1.  DRAFT CEMR Response to the Consultation on the EU Budget Review Communication (COM (2010) 700 final)    Brussels, December 2010

2. Background 1
On 19 October 2010, the European Commission published its Communication on the EU Budget Review.
The Communication presents ideas for discussion on the future EU financial framework.
It concentrates on the political priorities and does not contain any figure, aiming at discussing the thematic priorities before looking into the allocation of funding.
Other relevant documents in the debate on the future EU financial framework:
Europe 2020 Strategy (adopted in May)
5th Cohesion Report (adopted on 10th November)
Communication on the future of the Common Agricultural Policy (adopted on 18th November)
Commission’s Work Programme 2011 (adopted on 27th October)

3. Background 2
The Commission wants the budget to mirror the EU’s core policy priorities and mainly help to deliver the Europe 2020 Strategy.
Further principles should be flexibility, conditionality, payment based on results and simplification.
Cohesion policy is considered to implement the Europe 2020 Strategy.

4. Background 3
The Commission also proposes own resources and a 10 year period with a substantial mid-term review (“5 + 5”)
Simplification proposals include:
a common implementation framework for the funds
lighter procedures for smaller grants and more use of lump sums

5. Background 4 Time frame:
Council and European Parliament will discuss and comment the Budget Review
Council conclusions by the end of the year
European Parliament: SURE Committee report by May 2011, for adoption in June
Commission will present its proposal for the Multiannual financial framework in June 2011
Second half 2011: legislative proposals for the policies and programmes beyond 2013

6. Key message 1: Prominent involvement of LRA in budget debate
Local and regional authorities are strongly affected by the economic and financial decisions taken at national and European level.
Therefore it is crucial that their views are taken into consideration in the further debate.

7. Key message 2: Mandatory partnership including local level
CEMR welcomes that the Commission proposes partnership contracts.
The partnership principle should be mandatory and include the local level:
partnership between the European, national, regional and local level is required in order to design, decide and implement policies.

8. Key message 3: Quality, development and sustainability as EU priorities
We question the statement that
growth, competitiveness and the Single Market should be the EU’s overarching priorities.
CEMR believes that one of the reasons for the recent economic and financial crisis was the concentration on profit, growth, productivity and quantity.
We suggest to reconsider these priorities and to replace growth with development and quantity with quality.

9. Key message 4: A budget for sustainability and sustainability of the budget
The sustainability concept should not only apply to the policy content, but also to the budget itself: a budget for sustainability and sustainability of the budget.

10. Key message 5: Cohesion is an EU objective and a policy in its own right
The Europe 2020 Strategy covers only some goals of the European Union.
Territorial, economic and social cohesion for example, is an objective of the EU and enshrined in the Treaty.
Therefore cohesion policy and the Structural Funds cannot just become instruments to implement the Europe 2020 Strategy.

11. Key message 6: Against macroeconomic conditionality
The Commission raises the question of macroeconomic conditionality, proposing that
the receipt of EU funds could be used to reinforce both preventative and corrective measures to support the Stability and Growth Pact.
CEMR is strongly opposed to such an approach.
Within cohesion policy, CEMR supports result oriented conditionality for the Structural Funds under certain clearly defined circumstances: a) the conditionality has to be limited to cohesion policy, thus on the fulfilment of specific cohesion policy aims for a specific region by a specific region; b) only if these latter have been jointly agreed upon by all governmental levels with the obligatory involvement of local and regional authorities

12. Key message 7: A strong Common Strategic Framework
A Common Strategic Framework (CSF), as proposes in the Communication, would be a very important step to increase effectiveness and efficiency of EU-funded programmes.
The new CFS should effectively become a general regulation including concrete implementing provisions (like eligible costs, financial issues, audit).
The specific regulations for each fund should deal only with unavoidable implementing measures that are specific for a given fund.