To: FCCC

Who should be allowed to participate?

Mechanisms for Consultations with

Non-Governmental Organizations

The reflection within the secretariat on the relationship between non-governmental organizations (NGOs) and the Convention process, notably on the principles governing the participation of NGOs, comes immediately after the first appearance of eco-logic Bonn, during AGBM 6, published by Sovereignty International especially for the delegates to the AGBM negotiating sessions. The timing of the "reflections within the secretariat" in relation to the appearance of our publication may be coincidental, but in any event, provides an excellent opportunity to address and clarify the principles and procedures for NGO participation.

Article 7.6 of the FCCC assures that NGOs which "are qualified in matters covered by the Convention" may participate as observers, "unless at least one-third of the Parties present object," a barrier which has never been raised. Since the Convention fails to define or specify exactly what is meant by "qualified in matters covered by the Convention," the Secretariat is free to set whatever qualifications it wishes. If there is a single foundational principle governing all UN and FCCC activities, it surely must be transparent, democratic processes. With that principle as a guiding objective, the questions raised by the Secretariat in FCCC/SBI/1997/14/Add.1, (June 11, 1997) become more focused.

The question of "relevance to the Convention" raised in paragraph 3 of the June 11 document, is hardly relevant at all. Since the FCCC affects virtually every person on earth, every person on earth has the right to be represented in the process. Representation does not occur by simply allowing a representative to "observe." Representation occurs when the ideas, views, and comments of the represented constituency are effectively transmitted to the policy makers. This is the function of ECO, published by the Climate Action Network (CAN), our publication, and the numerous other publications at each of the negotiating sessions.

The question of "constituencies" is extremely relevant (paragraphs 5 and 6). The three identified constituencies, (1) environmental, (2) business and industry, and (3) local government and municipal authorities, hardly represent the vast array of people who are "qualified in matters covered by the Convention." Therefore, the Secretariat's conclusion is correct: that the present process does not "accommodate the diversity of groupings or of the opinions held." To have a truly democratic process, it is essential that the diversity of groupings and opinions have access to the process.

Sovereignty International brings a diverse constituency -- one of the most important constituencies -- consisting of the people whose behavior will be forced to change in order to pay the cost of reaching the objectives of the Convention. This constituency is quite diverse in its groupings, including organizations that represent ranchers, loggers, and farmers, as well as organizations that focus on education, population control, land use planning, and public policy institutes. Our constituency, while primarily in the U.S., is rapidly growing in other countries which now include Australia, Canada, England, Germany, the Netherlands, Kuwait, and Thailand. Unless those who must be governed by, and pay for the policies created by the Convention are deemed unqualified "in matters covered by the Convention," Sovereignty International brings the diversity the democratic process demands.

"Should there be a more transparent procedure to ascertain and place on record the nature of participating NGOs: what are their aims, who are their members, and by whom are they funded (paragraph 11)?" The procedure should be as transparent as the Secretariat can afford -- but the procedure should be applied equally to all NGOs -- those with existing accreditation as well as those that come in the future. Our "aims" and our "members" were required with our application. Was not the same requirement imposed on NGOs in the past? Our tax returns are a matter of public record, as are all other American NGOs. Why should the Secretariat spend additional dollars seeking information that is already available, unless, of course, it is to obtain the same financial records from those NGOs located outside of the United States.

"Should accreditation procedures require NGOs to declare support for the aims of the Convention (paragraph 12)?" If the "aims" of the Convention are limited to Article 2 "stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system," then few would hesitate to embrace the aims of the Convention. If, on the other hand, the declaration of support requires support for each and every decision made by the delegates and the Secretariat, then there is no need for NGO participation at all. Policies might as well be written by the staff and rubber-stamped by the delegates.

A requirement for a declaration of support for the aims of the Convention, is on its face, a rebuke of the democratic process. Such a requirement would be prima facia evidence that the FCCC welcomes only agreement and banishes dissent. It would be difficult, indeed, to claim a transparent and democratic process if all those who may have a different point of view are not even permitted to observe the process. Moreover, dissent can be an extremely valuable ally for the aims of the Convention. Dissent may slow an imprudent rush to judgment. Dissent may actually produce a new, or better idea. Dissent is the abrasion that polishes policies in preparation for eventual acceptance by the people who must be governed by them. We strongly recommend that any move to require a "declaration of allegiance" be rejected.

Whatever the procedure for accreditation, it should apply equally to all NGOs. If new requirements are imposed, they should apply to those NGOs that have received accreditation as well as those that may come in the future. Accreditation policies should seek inclusion, not exclusion. Access and participation policies should apply to all NGOs equally. Transparency and democracy demands equal treatment for all.

Thank you,

Sovereignty International Incorporated,

Michael S. Coffman, Ph.D.,

Chief Executive Officer

Henry Lamb,

Chairman of the Board of Directors

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