WHAT ARE THE FUNDS ACHIEVING?
STATISTICAL EVIDENCE ON DISPARITIES
57. The Commission's
Cohesion Report[11]
is a valuable source of statistical evidence on the reduction
of the gaps in standards of living and economic opportunities
existing between Member States, regions and social groups. The
following paragraphs give no more than a brief outline of a few
salient features.
58. In the last ten
years the four poorest countries of the EU, the Cohesion Four,
have raised their GDP per capita from 66 per cent to 74
per cent of the EU15 average. However, averaging performance
across four countries in this way masks real differences in their
economic performance. Ireland has had the best performance with
an average growth rate of 4.5 per cent a year from 1983-95, followed
by Spain with 3 per cent and Portugal with 2.6 per cent while
the EU15 average growth rate was just over 2 per cent a year.
Commenting to us on the statistics, Commissioner Wulf-Mathies
said that the performance of the Union's four poorest countries
was "truly remarkable by any international or historic standards".
She said it was estimated that EU support had added "at
least 0.5 per cent to their end year growth rate, at the same
time creating or maintaining over 500,000 jobs between 1989 and
1993". This benefit flowed back from the Cohesion Four to
the extent that, according to Commissioner Wulf-Mathies, up to
40 per cent of the funding that goes to them returns to the other
richer Member States in the form of purchase of know-how and capital
equipment (Q 501).
59. Table 2 in Appendix
3 shows GDP per capita in Member States, in percentage
terms of the EU15 average, for 1983, 1988 and 1993. Across the
EU as a whole disparities between the best-off regions and the
worst-off regions were little changed: the 25 best-off increased
their level of average GDP per capita from 140 per cent
of the EU15 average to 142 per cent while the 25 worst-off regions'
moved from 53 per cent to 55 per cent. For Objective 1 regions,
the poorest, as a group, their average moved from 64.6 per cent
to 67.2 per cent. Table 3, in Appendix 3, represents the situation
in 1993 when, within each Member State, large regional income
disparities remained and, with the exception of the Netherlands,
had increased.
60. Commissioner Wulf-Mathies
saw unemployment as "the greatest challenge in Europe"
(Q 501). According to the Cohesion Report the unemployment
problem was most acute at the regional and local level where disparities
remained particularly acute and showed little sign of narrowing[12].
Map 1 in Appendix 3 shows unemployment rates by region in 1995
and Table 4 shows unemployment rates by Member States and regional
extremes. Commissioner Wulf-Mathies highlighted the position
of young people: 20 per cent of those under 25 were unemployed.
As to the joint responsibility of national governments and the
Community for reversing the trend of unemployment she said "Primary
responsibility falls on the policy of Member States but economic
problems less and less respect national borders and there is a
need for a European development perspective and a framework for
coordination and the exchange of views" (Q 501).
61. Asked to estimate
the number of jobs created by the EU structural funds, Commissioner
Wulf-Mathies said that estimates made by Member States and by
the Commission were that from 1994 to 1999 2.4 million jobs would
be created or secured (Q 512). She added as a caveat that it
would be difficult to prove the validity of these figures. As
to the costs involved, she pointed out that the structural policies
were enabling strategies which worked through improving the infra-structure,
competitiveness and through linking skills training to jobs available:
"jobs have to come from the enterprise and are not brought
from the EU" (Q 513). There was also a difficulty in that
the necessary statistics were not available, at least not regionally
(Q 516).
NATIONAL MACRO-ECONOMIC POLICIES
62. The Cohesion Report
makes clear that the Member States' macro-economic policies have
generally helped to strengthen cohesion. Inflation rates have
decreased, interest rates have come down and the differences in
these rates between Member States have diminished thus improving
the climate for investment and growth. Member States' own regional
policies cover some 46.7 per cent of the EU total population with
the most intense aid going to the least favoured regions, although
the richer Member States can afford to give more aid to their
poor regions than can the poorer Member States. Consequently,
national regional state aid per capita was on average much
higher in the new Länder in the east of Germany and in the
Italian Mezzogiorno than in the Cohesion Four.
63. Within this general
picture it is not easy to separate out the effects of the Structural
Funds and the Cohesion Fund from those of the national government's
other policies. In Ireland, by far the best performing economy
of the EU15 in recent years, we were told that the Irish CSF had
made a "significant" contribution: this was estimated
by government sources and by independent researchers to have added
about 1 percentage point to the average annual growth rate of
GDP.
FUNDING ISSUES
64. The European Investment
Bank (EIB) is a major source of loan funding for regional development
in the EU. Sir Brian Unwin, President of the EIB, told us that
in 1996 loans totalling about 12 billion ecu were made to the
regions. He spoke of the modulation principle[13]
under which the best combination of grants, from the Structural
Funds or the Cohesion Fund, and loans, from the EIB, was used.
He expected that in future there would be what he described as
"a more systematic combination of loans and grants"
(Q 195). He attributed some of the attraction of EIB loans to
its fine rates, which it could apply because of its triple-A status,
and to its refusal to lend without a thorough technical, financial,
economic and environmental appraisal of a project (Q 198). The
EIB did not normally make a loan for a project of less than 20-25
million ecu. It was, therefore, more involved with big projects
under the Cohesion Fund than with smaller ones under the Structural
Funds (Q 214). As to EIB support for SMEs[14],
Sir Brian explained that 15 to 20 per cent of EIB lending was
to SMEs through a line of credit to a commercial bank for that
bank to pass on to SMEs in accordance with criteria and for projects
agreed with the EIB (Q 199). Sir Alastair Morton, formerly
Co-Chairman of Eurotunnel plc, commenting on EIB practice, described
them as "an institution concerned with their triple-A status
rather than a development bank which they are not" (Q 328).
65. As to involvement
with Northern Ireland, Sir Brian said the EIB had played a major
part in the peace initiative by lending to SMEs in Northern Ireland
and the six border counties (Q 221). A crucial factor here was
that the British government, the Irish government and the European
Commission had jointly funded a 4 percentage point interest rate
subsidy on the EIB loans (Q 229).
66. As to the enlargement
of the EU, Sir Brian Unwin said that the EIB was already lending
about 1 billion ecu a year in eleven countries of central and
eastern Europe. The EIB was concentrating on the Visegrad countries
(the Czech Republic, Hungary, Poland and Slovakia) and would probably
be contemplating a pre-accession facility of the kind that existed
before the entry of Greece, Portugal and Spain. The EIB was "amassing
a good deal of knowledge of [the CEECs] and their banking systems"
(Q 207). Asked about EIB's relationship with the European
Bank for Regional Development (EBRD) in the CEECs, Sir Brian pointed
out that the EBRD had a different remit: sixty per cent of its
activity by statute had to be in the private sector. The EBRD
concentrated on the private sector, small projects and the development
of the banking systems in the CEECs. He said that the EIB worked
very closely with the EBRD (Q 208). Looking ahead, Sir Brian
saw a continuing large need for basic infrastructure investment
in Spain, Portugal and Greece and southern Italy and in new Member
States following enlargement where enormous environmental improvements
were necessary. In more developed countries there was a shift
to a greater involvement of private investment (Q 235).
67. The Court of Auditors
annual report for 1995[15]
called for caution in using grants for projects with a high direct
profitability and commented that the Commission did not appear
to pay sufficient attention to the expected internal financial
rate of return when deciding on the amount of grant to be provided.[16]
In their response the Commission pointed out the rate of return
was only one of the factors to be taken into account. "Grants
for industrial projects may actually be necessary in regions lagging
behind in order to attract investors who without grants from the
regions would go elsewhere".[17]
68. State aids, that
is subsidies which favour assisted companies at the expense of
their unassisted competitors, raise difficult policy issues.
On the one hand, they are seen by Member States as a vital instrument
of national regional policy, and thus of their national efforts
to promote cohesion. On the other hand, and given the scale of
such aids in some countries, they can easily subvert the aims
of the EU's cohesion policies. Surveys conducted by the Commission
have shown that state aids continue to be extensively used by
Member States and we are aware from our evidence of the deleterious
effects of state aids offered in some regions on companies elsewhere.
Sir Brian Moffat, chairman of British Steel plc, referred to
the case of Irish Steel where the payment of state aids of over
£30 million to an unprofitable company had prejudiced the
market of British Steel which, consequently, had had to announce
redundancies in its United Kingdom works (QQ 147-148).
ADMINISTRATIVE WEAKNESSES
69. The major complaints
from our witnesses concerned the over-bureaucratic processes of
the system and the inordinate delays which resulted. Delays affected
approval decisions and payment of funds. There was a strong sense
of frustration at the procedures involved in setting up programmes,
in selecting projects, in monitoring progress, in reporting back
and in making payments to final beneficiaries. Complexity was
endemic and, all too often, there was inconsistency between responses,
so that one part of the machine would say "yes" while
another part of the same machine would say "no" (p 205).
A few examples will suffice to indicate a depressingly general
picture.
70. At national level
new programmes were late in being agreed between the Government
and the Commission, as already noted in paragraph 38 above. At
more local levels, there were difficulties in demonstrating that
the criteria of more than one fund, say ERDF and ESF, were satisfied
and in obtaining cash at the time needed from these funds and
from the suppliers of matching funding. Projects, long agreed
by all concerned, experienced delays in receiving cash so that
they were forced to borrow money and incur interest charges.
This caused particularly severe problems for small NGOs with little
or no other cash-flow. The Commission was generally confident
that once a programme was agreed it was prompt in paying out to
the national government. Delay thereafter could benefit the national
government in that it would retain interest earned on the cash
held (Q 523).
71. The Court of Auditors'
report for the financial year 1995 comments on the failure by
national governments, within the maximum period of three months
set by Council Regulation[18],
to pay out to final beneficiaries funds received from the Commission.
The report mentions that this deadline was not respected in Spain
in 31 per cent of cases and in Italy in 72 per cent of cases.
The report also mentions a case in Germany where seven and a
half months after receipt of a first advance payment only 50 per
cent had been paid out to the promoters. Our impressions of the
situation in Ireland were that, where the paperwork was in order,
payment was received by the national authorities from the Commission
within a few weeks and was then passed on to the final recipients
within a few days. This compared very favourably with our evidence
on the situation in this country. Commissioner Wulf-Mathies also
told us that she wanted to encourage the United Kingdom Government
"to make payments in advance rather than in arrears for projects,
for instance, by community organisations" (Q 523).
72. One aspect of the
Structural Funds which attracted particular criticism for the
level of bureaucracy entailed was the CIs[19].
The Court of Auditors most recent report, covering the financial
year 1995, commented that a large number of areas eligible for
CIs had been established: this had led to fragmentation with a
consequent loss of effectiveness of the aid measures[20].
In the opinion of the DTI "the complexity of the administration
of the administration of these funds really does outweigh the
benefit from having the special extra assistance that is available
under them" (Q 13). The Commission, however, was strongly
in favour of retaining CIs. Commissioner Flynn spoke of their
special value in promoting innovation and in disseminating good
practice across the EU. He spoke particularly of the usefulness
of NOW, HORIZON, YOUTHSTART and INTEGRA-all CIs concerned with
new opportunities for employment. He thought the United Kingdom's
experience in dissemination had been one of the most effective
throughout the Union (Q 498). Commissioner Wulf-Mathies saw room
for improvement and looked for "reducing the number of CIs
while keeping the experimental, innovative and very often bottom
up approaches which have been most successful" (Q 501).
73. All of our witnesses
agreed that there was need for accountability, probity and transparency
in the use of what was recognised to be European tax-payers' money.
The required level of careful accounting was acceptable to all.
Commissioner Flynn commented that the Court of Auditors in their
1995 report had not found any evidence of widespread fraud or
irregularity (Q 463). Mr Lang, speaking of the situation in the
United Kingdom said, "I am not aware of any significant fraud
or any evidence thereof" (Q 579).
PSYCHOLOGICAL EFFECTS
74. The existence of
the structural funds has had important effects on the mechanisms
for regional and local cooperation. Some of these were noted
in paragraphs 39-42 above. We now turn to consider the psychological
and morale effects of the new structures. The process of devising,
implementing and monitoring regional programmes has led not only
to the establishment of programme Monitoring Committees, but,
in Scotland, to equipping them with independent secretariats thus
increasing the sense of participation of the non-governmental
partners. Administration of the Structural Funds and the Cohesion
Fund has intensified consultation between national governments
and lower tier authorities in a variety of ways. This phenomenon
is not peculiar to the United Kingdom. In Ireland we found that
the role of regional and local authorities was under consideration
in a way which had been stimulated by the process of handling
EU structural funds. In Greece, too, there were signs of some
decentralisation of government structures, again partly, we suspect,
as a response to the same pressures.
75. In our visits we
repeatedly noted the positive morale effects which derive from
a sense of participation and increased local control. These intangible,
but nonetheless valuable, effects were visible at many levels:
at the level of an individual, who was long term unemployed and
who was obtaining from a training programme the confidence to
seek to reenter the employment market, as well at the level of
local organisations, which might otherwise see themselves as rivals
(these could be chambers of commerce, or TECs or Business Links
or voluntary bodies), who are constrained to cooperate and to
work together in partnerships and on Monitoring Committees by
the wish to benefit from EU funds.
Opinion: economic achievements
76. Any attempt to
quantify and allocate responsibility for outcomes between national
policy and EU structural policy is difficult and to some extent
artificial: national policy may well have been influenced by the
opportunity to take up EU funds. The policies, EU and national
as influenced by the EU, are likely to be synergistic, as they
are intended to be. The excellent performance of the Irish economy
in recent years must be attributed to a number of causes as well
as to the substantial injection of EU funds. We think these include
the national government's sound macro-economic policies; its emphasis
on human resource development and improved labour relations policies
involving the social partners; its inward investment policies;
and, importantly, the high quality of the public administration
of the country. The Greek government ministers whom we met were
frank in acknowledging that the country lacked until recently
a history of prudent management of the national economy and that
the Greek civil service needed strengthening in capacity and quality.
Put simply, our conclusion is that the effect of a given amount
of EU funding for cohesion purposes flowing into a Member State
will be determined principally by the macro-economic and human
capital development policies and by the competence in public administration
of the receiving country.
77. We suggest that
there is a lesson here for other Member States and potential Member
States: the competence and probity of the civil administration
need to be given a high priority by countries without this tradition.
We have in mind particularly some of the CEECs seeking to join
the EU and who are still adjusting to the norms and civil institutions
required in democratic market economies.
78. Despite logical
and methodological difficulties in discriminating between the
effects of national and EU policies and funds, we wish to make
some general, and necessarily partly political, assessment of
the EU cohesion policies. These policies address issues of major
importance to the citizens of the EU: there can be little more
important for the poor, (whether they are countries, regions or
smaller communities), than having jobs which provide a decent
quality of life and a sense of opportunity for improvement. It
is a treaty commitment for the EU to pursue such policies. So
far, the EU's cohesion policies have had marked and beneficial
effects for the poorest countries but regional disparities within
and between Member States remain unacceptably large. At the national
level, if conditions in the receiving country are favourable,
the funds can achieve an important economic effect.
Opinion: funding issues
79. The EIB has an
impressive record based, in part, on its facility for making economic,
technical and environmental assessments. The EIB must strike
the right balance between legitimate caution and the inherent
risks in meeting obvious needs. For the future it will be even
more important that the best possible combinations of loans and
grants are employed and that the rate of return from a project
is given due weight. In the CEECs the EIB needs to work constructively
with the EBRD and other banks in and out of region to develop
the most productive and innovative financing mechanisms.
80. We recognise
that governments will always face pressures to grant subsidies
and that these can, on occasion, be a valid means of promoting
economic development in less-favoured areas. Nevertheless, we
believe that such measures should be used sparingly, and call
on the Government to exert its influence within the Council and
on the Commission to prevent the use of state aids which harm
enterprise in another Member State. It is our view that structural
measures should provide general support for a regional economy,
rather than directly favouring individual enterprises.
81. We have been
struck by the evident differences between regions in the impact
of structural measures. In part, this can be attributed to the
extent to which additional private sector investment can be induced
by outlays of public money through either the Structural Funds
or the Cohesion Fund. Plainly, the more `leverage' of private
investment, the more likely it is that economic development objectives
will be achieved and it is our impression that this dimension
of structural policy is not given sufficient weight in some of
the schemes and measures currently supported.
82. However, we recognise
that the problems confronting regions differ substantially, with
the result that the opportunities for private sector involvement
will vary. In some regions, the need for major physical infrastructure
development remains paramount, and the scope for private investment
is limited, although recent practice of bringing-in private sector
project management appears to have had valuable benefits, as we
saw in Greece. We also recognise that in areas of severe social
deprivation, there can be advantages in engendering a culture
of work and self-help where that has previously been lacking.
Elsewhere, our impression is that greater efforts could be made
to bring in market discipline and to chart a course by which private
sector involvement is enhanced, and we urge all the partners involved
in structural policies to explore options for doing so.
Opinion: psychological effects
83. The structural
funds often act as a catalyst, speeding a reaction. We certainly
see the effects as catalytic but also as going wider. There is
a magnifying effect from levering in other funds. But we now
focus on the effects of bringing together disparate regional and
local organisations not otherwise working together; and, of constraining
existing centres of power to consult and involve those who have
previously been comparatively peripheral, either politically or
geographically.
84. The moves which
we noted above in Greece, Ireland and the United Kingdom, the
three Member States in which we made visits, for some devolution
of decision-making in relation to the operation of the structural
funds to bodies outside the normal national power centres cannot
be said to be either substantial or irreversible. However, they
are consistent with a wide-spread demand, not confined to the
Member States of the EU15, for greater local and regional autonomy.
The EU's structural policies by their nature require the existence
of regional and local machinery for consultation. To take examples
from our own experience in making our visits in the course of
this enquiry, we would say that the Scots like and benefit from
the delegation of some decision-making from Whitehall to the Scottish
Office; the Cornish, who lack even a level of local influence
comparable to that in Scotland, welcome the influence of the Commission
partly as a counterweight to the highly centralised national government
Whitehall machine, which is perceived, fairly or unfairly, as
lacking in local understanding or concern.
85. It does, of
course, suit the Commission to gain credit for locally popular
actions, but we do not see the existence of new centres of power
outside the existing national bodies as detrimental to the citizen.
On the contrary, we welcome the development of structures, whether
national or EU in origin, which bring government closer to the
citizen, whether intentionally or not. We believe that, with
reasonable good will, these structures can work together for the
common good and produce results more beneficial than could be
achieved without them. This desirable outcome will only come
about if national and EU bodies and the new devolved bodies see
each other as politically legitimate partners and not as adversaries.
We are sure that where there are mutual suspicions and "turf
wars" it is the citizen who suffers.
86. Strategy should
not be imposed from the "top-down": that way lie authoritarianism
and local alienation. Equally, strategy should not be devised
only from the "bottom-up": that way lie fragmentation
and incoherence. Programmes must be the result of partnership
between national and sub-national bodies, down to local communities,
at the planning stage as well as at the implementation stage.
At present we believe that the balance, certainly at the planning
stage, lies too near the "top" with bodies geographically
and politically remote from the ground.
87. The temptation
for those with power is to use it; but cohesion, we believe, is
promoted not only by hard measurable outcomes but also by local
participation and the sense of ownership. The value of "bottom-up"
contributions to programmes was brought home to us very forcefully
in our visits. The degree of local enthusiasm, the sense of hope
for a better quality of life and the conviction that, with local
effort and national and EU support, it could be achieved, were
palpable. In the East End of Glasgow, in Looe, Cornwall, in Tallaght,
outside Dublin, and in fruit packing firms near Corinth, the strength
of this feeling was the same. There was also a common feeling
that the improvements already made and the prospects for further
improvements would not have existed without the availability of
EU support. In some cases the achievements, as yet, were modest,
at least in quantity of jobs created, and some benefits will probably
remain intangible; but the positive qualitative effect on local
morale was obvious and, we believe, its importance cannot be over-estimated.
88. We conclude that,
in addition to the economic effects already noted, the Structural
Funds and the Cohesion Fund have had important positive psychological
effects, particularly in countries, regions or communities who
have lacked self-esteem or a sense of concern from the authorities
within their own Member State.
Opinion: basis for reform
89. The administration
of the funds for supporting and implementing the cohesion policies
presents an unsatisfactory picture. We are convinced that there
is a need for radical reforms which reduce bureaucracy and delay.
We are not in favour of changes limited, for fear of disturbing
existing administrative empires, to minor tinkering. The citizens
deserve a bolder approach. The need for reform arises from recent
experience within the EU15: it is not dependent upon or driven
by the prospect of enlargement of the EU.
90. In broad terms,
the desiderata for the new arrangements are, we think, not difficult
to identify. First, there are some wide policy objectives: funding
should not be expected to continue indefinitely although benefits
already achieved must not be endangered by sudden cessation or
reduction of funding; future funding must be more closely targeted
to the most needy countries, regions and smaller pockets of deprivation;
there must be greater complementarity between the national actions
and the EU supported actions for cohesion; and programmes must
be strategic and integrated as between the development of capital
and human resources.
91. Second, there
are some administrative or process requirements of the reform:
the national government and the Commission should work, as partners
not adversaries, to steer, but not to dominate, the planning of
regional strategies and programmes which should be seen to meet
regional needs assessed on the basis of reliable regional economic
statistics; the implementation of programmes and the selection
of component projects should be devolved to the competent bodies
at sub-national level-this is not normally a task for which the
national authorities or the Commission are best equipped; at sub-national
level there must be effective mechanisms for achieving among the
many potential participating organisations consensus and solidarity
on the regional strategies adopted, thus avoiding parochialism;
administrative complexity and delay must be drastically reduced;
and there must be, built in from the outset, arrangements for
monitoring and independent evaluation to take place at a time
when lessons can be learned and applied to the next phase of the
programme.
92. Our recommended
approach to reform set out in the two preceding paragraphs can
be summarised as based on four policy principles:
-- continuity-building
on existing achievements;
-- concentration-on
the most needy;
-- complementarity-of
national and EU cohesion policies and actions; and
-- coherence-programmes
which integrate economic and social elements;
which are to be applied by processes
which embody:
-- subsidiarity
within Member States-devolution to the lowest competent level;
-- solidarity-seeking
the common good, not pursuing parochialism;
-- simplification-of
administration; and
-- scrutiny-of
performance.
93. The first
step to ensuring a prompt and well-considered start to programmes
is that the framework rules should be clear and agreed between
national governments well in advance of the formal start date
of the funding period. For the period after 1999, therefore,
the arrangements for the operation of the structural funds, must
now be agreed as soon as possible. We recommend that the Commission
should bring forward proposals for the reform of the funds as
a matter of urgency-a Green Paper issued this year would not be
too soon.
94. We recommend
that the number of structural funds should be reduced: perhaps
there should be one fund for the development of human resources
and one fund for all other structural purposes. The funds must
fit together easily from the users' point of view, avoiding compartmentalization
and a tangle of overlapping or conflicting rules on eligibility,
funding periods and monitoring and auditing requirements. We
are not persuaded that the existence in the Commission of five
or more Directorates General[21]
with a current responsibility for the operation of the funds is
a reason for retaining the present number of funds with their
separate rules for eligibility.
95. Within national
governments there are or may be a number of different Departments
currently responsible for these funds: in England DTI, DoE, MAFF
and DfEE are involved. In Scotland, the role of the Scottish
Office makes for some useful and welcome simplification of the
administration. At Member State level, we recognise that each
Member State will have its own reasons for its administrative
structures and we make no general recommendation. However, in
the United Kingdom we are sure that better coordination occurs
in Scotland than in England. Standards should be raised throughout
the United Kingdom. We should be surprised if this could be achieved
without further devolution of real autonomy to GORs which should
function as Offices for all government Departments not only those
four[22]
currently participating.
96. The present
position with regard to delays by national governments in paying
out to final beneficiaries the EC funds which governments have
already received is deplorable and most harmful to those promoters
least able to bear financial burdens. We recommend that the United
Kingdom government, and other national governments, where appropriate,
reduce to a few days rather than the present weeks or months the
time between funds being received from the Commission and being
paid out to promoters. Time targets should be set, monitored
and the results given to the Monitoring Committees concerned.
A reduction in the number of persons handling the money will
probably be required. We see no reason for a speedier process
to be more liable to financial irregularity.
97. As to CIs,
we recommend that there should a significant reduction in their
number and an elimination of CIs that address issues which could
more easily be tackled through CSFs or SPDs. If this recommendation
were acted upon CIs should be retained for their potential for
innovation and for spreading best practice between Member States.
Their duration should be limited so that after a period of trial
and evaluation CIs could be either discontinued if they had failed
or completed their work or brought into the mainstream of policy
if they had lessons of general application.
11
See footnote 2. Back
12
Page 25 of the Cohesion Report: see footnote 2. Back
13
The principle is to reduce the proportion of grant funding for
projects with better prospects of revenue generation. Back
14
Small and medium enterprises. Back
15
OJ C 340 volume 39, 12 November 1996. Back
16
Paragraph 5.50. Back
17
Response paragraph 5.52. Back
18
Article 21(5) of Council Regulation (EEC) No 2082/93. Back
19
See Appendix 3 for a full list of CIs. Back
20
OJ C 340 volume 39, 12 November 1996, paragraph 5.33. Back
21
The following Directorates-General have some responsibility: XVI-Regional
Policy and Cohesion;V-Social Affairs; VI-Agriculture; XIV-Fisheries;
II-Economic and Financial Affairs (liaison with EIB); and XIX
and XX-Budgets and Financial Control.
Back
22
The Department of the Environment, the Department for Education
and Employment, the Department of Transport and the Department
for Trade and Industry. Back
