Opinion of the European Economic and Social Committee on the Proposal for a Regulation of the European Parliament and of the Council on a European Regional Development Fund (COM(2004) 495 final — 2004/0167 (COD))
Date: 2005-04-06
Institutions: European Economic and Social Committee
Subjects: EU regional policy, European Regional Development Fund, less-favoured region, regional development, sustainable development

14.10.2005

EN

Official Journal of the European Union

C 255/91

Opinion of the European Economic and Social Committee on the Proposal for a Regulation of the
European Parliament and of the Council on a European Regional Development Fund

(COM(2004) 495 final — 2004/0167 (COD))

(2005/C 255/18)

On 21 December 2004 the Council of the European Union decided to consult the European Economic and
Social Committee, under Article 262 of the Treaty establishing the European Community, on the above-
mentioned communication.

The Section for Economic and Monetary Union and Economic and Social Cohesion, which was responsible
for preparing the Committee's work on the subject, adopted its opinion on 18 March 2005. The rappor-
teur was Mr Matousek.

At its 416th plenary session on 6 and 7 April 2005 (meeting of 6 April), the European Economic and
Social Committee adopted the following opinion by 123 votes to 1 with 4 abstentions:

1. Preamble

1.1
This opinion has been developed within the overall
context of the discussion on the EESC Opinion on the General
Regulations (1).
It also relates to the other opinions of the
Committee on the Regulations for Cohesion Fund (2), on the
European Grouping of Cross-Border Cooperation (EGCC), on
European Social Fund (3) and on the Agricultural Fund for
Rural Development (EAFRD) (4).

1.2
The opinion reflects the impact of changes in the world
economy, of the dramatically increased competition in world
markets and the challenges for the European Union. Its starting
point is the urgent need to use all means possible to reach the
position of the EU in the world which will correspond to the
European potential. It recognises the necessity to mobilise all
significant resources in the short or medium term required to
enhance the capacities of new Member States as an integral
part of the EU economy and society including the hidden
strength of regional structures. This means increasing the rate
of progress towards reaching higher level of real convergence
of the economies with the synergy for the overall economy of
the Union. Therefore the Cohesion policy and its instruments
respecting actively the main goals of EU developments based
on sustainable development and quality European social model,
are subject to increase of significance.

2. Summary

This document first provides a brief description of the
2.1
challenges facing European Cohesion and Structural Policies,
and makes some general comments and then presents a
summary of the proposed Regulation.

(1) COM(2004) 492 final – 2004/0163 (AVC), CESE 389/2005.
(2) COM(2004) 494 final – 2004/0166 (AVC),CESE 390/2005.
(3) COM(2004) 493 final – 2004/0165 COD, CESE 250/2005.
(4) COM(2004) 490 final – 2004/0161 (CNS), CESE 251/2005.

2.2
In the concluding section the Committee comments in
more detail on the particular Articles of the proposed Regu-
lation. The Committee generally welcomes the broad approach
regulations. The
the Commission in drafting
of
Committee particularly concludes that:

these

It welcomes the fact that the actions to be supported
2.2.1
by the Fund will be concentrated on the European Union's
priorities as defined at the Lisbon and Gothenburg Summits.

that
Expenditure on housing and refurbishment
2.2.2
related to regeneration and development should be permitted.

is

Research and technological development,

2.2.3
innovation
and entrepreneurship should be given high priority, particularly
to support Small and Medium Enterprises (SMEs) development.

2.2.4
energy are all also important.

Sustainable tourism, public transport and renewable

2.2.5
Innovation should be broadly viewed with support for
the development and take-up of information and communica-
tion technology.

2.2.6
eration are welcomed and should be strengthened.

The proposals to promote European Territorial Coop-

2.2.7
The provisions on Urban areas and conurbations
should explicitly facilitate closer cooperation between the cities
of the Community.

2.2.8
diversification.

Rural areas should be supported to encourage greater

The

regulations

2.2.9
full
should
programmes of convergence to be implemented in the areas
with natural handicaps and the outermost regions as well as on
islands
island
states).

facing particular problems

(including small

explicitly

enable

C 255/92

EN

Official Journal of the European Union

14.10.2005

3. General comments

In the Third Report on Economic and Social Cohe-
3.1
sion (5) the Commission noted the challenges that faced the
Union in reducing disparities and with enlargement. It specifi-
cally noted:

— low levels of participation in continuing training in less
prosperous regions with significantly lower rates in new
Member States;

— major disparities in Research and Development (R & D)

expenditure;

— continuing disparities in terms of regional access to Infor-

mation and Communication Technology (ICT);

— the need for sustained high levels of growth, particularly in

new Member States;

— disproportionate amount of foreign direct investment going

into the economically stronger regions;

— employment rates well below the Lisbon Objectives.

3.2
The EESC has welcomed the report and the positive
contribution of the Structural Funds but has recognised that
‘very significant differences remain in terms of prosperity and
economic performance’. The Committee also recognised that
‘enlargement would significantly expand the Community's
internal market, bringing new opportunities’, but that enlarge-
ment would also bring wider disparities (6).

3.3
Reform is therefore needed to address the disparities
detailed above, to respond to the specific challenges of enlarge-
ment and to take forward the objectives of the Lisbon Agenda
for increased competitiveness, more and better jobs, social
inclusion and environmental sustainability. The Committee
wishes to stress that the Regulation should make this concen-
tration clear and that the range of activities described under the
various priorities should be seen as a menu or a collection of
tools that regions and Members States will use to produce
programmes that raise long term growth rates and strengthen
competitiveness.

3.4
As noted in the preamble this opinion has been drawn
up in the context of the EESC opinion on the General Regula-
tions (7). That work has commented in detail on the context
and on the necessity to strengthen the involvement of the
social and economic partners (8). Social partners and other
organisations which represent
the specific and/or general
interest of citizens should be included in all the stages of devel-
oping and implementing programmes and have full rights on
Monitoring Committees. That opinion also argues that
the
Commission should promote effective partnerships. It is the
Committee's view that to be most effective, then the decisions

(5) Third report on economic and social cohesion - A new partnership

for cohesion, COM(2004) 107 final.

(6) EESC opinion on Third Report on economic and social cohesion, OJ

C 302 of 7.12.2004, p. 60,

(7) CESE 389/2005.
(8) CESE 389/2005, point 3.3.

of those partnerships should be respected. That opinion also
set out the view of the Committee in respect of the New Priori-
ties (9) that are necessary to respond to the challenge posed by
enlargement. This opinion reflects those priorities as they relate
to the specific regulations of the European Regional Develop-
ment Fund. The Committee has already expressed its general
view that there should be sufficient resources devoted to Cohe-
sion Policy to achieve its objectives.
In addition, there are
points that concern both ‘old’ and ‘new’ Member States.

Firstly the problem of

3.4.1
limited resources and their
optimal allocation when compared with the absorption capa-
city (co-financing) of the new members and the regions and
areas of great extremes of poverty.

3.4.2
Secondly the problem of statistical effect and ‘phasing
out’ which has challenges for ‘old’ Members States and also
implications for recent new Member States after the next enlar-
gement of the EU after 2007 as they have to adjust to the
possible loss of eligibility for some regions.

3.4.3
Related to this point, there are also questions on the
methods to be used for computation of performance indicators
(Gross Domestic Product — GDP) where new members could
also face the threat of losing eligibility especially for the Euro-
pean Regional Development Fund (ERDF) assistance. Although
Eurostat has available only full regional data for the three years
this could cause difficulties for those regions
2000-2002,
whose share of EU Gross National Income (GNI) is in decline.

There are many other EESC opinions already available
3.5
or being developed, concerning the EU political and economic
strategies, industrial or structural changes, R&D and innovation,
development of tourism, the problems of urban agglomera-
tions, infrastructures, handicapped and outermost regions etc.
them
with the regional and cohesion dimension. Some of
should be reviewed as a result of enlargement. Eastern enlarge-
ment brings opportunities and challenges of the totally different
quality when compared with former enlargements.

4. Summary of the proposal for a regulation

The proposed Regulation sets out the ‘tasks of the Euro-

4.1
pean Regional Development Fund’.

4.2
The purpose of the Fund is defined as contributing to
the funding of assistance to activities to reduce regional dispari-
ties and in so doing to contribute to the objectives of the Com-
munity to strengthen competitiveness, create jobs and promote
sustainable growth. The scope of the fund is to support produc-
tive investment,
initiatives
and technical assistance. The fund will focus its assistance on
the thematic priorities of Convergence; Regional Competitive-
ness and Employment; and European Territorial Cooperation.

infrastructure, other development

(9) CESE 389/2005, paragraph 3.4.

14.10.2005

EN

Official Journal of the European Union

C 255/93

On Convergence,

4.2.1
the proposed regulation focuses
ERDF assistance on supporting sustainable development by
mobilising and strengthening endogenous capacity and sets out
the range of activities that are to be supported. They include
Research and technological development, promotion of
the
information society, sustainable production and environment,
promoting tourism,
improving the
security and efficiency of energy supplies, Education invest-
improvements to
ments that make regions more attractive,
health to contribute to economic development and aid to SMEs
to create jobs.

investments in transport,

4.2.2
In respect of Regional Competitiveness and Employ-
ment, the proposed regulation would focus assistance on first
promoting innovation and the knowledge economy. Specifi-
cally enhancing Research and Technological Development
(R&TD) and innovation capacities directly linked to regional
development objectives, strengthening innovation in SMEs,
promoting economic exploitation of new ideas and creating
new financial instruments and incubation facilities to promote
knowledge intensive firms. Secondly, attention is given to
environmental
including stimulating
investment in reclamation of contaminated sites, energy effi-
ciency, clean public transport and risk prevention. Thirdly
under this theme the fund will support investments outside the
major urban centres to improve access to transport networks
and promote the use of ICT.

risk and prevention,

tourism, culture and cross-border trade.

4.2.3
Activity under the thematic priority of European Terri-
torial Cooperation focuses first on developing cross-border stra-
tegies for sustainable territorial development. Specifically to
encourage entrepreneurship and SME development, and the
development of
In
addition activities are proposed that seek to improve access to
transport and ICT networks, cross-border water and energy
networks, collaboration on health and education. ERDF can
also fund the promotion of cross-border labour-market initia-
tives. This theme secondly seeks to support transnational coop-
eration,
including bilateral cooperation between maritime
regions to promote approaches to waste and water manage-
ment, accessibility to trans-European transport networks and
advanced ICT systems, environmental
risk prevention and
scientific and technological networks. Thirdly this theme seeks
to reinforce the effectiveness of regional policy by promoting
networking and exchanging of experience specifically in inno-
vation, environment and risk prevention and urban regenera-
tion.

The proposal for a Regulation defines the eligible expen-
the
specific provisions
and contains

concerning

4.3
diture
following elements:

4.3.1
Urban areas: the ERDF will support the development
of participative, integrated strategies to tackle the high concen-

tration of economic, environmental and social problems
affecting urban agglomerations. This Article also permits a
limited amount of ERDF to be used to support activities that
fall within the scope of the European Social Fund.

4.3.2
Rural areas: It is proposed that ERDF intervention in
these areas concentrate on economic diversification, whilst
ensuring complementarity with measures supported by Euro-
pean Agricultural Fund for Rural Development (EAFRD) and
European Fund for Fisheries (EFF).

4.3.3
Areas of natural hardship: For regional programmes
that cover areas facing natural handicaps ERDF shall in particu-
lar invest in improving accessibility, promoting cultural heri-
tage, sustainable use of natural resources and tourism.

4.3.4
Outermost regions: ERDF shall support goods trans-
port services and additional costs of storage, maintenance and
labour supply.

There are also specific provisions on European Terri-
4.3.5
torial Cooperation. These provisions set out
the required
content of Operational Programmes; these include analysis of
the issues and justification of priorities, financial tables and
implementation. They also set out possible arrangements for
managing the programme, including a specific legal instrument
to set up a specific body for cross-border cooperation.

4.3.6
Final provisions: These confirm the transitional provi-
sions under the current regulations (EC) No. 1783/99 and
formally record the proposed beginning and review dates of
the regulations, as from 1 January 2007 and by 31 December
2013.

5. Opinion of the Committee

5.1 Introduction, Scope of the regulations and Eligible Expenditure

(Articles 1, 2, 3, 7 and 13)

5.1.1
The Committee welcomes the clear link made in
Article 2 between the purpose of the fund and the objectives of
the Community and particularly the Lisbon agenda. Similarly
the Committee would endorse the focus of assistance on clear
thematic priorities. The renewed Lisbon objectives of raising
long-term growth rates in the weakest regions and strength-
ening competitiveness across the European Union must be the
objectives of the new programmes. The Regulation then has to
set out a menu of activities that can be brought together in
specific programmes that will respond to the specific condi-
tions in each region whilst contributing to the overall objec-
tives of raising growth and strengthening competitiveness. The
process of drawing up EU-wide Guidelines and National

C 255/94

EN

Official Journal of the European Union

14.10.2005

Strategies must focus on delivering the renewed Lisbon agenda.
Social Partners must also be closely involved in drawing up
these documents. In its Opinion (10) the Committee argued that
the renewal of housing and the provision of affordable housing
for key workers was an integral part of regeneration and had a
particular role to play in urban and indeed rural policy, there-
fore the Committee is disappointed that expenditure on
housing is explicitly excluded by Article 7. It is the view of the
Committee that expenditure on housing that is related to regen-
eration and development should be permitted and also that
expenditure on housing that is part of programmes of refurb-
ishment of older urban and industrial areas should also be
eligible.

5.2.5
The strength of transport infrastructure is one of the
key enablers of growth. Investments that connect regions to the
main European networks and markets are to be welcomed.
Good, clean integrated public transport systems are important
in towns and cities to ease congestion and in both rural and
urban areas to help reduce social exclusion.

5.2.6
The development of trans-European energy networks
will contribute to security of supply and closer integration of
Member States. Energy efficiency and renewable energy also
provide opportunities for new business that can also contribute
to growth and competitiveness in lagging regions.

5.2 Activities to promote Convergence (Article 4)

5.2.1
The Committee has stressed the importance of R &
TD and innovation and entrepreneurship. The analysis of the
third cohesion report pointed to the significant disparities in
R & TD investments and noted that innovation and entrepre-
neurship are critical
to sustaining high levels of economic
growth in less prosperous regions of the Community. The
Committee reiterate its view of the importance of these activ-
ities. It also notes that for some new Member States this ERDF
in developing the
assistance will be particularly significant
necessary networks of R&TD centres linking regional universi-
ties and enterprises (with particular challenges in supporting
SMEs) to bring up the region closer to the situation in devel-
oped Europe.

The Committee has also argued that ensuring access
5.2.2
to broadband communication networks and assisting SMEs to
take advantage of ICT is also very important in regions that are
lagging behind.

5.2.3
The provisions on the Environment contain a range of
actions; it would be helpful if the Article clarified that it was
the contribution these investments make to sustainable devel-
opment and promoting renewal energy that is of importance.

5.2.7
The investment in education also has direct benefits
for innovation and competitiveness and for the development of
human capital. As was noted above lagging regions are also
more likely to have fewer opportunities for life-long and conti-
nuing education. The regulation as currently drafted refers only
to ‘increasing the attractiveness and quality of life in regions’.
The Committee recognises the need for concentration and also
recognises the role of the European Social Fund but, given the
importance of Education wishes to see greater scope in this
article and for the closet coordination between the ERDF and
ESF (11). The Committee
importance of
promoting new solutions to the problems of communication in
a multilingual Union. Despite the formal commercial offer of
language training, the situation, despite improvements, is still
unsatisfactory.

also notes

the

The article provides for investments in the health-care
5.2.8
system which contribute to regional development and quality
of life, and is welcomed by the Committee.

Support

5.2.9
for SMEs is important and good regional
entrepreneurial policy can attract investment into structurally
affected or economically weak regions. Incentives and other
significant system measures in economies should be able to be
used to attract foreign investors to regions in need, to support
sectors of strategic importance to the EU and to support inno-
vative clusters of companies and organisations.

5.2.4
The promotion of sustainable tourism with high value
added is to be welcomed as it makes a significant contribution
to the development of regional economies and has significance
in both rural and urban areas. Tourism has an under-estimated
role in the trans-European transport framework in that it has a
positive effect on the European awareness of citizens. In addi-
tion investment in appropriate infrastructures, services and a
good environment can raise the attractiveness of regions not
currently seen as tourism destinations.

5.3 Activities to promote Regional Competitiveness (Article 5)

5.3.1
On innovation the Committee may wish to propose a
the innovation process, often new ways of
broad view of
working and innovations in management and Human Relations
can contribute as much to the success and competitiveness of
enterprises as totally new technologies, products or processes.

(10) The programming of the Structural Funds 2000-2006: an initial
assessment of the Urban Initiative, OJ C 133 of 6.06.2003, p. 53,
points 3.3 and 4.7.1.

(11) The Committee has strongly argued that it would have preferred a
single fund for the whole of cohesion policy, which would have
overcome these issues (COM(2004) 492 final – 2004/0163 (AVC),
CESE 389/2005.

14.10.2005

EN

Official Journal of the European Union

C 255/95

Moreover modernisation of industrial relations can be a prere-
quisite for the successful introduction of new technologies and
as such is critical to the achievement of the Lisbon objectives.
The regulation should reflect these factors and whilst recog-
nising the primary role of the ESF in these areas, support for
network to promote best practice in innovation as widely
defined should be supported.

5.3.2
The Committee welcomes the commitment to sustain-
able development, energy efficiency and the promotion of
renewable energy sources as desirable goals in themselves.
However there are also specific business opportunities for
design engineers and manufacturers in environmental
tech-
nology that can also contribute to regional economic develop-
ment. The Committee also welcomes the reference to clean
public transport and recognises that well supported and inte-
grated public transport systems also make a key economic
contribution to easing the burden of congestion in urban areas
and in tackling social exclusion in both urban and rural areas.

5.3.3
The strengthening of key transport and other links is
recognised as an important component of development. Rural
areas can be disadvantaged as the market is not sufficient to
provide the range of infrastructure desirable. The interaction
between other Community polices will be of significance here
and the Committee wishes to ensure that the activities to be
promoted in this theme are not unnecessarily constrained.
Access to ICT outside the major urban centres is also necessary,
but it is not just physical access and connectivity that is impor-
tant but advice, business support and skill development is also
essential to enable SMEs to benefit from ICT. In addition the
Committee believes that we need to ensure that access to ICT is
available for all citizens to avoid creating a digital divide that
reinforces social exclusion. These latter points are also very
relevant in major urban centres.

5.4 Activities to promote European Territorial Cooperation (Article

6)

5.4.1
The Committee has welcomed the Commission's
proposals for support for cross-border, transnational and inter-
regional cooperation building on the experience of Interreg (12).
However the Commission's proposals provide different sets of
activities in cross-border or transnational projects and the
current regulation appears to exclude a number of important
areas of activity supported by the programme from the scope
of
to
promote convergence, specific activities in rural areas, areas
with natural handicaps and outermost regions.

interregional networks,

for example,

the activities

The Committee specifically supports measures

5.4.2
to
enhance cross-border cooperation between the EU-15 and new
Member States on the internal borders of these countries. The

(12) OJ C 302 of 7.12.2004, p. 60, Opinion on Third report on

economic and social cohesion.

aim should be to establish in reality new, dynamic and vibrant
regions with common or
commonly used infrastructure
(including health care and education), relations among people,
efforts to overcome language problems and enjoying the best
of cultures. Structural Funds will help address problems of
disparities in income and price levels and promote economic
development. The Committee welcomes the new ‘European
Neighbourhood Policy’ (13),
its new instruments and also the
possible link to third countries and wishes to see it established
in the next programming period and also that the ERDF should
also be able to support these activities.

the various

5.4.3
The Committee notes the provisions for cross-border
labour-market initiatives and suggests that there is an explicit
reference in the regulations that reflect support for the commit-
ments given in accession agreements on labour-market stan-
dards and the Lisbon objectives. The Committee also argued (14)
that these programmes should also take account of the need to
combat
social discrimination. The
Committee wishes to seek clarification on this matter and press
to ensure that all ERDF supported activities are eligible subjects
for interregional networks. The Committee had specifically
called for a special programme for regions that share a border
with new Member States, this has not been included and the
Committee wants the regulation to support such activities and
it would be helpful to include a specific reference in the regu-
lation.

forms of

The proposal for a Regulation makes provision for the
5.4.4
establishment of a European grouping of cross-border coopera-
tion. The Committee has drawn up a specific Opinion on this
matter (15) and the conclusion of that work should also be
incorporated into the regulations.

Eligibility of expenditure is

5.4.5
to be established at
national level with certain exceptions, for which it is necessary
to lay down specific provisions. This significant condition
should be clarified. In the case of Value Added Tax (VAT), non-
recoverable VAT should be eligible as it is a real cost to the
projects.

5.5 Specific provisions on territorial features

5.5.1 Ur b a n (A r ti c le 8)

5.5.1.1
The EESC proposed a separate urban programme.
The activities set out in Article 8.1 should contain all the
features of the Urban Community Initiative and the Committee
would like to see explicit regulations to enable the cities of the
Community to work together.

(13) COM(2004) 628 final 2004/0219 (COD).
(14) OJ C 302 of 7.12.2004, p. 60, point 7.8, Opinion on Third report

on economic and social cohesion.

(15) CESE 388/2005.

C 255/96

EN

Official Journal of the European Union

14.10.2005

5.5.1.2
There is also provision in this particular article to
permit the funding of activities within the scope of Regulation
(EC) No. 1784/1999 of the European Social Fund (16). The regu-
lation limits this derogation to activities under the ‘Regional
Competitiveness and Employment’ objective and also to 10 %
of the ‘priority concerned (17)’. The Committee takes the view,
in the context of the intention to have a single fund for a single
programme that there should be greater scope to fund labour
market and human capital activities in these programmes. This
derogation should perhaps be applied throughout ERDF funded
programmes, not
the urban dimension and should be
applicable across the three thematic priorities. The 10 % level
therefore should apply to the programme as a whole to enable
sufficient flexibility.

just

5.6 Rural areas and areas dependent on fisheries (Article 9)

The Committee specifically commented on the need to
5.6.1
ensure that these activities were not limited to agricultural
projects and welcomes the focus on infrastructure, telecommu-
nications, new economic activities,
links between urban and
rural areas and promoting tourism. However this list should
also include access to services of general interest, innovation,
and links to Higher Education Institutions that have all been
identified as of
rural diversification. The
Committee also welcomed the Commission's original guarantee
that
the new instruments would be ‘incorporated into the
Common Agricultural Policy’ (18). This proposal for a regulation
requires Member States to demonstrate ‘clear demarcation
criteria’ between measures financed by ERDF and the EAFRD
and EFF and also to demonstrate and complementarity and
coherence between the actions financed by these funds. The
Committee welcomes this and refers to the more detailed work
also undertaken by the Committee on the EAFRD.

significance for

and

and

structural handicaps

broadly welcomes these proposals. In a separate Opinion (19)
the Committee has assessed the needs of regions with perma-
nent natural
specifically
commented on the Commission's broad proposals that were set
out in the Third Cohesion Report. The Regulation for the ERDF
contains many of the points raised in that opinion and the
Committee welcomes the territorial dimension in the criteria
for ERDF support. Article 10 contains the phrase ‘without
prejudice to Article 3 and 4’, implying that these regions are
also eligible for support under those priorities,
it would be
useful to explicitly set out in the Regulation that this indeed is
the case. Similarly Article 11 indicates that
this provision
permits the funding of additional costs to activities set out in
Article 4, which the Committee welcomes. It would again be
helpful to clarify that these regions could also be eligible for
support under the other objectives.

5.8 Specific provisions on territorial cooperation objective (Article 12

and Articles 14-22)

instrument

The Committee welcomed the proposal

for a new
5.8.1
legal
to facilitate cooperation. These additional
regulations seek to facilitate effective cooperation, but in one
respect they are deficient in that there is no explicit provision
for the involvement in monitoring arrangements of social part-
ners and other organisations which represent the specific and/
or general interest of citizens. The relationship between ERDF
(Article 18) and the new European Grouping of Cross-border
Cooperation (EGCC) needs to be clarified, particularly for
conferring by Member States the responsibilities of the mana-
ging authority on EGCC.

5.8.2
These matters have been considered in more detail
and the Committee has drawn up specific conclusions on estab-
lishing a European grouping of Cross-Border cooperation (20).

5.7 Areas with natural handicaps and outermost areas (Articles 10

and 11)

5.7.1
The Committee has argued for the continuation of
solidarity with these regions with particular difficulties and

5.9 Final provisions (Articles 22 — 26)

These confirm the transitional provisions under the
5.9.1
current regulations (EC) No. 1783/99 and formally record the
proposed beginning and review dates of the regulations.

Brussels, 6 April 2005.

The President

of the European Economic and Social Committee

Anne-Marie SIGMUND

(16) COM(2004) 493 final - 2004/0165 (COD).
(17) Article 8.2.
(18) OJ C 302 of 7.12.2004, p. 60, point 7.10, Opinion on the Third

report on economic and social cohesion.

(19) EESC opinion on How to achieve better integration of regions
and structural handicaps,

suffering from permanent natural
CESE 140/2005.
(20) CESE 388/2005.