CONSIGLIO NAZIONALE SULLA DISABILITA'

PIAZZA GIOVINE ITALIA, 7 - 00195 ROMA
TELEFONO  +39 06 37350087   FAX  +39 06 37350758
e-mail: sede.legale@aism.it

Al Ministro dell’ Economia e Finanze

Dr. Domenico Siniscalco

Via XX Settembre , 97

00187 ROMA

Al Ministro agli Affari Esteri

Onorevole Franco Frattini

Piazzale della Farnesina, 1

00194 ROMA

Roma, 04 ottobre 2004 

Oggetto: discussione della struttura di budget Europeo 2007-2013

Onorevole Ministro,

Le scrivo quale Presidente del Consiglio Nazionale sulla Disabilità italiano. La nostra organizzazione è membro del Forum Europeo della Disabilità (EDF), l’organizzazione ombrello che rappresenta gli interessi dei 50 milioni di persone con disabilità in Europa.

Vorrei richiamare la sua attenzione sulla nuova proposta di struttura finanziaria e di bilancio (2007-2013) che si  sta’ attualmente discutendo presso il Consiglio degli Affari Economici e Finanziari (General Affairs and External relations) ed in particolare sulla sezione relativa ai fondi strutturali.

I Fondi Strutturali costituiscono uno dei più importanti strumenti finanziari Europei atti a promuovere la qualità di vita e la inclusione sociale delle persone con disabilità e le loro famiglie.

E’ risaputo che i finanziamenti europei sono considerati uno strumento per facilitare una maggiore inclusione delle persone con disabilità nella società e che non dovrebbero contribuire al sorgere di nuove barriere, quali per esempio le barriere fisiche e architettoniche, le barriere nella diffusione delle informazioni, nella progettazione di tecnologie di comunicazione, di sistemi di trasporto, ecc. Questa affermazione è in linea con le misure inserite nella Carta dei Diritti Fondamentali e quelle dei Trattati Europei che permettono all’Europa e ai suoi Stati Membri di assumere azioni nella lotta alla discriminazione contro le persone con disabilità.

Le saprà anche quanto sia meno costoso prevedere, negli stadi preliminari di pianificazione, i criteri di accessibilità per le persone con disabilità nelle progettazioni di infrastrutture piuttosto che eseguire adattamenti negli stadi successivi o peggio al termine dei lavori eseguiti.

Naturalmente di queste riflessioni potrebbero giovare il crescente numero di persone anziane presenti in Europa ed anche il più ampio numero di cittadini.

Noi, quindi,  crediamo che dovrebbero essere previste misure che, all’interno degli strumenti legislativi e finanziari dei Fondi Strutturali e dei Fondi di Coesione, assicurino:

-          La non distribuzione di denaro, appartenente ai Fondi Strutturali, per la costruzione di edifici non accessibili alle persone con disabilità.

-          La previsione che l’allocazione dei finanziamenti serva anche per lo smantellamento delle barriere architettoniche ancora esistenti e che impediscono l’accesso delle persone con disabilità al loro ambiente.

-          L’esplicito riconoscimento dell’eguaglianza e della non discriminazione delle persone con disabilità quale priorità orizzontale nei regolamenti generali dei fondi strutturali e nei vari stadi di attuazione degli stessi.

Le chiediamo cortesemente  di riconoscere alle nostre osservazioni una grande attenzione e di riportarle al tavolo di discussione del Consiglio degli Affari Generali del prossimo 11-12 ottobre 2004 e nell’incontro del Consiglio dell’ECOFIN del prossimo 21 ottobre 2004.

Resto a sua disposizione per ogni ulteriore approfondimento ritenesse utile all’argomento.

Confidando nel suo supporto a questo importante argomento, La saluto cordialmente.

Luisa Bosisio Fazzi

EDF Response

To the European Commission Paper

“A new partnership for cohesion :

Convergence, Competitiveness, Cooperation

EDF 04/11 – May 2004

"States should recognise the rights of organisations of persons with disabilities to represent persons with disabilities at national, regional and local levels. States should also recognise the advisory role of organisations of persons with disabilities in decision-making on disability matters."

Rule 18 of the United Nations Standard Rules on the Equalisation of Opportunities for Persons with Disabilities

TABLE OF CONTENT

1      Introduction........................................................................................................................ 3

2      General comments........................................................................................................... 4

3      The future of the European Regional Development Fund............................................ 5

i) Extending and upgrading basic infrastructures.............................................................. 7

ii) Support for Information Communication Technologies................................................ 7

iii) Support for Research and Development...................................................................... 8

4      The Future of the European Social Fund....................................................................... 9

5      The Community Initiatives.............................................................................................. 11

6      Coordination and Complementarity with other Community Policies........................ 12

7      Monitoring and Evaluation............................................................................................. 13

8      Participation of Representative Disability NGOs and of Disabled People............. 13

9      Summary of Policy Recommendations........................................................................ 14

DOC EDF 04/11 EN

EDF response to the European Commission Paper : “A new partnership for cohesion : convergence, competition, cooperation”

The document is available in English, and on diskette or in large-print upon demand from the EDF Secretariat, and on the EDF Website at: www.edf-feph.org

© Copyright European Disability Forum 2004. This document may be quoted and reproduced, provided the source is given.

1    Introduction

The European Disability Forum, the umbrella body of the representative disability movement, has carefully reflected upon the proposals made by the European Commission in relation to its plan for the new architecture for EU cohesion policy and the next round of the Structural Funds post 2006 as presented in the European Commission Third Report on Economic and Social Cohesion (COM(2004)107).

The Structural Funds constitute one of the most important financial instruments at European level for improving the situation of disabled people and their families.  Over 30% of the EU budget is devoted to the Funds which play a very significant role in shaping local, regional, national as well as European policy.

Disabled persons make up 10 percent of the population of the EU.  The disability movement in Europe represents a diverse group made-up of persons with disabilities ranging from physical, sensory, intellectual disabilities, persons with mental health problems and complex and multiple disabilities.  Enlargement will mean over 45 million disabled persons in the EU who are calling for their interests and those of their families to be properly recognised and represented in the funding criteria and funding allocation of the Structural Funds.   

EDF is well aware of the considerable impact that enlargement of the EU has  on the new framework for the Funds and the fact that enlargement will bring an unprecedented increase in the economic and social disparities within the Union.   These disparities are likewise reflected across the disability movement of Europe.

EDF has been coordinator of a major capacity building project of representative disability organisations in the accession countries of Central and Eastern Europe; a project funded by the European Commission DG Enlargement.  The reports drawn-up by the National Disability Councils from these accession countries illustrate the considerable economic, social and political disadvantage disabled persons and their families face in these countries.

The European Commission proposes to simplify the Structural Funds process and thereby reduce the number of  Funding instruments from six to three (ERDF; ESF; Cohesion Fund) and to reduce the number of objectives from nine to three (convergence; regional competitiveness and employment; territorial cooperation) and four key themes (innovation and the knowledge economy; accessibility and services of general economic interest; the environment and risk protection; and the reinforcement of institutional capacity). 

EDF regrets that social inclusion has not been identified as one of the four key themes in the Commission proposal for the new Framework programme.

In the process of simplifying the system and clarifying the role of the different instruments  EDF calls for the interests of disabled persons to be given much greater recognition and  for disability issues to be mainstreamed across all the Structural fund objectives and key themes of the programme; an approach which is crucial to ensure that disabled people do not continue to be marginalised and disenfranchised from society generally. 

2  General comments

EDF considers the Structural Funds are an essential tool for:

>       reducing and alleviating social exclusion of disabled persons and their families through promotion of non-discrimination and positive action towards disabled persons in all areas of life, not just the work place;

>       promoting mainstreaming of non-discrimination policies and practices horizontally across all EU level and national level funding programmes and policies;

>       promoting an accessible physical environment for disabled persons (ie access to ICT, transport and the built environment);

>       enhancing the capacity of representative disability NGOs.

EDF shares the view of the European Anti-Poverty Network (EAPN) that Social Cohesion should be approached  and discussed on an equal basis with regional and territorial cohesion.  EDF also shares the concern of EAPN that, in order to achieve high rates of territorial cohesion, it has been at a cost in terms of increasing rates of social inequality.

EDF supports the position of the EAPN that, while the European Social Fund is seen as the main instrument for combating social exclusion, the other financial instruments of the Structural Funds, notably ERDF, should also play a major role in addressing social exclusion as one of its main objectives. 

EDF would like to stress the potential major contribution ERDF could play in reducing discriminatory access barriers disabled persons and other persons with reduced mobility (such as older people) face in their daily lives.  EDF was extremely disappointed that, despite campaigning by EDF in 1999-2000, no recognition was given to disability and accessibility in the former Framework Regulation of the Structural Funds concerning ERDF[1] The new architecture of the structural funds must not be responsible for the creation of further barriers for disabled persons; be they barriers in the built environment, in the field of transport, in the field of access to information or in the field of education, training and employment.

EDF reiterates its call for disability issues to be mainstreamed across all the Structural fund objectives and key themes of the programme and for the design of the programmes to be full accessible to disabled participants. For mainstreaming to be successful,  funding must be available to allow for any additional costs incurred by disabled persons to guarantee their full and equal involvement  in all aspects of the Funding Programmes (eg sign language interpretation; personal assistance support; accessible hotel accommodation which is usually more expensive etc).

The design of the Structural Fund programmes must better facilitate the involvement and access for NGOs who have encountered great difficulty in participating in structural funds initiatives due to the complexity and demanding administrative procedures of the Funds and the cofinancing requirement which NGOs, in particular, find to be an obstacle to their participation in the programmes.

Specific reference must be made regarding the inclusion of disabled people across all the programming documents. Attention must be given to the involvement of disabled persons with severe and complex needs.  Without proper effective programme design and implementation there is a risk that the needs of disabled persons with complex needs will be excluded from the Programmes.

There must be regular monitoring and evaluation as well as appropriate consultation with representative disability organisations.

3  The future of the European Regional Development Fund

ERDF has a major role to play in breaking down access barriers faced by all persons in our society but in particular disabled persons and older persons.  Cohesion funding has a significant impact on the urban built environment in its funding of regeneration projects and urban transport infrastructure projects.  EDF calls for there to be a mandatory conditions on accessibility attached to funding which concerns extending and upgrading basic infrastructures; support for information communication technologies and support for research and development.  There must be a requirement for all such projects to fully respect and apply accessibility requirements in the design and implementation of such projects.

This call by EDF is fully consistent and complementary with Community policy:

The revised draft constitution of the EU explicitly sets down the principle of mainstreaming non-discrimination on grounds of disability Article III-8.  Disabled persons face daily discrimination due to the fact they are unable to access public buildings, transport systems, information technologies on an  equal basis with non-disabled persons.

This call is supported in the European Commission Communication on “Equal opportunities for people with disabilities: A European Action Plan”

(COM(2003) 650 final) which explicitly states that the promotion  accessibility provisions is necessary by way of public procurement policies and in the allocation of Structural Funds at national and regional levels.

A position strongly supported by the European Parliament Resolution on “People with disabilities: fighting against discrimination and integration in the economy and society (plan)” (A5-0263/2004).

The European Parliament Resolution on the future of the Structural Funds

(A5-0272/2004)  calls for support to be given from the Cohesion Fund and the ERDF to the priority topics, particularly as regards local infrastructure, the development of infrastructure for information and communication technologies, transport and social infrastructure. The Resolution states that in relation to these priority areas, the social inclusion of disadvantaged groups should be promoted and barriers to access for people with disabilities should be removed.

This view is supported   by the EU commissioned expert report  “2010: A Europe Accessible for All 2010 report”  (October 2003) which calls for accessibility requirements to be made mandatory in all projects co-funded by European grants.  It calls for the mid-term evaluation of the structural funds to take this issue into account, and to pave the way for the inclusion of accessibility requirements in the new set of regulations for the next programming

period (2007 onward).

Furthermore, the EU Directives on Public Procurement[2] (2004/18/EC)   include provisions to promote accessibility  and employment of disabled persons.   The Directives include provisions for accessibility of works, supplies and services for disabled persons which should be included in the tendering documents for public procurement contracts.  Given that many projects co-funded by the ERDF and the ESF are subject to tendering processes the EU Directives on Public Procurement provide an indisputable justification  for accessibility to be recognized and specifically promoted in projects funded by the Structural Funds.

i) Extending and upgrading basic infrastructures

In upgrading basic infrastructures in the field of transport and telecommunications, EDF calls  for there to be a mandatory requirement that allocation of Structural funding must recognise and demand access for persons with disabilities to these infrastructures.  This requirement   complies with the provisions of the EU Directives on Telecommunications Services[3] which include requirements on accessibility to telecommunications services for disabled persons. 

Such requirements are also  in compliance with a number of EU Directives in Transport; notably in relation to urban buses[4] and railways[5] (access to infrastructure and rolling stock).  Furthermore this call from EDF corresponds with the clear and unequivocal political support of the EU member states as presented in the European Conference of Ministers of Transport Charter on Access to Transport Services, endorsed by the Member States and the European Commission.  The Charter clearly states that funding should be dependent on  respecting accessibility principles and basic accessibility standards and for public funding to be made conditional on achieving satisfactory progress with the inclusion of access features.

ii) Support for Information Communication Technologies

EDF welcomes the Commission’s intention to prioritise access to and use of information communication technologies.  An important political commitment made in the Lisbon agenda was in relation to the promotion of access to the information  society for vulnerable groups.  The European Commission recognises that the overriding purpose of the Structural Funds is to promote the Lisbon and Gothenburg Agenda.  This issue also has the political commitment of the Member States as presented in  the Council Resolution on ‘eAccessibility’ — improving the access of people with disabilities to the knowledge based society (2003/C 39/03) (6 February 2003).

Given the vitally important role played by Information Society in work, leisure, education, culture and other areas of society, it is vital that measures are taken to ensure that society reflects this development to the benefit of disabled people in all countries.

The potential of the Information Society is to create a much more inclusive society and indeed disabled people stand to gain disproportionately from effective participation. But without basic accessibility rules there is a danger that the information revolution will result in a new and more disabling barriers to full integration and contribution to society.

For instance, the development of new computer technology has dramatically reduced blind peoples’ ability to use personal computers – while 99% of PCs could be used by blind users in 1990, only 33% are accessible by blind users today.

Access to information is  essential to ensure equal participation in and access to the information and knowledge based society for  people with disabilities. Disabled people have the same rights as non-disabled people to access to government goods, services and systems, but are  heavily affected by the so called "digital divide", i.e. the gap between those who benefit from the information and knowledge based society and those who do not.

Structural Funds used to promote ICT must recognise the imperative of reducing access barriers faced by disabled persons.  The Funds must promote the rapid advancement of the Web Accessibility Initiative criteria and require, on a mandatory basis, the recipients of Funds to respect the WAI guidelines and to ensure information is made available in alternative  formats accessible for persons with disabilities.  Furthermore, the Funds must ensuring training programmes in ICT are fully accessible for disabled persons and that funding is earmarked for the specific training of disabled persons in order that they can enter the mainstream labour market on a more equal footing with non-disabled persons.

iii) Support for Research and Development

EDF calls for both a specific and horizontal approach to addressing the interest of disabled people in EU funded Research and Development activities. Given the benefit specific research and development (R&D) initiatives on disability can provide to the social integration of disabled people, specific actions on disability are important.  At the same time the horizontal nature of disability issues mean that disabled people should also be broadly recognised across all relevant sectors of the programme.

EU funded R&D activities should provide greater support to developments in EU policies towards disabled people particularly in the social field where the Research and Development programme has given insufficient attention to disability research.  At the same time research in the development of common standards for the access to transport, to the built environment, and information society are also necessary.

EDF considers that one of the weaknesses of former EU research programmes has been low level of user participation in the selection, implementation and evaluation process for projects. 

Proactive user participation in the new Framework Programme will be an asset to future developments in the field of assistive technology, as well as in the developments of design for all in the mainstream industry. Users can play an important part in identifying problems and in generating ideas.  Disabled user participation in relevant R&D programmes must be an imperative.

4  The Future of the European Social Fund

EDF supports the attention of the European Commission on the future programmes aimed at progressing full employment, quality and productivity at work and the promotion of social inclusion.  It is important that disabled persons, as one of the most vulnerable groups in this regard, are given specific recognition.

ESF is intended to advance the priorities of the European Employment Strategy (EES) and support the key policy initiatives of the Employment NAPs.  The EES has demonstrated very little impact with regard the employment status of disabled people as identified by the European Commission in the 2002 mid-term review of the European Employment Strategy.  Disabled people are 6 times more likely to be unemployed than disabled people. Disabled graduates are 4 times more likely not to be able to find a job than non-disabled graduates.  70% of disabled people in work are in manual or unskilled jobs.

EDF, therefore, welcomes the specific attention disabled persons will be given in ESF objective 2 – specific intervention ‘increasing the employment potential, access and inclusion of people with disabilities, migrants and ethnic minorities’.

However, EDF is concerned about the plans of the European Commission to dissolve the EQUAL programme which will, thereby, considerably diminish the ‘non-discrimination’ dimension in the Structural Funds and ESF in particular.   This non-discrimination dimension is imperative in order to progress social inclusion of disabled people.

EDF calls for the principle and practice of non-discrimination to be made an overarching issue in the ESF programme and across the Structural Fund programmes in general.

Given the fact that of all the vulnerable groups, there is evidence that disabled persons have benefited least from ESF in terms of reducing unemployment it is imperative that funding is earmarked for specific disability projects as is currently the situation for projects promoting  gender equality.

EDF shares the view of EAPN that the proposals in  the Third Cohesion Report do not sufficiently recognise the value of transitional labour markets which provide important experience, training and work of value for marginalised individuals and groups. 

Training targeted at disabled people must be, as far as possible, integrated into the mainstream training courses  funded by ESF.

There is a risk that specialised training for disabled people focuses on ‘rehabilitation’ issues only and is further removed from the labour market making it more difficult for disabled people to gain entry into the labour market.

The emphasis of ESF has been on training and adaptation of disabled people to improve their employability.  More emphasis needs to be placed on the appropriate training of employers and trainers to ensure they facilitate and support the entry of disabled persons into the labour market.

ESF has focussed considerably on social inclusion of vulnerable groups through the labour market.  It must be recognised that many disabled persons, in particular those with complex dependency needs and severe intellectual and cognitive disabilities, will not be able to access the labour market.  ESF and the other financial instruments must, therefore, address wider social exclusion issues and not enhance the conception that ‘employability’ defines the value of a person.

Accessibility must also be recognised among the criteria for the funding of ESF projects; for example ESF funded projects on vocational training MUST be held in accessible buildings;  sign language interpretation must be available on demand and information must be made available in accessible formats. This approach is fully consistent with the EU Directives on Public Procurement (2004/18/EC).  

The interests of vulnerable groups must be developed across all the main policy areas of the ESF programme - life long learning policies and strategies; in-company training and the fostering of entrepreneurship etc.

In strengthening delivery systems it is important to  ensure measures are taken to fully involve organisations of disabled persons in the activities supported by the programme and that disability organisations are also involved in the consultation process and in the development of the projects and activities supported by the Programme.

5      The Community Initiatives

EDF has important concerns about  the abolition of EQUAL which, while intended to mainstream the priorities of this Community Initiative into ESF,  could in practice mean a lessening of focus on the specific interests of disabled persons and a further deterioration in effectiveness of ESF in terms of  combating the obstacles disabled persons face in accessing the mainstream labour market.

As previously mentioned, EDF is concerned, that by dissolving the EQUAL programme the ‘non-discrimination’ dimension in the Structural Funds will be considerably weakened.   This non-discrimination dimension is imperative in order to progress social inclusion of disabled people.

The emphasis on partnership, described by the Commission as ‘the main vehicle for innovation’  and transnational collaboration is unique  to the way in which Community Initiatives operate.   EDF understands that one third of all partnerships have been led by NGOs which is a welcome fact.   Such NGO-led partnerships are likely to be considerably diminished or lost if the Community Initiative EQUAL is to be mainstreamed into ESF given that the ESF programme is less accessible to NGOs than are the Community Initiatives.  Furthermore the obligation for the ‘richer’ Member States to partner with the poorer Objective 1 Member States provides an important means whereby stakeholders in these different European regions can exchange best practice and information; it can promote a means whereby more prosperous European regions can provide support to the least prosperous regions in Europe.

EDF is aware that the conclusions of the European Commission’s Cohesion Report (February 2004)  came in advance of the final evaluation report of EQUAL which was only just made available end April 2004.  The recommendations of the Cohesion Report to abolish the EQUAL programme were, therefore, made prematurely.

There is a real danger that by abolishing the EQUAL initiative it could have the effect of side-lining vulnerable groups such as disabled persons thereby not at all addressing the principle issues of concern in relation to addressing socio-economic development in Europe.

6  Coordination and Complementarity with other Community Policies

It is vital that disability policy is addressed horizontally across  the framework of the Structural Funds and in complements the different Community programmes and initiatives, which impact on disabled persons.

Comprehensive strategies must be sought which involve disabled people themselves as the primary stakeholders and the different aspects of disability policy cannot be developed in isolation.  Barriers to the participation of disabled people are inherently linked; for example, disabled people who receive sub-standard education will be less likely to find meaningful employment. If disabled persons are constantly faced with physical access barriers in the built environment they will never be able to fully participate in society.

It is important to note that commitments have been made by the EU institutions to promote the social inclusion and non-discrimination of disabled people in all areas of life; commitments which are both legislative and non-legislative.

Notably:

>       The Council Directive 2000/78/EC of 27 November 2000 establishing a general framework for equal treatment in employment and occupation

>       The European Commission Communication on “Equal opportunities for people with disabilities: A European Action Plan” (COM(2003) 650 final)

>       The EU Directives on Public Procurement (2004/18/EC) & (2004/17/EC) which includes specifications on accessibility in the technical requirements of the Directives and allows for social criteria to be used in the selection of contracts.

>       The Commission communication on Towards a Barrier Free Europe for People with Disabilities (COM(2000)284 FINAL)

>       EU legislation in the field of transport and ICT  which incorporate disability and accessibility provisions (as specified previously in this paper)

7  Monitoring and Evaluation

All levels of management and implementation of initiatives supported by the Funds which are targeting disabled people should be subject to independent  continuous monitoring and evaluation;  monitoring and evaluation which fully takes on board the views and experiences of disabled people involved in the projects and initiatives.

Evaluations, particularly those linked to human resources, should focus on qualitative criteria and not relate purely to finance and cost benefit. Furthermore, there should be recognition that outcomes which further the independence of disabled persons and enhance social and personal development are as important as those relating to employability.

Emphasis should be placed upon the transferability of the results of structural fund projects. NGO networks can play a primary role in evaluating this and subsequently encouraging information dissemination.

8  Participation of Representative Disability NGOs and of Disabled People

EDF calls on the Commission to ensure that the fourth priority theme ‘institutional capacity’ must apply to the NGOs as well as to the governmental sector.

EDF would like to reiterate the importance of involving representative organisations of disabled people at all levels of decision-making for the Funds. At European level, in the spirit of "civil dialogue" representative European NGOs must be consulted when core documents are drafted outlining general regulations and procedures for the Structural Funds. At national level, there must be proper consultation on operational programmes, and meaningful involvement of national councils of disabled people in the national "monitoring committees".

9  Summary of Policy Recommendations

>       All financial instruments of the Structural Funds, must play a major role in addressing social exclusion and discrimination;

>       Call for disability issues and the principle and practice of non-discrimination to be mainstreamed across all the Structural fund objectives and key themes of the programme;

>       The Social Cohesion should be recognised and approached  on an equal basis with regional and territorial cohesion;

>       Call for there to be a mandatory conditions on accessibility attached to funding which concerns extending and upgrading basic infrastructures; support for information communication technologies and support for research and development;

>       Funding must be available to allow for any additional costs incurred by disabled persons to guarantee their full and equal involvement  in all aspects of the Funding Programmes;

>       It is imperative that funding is earmarked for specific disability projects within ESF and ERDF;

>       Accessibility must also be recognised among the criteria for the funding of ESF and ERDF projects;

>       ESF and the other financial instruments must address wider social exclusion issues and not simply enhance the conception that ‘employability’ defines the value of a person;

>       More emphasis needs to be placed on the appropriate training of employers and trainers;

>       Call for the participation and consultation with representative Disability NGOs at all stages of the process (decision making on priorities, project selection, project design, implementation, monitoring evaluation).