Opinion of the Economic and Social Committee on "European policy on crossfrontier cooperation and experience with the Interreg programme"
Date: 2001-03-28
Institutions: European Economic and Social Committee
Subjects: EU programme, cross-border cooperation, project evaluation, regional policy

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Official Journal of the European Communities

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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 oppor-
tunity 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.

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.

Another aspect of

2.2.
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, moni-
toring and management of projects, especially cooperation
projects. Although understandable and desirable, this require-
ment effectively excludes newer bodies which have not yet
proven themselves fully from drawing up and submitting
projects, some of which are of high quality.

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.

2.3.
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. General comments

2.1.
The Committee notes the clear distinction between
more and less developed Member States as regards the various

(1) COM(1999) 479 final.
(2) OJ C 51, 23.2.2000, p. 92.

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.

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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
to provide the end
States should make a greater effort
beneficiaries with information in good time.

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.

The lesser, or greater, involvement of the regions is
3.1.1.5.
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.

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:

The Committee feels that regional operators should
3.1.1.6.
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.

3.1.1. E f f e c t i v e a n d a p p r o p r i a t e i n v o l v e m e n t
i n
s a m e p r o j e c t , p a r t i c u l a r l y w i t h
v a r i o u s

b y t h e v a r i o u s r e g i o n s t a k i n g p a r t
t h e
r e g a r d t o t h e
r e g i o n a l p l a y e r s

i n p u t o f

t h e

3.1.2. D e f i n i t i o n

o f

r e g i o n s ,
t h e
( i n ) a p p r o p r i a t e n e s s
t h e m e t h o d
u s e d a n d t h e c o n s e q u e n c e s o f t h i s d e f i -
n i t i o n f o r t h e s e l e c t i o n o f p r o j e c t s

e l i g i b l e
o f

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.

3.1.2.1.
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.

However, the inappropriateness of using NUTS to
3.1.2.2.
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.

3.1.1.4.
Judging by the experience of regions which do
have cross-border agencies, the advantages such agencies bring

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

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3.1.3. S c o p e

o f

s t r a n d s v s .
j e c t s

a c t i o n
d i f f e r e n t
t h e h o r i z o n t a l i t y o f p r o -

u n d e r

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.

3.1.3.1.
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 demon-
strates 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 some-
times 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. O b s t a c l e s c r e a t e d b y d i f f e r i n g e c o n o -
m i c m o d e l s , l e g a l p r o v i s i o n s , a d m i n i s -
t r a t i v e
p r o c e d u r e s
b e t w e e n r e g i o n s p a r t i c i p a t i n g i n t h e
s a m e p r o j e c t

r e g u l a t i o n s

a n d

Judging from past experience, the Committee noted
3.1.4.1.
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 recei-
ving support.

The Committee feels that, in order for there to be
3.1.4.4.
effective cooperation,
it is advisable to establish common
standards to facilitate relations between regions. The Com-
mission 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 manage-
ment, payment and support) would address the differences
which exist, thereby increasing the effectiveness of the pro-
gramme.

3.1.5. I n t e r v e n t i o n b y t h e C o m m i s s i o n a t t h e
v a r i o u s s t a g e s o f t h e p r o g r a m m e , f r o m
i t s
s e l e c t i o n a n d
c o n c e p t i o n t o t h e
m o n i t o r i n g o f p r o j e c t s

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 inter-
vene in the selection of projects, but focus instead on the
planning stage of the programme.

At the same time, excessive intervention by Mem-
3.1.5.2.
ber States’ central administrations has the effect of inhibiting
regional players.

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.

3.1.5.3.
The Committee nevertheless feels that in some
circumstances the Commission should play a more pro-
nounced 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.

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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.

3.1.6.7.
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 pro-
gramme. 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.

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

3.1.7. D i s t r i b u t i o n

o f

I n t e r r e g

f u n d i n g

a m o n g d i f f e r e n t t y p e s o f p r o m o t e r s

3.1.6. S p e e d o f
n i n g
t o
i m p l e m e n t a t i o n

t h e p r o g r a m m e ,
s t a g e
t h e

f i n a l

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

f r o m p l a n -
p r o j e c t
o f

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

As information on the programme has not been
3.1.6.2.
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 pro-
cedural differences from country to country. The Committee
once again calls on the Commission to focus on this fact and
the need to address it.

The Committee feels that

3.1.7.2.
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 coope-
ration. 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.

3.1.6.4.
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.

3.1.8. C o n t i n u i t y o f p r o j e c t s b e y o n d t h e e n d

o f I n t e r r e g

3.1.8.1.
projects financed by Interreg once the programme is over.

The Committee notes the high mortality rate of

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.

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

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.

The Committee feels that the capacity of a project
3.1.8.3.
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 responsi-
bility. This in no way contributes to the development of a
capacity for initiative and for effective cooperation in concrete
terms.

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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.

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.

3.1.9. I n v o l v e m e n t
p a r t n e r s
p r o g r a m m e

o f

t h e

i n t h e v a r i o u s s t a g e s o f

s o c i o - e c o n o m i c
t h e

3.1.9.1.
The Committee has observed that the socio-econ-
omic 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 Com-
mittee wishes to highlight:

4.1.1.
In the various aspects of the programme and its
implementation, a clear distinction is apparent between more
the problems of
and less developed countries,

in that

Brussels, 28 March 2001.

The second point concerns the lack of flexibility in
4.1.2.
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 decentralis-
ation also pre-empts the problem of Interreg objectives being
distorted by central administrations.

The Committee feels that cooperation is increasingly
4.1.4.
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
an
important and powerful instrument for the achievement of
these objectives. Careful and thoughtful planning, involving
regional players from the start, is fundamental, and consider-
ation 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.

cooperation and Prism (1).

Interreg is

(1) OJ C 116, 20.4.2001.

The President

of the Economic and Social Committee

Göke FRERICHS