Contribution of the CoR members of the EC Task Force on Subsidiarity

"Better involvement of local and regional authorities in the preparation, coordination and implementation of Union policies"

Introduction

This paper sets out some initial ideas of the three CoR members of the EC Task Force on Subsidiarity in the framework of the third objective of the Task Force – Better involvement of local and regional authorities in the preparation, coordination and implementation of Union policies. It highlights the added-value of involving LRAs throughout the entire policy cycle, as well as in all debates on the future of the EU, and puts forward some proposals on how to strengthen this involvement, based on the Multi-level Governance approach, both in the short-term and in the longer-term.

About three-quarters of all EU legislation and a large part of the related EU budget are implemented at local and regional level throughout the EU. Therefore, EU legislation cannot be effective if the specificities and characteristics of its territories are not adequately considered in the preparation and implementation phases.

In this context, from the perspective of regional and local authorities, a key point is the proper application of the principles of subsidiarity and proportionality, as set down in Article 5 and Protocol No. 2 of the Treaty.

In preparing this paper, the CoR carried out a consultation1 of more than 2500 regional and local stakeholders (including regional parliaments and governments, national associations of local authorities, local authorities and CoR national delegations). The preliminary results of the consultation are presented in Annex I, and the consultation is ongoing until the end of June 2018.

In this paper, the involvement of LRAs has been considered in the context of the three main phases of the EU policy-making and legislative process, as well as in the overall policy coordination process:

1. Policy preparation phase of the legislative process, 2. Negotiation phase of the legislative process,

1 The online consultation ran from 2-14 February 2018 and will remain open until the end of the Task Force mandate.

CoR delegation to the Task Force on Subsidiarity, Proportionality and "Doing

Less More Efficiently"

19 February 2018

3. Policy implementation phase, including proposals how to capture better experience and data from Local and Regional level, and

4. Policy coordination.

The proposals in each of these four areas describe where improvement is required and give suggestions for possible solutions, grouped in short-term and long-term actions. Suggested improvements in the short-term are understood as proposals that would not require any changes to the current legal framework and that could already be implemented in the next MFF period. For the short-term proposals, it would be necessary to develop the full potential of Art 5 of the Treaty and Protocol No 2 on the application of the principles of subsidiarity and proportionality, the Interinstitutional Agreement on Better law making and of the CoR's Cooperation Agreements with the European Commission and the European Parliament. The implementation of the longer-term proposals to sustainably improve the role of LRAs would require a change of current legal framework.

Specific questions suggested by the Commission for the meeting on 23 February:

(1) What are the reasons behind local and regional authorities' low level of direct participation in Commission consultation/feedback activities which support impact assessments and evaluations of existing legislation? What improvements can be made?

This question needs to be taken in a broader sense: Therefore, Chapter 1 of this position paper covers the entire pre-legislative phase, including the more structured participation of LRAs in policy formulation, and includes the question of consultations as one sub-point.

(2) How can the views of local and regional authorities about subsidiarity and territorial impacts be better taken account of by the European Parliament and the Council when considering Commission proposals?

Chapter 2 of this paper covers these issues, also taken in a broader approach.

(3) Do the Commission's implementation plans help local and regional authorities to implement and apply Union policies? How can they be improved?

(4) How can the practical experience and hard data from local and regional authorities be more effectively captured by the Commission when evaluating and revising Union law?

Chapter 3 again takes a broader view and covers the entire implementation phase, within which questions 3 and 4 are covered as sub-points.

Additional CoR point EU policy coordination

Chapter 4 covers a fifth topic, namely the role of LRA’s in EU policy coordination, such as in the areas of Economic Governance, Social rights and Climate Change. How can local and regional authorities be better involved in policy coordination, in what areas? What actions could help to improve the involvement of LRA’s in the short-term and in the long-term?

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1. REGIONAL AND LOCAL INVOLVEMENT DURING THE POLICY PREPARATION PHASE OF THE LEGISLATIVE PROCESS

EU legislation can be properly understood on the ground and thus more effective if the specificities and characteristics of its territories are adequately considered in the preparation phase.

1.1 Participation of LRA’s in the Commission’s stakeholder consultations and feedback activities

Commission Question 1: What are the reasons behind local and regional authorities' low level of direct participation in Commission consultation/feedback activities which support impact assessments and evaluations of existing legislation? What improvements can be made?

Consultations are important instruments from the standpoint of deliberative democracy in the policy preparation phase2 and LRAs are aware of this. However, clear reasons can be identified for the low participation of LRAs in these consultations:

1) Regional and local authorities are often placed in the same stakeholder category as NGOs, civil society and business organisations and even individuals, where they do not see their specific interests addressed in the preparatory phase. If the Commission is interested in a stronger feedback from LRAs, it is vital that they are consulted in a manner that recognises their specific political/democratic role and legal competences as public authorities with self-government (in accordance with Article 4 (2) TEU) on the basis of targeted consultations. As it stands, consultations are mostly addressed to stakeholders, but there is no clear definition of a "stakeholder" either in the Commission's guidelines for stakeholder consultations3 or in the Inter-Institutional Agreement on Better Regulation. The Toolbox on Smart Regulation4 includes several contradictory references to stakeholders5, and this lack of clarity has significant consequences.

2) Qualitative aspects of consultations6 are relevant. Simplified consultations, sometimes reduced to opinion polls organised as multiple-choice questionnaires addressed to multi-category stakeholders, are not always compatible with enabling LRAs to highlight their particular territorial specificities and needs. The impression arises that Commission consultations are only oriented towards the mobilisation of support for the proposal and do not really allow for participation in the policy-making process. However, Protocol No 27 explicitly requires the Commission to take account of the local and regional dimension of proposed actions, and to contain an "assessment of its implications for regional legislation and take account of the need for any burden, whether financial or administrative, falling upon… regional and local authorities to be minimised and commensurate with the objective to be achieved". Research into the

2 Quittkat/Finke 2008.3 Commission's guidelines for stakeholder consultations 4 Toolbox on Smart Regulation 5 Referring (on p.61) to "relevant stakeholders (i.e. general public, a specific category of stakeholders or designated

individuals/organisations - SMEs, regions, MS authorities, NGOs, consumer organisations)" including regions and Member State authorities in this definition. The Toolbox also speaks of "EU and non-EU stakeholders" (p.66) while elsewhere a clear distinction between "stakeholders, regions or Member States" is made (p.146), while it also refers to stakeholder categories that sometimes include Member States and the European Parliament (p.130).

6 See for research of Commission's consultation regime Knodt/Quittkat/Greenwood 20127 Article 2: 'Before proposing legislative acts, the Commission shall consult widely. Such consultations shall, where appropriate, take into

account the regional and local dimension of the action envisaged'

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Commission's consultation regime8 shows that their impact on the formulation of EU policies remains low, which may give rise to a certain consultation fatigue among LRAs. It would be helpful to have more clarification as to how consultations are formulated, how responses are evaluated, and how the Commission provides a proper response to participants to show how their input has impacted on the proposal, as required by Art. 2 of Protocol No.2. The consultation process should always remain proportionate to the expected scope and impact of the initiative it supports, and should focus on those aspects that are relevant for LRAs.

3) As the Treaty-based institutional representative of regional and local authorities , the European Committee of the Regions does not participate in consultations, but adopts documents of a legal nature (although non-binding) called "opinions", as an advisory body within the policy-making process. The existing Cooperation Agreement between the European Commission and the European Committee of the Regions provides a mechanism for the CoR to be consulted and participate more extensively in the policy preparation phase, and LRAs are expecting that recommendations put forward in CoR opinions should feed into policy formulation on their behalf.

The European Court of Auditors is currently exploring the effectiveness of public consultations of the Commission. The results of this audit to be published mid-2019 could be used to review the existing system in close collaboration with local and regional authorities.

1.2 Regional and Local involvement in impact assessment and policy formulation

The important role of LRAs in policy implementation should be acknowledged in the policy preparation phase through a more structured involvement. LRAs should be better involved in Impact assessment, and ex-ante Territorial Impact Assessment (TIA) should be an integral part of the Impact Assessment (IA) process and used to help design the most efficient legislation that takes account of territorial specificities and the role of LRAs throughout the policy cycle.

Short-term actions for consideration:a. Promoting a decentralised political dialogue with local and regional authorities on the

European Commission Work Programme, legislative priorities and legislative proposals. b. Systematically including Territorial Impact Assessment (in accordance with Article 5 of

Protocol No 2) in the EU's ex-ante impact assessment process.c. EC Regulatory Scrutiny Board to include at least one expert with local/regional experience.d. Ensuring a complete analysis of the European Added-Value in legislative proposals.e. Strengthening the territory-specific approach to policy making, going beyond regional, climate

and energy policies9.f. Expanding the application of the principles of partnership and multi-level governance (as

existing in Cohesion policy) through an inter-institutional code of conduct. Codifying the principle of multi-level governance in EU policies.

g. Improving the availability and use of local and regional-specific data throughout the EU.

8 Knodt/Quittkat/Greenwood 20129 There are concrete examples in various policy fields: The Covenant of Mayors is an explicit materialisation of the place-based approach;

Sustainable climate and energy action plans (SECAPs) are specifically designed to better involve LRAs in the preparation, implementation and follow-up of EU climate and energy policies.

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Long-term actions for consideration:a. Including the territorial dimension in the Inter-Institutional Agreement on Better Law-making

by involving the CoR, to fully apply the principle of subsidiarity and in particular to respect the role of regional and local self-government in the Union.

b. Better involvement of regional parliaments in the Subsidiarity Early Warning System by making their consultation obligatory when their competences are concerned (amending Protocol No 2).

In replies to the CoR's recent consultation, it was suggested that LRAs also be consulted at the end of the preparation process to assess if the final policy might then also be applicable on the ground. This could be done through pilot projects implemented in different characteristic territories of the EU, testing what is realistic, what can be translated into concrete action and what should be re-considered or adapted according to the circumstances. This could provide more flexibility in the Policy preparation phase and could guarantee a link between the elaboration of European policies and the realities on the ground.

Furthermore, consultation respondents suggested taking particular care not to add to administrative burdens for LRAs.

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2. REGIONAL AND LOCAL INVOLVEMENT DURING THE LEGISLATIVE PHASE

Commission Question 2: How can the views of local and regional authorities about subsidiarity and territorial impacts be better taken account of by the European Parliament and the Council when considering Commission proposals?

Regional and local authorities are not involved in the negotiation phase of the legislative process, although some regions from federally-organised Member States do participate in the work of the Council of Ministers. Overall, the information received by regions and local authorities throughout the legislative process is far from complete10. Neither LRAs (including regions with legislative powers) nor the CoR (after it has issued its opinion) receive systematic information on the progress of the ongoing negotiations between the EU’s co-legislators (“trilogue” process), and they are entirely dependent on the goodwill of other actors to inform them11.

To improve this, a system of structured access to information for LRAs during the legislative phase needs to be ensured, within the current Treaty provisions. LRA’s have to be informed in order to enable them to feed their knowledge and experience into in the legislative process as needed.

As far as the CoR is concerned, this impacts on its institutional consultative role, particularly when legislative proposals are substantially changed after its initial consultation. The CoR-EC cooperation agreement (Art. 11) recognises this and foresees a new consultation of the CoR if the EC substantially modifies the initial proposal. As the Treaty obligation to consult the CoR also concerns the European Parliament and the Council, such a clause should be best placed in the Inter-Institutional Agreement on Better Law-making.

Short-term actions for consideration:a. Organising hearings for LRAs in cooperation with other institutions where appropriate.b. Better structured information to Regions and Local Authorities on developments during the

negotiation phase.c. Ensuring a verification of European added value and Territorial Impact following legislative

amendments.d. Granting observer status to regional and local authorities, represented by the European

Committee of the Regions as foreseen in the Treaties, in Council working groups in areas where consultation of the CoR is mandatory.

e. Better informing regional parliaments using the REGPEX platform.f. In each legislative act affecting local and regional authorities, the Commission should lay

down how LRAs have been consulted and how their views have been taken into account.

10 A lack of transparency was also highlighted in the EP's draft Report on the interpretation and implementation of the Interinstitutional Agreement on Better Law-Making (rapporteurs MEP Svoboda and MEP Corbett, AFCO and JURI joint committee procedure). Also, in a statement on 13 February 2018, the EU Ombudsman called on the Council of the EU to record Member States' positions and to open up preparatory documents to the public.

11 The CoR has the right to go to the European Court of Justice (ECJ) if its prerogatives are neglected, such as the right of consultation. According to ECJ jurisprudence, this is also the case if the CoR is not re-consulted on legislation that was substantially modified during the legislative process. Therefore, only a fully transparent approach throughout the legislative process can ensure that all institutional rights are respected.

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Long-term actions for consideration:a. Adapting the Inter-Institutional Agreement on Better Law-making to include the CoR in the

systematic inter-institutional document exchange and to foresee its consultation again in cases where the initial legislative proposal has been substantially modified.

b. Granting observer status to regional and local authorities, represented by the European Committee of the Regions as foreseen in the Treaties, in the "trilogue" meetings.

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3. REGIONAL AND LOCAL INVOLVEMENT DURING THE POLICY IMPLEMENTATION PHASE

About three-quarters of all EU legislation and a large part of the related EU budget are implemented at local and regional level throughout the EU. Many CoR opinions have highlighted issues and problems specifically related to the implementation of legislation12.

3.1 Implementation plans and other guidance for implementation

Commission Question 3: Do the Commission's implementation plans help local and regional authorities to implement and apply Union policies? How can they be improved?

In the CoR's opinion on the EU Agenda on Better Regulation13, the CoR explicitly welcomed the Commission's intention to publish implementation plans for legislation and guidelines, expecting that they would contain specific reference to the local and regional level. As set out in the Better Regulation Guidelines14, the objective of an implementation plan is to support Member States in the implementation of legislation and to set monitoring arrangements to ensure the availability of strong data and other evidence to track progress and report on the performance of the measure. However, even if internal guidance refers to the sub-national level in a very general way, in practice, few implementation plans explicitly include reference to the local and regional level.

Nonetheless, it is often more important for local and regional authorities that they are taken into account in the national implementation plans, and the Commission should insist on such an involvement when monitoring their implementation.

A stronger focus on LRAs in implementation plans could be beneficial in terms of guidance for implementation and in monitoring arrangements at local and regional level (to gather hard data and monitor performance). However, it is important to ensure that individual tiers of government are not burdened unnecessarily or have unnecessary expenditure when it comes to implementation.

3.2 Feedback from implementation at local and regional level: Ways to better capture data and experience

Commission Question 4: How can the practical experience and hard data from local and regional authorities be more effectively captured by the Commission when evaluating and revising Union law?

The practical experiences and hard data from local and regional authorities can be more effectively gathered by the Commission when evaluating and revising EU law through the following measures:

Regarding the provision of data: making sure that more data is available at NUTS II and NUTS III level by putting more

emphasis on its collection as part of the European Statistical System beyond 2020; generating more data on the cross-border impact of EU policies; focussing on the local and regional level in Eurostat data collection;

12 CoR opinions on the Service Package, on the Fitness Check of the Birds /Habitat and Natura 2000 directives, and on the Environmental Implementation Review (where the CoR suggested a number of ways to improve LRA involvement in this field, and which would also be applicable to other policy areas).

13 COR-2015-04129-00-01-AC14 SWD(2017) 350 final

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investigating the possibilities - and also the limits - that "big data" provides for capturing local and regional specificities;

ensuring that the 2021 census will allow a full geo-referencing of the data generated; ensuring that appropriate funding is available in the event that LRA are invited to collect and

provide such data.

Regarding the interpretation of data: extending the co-operation between DG Regio, the ESPON programme, the Joint Research

Centre and local and regional authorities to further develop instruments to assess the impact of EU policies15;

further developing the models and methodologies for territorial and urban impact assessment by extending the collaboration of local and regional authorities with the “Knowledge Centre for Territorial Policies”16.

Knowledge and experience on the ground should feed back into the legislative cycle through the monitoring and evaluation of implementation. However, the EU policy-making and review system is currently lacking a structured feedback mechanism on implementation involving LRAs, a situation creating a lot of frustration on the ground. The Commission's implementation review and evaluation system remains programme-focused and provides insufficient feedback of data and recommendations on policy implementation. Inter-institutional coordination and cooperation on the review of policy implementation is insufficient.

Short-term actions for consideration:a. Systematically include territorial aspects in the ex-post evaluation of implementation of EU

legislation for the review of legal acts, using regional and local level data and surveying.b. Apply ex-post Territorial Impact Assessment (TIA) as part of the impact assessment

evaluation.c. Improve inter-institutional cooperation in the monitoring and evaluation of policy

implementation, including at local and regional level17.d. Re-assess the European added-value criteria when evaluating policy fitness at the

implementation stage.e. Set clear indicators before the implementation of legislation to allow for quantitative and

qualitative evaluations.

Long-term actions for consideration:a. Set up a structured and systematic feedback mechanism involving Regions and Local

Authorities. This could include the setting up of a decentralised network on monitoring of EU policy implementation at local and regional level, codified in the relevant EU legislation.

15 Such as the European Commission's RHOMOLO model for impact assessment, which provides sector, region and time-specific simulations to support to EU policy making on investments and reforms covering a wide array of policies.

16 The Knowledge Centre for Territorial Policies (KCTP) is a new European Commission initiative on better knowledge management for sound EU policy making. To strengthen the Commission’s overall support to territorial development, the KCTP aims to be the point of reference for Commission services and Member States on territorial and regional related issues. It will allow for analytical and networking activities accompanied by a repository of relevant research and new initiatives to deepen knowledge and understanding. https://ec.europa.eu/jrc/en/territorial-policies

17 Through the inter-institutional code of conduct referred to under Point 1.

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4. REGIONAL AND LOCAL INVOLVEMENT IN POLICY COORDINATION

Particular attention should be given to LRAs in EU policy coordination, such as in the areas of Economic Governance, Social Rights and Climate Change.

EU action to promote the stronger involvement of LRAs in policy coordination would be in line with the subsidiarity and proportionality principles, and would better involve LRAs in areas where they have competences. The EU's policy coordination often affects the competences of local and regional authorities, even though they are not directly involved in this process. Promoting a dialogue with all levels of government would promote multi-level governance solutions and increase ownership at all levels.

Economic Governance

As key policy areas addressed by the County Specific Recommendations (CSRs) are often within the remits of LRAs, the involvement of LRAs as partners in the European Semester process would make it more effective, while increasing ownership of structural reforms. To this aim, the Semester needs to build on an analysis of territorial disparities, challenges and opportunities, and to make appropriate arrangements at the EU and country levels.

Such action would bring added value by contributing to resilience, convergence and cohesion and by addressing negative policy spill-overs from one country to another, while stimulating positive ones. It could be limited to the minimum necessary by leaving implementation to the Member States.

Short-term actions for consideration:a. All aspects of the Semester process should systematically include an analysis of territorial

disparities and of the territorial impact of structural reforms, and the process should better involve LRAs in setting up the national reform programmes and in developing the Country Specific Recommendations, as well as at EU level through the CoR.

b. Territory-related CSRs should address the role of LRAs on a multi-annual basis, while the Council should look at territorial disparities when it deals with the European Semester.

c. The Commission should encourage Member States to adopt the principles of partnership and multi-level governance at country level, including LRAs in its Semester-related country visits.

d. The next MFF could ensure that the provision of EU funding is made conditional upon the involvement of LRAs in the design and implementation of (a) structural policies at country level, and (b) appropriate measures at regional and local level.

e. Granting of observer status to regional and local authorities, represented by the European Committee of the Regions as foreseen in the Treaties, in Council working groups dedicated to economic, social and territorial cohesion when the debates on CSRs take place.

Long-term actions for consideration:a. The short-term actions listed above could become permanent, possibly by adopting the CoR's

proposal for an inter-institutional Code of Conduct, for which an appropriate legal basis should be provided.

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ANNEX 1Task Force on Subsidiarity, Proportionality and

"Doing Less More Efficiently"

RESULTS OF THE CoR STAKEHOLDER CONSULTATION

on Objective 3: "Better involvement of local and regional authorities in the preparation, coordination and implementation of

Union policies"

1. Regional and Local involvement during the Policy Preparation Phase of the legislative process

1.a. Do you believe that the following actions could help to improve the involvement of LRA's in the short term?

a) Promoting a decentralised political dialogue with local and regional authorities on the European Commission Work programme and legislative priorities:

Ratio

Yes 82.61 %

No 8.7 %

No Answer 8.7 %

b) Systematically including Territorial Impact Assessment in the EU's ex-ante impact assessment process:

Ratio

Yes 78.26 %

No 13.04 %

No Answer 8.7 %

c) EC Regulatory Scrutiny Board to include at least one member with local/regional experience:

Ratio

Yes 84.78 %

No 4.35 %

No Answer 10.87 %

d) Ensuring a complete analysis of the European Added-Value in legislative proposals:

Ratio

Yes 73.91 %

No 17.39 %

No Answer 8.7 %

e) Strengthening the territory specific approach to policy making, going beyond regional, climate and energy policies:

Ratio

Yes 78.26 %

No 10.87 %

No Answer 10.87 %

f) Expanding the application of the principles of partnership and multi-level governance (as existing in Cohesion policy) through an inter-institutional code of conduct:

Ratio

Yes 78.26 %

No 10.87 %

No Answer 10.87 %

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g) Improving the availability and use of local and regional-specific data throughout the EU:

Ratio

Yes 84.78 %

No 4.35 %

No Answer 10.87 %

1.b. Do you believe that the following actions could help to improve the involvement of LRA's in the long term?

a) Including the territorial dimension in the Inter-Institutional Agreement on Better Law-making by involving the CoR, to fully apply the principle of subsidiarity:

Ratio

Yes 82.61 %

No 10.87 %

No Answer 6.52 %

b) Better involvement of regional parliaments in the Subsidiarity Early Warning System by making their consultation obligatory when their competences are concerned (amending Protocol No 2):

Ratio

Yes 80.43 %

No 6.52 %

No Answer 13.04 %

2. Regional and Local involvement during the Negotiation Phase of the legislative process

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2.a. Do you believe that the following actions could help to improve the involvement of LRA's in the short term?

a) Organising hearings for LRA in cooperation with other institutions where appropriate:

Ratio

Yes 86.96 %

No 6.52 %

No Answer 6.52 %

b) Better informing Regions and Local Authorities of developments during the negotiation phase:

Ratio

Yes 84.78 %

No 4.35 %

No Answer 10.87 %

c) Ensuring a verification of European added value and Territorial Impact following legislative amendments:

Ratio

Yes 82.61 %

No 6.52 %

No Answer 10.87 %

d) Granting observer status to LRA representatives in Council working groups in areas where consultation of the CoR is mandatory:

Ratio

Yes 84.78 %

No 6.52 %

No Answer 8.7 %

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e) Better informing regional parliaments using the REGPEX platform:

Ratio

Yes 71.74 %

No 8.7 %

No Answer 19.57 %

2.b. Do you believe that the following actions could help to improve the involvement of LRA's in the long term?

a) Adapting the Inter-Institutional Agreement on Better Law-making to include the CoR in the systematic inter-institutional document exchange:

Ratio

Yes 86.96 %

No 2.17 %

No Answer 10.87 %

b) Granting observer status with speaking rights to LRA representatives in the "trilogue" meetings:

Ratio

Yes 76.09 %

No 13.04 %

No Answer 10.87 %

3. Regional and Local involvement during the Policy Implementation Phase

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3.a. Do you believe that the following actions could help to improve the involvement of LRA's in the short term?

a) Systematically include territorial aspects in the ex-post evaluation of implementation of EU legislation, using regional and local level data and surveying:

Ratio

Yes 86.96 %

No 2.17 %

No Answer 10.87 %

b) Apply ex-post Territorial Impact Assessment (TIA) as a part of the impact assessment evaluation:

Ratio

Yes 80.43 %

No 6.52 %

No Answer 13.04 %

c) Improve inter-institutional cooperation in the monitoring and evaluation of policy implementation, including at local and regional level:

Ratio

Yes 82.61 %

No 6.52 %

No Answer 10.87 %

d) Re-assess the European added-value criteria when evaluating policy fitness at implementation stage:

Ratio

Yes 71.74 %

No 8.7 %

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No Answer 19.57 %

3.b. Do you believe that the following action could help to improve the involvement of LRA's in the long term?

Set up a structured and systematic feedback mechanism involving Regions and Local Authorities. This could include the setting up of a decentralised network on monitoring of EU policy implementation at local and regional level, codified in the relevant EU legislation:

Ratio

Yes 76.09 %

No 13.04 %

No Answer 10.87 %

4. Regional and Local involvement in Policy Coordination

4.a. Do you believe that the following actions could help to improve the involvement of LRA's in the short term?

a) All aspects of the Semester process should systematically include an analysis of territorial disparities and of the territorial impact of structural reforms, and the process should better involve LRAs at EU level:

Ratio

Yes 69.57 %

No 17.39 %

No Answer 13.04 %

b) Territory-related CSRs should explicitly address the role of the LRAs, while the Council should look at territorial disparities when it deals with the European Semester:

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Ratio

Yes 71.74 %

No 6.52 %

No Answer 21.74 %

c) The Commission should encourage Member States to adopt the principles of partnership and multi-level governance at country level, while including LRAs in its Semester-related country visits:

Ratio

Yes 76.09 %

No 4.35 %

No Answer 19.57 %

d) The next MFF should adopt the concept of "smart conditionality" making EU funding conditional upon the involvement of LRAs in the design and implementation of (a) structural policies at country level, and (b) appropriate measures at local and regional level:

Ratio

Yes 73.91 %

No 6.52 %

No Answer 19.57 %

e) Granting of observer status to LRA representatives in Council working groups dedicated to economic, social and territorial cohesion when the debate on CSRs takes place:

Ratio

Yes 73.91 %

No 4.35 %

No Answer 21.74 %

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4.b. Do you believe that the following action could help to improve the involvement of LRA's in the long term?

The short-term actions listed above could become permanent, possibly by adopting the CoR's proposal for an inter-institutional Code of Conduct, for which an appropriate legal basis should be provided:

Ratio

Yes 69.57 %

No 10.87 %

No Answer 19.57 %

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