Feedback on Proposals adopted by the Commission: Mid-term evaluation of the EU Drugs Strategy 2013-2020 and final evaluation of the Action Plan on Drugs 2013-2016

Mid-term evaluation of the EU Drugs Strategy 2013-2020 and final evaluation of the Action Plan on Drugs 2013-2016

Contribution by De Regenboog Groep/Correlation Network on 23/09/2015

Country:	Netherlands
Domain:	Non governmental organisation
Contributor's name:	Eberhard Schatz
Transparency register:	37826442653-25
Feedback:	Relevance To what extent has the EU Drugs Strategy been relevant in view of the EU needs and is it still relevant in view of current needs? The EU drug strategy is a well balanced document which is relevant for current needs Would a new Action Plan for the period 2017-2020 be useful and necessary? A new action plan is necessary and useful and can support actions in member states. New developments have to be taken into account like nps, hepatitis epidemic under drug users, stronger civil society involvemnent, funding for harm reduction Coherence To what extent is the EU Drugs Strategy and Action Plan coherent with other EU policies, as well as with Member States drugs policies? To what extent is the EU Drugs Strategy and Action Plan coherent with the developments in the international fora and with the EU external action ? To what extent is the EU cooperation with third countries coherent with the objectives of the EU Drugs Strategy? It seems that the EU Drug Strategy is not common base for negotiations with other countries and UN level, see UNGASS 2016 EU-added value What is the additional value resulting from the EU Drugs Strategy and Action Plan, compared to what could be achieved by Member States at national and/or regional level? EU action plans and related funding in EC programmes (implementing innovative approaches, sharing and exchanging experiences across EU) are extremely important also for national and local situations. EU added value also contains: Improve the quality and standards of public health interventions through the promotion of the EU Council recommendations on minimum quality standards in demand reduction Balance its focus on the development of Novel Psychoactive Substances (NPS) legislation that ensures equal emphasis on research and the promotion of best practice in reducing NPS related health and social harms´ The EU should ensure the meaningful engagement of civil society through support, both political and financial, to the civil society task force, as well as supporting a formal civil society hearings.

Contribution by EURAD on 18/09/2015

Country:	Belgium
Domain:	Non governmental organisation
Contributor's name:	Contributor requested anonymity
Transparency register:	24340297158-92
Feedback:	EURAD is highly concerned by the intentions of this Roadmap. We strongly believe that the EU Drugs Strategy and Action Plans, which were approved by the Council of the European Union, provide a strong framework for collaboration between Member States and external international partners to work together to tackle the drug problem. Overall, we are concerned that the "Evaluation and Fitness Check Roadmap" has been constructed in a leading way, which from a research perspective may purposively solicit negative feedback. For example in Section C.2, negative questioning is used such as "To which extent is it perceived as a burden" and "To which extent have the Strategy and Action Plan had an impact on the Member States' budgetary resources" and notably these questions are not balanced with questions which would seek to know the benefits of the EU Drugs Strategy and Action Plan. A balanced questionnaire would, in my opinion, set out to research the positive and negative impacts, as well as the challenges and opportunities that the EU Drugs Strategy and Action plan bring to Member States, as well as to external partners. I would therefore like to suggest the following amendments: Section B: - The number of NPS detected in the last 2 years is in included in this section - That further EMCDDA statistics are included in this section to show the wider consequences of drug use (i.e. not just drug related deaths but also number of people requiring treatment across the EU, drug related car accidents, statistics regarding the production of drugs within the EU area, connection with wider serious organised crime and money laundering which are cross-border in nature) Section C: - That third countries could also be involved with the consultation (such as countries with bilateral agreements on drugs with the EU) - That the questions in Section C.2 are reviewed and leading questions are removed or balanced - That "Benefits" should also be a theme of the consultation alongside "Current Situation, Effectiveness, Efficiency, Relevance, Coherence and EU Added Value".

Contribution by Hungarian Civil Liberties Union on 17/09/2015

Country:	Hungary
Domain:	Non governmental organisation
Contributor's name:	Peter Sarosi
Transparency register:
Feedback:	19.1: the availability, accessibility and coverage of effective and diversified drug demand reduction measures has not been improved in Hungary, on the contrary, several important services were terminated, including the two largest needle and syringe programs that served 55% of all NSP clients in Hungary. There is an increasing demand for sterile injection equipment because of the spread of NPS, injected 15 times a day (compared to 3-4 times/day with heroin). There are political attacks against harm reduction programs in the local level, the government does not protect them. http://drogriporter.hu/en/node/2679 19.2: according to a recent survey the access to prevention programs has been declining in previous years: in 2009 prevention programs were present in more than 80 percent of schools, in 2015 only in 54% of schools. A current survey among key professionals showed that the most prevalent school prevention program is operated by policemen. We documented the massive presence of Scientology-based programs in Hungarian schools, with dubious quality (http://drogriporter.hu/en/scientology). In 2012, the government in Hungary created an accreditation system for school drug prevention programs, whereby - in theory - only health programs recommended by the National Institute for Health Development are allowed to enter schools. But the system is not enforced, and there are only a few high-quality programs with the official recommendation and the necessary funds to do prevention work. 19.3 No specific programs were implemented to address NPS use in Hungary, except one media prevention campaign in 2012, with no evaluated impact. 19.4 HCV prevalence in the country doubled between 2011 and 2014, in a period when NSP coverage significantly decreased. http://drogriporter.hu/en/node/2711 19.6 There are no treatment or harm reduction services for prisoners, except psychological consultation at the so-called drug-free wings of prison but there number has been declining, the number of prisoners in these wings decreased from 252 persons in 2011 to 207 persons in 2015. According to a study published in 2014 by the National Institute of Criminology risk behaviors has increased in previous years in prisons but there is no access to sterile needles, low access to HIV and HCV testing. 19.7 there is only one addiction treatment facility for children and young people in the country, opened this year. Because of the spread of NPS use, the average age of problem drug users is declining, there is a great need for such facilities. 19.9 local outbreaks of NPS drug user were reported in impoverished small villages of Hungary in 2015, the use of synthetic cannabinoids is spreading especially among young Roma people living in segregated parts of villages. 19.10 the drug budget has been reduced significantly between 2009 and 2012: labelled drug budget was more than 1 billion HUF in 2009, it is 355 million HUF in 2015.

Contribution by UNAD - SPAIN on 15/09/2015

Country:	Spain
Domain:	Non governmental organisation
Contributor's name:	Pedro Quesada Arroyo
Transparency register:	557
Feedback:	From UNAD-SPAIN, we deeply welcome this proposal, since we do think we need an European political framework to determine minimum efforts in the Member States so that we can find a relative homogeneous policy and legislation, with real solutions, on Health and Drugs related Issues. Otherwise, we would not find a way to improve good results coming from the practice done by specific Member States, not to repeat the bad ones. So we do find the EU Drugs Strategy 2013-2020 should carry on with a new Action Plan 2016-2020, taking into account results from the previous one 2013-2016. Otherwise we could not arrive to a conclusion, losing all the efforts done in these last three years and with nothing in our hands. On the other hand, the EU Drugs Strategy 2013-2020 and the Action Plan 2013-2016 have clearly contributed to improve the efficiency and quality of national drugs interventions, and have created a stronger coordination across the EU. Member States expect some suggestions in order to establish some short of red lines in their own Drugs Strategies. UNAD philosophy deeply bet for evidence based Drugs Strategies focused on human rights and public health. Taking into account this circumstance we do fully support the European Action Plan 2013-2016 and expect a second round to be able to confirm real conclusions and results. We do welcome Strategies based on drugs supply reduction and the fight against organized crime. We find these measures are really important. Nevertheless we think main goals should prevent the use of Drugs focusing their efforts on an early intervention, treatment, harm reduction, rehabilitation, and social integration. These goals should lead all the efforts of both, the EU policies and the ones taken by the policy makers in the Members Estates. Regarding programmes developed on Drugs field, we cannot forget the efforts coming from the third sector, NGOs and the civil society in general. Actually, most of them depend on the strength of these organizations which, on the other hand, depend directly of the funding coming from the EU and the Member Estates. With a proper funding, NGOs and the civil society will be able to maintain these programmes, even with a really big effort by themselves (as all we know). With a lack of funding, unfortunately most of programmes will disappear. In Spain, the third sector is suffering the economic recession in two ways. First of all, this economic recession brings strong cuts on the funding of programmes, which means almost impossible efforts from the human resources (volunteers) and sometimes the end of the programmes (with dangerous consequences for the society). Secondly, this situation let the National and Local Administrations to focus their economic efforts on very concrete options. We can see some very intense activity on means in order to reduce the drugs supply, but at the same time we can see how programmes related to reduce the drugs demand are losing their funds (depending on the area 25% or more, even closing these programmes). With a strong European Strategy, based on the real experience coming from all the European Countries, setting out a consensus on the red lines not to forget, we would be able to claim for these minimum standards in all the EU. Regarding the action Plan 2013-2016, we would highlight next issues: 1. Objetive 1. Prevent drug use and, secondly, delay the onset of drug use. Even though we find these issues are essentials, we do think they are relegated to a second level. In Spain, because of some financial cuts, main programmes related to drugs demand reduction are suffering important economic cuts, and many of them have disappeared. So, we do think this issue should be critical in the next Action Plan 2016-2020. 2. Enhance the effectiveness of drug treatment and rehabilitation. Same considerations done before. Some really good programmes all over Spain (depending on the region it is more or less dramatical) see how their funds are disappearing. On the other hand a really restrictive new legislation on Public Safety and Criminal Law are breaking with some important measures related to rehabilitation of small offenders and people that committed their crimes because of their addictions. This means, in most cases, no options to recover this people. 3. Objective 3: Embed coordinated, best practice and quality approaches in drug demand reduction. Really important the work done from the EU. We find really important to come this to the field and get an answer from the NGOs. Civil Society should give their suggestions so that quality standards count on real experience and results. 4. Objective 5. Members States to provide, where appropriate and in accordance with their legal frameworks, alternatives to coercive sanctions (such as education, treatment, rehabilitation, aftercare and social integration) for drug-using offenders”. We deeply bet for alternative measures to prison. We do think prisons cannot afford an appropriate atmosphere to get good results on rehabilitation, social inclusion, etc … UNAD bets strongly for a new Action Plan 2016-2020 within the EU Drugs Strategy 2013-2020 in order to continue with the objectives initiated in this previous Action Plan 2013-2016. European Estate Members need a strong policy background agreed within the European institutions in order to be able to develop fair drugs policies based on the real experience. Finally, we do think Civil Society must be main participant on the execution of this brand new Action Plan 2016-2020.

Contribution by Actis on 11/09/2015

Country:	Norway
Domain:	Non governmental organisation
Contributor's name:	Contributor requested anonymity
Transparency register:
Feedback:	As a new member of the Civil Society Forum on Drugs, Actis, would first like to thank you for the opportunity to comment on the mid-term evaluation of the EU Drugs strategy and the final evaluation of the Action Plan. We believe that the Strategy is a broad and balanced framework for the development of EU drug policy, and that the Action Plan sets out concrete and measurable targets, ensures a clearer division of tasks and strengthens the coordination of the many actors involved in drug policy in Europe. The evaluation will be useful in identifying areas where there has been progress and areas where there is need for further efforts. The drugs problem is not static, and new strategies need to be developed to face new challenges and shifting patterns. The results of the evaluation should feed into the development of the next action plan, as envisioned in the EU Drugs Strategy that was approved by the Council of the European Union. We are therefore concerned to see that there seems to be doubt whether a new action plan should be proposed at all. We believe that an action plan is a useful focal point for drug policy development on the European level and a way to ensure that drug policy stays on the agenda.

Contribution by FEDERACIÓN ANDALUZA ENLACE, ENLACE ANDALUSIAN FEDERATION on 08/09/2015

Country:	Spain
Domain:	Non governmental organisation
Contributor's name:	Jorge Ollero
Transparency register:
Feedback:	We welcome the opportunity to express our point of view, as we believe the consultation with civil society is vital to improve European and national drugs policies. Firstly, we will outline some general issues that impact transversely to the European approach on drugs and then, secondly, we will specifically analyze the grade of achievement of some of the objectives and actions of the Action Plan on Drugs 2013-2016. Overall, we believe the Drugs Strategy and Action Plan are positive steps to a better solution of the drug problem in Europe, and therefore we markedly encourage the continuation of these political efforts. The Strategy and the Action Plan have contributed to improve the efficiency and quality of national drugs interventions, and have created a stronger coordination across the EU. ENLACE firmly and consistently supports drug policies and practices that are balanced, integrated, evidence based and focused on human rights and public health. Therefore, we believe that a drug demand reduction approach, including prevention, early intervention, treatment, harm reduction, rehabilitation, and social integration is the best way to improve our response to the drug problem. Recently, there has been a relocation of European drugs policies, initiatives and agencies in the Directorate General of Migration and Home Affairs of the European Commission, which may shift the focus to drug supply reduction and the fight against organized crime. Although it is important to tackle those issues, we would like to reaffirm our preference for a drug demand reduction approach. We are concerned about the possibility that this administrative rearrangement will diminish the funding options available for drug demand reduction programs, and civil society organizations are already under great pressure due to funding constraints. We consider that funding civil society organizations that work in the field of drug demand reduction is of the utmost necessity in these moments of economic hardship. These organizations help to reduce the social roots and consequences of the drug problem, mainly poverty, deprivation and social inequality. There has been a persistent lack of funding for these organizations and therefore the level of achievement of the objectives of national and European drug demand reduction programs have been affected. In our region, Andalusia, the budget allocated for drug demand reduction policies has been reduced a 26% in the period 2011-2015 and some resources, as day centers, have been closed. Meanwhile, at national level, the budget for prison policies has been reduced only in a 7%. Although these figures are not directly comparable, we want to highlight that the reduction in policies that improve social cohesion has been much sharper than in punitive policies. We would prefer that this trend is not replicated across Europe. Regarding the specific implementation of the objectives of the 2013-2016 Action Plan, we can point out the following: 1. Drug demand reduction: - Objective 1: Our organizations are committed to family and community- based interventions that effectively prevent drug use, including interventions in nightlife and recreational settings. However, some programs have not been improved or extended due funding restrictions, therefore we do not believe Action 1 of objective 1 is increasing its accomplishment. - Objective 2: We want to point out three considerations on this regard. Firstly, although we believe that Andalusia has a comprehensive treatment network, there have been some legislative measures at national level that obstruct the provision and expansion of these treatment services. In particular the “Public Safety Act” (Ley de Seguridad Ciudadana), published in 2015, hinders the possibility for those who have been arrested carrying small amounts of drugs to receive drug treatment, because now they are fined directly, with no possibility for a suspension of this fine if they successfully finish their treatment. Secondly, we believe that not enough efforts are being made in the field of diagnostic, treatment and reintegration of dual diagnosis patients, which represent in our view a challenge for the next years. Finally, we are consistently asking that health care measures for drug users in prison to be improved and equal to those received in the community. We think further enhancements must be made in this area. - Objective 3: We appreciate there has been progress in this area, with the creation of quality standards in this field. We now ask for a comprehensive implementation plan, to make the standards become a reality, in which the voice of civil society organizations must be taken in to account. 2. Drug supply reduction: We would like to make a remark regarding Objective 5, Action 21, of the Drug supply reduction area of the Action Plan. This Action is set to “Members States to provide, where appropriate and in accordance with their legal frameworks, alternatives to coercive sanctions (such as education, treatment, rehabilitation, aftercare and social integration) for drug-using offenders”. ENLACE is a firm advocate of the use of alternatives to coercive sanctions, especially we stand for abandoning the use of imprisonment for drug users who have committed their crime due to their addiction. Spain has one of the highest imprisonment rate of the whole EU and most of the inmates are serving medium to short sentences of drug related offenses. We think there is a lack of alternative measures available in Spanish legislation (such as probation, diversion, or extended restorative justice services) and a recent reform of the Criminal Code has not improved the situation. Therefore, this action should recieve more attention.

Contribution by Dianova International on 07/09/2015

Country:	Spain
Domain:	Non governmental organisation
Contributor's name:	Montserrat Rafel
Transparency register:
Feedback:	Dianova is an international net of NGOs working in Europe and the Americas; it holds ECOSOC status and id member of Civil Society Forum on Drugs (www.dianova.org) Regarding the proposed roadmap we are worried to read that the design of the Action Plan for the period 2017-2020 is constrained to the outcome of the evaluation of the previous Action Plan (section A.1 & B.1). We do believe that the evaluation of the previous Action Plan 2013-2016 needs to be reflected in the new plan so that the latter is improved. Nevertheless, we consider that the configuration of an Action Plan for the period 2017-2020 should not even be doubted given the serious social and health consequences that drug consumption have globally, and concretely at the EU level. Furthermore, the Action Plan 2017-2020 was already foreseen by the EU Strategy on Drugs for the period 2014-2020. In addiction, we welcome the proposal that an external contractor will be asked to attend the Civil Society Forum as a consultation step. Thank you for your time and consideration.

Contribution by European Association for Palliative Care on 03/09/2015

Country:	United Kingdom
Domain:	Non governmental organisation
Contributor's name:	Dr David Oliver
Transparency register:
Feedback:	It seems reasonable to undertake a review of the drugs Strategy Action Plan for 2013-2016 to evaluate its effectiveness and contribute to the ongoing Action Plan for 2017-2020. However as there is a clear Drugs Strategy for 2013-2020 it is essential that the Action Plan does continue until 2010, as agreed by the Council of the European Union in 2012. Throughout the evaluation of the Action Plan it is important to ensure that any actions taken do not affect the people who do require opioids and certain other medication for the legitimate treatment of pain and distress. There are many millions of people within the EU who still do not receive adequate treatment of pain and although it is important to ensure that these drugs are not used in an illicit way it is also essential to ensure that all people who do require opioids for pain control are able to do so easily and without delay. It is important to ensure that there are no unduly restrictive laws or burdensome regulations which may affect the legal and very important use of opioids for pain control (International Narcotics Control Board. Report on the Availability of Internationally Controlled Drugs: Ensuring Adequate Access for Medical and Scientific Purposes (2010) http://www.incb.org/documents/Publications/AnnualReports/AR2010/Supplement-AR10_availability_English.pdf)

Contribution by Ana Liffey Drug Project on 03/09/2015

Country:	Ireland
Domain:	Non governmental organisation
Contributor's name:	Tony Duffin
Transparency register:
Feedback:	In Section (A1)Purpose, it is noted that 'the outcome of the evaluation will also contribute to the decision whether the Commission will propose a new action plan to cover the period 2017-2020'.Similarly, in Section (B1), it is noted that 'on the basis of the evaluation subject to this roadmap, the Commission will decide whether to propose an action plan for 2017-2020'. This appears to raise the possibility that there may not be an Action Plan for the period 2017-2020. We are of the opinion that this path, even as a possibility, is undesirable for two main reasons: 1. The current strategy was approved by the Council as a plan to cover the period 2013-2020, not 2013-2016. In setting the strategy, the Council clearly envisaged a plan to have an impact over the full term; the decision to implement further strategies and action plans should properly be taken when the entirety of the strategy has run its course, not at the midpoint. 2. Notwithstanding the point made at 1, above, it is unclear as to why there would be any consideration given to not having an EU Action Plan on drugs for the period 2017-2020. Drug use is, and will continue to be, a significant health issue for a large number of EU citizens. As the roadmap notes, over 6,000 people in the EU die every year from overdose, 1,700 people die of HIV/AIDS attributable to drug use, and 1,800 become infected with HIV as a result of drug use. Many, many more people will have other adverse sequelae from drug use such as hepatitis infection, thrombosis, endocarditis, etc. Aside from the direct health costs, drug use impacts indirectly on issues like employment, social inclusion and criminal justice. To not have a strategic response at EU level which deals with the issue of drugs is unfathomable.