Legal provisions of SEC(2010)198 - Summary of the impact assessment - Accompanying document to the Proposal for a Decision of the European Parliament and of the Council establishing a EU action for the European Heritage Label

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dossier SEC(2010)198 - Summary of the impact assessment - Accompanying document to the Proposal for a Decision of the European Parliament and of ...
document SEC(2010)198 EN
date March  9, 2010

EN

EUROPEAN COMMISSION

Brussels, 9.3.2010

SEC(2010) 198


COMMISSION STAFF WORKING DOCUMENT

SUMMARY OF THE IMPACT ASSESSMENT

Accompanying document to the

Proposal for a

DECISION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

establishing a European Union action for the European Heritage Label

{COM(2010) 76 final}
{SEC(2010) 197}

Executive Summary

This impact assessment will accompany the proposal for a Decision of the European Parliament and of the Council establishing a European Union action for the European Heritage Label.

1. Problem definition

The original concept of the European Heritage Label (EHL) was born as one of the responses to the gap between the reality of the EU and the perceptions of its citizens. This gap is linked to an important extent to a lack of knowledge of the history of Europe, of the role of the EU and of the functioning of its institutions.

The scheme was subsequently launched in April 2006 as an intergovernmental initiative. To date, a total of 64 sites located in 17 EU MS as well as in Switzerland have obtained the label. The aim of the original EHL was to use the potential of cultural heritage to strengthen European citizens’ sense of belonging to Europe and promote a sense of European identity. It is important to note that right from the start, it was clear that the EHL alone could not fill the gap between citizens and the EU. It was meant more modestly to be one contribution alongside other initiatives in the field of communication, education, culture or citizenship aimed at addressing the same problem.

This leads us to a second level of the problem which is that the reading or interpretation of cultural heritage in Europe, including of the most symbolic sites of our shared heritage, is still to a very large extent a national reading. The European dimension of our common heritage is insufficiently highlighted and its potential to stimulate intercultural dialogue is not optimally exploited. This situation has been clearly acknowledged by the Ministers of Culture who launched the intergovernmental EHL and this initiative aimed to tackle this problem by identifying and designating sites which have played a key role in building and uniting Europe, promoting a European reading of these sites, developing their educational potential, and fostering the sharing of experience and best practices.

However, the intergovernmental EHL has not achieved concrete results so far. This is due in part to the fact that the EHL is only very recent and that the problem it seeks to address is complex and deep-rooted. This is due also to the fact that the EHL is still very far from having reached its full potential and its implementation shows many deficiencies which need to be addressed. This was confirmed by an evaluation of the initiative carried out by the external consultant ECOTEC as part of their support services for this impact assessment, which demonstrated for example that as a consequence of the current selection procedures, the nature of the selected sites, their relevance, and their activities are rather disparate and in some cases difficult to comprehend; that the EHL lacks visibility even among the main stakeholders in the heritage sector; and that little progress has been made so far on the educational dimension and networking between labelled sites. In order to achieve concrete results and to make an impact, the EHL needs a more proactive approach and to take a qualitative step forward.

2. Analysis of subsidiarity

On 20 November 2008, the Council of Ministers of the European Union adopted conclusions inviting the European Commission to submit to it ‘an appropriate proposal for the creation of a European Heritage Label by the European Union and specifying the practical procedures for the implementation of the project’.

The legal basis for the EHL can be found in Article 167 of the Treaty on the Functioning of the European Union. This article gives the EU the mandate to ‘contribute to the flowering of the cultures of the MS, while respecting their national and regional diversity and at the same time bringing the common cultural heritage to the fore’. The EU should also encourage ‘cooperation between MS’ in the field of culture and ‘if necessary, support and supplement their action’. In accordance, with the Council conclusions, the participation of the MS would be on a voluntary basis. EU involvement in the EHL is expected to reinforce coordination between MS and thus to contribute to the development and the application of new common, clear and transparent selection criteria, as well as new selection and monitoring procedures for the EHL, thereby ensuring the relevance of the sites in the light of the objectives. The results of the evaluation of the current EHL mentioned above demonstrated that this could not be achieved with the intergovernmental arrangements. Other expected benefits of EU action are an increase in the number of MS participating in the initiative and a solution to the problems linked to the present rotating secretariat. This should help to improve the value of the initiative in order to ensure its quality, credibility and long-term success.

3. Objectives of EU initiative

As mentioned above, the gap between the EU and its citizens is a broad and complex problem which cannot and will not be solved by the EHL alone. Different initiatives address this issue in complementary ways and it is important to stress that the label will certainly not have an impact on the same level as for example student exchanges or language learning. Therefore it has been decided to propose four levels of objectives for the renewed EHL, with general objectives which reflect the overall ambition of the EHL and link it into the wider EU policy agenda and intermediate objectives which are the highest level of impact that the EHL can achieve on its own. At a more basic level, specific and operational objectives are included.

3.1. General objectives

Strengthen European citizens’ sense of belonging to the European Union, based on shared elements of history and cultural heritage, as well as an appreciation of diversity.

Strengthen intercultural dialogue.

3.2. Intermediate objectives

Enhance the value and profile of sites which have played a key role in the history and the building of the European Union.

Increase European citizens’ understanding of the building of Europe, and their common yet diverse cultural heritage, especially related to democratic values and human rights that underpin European integration.

3.3. Specific objectives

Develop sites’ European significance.

Raise young people’s awareness of their common cultural heritage.

Facilitate sharing of experiences and exchanges of best practice across Europe.

Increase access to heritage sites for all members of the public, especially young people.

Increase intercultural dialogue, especially among young people, through artistic, cultural and historical education.

Foster synergies between cultural heritage and contemporary creation and creativity.

Contribute to the attractiveness and the sustainable development of the regions.

3.4. Operational objectives

a) Practical arrangements for the EHL

Ensure the application of common, clear and transparent criteria for the selection of the sites.

Foster a fair distribution of labels across the European Union.

Introduce a monitoring procedure to ensure that the labelled sites respect their commitments.

Improve the complementarity with other initiatives in the field of cultural heritage, notably through good communication with relevant international bodies.

Ensure that the practical arrangements remain light and flexible for the EU and the MS.

Increase the visibility at European level, notably through the development of a website.

Develop transnational networks of sites to develop their European profile and exchange.

b) Activities of the labelled sites

Develop the European dimension of sites through appropriate information activities and multilingual signage.

Develop programmes of educational activities.

Undertake marketing and promotion of sites as tourist destinations locally, nationally and at European level.

Develop access to sites through site adaptations, visitor tools, staff training, privileged access for the young public.

Develop programmes of cultural activities: events, festivals, artist-in-residence schemes, etc..

4. Policy options

The Council conclusions mention that the new EHL should keep ‘flexible and streamline administrative arrangements in compliance with the principle of subsidiarity.’ This same concern to keep the costs limited both at national and European level was also expressed on numerous occasions during the consultation process and it has been reinforced by the current context of financial and economic crisis which makes it highly unlikely that much funding will be available either at national or European level for the EHL in the coming years. In view of these factors we excluded an option which would have involved continuing the EHL as an intergovernmental initiative but with significant financial support from the EU to develop sites and the networking between them, as well as an option which would have involved transforming the EHL into an EU initiative with significant financial support to the sites.

As a result of this initial screening process, three main options which appeared to be realistic and feasible were developed, with one of the options containing three sub-options. All of these options would have very limited impacts on the EU budget. All of them also comply with the principles of subsidiarity and proportionality.

4.1. Option 1: Status quo (baseline scenario)

The EHL continues as an intergovernmental initiative with a secretariat hosted by participating countries on a rotating basis (unfunded by the EU) and without any EU action.

4.2. Option 2: Status quo plus limited EU financial support

The EHL continues as an intergovernmental initiative with limited financial support from the EU budget to support part of the running costs of the secretariat, part of the communication costs, expert meetings and networking. Funding would have to come from either the current or future Culture programme.

4.3. Option 3: The EHL becomes an EU initiative through a Decision by the Council and the Parliament

This Decision would specify the objectives and the rules of the new Label, define the common selection criteria, set up the selection and monitoring procedures and clearly allocate the tasks and responsibilities between the MS and the Commission. A secretariat would be provided by the Commission. Some limited financial support would be provided to assist the transnational networking of the sites, either through calls for proposals or by the organisation of expert meetings by the Commission. The Commission would also be responsible for the communication and the visibility of the EHL at European level.

Three sub-options are possible according to the various selection and monitoring procedures that came up during the consultation phase:

3(a) Selection of sites is undertaken by the MS against common, clear and transparent criteria. Each year the MS put forward sites up to a maximum number and according to country quotas. The sites are then validated by the EU. Monitoring is a MS responsibility. The function of the Commission is to ensure a good coordination between the MS and the smooth running of the procedures and the practical arrangements.

3(b) Sites are selected through an open selection process which does not take into account the national origin of the candidate sites by an expert committee at European level. A limited number of Labels could be awarded each year. Monitoring functions would also be undertaken at EU level.

3(c) Sites are pre-selected by MS and then subject to final selection by an independent panel at EU level. Monitoring is primarily a MS responsibility, but with supervision and review by the independent panel and the possibility of withdrawal of the designation.

5. Assessment of impacts

In order to undertake the impact assessment a range of potential impacts were identified in cooperation with the external consultant. They were derived from various sources: from a review of the literature relating to the impact of culture and heritage; from an analysis of the objectives of the EHL; and from the comments and perspectives of the individuals, organisations and MS that participated in the consultation process.

The following impacts were analysed:

5.1. Social / societal impacts:

Increased access to cultural heritage resources.

Increased access to heritage for young people.

Increased interest in and knowledge of common European heritage.

Increased understanding of European cultural diversity.

Increase in intercultural dialogue.

Greater sense of belonging to the European Union.

Stronger participation in the democratic process.

5.2. Economic impacts:

Positive effects on the local tourism industry, including number of people employed.

Development of links with cultural and creative industries.

Development of innovation and creativity.

5.3. Environmental impacts:

Negative effects linked to over-development of tourism.

Protection of cultural heritage.

The analysis of the various impacts showed that the primary direct effects of the EHL would be social ones. Economic benefits should rather be considered as secondary or indirect benefits in a first stage, although this does not preclude MS and sites from pursuing them more actively. The capacity of the EHL to have a significant impact on the number of visitors to a site may increase over time, but this will depend on the quality, credibility and prestige of the label as it develops. Environmental impacts are unlikely in general to be substantial.

The analysis also demonstrated that the transformation of the EHL into a EU initiative through a Decision by the Council and the Parliament (option 3) would bring a clear added value and enable benefits that could not be achieved by MS acting alone, even with EU financial support. Among the three sub-options of option 3, the sub-option of MS selection with an EU secretariat (3a) would probably deliver less marked improvements across the range of impacts.

Between sub-options 3b (selection at EU level only) and 3c (combined MS and EU level selection), sub-option 3b offers the prospect of a better level of improvement only concerning the increased understanding of cultural diversity, while sub-option 3c is likely to deliver greater improvements on several fronts, including increased access to cultural heritage resources, increased access to heritage for young people and, in the longer term, positive effects on the tourism industry, including the number of people employed.

6. Comparison of options

Having looked at the likely impacts of the different options we turned to an assessment in terms of three main criteria: effectiveness, efficiency and coherence. However, within these general criteria there were a range of sub-criteria to consider. These derived from the key features of the current EHL, from the Council Conclusions, from the consultation process, and from the lessons learnt from other labelling and award schemes. The criteria selected closely mirrored all of the objectives proposed for the renewed EHL.

In relation to the effectiveness of the options, we considered the fair distribution of Labels across the MS, the promotion of the European dimension of the sites, networking between the sites, the visibility and profile of the EHL, the implementation of educational activities and the implementation of cultural activities.

In relation to the efficiency of the options, we analysed the selection processes, the delivery and compliance, the administrative arrangements required, the financial impacts, and communication with other international bodies.

Finally, concerning the coherence of the options, we took into account the limitations of trade-offs across social, economic and environmental domains, the synergies and complementarities with other initiatives, and the possibility of participation by non-EU countries, although such participation is likely to take place only once the EHL is already well established.

The comparison of the options has shown clearly that, here too, sub-options 3b and 3c offer the prospect of the most significant improvements. Between the two sub-options, 3c (combined MS and EU level selection) is preferable on the grounds that it would ensure a fairer distribution of sites across Europe and hence be more likely to ensure the ownership and the commitment of all Member States. It is also likely to be more effective in relation to the visibility and profile of the EHL, since both levels could be engaged in marketing and publicity, and it would be able to draw on both MS and EU resources for selection and monitoring, whilst ensuring a consistent application of criteria. Finally, option 3c also proved to be the most cost-effective option.

6.1. Preferred policy option:

On the basis of the assessment above, as well as of the consultation process, the preferred option for the EHL is option 3c.

7. Monitoring and evaluation

The monitoring and evaluation framework of the EHL will comprise two elements which need to be distinguished:

The monitoring of the labelled sites

The aim here is to verify that labelled sites have met the obligations they agreed to undertake when they made their application and were selected. This monitoring will be under the responsibility of the MS, which will report to the European panel. After a period of dialogue, in the event that specific sites no longer meet their obligations, there will be a possibility to withdraw the Label.

The evaluation of the EHL programme as a whole

This evaluation will need to combine a focus on examining both the processes involved in operating the programme and the actual cumulative impact of the EHL at programme level. The aim will be to identify in which respects the programme is working well, where there is room for improvement and, crucially, how this improvement might best be achieved in the future. The monitoring of the labelled sites will of course feed into this evaluation. The evaluation will be under the responsibility of the Commission and will take the form of an external evaluation every 6 years.

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