20 Achievements In 20 Years: ECAS 1991-2011
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Transcript of 20 Achievements In 20 Years: ECAS 1991-2011
20 Achievements in 20 Years: ECAS 1991 - 2011
Author: Tony Venables
Editor: Elisabeth Victoria Lasky
ISBN: 2-87451-017-3
This document is copyright of ECAS ©ECAS 2011. All rights reserved.
Any redistribution or reproduction of part or all of the contents in any form is prohibited other than
the following:
• you may print, copy or download to a local hard disk the file for your personal and non-
commercial use only;
• you may copy the content to individual third parties for their personal use, but only if you
acknowledge the authors as the source of the material
You may not, except with the express written permission of the author, distribute or commercially
exploit the content.
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1
A foreword to
20 Achievements in 20 Years
In this document, we highlight 20 achievements by ECAS over the last 20 years in the context of our
programme under three C’s: Civil society development, Citizens’ rights, Citizenship and governance. A few
things stand out:
- ECAS has helped create new European associations and networks and improve access to the EU
for non-profit organisations;
- ECAS has been a pioneer in European participatory projects starting with a hotline for citizens,
and a key stakeholder on ways to improve the communication channels between citizens and the
EU institutions, bringing both of them closer together;
- ECAS is a distinctive and rare European association because it is directly accessible to citizens;
- ECAS has stood at the forefront of promoting citizen friendly institutional and Treaty reforms,
such as the general anti-discrimination clause and better standards of consultation;
- ECAS has advocated in support of enlargement and civil society in candidate and neighbouring
countries, particularly in relation to its Ljubljana declaration;
- ECAS has created the European Civil Society House which is about to take on its first virtual
existence as a one-stop shop for citizens.
Nevertheless, an anniversary as just being a celebration is a wasted opportunity. Looking back raises
questions for the future, which we ask you to consider. After our 20th
anniversary event on 1-2 September
2011, our Board of Directors and members will carry out a brainstorming session on the future activity of
ECAS. Please help us get started by sending your comments on ECAS’ 20 achievements and answering one
or more of the questions in the document.
Acknowledgements of support
ECAS would not exist and none of these achievements would have occurred without our funders. The
organisation was founded by the Joseph Rowntree Trusts in York with a campaigner Des Wilson playing a
prominent role. The Joseph Rowntree Charitable Trust has remained a supporter of many projects, not
least the European Civil Society House. A 10th
anniversary grant allowed ECAS to develop a capacity for
policy research. Two other foundations have played a prominent role: the MOTT foundation which for 6
crucial years in the run-up to the most recent enlargement funded the Information, Training and
Scholarship (ITS) programme. Compagnia San Paolo supported the COOPERATE programme which shifted
the training emphasis for new member states towards the structural funds and inspired ways of securing
access to these funds for CSO’s in new member states.
A constant asset for ECAS has been the support of the European Commission. This began with the
Secretariat General providing a core grant and the then Social Economy Unit which helped to launch
projects such as the first citizens’ week. Currently, the two main sources of funding are the Europe for
Citizens’ programme which provides a three-year strategic partnership grant and Your Europe Advice,
which is different in being a service contract to advise 12,000 citizens of their European rights. Although
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ECAS has often been critical of the Commission (generally for not being more assertive or not doing
enough to promote European citizenship), the relationship has been positive, allowing for more flexibility
and independence of action than is generally thought possible with European projects.
Finally, there is a huge in-kind contribution. ECAS has attracted a number of volunteers, most recently
in relation to the European Civil Society House – a project which particularly appeals to the young
generation. The EU Institutions and in particular the Economic and Social Committee have often stepped
in and provided logistical support. In the European Parliament, Jean Lambert MEP has done this several
times for meetings in Strasbourg on the ECAS report “Who’s afraid of EU Enlargement?”
It would be wrong however to give the impression that this kind of support is just to meet basic
needs. The ECAS Board of Directors provides significant, creative input and help with fundraising. For
example, Michael Brophy, when Chairman, took the organisation through a reassessment which resulted
in the three Cs. Many students have written or contributed to ECAS publications especially when linked to
their own post graduate studies. Sometimes in kind support goes beyond what the ECAS can do itself.
Freshfields Bruckhaus Deringer takes on more difficult cases to defend European rights and helped shape
the report “Mind the gap”. Deloitte has also provided advice and produced a business plan for the
European Civil Society House.
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Twentyyearsofachievements:
ECAS1991-2011
1. Enabler of access to EU funding
2. Creator of new European associations and networks
3. Promoter of partnership with civil society in EU Cohesion and pre-accession funds.
4. Builder of civil society capacity linked to EU enlargement
5. Advocate of an EU open to all civil society organisations
6. Inventor of the European hotline and manager of the largest single European advice service
7. Supporter of the high level panel on free movement of persons
8. Proposer in Mind the gap: towards better enforcement of European citizens' right to free
movement
9. Coordinator of innovative projects to support a one-stop shop for free movement of people
within the EU
10. Convener of the European Forum of Citizens' Advice Services
11. Campaigner against a two-speed Europe for citizens, ECAS keeps asking "Who's afraid of EU
enlargement"?
12. Campaigner against visa requirements for candidate and neighbouring countries
13. Promoter of Treaty reforms: bringing the EU closer to the citizen
14. Supporter of better European governance and standards of consultation
15. Advocate of freedom of information and the access to documents regulation
16. Promoter of a new right to information so that citizens know about their European rights and
activities
17. Participant in the European Citizens’ Consultations
18. Promoter of the European citizens' initiative (ECI)
19. Promoter of European citizenship
20. Inventor of the European Civil Society House
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C1.CivilSociety
1. Enabler of access to European funding. The ECAS guide to European Union funding,
now in its 17th
edition has enabled hundreds of CSOs to access EU funding with the use of more
hands-on advice. The guide includes tips, a summary of EU Commission contacts, grants and
programmes, both within and outside the Union, as well as chapters on Cohesion policy and the
foundations supporting European activity. The 200 page book has been revised and published
annually since 1993 without interruption.
For its members, ECAS offers an attractive package. For instance, for just 50 euros as a “friend
of ECAS”, a copy of the funding guide is accompanied by monthly up-to-date news from the EU,
calls for tender and proposals, events, and summaries of policy developments.
2. Creator of new European associations and networks. In its early days with the
expansion of Treaty reforms and EU activities into new areas of interest to civil society, ECAS
provided premises and helped to establish a number of European associations in areas such as
culture, health or citizens’ advice. A first “citizens’ week” of conferences held in September 1991
led to such initiatives and in particular to the creation of the “European Public Health Alliance”
(EPHA) and the “European Forum for the Arts and Heritage” (EFAH), now called “Culture Action in
Europe”. At this time helping fill gaps in the representation of CSO’s at European level also meant
for ECAS helping them fill corresponding gaps in the EU budget- ECAS lobbied the European
Parliament which adopted budget amendments for cultural organisations and for those in the
social economy.
In the early days, a number of European associations which are now fully independent began
in Brussels with a Euro-secretariat arrangement with ECAS: ECRE, Save the Children and Eurolink
Age. Most civil society sectors are now represented at EU level, so there is less need for this social
entrepreneurial activity.
Q1. European funding is still too much for “insiders” even in a period of
economic downturn and cuts in national budgets when the EU budget
remains a relatively safe haven. Why? Are the rules too complex? Or should
ECAS make more effort to promote agreements for different language
versions? How is it possible to create a help desk with significantly more
outreach as part of the European Civil Society House?
Q2. Is the issue now to bring together and encourage more sharing of
premises and facilities among existing European associations? Could the
European Civil Society House be a response to this?
5
3. Promoter of partnership with civil society in EU Cohesion and pre-
accession funds. Early on, ECAS created a coalition on the structural funds and has helped
successfully to enlarge the partnership principle to include civil society in the regulations. The title
of an ECAS publication “The illusion of inclusion” sums it all up, stressing the difficulty of achieving
real partnership.
The COOPERATE programme, bringing together in a training programme CSOs and officials
from new member states, was a response to the needs of capacity building and cross-sectoral
partnership. More recently, a forum held during the Open Days for Cities and Regions has been
an opportunity to gather the evidence of how partnerships are working and to make
recommendations. ECAS should react to the legislative proposals for the Cohesion policy 2014-
2020 and review its activity within this new context.
4. Builder of civil society capacity linked to EU enlargement. ECAS ran for several
years the ITS or “Information, Training and Scholarship Programme” which was a structured
approach to training a selected group of CSOs on EU accession in candidate countries, then
bringing them on study visits to Brussels and finally hosting individual “scholars” for a month. This
led to helping with the setting up of the Polish NGO office and more recently the office for the
Civil Society Development Foundation and the IMPACT centre in Croatia. An even wider impact
has been achieved by the 10 point Ljubljana declaration of April 2008.
5. Advocate of a European Union open to all civil society organisations. In the
“Commission’s relations with NGOs” and other publications and conferences, ECAS was always an
advocate of open dialogue to reach out beyond Brussels “insiders”. Policy research for our 10th
anniversary had an influence on the debate on European governance and the Commission’s
consultation standards of December 1992. ECAS has recently updated a 2008 study on framework
agreements (compacts) between civil society organisations and public authorities in cooperation
with the ENNA (European network of national associations). The outcomes of the research show
that compact-like agreements are the best, most modern forms of open agreements between
governments and CSOs.
Q3. Is there not a tendency for CSOs to compete for small European funds
and ignore the millions of unspent social and regional funding in their
country? To whaty extent sould access to cohesion fuding be a priority for
ECAS?
Q4. Would it be a good idea to examine the strengths and weaknesses of
civil society development and the implementation of the Ljubljana
declaration?
Q5. Could there be a framework agreement between the EU and civil
society as a way of implementing Article 11 of the Lisbon Treaty on
participatory democracy?
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C2.Citizens’Rights
6. Inventor of the European hotline and manager of the largest single
European advice service. ECAS hotlines on visible and hidden barriers to free movement
started on 1 January 1993, making a huge impact as the catalyst for the Commission to launch the
“Citizens’ first” communication campaign. ECAS ran the “Citizens’ Signpost Service” for 9 years,
which consisted of a multilingual team that expanded to 60 legal experts from all over Europe
answering about 10-12,000 questions a year. Recently, the contract has been won to run the
service, renamed “Your Europe Advice” (YEA), for another 4 years. ECAS has a highly experienced
and well qualified team covering all languages and all aspects of free movement of people which
has helped thousands of citizens assert their European rights. This is a high profile project with a
good working relationship with the Commission (DG Markt).
7. Supporter of the high level panel on free movement of persons. The 100 page
report of this panel was chaired by Simone Veil, who was ECAS’ first President, and it was
presented in March 1997 to the Commission. Tony Venables, ECAS Director, contributed actively
to this report, for example by drafting the executive summary and highlighting evidence from the
hotline on barriers to free movement.
The panel’s work raised the profile of issues surrounding free movement of people which
made 80 recommendations to remove the barriers. The report of the panel helped bring together
evidence scattered across Commission departments and policy recommendations, paving the way
for a number of legislative reforms. It resulted in more general legislation on free movement and
residence, recognition of professional qualifications and an updated regulation on the co-
ordination of social security arrangements for migrant workers and their families. The panel
provided an opportunity to create a clearer focus to the free movement of persons and its report
set the agenda for further legislation.
Q.6 As with all advice services, the questions are: how to promote the Your
Europe Advice service? How to use the evidence and produce more
feedback reports? and how to follow up more serious complaints where
advice is not enough?
Q7. Is a new panel on free movement of persons needed to examine how
well the legislation is being applied? At a time when free movement of
persons within the Union is less popular and directly under threat with
attacks on the Schengen Area, could the answer be affirmative?
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8. Proposer in Mind the gap: towards better enforcement of European
citizens' right to free movement. With extensive experience as an advice service for
European citizens, ECAS is acutely aware of the continuing obstacles to residence, transfer of
social rights, recognition of qualifications and the new emerging problems of cross-border family
law. There is a growing gap, apparent to increasingly aware citizens, between the fine principles
of the Treaty, the Charter of Fundamental Rights and the judgements of the European Court on
the one hand and on the other what happens on the ground.
A first study was completed in early 2009 for the European Parliament on the implementation
of Directive 2004/38 the so called “citizenship directive”, which was followed by a new initiative.
A high level panel chaired by Sir David Edward, former judge at the European Court, produced a
report on how to enforce European rights more effectively.
The “Mind the Gap” report is being followed up by a second report prepared by Freshfields,
Bruckhaus and Deringer on how to increase Commission powers of enforcement. This new
document will be presented at the 20th
anniversary conference on 1-2 September 2011. The high
level panel’s 10 recommendations are realistic, readable and have been well received.
9. European coordinator of innovative projects to support a one-stop shop
for free movement of people within the Union. Following its European hotlines,
ECAS was a leading participant in the 2006 European Year of Workers’ Mobility with the then
ECAS president Mario Monti participating in the opening conference and other activities. For the
year, ECAS partnered with advice services to run a project on the impact of enlargement on free
movement of people. It was followed by a second project, the “one-stop mobility shop” under the
“Progress” programme. More recently, a staff exchange scheme among advice services following
migration flows called “Flowchart” has been completed and a charter circulated. These projects
were designed to test out the idea of the one-stop shop particularly at local level and for the EU’s
most vulnerable migrants. However, to be really effective there should be a shared responsibility
among countries of origin, countries of destination and the EU budget.
10. Convener of the European Forum of Citizens’ Advice Services. ECAS has
always advocated for European level information and advice services, whilst recognising that
Q8. For better enforcement, political will is needed, but is lacking. The
Roma affair of summer 2010 highlighted the issues of enforcing European
citizens’ rights, but in general they receive little support and are not in the
public eye. How should ECAS promote an enforcement culture?
Q9. Could such projects linking local grassroots migrants’ advice services
and bringing them together at European level be scaled up in EU Cohesion
policy?
8
these will always be “a drop in the ocean” in comparison to the actual needs of citizens. To meet
the needs, national advice services need to be assisted in building the capacity to deal with the
10% of citizens’ queries and complaints which have a cross-border dimension and impact on
European rights and legal rules. This is why ECAS, since 2000, has been active in convening
practically every year a European Forum of Citizens’ Advice Services. This is an opportunity for
dialogue among advice services themselves on new challenges -such the debt crisis- and new
ideas –such as the one-stop shop, which came from the forum. The forum also led to the creation
of a more permanent structure, “Citizens Advice International”, in which ECAS played a leading
role.
11. Campaigner against a two-speed Europe for citizens, ECAS keeps asking
“Who’s afraid of EU enlargement?” Despite scaremongering about the “Polish
plumber”, the actual impact of enlargement on free movement of people overall in the EU has
been relatively neutral, and more significant in certain countries with more open labour markets.
ECAS produced a series of reports measuring the actual impact of the 2004 enlargement on free
movement. These attracted widespread press coverage and were a factor in arguing the case for
a rapid phasing out of transitional arrangements for workers from new member states. Jean
Lambert MEP became our interlocutor in the European Parliament by hosting a regular meeting
at the September session where the reports were presented. These reports were a great success
for ECAS. With the end of transitional arrangements except for Bulgaria and Romania, this activity
proved to be successful.
12. Campaigner against visa requirements for candidate and neighbouring
countries. ECAS has consistently maintained a position of insisting that free movement of
people within the EU should not occur by creating a “fortress Europe” at the external borders. In
2009, a high profile hotline launched simultaneously in 5 Western Balkan countries under an ECAS
project demonstrated convincingly the case for visa liberalisation instead of mere facilitation. The
results of the hotline and a survey were brought together at a conference in Brussels with EU
policy makers. Except in the case of Kosovo, a visa-free regime has been achieved for the Western
Balkans. The same cannot be said for Turkey and the takeover of the hotline run with our partner
IKV in 2010.
Q 10. From the European Forum of Citizens’ Advice Services, it should be
possible to create a network of advisors, advocates and researchers on free
movement of people. How to find the support and resources for such a
task?
Q 11. Could it be useful to look at the impact of Croatia and other Western
Balkan countries on free movement of people when they join the European
Union?
Q 12. The visa hotlines were using similar techniques to the ECAS hotlines
of the early 90s at the start of the single market and the Schengen area.
How is it possible to translate this kind of bottom-up pressure into results
in the case of Turkey?
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C3.CitizenshipandGovernance
13. Promoter of Treaty reforms: bringing the EU closer to the citizen. ECAS has
produced several publications on Treaty reforms, but has done more than carry out this didactic
function1. It is difficult to assess the impact of this activity which might initially appear theoretical.
On the other hand, understanding the scope and limits of the Treaties is fundamental to any
European strategy and Treaty reforms have been a mobilising factor for civil society over the last
20 years.
Early on, a coalition was created called VOICE (Voluntary organisations in a citizens’ Europe)
bringing together a number of civil society demands for revision and experiences of competences
in the new Treaty of Maastricht. By organising on 6-10 September 1993 a second citizens’ week
demanding a ban on all forms of discrimination not included in the Treaties -whether on the basis
of race, disability, sexual orientation or age, ECAS was instrumental in first presenting the idea of
a general anti-discrimination clause which became article 13 in the Treaty of Amsterdam.
14. Supporter of better European governance and standards of consultation.
In the early 90s, the European Commission launched a major internal and external consultative
exercise and a white paper on European governance in which ECAS was a leading stakeholder.
ECAS carried out policy research and organised conferences on the Commission’s relations with
NGOs. With their emphasis on openness to all opinions, including minority interests, and their
rejection of an over institutionalised and rigid approach, these conferences had a positive
influence on the Commission’s consultation standards of December 2002.
The consultation standards were seen as a way of increasing the involvement of civil society
in policy development, making it an instrument of participatory democracy. They have however
become (with some exceptions) a much more technical instrument for better regulation linked to
impact assessments.
1 In the run-up to the ratification of the Maastricht Treaty, ECAS produced an analysis of the new Treaty. Tips for
the would-be Euro-lobbyist and lobbying after Maastricht – were produced. An analysis of the next Treaty revision at
Amsterdam was published under the heading “The Treaty of ambiguity”. On the Constitutional Treaty, ECAS
followed the work of the Convention, and produced a “50 questions and answers” analysis. During Mario Monti’s
ECAS presidency, a series of meetings took place in member states holding a referendum or likely to do so. After the
rejection of the Treaty in the French and Dutch referenda, ECAS produced a 25 question and answer analysis “What
way out of the Constitutional impasse?” For the anniversary of the founding Treaty in 2007, ECAS produced “50
questions and answers on the Treaty of Rome”.
Q 13. In some respects, the Lisbon Treaty takes the EU closer to citizens and
in others further away. Would it be useful to organise an event on the
Lisbon Treaty?
10
15. Advocate of freedom of information and the access to documents
regulation. Since its beginnings, ECAS has followed the development of more transparency in
EU documents. Following a declaration attached to the Maastricht Treaty, the development of
codes of conduct and of the European ombudsman’s role, an article was added to the Amsterdam
Treaty and a regulation adopted. In September 2006, ECAS published the report “Should there be
a freedom of information act for the EU?” which analysed the case-law of the European Court and
the application of the regulation. This was the basis of a conference organised with the Swedish
Presidency at a time when revision of the regulation was being discussed.
ECAS has also used the regulation to good effect, for example to obtain publication of the
agenda and minutes of the Presidium of the Convention on the future of Europe. This work will
be taken up and developed as part of the one-stop shop for citizens using the European Civil
Society House (see 20 below).
16. Promoter of a new right to information so that citizens are informed
about EU rights and activities. In the wake of the rejection of the Constitutional Treaty,
the Commission launched a white paper on European communication policy. ECAS’ response was
to update an earlier study under the title “Connecting with Citizens: does the EU have the will to
tackle its information deficit?” The report analysed the results of referenda on the Constitutional
Treaty, accession to the EU and European elections. It proved that there is a link between lack of
information and low turnout, for example in elections to the European Parliament. Amending the
Treaties to include a right to be informed was a proposal taken over by the Commission and the
European Parliament, but has not yet found sufficient support with governments.
The issues of information and communication were a high priority during the constitutional
crisis. ECAS organised conferences with Margot Wallström, the Commission Vice President,
gathering on occasions more than 600 participants.
Q 14. Feedback for organisations participating in consultations remains
weak even though there is a report on the results of some consultation
exercises. Should ECAS revisit this issue and push for more inter-
institutional and multi-level governance on the basis of article 11 of the
Lisbon Treaty?
Q 15. How to make the EU regulation on access to documents more popular
and not just a tool for lobbyists?
Q 16. Whilst the absence of communication and information campaigns is
regularly deplored – for example in relation to the new European right to
propose an initiative – it is curiously absent from the political agenda. What
should be done to bring this issue, which concerns everyone and no-one,
back on the agenda in time for the next elections to the European
Parliament? How should we promote a right to be informed?
11
17. Participant in the European citizens’ consultations. As an organisation which had
experimented with hotlines and published policy research on EU information and communication,
it was natural for ECAS to become involved as one of the European partners of the King Baudouin
foundation with the “European Citizens’ Consultations” (ECC). This was part of the “Plan D for
Democracy, Dialogue and Debate”. ECC broke new ground, because for the first time citizens
gathered in all 27 member states to establish an agenda of EU priorities and then presented them
at a final event in Brussels. ECAS contributed by shaping partnerships, steering outreach activities
as well as organising a follow up conference with EU policy makers.
In 2009 – 2010, ECAS organised its own citizens’ panel project in four countries with input
from experts and a final European event resulting in the publication “How the participatory
Toolbox can make the European Union less remote from Citizens”. Despite extensive evaluations
and the success of ECC and other projects in demonstrating that citizens can engage with
European issues and the complex EU environment, there has been no real follow-up to plan D.
Citizens’ panel projects still continue under the “Europe for Citizens” programme and there are
other initiatives, for example to gather input from citizens on options for scientific research. But
these are still limited experiments.
18. Promoter of the European citizens’ initiative (ECI). ECAS has been involved with
getting European citizens’ initiatives (ECIs) on the agenda, whereby over 1 million people can
demand European legislation. This began with policy research in 2004, which advocated for
example that the organisers of a citizens’ initiative should have a hearing with the European
Parliament and Commission, a demand successfully repeated in the run-up to the adoption of the
regulation. After contributing actively to the consultative process on the adoption of the
regulation, ECAS organised the first major European event to coincide with the publication of the
regulation in March 2011.
19. Promoter of European citizenship. ECAS activities come together round the concept of
European citizenship. In parallel to the Convention on the future of Europe, ECAS produced a
collection of essays by leading academics under the title “Rethinking European Citizenship” and
has produced model drafts for strengthening and extending this concept in successive Treaty
Q 17. There is no mainstream mechanism for citizen participation across
policy areas. Above all questions of cost are invoked, even though the costs
of not involving citizens could be higher. How to convince the Commission
and other Institutions to build upon plan D?
Q 18. Ideas have been put forward for support mechanisms for initiators of
ECIs. The plan is to continue this activity in 2012 with training and
awareness-raising through a help desk in the context of the European Civil
Society House. To what extent will this be the foundation of the house?
12
revisions. In projects and conferences such as “Searching for Cinderella”, ECAS has also drawn
attention to the importance of the case-law of the European Court of Justice. An alternative
report to the Commission’s Fifth Report on Citizenship of the Union was produced and a
complaint sent to the European Ombudsman about lack of consultation. There was consultation
by the Commission on the 6th
report, which was also more substantial than its predecessors. One
next step for ECAS is to produce a book on European Citizenship.
20. Inventor of the European Civil Society House. ECAS is setting out to create a
European Civil Society House in order to bridge the gap between citizens and the EU Institutions
in the interests of both. Among all the prestigious institutional buildings, agencies and 15,000
lobbyists around the EU, citizens should have their own space. This should take first the form in
2011 of a virtual house, accessible from anywhere in the EU and neighbouring countries through
the online platform citizenhouse.eu. This will bring together in a one-stop shop five ways for
citizens to defend their European rights and make their voice heard: complaints to the
Commission, access to documents, petitions, requests to the European ombudsman and citizens’
initiatives. The physical house should bring together associations particularly in the areas of
human rights and democratic participation, but that will take more time to set up.
A survey has been conducted in which more than 92% of respondents are in favour of the
creation of the Civil Society House and in the European Institutions, there is significant support for
this mechanism. Viviane Reding, Vice President of the European Commission responsible for
justice, fundamental rights and citizenship has highlighted the need to make the visitors’ centre
more available to civil society. In the European Parliament a budget line has been created and
cross-party political support has increased.
Q 19. ECAS has long advocated a less fragmented approach to citizenship of
the Union by the European Commission. This was reflected in the
appointment of Viviane Reding in the current Commission as Vice-
President responsible for Justice, Fundamental Rights and Citizenship. How
to promote European citizenship further for the European Year of the
Citizen in 2013?
Q 20. The ESCH has the potential to make a difference. If set up not only in
Brussels but also across the member states, it will reduce the gap between
the EU and the citizens. Should ECAS continue to pursue this venture as its
no. 1 priority?