In Germany, the question concerning how far nongovernmental organisations (NGOs) should have access to the courts is greatly disputed. The decision of the ECJ of 12 May 2011 in Case C-115/09 has made it clear that the German provisions in the Umweltrechtsbehelfsgesetz (the Law on Supplementary Provisions Governing Actions in Environmental Matters) requiring environmental NGOs to rely on a rule designed to protect the interests of individuals (in co