In March 2018, Euromontana has responsed to the public consultation on EU funds in the area of Cohesion. Its position paper points out solutions to move towards a more place-based development that more effectively considers territorial cohesion. It recalled that cohesion policy is also territorial cohesion and should pay particular attention to mountain areas, as requested in the Treaty of the Functioning of the EU.
Euromontana suggests how to better use existing tools to address place-based development in mountain areas all over the policy process from ex-ante evaluation, to designing and implementing the Operational Programmes to ex-post evaluation stage. It underlines the relevance of some tools like ITIs and CLLD instruments, even if insufficiently used so far or the possibility of modulating co-financing rates to give a higher co-financing rate to areas with geographical specificities. It also recognises the key role played by macro-regional strategies.
In addition, Euromontana suggests widening the set of available tools to make it easier to pay special attention to mountain areas. An Agenda for EU Mountainous Regions, a specific macro-regional strategy for the Carpathians, the development of cross-border Operational Programmes for some mountain ranges, like the “Comités de massifs” in France or better taking into account functional territories, with the possibility of creating multi-regional or intra-regional Operational Programmes for inter alia mountain ranges when relevant are among the examples presented. In addition, Euromontana suggests to better earmarked support with a minimum of 5% of Structural and Investment Funds for areas with geographic specificities to encourage place-based, integrated and sustainable development.
Finally, as simplification should first and foremost be done for beneficiaries, Euromontana presents simplification solutions to make Cohesion policy more accessible for all potential beneficiaries and more coherent. Euromontana notably recommends the following measures to be adopted:
- Increased flexibility with multi-fund Operational Programmes and solutions for cross-financing of operations between ESF and ERDF
- Encourage the possibility to have more synergies between the different Operational Programmes in one region
- Encourage a one-stop shop for all managing authorities of Structural and Investment Funds
- Promote the principle of proportionality in the controls
- Use more simplified and unit costs to simplify the management and reporting of the operations for the beneficiaries.
- Encourage managing authorities to systematically have a pre-financing of at least 50% of project costs at the beginning of each project to avoid cash flow problems for smaller organisations.
- Simplify reporting processes.
To conclude, if Euromontana welcomes the fact that DG Regio has contracted a consultant to deliver a study, by August 2018, on how the current Operational Programmes are strengthening the development of islands, mountains and sparsely populated areas through Cohesion Policy, Euromontana can only regret that this study will not be taken into account in the next legislative proposals due by the end of May 2018. More generally, regarding the timing, Euromontana wonders why this public consultation was done so late in the process and how its results will really be taken into account, as these legislative proposals have to be adopted by the College of Commissioners less than 3 months after the end of the consultation.21 March 2018