More than half of the ministries are violating the legal obligation to publish the work programme for the current year, while only two ministries have published a list of laws and strategies to be subject of public discussions in 2019.
Planning and preparation for public discussions and consultations are one of the important preconditions for effective public participation in public policy making, especially when it comes to complex issues. In order for citizens to make their contribution, first of all they must be aware of what authorities plan to do in the current year. In this regard the Law stipulated the legal obligation for the state administration authorities and public authorities to publish work programme for the current year at their official web presentation (Article 51 of the Law on State Administration, Information on Work).
Until 27 March 2019, only seven out of 17 ministries of the Government of Montenegro fulfilled this legal obligation. The following ministries published the 2019 Programme/Work Plan:
– Ministry of Labor and Social Welfare,
– Ministry of Health,
– Ministry of Agriculture and Rural Development,
– Ministry of Public Administration,
– Ministry of Justice,
– Ministry of Science,
– Ministry of Education.
The situation is even worse when it comes to the obligation of the ministries to propose to the public a list of laws and strategies to be discussed in the current year. Namely, the Decree on the Selection of the Representatives of NGOs in Working Groups and Implementation of Public Discussions on the Draft of the Laws and Strategies stipulates the obligation of the ministries to post on their websites lists of draft laws and strategies to be subject of public discussions at the latest 15 days after the adoption of the work programme.
On this day, only two ministries publish lists of laws to be subjects of public discussions during 2019:
– Ministry of Public Administration,
– Ministry of Justice.
Taking into account “determination” of ministries to create a space for public participation, results on the number of citizens commenting on the draft documents on the eGovernment is not surprising – only two comments posted by citizens in 2018, according to Government’s official data.
The upgraded electronic public discussion service, which was launched in early March, is not enough if the ministries are not willing to enable meaningful civic participation, through timely announcement of public discussions whose implementation is expected during this year.