Position négative du secrétariat général de la Commission européenne sur l'avancée des travaux Horizon 2020

8/3/2019 Position ngative du secrtariat gnral de la Commission europenne sur l'avance des travaux Horizon 2020

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Commission europenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.

EUROPEAN COMMISSIONSECRETARIAT GENERAL

The Secretary General

Brussels, 13 October 2011

SG D1/JA/ge

NOTE IN REPLY TO AN INTERSERVICE CONSULTATION

Subject: Inter-service consultation RTD/1074831 concerning the adoption of legislative

acts and a Commission Communication on 'Horizon 2020-The Framework

Programme for Research and Innovation (2014-2020)'

CIS-Net Reference: RTD 1074831

Thank you for consulting the SG on the package of proposals for Horizon 2020. Unfortunately,

after a detailed look into these proposals we can only maintain ournegative opinion for a number

of reasons which are spelt out in more detail in the attachment.

1) Simplification: This package is a big test of our simplification claims. However it falls

significantly short of our, and we imagine, stakeholder expectations. In particular the single "set of

rules for participants" is too complex, long, detailed, and contains far too many derogations.

2) A break from the past: In this extremely difficult economic climate it is critical that we

demonstrate how this programme represents a structural change from FP7. Unfortunately this is notdrawn out well in the documents and is significantly hampered by a lack of a budgetary

breakdown. It is unclear whether Horizon 2020 is tied closely in to Europe 2020 objectives; whether

it is pro-growth; and where the negative priorities are compared with FP7.

3) European Added Value: This will be a key selling point for Horizon 2020 and it is essential we

state our case clearly. In a number of cases this has not been achieved.

4) ITER: The June MFF decision specifies that ITER should be funded outside of the MFF after

2013. Any references to ITER under Horizon 2020 should be removed.

5) Links with other programmes: We must explain very clearly how these proposals do not

overlap with other funds / programmes, but instead develop synergies. This is particularly important

for the Structural Funds and the Competitiveness and SME Programme.

Our services are available to urgently work with DG RTD to improve the quality of these proposals

prior to adoption.

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Simplification:

This package is a big test for our simplification claims, and has the potential to be a good example.

That said, there is a significant disconnect between intentions / claims and the specifics. A good

deal of work has gone into simplification prior to the package being put together - and there is a lot

of interest from stakeholders on issues like a clearer simpler reimbursement towards actual costs,faster payments, changes to the audit system, and the use of lump sum payments.

Unfortunately the package does to explain clearly where and how Horizon 2020 presents a simplerlandscape for users / stakeholders than under FP7 and the other programmes now brought into the

family. In many respects these changes are modest. For example, our proposals on the use of lump

sum payments stop short of stakeholders wishes.

Our second major area of concern is in respect to the "single set of simplified rules". Unfortunately

these fall considerably short of this claim. In fact, it could be argued that the proposals as they stand

represent a complication compared to the past. In particular:

The rules of participation have nearly doubled in length and content. These rules contain very detailed provisions which normally belong in the Grant

Agreements but are now upgraded into the basic act. These do not belong here. We should

not transfer issues of detailed technical implementation into the basic acts.

Article 14 of the Financial Contribution states that "The Horizon 2020 financial contributionshall be 100% of the total eligible costs of the action. The financial contribution for an

action shall not exceed the total eligible costs minus the receipts of the action". This is a

major change from previous Framework Programme and indeed EU policy. Competition

rules prescribe the level of state aid that private enterprises (including private laboratories)

are allowed to receive. Art 14 seems to propose 100% funding across all actions irrespective

of size and legal entity, i.e. large private companies. This needs to be clarified.

The single set of rules is riddled with exceptions and derogations making the landscapemore complex for an applicant. An applicant with familiarity of the rules in one part of the

Horizon 2020 would not necessarily be made more familiar when applying under anotherarea (EIT for example) defeating the whole purpose of a single set of rules. Moreover, any

proposal to derogate from the Financial Regulation requires a clear justification, which is

currently not provided.

One of the well-known issues with the current framework programme is the absence of legalprovisions allowing the use of the lump sum payments for grants. This implies cumbersome

procedures for beneficiaries and for the Commission and undermines the performance of the

programmes concerned. In the current proposal (Art 10, 11 of rules of participation), it is

only foreseen to use lump sum payments, and only as a derogation, for indirect costs: this

means that for direct costs, i.e. the vast majority of costs, a system requiring the verificationof individual costs incurred, for example the ex-post verification of actual hours workedbased on time recording, will be maintained. We believe that in order to produce genuine

simplification, the proposal should tackle this problem and propose lump sum payments as

the norm, not the exception.

The Horizon 2020 package contains 4 proposals for Council decisions concerning thespecific programmes for "Excellent science base, Industrial leadership and competitive

frameworks, Tackling Societal challenges, JRC" which essentially contain identical

provisions on funding schemes, rules for participation, public private partnerships, work

programme, comitology. It should be possible to regroup these 4 separate legal decisions

into one as this was done for structural funds.


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By way of example we would draw your attention to the following:

1) Whereas 6 reads " .In order to ensure a coherent framework which could facilitate the

participation of European entities in programmes receiving an EU financial contribution from the

Horizon 2020 budget, (including the participation in programmes managed by EIT, joint

undertakings or any other structures under Article 187 TFEU or participation in programmesundertaken by Member States pursuant to Article 185 TFEU), common rules should apply.

However, flexibility to adopt specific rules should be ensured when justified by the specific

needs of the respective actions. "

2) Article 2 reads "The rules applied by a funding body may depart from the provisions laid down

in this Regulation if provided for in its basic act or if its specific operating needs so require and

with the Commission prior consent."

Our suggestion is for your services to urgently work closely with both DG BUDG and the SG to

significantly simplify these rules, addressing the above points.

Link to Europe 2020 and a pro-growth agenda:

(i) A break from the past: The proposals for Horizon 2020 will be adopted in a drastically changedeconomic climate from FP7. It is absolutely critical that the Commission strongly emphasises how

these new proposals represent a clear break from the past, and how Research and Innovation policyis adapting in order to support our efforts to improve the economic context. With this in mind the

Chapeau Communication must more clearly demonstrate how these proposals differ from a scenario

of "continuing on from FP7".

(ii) A framework to support growth: Unfortunately, because of the lack of a breakdown of thebudget across the programme it is impossible to judge the overall policy priorities of Horizon 2020,

leaving too many open questions:

Are these proposals pro-growth? For example are sufficient funds allocated towards innovation

amongst SMEs or support for risk financing? Do promising research areas like Key Enabling

Technologies receive sufficient support? What is the balance between direct and indirect research?

Are we striking the correct balance between the societal challenges?

In addition, this is a simple presentational issue, but a reordering of the chapters which currently

starts with "excellent science base" would help illustrate a pro-growth agenda. We should start withIndustrial leadership, then societal challenges and lastly excellent science base.

Finally there seems no dynamics built into the programme. This would allow us flexibility to

adapting the allocations of funding to the economic climate so that for example we could investmore heavily into SME's and risk financing in the early stages of Horizon 2020, and taper this down

as and when the economic climate improved.

European Added Value:

This will be a key selling point for Horizon 2020 and it is essential we state our case clearly and

forcibly. In a number of cases this has been done but there is too much variation between the fiches

in the main communication. Unfortunately a number of the most important cases trend also to be

the ones where the text does not demonstrate EU added value well enough. These include:

Under Industrial Leadership: The ICT challenge; Advanced Manufacturing; Space. Under Grand Societal Challenges: Smart, Green and integrated transport; The EIT and JRC.


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The EIT and the JRC also need to be better mainstreamed into the text notably. This is particularly important when linking the work of both to Europe 2020 and by introducing

pertinent policy impact and performance indicators.

Much of this is drafting, and the SG is happy to work with your services on this to bring out themessages clearly.

Overlap and links with other programmes:

We must explain very clearly how these proposals do not overlap with other funds / programmes,

but instead develop synergies. This is particularly crucial for the Structural Funds and the

Competitiveness and SME programme. The relevant sections in the main communication need to

bring this out more clearly.

In this context one aspect that has received particular attention from the EP (Matias report) and

from the Council concerns access to Horizon 2020 from the less developed Member States.

Currently missing is an explanation of how the Structural Funds and Horizon 2020 will work

together to build innovative capacity, and develop excellence in research amongst disadvantagedregions. We should address upfront how Horizon 2020 would address the concerns set out in

articles 10 and 11 of the Matias report referring to "stairways to excellence" and the use ofcompetitions for cutting edge research centres in disadvantaged regions. Reference is made to this

issue under the Inclusive, innovative and secure societies fiche "Linking emerging institutions,

centres of excellence and innovative clusters in less developed regions to international leading

counterparts elsewhere in Europe. This will involve . support for cases where international

leading institutions seek to establish facilities in less developed regions. Where appropriate, it will

be linked to significant investments from the Cohesion Policy funds, including in research

infrastructures, in order to increase the levels of excellence achieved through these investments".

This however, tends to be lost in the main text and the issues merits being addressed in theChapeau Communication.

Financing of SMEs

It would be beneficial to explain (e.g. in the "EU added value" section) how the SME financing

provided under Horizon 2020 compares to other SME financing foreseen under the Competitiveness

& SME programme and under the Structural Funds, and what the complementarities are.

The use of Partnerships:

Partnerships are an ever more important aspect of the EU research and innovation picture and

these proposals stress this will be reinforced under Horizon 2020. However, no effort is made toillustrate how we have learnt the lessons from our experiences working in partnerships over FP7.

The Commission recently issued two communications one on Partnerships and one on the

European Innovation Partnership Pilot yet we do not illustrate how the conclusions of these

communications have influenced our thinking on partnerships.

ITER:

The June MFF decision specifies that ITER should be funded outside of the MFF after 2013. Anyreferences to ITER under Horizon 2020 should, therefore, be taken out (e.g. in the draft Euratom

decision).


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Space:

Section 1.6 of Annex 1 of the draft Decision on Horizon 2020 refers to foreseen space research. In

this section reference is made to the investments already done on Galileo and GMES, stating that

"effective use of these will have to be safeguarded in the time frame of Horizon 2020". As a

decision on GMES's future has not yet been taken the reference to GMES should be removed.

The reference to enable European participation to global space endeavours is not clear. There is aprecise line that space policy for the EU should not go beyond GALILEO and GMES. This meansthat EU financial involvement in space missions is not necessarily a priority. Of course Member

States which are part of ESA could choose to participate to these missions via ESA. Hence the

action should be removed.

Section 1.63 on cross cutting actions is unclear about Key Enabling Technologies and ICT. The fact

that space uses KETs does not say much as to why we would have an activity on it and what it

would involve. The text needs to be much clearer as to what is intended.

The separate draft proposal foreseen on Galileo specifies that this project will also benefit from

research funding under Horizon 2020. However, this is currently not made clear in the Horizon2020 text.

Performance, evaluation and monitoring arrangements:

Performance indicators and objectives: The SG fully complies with the views of DG BUDG. The

guidelines on performance measurement jointly issued by SG and DG BUDG called on all DGs to

respect the obligation for all legislative proposals for programmes/actions starting in 2014 to be in

full compliance with the performance-related principles enshrined in the Financial Regulation.

It is clear that the proposed Decision does not meet this criteria. There are no SMART specific

objectives; there are no performance indicators closely linked to the specific objectives and noexpenditure-related outputs. Cross-references between documents appear not to lead to any relevant

piece of information. These aspects must be dealt with directly in the legal proposal, and by making

references to impact assessments.

Evaluation & monitoringarrangements lack focuss, are not well developed in the text, andconsequently falling well short of our required standards. In particular there is no evaluation and

monitoring timetable linked to decision making; No reference is made to a pre-defined baseline;

And the arrangements for the collection of data and information, and indication of responsibilities

of different actors, are not clarified. Again the SG is ready to work with RTD to clarify what is

required in this area. We would start by suggesting the addition of the following:

1) Evaluations shall have the right scope and will be carried out in a sufficiently timely manner to

feed into the decision making process.

(a) No later then mid-2018, an evaluation report shall be established by the Commission on theachievement of the objectives of all the measures (at the level of results and impacts), the

efficiency of the use of resources and its European added value, in view of a decision on therenewal, modification or suspension of the measures. The evaluation shall additionally address the

scope for simplification, its internal and external coherence, the continued relevance of all

objectives, as well as the contribution of the measures to the Union priorities of smart, sustainable

and inclusive growth. It shall take into account evaluation results on the long-term impact of the

predecessor measures;


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(b) An evaluation report shall be established on the longer-term impacts and the sustainability of

effects of the measures to feed into a decision on a possible renewal, modification or suspension of

a subsequent measure.

2) A set of key performance indicators shall be developed as a sound basis for assessing the extent

to which the objectives of the measures have been achieved. They shall be measured against pre-defined baselines reflecting the situation before implementation.

3) Member States shall provide the Commission with all the data and information necessary topermit the monitoring and evaluation of the concerned measures.

Administrative burden issues: The proposals need to explain clearly why a distinction is madebetween administrative and participation costs. And more generally would need to better explain

how administrative cost calculations have been made in particular whether audit, control and

evaluation costs account for the demands on the applicant in terms of data provision.

signed

Catherine Day

Contact: James ALLEN SG D1 tel. 66899

Copies: Messrs /Ms M. Klingbeil, M. Servoz, C. Danielsson G. Di Vita, J. Ayet Puigarnau,

H. Szlaszewski, J. Nymand Christensen, J. Korte, T. Anastopoulos, S. Jakobsen,

F. Genisson, M. Haag, J. Watson, W. Sleath, E. Golberg, L. Tholoniat, A. Kulas,C. Becher, M.L. Llano Cardenal, M. Lautso-Mousnier (SG), M. Bjorklund (SG).

Ms de Richemont (CAB)

Documents

Position négative du secrétariat général de la Commission européenne sur l'avancée des travaux Horizon 2020