The “consultation period” for comments and proposals to the draft of the new National Human Rights Plan 2015-2019 expired on October 15 after a brief extension. State media reports that the government has held 64 consultations in all 23 states and the Capital District, in the three months since the presentation of the draft plan. It also says it has received comments from 20,700 persons via the web page of the National Human Rights Council, the promoter of the plan.

Independent human right organizations however remain skeptical both of the draft and of the consultation period opened by the government. On October 13, right before the expiration of the consultation period, Rafael Uzcátegui, General Coordinator of the Programa Venezolano de Educacción – Acción en Derechos Humanos (PROVEA), wrote an open letter exposing the main critiques his organization has of the draft plan.

In his letter Uzcátegui argues that the three months of the consultation period were insufficient. He says that similar experiences of drafting and consultations of national human rights plans in other countries, for example Chile and Mexico, have taken far longer in order to ensure adequate participation of civil society.  He also reminds that PROVEA had asked for the inclusion of the UN High Commissioner for Human Rights in the process, but this petition went unanswered.

As in previous criticisms of the original draft, Uzcátegui points to “partial ideological visions” in the document which limits its universality and makes it acceptable to “only one sector of society.” He argues that with an adequate consultation methodology these biases could have been corrected and the “many good ideas in the draft” could have been reinforced.

On August 4, while the consultation period was running, several human rights groups under the umbrella organization Foro por la Vida–including PROVEA, the UCAB Center for Human Rights, the UCV Center for Human Rights, COFAVIC, and others–published a press release in which they criticized the consultation methodology and claimed that it excluded the participation of civil society in the process.

Foro por la Vida also made concrete proposals to the draft plan, such as the inclusion of the United Nations recommendations made in several evaluations of the country, the extension of the consultations period to 9 month, and the incorporation of UN experts and of interdisciplinary teams of human rights defenders of recognized trajectory in the re-writing of the draft.

State media reports that in the last month that the National Human Rights Council has taken the draft plan for discussion to government institutions, the National Assembly, high schools and universities, and that even elementary school children to ask for opinions.

Local press also informed about a series of proposals made by the Judicial Power and presented by its president Gladys Gutiérrez Alvarado to the Human Rights Council, but those proposals have not been made public.

In one of the meetings led by the National Human Rights Council executive secretary Larry Devoe, the plan included the “need for the State to strengthen measures to protect citizens from possible violations of human rights which come from the private sector,” in agreement with “a new vision which has been advancing all over the world that recognizes that not only State institutions, but also private and business sectors can affect and violate human rights.” In another meeting in the State of Lara, Devoe also made emphasis on the achievements of the current government on human rights when compared to previous governments.