REGULATORY ENVIRONMENT REPORT Deliverable D.T1.5.1

Organisation Eurac Research

Authors Cutello Giulia, Weiß Miriam

Delivery date March 2019

Status Final

Distribution level Public

Contents

About the PlurAlps project ...... 4 Introduction and theoretical background ...... 5 1. Approach and study area ...... 6 1.1. Approach and methodology ...... 6 1.2. The area of study: pilot areas in the Alpine region ...... 7 2. Addressing migrant integration and welcoming services in the EU Alpine Space 8 2.1. Integration in the EU: Overview of the policy framework ...... 9 2.2. Policy framework on the national level ...... 10 2.3. Overview of regulatory environment at pilot area level ...... 10 2.3.1. Austria: Bezau, Mellau, Kapfenberg ...... 10 2.3.2. Italy: Mals/Malles, St. Ulrich/Ortisei, Nizza Monferrato, Val di Non ..... 13 2.3.3. Slovenia: Jesenice, Kamnik, Postojna ...... 17 2.3.4. Switzerland: Engelberg, Zermatt ...... 18 3. Comparative analysis of the regulatory framework ...... 20 4. Conclusive remarks ...... 21 Bibliography ...... 23 Annex I – Regulations on national level ...... 25 Annex II – Timeline of the EU framework for migrant integration ...... 28 Annex III – Survey tool for regulatory environment analysis ...... 29

About the PlurAlps project In PlurAlps, partner institutions from across the Alps support organizations and actors at the local level to develop a welcoming culture and engage in social planning. The partner institutions cooperate with municipalities, small and medium-sized enterprises and public authorities in this regard. In this way, PlurAlps considers and responds to the needs of both newcomers and receiving communities in mountain and peripheral municipalities. In the course of 2016-2019, in selected territories of the Alpine Space, welcoming services and strategies have been developed to implement innovative approaches to welcome newcomers with the perspective of a pluralist society, thereby taking into account the regulatory framework shaped on the local, national and European level.

Introduction and theoretical background While migration is a historical phenomenon, the role of actors below and above central governments has emerged and strengthened in recent decades (Doomernik & Bruquetas-Callejo 2016). In the last few years, several studies have adopted a multilevel governance approach (MLG), which focuses attention on the relation between different administrative levels. Local and regional level, particularly, become prominent in the field of migrant integration (Zapata-Barrero et al. 2017). This approach suggests that some subnational actors (for example the Länder in Germany) influence, more than others do, the concrete integration of migrants because of their financial power and their proximity to the territories where the actual integration takes place. At the same time, legal and institutional rules, that frame and steer local immigration and integration mechanisms, are de facto established at the regional, national and European level (Penninx 2009, OECD 2018). This new research perspective underlines that local administrations play a crucial role in the development of a welcoming culture, especially when they make up for national shortages through their own initiatives, as asserts the OECD (2018):

“While migration policy remains a national responsibility, central and local authorities recognize that integration needs to happen where people are, in their workplaces, in their neighborhoods, and in the schools where they send their children. […] Local authorities, while coordinating with all levels of government and other local partners, play a key role in integrating newcomers and empowering them to contribute to their new communities […] weaknesses often stem from the lack of coordination among policies across different sectors (such as labor, health, housing and education), as well as across levels of government”. OECD – Working Together for Local Integration of Migrants and Refugee, 2018

If before the studies on the integration of newcomers at the local level have focused on urban contexts and larger agglomerations (Pastore & Ponzo 2016), recent interest of studies focuses on small municipalities (Balbo 2015). Understanding this “local turn” through an analysis of the legal framework on integration can contribute to improving state-based models of migration management (Zapata-Barrero et al. 2017). It can be argued that integration is a challenge that concerns everyone and starts mainly from the bottom up (Villa 2018). Within this framework, the present study takes a cross-national perspective to show the regulatory environment, which affects the establishment of a welcoming culture in Alpine regions. A better understanding of the differences in the regulatory framework in Alpine regions can clarify the role of each level of government about the issue of integration and consequently support developing services able to speed up the process of integration in the receiving communities (Weiß et al. 2017). This report investigates how the regulatory and institutional framework looks like that offers efficient solutions or approaches and allows territorial actors to take action for welcoming newcomers. The following questions guide the analysis: • Which regional laws or directives are dedicated to welcoming/receiving migrants? Of these, which refer to municipalities? • Who on the state, regional or municipal level has room for maneuver? • How does the legal framework influence the implementation of the newly established/tested services/offers in the pilot areas?

After an initial overview of the approach and methodology applied to investigate the regulatory framework of the PlurAlps pilot territories, the report introduces the area of

study, i. e. the Alpine Space Programme region. Then, an overview of the regulatory framework on integration on European, national and local (pilot area) level is given. Chapter 3 presents a comparison of the regulatory frameworks, identifying factors of success, responsibilities, and modalities – normative and not – that affect the establishment of welcoming services. Finally, concluding remarks ensue. 1. Approach and study area

1.1. Approach and methodology A case-based comparative policy analysis approach was applied to systematically assess the regulatory environment for welcoming and integrating newcomers in the pilot areas and across countries (Meltsner 1976, Weimer & Vining 1999). This was done to describe and explain how the regulatory framework influences and shapes what municipalities/regions can do to welcome/integrate newcomers (Howlett & Ramesh 2003). This method helps to bring out similarities and differences in the regulatory framework of five countries (AT, DE, CH, IT, SI) and allows for a deeper insight into the regulatory context of sectoral policies related to integration (Ragin 1987). This is expected to uncover which regulatory environment is more favorable to establishing welcoming services. Generally, policies are a result of government decisions and there exist different ways to understand how policies come into force, how governmental decisions alter policies and vice versa (Howlett M & Ramesh 2003). In PlurAlps, the focus is thereby more on the policy outputs that is the “practical” side of policy issues and less on the policy-making process (Howlett & Ramesh 2003). In view of the complexity and difficulty to study public policy as asserted by Howlett and Ramesh (2003), for the purpose of the PlurAlps project, the following documents were collected for a comparative analysis of integration policy in the pilot areas:

• Key legislation on integration at the local level • Non-binding regulatory acts/instruments • Financial instruments • Integration plan at the local level

In detail, the following aspects of the documents were examined: • Main contents • Innovative aspects • Objectives and topics related to welcoming culture and integration of migrants • Definition of integration and migrant/newcomer used in the documents • Involvement, responsibilities, liabilities of persons/institutions in welcoming and integrating migrants • Priorities for integration set by the PlurAlps pilot territories • Effect/impact of the regulatory environment on carrying out the PlurAlps pilot activities

Key topics considered were: • Employment • Housing • Training & education • Healthcare • Political-legal participation • Measures related to cultural integration

The data was collected by means of a policy analysis tool (see Annex III – Survey tool for regulatory environment analysis) elaborated by Eurac Research that the PlurAlps project partners were responsible to fill in. Eurac carried out additional desk research on the European and national legal framework on integration.

1.2. The area of study: pilot areas in the Alpine region In the Alpine area, the number of foreign resident population has increased in the period 2011-2015: from about 4.9 million to about 5.6 million in the ESUALP area (+ 14.7 %). The number of non-EU citizens went from about 1.5 million to 1.8 million; that is an increase of + 18 %. For the alpine countries, migration is an important factor of demography; and non-European migration is an important component in the demographic change (Ravazzoli and Lolini 2018). It includes various types of domestic or international migrants: refugees and asylum seekers but also pensioners (amenity migrants), re-migrants/returners as well as seasonal workers. This is combined with the challenges of a population that is becoming older and that needs to be taken care of. As well as a population that is becoming less as birth rates are low. This situation sets the conditions for the need to develop strategies, plans, and instruments to find ways of welcoming newcomers, while ensuring quality of life for all citizens. There is the need to deal with language barriers, to deal with cultural differences, to acquire intercultural competences, to maintain local services and to make them accessible to newcomers. Alpine municipalities can respond by adapting public services in such a way that they consider the needs of both the long-standing community members and newcomers. The map (Figure 1) shows the PlurAlps pilot areas that are the object of analysis. Among them, twelve were chosen as case studies for the report at hand, covering four Alpine countries. The case study areas are listed below, grouped as follows (some territorial information is provided): • Austria: Bezau and Mellau are two small municipalities located in the Bregenzerwald region, in the Land Vorarlberg near Lake Constance. Kapfenberg is an Austrian municipality in the district of Bruck-Mürzzuschlag in Styria, a Land in the southeast of Austria. • Italy: Malles (Venosta Valley) and Ortisei (Gardena Valley) are two small municipalities in the Autonomous Province Bolzano-Südtirol of which Bolzano is the capital. Nizza Monferrato is a municipality in the province of Asti in Piedmont, located between the cities of Alba, Asti and Alessandria. Val di Non is a valley of Trentino, situated in the North-West of the Autonomous Province of Trento. Administratively, Val di Non belongs to the Community of Val di Non, one of the valley communities established in the Province in 2010. • Slovenia: Jesenice is a town on the southern side of the Karawanks, a mountain range of the Southern Limestone Alps on the border between Slovenia to the south and Austria to the north; Kamnik and Postonja are municipalities one in central and other in southwestern Slovenia. • Switzerland: Engelberg is a small municipality in the half canton of Obwalden and Zermatt is a municipality in the canton of Valais, in the district of Visp.

Further pilot areas are Lauterbrunnen and St. Moritz, which have however not been included in the research

Figure 1: Overview map of the PlurAlps pilot regions (Source: Laner P, Dalla Torre C 2018. Eurac Research

2. Addressing migrant integration and welcoming services in the EU Alpine Space Post-war Europe has experienced four distinct periods of immigration shaped by time, geographical patterns and type and size of migration groups as Penninx suggests (2016). The current period that began with EU enlargement in 2004 is hence characterized by new intra-European mobility, diversification of migration and of origin, and asylum reviving, the latter mainly since 2014/15 (ibid.). Regarding third country nationals, attempts prevail to further harmonize immigration and integration in the EU but different immigration/integration regimes continue in the North-Western, Central- European and Southern-Mediterranean EU countries (ibid.) that are rooted in past migration movements, policy approaches to integration, as well as a (non-)willingness to be considered immigration countries (ibid.). The following paragraphs introduce the EU policy framework on integration and give a brief account of the national situation. The regulatory framework on regional level ensues.

2.1. Integration in the EU: Overview of the policy framework On EU level, when referring to migrants, a distinction is made between mobile EU nationals and third-country nationals (non-EU migrants). Mobile EU nationals are also defined as ‘migrants’ (in the context of the EU, a person who takes an action of immigration) or ‘emigrants’ (a person who performs an act of emigration) (European Migration Network 2018). There are divergent priorities and budgets as well as responsibilities for these types of migrants in the field of integration. EU nationals are competence of DG EMPL (Directorate-General Employment, Social Affairs and Inclusion), while third-country nationals are competence of DG HOME (Directorate- General for Migration and Home Affairs) (Petrovic & Collett, 2014). The European institutions promote mainstreaming the approach in the field of integration through three main tools: funding, policy networks, and legislation. For EU migrants, the European Union adopts legislation setting out minimum requirements at EU level. Through "transposition”, EU member states incorporate and implement EU law into their national legislation, ensuring a uniform level of protection of rights and obligations across the EU. Based on the principle of free movement enshrined in the Treaty on the European Union (TEU)1 European citizens have the right:

• to look for work in another EU country • to work there without having to obtain a work permit • to reside in another country while seeking work • to stay in that country, even when the professional activity has come to an end • to enjoy equal treatment with citizens national legislation regarding access to employment, working conditions, as well as any other social and taxes benefits

EU migrants can also ask for certain health and social security benefits to be provided in the country to which they move to seek work. In some cases, their professional qualifications may be in line with the ones recognized abroad. Rights may differ slightly for the self-employed, students, pensioners and economically inactive persons. There are restrictions for reasons of public order, public security, public health and occupational access in the public sector. In principle, EU law on the free movement of workers also applies to Iceland, Liechtenstein and Norway, which are members of the European Economic Area (EEA), and to Switzerland (European Commission 2014). In the EU framework, for non-EU migrant integration three main documents can be identified (see also Annex II – Timeline of the EU framework for migrant integration):

The increase of migration flows from non-EU migrants required a multilevel response from EU that for this reason has developed:

• Policies to manage regular and irregular immigration

1 Article 3(2) of the Treaty on the European Union (TEU); Article 21 of the Treaty on the Functioning of the European Union (TFEU); Titles IV and V TFEU; Article 45 of the Charter of Fundamental Rights of the European Union.

• Common EU-wide rules on asylum to create the Common European Asylum System (CEAS) • Reform to guarantee border security and asylum seekers distribution among EU countries

To manage regular immigration the EU also decides: • Conditions for legal entry • Conditions for residence

Instead, member states can establish volumes of admission to seek work for non-EU migrants. In recent years, European countries significantly reduced these admission volumes and one of the indirect effects related to this choice was the increase of application numbers for asylum since they are the only way of gaining legitimate access to the EU member states. To manage irregular migration, the EU elaborated a return policy in respect of fundamental rights. Even if the integration is part of migration processes, at national legislation level there is not a real harmonization, so in this regard the EU plays a supporting role by financing or by engaging with non-EU countries to address the main causes of migration.

2.2. Policy framework on the national level Migrant integration policy is primarily a national competence. Due to the vastness of regulatory acts on national level, information is presented in Annex I – Regulations on national level. To reconstruct the regulatory national framework, information on the main legal acts were provided by the project partners and added to through desk research (European Web Site on Integration EWSI)2. Annex I at the end of this report contains for each national partner information on: Ministry with overall responsibility; list of policy papers and programs; list of key legislation. In the subsequent regional analysis part, references to national acts are made. It is important to consider that this report is based on the information provided by PlurAlps partners, it accounts for their different points of view on the culture of welcoming newcomers, but it cannot be considered as an expression of the general opinion of the EU member states on the integration of newcomers. Additionally, the perspective of the PlurAlps project partners is in the foreground of this analysis.

2.3. Overview of regulatory environment at pilot area level Based on the information provided by the PlurAlps project partners with a pilot area, the regulatory frameworks on local/regional level are reconstructed in the following subchapters, grouped per country (Austria, Italy, Slovenia, Switzerland). What is presented in this report bases on information received from the project partners.

2.3.1. Austria: Bezau, Mellau, Kapfenberg Austrian project partners consider positively a recent (2017) Federal Law (Integrationsgesetz – IntG3), indicating it as key legislation for newcomers’ integration in their regions. The Austrian Integration Act aims to facilitate the integration of persons

2 EWSI, the European Commission's portal for information on migrant integration, providing up-to-date information and good practices on migrant integration in Europe for policy-makers and practitioners (https://ec.europa.eu/migrant-integration/). 3 Bundesgesetz zur Integration rechtmäßig in Österreich aufhältiger Personen ohne österreichische Staatsbürgerschaft

legally residing in Austria into society. On one hand, it provides integration promotion measures, and on the other hand, it provides an obligation to integrate on the part of the newcomers (i. e. active participation in the integration process), based on personal interaction. At the federal level, the responsibility for achieving the measures of integration is shared mainly by the Federal Minister for Europe, Integration and Foreign Affairs (competent to respond to provide value and orientation courses of the legal and social order) and Federal Ministry of Labor, Social Affairs and Consumer Protection. Indeed, Federal Government promotes for example language courses (§4 Deutschkurse) for third-country nationals from the age of 15 (including asylum and subsidiary protection). The law also provides for an Expert Council4 as well as an Expert Advisory Council5 and establishes the tasks of a monitoring and research system for the integration process. The latter is composed not only of members representing the federal government but also of representatives of Austrian municipalities and cities; all levels of government are thus represented and taken into account. The Integration Act requires a co-ordinated approach specifying that all state institutions at the federal, state and local levels also give their own contribution to a successful integration process according to their own possibilities. By defining integration as a holistic task, the whole of society is addressed. As indicated by the project partners, integration measures are largely financed by the Austrian Integration Fund (ÖIF) and the Asylum, Migration and Integration Fund (AMIF). The objectives related to the welcoming and integration of migrants are establishing measures, which include participation in the social, economic and cultural life in Austria through gainful employment, access to and acceptance of educational opportunities, gender equality and the rapid attainment of self-preservation abilities. The final aim of the integration process of the newcomer is to consider obtaining Austrian citizenship.

Austrian project partners consider that the Integration Act has a positive impact on the pilot activity because it foresees German courses for persons entitled to asylum and subsidiary protection and for third-country nationals.

Bezau and Mellau In addition to the Federal Law, the Government of Vorarlberg in 2016 adopted a specific integration agreement for refugees, persons with subsidiary protection and third-country nationals. In virtue of this binding declaration, arriving third-country nationals are obliged to “acquire knowledge of the German language as well as the democratic order and the basic principles derived from it”6 (own translation). Moreover, the Vorarlberg project partner refers to an Integration Plan in force for the Region. The Integration Model of the State of Vorarlberg7, a regional act issued in 2010, was created by a cross-party consensus on integration in Vorarlberg and approved by all parties represented in Parliament. The Model defines the following strategic areas and priorities:

4 A consultative committee consists of persons who have proven expertise on integration. 5 Its main aim is to promote a comprehensive knowledge- and information exchange and the exchange of views concerning questions of integration of general importance and it shall contribute to an interdisciplinary cooperation. 6 https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=3&ved=2ahUKEwihw7XJ-- XiAhUHzqQKHQGBDNwQFjACegQIBBAC&url=https%3A%2F%2Fpresse.vorarlberg.at%2Fland%2Fser vlet%2FAttachmentServlet%3Faction%3Dshow%26id%3D26713&usg=AOvVaw10tVUPh5IDHZhkeyIQ XZ9W 7 https://vorarlberg.at/web/land-vorarlberg/contentdetailseite/- /asset_publisher/qA6AJ38txu0k/content/integrationsleitbild?article_id=94622

• Integration Policies in Vorarlberg • Language and Education • The Economy and the Job Market: Access and Advancement • Health and Social Services • Living Together: Housing, Neighbourhood, Free Time and Socializing • Culture and Religion • Participation and Partnership

Politically at all levels of government a lot of emphasis is on learning the language and understanding Austrian culture and customs. The strict regulations for access to work somewhat conflict with reality, especially in the agriculture and tourism sectors, which are the main sectors of employment of newcomers, and in which employers seek to keep asylum seekers, for example, who have started an apprenticeship, even though they have received a negative asylum status.

Generally, the partner Regio-V believes that the Model had positive effects on the pilot activities and facilitated the integration of newcomers over the years, stating: “With an integration network comprising the State Government, municipalities, the project group, immigrant organizations and other partners, Vorarlberg’s immigration policies have proved to be effective”8.

Kapfenberg In addition to the Federal Law, the Styrian government elaborated in 2016 the Work Program Integration (Arbeitsprogramm Integration). This specific regulatory program is based on the framework of the “Charter of Co-Existence” (see Figure 2) and includes an interdepartmental coordinated package of measures with the aim of a targeted integration of refugees in Styria.

Figure 2: The six areas of focus and measures for integration of the Styrian Charter of Co-Existence

8 ibid.

The Program establishes that the key points and measures for each of the areas of action shall be adapted and further developed in a demand-oriented way about challenges of today. The aim of this work program is a regional and sustainable support for the integration of displaced people right from the start. Thus, the local co- existence is facilitated and the social participation, as well as the self-preservation capacity of refugees, shall be challenged and supported early on. Many different stakeholders, associations, institutions and organizations were brought together in the six action fields mentioned above9. Moreover, the Styrian region has an Integration Plan issued in 2011 and in force called Charter of Co-existence. The State of Styria has agreed upon a common position regarding diversity. The Charter summarizes the principles, as well as related objectives and values ensuring that all people in Styria live together in harmony. For the project partner in Kapfenberg it is important that the newcomers obtain German language skills or develop an interest in learning German. They believe that the Kapfenberg community must also be able to accept other cultures, likewise the newcomers must get involved in the local culture. Companies and public authorities actively support the arrival of skilled workers from other regions of Austria, EU countries and third countries. There is a need for skilled labor in Upper Styria, which can be covered by the new arrivals. Indeed, a good/high level of technical or scientific skills opens up a fast integration into the labor market in the Kapfenberg region.

The project partner for Kapfenberg retains that the welcome package containing information on the region, which newcomers received under the Integration Act, concretely and positively supports the pilot activities of PlurAlps. Moreover, it is considered important that private, humanitarian or church-related institutions, as well as non-statutory care and community institutions, should be involved wherever possible in the implementation and promotion of integration. According to the PlurAlps partner, the Charter of Co-Existence has a very positive effect on the PlurAlps pilot activities because it facilitates the bi-directional (two-way) process of integration.

2.3.2. Italy: Mals/Malles, St. Ulrich/Ortisei, Nizza Monferrato, Val di Non Mals/Malles and St. Ulrich (South Tyrol) The integration of foreign citizens has been the subject of a special provincial law n.12/2011 of the Autonomous Province of Bolzano/Bozen, which has also set up the Coordination Unit for Integration. It offers advice, coordinates and promotes actions for the integration of foreigners. The measures and tasks provided for by the law have been better defined by the Decree of the President of the Provincial Council no. 35 of 2012. In 2016, a shared Agreement for Integration10 was elaborated through an active participatory process that involved all citizens and defines mutual obligations and rights. This act was approved by the Provincial Council for Integration and by the Provincial Government, containing common principles and objectives aimed at fostering the co-living in diversity and constituting the basic act for integration work in South Tyrol. From 2016, to encourage integration at local level, grants have been given to local authorities for the implementation of initiatives aimed at the integration of new citizens. Funded are also measures to promote the participation of immigrants in social life, to raise awareness and inform public opinion, for the training and updating of multipliers in the field of integration.

9 The measures were developed in several round-table meetings with representatives of public and civil institutions and organizations as well as representatives of the relevant authority of the Styrian government. 10 Italian and German original titles: Convivere in Alto Adige – Un patto per l’integrazione. Zusammenleben in Südtirol – Integrationsvereinbarung

Therefore, the competence on the integration subject lies transversal with the municipalities and district communities, so targeted actions are required, dynamic relations at every administrative level, collaboration with the social partners and the citizens concerned can translate the processes of integration at local level and on a practical level. The role played by local and regional authorities in integration is essential since they know the needs of the area and can act in a targeted manner to solve problems. Within the provincial framework of newcomers’ integration, the role of the Provincial Coordination Unit for Integration (Koordinierungsstelle für Integration) is relevant, which is responsible for offering advice to municipalities and district communities, coordinate and promote actions aimed at the integration of new citizens. Within integration policies, another important role is played by the municipalities, by the municipal integration officer (Integrationsbeauftragte/r) and district community because they know the needs of the territory and can act, seeking to solve problems arising locally. Municipalities represent local communities, preserve their interests and promote their development. In South Tyrol, they have full administrative and financial autonomy and can support the integration process through different measures in different fields of action (e.g. housing policies, training, labor market, social policies). Despite this wide margin for action granted to municipalities, however, they have been activated in a marginal and different way as engagement with integration and shaping the process depends to a great extent on interests, strategies and motivation of the mayor or the municipal integration officer as well as the municipal council, as a study by Eurac shows (cf. Mitterhofer et al. 2016). Across the range of activities, this department of the province has been responsible for creating a vademecum for integration, dedicated to municipal and district referents where all the information concerning the theme and services related to integration are contained. In addition, an information guide for new citizens has been created, which provides information on South Tyrol but also on the services offered by private and public institutions in the area. The same guide can be customized with specific content for each municipality11. Activities aimed at integrating newcomers/foreigners are financed with funds from all levels of government (provincial, regional, national, EU) to varying degrees and according to the competences of each level of governance. Fundamental to the integration process in South Tyrol are considered language learning, as well as knowledge of culture and customs.

In the South Tyrolean case studies, the collaboration with associations, institutions and organizations within their municipality, as well as with external actors (i. e. associations, parishes, private entrepreneurs, training institutions etc.) promotes not only the exchange of information among the operators themselves but facilitates also in a decisive way the search for and adoption of certain measures to encourage co- existence in the municipality. All this had a positive effect on the implementation of PlurAlps pilot projects. The different approach of each municipality to the theme of integration seems to be influenced by several factors mainly related to political/financial issues (cf. Mitterhofer et.al. 2016).

Nizza Monferrato (Piedmont) The Piedmont has issued a regional law “in favor of non-EU resident immigrants” in 1999 n. 64, that is considered by the project partner the key legislation on integration for the pilot territory. The Law establishes purposes within the areas of regional competence: • Promoting integration

11 http://www.provinz.bz.it/familie-soziales-gemeinschaft/integration/downloads/Rahmenbroschuere.pdf

• Promoting equal opportunities • Protecting language, culture and links with countries of origin

It provides that Piedmont Regional Administration with own direct initiatives as well as in collaboration with local authorities and associations of migrant, coordinates, promotes and organizes initiatives aimed at encouraging: • Knowledge of the Italian language • Vocational training and retraining • Adequate housing • School integration • Integration through cultural activities

The financial instruments for the implementation of projects aimed at the integration of newcomers are partly European, partly national (i. e. Asylum Fund, Migration and Integration 2014-2020, funds from the Ministry of Labour Department for Equal Opportunities at the Presidency of the Council of Ministers). Based on this regional law, by 31 October each year the Regional Council proposes and approves the annual program of interventions required by law and to be carried out in the following year. This provision has allowed the development of regional policies aimed at integrating migrants, starting with local authorities. However, the partner points out that, over the years these policies have had to consider national regulations and the application of regional laws, according to the choices of the regional administration of the specific period. The objective related to welcoming and integration in the pilot region is the promotion of initiatives so that non-EU migrants (in particular) residing in the regional territory, could get all their rights recognized, according to the principles of the Italian Constitution. The PlurAlps project partner quotes a set of different initiatives to achieve this goal: Italian language courses; training and re-training for migrant workers; offer suitable housing for migrants; inclusion of migrants’ children in the national educational system (of every order and degree); cultural initiatives and activities favoring integration between migrant communities and the Piedmont locals; taking care of the dissemination of publications and audiovisual and radio material among the migrant communities; studies, survey, research relating to the migratory phenomenon; social- welfare interventions in favor of migrants in need; initiatives aimed at making effective the right to health care and social services provided for Piedmontese citizens; initiatives in favor of the right to education and aimed at the recognition of qualifications obtained abroad by the Italian state. The Piedmont Region is developing a Memorandum of understanding for seasonal migrant workers in agriculture (DGR, n. 39 – 8502; approved 1 March 2019).

According to the partner the regional law about integration has allowed local authorities to develop reception and integration policies. The partner also specifies that the institutions and local authorities of the two pilot areas have the objective of developing a widespread reception policy, thus creating, together with the third sector, targeted paths for social and labor market integration in line with regional legislation.

Val di Non (Trentino) The provincial legislation in Trentino about immigration is the law n. 13 of 1990. It implements certain provisions of national law 30 December 1989 n. 943, that is aimed at supporting the inclusion of non-EU immigrants in the Trentino community and is the legal basis for any intervention in the field of immigration in the Autonomous Province of Trento (PAT). This system essentially was based on the delegation of integration issues to social private bodies. The law, therefore, has the undeniable merit of having

recognized the importance of the role that associations played in terms of social inclusion of immigrants already before the law’s entry into force (e.g. ATAS – Associazione Trentina Accoglienza Stranieri, Onlus, Shangrillà Association, Community Solidarity Foundation [formerly Caritas Tridentina], the Villa S. Ignazio cooperative). In 2001, the PAT created an operational unit of Social Policies and Health Department – Centro informativo per l’immigrazione – Cinformi. Cinformi is structured on the collaboration between public and private social bodies and its three specific areas of intervention are: • Information: service counters on the territory, training to enable services to respond to needs expressed differently; • Awareness: events and initiatives on the territory, study and research activities, integrated communication project; • Reception: applicants for international protection, unaccompanied foreign minors, victims of traffic for exploitation

Over the years, the scope of Cinformi has expanded to respond to the stabilization of immigration and to accompany the Trentino community in the face of challenges related to the migration phenomenon entails. As idea lab, it is a location where projects are organized favoring a better social inclusion of immigrants. Cinformi has become the inter-institutional coordination and reference center that had been lacking up to that point, and the central point of an increasingly stable network of various actors involved in the integration process. Even if the PAT does not have normative documents establishing reciprocal rights and obligations for the receiving communities and newcomers, art. 17 of law 13/90 establishes the possibility of stipulating agreements between public bodies and associations in order to implement interventions in favor of immigrants from outside the EU. In 2018, the PAT and the Government Commissariat for the Province of Trento elaborated a protocol relevant in the field of integration. The act has as its object a targeted and shared project among different subjects. It has different goals: counteract social marginalization, inclusion of people in projects and activities of social utility; using funds allocated by the State for asylum seekers. This agreement defines the guidelines for projects, activities and initiatives of territorial level for the integration of the people accepted, within a framework of permanent collaboration between the Health Department and social solidarity – Cinformi, Consorzio dei Comuni Trentini, municipalities and communities.

Among the financial instruments available there is the possibility for associations to obtain an annual contribution from the PAT to finance their activities up to 90% of eligible expenses. The procedure is simple, standardized and widely used so the project partner believe that it is a useful, effective and an easily accessible tool.

The project partner does not believe that the Protocol has any impact on the activities of the pilot, which are mainly focused on the type of long-staying migrants rather than on asylum seekers and refugees. However, the partner considers that the PAT’s legislation creates a facilitating context for the implementation of the pilot project activities. Indeed, thanks to the actions in support of local associations, the provincial territory is characterized by a wide range of services managed by third sector organizations. The Province promotes autonomous initiatives to foster the widest participation of citizens in the establishment of the service system and the growth of a culture of solidarity. According to the project partner, the private sector is confirmed to be very important for newcomer’s integration. However, it is not clear whether the organizational system of integration in the Trentino province is able to guarantee

effective autonomy of the associations as on the one hand, they depend entirely on public funding, while on the other hand, they are in direct competition with public entities (e.g. with Cinformi). Finally, it should be emphasized that, now, following the political change at the Provincial level that has led to the establishment of a strongly right-oriented government, public resources for the social integration of migrants will probably undergo downsizing or, at least, there will be a change of approach in dealing with these issues.

2.3.3. Slovenia: Jesenice, Kamnik, Postojna A Slovenian key legislation for newcomers’ integration is the Resolution on Immigration Policy of the Republic of Slovenia (Official Gazette RS no. 40/99), adopted in 1999, which defines three main pillars of immigration policy for the country, namely: • Prevention of illegal migration • Protection and assistance to refugees and asylum seekers • Integration of immigrant into Slovene society

The same Resolution provides the normative and organizational structure necessary for a successful and consistent implementation of EU immigration policy. In order to implement the Resolution, Slovenia has issued a new visa regime and laws in line with EU immigration policy:

In 2002, the Resolution on Migration Policy of the Republic of Slovenia (Official Gazette RS, no. 106/2002) was adopted, which defines even more concrete activities and measures for the application of migration policy by harmonizing them with the European acquis communautaire and basic European principles such as solidarity, right to freedom of movement, equality, providing security and maintaining peace. The aim of integration is defined in these two normative acts as empowering migrants to “become responsible participants in the social development of Slovenia”. Then, the Aliens Act (AA-2) (Zakon o tujcih – Ztuj-2), adopted in 2011, specifies the conditions for and methods of entry, departure and stay of foreigners in the Republic of Slovenia. All activities regarding newcomer and migrant integration are set on national level but for the procedures relating to the integration of foreigners in the Republic of Slovenia, the administrative unit in whose territory the newcomer resides is competent in the first instance. The International Protection Act (IPA-1) (Zakon o mednarodni zaščiti – ZMZ- 1), adopted in 2016, lays down the basic principles and guarantees the proceedings of international protection. In 2017, statutory instruments which further regulate the implementation of the IPA-1 were adopted to provide better treatment of refugees, especially unaccompanied minors and other vulnerable groups. In March 2017, the Government set up the Government Office for the Support and Integration of Migrants. This office “performs the tasks defined by the laws governing the aliens, international

protection and temporary protections of displaced people” 12 . It thus provides accommodation for migrants, their health care, and integration into education and work. The partner identifies another important act: Employment, Self-employment and Work of Aliens Act (ZZSDT) (Zakon o zaposlovanju, samozaposlovanju in delu tujcev – ZZSDT). This Act sets out the conditions under which aliens may be employed or work in the Republic of Slovenia, unless otherwise determined by international and national agreements. Thus, this Act regulates the procedures concerning the acquisition of work permits but it is specifically aimed at asylum seekers, refugees and persons with subsidiary protection. Another key act for migrant integration identified by the PlurAlps partner is The Strategy of Economic Migration 2010-2020 (Strategija ekonomskih migracij za obdobje od 2010 do 2020). This action plan describes the main instruments and strategic mechanisms directed towards a more coherent and effective management of economic migration, so it deals with labor immigration. The immigration is regarded as one of the possible instruments to tackle the problem of labor shortage and certain professions in Slovenia. The Strategy primarily focuses on attracting highly skilled migrant workers and partly also touches upon the problem of the lack of low-skilled and skilled workforce. In 2012 started the Initial Integration of Immigrants Program to facilitate the integration of third-country nationals, which is a public educational plan to teach Slovene language to adult immigrants. This program was signed by the Slovenian Centre for Adult Education and includes content from life and work in Slovenia and is covered by the Ministry of Interior and co-financed by the European Asylum, Migration and Integration Fund (AMIF). Language courses are provided by regional/local institutions selected via public tender and financed by the Ministry of the Interior. The Government Communication office financially supports NGO’s projects (which address respect and acceptance of different ethnic groups, refugees and migrants) and other contractors selected through public tenders, in the field of education and awareness raising because “it has become one of the basic programmes for assistance in integration into Slovenian society”13. Until recently, Slovenia did not have a strategy on refugees’ integration, nor on the integration of migrants in general. In July 2019, the Government adopted a strategy in the field of migration, which defines the basic lines of action in the area of both legal and illegal migration. The strategy consists of six pillars that are interconnected and form a holistic approach to migration. The six pillars are linked to specific aspects of migration, i. e.: legal migration; international protection; illegal migration and return; security aspect; integration and external dimension of migration. Each pillar has individual goals, which are interlinked with each other. The pillar “integration” does not seem to bring any substantial novelties for the pilot municipalities. The local level is rather vaguely addressed in the strategy by stating that “consideration should be given to transfer of competencies and resources to the local level”. Furthermore, no improvements are foreseen for better support or stimulation from the national level to ease cooperation between municipalities that are facing similar challenges regarding migration.

2.3.4. Switzerland: Engelberg, Zermatt In Switzerland, the project partner reported on the regulatory framework for the municipalities. For the pilot activities in Engelberg and Zermatt, two regulatory acts are considered key for integration:

12 http://www.uoim.gov.si/en/areas_of_work/ 13 http://emm.si/en/news/report-on-the-work-of-the-migration-office-for-2017/

• Federal Act on Foreign Nationals (Bundesgesetz über die Ausländerinnen und Ausländer) • White Paper – Specific Promotion of Integration as a Task for Federal State – Cantons 2018-2021 (Grundlagenpapier: Spezifische Integrationsförderung als Aufgabe Bund – Kantone in den Jahren 2018-2021)

The federal law regulates the procedures concerning integration in Switzerland and serves as main basis for all integration activities. It states that integration is a task for federal government, the cantons and municipalities. Particularly important is the revised article 53 that states: • Federal state, cantons and municipalities respect concerns of integration and protection against discrimination in fulfilling their duties. • They create the beneficial frame conditions for equal opportunities, in inclusion of the foreign population in public life. • They make sure they inform foreigners adequately about living and working conditions in Switzerland, especially about rights and duties. • Federal state, the cantons and municipalities inform the public adequately about immigration policy and about the special situation of foreigners.

The federal law does not speak about migrants but about foreigners. This means that the law applies to persons with a foreign passport. The level of integration and what an “integrated person” would mean is not defined. “Foreigners” are further differentiated into person with EU/EFTA nationality and nationality from a Schengen country. The new federal legislation states that the cantons and municipalities are responsible coordinating and implementing regulation to foster better integration. This requires each canton to define its strategic direction of integration activities and to coordinate these. All cantons have a Program for Integration, which is defined together with the Federal Secretariat for Migration (SEM, Staatssekretariat für Migration). The Cantonal Programs (KIP, Kantonale Integrationsprogramme) define topics of national significance. For the KIP 2018-202114, the defined pillars are: • Information and counsel • Education and work • Understanding and integration into society

The structures and responsibilities might vary between cantons. Some cantons have laws that specify the responsibilities between cantons and municipalities. Cantonal laws refer to the federal law as background for their own regulations. This means that the structures in the four pilot regions (Bernese Highlands/Lauterbrunnen, Wallis/Inneres Mattertal, Grisons/Oberengadin and Obwalden/Engelberg) are all different. Main partner in the four regions are the offices responsible for the implementation and coordination of the KIP. But their embeddedness in the regions differs. This makes it more difficult to develop a strong, local partnership for the pilot activities. Since the implementation of integration activities is in the responsibility of the municipality as well, there are differences between cantons but also between municipalities within the same canton. The integration offices support municipalities in their efforts even if some municipalities might have welcoming services (e.g. in Obwalden all new inhabitants are invited for a welcoming interview) on their own, whereas others do not offer any

14 The KIP currently in force bases on goals and pillars of previous KIP.

event or interview. Some municipalities have integration officers (Integrationsbeauftragte/r) other do not. The KIP are innovative for Switzerland in the sense as they render authorities on all three levels – national, cantonal and municipal – responsible for integration. The KIP have led to cantonal offices that coordinate the integration in contact with regional organisations and municipalities, allowing the regional level to develop activities according to their needs. Financial support from federal government is only granted if the cantons commit to national integration goals. This means that each canton defines its own goals on the operational level, which allows the regions to develop need-oriented activities.

All cantonal activities must follow the structure of the above-mentioned pillars and adapt to territorial and municipal needs, which means that structures and responsibilities might vary from canton to canton. For the four Swiss PlurAlps pilot regions, this means that structures are all different though the Swiss partner concludes that the KIP has overall favored the implementation of the PlurAlps pilot activities. 3. Comparative analysis of the regulatory framework For all examined pilot territories, key legislation applies that is negotiated at EU and national level. Indeed, in all cases considered national law establishes the main objectives and measures related to the integration of migrants/newcomers so there lies the main responsibility for the promotion of integration measures. However, mirroring the EU’s principle of subsidiarity, there is a vertical share of responsibilities (cf. Collett et al. 2017) between national and local level so that the role played by local authorities is essential for concrete implementation of initiatives to promote integration in socio-economic life in the territory. National laws are accompanied by federal regulation (in the case of Austria), regional regulation (e. g. Piedmont), provincial regulation (in the case of Trentino and South Tyrol) or a program for each territory (Cantons in the case of Switzerland). In Slovenia as well, at national level a partial transfer of jurisdiction to local level is foreseen[CG1], where however instruments on municipal level currently still seem to be lacking so that local capacities and activities for welcoming and integration cannot be fully exploited. Integration plans, non-binding in nature, have been implemented in the pilot territories in different ways: mainly at regional level (e.g. Piedmont approved the Memorandum of Understanding for seasonal migrant workers in agriculture and the related local Memoranda of Understanding such as the one approved in Saluzzo on 13 March 2019; Vorarlberg elaborated the Integration Model of the State of Vorarlberg; in Switzerland are created four different cantonal integration programs for Wallis, Berne, Obwalden, Graubünden) but also at Province level in the case of the Autonomous Provinces of Trento (with a Memorandum of Understanding focused on migrants staying long-term) and Bolzano (with an Agreement of Integration). These types of acts can be considered to constitute a helpful guiding, orientation and visionary tool for both the population and policy makers. The local level is thus the administrative level that in all countries seems to have most room for maneuver to adapt concrete integration activities to their needs, as this is where welcoming and integration take place. Indeed, the norms of the administrative levels closest to the territory concretely provide for the modalities in which the integration activities must be carried out so that the local level is considered responsible for concrete implementation in coordination with public institutions but also with the private sector.

PlurAlps partners generally argue that the legal framework about integration of newcomers is conducive to their pilot activities, recognizing at the same time that it suffers from defects, especially of being applied in a different way in each local context (e.g. some Swiss municipalities have integration delegates others do not). Indeed, municipalities have different approaches to integration, influenced by several factors, related both to the legal system and political issues but especially to the accessibility of funds. For example, South Tyrol with its status as Autonomous Province, has access to territorial (provincial) funds, unlike the Slovenian partner which refers only to European and national funds (AMIF, ISF), or Switzerland, where the Federal State and the Cantons invest 32.4 million each for the KIP financing it for 50% each. Municipalities nevertheless also seek exchange and cooperation on the inter- municipal and regional levels to unite forces, to secure funding and share tasks that do not stop at the municipal administrative border. The key points and areas of action for integration are similar in all our cases of study. They can be individuated generally with all the activities related to language acquisition, understanding culture and customs of the welcoming/receiving territory. Moreover, the data provided by the present examination, as well as according to literature, shows that the municipal initiatives aimed at integration to be successful should be inclusive addressing the entire community and not relate to a specific target exclusively (Mitterhofer et al. 2017). For the implementation of the pilot activities and generally for the concrete integration of newcomers, the following can be considered favorable solutions: the creation of an operational unit (i. e. Cinformi in Trentino) that facilitates the access of foreign citizens to public services, offers, information; a Provincial Coordination Unit for Integration (e. g. South Tyrol) that has a networking and facilitating role, also granting financial support; an integration office that supports municipalities in the provision of the services for the integration (i. e. Switzerland); a welcome package (Austria) or a vademecum for integration (South Tyrol) for newcomers containing information on the region; existence of a jointly elaborated plan for integration i. e. KIP (Switzerland), Multiannual National Programme (Slovenia), Work Program Integration (Austria), or Agreement for Integration (South Tyrol), the creation of a network of services resulting from a negotiation table among public administration, entrepreneurs’ associations, unions, NGOs working with migrants and social assistance and health services (Piedmont). 4. Conclusive remarks With this report we have sought to gain a better understanding of how the regulatory framework looks like in the PlurAlps pilot territories, which offers efficient solutions, approaches and practices of integration and allows territorial actors to take action to welcome newcomers. Heterogeneous national models have prevented the development of fully harmonized integration policies. The difference is mainly since these models need resources that are not available at European level to be implemented (Villa, 2018). In this context and in accordance with the main literature (Zapata-Barrero et al. 2017), the study shows that the subnational (regional and local) administrative levels concretely influence the integration of newcomers because they are closest to the needs of the territories and the community. Indeed, the different approaches to the issue of newcomer’s integration are reflected in a different application of a common regulation that is modulated at the local level according to the needs of the territory. Of course, the room for maneuver of the local administrative levels is strongly influenced by the policy and the concrete accessibility to funds for the implementation of activities aimed at integration, which is very different in the pilot areas of PlurAlps.

The local level becomes crucial, especially when it makes up for national shortcomings with its own initiatives. Local communities become the places where national policies take shape and laboratories for experimentation, collection and sharing of good practices. Integration is a challenge that starts from the bottom up, which is why it is important to understand the role of the local governance level, where daily integration is carried out, where policies emerge that go beyond those imposed by central governments and from which the political debate takes shape (Villa, 2018). The comparative analysis, in agreement with the partners of PlurAlps, shows also that in general the regulatory framework on integration has positively supported the implementation of the pilot activities.

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Annex I – Regulations on national level

AUSTRIA FRANCE GERMANY ITALY SLOVENIA SWITZERLAND Ministry for Europe, Ministère de l’Intérieur Federal Ministry of the Ministry of Interior – Ministry of the Each Canton in respect Integration and Interior Department for Civil Liberties Interior with federal law Foreign Affairs and Immigration

Overall Overall Ministry of Labour and Social Ministry with Ministry Responsibility Policies – Immigration

50 Action Points – Arrêté du 12 août 2013 Der Nationale Planning document Resolution on Kantonales A Plan for the portant organisation Integrationsplan concerning Italian policy on immigration policy Integrationsprogramm Integration of interne de la direction immigration and foreigners in the Republic of 2014-2017 Persons entitled to générale des étrangers Nationaler 2004-2006 Slovenia (adopted Asylum or en France Integrationsplan – Erster by the Parliament in Kantonales

Subsidiary Fortschrittsbericht Economic and financial 1999) Protection in Arrêté du 12 août 2013 planning document 2010- Integrationsprogramm Austria; portant organisation Nationaler Aktionsplan 2013 Resolution on 2018-2021 interne du secrétariat Integration / National migration policy in Integration Report général du ministère de Actions Plan on The Civis Project: Towards a the Republic of Kantonales 2011/2012/2013/20 l'intérieur Integration multicultural society Slovenia (adopted Integrationsprogramm 14/2015; National National Integration Plan for by the Parliament in Bern 2018-21 Action Plan for Décret n° 2013-728 du Integration in Refugees (2018) 2002) Actionplan Integration; 12 août 2013 portant Deutschland. Erster organisation de Integrationsindikatorenber Report of the Kantonales Anerkennungs- l'administration centrale icht working group for Integrationsprogramm ABC-Anerkennung du ministère de preparing possible ausländischer l'intérieur et du ministère Zweiter measures for Wallis KIP 2 Wallis Policy Papers or Programmes or Papers Policy Qualifikationen aus des outre-mer Integrationsindikatorenber putting into force Beruf und Bildung; icht the migration policy Circulaire NOR – estimation of the Integrationsindikato IMI/C/09/00053/C du 7 Bundesweites current situation on renbericht des janvier 2009 relative à la Integrationsprogramm the field of the Nationalen mise en place d’une migration and

Aktionsplans für nouvelle politique Konzept für einen integration policies Integration; d’intégration des bundesweiten in the Republic of étrangers en situation Integrationskurs / Concept Slovenia (2005) - Co-existence in régulière for a nation-wide Internal document Austria integration course Rahmencurriculum für Strategy of einen bundesweit Economic Migration einheitlichen 2010-2020 Einbürgerungskurs Government Migrationsberatung für strategy on erwachsene Zuwanderer migration (2019) und Jugendmigrationsdienste

Red-White-Red- Code de l’entrée et du Gesetz über den Law 5.2.1992, no. 91, 'New Decree on Rights Ordinance of 24 Card séjour des étrangers et Aufenthalt, die provisions on citizenship' and Duties of October 2007 on the du droit d’asile Erwerbstätigkeit und die Refugees in the Integration of Settlement and (CESEDA) Integration von Legislative Decree Republic of Foreigners (OIntS) Residence Act Ausländern im 25.7.1998, No. 286 on Slovenia – 2008 Loi n°2003-1119 du 26 Bundesgebiet 'Consolidated Act of Foreign Labour Act novembre 2003 relative (Aufenthaltsgesetz) Provisions concerning Aliens Act – 2011 Federal Act of 16 à la maîtrise de immigration and the condition December 2005 on Asylum Act l’immigration, au séjour Gesetz über die of third country nationals' International Foreigners (LEtr) des étrangers en France allgemeine Freizügigkeit Protection Act – Nationality Act et à la nationalité von Unionsbürgern Law 189, 26 August 2002 - 2012 Ordinance of 22 May (Freizügigkeitsgesetz/EU) 'Modification of immigration 2002 on the gradual Equal treatment Act Loi n°2005-32 du 18 and asylum norms' Decree on the introduction of the free KeyLegislation janvier 2005 de Gesetz über die Integration of movement of persons Migration Affairs - programmation pour la Angelegenheiten der Legislative Decree 8.1.2007, Foreigners – 2012 between the Swiss Public Employment cohésion sociale Vertriebenen und no. 3, 'Transposition of the Confederation and the Service (chapitre V) Flüchtlinge Directive 2003/109/CE (Bundesvertriebenengese concerning the status of European Union and its Aliens Police Act Loi n°2006-911 du 24 tz) third-country nationals who member states and the juillet 2006 relative à are long-term residents' member states of the European Free Trade

l’immigration et à Gesetz über die Association (Ordinance l’intégration Feststellung der Legislative Decree 8.1.2007, on the introduction of Gleichwertigkeit von no. 5, 'Transposition of the the free movement of Loi n° 2007-1631 du 20 Berufsqualifikationen (Ane directive 2003/86CE on the persons, OLCP) novembre 2007 relative rkennungsgesetz) right to family reunification' Asylum Act of 26 June à la maîtrise de l'immigration, à Verordnung über die Directive on foreign minors’ 1998 (LAsi) l'intégration et à l'asile Durchführung von asylum seekers Loi no 2011-672 du 16 Integrationskursen für juin 2011 relative à Ausländer und Minister of Foreign Affairs l’immigration, à Spätaussiedler Decree - May 11th, 2011. l’intégration et à la Definition of the types of nationalité Staatsangehörigkeitsgese entry visas and the tz requirements for obtaining them (non-EU foreigners) Verordnung über die Beschäftigung von Integration Agreement Ausländerinnen und Ausländern Destination Italy (decree no 145/2013). In the framework Ausländerzentralregisterg of a new legislative decree esetz (AZRG) (no. 145/2013), there is a section dedicated both to Einbürgerungstestverordn facilitating the entry of highly- ung (EinbTestV) skilled foreigners and the tertiary education of foreign students

Source: Eurac Research, Institute for Regional Development, based on EWSI (European Web Site on Integration) .

Annex II – Timeline of the EU framework for migrant integration

Figure 3: Timeline of the EU framework for migrant integration (European Court of Auditors 2018, p. 40).

Annex III – Survey tool for regulatory environment analysis

Title of the document (in original and English translation): Date of issue: Scope (national, regional, local): Source of the document (name of the organisation issued, and www.link):

Main contents:

Please provide a brief summary of the provisions of the policy document.

What impact does/did it have on carrying out the pilot activity (e.g. is it favouring the pilot activity? Is it hindering? Why?) and in the region? (1 paragraph):

Item to be evaluated: Main content and innovative aspects

Please include here the main provisions and activities regarding integration and efficient solutions or approach to be found in the policy, e.g. support of existing networks or cooperation, creation of new institutions, creation of new governance arrangements, e.g. with civil society actors or other actors not yet considered by policies.