EDF Response to the Commission Communication on the Community Strategic Guidelines 2007-2013

EDF response to the Commission Communication on the Community Strategic Guidelines 2007-2013 (COM(2005)0299)

DOC EDF 05/09 EN

September 2005

"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

List of contents

1. The interest of disabled persons in the Cohesion policy’s support for growth, jobs and the Lisbon process

2. Advancing visibility of disability in the cohesion policy agenda

3. Other aspects to include in the cohesion policy agenda

4. EDF’s proposals for specific amendments to the Commission Communication on the Community Strategic Guidelines 2007-2013

APPENDIX – About EDF and other documentation

DOC EDF 05/09 EN

EDF response to the Commission Communication on the Community Strategic Guidelines 2007-2013 (COM(2005)0299)

The document is available in English, and in alternative format upon demand from the EDF Secretariat, and on the EDF Website at:

© Copyright European Disability Forum 2005. This document may be quoted and reproduced, provided the source is given.

1. The interest of disabled persons in the Cohesion policy’s support for growth, jobs and the Lisbon process

The European Disability Forum, the representative body of the European disability movement, considers that the Structural Funds and the Cohesion policy has a key role to play in the generation of employment for all. The policy and the structural fund mechanism should ensure long term sustainable approaches to growth and ensure the inclusion of all persons in society, including disabled persons, into the mainstream.

It has been demonstrated by the European Commission’s own evaluations of the European Employment Strategy that, so far, there has been little or no improvement in the employment rate of disabled persons into the mainstream labour market in Europe.

Much more needs to be done to raise awareness and to train employers about the benefits of employing a diverse workforce and, thereby, of employing disabled people.

The Structural Funds should complement and support the European Commission Action Programme on Non-Discrimination to promote, full and effective implementation of the Employment Equality Directive 2000/78EC. The Structural Funds programme should raise awareness among decision makers and train employers and representative organisations of disabled persons about the principle and practice of reasonable accommodation.

Furthermore, much more effort is needed to ensure the Structural Funds give full and equal access for disabled persons to mainstream vocational training schemes.

Positive actions measures should be supported by the Structural Funds to give disabled people a chance to access the labour market in view of the discrimination and disadvantage disabled persons continuously face.

The Structural Funds should systematically ensure the principle of design-for-all and disability access is recognised as a requirement for infrastructural development projects, developments in the built environment, public transport and information communication technologies.

EDF has prepared a number of proposals for amendments, in this respect, to the Commission paper on the Guidelines which are set out later in this document.

2. Advancing visibility of disability in the cohesion policy agenda

The European Disability Forum, the umbrella body of the representative disability movement, recognises that the Structural Funds constitute one of the most important financial instruments at European level for improving the situation of disabled people and their families.

Disabled persons make up 10 percent of the population of the EU. EU Enlargement means that over 45 million disabled persons in the EU 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.

Given the role the Structural Fund has in supporting infrastructural development across Europe, notably in the field of built environment, transport and information communication technologies, employment and vocational training, the Funds can assist in an extremely important way to advance and promote the issue of accessibility for disabled people to the physical environment as well as to promote the wider social inclusion of disabled people.

EDF welcomes the existing references to non-discrimination and disability access in the Commission communication on the Strategic Guidelines but considers they could be emphasised more. There are areas identified in the amendments EDF proposes where the issue of disability access is of direct relevance, notably in sections which set out the general context and the principles of cohesion policy and structural fund support.

EDF is concerned that, if the issue of accessibility for disabled persons is not included in these sections, it could be overlooked in the design of the national operational programmes and in the implementation of the programmes and projects.

The issue of accessibility and non-discrimination of disabled people should be given explicit recognition in the Strategic Guidelines as both a horizontal and specific issue and this approach should be recommended and adopted by the national operational programmes.

Representative organisations of disabled persons should be fully involved and consulted in the drawing up and implementation of the operational programmes to ensure the interests of disabled persons are properly included in the design of the operational programmes.

3. Other aspects to include in the cohesion policy agenda

EDF considers that the main issues identified in the Commission communication are all relevant but considers that the principle of non-discrimination and disability access should be more strongly recognised as a horizontal as well as a specific issue by the Structural Funds as is the case with gender equality. Disabled persons make up 10% of the population of Europe – a very significant population. Equality and integration of disabled persons cannot be achieved if the needs of disabled persons are not recognised in mainstream policy.

The EU commitment to social inclusion of disabled persons and non-discrimination towards disabled persons needs to be recognised and actively supported by the EU funding schemes. The Structural Funds represents the second most important EU funding scheme and impacts in an important way in shaping the public environment across Europe.

Disability access and non-discrimination is a horizontal issue impacting across all aspects of regional development. If disabled persons are to have any chance of living their lives on an equal basis with non-disabled persons, of being active in the community, active in the labour market and active in the European economy there must be horizontal measures taken by the Structural

Funds programme to ensure no further environmental barriers are created and existing barriers to environment and goods and services are removed.

4. EDF’s proposals for specific amendments to the Commission Communication on the Community Strategic Guidelines 2007-2013

Part 2.2 The contribution of cohesion policy to growth and jobs

EDF considers it important to include explicit in the EC commitments to non-discrimination and the mainstreaming of disability access when referring to synergies and complementarities with Community policies. The principles and practice of non-discrimination and disability access are crucial to promoting social sustainability and should not be neglected across the mainstream of Structural Funds programmes.

EDF proposes the following wording

(page 7 of communication)

Developing synergies and complementarities with other Community policies.

Cohesion policy acts as a powerful lever for the implementation of other Community policies. For example, Trans European Network projects are financed directly by the Cohesion Fund in the cohesion countries, leading to substantial gains in accessibility to the rest of Europe; compliance with the environmental acquis and with the broader aims of sustainable development, to include social sustainability and accessibility for disabled persons and older persons, is strongly supported by cohesion policy; RTD policy and its concerns with, in particular, research infrastructures and the development of human resources in research is also supported by cohesion policy, as are Community innovation and SME policies.

In respect to the reference to ‘Improving governance’ the importance of consultation and partnership with civil society should be explicitly referred to. Partnership serves to strengthens both society’s sense of ownership of the projects funded and the legitimacy of the cohesion policy. At a time when legitimacy of EU policies and efficiency of its expenditure are seriously debated, partnership in cohesion policy needs to be strengthened.

EDF proposes the following wording

(page 7 of communication)

Improving governance. The unique delivery system for cohesion programmes favours improvements in institutional capabilities in policy design and implementation; the dissemination of an evaluation culture; public–private partnership arrangements; the promotion of civil dialogue and consultation with civil society; transparency; regional and cross-border cooperation; and the exchange of best practices. It also contributes to better governance at all levels by improving responsibility and ownership of the Lisbon strategy at sub-national level.

Part 3 The Framework for Cohesion Policy 2007-2013

3.1 Concentration

EDF proposes the following wording

(page 8 of communication)

Growth in economic output is essentially composed of two drivers: employment and productivity growth. They are intimately related and must be boosted simultaneously to achieve maximum impact. In order to promote under the national and regional development programmes, 2007-2013, a sustainable development path and strengthen competitiveness in the knowledge-based economy, it is essential to concentrate resources on basic infrastructures, human capital, and research and innovation, including access to and strategic use of information and communication technologies (ICTs). Resources devoted to basic infrastructures, research and innovation and ICT must take due account of the access needs of disabled people. Both tangible and intangible assets are required.

3.2 Convergence

EDF proposes the following wording

(page 9 of communication)

Their strategies therefore will focus on the investments and collective services which are required to increase long-term competitiveness, job creation and sustainable development.

Basic infrastructures and services will need to be created, upgraded and expanded in order to open up regional and local economies, set up a proper business support framework and exploit the opportunities afforded by the Single Market. Resources devoted to basic infrastructures and services must take due account of the access needs of disabled people. Moreover, substantial efforts are required to expand investment in human capital; increase access to employment; strengthen social inclusion and non-discrimination; and introduce and implement reform in education and training systems.

3.3 Regional Competitiveness and Employment

EDF proposes the following wording

(page 9 of communication)

The aim of the new regional competitiveness and employment objective is to anticipate and promote economic change by improving the competitiveness and attractiveness of EU regions through investments in the knowledge economy, entrepreneurship, research, university-enterprise cooperation and innovation; access (to include also access for disabled persons) to transport and telecommunication infrastructure, energy, and health; environment and risk prevention; supporting the adaptability of workers and enterprises; reinforcing participation in the labour market; and promoting social inclusion and sustainable communities.

3.4 Community contribution rate

EDF proposes the following wording

(new provision)

Call to not prejudice the participation of not-for-profit NGOs when calculating the co-financing rate contribution from the Funds for all operational programmes. Not-for-profit NGO expenditure shall be considered as similar eligible expenditure.

4. Guidelines for Cohesion Policy 2007-2013

EDF proposes the following wording

(page 12 of communication)

– improving the attractiveness of Member States, regions and cities by improving accessibility (to include also access for disabled persons), ensuring adequate quality and level of services, and preserving their environmental potential;

EDF proposes the following wording

(page 13 of communication)

MemberStates and regions should pursue the objective of equality between men and womenand non-discrimination of Article 13 TEC groups at all stages of the preparation and implementation of programmes and projects. This may be done through specific actions to promote equality for all or to combat discrimination, as well as by taking careful account of how other projects and the management of the funds may affect women and men and specific groups vulnerable to discrimination.

4.1.1. Expand and improve transport infrastructures

EDF welcomes the recognition of the need to provide for accessibility to common public transport services for certain target groups, notably disabled persons and older persons as expressed in the guidelines for action on transport networks and public transport facilities.

EDF considers that a reference to disability access to public transport should also be made in the opening explanatory section of section 4.1.1 in order to provide a context for the guidelines for action.

EDF proposes the following wording

(page 14 of communication)

In order to maximise the benefits deriving from transport investments, assistance from the Funds must be based on a number of principles.

First, objective criteria should be used to determine the level and nature of the infrastructure investment to be undertaken………, due account must also be taken of environmental and social implications of prospective infrastructure projects including the importance and wider social benefits of promoting access for disabled persons and older persons to transport infrastructure.

4.2.3 Promote the information society for all

EDF welcomes the recognition of the need to provide for accessibility to ICT products and services notably for disabled persons and older persons as expressed in the guidelines for action.

EDF considers that a reference to disability access to ICT should also be made in the opening explanatory section of section 4.2.3 in order to provide a context for the guidelines for action.

EDF proposes the following wording

(page 21 of communication)

Policy measures should therefore focus on….transfer between research institutions and enterprises. Measures should also focus on promoting design-for-all and accessibility to ICT for disabled persons and an ageing population….

4.3.3 Increase investment in human capital through better education and skills

It is extremely important that disabled persons are able to access the mainstream education and vocational training schemes funded through the Structural Funds. The accessibility to these schemes must be an explicit consideration and requirement.

Therefore, EDF calls for an explicit reference to be made to disability access in section 4.3.3.

EDF proposes the following wording

Page 27 of the communication

The following general priorities should be addressed:

-supporting coherent and comprehensive lifelong learning strategies…..Particular attention should be given to addressing the needs of disadvantaged groups including the access needs of disabled persons to mainstream education and training courses.

APPENDIX – About EDF and other documentation

1About EDF

The European Disability Forum (EDF) is the European umbrella organisation representing the interests of 50 million disabled citizens in Europe. EDF membership includes national umbrella organisations of disabled people from all EU/EEA countries, accession countries and other European countries, as well as European NGOs representing the different types of disabilities. The mission of the European Disability Forum is to ensure disabled people full access to fundamental and human rights through their active involvement in policy development and implementation in Europe.

2Other relevant EDF documents:

3Contact person at the EDF Secretariat:

Sophie Beaumont

Tel :+322 282 46 02, E-mail :

More information about EDF is available on the EDF homepage at: Should you have any problems in accessing the documentation, please contact the EDF Secretariat. (T: +32-2-282.46.00)

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EDF response to the Commission communication on the Community Strategic Guidelines (COM)2005)0299

EDF 05/09 - September 2005