Special Report No 4/2004 on the programming of the Community Initiative concerning trans-European cooperation – Interreg III, together with the Commission's replies
Date: 2004-07-01
Institutions: European Court of Auditors
Subjects: EU initiative, cross-border cooperation, frontier region, project evaluation, regional cooperation, report

7.12.2004

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I

(Information)

COURT OF AUDITORS

SPECIAL REPORT No 4/2004

on the programming of the Community Initiative concerning
trans-European cooperation – Interreg III, together with the
Commission’s replies

(pursuant to Article 248(4), second subparagraph of the EC Treaty)

(2004/C 303/01)

CONTENTS

Paragraph

Page

SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Main features of the Initiative for the period 2000 to 2006 . . . . . . . . . . . . . . . . . . . . . . .

The Court’s audit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

THE COMMISSION GUIDELINES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Do the guidelines contain an adequate definition of trans-European projects? . . . . . . . . .

Do the guidelines include specific implementing rules? . . . . . . . . . . . . . . . . . . . . . . . . . .

Do the guidelines include specific measurable objectives and targeted measures? . . . . . .

Objectives and indicators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Targeting of measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Are the eligible areas clearly defined? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Were the guidelines and methodology documents made available to the Member States at
the appropriate time? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

THE COMMISSION’S PROCEDURE FOR EXAMINING CIP PROPOSALS . . . . . . . . . . . . . . . .

Did examination help to enhance CIP quality? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Did the Commission approve the CIPs within the agreed deadlines? . . . . . . . . . . . . . . . .

COOPERATION DURING PREPARATION AND IMPLEMENTATION . . . . . . . . . . . . . . . . . . .

Did the preparation of CIPs include a process of consultation? . . . . . . . . . . . . . . . . . . . .

Do the Member States cooperate on the implementation of CIPs? . . . . . . . . . . . . . . . . . .

CONSISTENCY BETWEEN THE INITIAL ANALYSIS AND CHOICE OF MEASURES AND THE
ADDED VALUE OF THE FIRST PROJECTS TO BE ADOPTED . . . . . . . . . . . . . . . . . . . . . . . . .

Is the ex ante evaluation used in the drafting of programmes? . . . . . . . . . . . . . . . . . . . . .

I-XI

1-11

1-5

6-9

10-11

12-29

13-14

15-16

17-25

19-21

22-25

26-27

28-29

30-39

31-34

35-39

40-50

41-42

43-50

51-69

52

Were the results of the previous programming period taken into account? . . . . . . . . . . .

53-54

5

6

6

7

7

8

8

8

8

9

9

10

10

10

10

11

11

11

12

12

13

13

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Paragraph

Page

Was there integrated analysis of the regional situations? . . . . . . . . . . . . . . . . . . . . . . . . .

55-57

Can the problems addressed be attributed to the existence of a border?

. . . . . . . . . . . . .

58

Are programme priorities synonymous with identified needs? . . . . . . . . . . . . . . . . . . . . .

59-63

Is there complementarity between the Interreg III CIPs and traditional ERDF interven-
tions? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Do the first projects adopted qualify as trans-European and do they offer added value?

THE FEASIBILITY OF MEASURING PROGRESS EX POST . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Are the programme objectives well structured? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Are the objectives measurable and quantified? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

CONCLUSION AND RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The guidelines focus on operational procedures but were made available too late and
contain over-generalised objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The procedure for examining CIP proposals must be improved . . . . . . . . . . . . . . . .

Preparation and the start of implementation are generally characterised by coopera-
tion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Analyses are generally integrated but of little use; no connection exists between
analyses and the definition of programme measures; the added value of projects
needs to be enhanced . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The available tools are inadequate to the task of measuring the impact of CIPs in rela-
tion to their objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Recommendations

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

64-65

66-69

70-78

71-72

73-78

79-99

79-96

80-83

84-85

86-87

88-94

95-96

97-99

The Commission’s replies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

13

13

14

14

14

15

15

15

16

16

16

16

17

17

17

17

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CI

CIP

EEIG

ERDF

ESDP

JTS

ABBREVIATIONS AND GLOSSARY

Community Initiative. One form of Structural Fund intervention, alongside opera-
tional programmes, technical assistance and innovative actions. There are four CIs:
Interreg, Urban, Leader and Equal.

Community Initiative programme.

European Economic Interest Grouping. EEIGs are legal instruments established
under Council Regulation (EEC) No 2137/85 of 25 July 1985 (OJ L 199, 31.7.1985,
p. 1) to permit legal entities and natural persons from different Member States to
form legal groupings.

European Regional Development Fund

European Spatial Development Perspective. A discretionary and non-binding inter-
governmental document adopted in Potsdam in May 1999 by the Informal Council
of Ministers responsible for Spatial Planning. It is a policy framework that was
adopted to improve cooperation between Community sectoral policies with signifi-
cant spatial impacts.

Joint technical secretariat. This body assists the managing authority in the exercise
of its duties.

Managing authority

An authority or body designated to manage an intervention programme. It is
responsible, on the one hand, for the efficiency and correctness of management and,
on the other hand, for implementation (receiving, examining and evaluating pro-
posed operations, gathering data, drawing up the annual report, organising the mid-
term evaluation, etc.).

Monitoring committee

Body appointed for each programme by the Member States concerned. It is respon-
sible for checking how assistance is being managed by the managing authority,
ensuring compliance with the programme priorities and implementing rules and
reviewing the programme evaluation.

NUTS

Objective 1

Objective 2

Nomenclature of Statistical Territorial Units, which divides each Member State into
a hierarchy of regions (NUTS level I). These are then subdivided into NUTS level II
regions, which are again sub-divided into NUTS level III. The territory of the Euro-
pean Union comprises 78 regions at level I, 210 regions at level II and 1 093 at
level III.

One of the three priority objectives of the Structural Funds. It seeks to promote the
development and structural adjustment of regions whose development is lagging
behind. As a rule, all the Funds contribute to programmes targeting these regions.

One of the three priority objectives of the Structural Funds. It seeks to support the
economic and social conversion of areas facing structural difficulties. Only the ERDF
and the European Social Fund (ESF) contribute under this objective.

Paying authority

An authority or body designated for the purposes of drawing up and submitting
payment applications and receiving payments from the Commission.

SFs

Structural Funds

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Steering committee

Committee responsible for the joint selection of projects and for the coordinated
monitoring of project implementation. It is composed of representatives from each
country. Where appropriate,
its duties may be discharged by the monitoring
committee.

SWOT

Trans-European

Strengths, weaknesses, opportunities and threats. SWOT analysis is a strategy defi-
nition tool. It consists of establishing a list of strengths and weaknesses, opportu-
nities and threats in the field concerned, which in this case is a territorial area.

Generic term used for the three strands of the Initiative: cross-border cooperation
(Strand A), transnational cooperation (Strand B) and interregional cooperation
(Strand C).

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SUMMARY

I.
The Interreg Community Initiative (CI) was launched in 1990 in an attempt to tackle the isolation of
border areas. By proposing cooperation between partners in different Member States, it contributes to the
opening of borders. It was renewed for the periods 1994 to 1999 (Interreg II) and 2000 to 2006 (Interreg III).
With commitment appropriations of 4 875 million euro, Interreg III is the most substantial CI.

The Court’s audit of Interreg III covered the period from the preparation of the Commission guidelines

II.
to the first decisions to adopt beneficiaries’ projects. The objective was to answer the following questions:

(a) Do the guidelines make it easier to attain the CI objectives?

(b) Did the Commission use a suitable procedure for examining CIP proposals and were decisions taken

within the agreed deadlines?

(c) Did the various partners cooperate as provided by the guidelines?

(d) Was the initial analysis for each region consistent with the priorities and measures of the corresponding

CIP, as required by the guidelines?

(e) Will it be possible to measure progress ex post?

The Interreg III guidelines focus on the procedures for implementing programmes that seek to enhance
III.
cooperation. However, they were not made available until preparation of the CIP proposals had been under
way for at least a year. The proposed objectives are not targeted and cannot be measured or quantified. There
are no indicators with which to assess how much overall progress has been made.

IV.
Procedures by which the Commission could examine CIP proposals had been devised and put in place.
However, the assessment criteria were under-prepared and insufficient improvements had been made in
response to the significant shortcomings identified in the proposals. The adoption of the programmes was
delayed, with the result that the process of cooperation between eligible regions was interrupted and the avail-
able appropriations were under-utilised.

V.
As advocated by the guidelines, the programmes were prepared in the context of a consultation pro-
cess. The partners from the various Member States generally contribute to implementation in a spirit of
cooperation. However, there remain some obstacles to setting up CIP implementation structures that are genu-
inely shared and to allocating the financial resources of the ERDF.

From the point of view of consistency, the Strand A and B programmes incorporate numerous analy-
VI.
ses. However, these are of little use. This is because the priorities and measures were established on the basis of
other concerns which are not elucidated in the programmes. Neither were decisions made concerning the reso-
lution of problems caused by the presence of a border, and the analyses do not help to fix the starting points
in terms of which progress is to be measured. The first projects to be adopted were prepared and will be imple-
mented in the context of cooperation between the different partners concerned. However, because some
projects are limited to the sharing of experience, they do not always contribute significantly to the resolution
of problems specific to border areas.

VII.
The indicators are inadequate to the task of ex post evaluation of the progress made. They do not cor-
respond closely enough to the objectives. Moreover, some indicators need to be clarified and the information
sources used to constitute them should be more precise. In most of the cases examined the computer appli-
cation had still not been introduced.

VIII.
For the current period, the Court recommends that the systems of indicators applied to each CIP be
simplified and improved in order to give a more valid measure of impact. The project selection criteria should
be strengthened so as to enhance the added value of projects, i.e., the degree to which they contribute to the
resolution of border-related problems.

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If the Initiative is renewed after 2006, the Commission should launch a study to ascertain which prob-
IX.
lems are caused by the existence of a border. Whatever the approach adopted, the study would help in the set-
ting of concrete objectives to be given priority status in the CI and which give the CI itself added value. Indi-
cators therefore need to be defined for each strand. Subsequently, setting detailed criteria for the Commission’s
assessment of CIP proposals would make it possible to adopt a proactive approach towards the Member States.
The analyses requested at the level of each CIP should be used to set specific objectives and measure progress
at that level.

The guidelines and methodology documents should be made available before work starts on preparing

X.
CIPs, and the ex ante assessor’s role and the content of the programme complement need to be clarified.

XI.
Finally, in order to encourage cooperation the financial resources allocated to the Initiative should no
longer be assigned by Member State, and the work begun on legal cooperation instruments should be com-
pleted and the recommendations put into effect.

INTRODUCTION

Context

1.
The Interreg Community Initiative (CI) was launched in
1990 in an attempt to tackle the isolation of border areas.
National frontiers are obstacles to the balanced development and
integration of the European territory. Firstly, they separate bor-
der communities economically, socially and culturally, thereby
hindering collaborative management (1). In addition, there is a
tendency for national policy to neglect border areas, which thus
take on secondary importance within the national territory. The
CI was renewed for the period 1994 to 1999 (Interreg II) and
again for 2000 to 2006 (Interreg III). It seeks in particular to pro-
mote cooperation between regions in different Member States
and is therefore at the heart of European integration.

2.
There is an explicit reference to Interreg in the basic instru-
ment establishing the Structural Funds (SFs) (2). It is carried out at
the initiative of the Commission, which adopts guidelines defin-
ing its aims, scope and method of implementation. The process
linking the basic legislation to the end projects to be implemented
by the beneficiaries of aid is shown in Table 1.

(1) For example, environmental decisions (pollution, water resources, etc.)
may be taken on one side of a border without allowing for the situa-
tion on the other side, infrastructure (roads, buildings, etc.) may be
built without considering what needs exist just across the border, and
transport networks may stop at border crossings or fail to be coordi-
nated.

(2) Paragraph 38 of the preamble and Articles 20 and 21 of Council
Regulation (EC) No 1260/1999 of 21 June 1999 laying down general
provisions on the Structural Funds (OJ L 161, 26.6.1999, p. 1).

For

3.
total
the period 2000 to 2006, out of
of 10 432,5 million euro assigned to the four CIs (3), 4 875 mil-
lion euro in commitment appropriations were allocated to Inter-
reg III for interventions under the European Regional Develop-
ment Fund (ERDF), one of the four SFs. Interreg is thus the largest
CI. An overview of the utilisation of the available appropriations
since the start of the period is given in Table 2.

a

4.
The Court previously examined the Interreg CI at the end
of its first implementation period (Interreg I) (4). The main con-
clusions highlighted:

(a)

the projects’ lack of a cross-border character and the absence
of cross-border cooperation, inter alia, in the management of
the Community Initiative programmes (CIPs);

(b)

the absence of indicators and the unsatisfactory nature of the
assessment of the CIPs’ impact;

(c) delays

in the adoption of

the programmes by the

Commission.

At the end of the second implementation period (Inter-
5.
reg II), the Commission reported that the projects’ cross-border
character, the ex ante evaluations and the systems of indicators
needed to be improved (5).

(3) Pursuant to Article 7 of Regulation (EC) No 1260/1999, 5,35 % of the
commitment appropriations from the Structural Funds for the period
2000 to 2006, or 195 000 million euro at 1999 prices, is allocated
to the CIs (Interreg, Urban, Leader and Equal). Article 20 adds that
2,5 % of this 195 000 million euro is assigned to Interreg.

(4) Annual Report concerning the financial year 1994, paragraphs 4.61

to 4.72 and 4.89 (OJ C 303, 14.11.1995).

(5) See ‘Community Initiative Interreg II 1994 to 1999: an initial evalua-
tion’, January 2000, and ‘Working paper 6 (5 May 2000) – Ex ante
evaluation and indicators for Interreg (Strand A)’. Working paper 6
was expanded to include Strand B and reissued as working paper 7.

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Main features of the Initiative for the period 2000 to 2006

Interreg III comprises three strands (1): Strand A covers
6.
cross-border
regions
cooperation between neighbouring
(53 CIPs); Strand B covers transnational cooperation across large
groupings of regions (13 CIPs); and Strand C covers interregional
cooperation across the Community as a whole (four CIPs). The
main features of each Strand are shown in Table 3. The Initiative
is therefore no longer limited to cross-border cooperation,
although this was the basis for its establishment in 1990. It has
become a trans-European cooperation initiative (see glossary) (2).

7.
Compared with the previous generations of the Initiative,
the guidelines for Interreg III are characterised by a considerable
strengthening of procedures with a view to improving coopera-
tion, especially as regards:

(a)

the joint nature of the strategy for the eligible area;

(b)

the establishment of joint bodies for CIP implementation.
Each programme must have a single managing authority, a
single paying authority, a joint technical secretariat (JTS), a
steering committee composed of representatives from each
country and a single monitoring committee (see glossary).
Each aid contract must be concluded with a single final ben-
eficiary having legal liability, which is subsequently respon-
sible for settling its contractual rights and obligations vis-à-
vis its partners in the project in question (3);

(c)

the shared nature of each CIP’s financial elements. There is to
be a single financial plan, contributions from the ERDF no
longer being broken down by Member State, and the bank
account into which ERDF payments are made must also be
shared (4).

(1) Communication from the Commission to the Member States of
28 April 2000 laying down guidelines for a Community initiative con-
cerning trans-European cooperation intended to encourage harmoni-
ous and balanced development of the European territory – Interreg III
(OJ C 143, 23.5.2000, p. 6) and Communication from the Commis-
sion to the Member States of 7 May 2001 – ‘Interregional coopera-
tion’ – Strand C of the Interreg III Community Initiative (OJ C 141,
15.5.2001, p. 2).

(2) Although regions from the accession States and third countries are
partners in a number of Interreg CIPs (see the titles of some CIPs on
map 1, the hatched regions of map 2 and some regions and countries
on map 3), they do not receive funding under the CI. The assistance
from which they benefit derives from Community instruments other
than the SFs.

(3) Previously, each of the Member States involved in a CIP designated a

separate implementing body and different final beneficiaries.

(4) Previously, each CIP had as many financial plans and bank accounts
receiving Community payments as there were Member States
involved.

This ‘pooling’ of the implementing bodies and financial
8.
elements should in principle encourage the emergence of a com-
mon strategy and approach for the area concerned. It could also
simplify the Commission’s management of CIPs, since hitherto
the Commission had to handle as many representatives and pay-
ment requests as there were Member States involved in each
programme.

The new guidelines also introduce the need for enhanced
9.
complementarity with other SF interventions. Moreover, in the
interests of simplification, Interreg has now been assigned exclu-
sively to the ERDF.

The Court’s audit

In view of the importance of the Initiative (see para-
10.
graph 3) , the difficulties that were detected (see paragraphs 4 and
5) and the substantial changes that were made for the period
2000 to 2006 (see paragraph 7), the Court resolved to audit the
programming of Interreg III. Its objective was to answer the fol-
lowing questions and examine what follow-up had been given to
the observations made by the Court in the course of its first audit
(see paragraph 4):

(a) Do the guidelines make it easier to achieve the CI objectives?

(b) Did the Commission use a suitable procedure for examining
CIP proposals, and were decisions taken within the agreed
deadlines?

(c) Did the various partners cooperate as required by the

guidelines?

(d) Was the initial analysis for the region concerned consistent
with the priorities and measures of the CIPs, as required by
the guidelines?

(e) Will it be possible to measure, ex post, the progress achieved?

11.
The audit covered the period from the preparation of the
Commission guidelines to the first decisions to adopt beneficia-
ries’ projects. No statements of expenditure had yet been submit-
ted in respect of these projects. The first two questions were
examined at the level of the Commission, and the remaining three
at Member State level. Eight CIPs were selected so as to form a
representative sample of the situations encountered, i.e. of each of
the strands set out in the Commission guidelines, and of a variety
of contexts (see Table 4). These CIPs account for 20 % of the bud-
getary envelope allocated to the Initiative. The audit was not con-
cerned with matters connected with cooperation at external bor-
ders, which constitute a separate case, especially as regards
coordination with other financial instruments (5).

(5) See the Annual Report concerning the financial year 2002, paragraphs
7.46 to 7.59 (Tacis cross-border cooperation programme) and 8.51 to
8.57 (Phare cross-border cooperation programme)
(OJ C 286,
28.11.2003).

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THE COMMISSION GUIDELINES

12.
The Commission sets guidelines for each CI. The purpose
is to establish conditions aimed at ensuring added value vis-à-vis
the traditional measures applied under Objectives 1 and 2 (see
glossary). In the Court’s view, the guidelines should lay down
desiderata concerning the projects to be implemented by benefi-
ciaries, as well as operational rules specific to the CIPs, and define
the eligible areas. There must also be a definition of specific, mea-
surable and operational objectives and targeted measures. If the
guidelines are to be sufficiently taken into account, it is crucial
that they be made available before the work of preparing CIPs
gets under way.

CIPs on the basis of the methods used for implementing pro-
grammes, emphasis being placed on the most integrated prac-
tices. The recommendations, which are taken up by the guidelines
(see paragraph 7), included the following:

(a)

(b)

that all sectors, including the private and non-commercial
sectors, participate as much as possible and from as early as
the CIP preparation stage;

that preparation and management be centralised, preferably
at a permanent cross-border organisation. The Commission
was therefore to encourage the establishment of permanent
cross-border bodies and prepare model
interregional
agreements;

Do the guidelines
trans-European projects?

contain an adequate definition of

(c)

that a single bank account be used to receive Community
funds. National funds could also be paid into this account;

13.
The Commission guidelines define trans-European
projects (1) in terms of their implementation and impact: opera-
tions must be ‘selected jointly and implemented, either in two or
more countries or third countries, or in a single Member State,
where it can be shown that the operation has a significant impact
on other Member States or third countries’ (2). The guidelines also
stipulate that all measures and projects must demonstrate the
added value of a trans-European approach.

14.
It is therefore important at the level of each CIP to put the
definition of trans-European projects into practice and ensure that
projects contribute to the resolution of problems caused by the
existence of a border (see paragraphs 66 to 69).

(d)

that each aid contract be concluded with a single partner,
into whose account payment would be made. This benefi-
ciary should have its own contractual arrangements with
partners on both sides of the border.

16.
The guidelines provide for the establishment of European
Economic Interest Groupings (EEIGs – see glossary) in order to
ensure that the bodies implementing cooperation are genuinely
shared. However, some Member States drew attention to a num-
ber of legal problems that the Commission had insufficient time
to address in detail (see paragraph 44). In January 2003, the Com-
mission launched a study of legal instruments that might be used
in the field of trans-European cooperation.

Do the guidelines include specific implementing rules?

Do the guidelines include specific measurable objectives and
targeted measures?

15.
Various recommendations concerning implementation
were formulated at the time of the ex post evaluation of Interreg I,
which was carried out at the Commission’s request. Subsequently,
the ‘Linkage Assistance and Cooperation for the European Bor-
der Regions’ (LACE) project (3) drew up a typology of Interreg II

(1) A generic term used for the three strands of the Initiative: cross-border
cooperation (Strand A), transnational cooperation (Strand B) and
interregional cooperation (Strand C).

(2) Paragraph 7 of the Communication to the Member States of 28 April

2000.

(3) Ex post evaluation of the Interreg I cross-border CIPs for 1989 to
1993, which was carried out by FERE Consultants in August 1996.
The ‘‘Linkage Assistance and Cooperation for the European Border
Regions’ (LACE) project was run by the Association of European Bor-
der Regions (AEBR). This body, which was set up in 1971 with the
aim of representing European cross-border regions, has almost
80 members in 160 zones adjacent to the European Union’s internal
and external borders. Documents that it has produced address the fol-
lowing subjects: cross-border cooperation on maritime borders (June
1998), institutional aspects of cross-border cooperation (March 1999)
and programme management models for Interreg IIIA (November
1999). Other documents, published after the guidelines were pre-
pared, concern cross-border financial management (January 2000)
and operational guidance on the preparation and management of
Interreg IIIA programmes (June 2000).

Regarding objectives and indicators, the ex post evalua-

17.
tion of Interreg I drew attention to:

(a)

the need to clarify the purpose of cooperation, since Interreg
programmes pursue the same objectives as traditional pro-
grammes. However, the latter can call on far more generous
financial resources, and the eligible regions are not all affected
by development difficulties;

(b)

the absence of clear, quantified initial objectives;

(c)

the need to establish relevant indicators.

18.
In anticipation of a Parliament opinion on the Interreg III
guidelines, the Commission prepared a brief information paper
consisting of an initial review of Interreg II (4). However, this
document is very general and focuses on matters of implementa-
tion. Usually, despite the studies referred to in paragraph 15 and
the results of the Interreg II interim evaluation, no analysis of the
specific situation of eligible areas or information concerning the
progress made towards attaining the CI objectives or the specific
II
CIP objectives under

Interreg

Interreg

either

I or

(4) ‘Community Initiative Interreg II 1994-1999: an initial evaluation’,

January 2000, European Union — regional policy.

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was available to the Commission. This situation hampered the
setting of specific concrete objectives.

(c)

Objectives and indicators

fail to address Strand C, for which it was decided to define
indicators in the course of implementation, since the Com-
mission conceived of this Strand as a framework for coop-
eration without precise knowledge of the specific needs and
corresponding objectives (see paragraph 24). Although inter-
regional cooperation projects had been in receipt of ERDF
support since 1995, the Commission had no access to the
relevant evaluations when preparing the Strand C guidelines.

In the Interreg III guidelines, each Strand has many far-
19.
reaching specific objectives (see Table 3). The guidelines also state,
in the light of the general guidelines of the SFs and Community
policy, that preference will be given to employment, competitive-
ness, sustainable development and the promotion of equal oppor-
tunities for women and men.

Targeting of measures

The Commission has entrusted the authorities respon-
20.
sible for CIPs in the Member States with the task of setting
concrete objectives on the basis of an analysis of the problems
facing border areas. It has established operational rules (see para-
graphs 7,15 and 16) but no specific measurable objectives. It is
therefore especially important that, when examining the Member
States’ programme proposals, it should ensure that substantiated,
targeted choices have been made.

21.
The documents produced in order to guide the authori-
ties preparing CIPs through the ex ante evaluation and the selec-
tion of indicators specific to Interreg (1) should have focused
above all on key ideas translating the Commission’s priorities,
with a view in particular to the ex post evaluation. With this in
mind, and on the basis of the experience acquired during the two
previous generations of the CI, it would have been helpful, say, to
devise a minimum common system of indicators that could be
applied to all programmes under the same strand. Instead, the
documents:

(a)

emphasise above all the difficulties of making an ex ante
evaluation, defining priorities for action and measuring pro-
gramme impact. They are not really suited to the task of set-
ting up a system with which to assess the impact of CIPs;

(b) maintain a certain degree of confusion as regards indicators:
while advocating that the indicators be limited in number,
impact,
they refer successively to indicators of context,
cooperation/integration, output and result, as well as to key
indicators, and recommend the use of qualitative indicators.
Examples are given of output, result and impact indicators.
Moreover, the definition of these separate categories is some-
what unclear, in particular as regards output and result indi-
cators: the number of project participants, for example, is
seen at times as a result indicator;

22.
Where the Initiative’s Strand A is concerned, the Com-
mission guidelines contain a list of purely discretionary measures.
The Member States have the option of setting up programmes
that are very broad in scope. While, along the lines of the inter-
vention programmes run under Objectives 1 and 2, these may
include economic, social, cultural and environmental measures,
their implementation is subject to special conditions that aim at
strengthening cross-border cooperation. At the same time, they
enjoy far less funding than these traditional programmes, espe-
cially if account is also taken of the geographical extent of CIP-
eligible areas, which may include zones that are ineligible for
ERDF assistance under Objective 1 or 2 because they are not
experiencing particular development or conversion difficulties.
Given these considerations, there is all the more reason (see para-
graph 20) for the Commission to ensure, when examining the
Member States’ programme proposals, that measures are targeted
(see paragraphs 59 to 63).

As regards Strand B, the guidelines call for attention to be
23.
given to the Community’s policy priorities, and above all to the
trans-European networks and the territorial development recom-
mendations contained in the European Spatial Development Per-
spective (ESDP — see glossary). This Strand thus gains a certain
degree of specificity, although, since it applies to a vast spatial
area and enjoys limited financial resources, choices have to be
made concerning the possibilities for intervention.

24.
Where Strand C is concerned, the Commission’s initial
guidelines outline a single general objective, namely, to improve
the effectiveness of policies and instruments for regional devel-
opment and cohesion (see Table 3). A second communication
published on 15 May 2001 delimitated the content of coopera-
tion by identifying five themes for interregional cooperation (2),
among them a heading of ‘Other subjects’. Since the implemen-
tation of Strand C CIPs began, this last theme has attracted the
majority of aid applications and agreements, which underlines the
fact that, as a whole, this Strand is too broad.

(1) ‘Working paper 6 (5 May 2000) — Ex ante evaluation and indicators
(Strand A)’ — and working paper 7 (October 2000), which expands
the content of working paper 6 to include Strand B. The ex ante evalu-
ation should seek in particular to assess the consistency of the strat-
egy and the designated objectives, account being taken of the strengths
and weaknesses identified.

(2) ‘Activities supported under Objective 1 and 2 of the Structural Funds’,
‘Interregional cooperation linking public authorities or equivalent
bodies involved in other Interreg programmes’, ‘Interregional coop-
eration in the field of urban development’, ‘Interregional cooperation
linking regions involved under one or several of the three themes of
the regional innovative actions for 2000 to 2006’ and ‘Other subjects
appropriate to interregional cooperation’.

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In conclusion, the objectives that appear in the Commis-
25.
sion guidelines can be described as general. Moreover, the work-
ing documents that are made available do not offer sufficient sup-
port to project managers setting up suitable operational indicators
for assessing how well the objectives have been attained. Eligible
measures are therefore heterogeneous and result in a wide dispar-
ity of projects. It is in precisely these terms that the Commission’s
working paper 6 explains the mediocre quality of earlier pro-
gramme evaluations. Yet one of the key principles for the effec-
tiveness of SF intervention is the concentration of assistance.
When implementing CIPs, unless they were selected with a view
to setting concrete objectives and restricting the scope of opera-
tions, it will be necessary to spread resources very thinly and
extremely difficult to measure the progress achieved.

Are the eligible areas clearly defined?

26.
When the new guidelines were being prepared, the mat-
ter of defining eligible areas was raised in respect of Strand A. The
effectiveness of cross-border cooperation starts to decline some
50 to 70 km from the border. In the absence of a more subtle
zoning instrument, the areas were once again defined on the basis
of the NUTS III nomenclature (see glossary). As a result, some
areas extend up to 200 km from the border, and further in cer-
tain Member States. Almost all of the Strand A CIPs examined
cover eligible areas stretching more than 70 km from the border
(Ems-Dollart Region, Alps, Ireland-Wales and Spain-Portugal).

27.
This issue does not arise for Strands B and C, which,
unlike Strand A, do not cover cooperation between neighbour-
ing regions.

Were the guidelines and methodology documents made
available to the Member States at the appropriate time?

The Commission first gave thought to the strategy for
28.
Interreg III at the end of 1997. A document setting out the basic
options was drawn up in March 1998 (1). The Commission guide-
lines were not finalised until January/May 2000, or, in the case of
Strand C, the early months of 2001. However, given the particu-
lar difficulties associated with the preparation of Interreg pro-
grammes, the Member States had already set to work. An analo-
gous situation emerged with regard to the various methodological
working papers that the Commission prepared specifically for
Interreg (see paragraph 21).

COMMISSION’S

THE
CIP PROPOSALS

PROCEDURE

FOR

EXAMINING

30.
The Commission checks that all CIPs conform to the
guidelines. The Court feels that the examination procedure needs
to be sufficiently detailed and that the shortcomings that are
revealed should lead to improvements in the CIPs. Lastly, it is cru-
cial that the CIPs be adopted on time in order to avoid interrupt-
ing the cooperation established by Interreg II and allow utilisa-
tion of the available appropriations.

Did examination help to enhance CIP quality?

31.
Procedures for the examination of programme propos-
als have been devised and put in place and consist of two stages.
The first stage looks at admissibility and establishes that there has
been formal compliance with Community legislation. The second
stage focuses on programme quality and serves as a basis for the
improvements that will be agreed to programme content in the
course of negotiations with the Member States.

32.
The Commission services applied a list of criteria for
examining CIP proposals during the first stage only. The list in
question is fairly general, and the sole purpose of checking was
to obtain assurance that certain formal elements were present in
the programme proposals. The Court was unable during its audit
to source clearly every one of the observations made during the
second examination stage and forwarded by the Commission to
the Member States. Records did not always include a monitoring
document indicating to what extent a response had been made to
the requests or observations contained in the letter to the Mem-
Ireland-Wales, Alpenrhein-
ber States (save in the cases of
Bodensee-Hochrhein and Ems-Dollart Region and, in part, West-
ern Mediterranean).

The procedure for examining CIP proposals did not

33.
always result in the desired improvements in CIP quality:

(a)

the concerns that had caused a first programme proposal to
be judged inadmissible were not always sufficiently taken
into account. In the case of the Spain-Portugal CIP it had
been ruled that the JTS was not functioning as required by
the guidelines. This matter re-emerged during the Commis-
sion’s negotiations with the Member States. Although no
substantive changes were made, the Commission subse-
quently adopted the programme proposal;

29.
Owing to the complexity of the Interreg CI, the late avail-
ability of the guidelines and working papers contributed to the
fact that the CIPs’ effective launch was delayed. It may also have
resulted in the poor quality of some CIP proposals.

(1) ‘Trans-European cooperation initiative for balanced development’,

6.3.1998, DG XVI/A/1.

(b) notwithstanding the many changes that were made to the
CIP proposals, serious failings were not redressed. However,
shortcomings concerning strategy and indicators,
for
example, had been identified as early as the first stage of
examination (Alps, Spain-Portugal and Western Mediterra-
nean). In some cases (Spain-Portugal and Western Mediter-
ranean), the Commission services with particular responsi-
bility for regional policy evaluation had even recommended
declaring the CIP proposals inadmissible.

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Given the number of programmes to be examined and
34.
the complexity of the examination procedure, improvements to
CIP content could have been achieved through a more structured
approach based on detailed criteria and aimed at obtaining a
transparent, homogeneous evaluation (see paragraphs 51 to 78).
These criteria should then have been communicated to the Mem-
ber States, in one of the working documents drawn up by the
Commission, before they embarked on the task of preparing the
CIPs (see paragraph 21).

Did the Commission approve the CIPs within the agreed
deadlines?

The statutory deadlines for the Commission to adopt

35.
programme proposals were as follows:

(a)

the Member States were to submit proposals no later than six
months after the date of publication of the Commission’s
Communication in the Official Journal of the European Com-
munities, i.e., by 22 November 2000 in the case of Strands A
and B and 14 November 2001 in the case of Strand C;

(b)

the Commission was to decide whether to adopt no later
than five months after the date of receipt of an admissible
proposal, i.e., by 21 April 2001 in the case of Strands A and
B and 13 April 2002 in the case of Strand C.

36.
The statutory deadlines were exceeded by a very consid-
erable margin. Only 27 of the 66 CIP proposals for Strands A and
B were submitted within the agreed deadline. Not one proposal
was adopted within the five-month deadline. The period for
adoption varied from seven-and-a-half to fourteen-and-a-half
months and lasted an average of roughly one year.

37.
Analysis of the decision-making process for the eight-
programme sample reveals that on average the adoption period
breaks down as follows:

(a) almost one month to declare the programme admissible;

(b)

just under a further three months to submit written obser-
vations on the proposal to the Member States;

(c)

eight months to negotiate with the Member States and
receive, examine and adopt the amended proposal. The
decision-making process per se, once the programme has
been finalised by agreement with the authorities of the Mem-
ber States, takes an average of around one month.

38.
Finally, once each programme had been approved by the
Commission, the monitoring committee for each CIP had three
months to prepare and adopt a programme complement. The
purpose of this document is to clarify certain aspects of the imple-
mentation and monitoring process. The complements for several
of the programmes examined were not adopted by the monitor-
ing committee within the agreed deadline (Ireland-Wales and
Spain-Portugal). In some cases, the poor quality of the comple-
ments meant that the Commission was unable to approve the

wording of these documents before a year or more had passed
(Alpenrhein-Bodensee-Hochrhein, Ems-Dollart Region and West-
ern Mediterranean). The programme complements contain a
good deal of repetition and placed significant constraints on the
preparation process (1).

39.
Delays in programme adoption do not affect the start of
the eligibility period of the final beneficiaries’ expenditure in the
Member States. This period is ruled to start on the date on which
the Commission receives an admissible CIP proposal. None the
less, these delays interrupt the cooperation process. The reason is
that beneficiaries prefer to wait for their applications to be
approved before starting to implement their projects, and this is
only possible after the Commission has adopted the programme
and other elements, such as the project selection criteria, have
been agreed and put in place. These delays, combined with the
belated publication of the guidelines, were in part responsible for
the fact that the commitment appropriations for 2000 were re-
allocated and the payment appropriations made available in
2001, 2002 and 2003 were under-utilised (see Table 2).

COOPERATION
IMPLEMENTATION

DURING

PREPARATION

AND

40.
The guidelines state that the preparation and implemen-
tation of CIPs must be carried out on a cooperative basis, the aim
being in particular to promote the emergence of a common strat-
egy for the eligible area and thereby enhance the quality of ben-
eficiaries’ projects.

Did the preparation of CIPs include a process of consultation?

41.
The guidelines encourage the private sector, universities
and non-governmental organisations to participate as early as the
preparation stage. These sectors were indeed involved from the
earliest reflections on the Strand A CIPs, albeit belatedly in one
case (Spain-Portugal). Consultation on the Strand B CIPs involv-
ing a large number of Member States was entered into only par-
tially or not at all because of the already very complex nature of
the preparation process. Where there was consultation, the results
were not encouraging. In the case of Strand C, the CIPs were
jointly prepared by the Commission and the competent
secretariats.

42.
Meanwhile, since the ‘bottom-up’ design process is not
followed by choices aimed at identifying priorities for action, it
delivers very broad intervention programmes that are character-
ised by heterogeneous measures and result in the dilution of the
available resources (see paragraphs 59 to 63).

(1) See Special Report No 7/2003 on the implementation of assistance
programming for the period 2000 to 2006 within the framework of
the Structural Funds, paragraphs 18 to 24 (OJ C 174, 23.7.2003).

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Do the Member States cooperate on the implementation of
CIPs?

43.
The main changes affecting the third generation of Inter-
reg programmes (see paragraph 7) include the establishment of
shared managing authorities, paying authorities, monitoring
committees, financial plans and bank accounts into which ERDF
aid is to be paid, as well as the constitution of JTSs and steering
committees.

44.
A single managing authority and a single paying author-
ity were designated for each programme. A steering committee
was set up comprising representatives from each country con-
cerned. Attempts to establish EEIGs as agents for the implemen-
tation of Interreg programmes were unsuccessful (Alps and north-
west
(see
Europe), despite Commission encouragement
paragraph 16). However, legal entities of this description could
provide representation for the Member States involved in a CIP, a
situation which is not possible when regional governments act as
the single authorities, as in the case of the programmes that were
examined.

45.
The different models used for the constitution of JTSs
were sometimes far removed from the spirit of the guidelines,
which is also to promote cooperation between the bodies imple-
menting CIPs. However, the Commission accepted the different
models because it was concerned above all that the programmes
be adopted without further exacerbating the delays:

(a)

the most successful model is that of a JTS set up in a single
location and consisting of representatives of each of the
Member States concerned, usually with offices in some or all
of the Member States. In the best case examined (Ems-Dollart
Region), the JTS is part of an organisation for trans-European
cooperation that was set up by the Member States. In another
case (north-west Europe), it is part of an undertaking uncon-
nected with the implementation of the CIP but nonetheless
retains a trans-European character. In one final case (Alps),
while legally a part of the managing authority, it is located
separately and has representatives from the different regions
of the Member States;

(b) a model that reflects the spirit of the guidelines less well is
that of a JTS that is physically part of the managing author-
ity but has no representatives from the other Member States,
although these are approached for consultation (Ireland-
Wales and Alpenrhein-Bodensee-Hochrhein);

(c) a final model (Spain-Portugal) is even further removed from
the spirit of the guidelines. This model consists of no more
than offices under the aegis of the regional authorities on
both sides of the border. They are often situated outside the
eligible area, which itself extends a good distance from the
border. This arrangement deprives the cross-border region of
a base from which to raise awareness of the CIP.

Each of the CIPs examined also has a single financial
47.
plan, i.e. a plan that does not indicate the share of each Member
State. On occasion, however, a breakdown of the plan by Mem-
ber State is attached to the programme complement, the content
of which has been verified by the Commission (Alps), or the CIP
indicates each Member State’s share in ERDF aid (Spain-Portugal
and Western Mediterranean). In one instance, moreover (Spain-
Portugal), promotional material on the CIP refers exclusively to
the share of one of the two Member States.

48.
None the less, an attentive eye is generally kept on the
utilisation of the appropriations that each Member State brings to
the CIP financial plan. Indeed, the single financial plan for each
CIP is drawn up on the basis of, on the one hand, the distribution
of ERDF resources by Member State and type of intervention (1)
and, on the other hand, the way each Member State distributes
these resources among the Interreg programmes, according to its
own priorities.

Finally, the guidelines recommend that aid contracts be
49.
concluded with a single beneficiary having the status of project
leader, which must then agree its rights and obligations vis-à-vis
its trans-European partners in the project in question. This prin-
ciple was observed in each of the programmes examined, the one
exception being where each aid proposal was signed by all the
project partners (Ireland-Wales).

50.
There remain some obstacles to cooperation between all
the partners involved in the CIPs that were examined. These
obstacles relate to legal questions and the allocation to the CI of
ERDF funding. None the less, the Interreg III guidelines made it
possible to strengthen cooperation between all partners, although
the level of commitment to cooperation varies from one CIP to
another.

CONSISTENCY BETWEEN THE INITIAL ANALYSIS AND CHOICE
OF MEASURES AND THE ADDED VALUE OF THE FIRST
PROJECTS TO BE ADOPTED

51.
The guidelines provide that the process of planning the
CIPs should be analogous to that set out in the basic instrument
establishing the Structural Funds. This process seeks to base the
choice of measures for which beneficiaries’ projects are eligible on
an analysis of the regional situation. Both analysis and planning
must take account of the opinion of an assessor appointed by the
Member States. The success of the CI is largely dependent on the
consistency of this process, namely, on the appropriateness of the
measures to the problems diagnosed. It is not enough to qualify
as trans-European: projects must also contribute to the resolution
of border-related problems.

Each of the programmes examined operates a single bank

46.
account for the receipt of Community funds.

(1) This distribution was agreed at the meeting of Heads of State and Gov-

ernment in Berlin on 24 and 25 March 1999.

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Official Journal of the European Union

C 303/13

Is the ex ante evaluation used in the drafting of programmes?

52.
The ex ante assessors often made a significant contribu-
tion to the preparation and drafting of CIPs. The documents pro-
duced under the heading ‘ex ante evaluation’ are composed, as a
rule, of texts which have already been incorporated in their
entirety into the CIPs, and of notes explaining the content of
those texts. Consequently, the ex ante assessors usually did not
comment critically on the programme proposals that were sub-
mitted to the Commission, and to which they had contributed.
However, in one case (Europe), a number of fundamental criti-
cisms were formulated, observing, for example, that the CIP’s
objective was too broad and that it would be beneficial to define
a single, clear and unambiguous objective. Yet it was where the
assessor was not involved in preparation of the CIP (Ireland-
Wales) that he raised the most important questions: the useful-
ness of multiple analyses, the weakness of the link between the
analysis and the definition of priorities and measures, and the
poor identification of border-related problems and potential. The
lack of objective criticism during the drafting stage of CIP pro-
posals, the general nature of the CI objectives, the lack of specific
information on each eligible area (see paragraphs 17 to 25) and
the failure to establish detailed qualitative criteria in advance (see
paragraph 34) all combined to form an obstacle to the prepara-
tion of quality CIPs.

Were the results of the previous programming period taken into
account?

When the Interreg III programmes were being prepared,
53.
only the mid-term evaluations for the previous period were avail-
able. The content of these evaluations, in terms of recommenda-
tions for the new period, varies greatly. The most significant
aspects noted by the assessors, which, it seems, were not given
sufficient consideration, are the following:

(a)

the lack of clarity of the strategy and priorities laid down for
the programmes (see paragraphs 58 to 63);

by the higher number of Member States participating in each pro-
gramme. There are numerous difficulties in obtaining harmon-
ised and up-to-date statistics: the absence of statistics in one or
other of the Member States, statistics submitted on different dates
or according to different criteria, and poor data reliability owing
to the small geographical divisions encountered at Strand A level.

These analyses are of little value as they fail to perform

56.
two necessary functions:

(a)

(b)

they were not followed by targeted choices generating strat-
egies for the regions concerned, on the basis of which pri-
orities and measures for the CIPs should have been defined
(see paragraphs 58 to 63);

the statistics on which they are based are of no use in defin-
ing regional points of departure against which the indicators
are to measure the impact of the CIPs (see paragraphs 73 to
77). This detracts from the relevance of impact assessment.

57.
As regards Strand C, the failure of the Commission guide-
lines to provide a clear identification of needs (see paragraph 24)
is echoed in the CIPs under this strand, which refer to no analysis
in any form. It is therefore difficult to specify the objectives of
these programmes and determine a method for measuring the
progress to be achieved.

Can the problems addressed be attributed to the existence of a
border?

58.
The descriptions present development-related problems,
in the same way as traditional ERDF intervention programmes,
but do not usually focus on the problems created by the existence
of borders, such as missing links (1). However:

(b)

the need to define indicators which would enable a pro-
gramme’s impact to be measured; in spite of efforts in this
respect (see paragraph 21), the resulting proposals remain
inadequate (see paragraphs 73 to 77).

Strand C did not exist under Interreg II. Interregional
54.
cooperation projects were, however, managed directly by the
Commission in the form of innovative actions in the context of
the SFs. No evaluation of
the latter was available to the
Commission.

(a)

(b)

Was there integrated analysis of the regional situations?

in some areas, borders appear to impede efforts to attain
development objectives. This is true in particular of environ-
mental problems on one side of a border that also impact on
the opposite side (water quality, fire prevention, reafforesta-
tion, joint action in protected zones, natural hazards, etc.);

some programmes include an assessment of cross-border
cooperation and of the advantages which this can bring in
specific sectors, such as the labour market, transport and
communications, science and health (Alpenrhein-Bodensee-
Hochrhein and Ems-Dollart Region). Another programme
(Spain-Portugal) highlights the advantage of cooperation in
certain fields, in the cross-border area, such as railway con-
nections, spatial management, rivers and water resources;

55.
With one exception (Ireland-Wales), all of the pro-
grammes examined included a statistically-based integrated
regional description. The Strand B programmes examined offer
the most complete analysis, a situation that can undoubtedly be
explained

(1) This expression is used on page 7 of the Commission’s ‘Working
paper 6 (5 May 2000) — ex ante evaluation and indicators for Interreg
(Strand A)’. The missing link refers to the barrier effect of a border. As
examples, the Commission quotes the lack of border crossings, river
pollution and lack of mutual recognition of qualifications.

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Official Journal of the European Union

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(c) one Strand B programme in particular (Europe) demonstrates
the transnational significance of a series of new themes
linked to spatial development (ESDP). These include the
development and complementarity of alternative modes of
transport, coordination in the management of regional riv-
ers, reafforestation, measures to increase complementarity
between urban areas, the development of transport from the
region’s peripheral areas and the coordination of measures to
prevent pollution of the English Channel.

Are programme priorities synonymous with identified needs?

59.
Most of the Strand A programmes were drawn up using
the ‘bottom-up’ approach advocated in the Commission guide-
lines: potential partners in a CI were invited to propose areas in
which projects could be implemented. These proposals were used
to determine CIP measures and, subsequently, priorities, without
any choices being made. There was rather a tendency to establish
very broad programmes so that as many partners as possible
could then be involved in implementation. Sometimes the Mem-
ber States concerned agreed on measures before analysing the
regional situation (Ems-Dollart Region and Spain-Portugal).

60.
This often results in very broad programmes composed
of artificial groupings of measures and in the formulation of
abstract priorities and objectives. It is impossible to measure
whether such objectives have been achieved. Similar criticisms
were voiced of the evaluations of previous periods and, here, by
certain ex ante assessors (see paragraphs 52 and 53). For example
all the Strand A programmes examined included measures in the
economic, social, rural development, human resources, environ-
ment, cultural heritage and tourism sectors. This explains why
these CIPs are no different from traditional intervention pro-
grammes, save as regards the specific implementing rules attached
to the Initiative (see paragraphs 43 to 49). In one case where the
Commission found the measures to be too broad in scope
(Alpenrhein-Bodensee-Hochrhein), one priority was cancelled,
only for the measures under this priority to be transferred to the
remaining priorities.

61.
Under Strand B, measures are more specific because, in
the two cases examined, a connection exists with the ESDP. Nev-
ertheless, for the sake of agreement between the different Mem-
ber States, the various ESDP priorities (1) were retained and
supplemented with others. Given that the geographical area of the
programme is greater than that of the largest EU Member States,
none of the measures has much significance.

(1) The ESDP priorities concern ‘polycentric spatial development and a
new urban-rural relationship’, ‘parity of access to infrastructure and
knowledge’ and ‘wise management of the natural and cultural heri-
tage’.

The Strand C programmes, which contain no needs
62.
analysis and no breakdown of the general objective assigned to
the Strand by the guidelines, are not broken down by priority and
measure.

63.
In all the Strand A and B programmes examined, there-
fore, there is a discrepancy between the analysis of the region eli-
gible for Interreg and the definition of a strategy and priorities for
the programme. The key programme measures were drawn up on
the basis of other concerns which the programmes do not make
explicit, and there is a very broad content base. By combining the
‘top-down’ and ‘bottom-up’ approaches, it should be possible to
take account both of the needs emerging from the preliminary
analyses and of those expressed by local partners. Although the
sharing of the implementing bodies and financial elements is con-
ducive to cooperation (see paragraph 50), it has not resulted in a
targeted strategy that might resolve border-related problems.

Is there complementarity between the Interreg III CIPs and
traditional ERDF interventions?

64.
The Strand A CIPs examined sometimes include argu-
ments that seek to demonstrate complementarity with traditional
intervention programmes. In fact, this complementarity is simply
the consequence of the very broad scope of the CIPs, which com-
prise many measures resembling those implemented through tra-
ditional intervention programmes, the only difference in general
being in the implementing rules (2) (see paragraphs 22 to 25, 59
and 60).

The audit did not perform the same comparison in
65.
respect of Strands B and C, since the regions concerned are gen-
erally eligible under scores of different Objective 1 and 2 pro-
grammes. Any emphasis on complementarity is a formal response
to legislative requirements (Europe).

Do the first projects adopted qualify as trans-European and do
they offer added value?

66.
In every one of the programmes examined, the definition
of a trans-European project given in the Commission guidelines
(see paragraphs 13 and 14) is put into practice by means of eli-
gibility and selection criteria to which a rating scale is applied
(save in the case of the Ems-Dollart Region CIP). Such criteria
might be, for example, that there is an impact on both sides of the
border, the intensity of cooperation within the partnership or the
setting up of cross-border networks. Other criteria are added for

(2) For a given eligible region, it is difficult to compare the financial
resources made available under Interreg III with those made available
under Objective 1 and Objective 2 Intervention programmes, given
that the eligible regions are not exactly the same, since regions eligible
under Interreg do not necessarily have to be regions eligible under
Objectives 1 and 2. It may, however, be estimated that, for Strand A
Interreg programmes,
resources varies
between 1:20 and 1:50.

the ratio of

financial

7.12.2004

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Official Journal of the European Union

C 303/15

always

the assessment of overall project quality and might include a mea-
sure’s contribution towards the objectives, whether or not it is
innovative, the sustainability of its results and the partners’ capac-
ity to see it through to its conclusion. A total score for each
project would enable it to be compared with other projects but is
calculated (Alps, Spain-Portugal, Alpenrhein-
not
Bodensee-Hochrhein and Northern Zone). Furthermore, none of
the programmes examined defines a minimum quality threshold
for projects to be submitted for consideration or approved, how-
ever useful such a threshold would be, given that concerns about
the utilisation of appropriations may lead to the adoption of
projects of inferior quality.

67.
Most of the projects examined (1) can be termed trans-
European, having been prepared by a number of Member States
which were to implement them jointly. Cooperation is a salient
feature. However, some projects essentially consist of bringing
parallel subprojects on both sides of the border under a single
roof and have relatively little trans-European interest (Strand A:
work on both sides of a border to develop river tourism infra-
structure and museums and renovate two historic buildings, even
if there are plans to follow up by imparting a cross-border iden-
tity to these projects; the resurfacing of two roads on one side of
the border while a new road is built on the other; construction of
part of a technology park on one side and a business park on the
other. Strand B: a network formed by eight partners from four
Member States with the aim of setting up an Internet portal for
each region around the same basic design).

68.
Projects do not always make a significant contribution to
the resolution of border-related problems because some of them
are limited almost exclusively to the exchange of experience and
are not sufficiently focused on practical action (Strand A: the
transfer of medical expertise, the exchange of experience between
growers and the establishment of a network of organisations
offering business support by means of joint seminars. Strand B:
the exchange of experience on the prevention of coastal erosion).

It appears from the first projects to have been adopted
69.
that the definition of trans-European projects has been respected
and that many projects entail the cooperation of all the partners.
Nonetheless, some offer limited added value because they do not
focus on practical action or could have been implemented in
other regions. Although the systems of selection criteria could be
improved, this weakness is largely due to the imprecise nature of
the stated objectives and the broad scope of the measures within
each CIP (see paragraphs 59 to 63).

THE FEASIBILITY OF MEASURING PROGRESS EX POST

70.
The basic instrument establishing the Structural Funds
provides that interventions shall be evaluated, especially ex post,
in order to assess their impact. The results of evaluation should
be used to improve the quality of interventions in subsequent
periods.

Are the programme objectives well structured?

71.
As is shown by the process of defining priorities and
measures for the CIPs of Strands A and B previously examined
(see paragraphs 55 to 63), it was not possible to set objectives on
the basis of the regional situational analysis or any strategic
choices made. Most programmes have one or two very general
objectives and a few sub-objectives, although a greater number of
sub-objectives were set in some cases (15 for Spain-Portugal,
21 for Europe and 10 for the Western Mediterranean — see
Table 5). The absence of one main, clear and concrete objective
broken down into its most important sub-objectives betokens dif-
ficulties in evaluating impact.

72.
The Strand C CIPs were designed in response to a single
Commission objective, namely, to improve the effectiveness of
policies and instruments for regional development and cohesion.
No sub-objectives were set.

Are the objectives measurable and quantified?

73.
The Commission insisted that all programmes should
include indicators. The only exception concerns Strand C pro-
grammes: here it was decided not to establish indicators until
such time as a sufficient number of projects had been adopted, so
as to give a clearer understanding of the content of the actions
carried out. Indicators were therefore identified. However, every
one of the programmes examined suffers from an unclear or very
incomplete assessment of impact, that is, the indicators measure
just one aspect of the stated objectives or, where they address a
priority, deal with only a few of the measures under that priority
(see Table 5). What is more, in some programmes each project
partner also has the option of determining its own indicators
(Ems-Dollart Region, Alps and Alpenrhein-Bodensee-Hochrhein).

74.
Some of the Strand A programmes have indicators which
are independent of the stated objectives and known as ‘cross-
border context’ (2) and ‘cooperation intensity’ (3) indicators (Alps,
Alpenrhein-Bodensee-Hochrhein and Ems-Dollart Region; the
Spain-Portugal CIP provides for such indicators but has not devel-
oped them). Although these vary from one programme to the
next, they are very general in nature and of limited relevance to

(1) The audit focused on a sample of projects selected among the first to
have been adopted by the authorities responsible for each CIP chosen
for inspection. No statements of expenditure had yet been made for
these projects.

(2) For example, the number of cross-border workers, the number of
firms engaged in cross-border activity and the percentage of the popu-
lation that can speak the language of the neighbouring country.
(3) For example, the number of shared information systems and cross-

border networks.

C 303/16

EN

Official Journal of the European Union

7.12.2004

the programme concerned. They could, however, have had some
relevance for Strand A as a whole if they had been developed and
applied as standard to all the CIPs in this strand.

The guidelines focus on operational procedures but were
made available too late and contain over-generalised
objectives

75.
Another weakness is the absence of a definition of the
information sources or the procedure that will be used when cal-
culating the indicators. It is often impossible to establish the rela-
tionship between indicators from the lowest to the highest levels,
i.e., from project level to that of global CIP objectives.

Lastly, despite these shortcomings, there were attempts
76.
to quantify the objectives for a number of programmes, either
globally or by reference to priorities or measures. However, the
working documents that were necessary to establish how quan-
tification was carried out were unavailable. Yet if these quantified
objectives are to have any relevance, it must be possible to com-
pare them ex post with what has been achieved so that conclu-
sions can be drawn. If the context in which targets were set can-
not be recreated, there will be little basis on which to draw
conclusions from this comparison.

77.
There is a tendency to put off the business of measuring
the degree to which objectives have been achieved. The general
nature of the objectives defined for each CIP and the diversity of
measures hamper the identification of relevant and workable indi-
cators. However, it is important that the situation be clarified and
a selection made with the aim of retaining only those indicators
that are essential for monitoring the progress of the CIP, making
decisions or measuring programme impact.

With a view to enhancing cooperation, the Commission
80.
guidelines contain a definition of the trans-European projects that
are to be implemented in every CIP (see paragraphs 13 and 14)
and establish stricter requirements concerning implementation.
However, not enough thought was given to the matter of imple-
menting cooperation via bodies that are genuinely shared, such as
EEIGs. Bodies of this sort are able to represent the various regions
concerned and take on the task of implementation (see para-
graphs 15 and 16).

81.
No analysis was available to the Commission of the spe-
cific situation of eligible areas or the progress that had been made
towards achieving the CI objectives or the more specific objec-
tives of CIPs. The new guidelines do not contain objectives that
are targeted and measurable. Instead, they outline a possible field
of action in which the regions of the Member States are encour-
aged to work together on issues which it is up to them to define
jointly. If no choices setting concrete objectives at CIP level are
made, implementation of the CI will
lead to the dilution of
resources. The Commission has not established common indica-
tors which would allow the progress achieved through imple-
mentation of the Initiative to be measured globally at Commu-
nity level (see paragraphs 17 to 25).

As regards Strand A, no solution has been found, using
82.
to
the present characteristics of
the problem of the existence, in a number of Member States, of
areas which are too large to allow effective cooperation (see para-
graph 26).

the NUTS nomenclature,

78.
Just two of the eight programmes examined (Alpenrhein-
Bodensee-Hochrhein and Ems-Dollart Region) employed a com-
puterised project management system and a database for compil-
ing information to be used when setting indicators. Systems had
been developed separately in different regions of the Member
States, but this can only mean higher costs and delays in the
implementation of programme monitoring.

83.
The Commission guidelines and the working papers pro-
duced to help the Member States with programme planning were
published late, after the Member States had started work on pre-
paring their CIP proposals. This delayed the implementation of
the CIPs and may have resulted in programmes of a mediocre
quality (see paragraphs 28 and 29).

CONCLUSION AND RECOMMENDATIONS

Conclusion

The procedure for examining CIP proposals must be
improved

The criteria for examining the quality of programme pro-
84.
posals submitted by the Member States were lacking in detail and
inadequately prepared. The procedure for examining CIP propos-
als did not always result in the desired improvements (see para-
graphs 31 to 33(a)).

79.
Compared with the shortcomings noted during the
Court’s audit of Interreg I, there have been improvements to the
trans-European nature of projects and cooperation in the imple-
mentation of CIPs (see paragraph 7). However, there are still seri-
ous delays and, despite some efforts, a satisfactory solution is still
to be found for evaluating the CI’s impact, owing in part to the
imprecision and very broad scope of the objectives set in the
guidelines and at CIP level.

85.
It took much longer than planned to examine pro-
gramme proposals. Delays of this nature limit the time available
for developing projects and mean a more or less lengthy inter-
ruption in the process of cooperation between eligible regions in
the Member States. As a result, commitment appropriations were
reallocated in 2000 and payment appropriations were under-
utilised throughout the first four years of the period (see para-
graphs 35 to 39).

7.12.2004

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Official Journal of the European Union

C 303/17

Preparation and the start of implementation are generally
characterised by cooperation

Most programmes benefited from a preliminary process
86.
of consultation with potential project partners. However, as no
choices ensued, this process led to CIPs that were poorly targeted
(see paragraphs 41 and 42).

87.
CIPs were constructed around shared implementing bod-
ies and financial elements. This effectively strengthened coopera-
tion between all the partners. However, there is still room for
improvement: on the one hand, the absence of bodies that were
genuinely shared to represent the various Member States con-
ferred an artificial role on the managing authorities (see para-
graphs 43 and 44); on the other hand, the spirit of cooperation
that was supposed to characterise the constitution of JTSs was not
always in evidence, and in several cases the principle of a single
financial plan was not fully respected because the resources allo-
cated to the SFs and, more specifically, to the CIs were assigned
by Member States (see paragraphs 45 to 50).

Analyses are generally integrated but of little use; no
connection exists between analyses and the definition of
programme measures; the added value of projets needs to be
enhanced

88.
Since the ex ante assessors usually contributed to the
preparation and drafting of the CIPs, they are unable to provide
the wholly independent critical opinion that is required of them
(see paragraph 52).

89.
The analyses which are supposed to underlie any deci-
sions concerning CIP priorities and measures take time and a
good deal of effort necessitating the involvement of experts.
Although they usually cover the eligible region as a whole, the
analyses are of little use, in particular because the information
that they incorporate does not establish a regional point of depar-
ture against which the indicators are to measure CIP impact.
Where the results of these analyses are contradicted by the
‘bottom-up’ consultation process, the programmes should explain
why (see paragraphs 55 to 57).

Strand C programmes are the least well defined, in that
92.
they offer vague specific guidelines without the ex ante evaluation
that would have served to clarify needs. That it was impossible to
define indicators also demonstrates that the Commission was not
entirely prepared for the introduction of this Strand (see para-
graphs 24, 57, 62 and 72).

93.
Any complementarity between Strand A CIPs and tradi-
tional interventions is essentially due to the broad scope of Inter-
reg programmes. There is no point in assessing the complemen-
tarity of CIPs unless they are more tightly focused (see
paragraphs 64 and 65).

94.
Most of the first projects adopted were prepared and will
be implemented through cooperation. However, projects do not
always contribute significantly to the resolution of border-related
problems, as some are limited to the exchange of experience or
exist irrespective of the proximity of a border. In the Court’s view
there is too little added value, mainly by virtue of the imprecise
nature of the stated objectives and the broad scope of the mea-
sures for each CIP (see paragraphs 66 to 69).

The available tools are inadequate to the task of measuring
the impact of CIPs in relation to their objectives

95.
The CIPs contain objectives at global level and at that of
priorities and measures. These objectives do not result from
choices made in order to resolve specific border-related problems,
and they were not further broken down (see paragraphs 71 and
72).

96.
The many indicators set for the CIPs embody the objec-
tives inadequately or not at all. They exist in response to an obli-
gation rather than to a need to measure the progress achieved
against the stated objectives. Moreover, some indicators need to
be clarified and the sources of information need to be defined
more precisely. Although efforts were made to quantify some
indicators, these bear no relation to the initial analysis and con-
cern largely irrelevant objectives. In most cases, the computer
application that should enable the statistical data necessary for the
indicators to be collected is still non-existent (see paragraphs 73
to 78).

90.
Moreover, the problems identified are of a general nature
and are not specifically caused by the existence of borders,
although for some CIPs measures (on the environment and terri-
torial concerns linked to the ESDP, etc.) are justified because the
borders appear per se to constitute an obstacle (see paragraph 58).

Recommendations

97.

For the current period:

91.
Finally, the causal links between these analyses and the
CIP priorities are unclear. Both the stated objectives and the pri-
orities and measures derive from other concerns than that of tar-
geting actions to resolve specific border-related problems. Pro-
gramme measures are extremely varied, with the effect that
resources are spread very thinly and their impact is diluted.
Although the sharing of implementing bodies is conducive to
cooperation, it has not resulted in a targeted strategy (see para-
graphs 59 to 63).

(a)

(b)

the system of indicators adopted for each CIP should be
improved and simplified in order to give a more valid mea-
sure of impact, also bearing in mind the weaknesses that
were highlighted;

the selection criteria for new projects that might benefit from
the appropriations that have yet to be committed for each
CIP should be strengthened so as to improve the response to
specific border-related problems.

C 303/18

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Official Journal of the European Union

7.12.2004

98.

If the Initiative is renewed after 2006:

(a) a study should be launched to determine what problems exist
in connection with border areas and in which areas Interreg
could offer added value as compared with traditional Objec-
tive 1 and 2 interventions;

(b)

(c)

(d)

(e)

for each Interreg strand, the Commission should use the
information that it has received concerning the situation in
eligible areas to draw up priorities and establish concrete
objectives. It should then propose a common system of indi-
cators for each Strand with which to monitor progress;

there is a need for detailed criteria for the assessment of CIP
proposals. These would make it possible to adopt a proac-
tive approach vis-à-vis the Member States in order to
improve, from the outset, the quality of proposals and the
relevance of the information they contain. With clearer CI
objectives, projects could then be expected to offer greater
added value;

the analyses requested for each CIP should serve as a basis for
setting objectives and measuring progress;

the guidelines, working papers and other information
intended as a tool for the preparation of CIP proposals should
be made available before preparation begins;

(f)

the role of ex ante assessors and the content of their evalua-
tions should be clarified, as it is not always easy to reconcile
the task of helping to draft CIP proposals with that of mak-
ing a critical examination of programme content;

(g)

the usefulness of the information in the programme comple-
ment should be considered with a view to reducing content;

(h)

the financial resources allocated to the Initiative should be
held in common rather than assigned by Member State;

(i)

the work begun on legal instruments for cooperation should
continue so that they can be applied to Interreg.

99.
The Interreg CI promotes cooperation between partners
in different Member States and contributes to the opening of bor-
ders. At all stages of its implementation Interreg brings together
a number of Member States and regions. It will benefit, during the
rest of the 2000 to 2006 programming period, from efforts with
regard to indicators, the measurement of impact and selection cri-
teria. Looking ahead to the next period, should the Commission
decide to renew the Initiative after 2006, there should also be
efforts focusing mainly on programme planning and the condi-
tions of implementation.

This report was adopted by the Court of Auditors in Luxembourg at its meeting of 1 July 2004.

For the Court of Auditors
Juan Manuel FABRA VALLÉS
President

7.12.2004

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Official Journal of the European Union

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From the basic Community Structural Funds legislation to projects receiving ERDF assistance

Table 1

C 303/20

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Official Journal of the European Union

7.12.2004

Table 2

Implementation of Interreg III budget

2000

818,0

– 818,0 (1)

0 %

139,0

139,0

0 %

2001

777,0

– 73,3 (2)

703,7

594,3

109,4 (3)

84 %

223,6

– 22,7 (5)

200,9

82,9

118,0 (5)

41 % (5)

2002

2003 (provisional)

(million euro)

762,9

+ 147,3

– 46,7 (2)

+ 109,4 (3)

972,8

972,8

0,0

100 % (4)

370,0

370,0

267,5

102,5 (5)

72 % (5)

688,9

+ 188,0

876,9

876,9

0,0

100 % (4)

563,3

– 370,0 (5)

193,3

182,2

11,1 (5)

94 % (5)

Commitments

Initial appropriations

– reallocations

– transfers

+ appropriations carried over

= appropriations available (a)

Implementation (b)

Appropriations to be carried
over (a)–(b)

Rate of implementation (b)/(a)

Payments

Initial appropriations

– transfers

= appropriations available (a)

Implementation (b)

Appropriations cancelled (a)–(b)

Rate of implementation (b)/(a)

(1) Reallocation of the 2000 instalment to the 2002 to 2006 instalments as no Interreg CIP was adopted in 2000.
(2) Transfer to ‘innovative actions’ following delays in the adoption of a number of CIPs and delays on the part of some Member States. In 2001: Greece-Albania (Strand A),
Greece-FYROM (Strand A), Italy-Albania (Strand A), Italy-Adriatic (Strand A), Caribbean (Strand B), Réunion (Strand B) and South Zone (Strand C). In 2002: Greece-Italy
(Strand A), Greece-Turkey (Strand A), Archimed (Strand B) and Western Mediterranean (Strand B).

(3) Appropriations carried over from 2001 to 2002 following delays in the adoption of a number of CIPs: Ireland-Northern Ireland (Strand A), Greece-Cyprus (Strand A), Spain-

Atlantic (Strand B), North-West Europe (Strand B) and West Zone (Strand C).

(4) Rate of 100 %, taking into account the mechanism for automatic commitment of annual instalments on 30 April each year (Article 31 of Council Regulation (EC)

No 1260/1999).

(5) Size of transfers of payment appropriations and cancelled appropriations, as well as low rates of implementation. This position is due to the late adoption of the CIPs by the
Commission and the time required afterwards for selecting and launching the first projects (see paragraphs 35 to 39). Around 70 % of the amounts paid in 2001, 2002 and
2003 corresponds to the payment of automatic advance payments of 7 % of the ERDF contribution to the CIPs that were adopted.

NB: see the Court’s Annual Report concerning the 2001 financial year, paragraphs 3.7, 3.8 and 3.34 (OJ C 295, 28.11.2002).
Source: DG REGIO and revenue and expenditure accounts

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Official Journal of the European Union

C 303/21

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C 303/22

EN

Official Journal of the European Union

7.12.2004

Table 4

Programmes examined as part of the audit

CIP

Type – ERDF budget

Specific context

Surface area of
eligible area (in
1 000 km2)

Ems-Dollart Region (D and NL)

Strand A — 35,4 million euro

Smaller programme

Alps (F and I)

Strand A — 63,3 million euro

Mountainous region

Ireland-Wales (IRL and UK)

Strand A — 47,6 million euro

Maritime region

Spain-Portugal (E and P)

Alpenrhein-Bodensee-Hochrhein
(A, D, CH and LI)

North-West Europe (NWE) (B, D, F,
IRL, L, NL, UK)

Western Mediterranean (MEDOCC)
(E, F, I, P, UK)

Strand A — 806,9 million euro
Two subprogrammes adopted
with an ERDF budget of around
330,2 million euro

Largest programme

Strand A — 17,5 million euro

Smaller programme

Strand B — 329,7 million euro

Strand B — 103,8 million euro

Transnational pro-
gramme

Transnational pro-
gramme

Interregional pro-
gramme

North zone (ZN) (DK, D, S, SF)

Strand C — 32,8 million euro

19

45

27

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not relevant (1)

(1) The territory of the Union is divided into four parts, each covered by a CIP in Strand C. If the lead manager for a project is resident in the
eligible area of the CIP, all the project expenditure is booked to that CIP, even though the other partners may be resident outside that
eligible area. The surface area of the eligible area is thus not a relevant data item.

7.12.2004

EN

Official Journal of the European Union

C 303/23

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EN

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7.12.2004

EN

Official Journal of the European Union

C 303/27

Map 2

Interreg IIIB (2000-2006): Cooperation areas

Northern Periphery
Northern Periphery

North Sea
North Sea

Baltic Sea
Baltic Sea

0

100

500

km

0

100

500

km

0

100

500

km

North West Europe
North West Europe

Atlantic Area
Atlantic Area

CADSES
CADSES

0

100

500

km

0

100

500

km

0

100

500

km

South West Europe
South West Europe

Western Mediterranean
Western Mediterranean

Alpine Space
Alpine Space

0

100

500

km

0

100

500

km

0

50

250 km

Northern Periphery

North Sea

Baltic Sea

North West Europe

Atlantic Area

CADSES

South West Europe

Western Mediterranean

Alpine Space

Caribbean Area

Archimed

Açores, Madeira,
Canarias Area

Indian Ocean Area

Açores - Madeira -
Açores - Madeira -
Canarias Area
Canarias Area

Archimed
Archimed

Caribbean
Caribbean

AreaArea

Indian Ocean
Indian Ocean
AreaArea

Non-E.U. areas are indicative only.

© EuroGeographics Association for the administrative boundaries

gRe oi GIS
R
ge oi GIS

0

100

500

km

Source: Commission, DG REGIO.

C 303/28

EN

Official Journal of the European Union

7.12.2004

Map 3

Canarias (E)

Guadeloupe

Martinique

Réunion

(F)

(F)
Guyane (F)

(F)

Açores (P)

Madeira

(P)

INTERREG IIIC (2000-2006)

South
West
North
East

Source: Commission, DG REGIO.

gRe oi GIS
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ge oi GIS

North East South West

INTERREG IIIC

0

100

500

km

© EuroGeographics Association for the administrative boundaries

7.12.2004

EN

Official Journal of the European Union

C 303/29

THE COMMISSION’S REPLIES

SUMMARY

III.
In view of the large number of cross-border programmes,
the many different types of area concerned and the priority objec-
tive of developing cross-border economic and social centres, the
Commission opted in its guidelines for a bottom-up approach.
This is why the guidelines for strands A and C refer to the prior-
ity areas in relatively broad and non-exhaustive terms. The added
value is to be found in the development of cross-border coopera-
tion and in the catalyst effect this produces. The indicators should
measure progress made in this field. However, the intangible
nature of a great many operations made it difficult to devise tar-
geted indicators.

The main actors were familiar with the general points of the
guidelines, and the Commission had been in regular contact with
them well before the guidelines were published.

IV.
Even though improvements are always possible, the Com-
mission believes that the procedural stages were adequately pre-
pared and that the main shortcomings had been corrected, as far
as was possible given that there had to be some negotiation. The
delays were largely due to the time taken to remedy these short-
comings given the need to secure the agreement of all the Mem-
ber States concerned. The delays had little impact on the start-up
of the programmes.

The creation of genuine joint management structures with
V.
their own legal personality would facilitate implementation of
cooperation programmes. In its third report on economic and
social cohesion the Commission announced that it intended to
propose to the Council a new legal instrument, in the form of a
European cooperation structure.

The bottom-up approach brings out concerns not iden-
VI.
tified by expert analysis but expressed by regional and local
authorities which feed into the strategy and choice of priorities.
As the overall objective of the cross-border CIPs is to contribute
to the development of cross-border economic and social centres,
any project which facilitates cooperation on this point can par-
ticipate in the objective.

The Commission encouraged Member States to put in place IT
project management systems and databases to compile informa-
tion for use with indicators.

After the mid-term assessments, the Commission urged
VIII.
many programme management authorities to improve the sys-
tems of indicators. As part of the simplification drive, the Com-
mission called on Member States to simplify and reduce the num-
ber of their impact indicators.

IX.
The Commission considers that added value is greater if
CIPs contribute to creating cross-border economic centres rather
than simply resolving problems still existing at borders. The
choice of this approach affects the possibility of laying down
standard indicators, even if improvements are possible in this
field.

X.
The Commission will present the guidelines and method-
ology documents well before the next programming period gets
under way. The Commission is reviewing the role of ex ante evalu-
ation in preparing the new regulations.

XI.
The Commission will examine the Court’s recommenda-
tion when preparing the next programming period. It is working
on the legal cooperation instruments.

INTRODUCTION

4.

(a) The Commission would point out that the recommenda-
tion made in 4(a) has been taken into account in the
guidelines for Interreg III. It would refer to the Court’s
observations at 7(b).

THE COMMISSION GUIDELINES

12.
The Commission shares the Court’s view that it is impor-
tant that guidelines are adopted before the preparation of pro-
grammes starts.

On the question of making available the guidelines for Interreg III,
the Commission would refer to its reply to paragraph 28. On the
question of specific operational and measurable objectives and
targeted measures, it would refer to its replies in paragraphs 17
to 25.

VII.
The Commission recognises that there is a difficulty in
finding suitable indicators due to the fact that the added value of
the Interreg Initiative takes a variety of forms. The sets of indica-
tors in individual Interreg III programmes are, however, a prom-
ising start in this direction.

15.

(b) Cross-border institutions had been involved in Interreg
programmes in some regions. However, the different
national legal situations meant that the Commission
could not prescribe cooperation structures and the
guidelines therefore limited themselves to requiring joint
governing bodies.

C 303/30

EN

Official Journal of the European Union

7.12.2004

In its guidelines the Commission gives European eco-
16.
nomic interest groupings (EEIGs) as one of the avenues to be
explored; this was done in a number of programmes but the
results were rather disappointing, as is stated in paragraph 44.
The Final Report on the ex post evaluation of Interreg II published
in December 2003 has since confirmed that the EEIG instrument
is not geared towards cooperation between public law based
authorities and that it is very time and resource consuming to set
up and created practical difficulties in operation.

On completion of the work carried out in the wake of the study
on legal cooperation instruments, the Commission envisaged, in
the proposals contained in the third report on economic and
social cohesion, creating a legal instrument to facilitate the man-
agement of cooperation programmes.

17.

(a) Cross-border programmes have similar objectives to
those of traditional Structural Fund programmes, but
with the specific feature set out in point 9 of the guide-
lines, namely the development of cross-border eco-
nomic and social centres. This can only be achieved by
developing as many links as possible between neigh-
bouring socio-economic fabrics which, because of bor-
ders, have no links. The fundamental problem for bor-
der areas is the limited exchanges between actors on the
two sides of the border.

(b) The intangible nature of a great many Interreg opera-
tions make it difficult to quantify the impact. The Com-
mission would refer to its remarks in paragraph 21(a).

18.
The Commission believes that the analyses at its disposal
were adequate for defining the general objectives in the guidelines.

19.
The Interreg III guidelines state the general aims and
objectives to be pursued. It is, however, the situation in a particu-
lar border region that should determine the specific types of
action that need to be covered by a programme.

20.
The definition of the concrete objectives and priorities
for the programmes by the Member States’ authorities on the
bases of the Interreg guidelines is in line with the principle of
subsidiarity.

(a) Some of the most important benefits of Interreg are not
quantifiable. One of the main ones is to create, often for the
first time, a context where cooperation between individuals,
public and private institutions and enterprises across borders
can take place.

The greater the intangible content of projects, the greater the
difficulty of developing indicators. The Commission has con-
centrated on developing indicators to measure the concrete
results of cross-border and transnational cooperation in par-
ticular programmes. The current sets of indicators in indi-
vidual Interreg III programmes represent a start in this
direction.

(b) Despite the inherent difficulty of quantifying effects that are
largely intangible, the Commission aimed in its documents to
give examples of indicators that could be used in practice. In
the light of the experience gained in using the indicators, the
Commission recognises that there is room for improvement
in the guidance on indicators.

(c) The Commission was aware of the needs in terms of interre-
gional cooperation (strand C). Over the period 1994 to 1999,
it had organised five calls for proposals which had attracted
over 1 500 applications each representing a number of part-
ners. In response to these calls it financed and monitored
some 150 cooperation projects. On the basis of this experi-
ence the Commission decided to focus this type of coopera-
tion on improving the effectiveness of regional development
and cohesion policies and instruments. The Commission
would emphasise the usefulness of this type of cooperation
in an enlarged, 25-member Union with many bodies and
authorities conducting policies or managing regional devel-
opment measures.

22.
The Commission adopted the approach of a basket of
options from which the Member States could choose because of
the diversity of situations in the regions. Both in the guidelines
and during the negotiations the Member States were recom-
mended, inter alia, because of the limited funds available, to focus
the actions in each programme on certain prioritised measures
deriving from the socio-economic analysis of the situation in the
regions concerned.

Only NUTS III areas along the border could be included. Such
regions may be disadvantaged in comparison with the average of
the NUTS II regions to which they belong. For example the
NUTS III areas on the Bavarian-Czech border face a different
socio-economic situation than the average of the NUTS II areas of
Niederbayern or Oberpfalz, which are close to the 2001 EU15
average.

Given the diverse situations the Commission preferred
21.
not to set common indicators ex ante;
instead it suggested
examples of indicators to Member States. Defining indicators is a
process which must be carried out on an ongoing basis and in
partnership between the Commission, the management authori-
ties and the monitoring and steering committees.

The Commission wanted to leave the decentralised pub-
24.
lic authorities the choice of areas in which they wished to coop-
erate to improve their development policies and instruments. This
allows steering committees to select the projects best suited to the
regional development and cohesion objectives.

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In concentrating operations, preference is given to
25.
projects with a heavy cooperation content, whatever the area, for
the reasons explained in paragraphs 17 and 22 for cross-border
projects and 24 for interregional projects. Sectoral concentration
is appropriate in regions which have marked sectoral problems
but not for a territory confronted with the general problem of
weak socio-economic links because of the border. In this area at
least it is the intangible nature of the effects of cooperation, in
particular, which limits the possibilities of precise indicators for
evaluation purposes.

The Commission was concerned not to complicate pro-
26.
gramme management, as any definition of areas not based on
NUTS III would make analyses and the organisation of partner-
ship more difficult and would also lead to disputes about the geo-
graphical eligibility of projects.

The Commission discussed drafts of the guidelines with
28.
the Committee for the Development and Conversion of Regions
on 30 November and 13 and 20 December 1999. Before the for-
mal approval of the guidelines the Commission services were also
in regular contact with the regions and gave advice on the draft-
ing of programmes. Drafts of the specific guidance on ex ante
evaluation and indicators for Interreg III were available to Mem-
ber States in the Technical Group on Evaluation as early as
November 1999.

29.
As stated in paragraph 28 the content of the guidelines
was known well before they were finally published. The Commis-
sion does not therefore believe that the date of publication
affected the quality of the proposals.

THE COMMISSION’S PROCEDURE FOR EXAMINING CIP
PROPOSALS

32.
The second phase of the examination of proposals
involved inter-service consultations and culminated in a position
paper. This was drawn up in accordance with internal instruc-
tions intended to ensure that the programmes were of good qual-
ity. It served as a basis for negotiations with the Member States’
authorities. All the comments made during the inter-service con-
sultation and all correspondence with the Member States were
filed in the computer system and in hard copy. Desk officers sys-
tematically followed up the points raised in the position papers
and discussed in the negotiation meetings.

(a) The first version of the Spain-Portugal CIP provided only for
the creation of secretariats working separately just for the
subprogrammes. The corrected version of the programme,
which was judged admissible, added the creation of a genu-
ine JTS for support for the overall management of the pro-
gramme (in the managing authority) and of the subpro-
grammes
the
responsibility of the central authorities of the two countries.

regards operations

coming under

as

In order not to delay programme start-up, the Commission
accepted this proposal which it felt was not ideal but was an
improvement. Subsequently the Commission took a number
of steps to ask for the position of the JTS to be improved.

(b) The Spain-Portugal programme proposal was found inadmis-
sible after the check of the first proposal of 18 December
2000. The proposal was found admissible on 14 February
2001 after additional documentation had been supplied.

The comments of the coordination unit on the admissibility
of the MEDOC programme were of a qualitative nature and
could not be used to justify declaring the programme pro-
posal inadmissible. The comments were of a type to be con-
sidered in the context of the position paper.

34.
The Commission considers that the internal instructions
were adequate to ensure a consistent and transparent treatment
of the programmes, while allowing the necessary flexibility to
deal with the wide variety of programme areas and of quality in
the programme proposals. It also considers that the Member
States received adequate instructions for drafting proposals (see
reply to paragraph 28). Further instructions would have run
counter to the principle of subsidiarity and to the need to keep
rules as simple as possible.

36.
The exceeding of the time limit for the approval of pro-
grammes was largely due to delays in programme authorities’
revision of their proposals, which first had to be agreed with their
partners (see the Court’s observation in paragraph 37(c)). Within
the Commission, too, it was a considerable challenge to process a
large volume of dossiers at the same time, with nearly half of the
programme proposals arriving within the space of a few weeks
around the deadline for submission.

As stated in its reply to paragraph 19 of Special Report No 7/2003
(see FN 19), the Commission believes that the regulation time lim-
its were not very realistic, particularly for Interreg.

37 (c) The Commission would refer

to its

reply

to

paragraph 36.

The Commission had to find a balanced solution in part-

33.
nership with the Member States.

The Commission has announced that programme
38.
complements will be dropped for the next programming period.

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Many actors were still occupied with projects under the
39.
old Interreg II programmes, which could be implemented until
the end of 2001. This reduced in practice the potential for new
projects under the new programmes and therefore also reduced
the effect of the delay in the publication of the guidelines and in
the approval of programmes. The Commission would also refer
to its communication of 20 September 2002 (COM(2002) 528)
on the evolution of budget execution of the Structural Funds, in
particular outstanding commitments (RAL).

COOPERATION
IMPLEMENTATION

DURING

PREPARATION

AND

41.
Due to the specificities of the three strands, the involve-
ment of the various partners was different. As laid down in the
guidelines (paragraphs 22 and 23), cross-border cooperation pro-
grammes were to be drawn up by the regional or local authori-
ties in partnership with the national authorities, whereas transna-
tional cooperation programmes were to be drawn up by the
national authorities in close cooperation with the regional or local
authorities.

The Commission would refer to its replies to para-

42.
graphs 59 to 63.

An attempt was made in the north-west Region Interreg
44.
III B programme to set up a transnational association in the form
of a European Economic Interest Grouping to host the managing
authority and the joint technical secretariat of the programme.
However, it was found during the negotiations that not all Mem-
ber States provide for this type of institution with public respon-
sibilities in their legislative systems. Concerning a possible new
legal instrument for cooperation in the new period, the Commis-
sion refers to its reply to at point 16.

45.
The guidelines state that the joint technical secretariat
should assist the managing authority with the implementation
and operational management of the programmes. Emphasis is
placed on effectiveness and operational aspects, while the strate-
gic aspects are left to the managing authority and the monitoring
committee. For this reason, a JTS set up in a single location and
consisting of representatives of the Member States concerned is,
as a rule, better adapted to the guidelines.

48.
In the guidelines the Commission had suggested that the
system of financial management should allow a transfer from the
ERDF, but preferably also national co-financing (point 25 of the
guidelines).

CONSISTENCY BETWEEN THE INITIAL ANALYSIS AND CHOICE
OF MEASURES AND THE ADDED VALUE OF THE FIRST
PROJECTS TO BE ADOPTED

The Commission would refer to methodology working
52.
document No 2 ‘Ex ante evaluation of Structural Fund operations’
which recommends an independent and objective evaluation,
underlines the principle of proportionality, advocates an interac-
tive link between ex ante evaluation and preparation of the strat-
egy and proposes that the work of the evaluators be transmitted
to the Commission either as an annex or as a document or series
of separate documents.

54.
The cooperation projects managed as ERDF innovative
actions were completed at the end of 2002, i.e. after strand C was
launched. Although there was no external evaluation of these
projects, the experience acquired helped the secretariats respon-
sible for implementing the CIPs of this strand.

56.

(a) The Commission would refer to its replies to paragraphs

57 and 63 to 66.

(b) The Commission would refer

to its

reply

to

paragraph 63.

In focusing strand C on the objective of improving the
57.
effectiveness of regional development policies and instruments,
the Commission believes that it is for the decentralised public
authorities to identify areas of cooperation.

It

is quite right

that descriptions

58.
should present
development-related problems, because the main problem cre-
ated by borders is that of the inadequate intensity of economic
and social relations between neighbouring actors, which is an
obstacle to development. This is a tricky problem which takes
time to resolve, as it involves developing cooperation between
administrations and organisations of all kinds on both sides of the
border. The missing links therefore concern a great many sectors
of activity. On this point see the reply to paragraph 17.

(b) The examples show the differences in cooperation needs
between different programmes. They also confirm the Com-
mission’s opinion that regions should have considerable
scope to choose for themselves the types of cooperation they
find most urgent.

It is true that the bottom-up approach, which the Commission
considers essential in regional development, is potentially at odds
with the principle of concentrating financial resources ‘on a lim-
ited number of topics and measures’ (point 11 of the guidelines).
In particular, for programmes where there is long experience of
cooperation and a limited development gap (at old internal bor-
ders), the tendency is to cover a large number of topics in order
to take cooperation further, rather than concentrate on a limited
number of topics.

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The strand A Interreg programmes differ from traditional
60.
operation programmes in that they are directed at cooperation
and use rather innovative mechanisms to achieve this goal. In
view of the problems facing these areas as set out in para-
graphs 17, 21, 22 and 58, it is normal that the topics covered
should be the same as in traditional programmes.

Complementarity lies principally in the cross-border
64.
cooperation aspect which comes on top of the traditional and
economic and social development. For instance, two border
regions will include the financing of business support in their
regional programmes and, by way of complement, the exchange
of experience in financing such services in Interreg.

What distinguishes strand B from strand A is that those
61.
who devised these programmes followed the recommendations
of the ESDP to structure their cooperation. As a result virtually all
the strand B CIPs have a structure related to the ESDP priorities,
namely polycentric spatial development and a new urban-rural
relationship, clarity of access to infrastructure and knowledge and
wise management of the natural and cultural heritage. The Com-
mission does, however, acknowledge that some of these CIPs
could have been more targeted, but this is not always possible in
trans-national partnership.

62.

The Commission would refer to its reply to paragraph 57.

63.
There are at least four reasons why strategy and priori-
ties do not flow solely from the SWOT analyses: 1. the territories
concerned do not come under a single public authority; 2. the sta-
tistics do not relate to all the territories concerned; 3. as the major
problem is the weakness of cooperation links as explained in
paragraph 17, the best way of identifying what steps needs to be
taken is by a bottom-up approach; 4. the programmes are the
outcome of a negotiation process between partners in different
Member States trying to find a consensus.

The Commission considers that, for the four reasons given above,
for cross-border CIPs a bottom-up approach gives better results.
This inevitably means less targeting than with a top-down
approach, but it must still take into account programme strategy
and priorities. It is also closer to the concerns of authorities which
are responsible for development matters and of local actors. The
steps referred to at 3 and 4 should be explained in the CIPs and
integrated in the SWOT analysis.

Finally, in the field of cross-border cooperation, even with more
targeting the problems connected with borders would not all be
resolved, some of them (e.g. differences between taxation and
social security systems) are outside the scope of the ERDF or can
only be addressed in part (e.g. judicial and administrative coop-
eration — See Annex II, point 7). Applying solutions in these
areas is the sole responsibility of the Member States.

65.
For strand B, complementarity is achieved in that the
CIPs finance transnational projects which are too complex for
mainstream financing. For strand C complementarity derives
from the objective of improving regional policies and instru-
ments, some of which are used for implementing mainstream
actions.

66.
The selection committee must be in a position to base its
decisions on its appraisal of the quality of the projects, as it is pos-
sible, with the quantified criteria, to quickly identify the strengths
and weaknesses of each project and to discuss them in the steer-
ing committee. The Commission agrees with the Court that defin-
ing minimum quality would improve the selection system for cer-
tain programmes.

67.
The trans-European nature of projects is one of the prin-
cipal requirements of the guidelines. The Court is quite right in
underlining that some strand A projects financed by Interreg are
not carried out jointly by partners on both sides of a border. This
is authorised by the guidelines where significant impact can be
demonstrated on the other side of the border.

68.
The Commission considers that exchange of experience
is a way for the bodies involved in these exchanges to improve
their know-how. In some cases they may then be in a position to
carry out more effectively local development actions financed, for
instance, under mainstream or Interreg financed cross-border
programmes. This applies to improvement in business support
and the prevention of coastal erosion.

69.
The Commission believes that projects for the exchange
of experience are often a prerequisite for the development of
innovative action and better use of public funds. As regards the
observation on the lack of targeting, the Commission would refer
to its reply to paragraph 63.

THE FEASIBILITY OF MEASURING PROGRESS EX POST

As regards transnational CIPs, the Commission can go along with
the Court’s analysis and its criticism of inadequate targeting. The
Member States concerned were, in some areas, not sufficiently
involved in identifying projects which genuinely created struc-
tures for the territories concerned. In future consideration should
be given, for this strand, to developing more top-down working
methods involving national administrations.

71.
As explained in the reply to paragraph 63, the bottom-up
approach means taking into account the opinions of partners in
determining objectives and not only the SWOT analysis. In addi-
tion, the general objective of cross-border CIPs of developing
cooperation between administrations and organisations of all
kinds on both sides of the border (see paragraph 63) and the
intangible nature of a good many of the activities chosen make it
difficult to quantify exactly the impact of the operation (see para-
graphs 21 and 22).

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Commission staff are in the process of analysing in detail
73.
the mid-term evaluation reports; this exercise will help to remedy
the problems and shortcomings detected by the Court concern-
ing the relevance of the indicators. What the Commission has
seen so far is that one point criticised in a good many reports is
that project partners can each determine their own indicators; in
its official reaction to the reports the Commission will recom-
mend that project partners be required to use the indicators stipu-
lated in the programming documents (programme and comple-
ment). The lack of accuracy of the measurement of impact is
mainly due to the intangible nature of the large number of activi-
ties financed.

The context indicators proper serve to define the starting
74.
situation, giving a snapshot of the region to which reference can
be made to see whether the programme has had any impact on
this situation. It is true that these indicators are not necessarily
influenced by the operation, and that their value as far as the pro-
gramme is concerned can be limited. Many earlier Interreg evalu-
ations found that impact objectives cannot be quantified if this
starting situation is not known. The Commission notes that a first
step has been taken, but that harmonious application to all the
CIPs would have been of more use.

75.
As regards quantifiable indicators, i.e. of outputs and out-
comes, as a rule it is the beneficiaries who state in their reports
what has been achieved or, for some indicators, it is the joint
secretariat.

It is only to be expected that contributions to overall objectives
made by specific projects should be difficult to determine.

77.
The Commission urged Member States to select only a
limited number of relevant indicators. It reminded Member States
of this recommendation in the simplification exercise (Commu-
nication of 25 April 2003 (C(2003) 1255)).

The Commission urged Member Stats to put in place
78.
computerised project management systems and databases to
compile information for use as indicators.

CONCLUSION AND RECOMMENDATIONS

The delays in the publication of guidelines and in the
79.
approval of programmes did not have any decisive effect on the
quality of programmes (see replies to paragraphs 28, 29 and 36
to 39). As regards evaluation, some progress was made through
the increased quantification of objectives, even though this
progress was limited because of the intangible nature of many of
them (see the reply to paragraph 21).

The Commission guidelines have produced significant
80.
advances in the CIP management system compared with the pre-
vious period. Further progress is expected on the basis of current
experience and exchanges between management bodies under the
Interact programme. The Commission is also planning to pro-
the next
pose

should introduce

the Council

that

for

programming period a new legal instrument to facilitate the cre-
ation of joint structures.

81.
On the matter of the analyses available, the Commission
would refer to its replies to the observations in paragraph 18. As
stated in paragraphs 17 and 58, the general objective of cross-
border cooperation is the development of a cross-border
economy by developing cross-border socio-economic centres out
of the two economies separated by the border. This means that
any opportunity for developing cooperation between administra-
tions and socio-economic actors located on either side of the bor-
der should be promoted. Hence the guidelines deliberately pro-
vide a relatively wide field of action. In some CIPs, however,
specific cross-border problems were identified, by reference to
which targeted and measurable objectives were defined and
resources were concentrated on these objectives. These two
approaches are not therefore mutually exclusive, as is shown by
the examples of targeting on specific problems that the Court
quotes in paragraph 58.

The Commission would refer to its replies to para-

82.
graphs 26 and 55.

83.
As the Member States were aware of the essential aspects
of the guidelines before they were published and as the Commis-
sion was in regular contact with the regions while the proposals
were being prepared, the Commission does not think that pro-
grammes suffered in quality because of the delay in publishing the
guidelines. It would refer to its reply to paragraph 28.

84.
The Commission organised systematic assessment of the
quality of the proposals and monitored the action taken on its
observations. Where, on occasion, it was unable to impose its
demands, this was because it was involved in complex negotia-
tions with a set of partners who also had to negotiate the adjust-
ments requested between themselves.

The delays that occurred were not only when the Com-
85.
mission was examining the proposals. They were also the result
of the time taken by Member States, who had to talk to each other
and reach agreement on the improvements requested by the
Commission. As explained in paragraphs 37 and 38, as a rule
they took longer in doing this than the Commission did in exam-
ining the proposals.

As regards the low take-up of payment appropriations, the Com-
mission would refer to its reply to paragraph 39.

86.
Because of the search for the essential consensus in pro-
grammes involving a number of Member States and the very pur-
pose of the programmes, CIPs are targeted at enhanced coopera-
tion and not at predetermined sectors of activity. The Commission
would also refer to its replies to paragraphs 58 and 59.

87.
The Commission believes that improvements are still
necessary in terms of shared structures, and it is reassuring to
note that in most cases there is a single financial plan, despite the
fact that the resources allocated to the structural funds are dis-
tributed by Member States.

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88.

The Commission would refer to its reply to paragraph 52.

89.
As the Commission explained in paragraph 63, the
bottom-up approach brings out concerns not identified by expert
analysis. These concerns of regional and local authorities are used
in cross-border areas in addition to expert studies to determine
strategy and priorities. It is difficult to measure the impact of CIPs
because of the intangible nature of cooperation objectives (see the
reply to paragraph 73). The Commission pays attention to the
analysis of the starting situation. It is for this reason that it pro-
posed context indicators.

90.
The principal objective of cross-border CIPs is to develop
cross-border economic and social centres through joint strategies
for sustainable territorial development and not only to resolve
problems directly linked to borders. The main concern is to over-
come the major handicap of these areas which lies in the weak
links between actors who are located close to each other but in
different Member States. Programmes do, none the less, seek to
resolve certain specific problems linked to the existence of
borders.

91.
The priorities and measures are directed at resolving the
major problem of limited links between actors, and not only to
seek out specific problems which would justify sectoral targeting
of actions. Targeting does exist, but it concerns the processes
which generate cooperation and not sectors of activity, given that
the key objective is to generate cross-border economic centres.

92.
The objective set by the Commission in its guidelines for
strand C, namely ‘improving regional development policies and
instruments’, responds to a need which can be identified only by
the public authorities concerned by comparing their own policies
with those of their counterparts in other Member States. The
bottom-up approach is therefore fully justified. It is, of course, dif-
ficult to provide a theoretical definition of relevant indicators for
such an objective. The Commission and the Member States there-
fore agreed to define indicators pragmatically after examining the
first series of selected projects.

93.
Complementarity is to be found principally in the cross-
border cooperation element which is additional to traditional eco-
nomic development.

94.
The wide range of measures financed derives from the
bottom-up approach. In this connection the Commission believes
that exchange of experience is a way of improving the know-how
of the bodies involved and, in some cases, a prerequisite for the
development of innovative actions and better use of public funds.

determining objectives and not just the SWOT analysis. In addi-
tion, the general objective of cross-border CIPs is to develop
cooperation between administrations and organisations of all
kinds located on the two sides of the border (see paragraph 58).

The Commission acknowledges that in many cases there
96.
are too many indicators. But certain intangible objectives, which
are a feature of Interreg programmes, cannot easily be measured
by quantifiable indicators.

97.
The Interact programme is an indication of the impor-
tance the Commission and the Member States attach to improv-
ing the design and implementation of these programmes by
exchanging methods and experience between managers, Mem-
ber States and the Commission.

(a) The Commission is looking into the problems with indica-
tors in the mid-term reviews (see reply to paragraph 73).

(b) The Court itself observes (paragraph 67) that most of the
projects selected so far satisfy the trans-European criterion.
The Commission does not believe that projects should be
concerned solely with resolving specific border-related prob-
lems (see paragraphs 58 and 63).

98. (a) The Interact programme also helps to prepare the future.
However, the Commission believes that in view of the
different situations which exist, the analyses must be
conducted border by border within a wide-ranging part-
nership on the responsibility of the authorities in charge
of the cross-border programmes and not on the Com-
mission’s responsibility.

(b) For all the objectives of the forthcoming programming
period 2007 to 2013, the Commission will propose that
the Council adopt strategic EU guidelines for cohesion
policy. These guidelines will serve as a framework for
preparing and implementing fund programming,
including the European territorial cooperation objective.

(e) The Commission will present the guidelines and meth-
odology documents before the next programming
period gets under way.

(g) The Commission has announced that programme
complements will be dropped in the next programming
period.

(h) The Commission will consider the Court’s recommen-

dation when preparing the new period.

As explained in the reply to paragraph 63, the bottom-up
95.
approach involves taking account of the partners’ opinions in

(i) The Commission will propose a specific Council regula-

tion on this subject.