69079
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, 2007.
TABLE OF CONTENT
Acknowledgements
Executive Summary
Abbreviations and Acronyms
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CHAPTER 1: INTRODUCTION
Project Background
Objectives of Study
Scope Study
Report Organization
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CHAPTER 2: METHODOLOGY
Project Context
Identifying case study
Analytical framework
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CHAPTER 3: FINDINGS
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CHAPTER 4: DISCUSSION
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CHAPTER 5: CONCLUSION AND RECOMMENDATIONS
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BIBLIOGRAPHY
ANNEX 1: Sample of EPA/NDPC Sustainability Test Sheets
ANNEX II: Sample of the EPA/NDPC Compound Test Sheet
ANNEX III: Sample of the EPA/NDPC Compatibility Matrix Sheet
ANNEX IV: Consultancy Terms of Reference
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31
34
35
36
Representativity of SEA/GPRS
SEA/GPRS Process
Mechanisms employed for Participation
Institutional Constraints
Programme Relevance
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 (2002-2006)
2
ACKNOWLEDGEMENT:
3
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
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
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
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
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 2006. 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
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
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.
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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
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
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.
STRATEGY
CAPACITY
Are there strategies to generate interest,
build capacity and relationships in all facets
of participation?
Do they have capacity to
participate and what
influence do they exert?
MECHANISMS
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
ROLE AND
INFLUENCE
What roles do they play
and what contributions do
they make?
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
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


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
CHAPTER 3: FINDINGS
The main findings of the study include the following:
3.1 Representativity of SEA/GPRS Process:
With reference to the 2framework 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
7%
2% 5%
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%
EPA
RCC
SEA Team
Consultants
DA Officials
87%
2
Stakeholder Participation Process Framework
15
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
B
(Vulnerable groups)??
NGOs, CSOs,
Consultants
SEA Team, NDPC,
EPA, MEST, MMDAs,
MOF, Donors,
(Private Sector)??
High Importance
/Low Influence
C
High Importance/
High Influence
D
Ministers
Low Importance
/Low Influence
Low importance/
High Influence
Stakeholder
Importance
to GPRS
Influence
on GPRS
Interest in
GPRS
MDAs
4
5
+
MMDAs
4
5
+-
CSOs, NGOs
5
5
+-
Ministers/Politicians
2
5
+
Donors
4
5
+
Consultants
5
2
+
Private Sec.
?
?
?
Vulnerable groups
?
?
?
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
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 20044. 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
Determine the main interventions
of the GPRS
The participatory
process of
undertaking an
SEA
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
3
Output: SEA report that
indicates environmental
impacts, opportunities
and institutional issues
EPA/NDPC SEA Content Report 2004. The report discusses the content designed in the SEA/GPRS under the GPRS 1.
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.
4
17
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, 2004
3.3 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 5SEA tools,
Tools developed by EPA. Sustainability Test, Compatibility Test and Compatibility Matrix Sheets. Attached as Appendix I, II,
and III.
5
18
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




Briefings
Mailing out
Presentations to
technical groups
Consultations (formal
and informal)
PARTICIPATION/ENGAGEMENT








Advisory groups
Key person interviews
Focus group
Interviews
Seminars
Meetings
Forum
Workshops(National,
regional, District levels)
TOOLS/TECHNIQUES







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
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 requirements6. (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
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. http://www.oneworldtrust.org/documents/Beyond%20top%20down%20stakeholder%20engagement.PDF
7The SEA of GPRS. Content report Part III by EPA/GPRS, 2004.
6
20
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
Source: EPA/NDPC, Content Report 2004
Breakdown of Natural Resource Based Policies
No. of Policies
10
8
6
No of Policies
4
2
0
Macro Economic
Production and
Human Resources
Vulnerable and
gainful
and Basic
Excluded
employment
Services
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 exercise10. 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 citizens11. Although these laws are
expected to enable an active stakeholder participation in policy decisions making, it is however
1992 Constitution of Ghana Article 37
1992 Constitution of Ghana Article 35
10
EPA EA Regulation LI 1652
11
Local Government Act, 1993 (Act 462) The Local Government System in Ghana
(http://www.clgf.org.uk/index_profiles.htm)
8
9
21
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
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 2003. 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, 2003.
Ev aluation of Measures by Districts to improv e PPPs
9%
24%
Strongly pro-poor, pro env ironment
Moderately pro-poor, pro-env ironment
Weakly pro-poor, pro-env ironment
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 10th November 2005. 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
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 2002-2006 (excluding IGF and
donor funds) significantly dropped from 6.47 billion in 2005 to 4.60 billion cedis in 2006. 12(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 (2002-2006)
GoG Budgetary Allocation to EPA from Consolidated Fund
(2002-2006)
Amount in billions (cedis)
9
8
7
6
5
Amount Allocated
4
Amount Released
3
2
1
0
2002
2003
2004
2005
2006
Years
12
Data source: from the Ghana Sector Study Synthesis (GESS) report prepared by SNV February 2007.
24
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
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, 2003. 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
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
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
“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
Bibliography:
Coppola, Nancy W. (1997) 'Rhetorical analysis of stakeholders in environmental
communications: A model' in Technical Communications Quarterly, Vol.6, No.1: 9-25.
Dalal-Clayton, B. and Sadler, B. (2005) Strategic Environmental Assessment: A
sourcebook and reference guide to international experience, Earthscan, London
DFID 2002. Tools for development. A handbook for those engaged in development activity.
Department for International Development.
Duram, Leslie, and Katharin Brown. 1999. Assessing public participation in U.S.
watershed planning initiatives. Society and Natural Resources 12:455-67.
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), 1117–1127.
EPA/NDPC, 2004. 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):512-557
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: 221-248.
Sevaly, S. 2001. 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, 20-25
February 2000. pp.83-93. 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 2004. Environmental Impact Assessment and Strategic Environmental
Assessment: Towards an Integrated Approach. First edition 2004.
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, Pages19 – 31.
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World Bank, (2005). Integrating Environmental Considerations in Policy Formulation. Lessons from
Policy based SEA, Report No. 32783, World Bank.
31
ANNEX I
Sample of Sustainability Test Sheet
Source: SEA Manual (EPA, Ghana)
32
33
34
ANNEX II
SAMPLE OF COMPARTIBILTY TEST SHEET
Source: SEA Manual (EPA, Ghana)
35
ANNEX III
Sample of Compatibility Matrix Sheet
Source: SEA Manual (EPA, Ghana)
36
ANNEX IV
Terms of Reference: Short Term Consultant
“Public Participation in Policy-Based SEA. The Case of Ghana’s
Poverty Reduction Strategy (GPRS).”
The World Bank
Department Environment
Organization:
Name:
Kwame Boakye-Agyei
PhD. Student – George Mason University
Dr. Fernando Loayza [World Bank SEA Specialist]
th
th
Duration 11 June, 2007 - 5 August, 2007.
Supervisor:
PROJECT BACKGROUND/RATIONALE
The Bank’s Environment department has been implementing its pilot program on
Institutions-centred SEA since 2006. 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. It seems necessary, therefore, to develop
new participation mechanisms and processes to better address the need for policy based
SEA. Moreover, there is a need for greater understanding of the most effective ways of
involving SEA stakeholders, particularly, weak and vulnerable ones in institutions-centred
SEA.
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. This presented major problems due
to the neglect of key sustainable issues. In 2003 an SEA was applied to the GPRS by the EPA
and the National Development Planning Commission in collaboration with the Netherlands
Embassy with technical advice from Department of Foreign Investment (DFID). This time a
top-down contribution by 23 ministries and a bottom-up exploration at the regional and
district levels resulted in a successful outcome. To many 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).
Due to its broad scope and the intensive consultation process undertaken, the Ghana’s PRS
has the potential to throw light on the key requirements for effective participation on SEA
for incorporating environmental considerations into high level plans and policies. To this
purpose, there is a need, among other things, to assess to what extent the Ghana’s PRS
recognized and incorporated the interests and concerns of weak and vulnerable
stakeholders in the SEA process. Also, it is timely to assess the effectiveness of existing
mechanisms for public participation during the implementation of the GPRS and the SEA
recommendations. The primary goal of this internship is, therefore, to review these issues
in the context of the preparation and implementation of the SEA for GPRS.
37
OBJECTIVES
i.
ii.
Analyze how the SEA for the Ghana’s PRSP was used as a tool for policy
dialogue involving key interest groups with a stake in environment.
Examine the mechanisms for and extent of public participation during the
implementation of the GPRS, assessing the extent of participation of weak and
vulnerable stakeholders particularly those with stake on environmental issues
and the effectiveness of this participation for promoting environmental
sustainability.
DELIVERABLES AND EXPECTED OUTPUT
i.
ii.
iii.
A short inception report including the findings of the literature review and the
protocol for the field. (Key questions and list of potential interviews) not later
than two week after the initiation of the consultancy.
A draft report by 27th July with the main results and findings of the study.
A final report including consideration of the Bank’s comments and
recommendations and a tightly worded executive summary, not later than a
week after receiving the Bank’s comments to the draft report.
PROJECTED TIMELINE AND ACTIVITIES WITHIN 8 WEEKS
Timeline
7 days
Projected Tasks

Literature Review:


i.
i.
ii.
iii.
10 days
8 days
2 days
Milestones
Information Search:
Review of published materials on Ghana’s PRS
Review of literature on public participation for influencing
decision making
Review of public consultation methods and techniques
used in SEA
Identify emerging issues, gaps and their relevance
i.
Interview key stakeholders in Ghana: the EPA, NDPC,
District Assemblies, Ministries and key civil society
stakeholders involved in the SEA
ii.
Gathering of complementary information from archives
Outline/Analysis/writing of Report:

Organizing paper into sections

Synthesis findings
Executive Summary and adjusting final report
Case study questions
developed
List of interviewees
Inception report

Interviews done in
Ghana

Draft Report

Final Report
The consultancy will be carried out between June and August 2007 starting at June 11th.
38
Additional Terms of reference:
Assist in scoping key issues on public participation for strengthening governance for the
Ghana/Natural resources and Environmental Governance Program (NREG) under the
guidance of the TTL for the program.
39