Assembly of European Regions

July 2012Common Strategic Framework 2014-2020www.aer.eu

Contribution by the AER to the EC Staff working document

Common Strategic Framework2014-2020

Common Strategic Framework2014-2020

Assemblée des Régions d’Europe

6 Rue Oberlin - F-67000 Strasbourg 210 Avenue Louise - B-1050 Bruxelles Tel.: +33 3 88 22 07 07 - Fax : +33 3 88 75 67 19 Tel./Fax : +32 2 880 95 60 E-mail : secretariat@aer.eu E-mail : aer.brussels@aer.eu

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26 July 2012

Foreword and acknowledgements

Dear Sir/Madam, Cohesion policy is the European Union policy conceived for and applied by the regions, geared towards achieving an economic, social, and regional cohesion in Europe, thanks of course to this policy, but also to financial tools called structural funds, to be extended over a period of 7 years.

The debates and negotiations concerning the upcoming 2014-2020 period are in full swing since the publication, in June 2011, of the proposal for a multi-annual financial framework and, in October 2011, of the draft regulations determining the rules that will reign over cohesion policy. These regulations included common provisions for 5 principal funds: ERDF, ESF, Cohesion Fund, EARDF and EMFF. The general objective of the regulation is to create the conditions for an integrated use of the 5 aforementioned funds such that the common objectives derived from the Europe 2020 Strategy are reached.

The Common Strategic Framework (CSF) translates the objectives of the Europe 2020 Strategy into possible actions for the 5 funds, which will thus be “matricized” and integrated into a common strategy. An initial working document exposing the contents of the Common Strategic Strategy was published by the European Commission on 14 March 2012.

The Assembly of European Regions hopes to contribute to the debate on the Common Strategic Framework. Our recommendations are founded in 25 years of work experience, follow-up, and dialogue on the European policies most crucial to the regions and for economic, social, and territorial development within the European Union.

The ARE would like to thank, in particular, the regions that brought their support and ideas during the writing of this document :

! Bekes (H) ! Borsod-Abaúj-Zemplén (H) ! Bruxelles-Capitale (B) ! Ile-de-France (F) ! Languedoc-Roussillon (F) ! Madeira (P)

! Ruse (BG) ! Tampere (FIN) ! Tirana (AL) ! Wallonie (B) ! Wielkopoksla (PL)

We wish and hope that our recommendations will be disseminated all over Europe and effectively taken into account in European papers.

On behalf of the AER,

Pascal Goergen

Secretary General

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Common Strategic Framework 2014-2020 (CSF)

The Assembly of European Regions’ Contribution to the Commission’s Working Document

Synthesis

Context

The Common Strategic Framework translates the objectives of the Europe 2020 Strategy into workable actions for the 5 European funds (ERDF 1, ESF 2, Cohesion Funds, EARDF 3, FEAMP4). These funds are “matricized” and integrated into a common strategy. An initial working document exposing the content of the Common Strategic Framework was published by the European Commission on 14 March 2012. An amended document is to be published in autumn. Problem

The AER fully supports the CSF objective, which is to increase the efficiency of cohesion policy cohesion by strengthening its thematic focus on the one hand, and the synergies and coordination between the funds on the other. As far as the AER is concerned, the CSF should provide useful guidelines for the elaboration and coordination of regional and national strategies in order to prepare programmes integrating the different funds into cohesion policy, in accordance with Europe 2020. However, the working document proposed by the European Commission responds only partially to the expectations of cohesion policy’s main stakeholders, first and foremost the regions of Europe. Recommendations

- The CSF should be an instrument at the regions’ disposal, not a supplementary constraining element. It should be the object of a debate within the Parliament and the Council.

- The partnership principle should be reaffirmed and connections with the EU’s economic governance should be established with caution.

- The key actions proposed in the CSF annex should remain indicative: their definition and purpose should be clarified.

- The AER requests an increased decentralisation of all the funds, in order to facilitate coordinated management on the regional level.

- The AER regrets to the quasi-absence of interregional cooperation in Annex 2 of the CSF, and emphasised the importance of strengthening complementarities between the interregional cooperation programmes and the other programmes.

1 European Fund for Regional Development 2 European Social Fund 3 European Agricultural Fund for Rural Development 4 European Fund for Maritime Affairs and Fisheries

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Dissemination of the AER contribution: The AER contribution will, in the first place, be sent to all the Presidents of AER member regions. It will also be presented to the European Commissioners in charge of cohesion policy (J. Hahn and L. Andor) and to DG REGIO, as well as to the President of the REGI Committee in the European Parliament and to a targeted number of MEPs. It will be communicated to the Cypriot Council presidency, to the National Permanent Representations to the EU, to the Committee of Regions and to the European Economic and Social Committee. The AER member regions will be invited to send this contribution on to their national governments, particularly in order to insist on the indicative nature that the CSF should maintain, as well as the crucial question of partnership and of the regions’ involvement in the preparation of operational programmes and partnership contracts. Strasbourg, 26 July 2012 Pascal Goergen Secretary General p.goergen@aer.eu +32 2 880 95 68 +33 388 22 74 40 Contact : Estelle Delangle e.delangle@aer.eu +33 368 46 00 82

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Working document from the Commission – Elements of a

Common Strategic Framework 2014-2020

The Assembly of European Regions’ Contribution

The AER fully supports the objective of the Common Strategic Framework (CSF), namely, of increasing cohesion policy by strengthening its thematic focus on the one hand, and the synergies and coordination of funds on the other hand. For the AER, the CSF should provide useful guidelines for the elaboration and coordination of regional and national strategies in order to prepare programmes integrating the different funds into cohesion policy, in accordance with the Europe 2020 Strategy. That being the case, the working document proposed by the European Commission responds only partially to the expectations of cohesion policy’s main stakeholders, in particular the regions of Europe. Status, terms of adoption and objectives of the document: The document proposed by the European Commission poses a core problem because of the ambiguity of its status. It is presented by the Commission as a framework document, not as legislation, to be the object of a delegated act. In this case, the CSF should provide a set of guidelines directed towards the regions and member states, clearly formulating points of reference for coordinating the objectives of the regions, of the funds and of European 2020. However, this document hardly seems explanatory, nor very illustrative, and hardly proposes examples of best practices or points of reference geared towards regions or member states with the aim of helping them prepare their programmes in line with the different European, national, and regional strategies. Rather, it proposes a number of key actions of an obligatory nature, complementing certain elements already found in the regulations, making it an effectively legislative document. A Common Strategic Framework adopted by a delegated act should not contain new obligations with respect to the regulation in the legislative cohesion package.

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In a general sense, the CSF should remain indicative and remain what it is supposed to be: a tool, an instrument at the disposal of the regions, and not a supplementary constraining element to be tacked on to the existing regulations and methodological constraints. Regional specificities and the regions’ ability to design their development according to their own assets should not be relegated to the background. Moreover, given the numerous debates and questions provoked by the European Commission’s working document, is seems particularly inappropriate to adopt it as a delegated act and to spare the trouble of a debate within the Parliament and the Council in that regard. The main principles of cohesion policy within the Common Strategic Framework:

" Partnership In the frame of the principle of partnership, reaffirmed in the regulations, and in accordance with the code of good conduct in preparation, it is essential for each member state to initiate or strengthen a constructive dialogue with the regional authorities and to involve them in the upper levels of programme preparation, especially in the most traditionally centralised countries.

In a general sense, the institutional conditions for the implementation of structural funds within the member states, and especially the role of regional authorities, continue to be considered a separate issue, despite being a determining factor for cohesion policy’s greater efficiency.

The AER therefore encourages the Commission and the Parliament to insist on the necessity of decentralising the management of structural funds in all member states where this is possible, and where the regions ask for it:

- In the countries in which experience has demonstrated that the regions can effectively manage their structural funds, the principle should be extended to all regions that request it.

- In the other countries, experiments should be led to evaluate the regional authorities’ capacity to take on such responsibilities. In certain member states having more recently joined the EU, the need for technical assistance and training is important and should be satisfied in order to allow the regional authorities to improve their administrative capacities and staff.

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" Proportionality

It is important to recall that, in accordance with the principle of proportionality, the obligations weighing on the member states and on the regions are adjusted in function of the level of funding allocated, which varies considerably according to the states, the regions and the programmes. This applies to the simplification, and therefore for the efficiency, of the structural funds.

" Additionality and semi-yearly recurrence :

The working document proposes linking the use of CSF funds with the implementation of the country-specific-recommendations, which are not necessarily in line with cohesion policy, since the objectives of cohesion policy are specific to that policy.

If connections can exist in specific cases, one must consider that cohesion policy would not always provide an effective leverage for action in response to the structural changes lauded in the recommendations. Cohesion policy was created to compensate for the effects of the structural changes necessitated by European integration, not to implement those very changes.

Moreover, the recommendations made to the member-state level might not correspond to the abilities and priorities of the regions, and therefore their implementation in the framework of cohesion policy would constitute a serious deviation from the original objective of that policy, as well as from the principle of additionality.

Finally, these country-specific-recommendations are by definition short-term recommendations, and readapting the programmes along with the new recommendations would threaten the principle of the funds’ multi-annual nature.

" Conditionality

For the abovementioned reasons, the AER emphatically reiterates its opposition to a macro-economic conditionality and proposes, in turn, strengthening the conditionalities linked to the implementation of funds. Political objectives, thematic focus and key actions: In a general sense, it is too early to ask the regions to go into detail on the key actions, and all the more so since the Annex 1 was translated rather late. Moreover, this consultation does not necessarily correspond to the national and regional agendas for preparing their programmes, which in many cases are still in the diagnostic phase. Certainly, the thematic focus will allow to better use the funds, avoiding spreading resources too thin, and better targeting the objectives of the Europe 2020 Strategy. It is nevertheless crucial to respect the principle of subsidiarity and partnership, which make up the basis of cohesion policy.

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The key actions should be indicative and not prescriptive; they should guide the regions, but should not impose from the top specific measures that are not necessarily anchored in regional strategic potentialities.

Nor can they claim to be exhaustive, thus limiting the playing field for possible investments in to the framework of thematic objectives and investment priorities defined in the regulations.

The AER therefore requests a clarification of the definition, role, and constraining value of the key actions. Strengthening the coordination and integration between the funds and local areas: The AER applauds the implementation of any mechanism allowing for improved coordination between structural funds and especially the possibility of preparing multi-fund programmes corresponding to a real need in the area. Concerning the complementarities between the ERDF and the ESF, the AER is nonetheless concerned with the potential difficulties tied to the governance of these funds. Today, in most of the member states, the ESF is managed on the national level, with a sometimes limited respect for the principle of additionality. No serious motivation can be detected from the member states, nor from the European Commission, to change that. On the contrary, upon reading the plan for regulation concerning the ESF, the AER detects a movement towards less decentralisation. The ESF and the ERDF are very often managed on different levels, while their implementation should ideally go hand in hand. Moreover, the actions sustained by the ESF have a very strong regional dimension. We therefore recommend an increased decentralisation in the implementation of the ESF. The AER is equally watchful of the coordination that could possibly be created between the EARDF and the ERDF/ESF, since this programme is managed by even more diverse departments. Managing all these funds on the same level and giving more weight to regional councils in their coordination would facilitate the programmes’ integration. Finally, the AER raises the question of coordination within the European Commission: what are the proposed internal measures for facilitating coherence and dialogue?

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Territorial cooperation: The AER regrets the quasi-absence of interregional cooperation in Annex 2 of the CSF, an annex dedicated above all to cross-border cooperation. Certainly, cross-border cooperation represents the heft of the territorial cooperation budget, but the other cooperation programmes also deserve to be tackled It is particularly necessary to reinforce the complementarities between interregional cooperation programmes (INTERREG and ESPON in particular) and other programmes, as well as emphasizing these programmes’ strategic contribution to regional policies. Conclusion: All in all, the proposed measures are fairly non-specific and not very concrete. The regions of Europe expected this CSF to guide them in an explicit, exemplifying, and concrete manner in order to better define the funds on the operational level, and to write partner contracts in accordance with the great number of other documents that they must adapt to. This is not a practical guide as expected. The CSF should not, paradoxically, excessively complicate the already dense and highly directive regulations. Finally, it is important for the Framework to be published in a timely manner, concomitant with the adoption of the “Cohesion” package, in order not to slow down the start of the programmes’ implementation.

Assemblée des Régions d’Europe

6 Rue Oberlin - F-67000 Strasbourg 210 Avenue Louise - B-1050 Bruxelles Tel.: +33 3 88 22 07 07 - Fax : +33 3 88 75 67 19 Tel./Fax : +32 2 880 95 60 E-mail : secretariat@aer.eu E-mail : aer.brussels@aer.eu

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Contacts Pascal Goergen Secretary General p.goergen@aer.eu +32 2 880 95 68 +33 388 22 74 40 Estelle Delangle e.delangle@aer.eu +33 368 46 00 82