republic:
www.asociacenno.cz  

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 About SFteam
SFteam (“Structural Funds” Team) for Sustainable Future is a network of NGOs 
established in 2002 with the aim of guiding regional development and regional 
policy towards sustainability through promoting meaningful partnership and 
public participation in decision-making.
From the initial number of four, its membership has grown to eight and covers 
Bulgaria, the Czech Republic, Hungary, Latvia, the Netherlands, Poland, 
Romania and Slovakia by now. SFteam members are umbrellas or at least serve 
as communication points for the broader NGO community in their countries.
SFteam members realized that EU cohesion policy through its funding 
instruments is a key factor in determining the development path of CEE 
countries. Therefore, they agreed to promote the principles of partnership, 
transparency and sustainability in the programming, monitoring, implementation 
and evaluation of Structural and Cohesion Funds, including the elaboration of 
some pilot projects.
SFteam members work in the above fi elds with a diverse national focus but 
with the shared goal of helping communities, stakeholders and decision-makers 
agree on a path towards sustainability for the common benefi t of all.
The majority of SFteam’s fi nancial resources comes from the Charles Stewart 
Mott Foundation but SFteam also appreciated funding from the International 
Visegrad Fund, the Dutch government, the Hungarian National Civil Fund and 
other European and national funding sources.
Contact:
Secretariat of SFteam for Sustainable Future
International Co-ordinator: István Farkas
Magyar Természetvédők Szövetsége
(National Society of Conservationists)
H-1091 Budapest, Üllői út 91/b, Hungary
Tel/fax: +36 1 216 7297, Fax: +36 1 216 7295
Email: xxxxxxxxxxx@xxxxxx.xx
Web-site: www.sfteam.eu 

90
SFteam members
Center for Community Organizing, Czech Republic
http://www.cpkp.cz ; http://www.cpkp.cz/regiony
BlueLink Information Network, Bulgaria
http://www.bluelink.net
Public Environmental Centre for Sustainable Development, Bulgaria
http://www.ecovarna.info
Focus Eco Centre, Romania
http://www.focuseco.ro
Friends of the Earth – CEPA, Slovakia
http://www.priateliazeme.sk/cepa
Green Liberty, Latvia
http://www.zb-zeme.lv
Milieukontakt International, Netherlands
http://www.milieukontakt.nl/
National Society of Conservationists, Hungary
http://www.mtvsz.hu
Polish Green Network, Poland
http://www.zielonasiec.pl




Imprint
Edited by:
Petko KOVACHEV
Authors:
Teodóra DÖNSZ-KOVÁCS (MTvSz/NSC-FoE Hungary)
István FARKAS (MTvSz/NSC-FoE Hungary)
Zoltán HAJDU (Focus Eco Center, Romania)
Iliyan ILIEV (PECSD, Bulgaria)
Przemek KALINKA (Polish Green Net, Poland)
Petko KOVACHEV (Bulgaria)
Ondrej MAREK (CpKP, Czech Republic)
Miroslav MOJZIS (Friends of the Earth – CEPA, Slovakia)
Alda OZOLA (Green Liberty, Latvia)
Vera STAEVSKA (BlueLink, Bulgaria)
Published by: 
SFteam for Sustainable Future and 
Magyar Természetvédők Szövetsége 
(National Society of Conservationists – Friends of the Earth Hungary)
Proof-read by: 
Kinga Kovács
Printed by: 
Vajai Produkciós Iroda Bt.
Printed on recycled paper
Budapest, 2011
SFteam would like to thank the C. S. Mott Foundation for their 
fi nancial contribution.