Position Letter / Advocacy
ADDRESSED TO: Shkodër Municipal Council
For the attention of: The Chairman of the Shkodër Municipal Council
SUBSEQUENCE: Request for the exercise of the legal powers of the Municipal Council in guaranteeing the inclusion of persons with disabilities in environmental policies and measures for adaptation to climate change.
LEGAL BASIS:
• Law No. 93/2014 “On the inclusion and accessibility of persons with disabilities”;
• Law No. 139/2015 “On local self-government”;
• UN Convention on the Rights of Persons with Disabilities (CRPD), ratified by the Republic of Albania, articles 4, 5, 9, 11 and 29;
• Constitution of the Republic of Albania, article 18;
• Law No. 10221/2010 “On protection from discrimination”, articles 3 and 5.
Dear members of the Municipal Council,
Through this Position Paper/Advocacy, civil society organizations, the community and representatives of persons with disabilities (PWDs) address the Shkodra Municipal Council, as the representative and decision-making body of local government, to request the active exercise of its legal powers in guaranteeing the real and effective inclusion of persons with disabilities in environmental policies, urban planning, natural emergency management and climate change adaptation measures.
The Municipal Council, in exercising its supervisory, regulatory and approving functions, is directly responsible for the approval of local policies, plans and budgets, which must reflect the needs of vulnerable groups, including persons with disabilities.
This Position Paper/Advocacy presents the positions and recommendations of civil society organizations (CSOs), the community and other interested stakeholders, with the aim of strengthening the inclusion and effective guarantee of the rights of persons with disabilities (PWDs) at the local level, emphasizing the need for concrete and measurable actions by responsible institutions.
Within the framework of the implementation of the project “Active Response: CSOs and Persons with Disabilities for the Environment in the Municipality of Shkodra”, implemented by the “Projekti Shpresa” Association, supported by Green-AL within the framework of the “Support to Civil Society Organizations 2024–2027” program, a project financed by the Swedish International Development Cooperation Agency (Sida) and implemented by Co-PLAN – Habitat Development Institute, in cooperation with VIS Albania and COSV – Cooperazione per lo Sviluppo, civil society organizations and the community of persons with disabilities (PWD) recall the urgent need to take concrete and immediate measures to guarantee effective inclusion in decision-making on environmental issues and climate impacts.
This document is based on the experience of the 4-day training “Awareness, Advocacy and Social Inclusion for PWDs in Environmental Issues”, held at the “Atelie” Youth Center, Shkodra Municipality, during November and December 2025, which was attended by 30 people, including:
• 5 civil society organizations (CSOs) that work directly with people with disabilities, each represented by 1–2 people;
• 2 organizations that implement projects for the most vulnerable groups, including people affected by natural emergencies and climate impacts;
• 3 institutions that provide services for people with disabilities;
• institutions that provide services for people with mental health problems;
• 15 people with disabilities;
• caregivers and family members of people with disabilities.
During the 4-day training, participants identified several critical challenges that hinder the inclusion of persons with disabilities (PWDs) in environmental issues and natural emergency management:
1. Physical and informational accessibility
Challenge: Public spaces and information on emergency measures and climate impacts are often not adapted for persons with disabilities (PWDs), limiting their access to information and services.
Legal basis:
• Law No. 93/2014 “On the Inclusion and Accessibility of Persons with Disabilities”, which obliges public institutions to ensure physical accessibility and appropriate information for PWDs;
• UN Convention on the Rights of Persons with Disabilities (CRPD),
Article 9 – Accessibility, which requires the elimination of physical and informational barriers for PWDs.
2. Participation in decision-making
Challenge: People with disabilities are not systematically included in the planning of environmental strategies and in decision-making processes for emergency management.
Legal basis:
• Law No. 139/2015 “On Local Self-Government”, which defines the responsibility of municipalities for the inclusion of local communities in decision-making processes;
• CRPD, Article 29 – Participation in public and political life, which requires ensuring the participation of persons with disabilities in decision-making and in the drafting of public policies.
3. Lack of dedicated planning and budgeting Challenge: At the local level, there is a lack of clear financial lines and budgetary mechanisms for the implementation of measures that guarantee the effective inclusion of persons with disabilities.
Legal basis:
• CRPD, Article 4 – General obligations, which obliges States Parties to provide the necessary resources for the inclusion and protection of persons with disabilities.
4. Impacts of natural emergencies and climate change
Challenge: Persons with disabilities are among the most vulnerable groups during natural disasters, often without adequate support and accessible response mechanisms.
Legal basis:
• CRPD, Article 4 – General obligations, which obligates States Parties to provide the necessary resources for the inclusion and protection of persons with disabilities.
4. Impacts of natural emergencies and climate change
Challenge: Persons with disabilities are among the most vulnerable groups during natural disasters, often without adequate support and accessible response mechanisms.
Legal basis:
• Law No. 93/2014 and Law No. 139/2015, which require protective and inclusive policies for vulnerable groups;
• CRPD, Article 11 – Situations of risk and humanitarian emergencies, which obligates States to take measures to protect persons with disabilities during natural emergencies and disasters;
• National and international instruments for emergency management and adaptation to climate change, which require the protection and inclusion of the most vulnerable groups. Constitutional principle of equality According to the Constitution of the Republic of Albania, Article 18 – Equality before the law,
“All are equal before the law.”
This means that any local public policy that:
• de facto excludes persons with disabilities, or
• does not take positive measures for their inclusion, violates the constitutional principle of real and not just formal equality.
2. Concrete recommendations with deadlines and indicators
• Within 3 months
1. Establishment of the Consultative Council for Persons with Disabilities (PWD) on Environmental Issues at the Municipality of Shkodra
• Composition: at least 5–7 representatives of PWD and civil society organizations
(CSOs).
• Indicator: PWD representatives included in over 80% of the Council meetings.
2. Audit of accessibility of public spaces and information on emergencies and climate impacts
• Includes: public buildings, sidewalks, parks, online information and information systems on emergency measures.
• Indicator: Initial audit report published and publicly distributed.
Within 6 months
1. Drafting and approval of the Local Plan for Accessibility and Participation of PWD, with a dedicated budget line
• Includes: new investments, accessibility policies and mechanisms for the participation of PWD in decision-making.
• Indicator: over 90% of new investments comply with accessibility standards.
2. Integrate accessibility and inclusion standards for PWD in every new environmental investment, including parks and public spaces
• Indicator: Each new project is published with an accessibility report and an action plan for the inclusion of PWD.
• Within 12 months
1. Publication of the annual report on the progress of the measures taken
• Indicator: Report published online and in local media, including data on accessibility and participation of PWD.
2. Organization of periodic trainings for institutional staff and the community
• Topic: inclusion of persons with disabilities in the management of natural emergencies and climate impacts.
• Frequency: at least 2 trainings per year.
• Indicator: 80% of relevant staff participating in the planned trainings.
3. Establish measurable indicators for assessing social impact
• Includes: the number of people with disabilities involved, improved accessibility and their level of satisfaction.
• Indicator: The progress report includes satisfaction surveys and concrete measures to improve accessibility.
Civil society organizations (CSOs) and the community of persons with disabilities (PWDs) request the organization of an official working meeting with representatives of the relevant institutions, specifically:
• Mayor;
• Department of Social Services;
• Regional Directorate of Environment;
• Department of Planning and Investments.
The purpose of the meeting is:
• Discussion of recommendations issued during the training and from the process of preparing this Position Paper/Advocacy;
• Agreeing on a concrete action plan, as well as defining institutional responsibilities for its implementation;
• Determining institutional contact points, in order to monitor progress and inter-institutional coordination;
• Ensuring the active participation of representatives of relevant institutions in the Social Forum, which will be held at the conclusion of the project, in the last week of March, specifically on March 27, from 10:00 to 12:00 at the Municipal Council Hall, Shkoder, with the aim of discussing with all relevant stakeholders and promoting recommendations for the implementation of inclusive measures for persons with disabilities in environmental issues. This approach aims to ensure that the institutional meeting does not remain an isolated activity, but is part of a comprehensive and collaborative process, integrating the community, civil society organizations and public institutions. In this way, it is aimed to increase transparency, effectiveness and institutional accountability in the implementation of inclusive measures for persons with disabilities in environmental policies and actions.
4. Engagement of Civil Society Organizations and the Community Civil society organizations (CSOs) and the community of persons with disabilities are engaged in:
• Providing technical expertise in the planning and implementation processes of inclusive measures;
• Public monitoring of progress in the implementation of relevant recommendations and policies;
• Facilitating dialogue between the community and public institutions, with the aim of increasing cooperation and inclusion;
• Supporting the drafting of strategic documents and action plans related to environmental issues and social inclusion;
• Providing transparent and periodic information to the community and the public on the progress of the implementation of the proposed measures.
5.Legal and institutional basis of the requests The requests submitted in this document are based on the legal and institutional framework in force, specifically in:
Law No. 139/2015 “On Local Self-Government”, which assigns to the Municipal Council the competence to:
• approve local strategic plans;
• approve the budget and distribute public funds;
• supervise the activity of the municipal administration;
• guarantee community participation in decision-making processes.
Law No. 93/2014 “On the inclusion and accessibility of persons with disabilities”, which obliges local public authorities to take concrete measures for:
• physical and informational accessibility;
• eliminate barriers to public services;
• include persons with disabilities (PWD) in public policies and programs.
The UN Convention on the Rights of Persons with Disabilities (CRPD), ratified by the Republic of Albania, which has binding legal force and requires:
• accessibility (Article 9);
• participation in public life and decision-making (Article 29);
• special protection in situations of danger and emergency (Article 11);
• provision of financial and administrative resources for the implementation of rights (Article
4).
Law No. 10221/2010 “On Protection from Discrimination”
According to Article 3 and Article 5, discrimination on the basis of disability also includes situations where appropriate measures are not taken to guarantee the inclusion of persons with disabilities.
Failure to take appropriate measures for PWDs:
• constitutes indirect discrimination,
• even in cases where there is no direct discriminatory intent.
In this context, the Municipal Council has the obligation not only to avoid discrimination, but also to take active measures to prevent and correct structural discrimination.
Failure to integrate these obligations into local policies constitutes a violation of the principle of equality and inclusion, and violates the legal obligations of local government.
• Findings from the 4-day consultation and training process The 4-day consultation and training process conducted with civil society organizations and the community of persons with disabilities resulted in the following:
1. Public spaces, infrastructure and information on natural emergencies are not accessible to persons with disabilities.
2. Persons with disabilities are not included in a structured manner in decision-making processes related to environmental issues.
3. There are no approved policies and dedicated budgets for the inclusion of PWDs in environmental and emergency policies.
4. Emergency management plans do not specifically address the needs of persons with disabilities. These shortcomings require direct intervention by the Municipal Council, in the exercise of its regulatory and supervisory function.
• Requests to the Shkodra Municipal Council In the exercise of its legal powers, the Shkodra Municipal Council is requested to:
1. Adopt a decision to establish a permanent consultative mechanism for persons with disabilities in environmental matters.
2. Request the municipal administration to draft and submit for approval the Local Plan for Accessibility and Participation of Persons with Disabilities, accompanied by a budget
dedicated for its implementation.
3. Condition the approval of environmental investments with respect for accessibility standards for persons with disabilities.
4. Exercise periodic control over the implementation of measures, through mandatory annual progress reports.
• Request for institutional review
In this context, it is requested to organize a hearing or official meeting at the Municipal Council, with the participation of relevant institutions, civil society organizations and representatives of the community of persons with disabilities, in order to:
• review this Position Paper/Advocacy,
• discuss the recommendations presented,
• and agree on concrete institutional steps for their implementation.
6. Final message
This document aims to create a sustainable model of cooperation between:
• Shkodra Municipality,
• Civil Society Organizations (CSOs),
• The Community of Persons with Disabilities (PWD), and
• environmental institutions, with the aim of improving the daily lives of PWDs and increasing the city's readiness to face environmental challenges and climate emergencies.
An inclusive and climate-resilient city is a fair, safe and democratic city for all citizens. The inclusion of PWD is not optional
— it represents a legal, social and moral obligation, aiming at their real integration in environmental decision-making processes. The Municipal Council, as a representative body of citizens, has a key role in guaranteeing this standard.
The organizations and parties involved remain ready for constructive cooperation and institutional dialogue, contributing to the creation of a model of inclusive and sustainable good governance, which guarantees the real and effective inclusion of persons with disabilities at all levels of environmental decision-making.
Attached to this message are the strategic recommendations drafted for implementation by the Municipal Council and relevant institutions.
STRATEGIC RECOMMENDATIONS TO THE SHKODRA MUNICIPAL COUNCIL
I. Normative and decision-making recommendations
1. Adoption of a decision of the Municipal Council for the establishment of a permanent consultative mechanism for Persons with Disabilities (PWD) in environmental issues, urban planning and natural emergency management.
2. Mandatory inclusion of PWD representatives and CSOs in the consultation processes for any environmental plan, strategy or project approved by the Municipal Council.
3. Adoption of local by-laws that determine the minimum accessibility standard in any public environmental investment.
II. Programmatic and strategic recommendations
1. Drafting and adoption of the Local Plan for Accessibility and Participation of PWD, as a mandatory strategic document for the municipal administration.
2. Integrate PWD issues into local climate change adaptation plans, including emergency and civil protection plans.
3. Update existing emergency plans with specific protocols for the protection and evacuation of PWD.
III. Financial and budgetary recommendations
1. Provide a budget line dedicated to accessibility and inclusion of PWD in the annual budget of the Municipality of Shkodra.
2. Condition the approval of public investments with respect for physical and information accessibility standards.
3. Provide funds for periodic audits of the accessibility of public spaces
and environmental services. IV. Administrative and monitoring recommendations
1. Require the municipal administration to periodically report to the Municipal Council on the implementation of PWD measures.
2. Publish annual progress reports to ensure transparency and institutional accountability.
3. Establish measurable indicators for assessing the social impact of environmental policies on PWD.
V. Recommendations for capacity and awareness
1. Organize mandatory training for municipal administration and emergency structures on the inclusion of PWD.
2. Develop accessible information campaigns for the community, especially on emergency measures and environmental risks.
3. Strengthen institutional cooperation between the Municipality, CSOs and the PWD community.
VI. Recommendations for institutional dialogue
1. Organizing a hearing in the Municipal Council, to review this letter and follow up on the implementation of the recommendations.
2. Designating an institutional contact point, responsible for coordinating measures for PWDs.
These requests and recommendations are based on: the Constitution of the Republic of Albania,
Law no. 139/2015 “On Local Self-Government”, Law no. 93/2014 “On the Inclusion and Accessibility of Persons with Disabilities”, Law no. 10221/2010 “On Protection
from Discrimination”, Law no. 107/2014 “On territorial planning and development”, and the UN Convention on the Rights of Persons with Disabilities (CRPD), ratified by the Republic of Albania
DRAFT AND SUPPORTED:
Drafted by:
• Project Lead Association: Project Shpresa, Shkodër
Supported by:
Civil Society Organizations and Associations for PWD:
• Madonnina del Grappa
• Para-Tetraplegjikeve, Shkodër Branch
• The Door
• Papa Giovani XXIII Community – Shkodër
State Institutions for PWD:
• Shkodër State Development Center
• “3 Dhjetori” Special School – Shkodër
• Harmonia Center
State Institutions for PWD and Mental Health:
• Supported Psychiatric Home for Women and Men
Organizations for the Most Vulnerable Groups:
• Malteser Albania
Other Organizations:
• Student Alternative
Community and family members:
• Family members and caregivers of PWD
• Persons with disabilities
