Opinion of the Economic and Social Committee on "European policy on crossfrontier cooperation and experience with the Interreg programme"

(2001/C 155/04)

On 11 July 2000 the Economic and Social Committee, acting under Rule 23(3) of its Rules of Procedure, decided to draw up an opinion on European policy on cross-frontier cooperation and experience with the Interreg programme.

The Section for Economic and Monetary Union and Economic and Social Cohesion, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 13 March 2001. The rapporteur was Mr Barros Vale.

At its 380th plenary session (meeting of 28 March 2001), the Economic and Social Committee unanimously adopted the following opinion.

1. Introduction

1.1. The present opinion is intended to provide an analysis of the practical experience to date of implementing the Interreg Community Initiative on crossfrontier cooperation in order to assess the effectiveness and efficiency of the programme with a view to introducing corrective measures in future.

1.2. In December 1999, the Committee had the opportunity to express its views on the Commission proposal on the Interreg III(1) programme in an opinion(2), but lack of time then means that a supplementary study of previous practical experience in implementing this kind of Community Initiative is now called for, which is the reason for drawing up the present opinion.

1.3. In drawing up this document, the regional bodies responsible for managing the programme in the Member States, as well as a variety of final operators, were consulted on their views and experience. The concerns which emerged, combined with the results of the hearing held on 19 December 2000 and a questionnaire, form the basis of this document.

2. General comments

2.1. The Committee notes the clear distinction between more and less developed Member States as regards the various stages of the programme, from conception to the type of projects, and including management and the procedures used. Opinion on the overall functioning and success of Interreg I and II is thus divided into two main camps, corresponding to the more and less developed and/or centralised countries.

2.2. Another aspect of the programme noted by the Committee are the high demands placed on the promoting bodies; promoters require a considerable amount of working experience, particularly as regards the implementation, monitoring and management of projects, especially cooperation projects. Although understandable and desirable, this requirement effectively excludes newer bodies which have not yet proven themselves fully from drawing up and submitting projects, some of which are of high quality.

2.3. The Committee feels that the Commission should establish simpler procedures to allow newer bodies access to the programme, otherwise we will continue to see the same institutions promoting cooperation projects to the exclusion of others which might be equally or more valid.

2.4. The Committee noted that there are projects where the promoters and bodies involved made substantial investments prior to submitting an application to Interreg and these investments were not accounted for in the application. The Committee feels that these bodies should be compensated retroactively for intangible costs incurred in the preparation of the project, even though the investments were made before the application was submitted, provided there is proof that such investments related to the project in question and did not infringe the Commission's general eligibility rules. Disregarding these sums may exclude projects which require the investment of own resources prior to application, such as studies, because the promoters have limited financial resources and are unable to take on the costs involved.

2.5. Another point noted by the Committee is the lack of sufficient information on the programme and its functioning provided by the public authorities of the Member States and the limited amount of time allowed for this to filter through. Although it is distributed, information takes too long to reach project promoters, which leads to delays in implementing the programme. The Committee therefore feels that the Member States should make a greater effort to provide the end beneficiaries with information in good time.

3. Specific comments

3.1. A number of important points covering the various stages and components of the programme emerge from the analysis of past experience. The Committee feels that these should be given appropriate consideration by the Commission:

3.1.1. Effective and appropriate involvement by the various regions taking part in the same project, particularly with regard to the input of the various regional players

3.1.1.1. Some regions have "cross-border agencies", bodies with responsibility for dealing with the various aspects of cross-border issues, and in particular, for promoting cooperation between border regions. These are composed of a vast range of representatives of regional operators. In such regions, the role played by these agencies has been fundamental, both in terms of procedure, and chiefly in terms of the regions' effective involvement in projects which have a clear relevance for them.

3.1.1.2. In countries where no such agencies exist, the difficulties involved are greater, as promoters have much less of a framework within which to initiate and monitor the programme, making it difficult to identify potential partners on the other side of the border. This often results in the selection of a partner with different characteristics, particularly as regards its financial capacity, which inevitably leads to regions having differing levels of involvement in projects.

3.1.1.3. In many cases, it seems to be particularly difficult to involve the various regional operators because of the absence of a cross-border coordination body.

3.1.1.4. Judging by the experience of regions which do have cross-border agencies, the advantages such agencies bring are clearly apparent. It would well behove the Commission to look into this issue with a view to promoting the creation of such agencies before the programme is implemented.

3.1.1.5. The lesser, or greater, involvement of the regions is determined by their specific interests, but it also depends on political interests at national level. These determine the type of projects approved in all cases where the decision-making process is too centralised.

3.1.1.6. The Committee feels that regional operators should be effectively involved, taking a leading role in projects between regions within the EU, with input coordinated at national level in the case of regions bordering onto the EU, as the experience of cooperation in such cases is still very limited or sometimes non-existent.

3.1.2. Definition of eligible regions, the (in)appropriateness of the method used and the consequences of this definition for the selection of projects

3.1.2.1. It seems to the Committee to be taken as read that eligibility is determined on the basis of NUTS, in order both to simplify procedures within the Commission and to allow use of an established and well-used nomenclature which is familiar to all Member States.

3.1.2.2. However, the inappropriateness of using NUTS to define areas eligible for Interreg becomes apparent in some cases, where relevant and high-quality projects are excluded because the promoters are not based within the eligible areas.

3.1.2.3. The Committee therefore feels that the criterion to be applied should be the region(s) benefiting from the project, that is to say, the project would meet the regional eligibility criterion as long as the benefits accrued to eligible regions. This procedure was used during previous programmes for some regions, with quite favourable results.

3.1.2.4. However, the nature of actions should be guaranteed so as not to distort the principles and objectives of the programme, which is cross-border cooperation.

3.1.3. Scope of action under different strands vs. the horizontality of projects

3.1.3.1. The Committee noted the existence of horizontal projects which did not "fit" perfectly into any strand, but instead had features which met the specifications of more than one strand. This horizontality resulted in most cases in the project not being adopted, or being split up into several different projects, each applying under the relevant strand. This demonstrates the inflexibility of the selection criteria.

3.1.3.2. The Committee feels that such procedures in no way contribute to the success of the programme and sometimes serve to distort the objectives of projects, possibly even prejudicing their quality. (It should be borne in mind that the difficulty is often compounded by having to manage several different projects instead of a single, integrated one).

3.1.3.3. The Committee also feels that creating obstacles for the submission of applications and the analysis of projects is discouraging for promoters, as it further complicates a procedure which is already slow and complex. Once again, projects of high quality and relevance with great potential for success in terms of Interreg objectives may be excluded.

3.1.3.4. Here too there is a clear need to build greater flexibility into the project selection criteria so as not to reject valid and relevant projects.

3.1.4. Obstacles created by differing economic models, legal provisions, administrative regulations and procedures between regions participating in the same project

3.1.4.1. Judging from past experience, the Committee noted that differing legislation from one country to another makes the projects more difficult to implement. The Committee thinks that those responsible for implementing the programme should be prevailed on to lay down common standards allowing the use of coordinated guidelines and procedures across the Member States, so as to make procedures as effective as possible, especially as regards the preparation of applications, assessments and decisions on the projects receiving support.

3.1.4.2. This is also true of economic models, where the differences which exist impose constraints, particularly by rendering it impossible to find common routes to development so as to be able to define truly common projects.

3.1.4.3. At the project analysis and selection stage, the Committee noted that the different procedures and rules applied by the various countries led in some cases to hold-ups and sometimes even to projects being abandoned.

3.1.4.4. The Committee feels that, in order for there to be effective cooperation, it is advisable to establish common standards to facilitate relations between regions. The Commission must therefore promote the approximation of the processes and procedures adopted in the regions, and even of legislation. Promotion by the Commission of agreements between border regions with a view to establishing common rules under Interreg is a possible option which has already been successfully tried in some regions.

3.1.4.5. The Committee also noted that the situation is even more serious in regions which border onto the EU inasmuch as there are already rules and standards applying to all Member States which are not shared by neighbouring countries. The Committee feels the Commission should make greater efforts with respect to these regions so as to make cooperation effective.

3.1.4.6. The Committee feels that, by making it possible to define common rules for project management, having joint cooperation mechanisms (especially for programme management, payment and support) would address the differences which exist, thereby increasing the effectiveness of the programme.

3.1.5. Intervention by the Commission at the various stages of the programme, from its conception to the selection and monitoring of projects

3.1.5.1. The Committee feels that decentralising Interreg procedures brings benefits in terms of more effective and efficient implementation of the programme. The Commission and Member States' central administrations should not intervene in the selection of projects, but focus instead on the planning stage of the programme.

3.1.5.2. At the same time, excessive intervention by Member States' central administrations has the effect of inhibiting regional players.

3.1.5.3. The Committee nevertheless feels that in some circumstances the Commission should play a more pronounced role in order to ensure adherence to the programme's true objectives, making it difficult for funds to be used for other purposes, more especially by the central administrations of the Member States.

3.1.5.4. It would seem to be important for the Commission to have greater involvement at the planning stage as Interreg is also a vehicle for implementing European policy and principles which must at all times reflect the broad directions of the EU.

3.1.5.5. The Committee also feels that the Commission should have a greater presence in coordinating and advising those responsible for the programme at regional level.

3.1.6. Speed of the programme, from planning to the final stage of project implementation

3.1.6.1. Looking at past experience of Interreg implementation, the Committee notes that there are delays at various levels which mean that procedures are slower than necessary or desirable.

3.1.6.2. As information on the programme has not been provided on time, there have in the past been delays in implementing the programme. The Committee would reiterate that it is vital to ensure that Member States are provided with quality information in good time.

3.1.6.3. Another of the factors leading to delays are procedural differences from country to country. The Committee once again calls on the Commission to focus on this fact and the need to address it.

3.1.6.4. The greatest delays occur at the stage of submitting projects because of procedural differences between regions, as already mentioned, and at the stage of inspection for the payment of funding.

3.1.6.5. The Committee feels that, in addition to a single management authority, it would perhaps be desirable to have a single payment authority so as to speed up procedures.

3.1.6.6. It should also be pointed out that, in countries where decisions are taken closer to the centre, the time needed for project approval is even greater. The Committee feels that this is another reason for the programme to be decentralised further.

3.1.6.7. It should also be mentioned here that the slowness of procedures necessarily shortens the time available for project implementation, to the detriment of the whole programme. The Commission should therefore give consideration to these points with a view to speeding the programme up and making it more effective in the process.

3.1.7. Distribution of Interreg funding among different types of promoters

3.1.7.1. Throughout the implementation period of previous Interreg programmes, the Committee noted that central administrations accounted for a large proportion of the total number of project promoters in the less developed countries.

3.1.7.2. The Committee feels that Interreg applications from central administrations should be rigorously assessed, in order to provide transparency regarding the manner in which the funds are used, as such projects often distort the prime objective of the programme, which is cross-border cooperation. It is vital that the essential objectives of Interreg do not take second place to the priorities of central administrations. Once again, the problem is more acute in those countries where management of the programme is more centralised.

3.1.7.3. Attention should also be focused in this context on the enormous difficulty encountered by newer private-sector bodies in gaining access to the programme, rejected as they often are because of their limited experience in the management, monitoring and implementation of projects. The Committee therefore feels it is important, as mentioned earlier, that simpler procedures are applied when analysing newer promoters and when monitoring, maybe more closely, the projects promoted by them.

3.1.8. Continuity of projects beyond the end of Interreg

3.1.8.1. The Committee notes the high mortality rate of projects financed by Interreg once the programme is over.

3.1.8.2. It also notes that some of the projects which continue after the end of the programme have recourse to public funding.

3.1.8.3. The Committee feels that the capacity of a project to be self-supporting should be a relevant factor in the selection of projects. It is well known that allowing "subsidy-dependent" projects to be implemented frees promoters of any responsibility. This in no way contributes to the development of a capacity for initiative and for effective cooperation in concrete terms.

3.1.8.4. It is the Committee's view that Interreg must serve to create structures, in this case in border regions, with the capacity to continue the work of cooperation beyond any Community programme or public funding by being self-supporting. This will give the programme a more lasting impact.

3.1.9. Involvement of the socio-economic partners in the various stages of the programme

3.1.9.1. The Committee has observed that the socio-economic partners are not involved to a sufficient degree in a number of Member States, from conception to practical implementation of the programme.

3.1.9.2. In order for the programme and the projects it comprises to be really in touch with the social and economic reality it is intended to serve, the Committee feels that the systematic involvement of the socio-economic partners in the various regions concerned is essential. The Commission should ensure that the Member States make this involvement a reality.

4. Conclusions

4.1. Some important points emerge from analysis of past experience of INTERREG implementation, which the Committee wishes to highlight:

4.1.1. In the various aspects of the programme and its implementation, a clear distinction is apparent between more and less developed countries, in that the problems of implementing and managing the programme are more acute in the latter category. The Committee feels that it is vital for the Commission to focus its attention on this issue with a view to preparing the ground for the less developed countries to implement the programme correctly. This would have a direct impact on the efficiency and effectiveness of the programme.

4.1.2. The second point concerns the lack of flexibility in project selection criteria which, as noted earlier, may exclude valid projects and promoters with major potential. The Commission should look into this issue and build greater flexibility into the programme.

4.1.3. The decentralisation of the programme is also an important point, as it enables regional players, who have a better knowledge of the realities in the regions where they are based, to manage matters more effectively and take a more direct and committed role in cooperation. Greater decentralisation also pre-empts the problem of Interreg objectives being distorted by central administrations.

4.1.4. The Committee feels that cooperation is increasingly a factor for success, and the EU is no exception. Promoting a rapprochement of regions divided by borders throughout history is a key element when setting out to achieve a true union of countries. Here the Committee would draw attention to the conclusions and analysis set out in its recent opinion on crossfrontier cooperation and Prism(3). Interreg is an important and powerful instrument for the achievement of these objectives. Careful and thoughtful planning, involving regional players from the start, is fundamental, and consideration must also be given to the diversity between countries, whether in the economic models they follow, their legislation and procedures or even in their levels of development.

Brussels, 28 March 2001.

The President

of the Economic and Social Committee

Göke Frerichs

(1) COM(1999) 479 final.

(2) OJ C 51, 23.2.2000, p. 92.

(3) OJ C 116, 20.4.2001.