Page 3, paragraph 1 of the EBRD strategy: “Although the Ohrid Agreement is unpopular with some of the ethnic Macedonians, a referendum on the territorial re-organisation law, held on 7 November 2004, failed.”

CRPM comment: The Ohrid Framework Agreement (OFA) has support among the Macedonian ethnic community. The number of those that see it as unpopular is low and it could not have serious implications on the implementation of the OFA. The reasons for the referendum on the territorial reorganization were more complex and cannot be reduced only to the unpopularity of the Ohrid Agreement among the Macedonians. This, especially so since opinion polls have shown that great percent of the Macedonian ethnic community was hoping and believed that the referendum would not have negative impact on the implementation of the OFA. (Check the opinion polls by the Institute for Democracy Solidarity and Civil Society, before the referendum)

Page 4: “It is encouraging that 2 projects were signed with foreign sponsors, despite a general perception about a difficult investment climate in the country.”

CRPM comment: Have some of the reforms as the one stop shop system for registration of businesses improved the image of Macedonia as investment destination? (Having in mind that in this part Macedonia has much better assessment then for example Croatia, according to the World Bank for 2006)

Page 9: “Overall, the Bank has achieved the operational objectives set out in the 2004 Country Strategy.”

CRPM comment: How is this achievement measured? In the text mostly the operations in which the Bank was involved are enumerated but the focus is not so much in their overall impact, contribution and success. In that direction relevant methodology and indicators are needed for the arguments of the (un)successful impact on the ground of those operations.

Page 10: “All new projects have good or excellent transition impact potential and are already under implementation.”

CRPM comment: There should be some information on who has made the impact evaluation. How is the impact measured? Is there an independent evaluation? If it is an internal one, is it open to the public? It should have been added to the EBRD 2006 strategy for public usage.

Page 11: “The Bank also made strenuous efforts to improve the performance of the local banks where the Bank has equity participation.”

CRPM comment: How can EBRD substantiate or at least give details of the ‘strenuous efforts’ being made?

Page 11: “The Bank also worked closely with executing agencies of the MEAP, FYR Macedonia-Bulgaria Power Transmission, Regional Road projects and set them on the path of accelerated procurement and disbursement. All new projects have good or excellent transition impact potential and are already under implementation.”

CRPM comment: In what sense the Bank worked closely with the mentioned executing agencies and what is the good or excellent impact of the project, how is it measured, and most importantly what are the benefits on the ground of that?

Pages 11-13 (section 1.3)

CRPM comment: In this part of the text the projects that EBRD is/has been financing are enumerated and given an overall assessment of “successful” or “moderate”, without relying on any concrete arguments. An analysis of the impact that those projects have on the Macedonian reality is lacking. There is no assessment being made on what are the benefits of these projects for the wider public.

Page 14: “Local elections were held in March/April 2005. The government coalition lost Skopje but did well enough countrywide to be able to get on with the implementation of the Ohrid Agreement. Parliamentary elections were held on 5 July 2006.”

CRPM comment: Actually, the Democratic Union for Integration, a part of the government at that time, won in the municipality of Chair, in Skopje. It is also unfounded to link the results of the local elections with the continuation of the implementation of the Ohrid Agreement.

Page 16: “The ethnic Albanians are concentrated in western and north western part of the country where the best agricultural land is.”

CRPM comment: On what basis EBRD writes that the best agricultural land is located in the western and northwestern part of Macedonia? Is there evidence regarding fertility of the land, export figures, productivity or something else?

Page 16: “Roma complain of widespread ethnic discrimination.”

CRPM comment: This is an unfounded generalization by the EBRD.

Page 16: “The controversial issue in education is that of the right of ethnic Albanians to education in their own language.”

CRPM comment: Why is this still mentioned as a controversial issue? Ethnic Albanians have a right to education in their own language in all levels from primary to tertiary. The report is supposed to be most updated and not rely on historical circumstances for judgments.

Pages 16-17: “Previous governments had refused to set up a separate university to teach in Albanian, or to secure a quota system for the enrolment of ethnic Albanian students at the two state universities.”

CRPM comment: The University of Cyril and Methodius has implemented an affirmative action kind of quota system for the members of the ethnic minorities in Macedonia since at least the 1994/5 academic year. The EBRD claim is thus, incorrect.

Page 17: “In the 1980s the state had provided a guaranteed and comprehensive healthcare service, which on paper continues. But, in reality, the quality of healthcare has deteriorated since independence due to an acute lack of funds and shortages of medical supplies. Compared with the private sector, the medical service is seriously underpaid. Many doctors have found positions abroad, and medical skills have stagnated due to lack of new technology.”

CRPM comment: This argument is problematic from different aspects; initially the approach is problematic when the salary in the private sector is taken as criteria for measuring the situation of underpayment in the state medical service. Additional problem is that that statement does not rely on any data and statistic that would prove that. More serious approach for the conclusions regarding the alleged underpayment of the medical service would be if the salary of the doctors is compared with the average Macedonian salary, for example. In addition, there is no supporting data that many doctors have found positions abroad. CRPM opines that the statement is to a great degree incorrect.

Page 21, EBRD uses data from the 2005 EBRD/World Bank Business Environment and Enterprise Performance Survey.

CRPM comment: data for 2006 have been released some time now and should have been used.

Page 26: “In the corporate sector, the Bank will target its support towards smaller-scale local export-oriented companies showing good corporate governance, by providing loans, guarantees or making equity investments, including through the new EBRD-Italy Western Balkans Local Enterprise Facility. Assistance to local enterprises will be provided through the TAM/BAS programmes. The Bank will continue its support to strategic foreign investors.”

CRPM comment: it would be good to know what kind of support is envisioned here.

Page 26: “Where possible, the Bank will look for opportunities to support or participate as a co-investor in the sale of state shares in telecommunications and banking sectors”

CRPM comment: How the Bank is going to give support? Is there some concrete plan, strategy or timetable that specifies the steps of the Bank in this area? Few times in this strategy is mentioned the support for the foreign investors but that “support” is defined to general or is not defined at all.