Directorate General III – Social Cohesion
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18 August 2009
Ref: EDF-009-061-CB-ja
Dear colleagues
Subject: EDF contribution to the 3rd version of the implementation report of the Council of Europe Disability Action Plan 2006-2015
EDF takes note of version 3 of the Draft report on the replies by Member States to the questionnaire on the implementation of the Council of Europe Disability Action Plan 2006-2015 produced by an independent consultant in advance of the 3rd meeting of the European Co-ordination Forum for the Action Plan of 23-25 September 2009.
This version of the report was disseminated among the EDF members, and herewith it is our pleasure to share the comments received with the Council of Europe Secretariat.
The overall impression EDF members had of the report was its extreme generality. EDF members felt that the collected data was not always consistent and could not be shaped up to produce a text of a political substance. Furthermore, EDF members regretted that in the absence of references to individual Member States, it was impossible to comment on specific national situations that might be omitted in the report. The EDF also regrets that the author of the report chose not to enter into more substantial details regarding the implementation of the individual Action Lines and only provided the reader with the general ‘flavour’ of the progress in implementation across Europe. Some EDF members have thus volunteered to submit more ample information in this regard that is attached to this document in Annexes I (Hungary) and II (members of the European Coalition for Community Living).
The main recommendation for the future relating to the above is to provide for a mode adequate questionnaire and opt for a different way of compiling and presenting the information. For example, it would be interesting, notes one EDF member, to have different questionnaires addressed to the Member States and to the organisations of persons with disabilities in order to be able to compare the responses and draw conclusions concerning the cooperation between the national governments and representative organisations in implementation of the Action Plan.
EDF members also found that the report does not sufficiently address the issue of overlapping of the Action Plan and the UN Convention on the Rights of Persons with Disabilities, although this is a burning issue. This gap might create confusion and a practical duplication of efforts which may not result in any concrete outcome. It is therefore suggested that the report be fine-tuned to adequately reflect the relationship between the UN CRPD and the Action Plan and the Member States’ obligations in this respect.
Furthermore, EDF members noted that the report does not sufficiently emphasise the role of national disability organisations in the drawing up and evaluation of the national implementation reports.
Concerning the recommendations put forward in the report, EDF finds that these are mainly of a formal nature and concern more the way of reporting than the initiatives to be taken on the basis of the responses received. At the same time, EDF does wholeheartedly support the ideas of developing international indicators to measure progress in implementation of the Action Plan, sharing the experts amongst the Member States and strengthening the links with NGOs and other international organisations.
EDF hopes that these remarks can be taken into account during the discussion of the report and reflected in the future work of the Council of Europe.
Please do not hesitate to contact us for additional information.
Kind regards,
Carlotta Besozzi
Director
European Disability Forum