The Common Guidance on CLLD from the Commission: a commentary
by Robert Lukesch, ÖAR Regionalberatung GmbH
On January 30th, the Commission published the Common Guidance of the European Commission Directorates-General AGRI, EMPL, MARE and REGIO on Community-Led Local Development in European Structural and Investment Funds. This release was followed by a seminar on February 6, organized by DG Regio, for managing authorities and a small circle of experts. Until today, the Guidance is still a draft as its definite version will only be published after adoption of the related legal acts.
The guidance has been waited for a long time… the first rumours that such guidance would “soon” be published date back to spring 2012. However in a number of Member States the course has already been set concerning the choice of whether or not integrating CLLD into the menu of Structural Funds-related instruments into their national or regional operational programs.
Running a CLLD component under EAFRD programs will continue to be obligatory (with at least 5% of funds), and there are also strong signs of an enhanced continuation within the framework of the EMFF. The uptake in ERDF and ESF OPs are the great unknown hitherto, and it was a major purpose of the Guidance, together with the seminar, to overcome some of the scepticism which persists among managing authorities to adopt CLLD as an instrument to support sub-regional partnerships in implementing territorial development strategies independently.
To say in advance, the Common Guidance has been elaborated with diligence, making the case for CLLD from the perspectives of all four funds involved (chapter 2). At the same time it cannot dispel many fears which have echoed from different sides since the idea has been launched in the draft CSF Regulation in the fall of 2011.
The Common Guidance is convincing in the methodological parts, for example while explaining the key building blocks: the strategy, the partnership and a coherent territory (chapter 3), as well as in the last three chapters (7, 8 and 9) where it relates to the selection of local action groups, the kind of development projects and functional costs which can be supported from CLLD, and monitoring and evaluation issues. There are also annexes which summarize important distinctions relevant to the different CSF funds (co-funding rates, principles of support, and presents exemplary selection criteria for LAGs).
The Guidance Paper’s weaknesses loom in chapters 5 and 6 where the implementation options (one fund or joint funding) and the design of coordination mechanisms are discussed. On the one hand, the various case examples from LD approaches (funded from LEADER, EFMM, ESF and ERDF) are inspiring. However, the guidance relating to governance and implementation mechanisms for CLLD in Structural Funds is visibly suffering from the lack of precedence. This finding mainly concerns issues of funding and coordination. Ultimately the text remains at the level of superficial encouragement: “The most powerful and advantageous form of cooperation is the option of joint funding…” (p. 15)…”It is desirable that Member States design the most flexible and comprehensive framework possible…” (p. 19)…”Mechanisms that envisage simplified procedures for small projects and reduce the administrative burden in the early stages of project approval may help to encourage potential beneficiaries…” (p. 33)…”The lead Fund option is a tool to simplify the management of jointly funded strategies….” (p.36). However when it comes to concrete advice, the paper is silent.
To put forth an example: The document does not explain how the simplified cost option can be effectively used to facilitate CLLD implementation. The SCO is recommended three times in the whole document, but nowhere a practical hint is given how that could be done.
In a seminar on rural development programming for 2014-2020 in Germany, some participants from German Länder raised doubts about the consequences of the integrative approach of partnership agreement. They argue that it looks more a novelty than it would turn out to be in practice. First, the policy silos hosting the different funds would be so deeply divided in terms of delivery mechanisms, monitoring and accounting rules, let alone the administrative “cultures” which have evolved over time, that the operations under each fund would have to be managed separately anyway. Secondly, coordination between funds at the level of intermediate bodies and “on the ground” would not constitute any new requirement, as it had been daily business in the past and would continue to be so. Public officials are risk averse, and when they extrapolate the rising complexity curve of the last twenty years into the near future, they have little hope that the cited “administrative burden” would give way to “simplified procedures” which would endure enhanced audit rules.
These are not the limitations of those who wrote the Guidance, these are the limitations of the paper itself. The delivery systems and implementing mechanisms of Structural Funds are so different in the EU27 that the Guidance Paper cannot go more into detail. The text would automatically become irrelevant for a majority of potential future users. What the paper does on several occasions is to emphasize how important it is to delegate decision making to the LAGs, to give autonomy and to cede strategic ownership to the local partners. This would make things easier under the circumstances that all the involved actors, starting with the LAG stakeholders, but also the administrative officials are endowed with the according capacities. Knowing that giving away power of decision making is not something central administrations are really hot for, this plea rather sounds as a caveat than an encouragement for newcomers.
I think the Common Guidance will not convince sceptics, but it will help the ones who are already preparing for cruising through unknown waters. Not surprisingly, among these we find administrations which have a history with similar schemes und ERDF and ESF in the past (Scotland, Brandenburg…). Their threshold of risk taking seems to be considerably lower.
Paradoxically or not, the slow infiltration of CLLD into the bastions of European Structural Funds could actually turn out as a blessing. I guess that those national and regional administrations really going for it will do so wholeheartedly, mobilize the required human and organizational capacities and act with prudence. They will be well aware of the imponderables. Their pioneering work will contribute to generating novel approaches which will create ripples across Europe. Ultimately the approach will speak for itself.
This first wave eventually will bring forth a European CLLD model transcending the limits of LEADER and other LD approaches experienced hitherto, reaching up to larger scales by 2020.