Complaint to EU Ombudsman: Maladministration of the European Commission in its decision to revise the Water Framework Directive

We, the European Anglers Alliance, the European Environmental Bureau, Surfrider Foundation Europe, Wetlands International Europe and the European Policy Office of WWF, are concerned that both this decision and the process leading to it fall short of the procedural standards expected of the European Commission. In particular, we have reason to believe that the announcement was made without the evidence-gathering, stakeholder participation and policy justification required to ensure transparent, evidence-based and coherent decision-making.

Taken together, the steps preceding the announcement, the announcement itself, and the process that has unfolded since point to a pattern of maladministration. They represent a significant departure from established principles of good administration and risk undermining the rights of citizens and stakeholders to participate meaningfully in EU policymaking.

This complaint sets out three principal procedural concerns: (1) the decision to review the WFD was not supported by adequate evidence and lacks policy coherence; (2) the process failed to ensure early, effective, balanced and equitable stakeholder participation; and (3) the proposed legislative revision is disproportionate and inappropriate to the objectives pursued.

We therefore respectfully request that the European Ombudswoman find maladministration and issue appropriate recommendations to remedy these procedural deficiencies.