Stakeholder Participation for Strategic Environmental Assessments (SEA). The Case of Ghana s Growth and Poverty Reduction Strategy (GPRS).

Transcription

1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Stakeholder Participation for Strategic Environmental Assessments (SEA). The Case of Ghana s Growth and Poverty Reduction Strategy (GPRS). Kwame Boakye-Agyei Consultant, World Bank November,

2 TABLE OF CONTENT Acknowledgements. 3 Executive Summary. 4 Abbreviations and Acronyms. 7 CHAPTER 1: INTRODUCTION. 8 Project Background. 8 Objectives of Study. 9 Scope Study. 9 Report Organization. 9 CHAPTER 2: METHODOLOGY. 11 Project Context. 11 Identifying case study. 12 Analytical framework. 12 CHAPTER 3: FINDINGS. 15 Representativity of SEA/GPRS. 15 SEA/GPRS Process. 16 Mechanisms employed for Participation. 18 Institutional Constraints. 19 Programme Relevance. 22 CHAPTER 4: DISCUSSION. 25 CHAPTER 5: CONCLUSION AND RECOMMENDATIONS. 28 BIBLIOGRAPHY. 30 ANNEX 1: Sample of EPA/NDPC Sustainability Test Sheets. 31 ANNEX II: Sample of the EPA/NDPC Compound Test Sheet. 34 ANNEX III: Sample of the EPA/NDPC Compatibility Matrix Sheet. 35 ANNEX IV: Consultancy Terms of Reference. 36 LIST OF FIGURES Figure 1. Stakeholder Participation Process Framework Figure 2. National SEA/GPRS Stakeholders Chart Figure 3. Regional Level SEA/GPRS 1 Stakeholders Chart Figure 4. Stakeholder/Interest/Importance/Influence Matrix Figure 5. SEA/GPRS Implementing Chart Source: EPA/NDPC, 2004 Figure 6. Links between SEA process, development planning and budget planning in Ghana. Figure 7. The Tools, Techniques and Mechanisms applied during SEA/GPRS Figure 8. Relevant Activities Considered under GPRS Figure 9. Breakdown of Natural Resources Based Policies considered under GPRS Figure 10. Evaluation of Measures by Districts to improve PPPs Figure 11. GoG Budgetary Allocation to EPA from Consolidated Fund ( ) 2

3 ACKNOWLEDGEMENT: 3

4 EXECUTIVE SUMMARY: In recent years the involvement of stakeholders in environmental decision making, planning and management has often been advocated but most often not applied effectively. Whilst the design of participation for policy based SEA approaches are influenced by interest groups of differing agendas and needs, it has followed EIA based methodologies which are limited in their capacities to adequately focus attention on identifying stakeholders and their interests, and effectively engaging them in decision making at the policy level. The paradigm shift may demand that SEAs evolve into a continuous process bringing in institutional and governance dimensions to influence and embolden policy formulation whilst applying stakeholder representation mechanisms to being together differing viewpoints. (World Bank, 2005). Highlighting on institutional strengthening, governance and policy decision making processes rather than just a simple linear, technical approach focused on impacts as often found in EIA would be necessary for SEA practioners. (World Bank 2005, OECD, 2006). In effect, the complex array of machinations within government s policy making machinery and how stakeholders are identified and engaged to influence policies in the context and literature of SEAs would need to be given much attention. Current SEA literature has commented that practice in SEA will require strategic thinking in the public decision-making process, and for the stakeholders involved. (Partidario, 2007). Others have also indicated that the real challenge to achieving both the aims and potential of SEA are not methodological but rather institutional and political. (Dalal-Clayton and Sadler, 2005). It is therefore imperative that for policy based SEAs to realize its potential, stakeholder participation in policy based SEAs should be understood in the context of public policy making both to secure political commitment and effectively involve key stakeholders. Furthermore, there is the need for a greater understanding of the most effective ways of involving SEA stakeholders, particularly the vulnerable ones in influencing policy decisions and how their interest can be met through the application of policy-based SEAs. Considering the above, this study has proposed a stakeholder participation framework that could be harnessed to assist practioners in understanding how stakeholder participation could be employed to meaningfully influence policies in policy based SEAs. A framework that encourages clear articulation of an initiative would help describe the participatory components necessary within the environment which reform is desired. Key elements highlighted in the framework included the effective representation of stakeholders, the identification of institutional constraints, selection and use of mechanisms and techniques that can ensure social learning, and the availability of enabling environment with triggering mechanisms that can be harnessed within the policy making process to influence policies, programs and plans. Using these elements as guide, the SEA of Ghana Poverty Reduction Strategy (GPRS) was reviewed. The case study was indicative of what participatory processes and mechanisms were applied and the extent to which vulnerable stakeholders were involved in influencing the GPRS policy. The study was undertaken using semi-structured interviews conducted in Ghana within a fairly open construct which allowed for focused, conversational, and two-way communication. Direct inputs were obtained from the Ghana SEA Team, experts and the general stakeholders. Some information was also extracted from international journals and the Web. The main findings of the study reveal the following: 1. Generally, the SEA allowed a wide range of stakeholder s to participate in reformulation of the GPRS policy statement. These included politicians, Ministries, Departments, Agencies, the donor community and some civil society organization. The 4

5 engagement of key stakeholders, particularly vulnerable groups and civil society to influence the SEA/GPRS policy decisions was rather minimally exercised. This probably suggests that the stakeholder s identification process employed could not adequately focus on vulnerable stakeholders and the civil society but on MDAs and MMDAs. 2. The processes of participation in the policy making processes were both consultative and deliberative. These were operationalised combining a top-down and bottom-up policy implementation trajectories. Key MDAs were engaged at the national level, and 108 out of 110 Metropolitan, Municipal and District Assemblies were guided at both the regional and district levels on how to mainstream environment into policy formulation. The resultant benefits were the refinement of district development plans to include environmental considerations and the enhancement of governmental interdependency. 3. The overall mechanisms and techniques utilized to influence the review of the GPRS policies indicated a picture that was one of maintaining traditional methods for stakeholder involvement. Nevertheless, a few new tools were introduced and well used. These were the sustainability test, compatibility test and compatibility matrix. 4. The potential of the SEA to influence the GPRS policy decisions were inhibited by some institutional constraints which included the lack of legal frameworks supporting the SEA, low capacity to adequately implement and engage in policy dialogue, absence of benchmarks for participation and, inadequate evaluation and monitoring procedures. 5. The overall relevance of SEA in facilitating the GPRS policy review was apparent to most MMDAs. However, its relevance was unclear to some civil society organizations and locals who thought participating in policies reviews such as the SEA/GPRS were designed for a selected few. These findings lead to the following recommendations. It is recommended that, in order for SEAs to influence policy decision making: 1. Stakeholder processes must be carefully planned by particularly focusing on stakeholders that are likely to be affected by policy decisions. Identifying the key primary and secondary stakeholders and also understanding their interest and motivation in participating in the policy process is a key first step in the public policy making process. Adequately preparing a stakeholder analysis would prevent arbitrary selection of participants which most often result to the exclusion of vulnerable stakeholders. The emphasis should not only be placed on broadening the stakeholder landscape but to purposely focus on the key stakeholders, their interest and their abilities to influence policies. 2. Understanding the political economy and the prevailing institutional constraints inhibiting the influence of stakeholders in public policy making is critical. Institutional and governance constraints can affect the legitimacy of SEA process is not addressed. This might come in the form of legal, capacity, political, historical or socio-cultural factors. Identifying these constraints supports the concept of recognizing prevailing institutional constraints when one is interested in studying how policy decisions are made. (Kraynor and Howard, 1997). Experience demonstrates that although the existence of formal 5

6 rules or rules-in-form exist in the many policy making landscapes, they are most often overridden by rules-in-use which over the years have been embedded within the political economy of decision making. Setting participation benchmarks at this stage would be necessary. Benchmarks for stakeholdership drawing its authority from a Public Involvement Policy would suggest to the drawing board the necessary ingredients for a desired output in SEA. Its productive support to monitoring and evaluation will be timely. 3. There must be a clear strategy for stakeholder participation that simply set out as an integral part of the overall planning and decision-making process. A review of varieties of mechanisms and techniques that can facilitate involvement in policy making must be carefully conducted. The use of a variety and combination of tools may also be required where necessary. Technical tools must be selected such that they deliver specific decision outcomes and should be arranged according to the contributions they can make. It is anticipated that tools selected would go beyond consultation to working towards collective agreements and actions. The inclusion of public budget and expenditure tracking tools to enhance capacities of stakeholders in pro-poor budgeting and expenditure would be opportune. These can ensure social accountability. Without understanding how budget and expenditure impact policy decisions can surmount a rather useful policy designed under SEA. This would represent an evolution of a new SEA culture which focuses on the priorities of wider participation and the equitable allocation of resources. These tools must be grounded in empirical evidence of what works and why. To this end, the academia and researchers in general could be encouraged to evaluate the trend, types, mechanisms and processes of participation that is being applied in country s programs and come up with best practices and innovations that could attend to the interest of these stakeholders and by that level the participation playing field for SEAs effective operation. 4. A strong political commitment on the part of government to involve stakeholder in policy decision should be clearly demonstrated and supported by government. Since SEA requires a widespread involvement of stakeholders, policy makers and the wider public, many conflicting interest of stakeholders should be expected. It would be important for SEA to take advantage of prevailing triggering mechanisms that supports participation and can be used by politicians to support SEA. In the same vein, explaining clearly what SEAs are, in order to convince politicians, policy makers and decision takers in general could unravel and attract the needed political audience. Parliament therefore continues to become a key stakeholder whose active participation in ensuring funding and enforcing wider participation for SEA is ultimately necessary. Their role in bringing into the stakeholder landscape, the mass of the people, the private sector, CSOs and government actors cannot be underestimated. 6

7 ABBREVIATIONS AND ACRONYMS CBOs Community Based Organizations CSOs Civil Society Organisations DAs District Assemblies DFID Department for International Development of UK DPCU District Planning Coordinating Unit EPA Environmental Protection Agency EIA Environmental Impact Assessment GoG Government of Ghana GPRS Ghana Poverty Reduction Strategy HIPC Heavily Indebted Poor Country M&E Monitoring and Evaluation MDAs Ministries, Departments and Agencies MES Ministry of Environment and Science MMDAs Metropolitan, Municipal and District Assemblies MoI Ministry of the Interior MFEP Ministry of Finance and Economic Planning MOFA Ministry of Food and Agriculture MTDP Medium-Term Development Plan MTEF Medium-Term Expenditure Framework NCEIA Netherlands Commission for Environmental Impact Assessment NDPC National Development Planning Commission NEAP National Environmental Action Plan NEP National Environmental Policy NGO Non-Governmental Organisations PRSP Poverty Reduction Strategy Paper RCC Regional Coordinating Council RPCU Regional Coordinating Planning Unit SEA Strategic Environmental Assessment 7

8 CHAPTER 1: INTRODUCTION 1.1 Project Background: The emergence of stakeholder involvement in policy-making has arisen out of a new general development model which seeks a different role for the state, which is based on pluralistic structures, political legitimacy and consensus. (Sevaly, 2001). As pressure mounts for institutional reform to make governments more responsible to the people, stakeholder participation now tends to spill beyond the precincts of project involvement to participation in policy decision making consequently merging the agendas of participation and good governance. (Gaventa and Valderrama, 1999). The reasons for this are that greater information and broader stakeholder experiences make it easier to develop and implement realistic policies and plans. This is of particular importance in the context of policy based SEA that seeks to effect the mainstreaming of environmental concerns into policies, plans whilst managing uncertain environmental and institutional changes. The Bank s Environment Department has been implementing its pilot program on institutions-centered SEA since Preliminary results of the pilots undertaken have shown the importance of the public participation process for influencing policy making through involving key stakeholders in the SEA. Yet, public participation in SEA is mainly carried out following the consultation processes developed for EIA which were not developed to influence strategic decision making. Whilst the design of participation for policy based SEA approaches are influenced by interest groups of differing agendas and needs, it has followed EIA based methodologies which are limited in their capacities to adequately focus attention on identifying stakeholders and their interests, and effectively engaging them in decision making at the policy level. (Videira et al., 2006). Over the last twenty years, the term 'stakeholder' has increasingly appeared in environmental agreements and the literature of environmental politics. (Coppola, 1997). Today the term stakeholder engagement is emerging as a means of describing a broader, more inclusive, and continuous process between organizations and those potentially impacted. (IFC, 2007). Whilst different organizations sometimes use different terminologies to explain the phenomena of engagement, be it consultation, public consultation, public participation or stakeholder involvement, they most often express similar concepts and principles. (IFC, 2007). Notwithstanding the varied meaning, it means different things to many different people. (Steelman & Ascher, 1997). However understood, they stakeholder consultation processes are expected to ensure that stakeholders are involved effectively and their views given adequate attention. The question however is Who are these stakeholders and how can they adequately participate in polices, programs and plans envisaged under SEA? What are their interests and how can they meaningfully play their vital roles? What capacities and influences can they exert the policy formulation process? Are there institutional constraints inhibiting their effective engagement? Are there mechanisms and techniques to generate interest, build capacity and relationships in all facets of participation? In order to answer these questions, policy based SEAs would need to better understand the political economy and institutional setting within which it is applied. (World Bank, 2005). Whilst some countries have been quite successful in involving stakeholders in decision making others have not. It seems, therefore, necessary that the processes applied by the successful countries are examined to reveal the lessons, complications, strengths, constraints to complement the international experience with stakeholder participation in SEA. It is with this 8

9 background that the SEA/GPRS is the subject of study to help understand how its implementation has involved stakeholders in defining the GPRS policy framework. 2.0 Objectives of this Study: The overall purpose of the study is to provide insights on how stakeholder participation processes was developed when an SEA was applied on Ghana s Poverty Reduction Strategy. The specific objectives of the project are to analyze how the SEA for Ghana s PRSP was used as a tool for policy dialogue involving key interest groups with stake in the environment and also examine mechanisms that were designed to ensure participation. Essentially, to reveal the complications, strengths, constraints and lessons to inform the World Bank institutions centered pilot program. 3.0 Scope of Research: Evaluating stakeholder participation in Ghana s SEA on Poverty Reduction Strategy is a fundamental building block to enable the accountability, effectiveness and coherence of good environmental governance. There is the need to establish required indicators and criteria for stakeholder participation in environmental decision making to meet regional and global expectations. To maintain Ghana s long term development sustainability through the application of Strategic Environmental Assessment (SEA), the study broadly investigates how stakeholders were involved in the most efficient and effective way, who and what organizations or groups were involved, and what mechanisms were followed in the process. This project was designed and carried out in such a way as to best meet the scope described above. 4.0 Organisation of Report: This report is organised into the following sections: Chapter one provides background of the SEA/GPRS, its objectives and scope. Chapter two discusses the methodology employed whilst chapter three presents the findings of the report. Chapter four discusses the findings with a conclusion and recommendation in chapter five. A bibliography is attached to the report study with a Sample of EPA/NDPC Sustainability Test Sheets as Annex 1, Sample of the EPA/NDPC Compound Matrix Sheet as Annex II, Sample of the EPA/NDPC Compatibility Matrix Sheet as Annex III and the Consultancy terms of reference as Annex IV. 9

10 CHAPTER 2: METHODOLOGY 2.0 Project Context: In recent years Ghana has been making attempts to mainstream environmental considerations into national development agenda. Several methods have been adopted which includes EIAs and SEAs. Whilst several SEAs have been undertaken in Ghana, or are currently in progress, it is maintained that SEA is not intended to replace other tools of environmental management such as the Environmental Impact Assessment (EIA), but it will complement project level assessments by providing the context for higher, more strategic levels of decision-making that would ensure that the country s development objectives are compatible with the tenets of sustainable development. (Dalal-Clayton, B. and Sadler, B. 2005). Prominent among SEA application in Ghana has been the pilot activity undertaken to apply Strategic Environmental Assessment (SEA) to Ghana s Poverty Reduction Strategy (GPRS). The key aim was to integrate national policy goals and practical delivery of sustainable development balanced between the three pillars of sustainable growth i.e. social, economic and environment. 1 Ghana s 2002 Poverty Reduction Strategy (GPRS) although identified environmental degradation as an underlying cause of poverty, failed to integrate environmental considerations as a cross cutting issue in the strategy. It was critiqued for treating the environment as a sectoral or "add on" issue rather than a cross cutting one. As a result, the environmental consequences of the policies were inadequately addressed. This presented major problems due to the neglect of key sustainable issues. In order to address these shortcomings, the Government of Ghana decided to conduct an SEA of the GPRS to: assess the environmental risks and opportunities presented by the implementation of the policies of MDAs (including the Districts) and other stakeholders as indicated in the GPRS. identify appropriate mechanisms to ensure that sound environmental management contributes to sustainable economic growth and lasting poverty reduction in Ghana. (EPA/NDPC, 2004) The Environmental Protection Agency of the erstwhile Ministry of Environment and Science (now under the Ministry of Local Government, Rural Development and Environment) and the National Development Planning Commission (NDPC) with donor and technical support from the Netherlands Commission for EIA (NCEIA) was charged to undertake an SEA of the GPRS. During that time there were few experiences to draw lessons from in the application of SEA to national and multi-sectoral plans. NCEIA therefore developed an approach with the objectives of studying to propose an appropriate institutional framework for environmental management and poverty reduction within a wider participatory process for the GPRS. This harmonized policy dialogue between the government at different levels and the public sought a win-win approach in integrating environment to policies, plans and programs (PPP). International SEA/PRSP experts have applauded the SEA/GPRS for having the potential to open up new windows for domestic public debate and civil society involvement. (OECD, 2005). Due to its broad scope and the intensive consultation process undertaken, the Ghana PRS has been 1 Incorporating environmental considerations into Ghana s poverty reduction strategy processes. OECD DAC Guidelines and reference Series. (2006) p76. 10

11 recognized as having the potential to throw light on the key requirements for effective participation on SEA. To this purpose, there is a need, among other things, to assess how the Ghana s SEA/PRS recognized and incorporated the interests of stakeholders particularly the vulnerable stakeholders and also investigate the mechanisms employed for public participation. 2.1 Identifying Case Study: The criteria for the selection of the study included: Review of SEA/Participation literature SEA best practice examples Representative of an international experience Incorporating sufficient stakeholder participation for the purpose of the study Have sufficient documented detail of the stakeholder participation process 2.2 Research: The study was conducted by first developing several approaches to locate relevant literature using a case study approach. The case study approach is selected as an ideal methodology for this research due to the holistic and in-depth investigation needed (Feagin, Orum, & Sjoberg, 1991). Case studies are also designed to bring out the details from the viewpoint of the participants by using multiple sources of data. (Yin, 1993).These included web-based searches of major databases and e-libraries of key international institutions including World Bank, OECD, NCEIA and DFID. Where databases searches were undertaken the most commonly used keywords were strategic, environment, assessments, stakeholder participation, public participation, active citizenship and civil participation. The study involved a field visit to Ghana with close collaboration with the EPA and NDPC who were charged to apply an SEA on the GPRS. The process involved interviewing individuals with knowledge and experience with the SEA/GPRS. Interviews were qualitative, in-depth, and semi-structured. All participants were assured that their responses would remain absolutely confidential and under the sole ownership of World Bank. 2.3 Analytical Framework: To ensure effective overall conclusions from the SEA/GPRS study on stakeholders can be engaged to influence policy making, an integrative analytical framework has been developed. Underlying this framework (Refer to figure 1 below) are two main levels for analysis: Level 1 indicating a stakeholder analysis and level 2 based on a participatory strategy that considers the policy making process in general as well as the addressing mechanisms and techniques that can be applied within an enabled environment. The framework draws strength from the gaps identified in the SEA/EIA literature which reveals the need for stakeholder participatory frameworks to influence policy making. Level 1: Issue Sensing Interest Role and Influence Capacity Institutional Constraints This level represent the state-of-the-art in matching salient elements for a stakeholder analysis sensing the issue at stake, role and influence of stakeholders, level of stakeholders capacity, their interest, and the institutional rules or constraints impacting the effective participation. As 11

12 there are obviously still unsolved problems in how stakeholders can be involved in policy making, this level might identify actual stakeholder needs and also understand the political economy of which participation is to happen. Level 2: Mechanisms, Tools, Techniques, Enabling Environment Policy Formulation Policy Implementation Monitoring and Evaluation/Feedbacks At the strategy level of the framework, the identified needs of stakeholders are analyzed for considering the most applicable mechanism and techniques. Carefully understanding the participatory environment will help identify triggering mechanisms that could be harnessed as an advantage to strengthen participation. Overall, information and outputs from level 1 will be input into level 2, and this will lead to identifying nodes for policy formulation, implementation, monitoring and evaluation with feedbacks to participating stakeholders in level 1. The final analysis will lead to conclusions and recommendations for a policy-based SEA. The derivation of this overall concept will be considered for other SEA projects that will greatly complement other efforts in securing an understanding for participatory processes for policy based SEAs. This framework is not intended to be prescriptive but serve as a guide or as a checklist when implementing a policy based SEA. Stakeholders in this regard are any individuals, community, group or organization with an interest in an outcome of a programme, either as a result of being affected by it positively or negatively, or by being able to influence the activity in a positive or negative way. (DFID, 2002). Figure 1: Stakeholder Participation Process Framework. Tracking the processes of involvement from stakeholder analysis to participation in PPPs. 12

13 STAKEHOLDER ANALYSIS Stakeholder scoping, determine degree of participation, define wider process, and investigate institutional constraints. PARTICIPATION IN PPP DECISIONS A clear representative process with the necessary Techniques, Mechanisms and enabling environment. CAPACITY Do they have capacity to participate and what influence do they exert? STRATEGY Are there strategies to generate interest, build capacity and relationships in all facets of participation? ISSUE SENSING What is at Stake, Who are stakeholders and how can they be mobilized? INTEREST Do they have interest to participate? INSTITUTIONAL CONSTRAINTS Laws, Rules, Regulations, Norms, Practices Procedures MECHANISMS Inform, Consult, involve/participate, Collaborate, Empower and, Partner, Ownership ENABLING ENVIRONMENT What triggering mechanisms can be tapped for policy agenda setting? Right to information, Legal frameworks Inclusive participation Research, Political Will. TECHNIQUES/TOOLS Focus groups, Consultation documents, public meetings, Consensus building, dialogue, Conflict resolution, Workshops, Surveys, Local newsletters, Pilot initiatives, IT, users comments & complaints ROLE AND INFLUENCE What roles do they play and what contributions do they make? POLICY FORMULATION Converting claims to commitments POLICY IMPLEMENTATION Converting policy commitments into practice Top-down, Bottom-up, Hybrid, Vertical - Horizontal M&E Feedback Guided by Benchmarks, Quality Assurance, Measuring change Determining their roles, interest and capacity to participate in the process is incumbent on the prevailing institutional constraints served through rules either in-form or in- use. Managing stakeholders to address these constraints, it being institutional or legal, can help overcome undermining variables of SEA policy implementation. Rules also refer to enforced prescriptions or principles ensuring inclusiveness, relevance and gender sensitivity. Maximizing the constructive potential stakeholders influence and their capability to assimilate and adequately indulge in process fulfills the stakeholder analysis segment of the framework. The other segment considers a system that has the ability to generate interest, build capacity and relationships necessary for SEA. Whilst focusing on mechanism and techniques that can enable deliberations, participation and partnerships when applying SEA, it also presupposes the presence on an enabling democratic environment where stakeholder participation is supported in all facets of governance. It was not an objective of this exercise to evaluate the effectiveness of the GPRS or suggest ways to make it effective. Also, not all the components identified in the framework were addressed adequately through the study. The study only investigated how stakeholders has been involved in the SEA/GPRS to draw lessons and suggestions for undertaking participatory processes in institutions-centered SEA or policy based SEA. The essence of the stakeholder participation framework was primarily to track the processes of involvement from stakeholder analysis to participation in PPPs. Some of the overarching questions asked were: What stakeholders were involved in the process? What roles did they play in facilitating the process? What capacities and interests enabled their effective involvement? What rules impact stakeholder participation? 13

14 What strategies were applied for engagement and decision making? Did stakeholders see the application of SEA on GPRS relevant? Interviewees were mainly from EPA, NDPC, NGOs, CSOs, MDAs, MMDAs and some local farmers. A limitation to the study the high turnover of officers both at the Regional and District levels. Many who were part of the SEA/GPRS process, and could have contributed to this study were not available for interview because they had left their respective institutions. This made a detailed analysis a greater challenge. The principal results revealed through the study included the following: 1. Generally, the SEA allowed a wide range of stakeholder s to participate in the GPRS policy statement. These included politicians, Ministries, Departments, Agencies, the donor community and some civil society organization. The engagement of key stakeholders, particularly vulnerable groups and civil society to influence the SEA/GPRS policy decisions was minimally exercised. This probably suggests that the stakeholder s identification process employed could not adequately focus on vulnerable stakeholders and the civil society. 2. The processes of participation in the policy making processes were both consultative and deliberative. These were operationalised combining a top-down and bottom-up policy implementation trajectories. Key MDAs were engaged at the national level, and 108 out of 110 District Assemblies were guided at both the regional and district levels on how to mainstream environment into policy formulation. The resultant benefits were the refinement of district development plans to include environmental considerations and the enhancement of some level of governmental interdependency. 3. The overall mechanisms and techniques utilized to influence the review of the GPRS policies indicated a picture that was one of maintaining traditional methods for stakeholder involvement. Nevertheless, a few new tools were introduced and well used. These were the sustainability test, compatibility test and compatibility matrix. 4. The potential of the SEA to influence the GPRS policy decisions were inhibited by some institutional constraints which included the lack of legal frameworks supporting the SEA, low capacity to adequately implement and engage in policy dialogue, absence of benchmarks for participation and, inadequate evaluation and monitoring procedures. 5. The overall relevance of SEA in facilitating the GPRS policy review was apparent to most MMDAs. However, its relevance was unclear to some civil society organizations and locals who thought participating in policies reviews were designed for a selected few. 14

15 CHAPTER 3: FINDINGS The main findings of the study include the following: 3.1 Representativity of SEA/GPRS Process: With reference to the 2 framework questioning the representatively of the process, it was inquired who the stakeholders in the SEA/GPRS process were. Generally, the SEA/GPRS had followed a National, Regional and District level processes. Whereas the national level stakeholders meetings involved mostly sector officials, the donor community, Ministers and Ambassadors, the regional comprised mainly of District Assembly officials and some regional staff. As illustrated in figure 2, 81% of the selected stakeholders at the National level were sector officials with the rest comprising of DAs, donors, ambassadors and ministers. With regards to the regional level meetings, as illustrated in figure 3, 87% of participants were District Assembly officials, and some representations from the regional offices of EPA, and RCC. Fig 2: National SEA/GPRS Stakeholders Chart NATIONAL SEA/GPRS 1 STAKEHOLDERS 5% 7% 2% 5% Ministers Sector offiicials DAs Donors Ambassador 81% Fig 3: Regional Level SEA/GPRS 1 Stakeholders Chart Regional Level SEA/GPRS 1 Stakeholders 4% 5% 3% 1% 87% EPA RCC SEA Team Consultants DA Officials 2 Stakeholder Participation Process Framework 15

16 Illustrations from figure 4, using stakeholder s influence matrix also revealed that a sizable number of selected stakeholders of high importance and high influence. On the other hand, stakeholders of high importance but often of low influence were very minimal. It is expected that the vulnerable groups if involved would have fallen in category A which is critical to this study. Figure 4: Stakeholder/Interest/Importance/Influence Matrix A (Vulnerable groups)?? NGOs, CSOs, Consultants High Importance /Low Influence C Low Importance /Low Influence B SEA Team, NDPC, EPA, MEST, MMDAs, MOF, Donors, (Private Sector)?? High Importance/ High Influence D Ministers Low importance/ High Influence Stakeholder Importance to GPRS Influence on GPRS MDAs MMDAs CSOs, NGOs Ministers/Politicians Donors Consultants Private Sec.??? Vulnerable groups??? Interest in GPRS Five point scale where 1= very little importance or influence, to 5 = very great importance or influence. Primary Stakeholders: Vulnerable Groups Secondary Stakeholders: MDAs, MMDAs, CSOs, NGOS, Donors, Private Sector, Consultants A significant finding related to the minimal inclusion of voices from vulnerable stakeholders may have been the manner in which the vulnerability was defined within the SEA/GPRS. Vulnerability was interpreted focusing on the poverty-environment discourse which refers to the risks posed by environmental/natural disaster. In quote, The poor are particularly vulnerable to the impacts of natural disasters like drought, fire and flooding because they live within the areas most prone to such events... When carefully planned and executed environmental management will actually save money by avoiding needless waste of soil, timber, and non-forest timber products. (SEA/NDPC Content 2004, p14). In essence, although the vulnerability of the poor was duly recognized in reference to the impact of disasters, it however paid minimal attention to how the aspirations and voices of the vulnerable groups such as the poor, women, youth, the disabled and other influential institutions such religious, traditional, judiciary and private organizations were going to be heard. Also, there were references to gender in the SEA/GPRS as an issue of significant importance when considering environmental management, the focus however was rather on giving women equal rights to access to land and security of tenure than addressing inputs that encourage their participation in developmental dialogue. (SEA/NDPC Content 2004) 16

17 3.2 SEA/GPRS Process: The SEA/GPRS had employed a combination of a top-down and bottom-up process to decision making. According to the SEA Team a pilot phase was initiated between January-March, 2003 to consult, inform and draw key actors, especially MDAs to develop a framework for SEA implementation in the Ghanaian context. As illustrated in figure 5, the stages followed for implementation began with a scoping conducted by the Netherlands EIA Commission (NCEIA), to identify the need to generate interest in the SEA/GPRS process. 3 (EPA/NDPC, 2004). A start-up phase was set up in February 2003, according to the report, to apply the recommendations of the scoping exercise into a pilot SEA. This first phase identified and highlighted emerging gaps in policies prepared for the GPRS. The discussions on SEA/GPRS began with a national level meeting when the main recommendation of the pilot SEA was presented at the national stakeholder s workshop. It was during this meeting that EPA and NDPC were charged to undertake a full SEA to let result influence the national budgeting process which was to start in 2003 and, the GPRS review scheduled for A second and third phase was designed respectively to broaden the scope of SEA application and stakeholder participation and, apply lessons to effect sectoral SEAs. Phase two (2) witnessed the organization of fora/workshop at the national and regional levels of planning and also carried out sustainability appraisal of all the 110 District Medium Term. In essence deliberation began at the national top level, then to the regional level and district levels (bottom-up) and finally to an all inclusive regional level stakeholders meeting represented by all the levels of decision making i.e. national, regional and district. (EPA/NDPC, 2004). Fig 5 SEA/GPRS Implementing Chart Source: EPA/NDPC, 2004 Process Content The participatory process of undertaking an SEA Determine the main interventions of the GPRS Analyze the GPRS context (environmental and institutional) Assess the impact of the main GPRS interventions and identify alternative options Comparison of alternatives and guidelines for environmental sustainability Establish an environmental monitoring system Outputs: build up of mutual understanding, awareness and the building of bridges amongst ministries and agencies Output: SEA report that indicates environmental impacts, opportunities and institutional issues 3 EPA/NDPC SEA Content Report The report discusses the content designed in the SEA/GPRS under the GPRS 1. 4 EPA/NDPC 2004 SEA/GPRS Process report. This is a supplementary report discussing the process followed in the phase 2 and 3 of the SEA/GPRS program. 17

18 With guidelines given by the Netherlands Commission on Environmental Impact Assessment (NCEIA) the SEA exercise was categorized into Process and Content. As indicated in figure 6, the process had the output of building up mutual understanding, awareness and the building of bridges amongst ministries and agencies. Whilst the content had the output of an SEA report that indicates environmental impacts, opportunities and institutional issues. An integration and interplay between departments, agencies, sectors and the development and budget planning unit were arranged into the formals links infusing the SEA process as illustrated in figure 6 below. Fig 6: Links between SEA process, development planning and budget planning in Ghana. Source: EPA/NDPC, Mechanisms employed for Participation: With regard to the mechanisms employed for the SEA/GPRS, the study reveals that the traditional forms of participation were well established and used. As a component of strategy (refer to framework in figure 1), the overall mechanisms and techniques utilized indicated a picture that was one of maintaining the older, traditional methods for stakeholder involvement. However, new tools such as the sustainability tools had been applied. The joint working agreement between the EPA and NDPC had also evolved over time into a formalized collaborative arrangement where respective organizational tools were used to benefit the SEA/GPRS program. Instances of inter-agency collaborative working among participating organizations were reported. A clear example was the arrangement between the EPA, MMDAs and Regional Economic Planning Officers at the regional level. The introduction of 5 SEA tools, 5 Tools developed by EPA. Sustainability Test, Compatibility Test and Compatibility Matrix Sheets. Attached as Appendix I, II, and III. 18

19 however, was reported to be essential. Some respondents attributed that to the SEA tools ability to mobilize diverse stakeholder experiences during the workshops and seminars. Tools applied during these SEA/GPRS sessions included sustainability test, compatibility test, compound matrixes and some costing processes on the participation process. Refer to Annexes I, II, III for sample sheets. Figure 7 indicates the techniques, tools and mechanisms employed for the process. Some interviewees responded that the sustainability tools helped them focus on the critical issues and therefore set the stage for debate and decision-making. An increasingly important challenge is how to design public dialogue processes to facilitate discussion and cooperation among people with diverse backgrounds, expertise, interests, views, needs and concerns. Figure 7: Participatory Mechanisms and Tools applied for SEA/GPRS TYPES OF MECHANISMS AND TOOLS APPLIED COMMUNICATION PARTICIPATION/ENGAGEMENT TOOLS/TECHNIQUES Briefings Mailing out Presentations to technical groups Consultations (formal and informal) Advisory groups Key person interviews Focus group Interviews Seminars Meetings Forum Workshops(National, regional, District levels) Sustainability test Compatibility matrix Compound Matrix Costing the participatory process Dialogue Consensus Building Conflict Resolution Some of the questions asked by participants during the deliberating sessions of the SEA/GPRS were as follows: How far are international donors engaged through SEA? Do MDAs have capacity to deal with technical debates over change of policy? How are conflicts over policy contradictions resolved and what framework has been established for this purpose? Importance of involving the banking institutions (banks lend directly to the poor) How do you maintain commitment /involvement of DAs with high turn over of staff? Are people engaged in looking at the SEA at grassroots level? How can the dialogue between national, regional and district level be institutionalized? How was the GPRS taken through in terms of participation? How would NGOs tackle this task? - Through local action groups 3.4 Institutional Constraints These constraints refer to the rules segment of the framework for this study in figure 1. Institutional constraints are being referred to in this study as enforced prescriptions or principles ensuring inclusiveness, relevance and the describing the character of the political economy existing that may or may undermine policy implementation. Critical to the political economy of participation is identifying the rules-in-form and rules-in-use. 19

20 Clearly, the depth and quality of public participation in public policy is severely inhibited by a number of structural and cultural factors in the Ghanaian political economy. The government of Ghana has a legitimate prerogative for policy making and implementation which affects bottomup processes of decision making. According to some respondents, this remains the single most important challenge facing the SEA/GPRS. Although some important achievements have been registered through the application of SEA there still exist some major gaps. Particularly, MDAs are still entrenched in the use of top-down decision making approaches. This is a clear indication of a rule-in-form not correlating with the rule-in-use. The GPRS 1 had to undergo an SEA process as a result. Although the GPRS I was premised upon a bottom-up participatory process and national ownership, the Ministry of Finance s short-term approach was driven by its fixed view of linking PRS programmes to resource availability, rather than allocating resources in accordance with PRS requirements 6. (Holland and Abugre, 2003). During the SEA/GPRS process all policies in the PRSP had to be re-examined in order to determine their relative importance and priority from the standpoint of poverty and environment. According to the SEA/GPRS Content Report (2004) 7, participating stakeholders identified existing policies within the GPRS that have particular significance for poverty and environment and grouped them into policies that are people centered. The explanation was that policies that are directed at people are most likely to have immediate impact in alleviating poverty, while policies directed towards natural resources are most likely to benefit and safeguard the environment. It is quite interesting to note, as expressed in figure 8, that the least activities considered under the GPRS were for the vulnerable and excluded and, governance. Thus, out of a total of 2843 activities considered under the GPRS, only 7% was realized as activities for the vulnerable and excluded. Fig 8: Relevant Activities Considered under GPRS Source: District Appraisal Report, 2003 Number of Activities by Thematic Areas Macro Economic Production and gainful employment Human Resources and Basic Services Vulnerable and Excluded Govenance Probably suggesting why vulnerable groups and governance issues that are critical for natural resource management were illusive under the GPRS. Figure 9 depicts an interesting feature when natural resource based policies categorised by themes. Out of the total of 120 policies 6 Paper prepared by Jeremy Holland and Charles Abugre for the One World Trust Workshop Increasing Accountability through External Stakeholder Engagement Centre for Development Studies, University of Wales Swansea. 7The SEA of GPRS. Content report Part III by EPA/GPRS,

21 No. of Policies that were formulated under the GPRS, only 11% under the GPRS, none reflected the vulnerable and the excluded. This probably is an indication of the challenges SEA will probably face in the ensuing years. Its ability to encourage the making of policies that addresses and involve vulnerable stakeholders whiles facilitating the making of natural resources protection policies would be its major test. A critical example will be how SEA could be used to address wicked natural resource problems emanating from the use of illegal tree chainsaw operators to small scale illegal miners (galamsey). Fig 9: Breakdown of Natural Resources Based Policies considered under GPRS Breakdown of Natural Resource Based Policies No of Policies 2 0 Macro Economic Production and gainful employment Human Resources and Basic Services Vulnerable and Excluded Govenance Themes Discussions with the SEA/GPRS Team revealed that the lack of a legislative order for SEAs implementation affects the clarity and commitment of government to the process. Generally, three key legislative frameworks provide a useful guide to assist with the involvement of stakeholders in the SEA/GPRS. An explicitly stated Constitutional objective to promote participation and participatory development. The Directive Principles of State Policy, Article 37 sections (1) and (2), of the Constitution of the Fourth Republic of Ghana (1992), guarantees to all citizens, the right to participate in the formulation and implementation of the development policies and programmes. Chapters 5 (21) and 6 (37) (1)(2)(3)) of the Constitution also define the political framework conducive for democratic participation in the formulation and implementation of policies, and spells out the complementary roles of government and nongovernmental actors in this process. 8 Article 35 (5d) requires the state to take appropriate measures to ensure decentralisation in administrative and financial machinery of government and to give opportunities to people to participate in decision-making at every level in national life and government 9. Secondly, schedules 1, 2 and 5 of the EPA EA Regulation Legal Instrument 1652 insist on a participatory screening and scoping exercise of which the involvement of stakeholders is very significant to the success of the exercise 10. Thirdly, the Local Government Act, 1993 (Act 462), vest in the 110 District Assemblies in Ghana the mandate to make developmental decisions under broad participation of citizens 11. Although these laws are expected to enable an active stakeholder participation in policy decisions making, it is however Constitution of Ghana Article Constitution of Ghana Article EPA EA Regulation LI Local Government Act, 1993 (Act 462) The Local Government System in Ghana ( 21

22 maintained by some CSO interviewees that stakeholder participation in the country often means no more than informing citizens of policies that have already been decided on. Thus these laws are only set in form but minimally translate as desired in operation. On issues about the legality of the process, the EPA commented that the Legal Instrument 1652 is not processed to effect policy but rather plans and programs. The EPA Act 1999 and Legal Instrument 1652 were enacted to provide the necessary legal backing for EIA procedures rather than SEA. It provided sanctions to address noncompliance with EIA rather than SEA. The SEA Team however suggests that the present approach of SEA is not inhibited by the lack of legislative order. Their current proposals emphasize on building capacity before any legislative order can be enacted. They recognize the need for an inter-sectoral coordination and a clear system of checks and balances with clear definition of responsibilities before such legislation can be considered. An area of importance to the SEA Team was the issue of monitoring. Due to lack of adequate funding and capacity, their SEA monitoring responsibilities cannot be performed. Monitoring whether recommendations of the SEA are incorporated and implemented respective policy, plan and programs seems to be a challenge. This poses as a delimiting factor in gathering lessons on the process and probably serves as an indicator depicting a weak commitment on the part of government. It is however recognized that without a strong legal backing SEA might not totally reap its long-term goal of infusing sustainability and broad participation into environmental planning. The study also reveals that although the task set by applying SEA was to also broaden the scope of stakeholder participation, the application of the SEA on the GPRS placed much emphasis on capacity building and the introduction of sustainability tools. The SEA team comments that SEA can develop its full effectiveness only if the stakeholders in the SEA processes are able to represent their interests adequately. This will however require the knowledge of the operating principles, skills of advocacy, processes and resources for defining and articulating positions and aspirations. They observe that most often stakeholders are often too weak to persuade overbearing actors in the decision making process with their opinions. They are not able to put forward alternative policy choices, turn queries or disagreement into credible and viable policy proposals. Participating in sustainability issues require capacity to dialogue on complex policy issues. According to the SEA team, the most appropriate and needed task was to build capacity to help mainstream environment into the District appraisals using SEA techniques. The team stated that capacity building should precede any efforts to legislate SEA. It was also realized that capacity at the regional and district levels were constantly changing with a high turnover rate. Many of the people whose capacities were enhanced as a result of the SEA/GPRS exercise had changed jobs. The increasing outflow of personnel with some requisite SEA training could be a challenge to overall monitoring and evaluation of the SE/GPRS process and skill dissemination. The low capacity of stakeholders, on the other hand, had prevented the understanding of sustainability principles and the engagement of intellectual dialogue. An unfortunate phenomena that can impact the implementation of a community level SEA. 3.5 Programme Relevance: The relevance of the SEA/GPRS was clear to most MDA respondents but however unclear to some civil society organizations and locals. The district assemblies especially were enthusiastic about the process considering the process output of district sustainability plans. All the 108 districts had produced their Medium Term Development Plans (MTDP) following guideline issued by NDPC and guided by SEA sustainability tools in meeting the GPRS objectives. 22

23 According to NDPC/EPA, the SEA/GPRS has provided an opportunity to integrate environmental issues into planning on a much broader stakeholder scale. Introducing SEA in other parallel programs at key sectors like energy, water, agriculture, tourism etc is the result of relevance accrued from applying the SEA process on the GPRS. On the issue of ownership, many of the respondents commented that it remains to be desired. Some CSOs and NGOs commented that ownership was confined to the narrow circle of official stakeholders and rather not the case for the NGOs and CSOs. Even for some district officials, they comment much is still desired to ensure ownership. Respondents commented on invitation to workshops on short notice, no clear terms of reference for participation and assurances that suggestions would impact policies. An analysis of measures by districts to improve PPPs revealed a rather moderate but increased adoption of pro-poor, proenvironment principles. Figure 10 shows such evaluation in Out of 93 Districts, only 9% applied pro-poor, pro-environment policies to their MTDP, whilst 67% were moderate and 24% weak. It probably indicates that the understanding and acceptance of the SEA process is moderately accepted among the technocrats. Fig 10: Evaluation of Measures by Districts to improve PPPs. Source: District Appraisal Report, Ev aluation of Measures by Districts to improv e PPPs 9% 24% Strongly pro-poor, pro environment Moderately pro-poor, pro-env ironment Weakly pro-poor, pro-environment 67% The general understanding among the respondents were that the SEA/GPRS has provided an opportunity to integrate environmental issues into planning on a much broader stakeholder scale. Introducing SEA in other parallel programs at key sectors like energy, water, agriculture, tourism etc is the result of relevance accrued from applying the SEA process on the GPRS. This was reflected in the Budget Statement and Economic Policy of the Government of Ghana for the 2006 Financial Year that was presented to Parliament on 10 th November On quote Mr. Speaker, the Ministry will continue with its effort to mainstream environmental issues into all aspects of GPRS and into sectoral and district planning guidelines issued by NDPC. The results of the Strategic Environmental Assessment (SEA) will provide the information to develop a framework for mainstreaming environmental concerns across all sectors. This will be achieved through the following activities: SEA tools will be used to mainstream environmental issues into sector and district policies, plans and programmes.. (Budget Policy and Economic Statement, 2005 para 468). 23

24 Amount in billions (cedis) This is quite an affirmative statement from Ministry of Finance. It was expected that this statement would have reflected positively on financial outflow from GoG to the EPA. Figure 11 however illustrates otherwise. Budgetary allocations between (excluding IGF and donor funds) significantly dropped from 6.47 billion in 2005 to 4.60 billion cedis in (SNV, 2007). The outlook is GoG funding is minimal on the environment and rather on donor support. In such a situation, the relevance advanced for SEA can be short lived without political support. Fig 11: GoG Budgetary Allocation to EPA from Consolidated Fund ( ) GoG Budgetary Allocation to EPA from Consolidated Fund ( ) Years Amount Allocated Amount Released 12 Data source: from the Ghana Sector Study Synthesis (GESS) report prepared by SNV February

25 Chapter 4: Discussion 4.0 Introduction: As can be seen from the analysis, this study has provided significant insights into the state of stakeholder participation regarding the SEA of the Ghana Poverty Reduction Strategy. In particular it has uncovered important information about the elements of stakeholder participation as defined by the stakeholder framework for SEA participation. This section discusses these findings and their context. 4.1 Stakeholder Analysis: As mentioned in section 3.1, a wider stakeholder landscape has been achieved through the SEA/GPRS, however it was evident that an important stakeholder analysis had been omitted. The idea of participants and stakeholders had been presumed to be the same. In essence all those who participated were seen as stakeholders of same importance and influence. The presumption, however, that a participant is an automatic stakeholder would be critical issue that needs redress before undertaking an SEA. This is necessary because a poor understanding of the participatory processes underlying SEA could lead to poor outcomes. The challenge has to be; Undertaking a stakeholder scoping to determine the width and depth of participation as a wider process focusing on the issue at stake and the goal for participation. The preparation of an adequate stakeholder analysis where the necessary nodes of interest, role, capacity and rules are observed as critical inputs for success. Ensure that stakeholder processes are documented making evaluation and learning possible. Care must be taken such that participation is not taken as acceptance. 4.2 Processes for Participation With reference to Section 3.2 we can conclude that the SEA/GPRS process had built on existing political processes and institutional arrangements to facilitate national consultations under a top-down and bottom-up approach. The presence of a three tier national planning framework involving National, Regional and District levels of authority were used as vehicles for the process. The dilemma of the process, however, may dwell with the unevenness of capabilities at the levels. The challenge however is, where should capacity building begin in such a process? How can the line of authority or command relationship on an SEA process be void of conflicts? How can the often unfunded bottom-up units accommodate the usually funded top level authority especially in decentralizing SEA authority? Further conceptual and strategic clarification of the combined processes may be needed for replication. It may also be beneficial that stakeholders be engaged at the level that decision makers themselves believe will result in most suitable decisions. 4.3 Institutional Constraints: Whereas there was a general agreement that capacity of stakeholders is a prerequisite for the SEA participatory processes, Section 3.4 indicated a low capacity level, particularly for district 25

26 and grassroots stakeholders. Building capacity for governmental actors, civil society and the grassroots stakeholders involved in SEA implementation must be considered with some urgency because it is a key element for skill dissemination and effective implementation. The needed financial boost to support capacity cannot also be taken for granted. Section 3.4 also indicated the absence of necessary legal institutional framework for the implementation of SEA. Although institutional frameworks may not necessarily be a panacea for an effective SEA, its presence can influence government commitment. In the case of the SEA/GPRS, it is not very clear the extent to which the absence of legal framework may have affected implementation. Other complementary laws had been tapped to support the process. Also, the legitimacy of the SEA process should be discussed with regard to several aspects of its procedure. SEA may not attract the requisite legal instruments to adequately keep up with the slow moving pace of democracy, particularly in ensuring accountability along implementation. It might therefore be more useful for the SEA practitioners to consider sectors of strategic importance in the overall sustainability of the economy than a wholesale application of SEA to all sectors. 4.4 Mechanisms employed for Participation: With reference to the strategy section of the participation framework (figure 1), there are many mechanisms for engaging stakeholders in decision-making. With regard to the mechanisms employed for the SEA/GPRS, the study reveals that the traditional forms of participation were well established and used. Although an inform or consult style of information were applied, the introduction of some new tools such as the sustainability tools (Appendix I), compatibility tools (appendix II) and the compound matrix (Appendix III) indulged stakeholders to participate. The range of tools were techniques that support the gathering of data from stakeholders, tools that allow balanced and objective information to be shared and mechanisms for bringing people together for engagement and dialogue. It would be appropriate for techniques to be selected guided by the participatory objectives designed and the type of decision to be made. Primarily, simply questioning what tools are necessary to help share information, tools to gather and aggregate data, tools to allow interaction and within what prevailing democratic environment may provide a valuable insight into effective methods that can be applied in different contexts. Nevertheless, it would be very important for research to focus attention on the mechanisms presently being applied to SEAs. Ascertaining their effectiveness in paying attention to stakeholders interests in SEAs would help the selection of mechanisms and techniques for better SEA productivity. 4.5 Program Relevance Some international SEA/PRSP experts laud the SEA approach for having the potential to open up new windows for domestic public debate and civil society involvement. (OECD, 2005). A Member of Parliament puts it I was overwhelmed when I read the SEA report, there is such a gap missing on our environment in the GPRS. The SEA has shown us that environment is being considered in every single sector policy states the Minister of Interior in the executive summary of the SEA of the GPRS, Many officials and politicians have had their first experience of engaging directly with civil society organizations on matters of public policy through a national regional and district consultation process as a result of the SEA/GPRS process. However in concurrence of the majority of contributors some critics challenge the assumption that the SEA processes reinforce democracy and offer opportunities for broadening the public debate. Some civil organizations thought it was a highly manipulated form of public consultation, in which stakeholders were selected discretionary without considering the involvement of the vulnerable 26

27 groups and the private sector. The governments continued support not only by expressing its importance but supporting it with the necessary funding is crucial. 4.6 Criteria for good stakeholder participation process for institution based SEA. As can be seen from the above characteristics depicted through the SEA/GPRS, the lessons that may guide participation in policy based SEA may include: The use of a thorough stakeholder analysis that can prevent arbitrary selection of stakeholders. This will require a significant focus on the issue at stake, who the stakeholders are, what influence and role they play in the process, what is levels of capacity they are bringing, and what the prevailing institutional constraints are. The use of appropriate techniques, tools, and mechanisms that facilitate understanding and participation within the prevailing democratic culture. These tools must be effective in aggregating data to provide useful information to decision makers and also provide feedbacks to stakeholders showing how their contribution impacted decisions. The accompaniment of tools that track public expenditure and budget will be helpful. A supportive regulatory framework with some guidelines and principles. The political, legal and regulatory environments are key determinants of the extent to which institutional based SEAs can impact the environment landscape. Taking advantage of triggering mechanisms as vehicles for political support would be helpful. An effective monitoring and evaluation process that can facilitate new learning for improved practice. Feedbacks should be made available to stakeholders to ensure that lessons are considered and imputed into process. Governmental commitment to the SEA process both in funding and willingness to embrace participation into the general developmental framework will be necessary. 4.7 Weaknesses It is a very strenuous exercise since all the necessary stakeholders needs to be involved which may make the process inherently slow. Following through to end where decisions are fed back to stakeholders is a resultant challenge. Doubts about the process and its ability to address stakeholder s interest within an even playground may always be contested. The needed technical expertise of stakeholders and core SEA implementers may not be sufficient. There are limitations in resources to undertake a more detailed exercise such as funding, good information database and training. There is a lack of an overall feedback mechanism that can support evaluation and consultative responsibilities. Political commitment for institutional adjustments in practice will continue to be a challenge. 27

28 Chapter 5: Conclusions and Recommendations 5.1 Conclusions: This report broadly provides significant lessons for the involvement of stakeholders when applying Strategic Environmental Assessments. The intention has been to provide a starting point for a research interest to understand the relation between stakeholder participation and SEA policy formulation. It must however be highlighted that identifying stakeholders may not necessarily mean their interest will be heard and addressed accordingly. Thus, the paper ends with a few general conclusions, which could serve to guide further research on the topic. First it is essential to study who participates in the decision process and to analyze the power relations between actors. Secondly, it is important to consider the prevailing institutional constraints restricting the decision maker's ability to implement policy decision, and thirdly, the recognition of a participatory strategy that comprises the identification of mechanisms and techniques attentive to the needs of stakeholders and also can stimulate deliberations for effective policy formulation. It is therefore desirable that further research on the topic be directed at advancing knowledge on the interplay of the various elements identified within the participatory framework in order to fully utilize its potential for Policy based SEAs and the objective to mainstream environment into policies, programs an plans. 5.2 Recommendations: These findings lead to the following recommendations. It is recommended that, in order for SEAs to influence policy decision making: 1. Stakeholder processes must be carefully planned by particularly focusing on stakeholders that are likely to be affected by policy decisions. Identifying the key primary and secondary stakeholders and also understanding their interest and motivation in participating in the policy process is a key first step in the public policy making process. Adequately preparing a stakeholder analysis would prevent arbitrary selection of participants which most often result to the exclusion of vulnerable stakeholders. The emphasis should not only placed on broadening the stakeholder landscape but to purposely focus on the key stakeholders, their interest and their abilities to influence policies. 2. Understanding the political economy and the prevailing institutional constraints inhibiting the influence of stakeholders in public policy making is critical. Institutional and governance constraints can affect the legitimacy of SEA process is not addressed. This might come in the form of legal, capacity, political, historical or socio-cultural factors. Identifying these constraints supports the concept of recognizing prevailing institutional constraints when one is interested in studying how policy decisions are made. (Kraynor and Howard, 1997). Experience demonstrates that although the existence of formal rules or rules-in-form exist in the many policy making landscapes, they are most often overridden by rules-in-use which over the years have been embedded within the political economy of decision making. Setting participation benchmarks at this stage would be necessary. Benchmarks for stakeholdership drawing its authority from a 28

29 Public Involvement Policy would suggest to the drawing board the necessary ingredients for a desired output in SEA. Its productive support to monitoring and evaluation will be timely. 3. There must be a clear strategy for stakeholder participation that simply set out as an integral part of the overall planning and decision-making process. A review of varieties of mechanisms and techniques that can facilitate involvement in policy making must be carefully conducted. The use of a variety and combination of tools may also be required where necessary. Technical tools must be selected such that they deliver specific decision outcomes and should be arranged according to the contributions they can make. It is anticipated that tools selected would go beyond consultation to working towards collective agreements and actions. The inclusion of public budget and expenditure tracking tools to enhance capacities of stakeholders in pro-poor budgeting and expenditure would be opportune. These can ensure social accountability. Without understanding how budget and expenditure impact policy decisions can surmount a rather useful policy designed under SEA. This would represent an evolution of a new SEA culture which focuses on the priorities of wider participation and the equitable allocation of resources. These tools must be grounded in empirical evidence of what works and why. To this end, the academia and researchers in general could be encouraged to evaluate the trend, types, mechanisms and processes of participation that is being applied in country s programs and come up with best practices and innovations that could meet the needs and interests of stakeholders and by that level the participation playing field for SEAs effective operation. 4. A strong political commitment on the part of government to involve stakeholder in policy decision should be clearly demonstrated and supported by government. Since SEA requires a widespread involvement of stakeholders, policy makers and the wider public, many conflicting interest of stakeholders should be expected. It would be important for SEA to take advantage of prevailing triggering mechanisms that supports participation and can be used by politicians to support SEA. In the same vein, explaining clearly what SEAs are, in order to convince politicians, policy makers and decision takers in general could unravel and attract the needed political audience. Parliament therefore continues to become a key stakeholder whose active participation in ensuring funding and enforcing wider participation for SEA is ultimately necessary. Their role in bringing into the stakeholder landscape, the mass of the people, the private sector, CSOs and government actors cannot be underestimated. 29

30 Bibliography: Coppola, Nancy W. (1997) 'Rhetorical analysis of stakeholders in environmental communications: A model' in Technical Communications Quarterly, Vol.6, No.1: Dalal-Clayton, B. and Sadler, B. (2005) Strategic Environmental Assessment: A sourcebook and reference guide to international experience, Earthscan, London DFID Tools for development. A handbook for those engaged in development activity. Department for International Development. Duram, Leslie, and Katharin Brown Assessing public participation in U.S. watershed planning initiatives. Society and Natural Resources 12: Edward R. Kaynor, Irving Howards (1971). Limits on The Institutional Frame Of Reference In Water Resource Decision-Making. Journal of the American Water Resources Association 7 (6), EPA/NDPC, Strategic Environmental Assessment of the Ghana Poverty Reduction Strategy Report. Part iii. Government of Ghana (2005) The Budget Statement and Economic Policy of the Government of Ghana for the 2006 Financial Year. Accra. IFC (2007). Stakeholder engagement. A good practice handbook for companies doing business in emerging markets. World Bank. Maria do Rosário Partidário (2007). Strategic Environmental Assessment Good Practices Guide Methodological Guidance. Portuguese Environment Agency. Rowe G and Frewer L.J. (2004). Evaluating public-participation exercises: a research agenda. Science, Technology and Human Values, 29(4): Roberts, Richard. (1996). Public Involvement: From Consultation to Participation. In Environmental and Social Impact Assessment, Frank Vanclay and Daniel A. Bronstein, eds. New York: John Wiley & Sons: Sevaly, S Involving stakeholders in aquaculture policy-making, planning and management. In R.P. Subasinghe, P. Bueno, M.J. Phillips, C. Hough, S.E. McGladdery & J.R. Arthur, eds. Aquaculture in the Third Millennium. Technical Proceedings of the Conference on Aquaculture in the Third Millennium, Bangkok, Thailand, February pp NACA, Bangkok and FAO, Rome. SNV (2007). Ghana Environmental sector Study: Synthesis report. Accra, Ghana Steelman T. A., and Ascher W (1997). Public involvement methods in natural resource policy making: Advantages, disadvantages and trade-offs. Policy science, 30:71-90 UNEP Environmental Impact Assessment and Strategic Environmental Assessment: Towards an Integrated Approach. First edition Videira N., Antunes p., & Lobo G. (2006) Public and stakeholder participation in European water policy: a critical review of project evaluation processes. European Environment Volume 16, Issue 1, Pages

31 World Bank, (2005). Integrating Environmental Considerations in Policy Formulation. Lessons from Policy based SEA, Report No , World Bank. 31

32 ANNEX I Sample of Sustainability Test Sheet Source: SEA Manual (EPA, Ghana) 32

33 33

34 34