We should try to find a catchy title:
EC Sustainability impact assessments: greenwashing or real political will?
NGO joint sign-on statement, February 2003
Sustainability Impact Assessment (SIA) is a central plank of the European Commission’s strategy to mainstream sustainable development into EU trade policy. Correctly conducted and used, SIA can help deliver more sustainable trade by highlighting the potential social, environmental, health and developmental impacts of trade agreements and identifying measures to mitigate negative impacts.
The Commission embarked on an ambitious SIA programme spanning both WTO and major bilateral agreements in 1999. But it was not until last year that the programme began to bear fruit. 2002 saw the publication of the first two studies – one of food crop sector and one of the EU-Chile bilateral agreement – and the launch of three further bilateral SIAs and the first sectoral studies in support of the WTO SIA.
Many NGOs welcomed the EC programme as an essential starting point in making EU trade policy more sustainable. It was also seen as an opportunity to improve the transparency and accountability of EU trade policy-making. But its is now three years since the start of this SIA programme and there is still little evidence that it is influencing EU trade negotiating positions. Nor is there any evidence of SIAs leading to the formulation of trade-related EU policies and measures that could help to mitigate the negative impacts of trade liberalisation, or to spread its positive effects more equitably and sustainably – particularly by addressing the impacts on vulnerable groups and women.
NGOs have engaged in the programme by providing comments on the development of the methodology, offering suggestions for integrating SIA output into policy making and contributing to specific SIAs. But, despite this input and the presence of a formal dialogue process, the Commission has yet to address fundamental NGO concerns about its approach to, and conduct of SIAs.
In particular, it has failed to tackle satisfactorily the following issues despite repeated calls from civil society to address them:
1. Pro-liberalisation bias: The Commission approach is still based on the primary assumption that trade liberalisation is desirable and will result in economic growth and development. This has not been questioned by any of the SIAs conducted to date and this is a serious weakness of these studies. Alternative proposals such as no liberalisation or trade in a different form are excluded from the analysis. This narrow scope closes off alternative policy options before they can be assessed and undermines the purpose of the tool. SIA is supposed to inform the development of policies, not simply assess them. Without this freedom, the utility of SIAs will be limited to proposing “flanking” measures to mitigate the excesses of liberalisation and enhance what benefits there are rather than coming up with truly sustainable options.
- The Commission must abandon its pro-liberalisation bias and embark on a wide ranging SIA programme which has the freedom to examine all the potential policy options and come up with truly sustainable solutions – including alternatives to liberalisation.
2. Limited scenario analysis: The selection of the scenarios to be analysed also restricts the scope of the studies. The Commission itself selects a small number of scenarios for analysis in the studies – these reflect pre-determined positions and civil society has no input into the construction of these scenarios. The scenarios studied so far have automatically favoured the preferred EU negotiating position calling into question the value and credibility of the whole process. The suggestion that other parties may construct and assess their own scenarios is not valid as few have the resources to do so, and even if they did, the studies would be largely academic with no influence on EU policies.
- Stakeholders must be involved in the selection of the scenarios for analysis in the study.
3. SIAs are conducted at arms length from policy formulation: SIA should not be an academic tool. Important political questions such as the purpose of SIA in the context of difficult trade negotiations need to be addressed upfront in the actual design of the tool. SIA is ultimately there to inform policy-makers about the impacts of various policy options to allow them to make well informed and balanced choices. Unfortunately, policy-makers – particularly at a Member State level – seem to be paying little attention to the tool and are not actively engaged in the process.
- SIAs must be integrated into the policy-making process. Policy-makers and negotiators must engage fully in the exercise from design to implementation of the SIA results. This requires high-level (political) support.
4. The burden of action lies with trading partners: There is a tendency for SIA recommendations (see for example EU-Chile SIA, and Food Crops SIA) to focus only on what needs to change and happen in the trading partner of the EU. The onus is placed on the producing nation to put in place policies to offset the negative impacts of the trade agreement. Even where most of the benefits accrue to the EU and its corporations. EU policies have impacts beyond EU borders and EU consumption patterns can influence production patterns abroad. The EU cannot expect its trading partners to act unless it too addresses its own damaging trade distorting policies like the CAP. Unless this happens, the current approach will have the perverse effect of reinforcing the defensive attitude of developing countries towards SIA.
- More effort should be placed on identifying what the EU can do itself and how it can reform its own policies to improve the sustainability of the trade agreement in question. Priority should be given to measures which can be promoted through EU programmes, policies and instruments.
5. The delivery of mitigation and enhancement measures: Effective delivery of mitigation and enhancement measures identified by an SIA will require a high degree of co-operation – both within the Commission and with trading partners. Yet, there is no visible mechanism within the Commission or process to co-operate with trading partners to implement and follow through SIA recommendations. This is particularly disheartening given the emphasis the Commission’s approach places on such measures. Liberalized trade – and EU corporations – must pay the social and environmental damages that their action creates.
- The Commission should put in place formal procedures to ensure that mitigation and enhancement measures are implemented appropriately. These measures have to be adequately resourced and supported and their delivery and impact must be monitored and reported on.
The credibility of the EC SIA programme will be open to question unless the Commission addresses these concerns. SIA is only a tool – it requires political will to deliver on its potential. We see little evidence of this will in the way the SIAs have been conducted and used to date. Without action to support its rhetoric, the Commission’s SIA programme will be viewed as little more than an expensive exercise to justify its own position. If these weaknesses are not addressed, there is a danger that the programme will lose the support of civil society.
Signatories:-
- ACSUR Las Segovias, Spain
- Asamblea de Cooperacion por la Paz, Spain
- Aprodev, Belgium
- Berne Declaration, Switzerland
- Campagna per la Riforma della Banca Mondiale, Italy
- Cooperaccio, Spain
- Economistas sin Fronteras, Spain
- European Public Health Alliance (EPHA), Belgium
- Eurostep, Belgium
- Friends of the Earth Europe, Belgium
- Forest and the European Union Resource Network (FERN), Belgium
- Fundacion CEAR, Spain
- Green Alternative, Georgia
- ICDA, Belgium
- IEPALA, Spain
- IPADE, Spain
- ISCOD, Spain
- KEPA (Service Centre for Development Cooperation), Finland
- MPDL, Spain
- Morton County Citizens for Responsible Government, USA
- National Federation of Women's Institutes, UK
- Paz y Solidaridad, Spain
- Paz y Tercer Mundo, Spain
- Solidar, Belgium
- Solidaridad Internacional, Spain
- Traidcraft, UK
- Weed (World Economy, Ecology & Development), Germany
- WIDE (Women in Development Europe), Belgium
- Women's International League for Peace and Freedom, UK
- World Development Movement, UK
- WWF European Policy Office, Belgium