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5Th REPORT on ECONOMIC and SOCIAL COHESION - EUROPEAN COMMISSION CONSULTATION

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5Th REPORT on ECONOMIC and SOCIAL COHESION - EUROPEAN COMMISSION CONSULTATION 5th REPORT ON ECONOMIC AND SOCIAL COHESION - EUROPEAN COMMISSION CONSULTATION RESPONSE BY EAST DUNBARTONSHIRE COUNCIL This consultation response by East Dunbartonshire Council complements the responses submitted under separate cover by the Industrial Communities Alliance Scotland (ICAS) and the West of Scotland European Forum (WOSEF). East Dunbartonshire Council supports the general views expressed by WOSEF and the ICAS in their consultation responses. In addition we welcome the opportunity to submit our own response to this report. Background East Dunbartonshire lies to the north of Glasgow, bounded by the Campsie Fells and the Kilpatrick Hills. It is a strategically significant location for economic, social and environmental development between the city and the gateway to the Highlands, through the West Highland Way and eastwards through the Kelvin Valley. It has a population of around 110,000 and comprises the suburban and rural towns and villages of Bearsden, Bishopbriggs, Kirkintilloch, Lennoxtown, Lenzie, Milngavie, Milton of Campsie, Torrance and Twechar. East Dunbartonshire Council (EDC) has benefited from European Structural Funds for many years and is at this time, running projects within the current European Structural Funds Programme (2007-2013). KEY MESSAGE RESPONSE Targeting of funds needs to be more effective. As Scottish structural fund allocations continue to decrease, it becomes more important that funds are geographically targeted effectively to those areas most in need. Due to the current climate, EDC faces continuing problems of economic adjustment and regeneration. As a council, we would like to stress the need for change within the evaluation process for spatial targeting. Many areas of Scotland are not eligible for a large proportion of Structural Funds, which in today’s climate is where most, if not all of our external funding comes from for regeneration & development activity. In East Dunbartonshire we have a mix of very affluent and very deprived areas and due to the generalisation of eligibility indicators our deprived areas are suffering, mainly because they are surrounded by larger, more affluent areas. The use of one indicator at one large spatial level leads to the possibility of areas with significant socio-economic deprivation losing out. In the event of a reduced budget in Structural funds post 2013, it is likely that the wider spread of funds will lead to even less effective targeting. EDC supports the view that the role of identifying target areas should be devolved to Member State governments, working in collaboration with regional and local authorities. The European Commission should consider devolving responsibility to those Member States who have significant experience in administering Structural Funds. In particular, responsibility for identifying appropriate geographic target areas and the range of activities to be supported within them. A simplification agenda on issues such as audit requirements and document retention periods is very much needed. The administrative side of structural funds is becoming so burdensome and time consuming for local authority staff that for some projects, it is almost not worth while. This is especially true if you are lead on a project with various partners. This issue has a great effect on the “buy in” to structural funds and I expect it will play a large part when considering any possible future bids. A systems based approach to audit procedures should be taken, which would focus on major, high risk elements of expenditure instead of repeated checks of items such as public sector payroll, which is extremely time consuming. Many of the problems which result from audit procedures relate to the interpretation of regulations and national rules. Constant claim item eligibility changes and retrospective guidance changes are also major issues which seriously impact on programmes and cause frustration for local authorities. Guidance notes need to be made publicly available at an early stage in the programming process in order to develop national rules that are readily understood and can work in an operational context. Stronger thematic concentration on the Europe 2020 priorities can only be achieved if the priorities relate to the needs of the region and the resources available. Having too many objectives/priorities will dilute the impact of the programme. Member States and regions, in close consultation with local partners, should be given the flexibility to determine the balance between actions under the three main headings of the EU 2020 strategy (smarter, more sustainable and more inclusive). The partnership principle needs to be evident at all stages of the process for it to work, from preparation through to evaluation. When the partnership principle is not introduced early on, it can cause major problems later. Local development and management of structural funds should be at the heart of the post 2013 programme. Scotland has had a lot of success in delivering projects through local development approaches (i.e. LEADER, Community Planning Partnerships etc.) Structural funds should be based on or at least try to initiate a “bottom up” approach in order to reflect the needs of the region. EDC supports the principles of local development and management of structural fund programmes as advocated by the Convention of Local Authorities (COSLA). Conclusions Decreasing EU Structural Funds means Member States need to be more aware of the needs of their regions and be allowed to become more involved in the design and implementation of programmes. Just as Managing Authorities can no longer continue to work in isolation, they must engage with stakeholders from the very beginning in order to fully reflect the needs of the regions. There is strong evidence for the argument that retargeting of funds towards areas in most need is required in the next Programming period. The role of identifying target areas should be devolved to Member State governments, working in collaboration with regional and local authorities. In addition, the use of one indicator (GDP per head) at one spatial level (NUTS level 2) to identify areas qualifying for the highest levels of cohesion policy funding is flawed and leads to areas with substantial deprivation missing out. Introducing more flexibility with regards to the types of interventions eligible for support, determined at a local level, would allow the introduction of more locally responsive and effective approaches. Structural funds represent the only EU funding stream that can support many aspects of regeneration activity and it is these activities that should be prioritised in future programmes. We would also stress the importance of the simplification agenda. If major changes are not delivered on, the programme may suffer as many may view the administrative obligations as too strenuous and not worth while in comparison with the value of the project. FT January 2010 .
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