17.

regrets that there has been a considerable delay in the implementation of integrated regional approaches and that the tool has not yet been able to produce all of the synergies that it could and should produce. However, this cannot and must not be extrapolated to suggest that implementing EU cohesion policy through integrated territorial investment is not effective. On the contrary, given the complications and lack of clarity, the fact that this tool — thanks to the great efforts of the staff of all the stakeholders — got off the ground at all and is yielding results with a real positive impact on the territory and its citizens is proof of its potential. Moreover, the CoR emphasises the added value of the integrated regional approaches where they have acted as a lever for capacity-building in certain contexts, facilitating an integrated territorial approach and multilevel governance where this had previously not existed. As emerged from the workshop on the state of sustainable urban development and ITI held at the European Committee of the Regions in 2017 (2), the main difficulties in introducing ITI in the current programming period are: — Late delivery of the ‘Guidance for Member States on Integrated Sustainable Urban Development (Article 7 ERDF Regulation)’, which the European Commission did not publish until May 2015. It was only on the basis of this document that a start was made on developing the architecture needed to implement ITI in Member States, tracing the boundaries of urban areas and identifying the procedures for approving policy documents on urban development, as well as the policy documents themselves. Only then could the planning of individual projects begin. — The main problem with the implementation and drafting of policy documents for urban areas with regard to ITI was that in most countries the operational programmes (OPs), along with their indicators and management systems, had already been approved at the beginning of the preparation phase for ITI implementation, without taking ITI into account. Urban strategies therefore had to adapt to the various pre-existing OPs and indicators, which greatly limited the flexibility of the strategies and their real synergetic effects. — In some cases the compulsory allocation of OP resources to ITI has not taken place, thus effectively rendering meaningless the whole notion of implementation and the achievement of effects of synergy by means of ITI. — Delays to implementation and the creation of unnecessarily complex ITI implementation structures in which, even at the level of urban areas, intermediary bodies need to be set up to monitor and evaluate projects, whereas in reality project selection mostly takes place at the level of the managing authorities of each OP. These structures seem disproportionate in some cases, given both the small amount of resources allocated to ITI and the very limited powers of these intermediary bodies or the possible duplication of action. Such complex implementation systems make the whole process unduly complicated in such cases. — The remit and powers of the bodies responsible for selecting operations (as defined in Article 7 of the ERDF Regulation) are not sufficiently taken into account in the implementation process. Where integrated territorial strategies for sustainable urban development are implemented in a functional area greater than official urban boundaries, the position of subregional authorities that are operating on the basis of a broad partnership of stakeholders in the area and on the basis of multi-level governance is, for the most part, not sufficiently well enshrined in law. The workshop also highlighted the positive aspects, in particular the fixed resources for the implementation of strategies, as well as the creation of synergies between projects and, above all, dealing with issues on the basis of local conditions and potential, i.e. the real application of a place-based approach;