Amml216000
Rufus Rottenberg
Regional European Funds Directorate
Department of Trade and Industry
Bay 1122
1 Victoria Street
London
SW1H 0ET
telephone
: 01851-709270
e-mail
: dmckim@cne-siar.gov.uk
fax
: 01851-706022
writer
: Derek McKim
our reference
: AMM/ESFP10
your reference
:
Date
: 22 May 2006
Rufus Rottenberg Chòir
DTi's DRAFT NATIONAL STRATEGIC REFERENCE FRAMEWORK:
EU STRUCTURAL FUNDS PROGRAMMES 2007-2013
On behalf of Comhairle nan Eilean, I should like to thank you for giving this Authority
the opportunity to respond to the above consultation.
The Comhairle has responded to those questions in the consultation that it feels are
of the most specific relevance to the Western Isles and these comments are outlined
in the Appendix of this letter. I trust that these comments are useful to you in
informing the final outcome of your deliberations with regard to the new EU Structural
Funds programmes 2007-2013.
In the meantime, should you require further information or clarification on the
Comhairle’s response, please contact me at the above telephone number or Angus
Murray (External Strategy): angus-murray@cne-siar.gov.uk.
Leis gach dùrachd
Derek McKim
Head of Strategy (External)
Chief Executive’s Office
Ag Obair Còmhla airson nan Eilean
COMHAIRLE NAN EILEAN SIAR
Working Together for the Western Isles
Q1
Do respondents agree with the assessment of the draft national strategic
reference framework of the economic strengths and weaknesses of the
UK’s nations and regions?
Taking due account of the necessarily synoptic nature of the framework, the
Comhairle agrees in general with the assessment of Scotland’s economic
strengths and weakness, and is especially pleased with the emphasis on
rurality and the aspirations of “A Rural Scotland: a new approach.” Overall,
however, there is not enough emphasis on the economic strengths and
weaknesses of the Highlands and Islands, a ‘statistical effect’ region, as
compared to other regions in Scotland.
A further aspect of concern is that while the Highlands and Islands ERDF and
ESF draft proposals are closely aligned to Scottish strategies and priorities,
these do not appear to take due or full cognisance of regional or local
strategies. The Comhairle's apprehension is that an ostensibly “top down“
approach has not been fully consultative at the regional level.
Regional strategies and local plans are arguably more able to identify and
address the social and economic difficulties specific to a region. It is especially
important to recognise that there are disparities between regions and within
regions, e.g., the Western Isles within the wider Highlands and islands. The
point is that certain relatively wealthy regions can have social and economic
black spots for reasons of geographical handicap: rurality, peripherality,
economic fragility and sparsity of population. For the period 2007-2013 it is
vital that ERDF and ESF resources are targeted at these areas which need it
most. One of the strengths of EU funds in the past has been that due to local
regional strategic involvement they have targeted and addressed the structural
problems of areas most in need.
In the Western Isles, the hope and expectation would be that the aspirations of
social and economic regeneration using EU structural funds, could be
completed logically and successfully under the new EU programme 20072013.
Q2
Do respondents agree with the proposed priorities for future
convergence and competitiveness programmes in England, Scotland,
Wales Northern Ireland and Gibraltar?
The Comhairle notes that while the Highlands and Islands region will continue
to qualify for “phasing out” Convergence funding as a “Statistical Effect” region
2007-2013, the budgetary deal agreed by the Council of Ministers in
Ag Obair Còmhla airson nan Eilean
COMHAIRLE NAN EILEAN SIAR
Isles
Working Together for the Western
December 2005 proposes that less funding will be made available to
“statistical effect” regions where less than 30% of the national population is
eligible for Objective 1 funding. This would apply to the Highlands and Islands
which is the only convergence region in Scotland, and the Comhairle and
partners have been lobbying MEPs on this ruling, seeking equitable treatment
in terms of eligibility funding for all “statistical effect” regions, irrespective of the
population eligible for Objective 1 funding in the country concerned.
The draft priorities for the Highlands and Islands (ERDF) are Enterprise
Sustainability; Economic and Environment Infrastructure Sustainability; and,
Community Sustainability The three draft priorities (ESF) are Supporting
Progress towards Sustained Employment for All; Supporting Progress through
Employment; and, Investing in the Employability and Lifelong Learning
Environment
The priorities for the Highlands and Islands should reflect the Region’s current
economic and social issues:
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We are still a low wage economy and poor in high value skills.
Parts of the region are poorly connected to regional and UK growth
points.
We have significant number of excluded people.
We still have some poorly performing sub regional areas whilst having
some of the fastest growing parts of Scotland.
Our most remote communities continue to have outdated infrastructure
and poor services.
It is the Comhairle’s view that the new Programmes should focus on
enterprise, innovation and sustainability and should be delivered through
single priorities for ERDF and ESF. In part this is based on experience of
delivery of EU programmes over many years.
People and communities are our biggest strength and in order to raise their
income levels the Programmes should concentrate ESF resources on skills
development, lifelong learning and adaptability with ERDF assisting where
training infrastructure is required.
The Programmes should focus on emerging sectors which require skilled
people and new infrastructure, and also on innovation.
The Programmes should be geographically targeted to those areas which are
experiencing most difficulty in catching up.
The Programmes should target clusters of projects (geographically or topics)
which can deliver “added value”.
Ag Obair Còmhla airson nan Eilean
COMHAIRLE NAN EILEAN SIAR
Isles
Working Together for the Western
Improved connectivity both by traditional transport modes and broadband is
vital for business efficiency. The Programmes must address this with partners,
but funds should not be diluted by using assistance, for example, for the big
infrastructure and education projects which could be delivered under the
national and regional programmes of roads and other agencies.
The Programmes should set out what local partners want to fund and what can
be afforded. Equally Programmes should be clear on what will not be funded,
alternative funding streams being identified to support these other actions.
Q3
Do respondents agree that the proposed priorities include a sufficient
focus on the Lisbon agenda?
The Lisbon Agenda, relaunched in February 2005, seeks to achieve “higher
economic growth…job creation and competitiveness in World markets” and
while regions might often feel somewhat remote from centralised decision
making, there are areas within the draft ERDF and ESF (EAFRD &EFF)
priorities which are consistent with and contribute to the achievement of the
Lisbon Agenda’s objectives, e.g., entrepreneurship, innovation, R&D, new
technology (ICT), sustainable use of resources and rural development. The
Commission has placed great emphasis on the role of rural development in
regions’ long-term social, economic and environmental sustainability. On
balance therefore it is accepted that the Lisbon Agenda will determine the
primary focus of the Programme. However, this should still allow the actual
mix of activities to be determined “bottom-up” rather than “top-down”.
While the draft ERDF and ESF for the Highlands and Islands are closely
aligned to EU and national strategies and policies it remains to be seen
whether their implementation at regional and local level can address its
specific problems. There has to be a realisation that the distribution of EU
funds needs to go to areas most in need, and the Comhairle would hope that
there would be sufficient flexibility within the broad Priorities and sub-key
objectives of the Programmes to enable regions to target the funds and
maximise the benefit.
Q4
Do respondents agree with the proposals in the National Strategic
Reference Framework for ensuring consistency between Structural
Funds programmes and other EU policies and funding streams, in
particular spending under the European Agricultural Fund for Rural
Development and the European Fisheries Fund?
It is proposed that the Highlands and Islands will have 4 separate EU
Programmes 2007-2013, two regional and two national. A key challenge is
integration. Agriculture and Fisheries have to address economic development
Ag Obair Còmhla airson nan Eilean
COMHAIRLE NAN EILEAN SIAR
Isles
Working Together for the Western
issues given the importance of the primary sector in the Highlands and
Islands.
The key issue at Western Isles level is the future relationship between the
Structural Funds programme, the European Agricultural Fund for Rural
Development (EAFRD) and the European Fisheries Fund (EFF). The latter two
are the subject of separate consultations, but in general, the Comhairle is
concerned that these are national programmes and as such may not be
specifically geared to or able to meet regional problems. There is possibly
less concern with the EFF which is likely to have a Highlands and Islands
dimension, under which auspices, the Western Isles would be making a strong
case for funds as appropriate, as it has done via FIFG.
Of greater concern is the EAFRD. The Comhairle’s view is that the Scottish
Rural Development Plan must take cognisance of regional issues and the key
to that is effective consultation. As with much of centralised decision making
there is the danger of a “one size fits all” approach which would reduce local
decision making and alienate communities.
A national Rural Development Plan should cover all aspects of rural
development: heritage, language and culture, leisure, recreation and tourism,
and not just land management, farming, agriculture and crofting. It is worth
noting that the Western Isles, in conjunction with the neighbouring Skye and
Lochalsh, has had a productive mechanism for delivering an integrated rural
development approach since the early 90’s via the LEADER programmes. This
has been a partnership and "bottom up" approach and one which has been
proactive and responsive in addressing specific regional problems.
Q5
Do respondents agree with the proposed architecture for future
Programmes?
The architecture and the level of funding (ERDF and ESF) of the EU
programmes in the Highlands and Islands are determined largely by the
eligibility status of the region, i.e., “statistical effect.” The Comhairle is in
agreement with the architecture proposed for ERDF and ESF in the Highlands
and Islands. As indicated above, given the importance of agriculture and
fisheries to the local economy it is considered that these merit separate
Highlands and Islands Programmes.
The Comhairle recognises that the new Programme mean a significant
reduction in funding available against previous programmes and it is keen to
ensure that these funds are spent in areas that are most in need.
Ag Obair Còmhla airson nan Eilean
COMHAIRLE NAN EILEAN SIAR
Isles
Working Together for the Western
Q9
Do respondents have views on how to improve co-ordination between
Structural Funds and domestic spending within England, Scotland,
Wales and Northern Ireland?
Although the Highlands and Islands qualify for the ERDF and ESF phasing-out
Convergence Programme rather than Competitiveness funding, it is the view
of the Comhairle that given the circumstances in the Highlands and Islands
that the current split between ERDF and ESF funding should be maintained,
i.e. approximately 80:20.
The Comhairle is of the view that there should be a direct correlation between
domestic priorities and EU Structural Funds. However, as mentioned
previously, domestic (national) priorities can be somewhat removed from
regional priorities and are not always relevant or appropriate across the board.
There are areas such as the Western Isles which have unique social and
economic difficulties and there has to be recognition of this if their aspirations
are to be met. The Structural Funds to date have been effective in this but can
only continue to be so insofar as there is national backing at (devolved)
government level.
The Comhairle is of the view that Partnerships will be key to ensuring the
success of the Programmes and not just in terms of leverage of other public
funds. However, in order to achieve objectives it will be necessary to partner
funders and in particular to influence their programmes and align investment.
It is recognised that the new Programmes need to be prescriptive and proactive, moving away from bidding arrangements to a “client-group” approach.
This will entail a variety of financing methods, such as co-financing, investment
fund, direct award, tendering, commissioning, to deliver projects.
The Comhairle would in particular be concerned about the applicability of a
series of pre-determined co-financing arrangements, which did not include it or
its partners.
Q12
Do respondents agree that greater use of single-stream funding
mechanisms would be beneficial in Scotland?
The Comhairle is supportive of a single stream funding mechanism which will
reduce bureaucracy and administration, free up and increase the amount of
funding that is available across programmes, and speed up the decision
making process which will facilitate the ease and speed with which recipients
will receive funding support.
The other key issue in respect of the design and future implementation of the
programmes is that the Comhairle would be extremely supportive of devolved
Ag Obair Còmhla airson nan Eilean
COMHAIRLE NAN EILEAN SIAR
Isles
Working Together for the Western
decision making to the local level wherever possible, in the interests of best
possible targeting of funds, less bureaucracy, more streamlining and coordination of local effort. This would not be possible with national centralised
programmes.
The Comhairle acknowledges that there will be a separate consultation issued
by the Scottish Executive on operational arrangements for the ERDF and ESF
programmes and the Comhairle will be supporting decentralisation to the local
level wherever possible.
Furthermore, the Comhairle would see scope for a key, strategic role to be
played by Community Planning Partnerships in determining and implementing
integrated development programmes.
External Strategy
Comhairle nan Eilean Siar
22 May 2006
Ag Obair Còmhla airson nan Eilean
COMHAIRLE NAN EILEAN SIAR
Isles
Working Together for the Western