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Document 52015IR6648

Opinion of the European Committee of the Regions — Tourism as a driving force for regional cooperation across the EU

OJ C 185, 9.6.2017, p. 15–23 (BG, ES, CS, DA, DE, ET, EL, EN, FR, HR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)

9.6.2017   

EN

Official Journal of the European Union

C 185/15


Opinion of the European Committee of the Regions — Tourism as a driving force for regional cooperation across the EU

(2017/C 185/03)

Rapporteur:

Hans-Peter WAGNER (AT/EPP), Mayor of Breitenwang

POLICY RECOMMENDATIONS

THE EUROPEAN COMMITTEE OF THE REGIONS

Multi-level governance

1.

supports the EU’s policy to maintain Europe’s leading position as most frequently visited region in the world accounting in 2015 for 51,4 % of all international tourist arrivals equivalent to some 609 million persons (1) and to maximise this sector’s contribution to sustainability, innovation, economic growth and employment;

2.

highlights the fact that, under Article 195 TFEU, tourism comes under the responsibility of the Member States and that the EU shall have competence to carry out actions to support, coordinate or supplement the actions of the Member States, and thus also of regional and local authorities, in this field. Regional and local authorities have a key role to play here given their competences, with many regions having exclusive competences in this sector. Given the importance of tourism for the internal market, cooperation between Member States and the regional and local levels of government in keeping with the principle of subsidiarity and multi-level governance is necessary, as are common European principles, criteria and measures with European added value;

3.

calls on the European Commission (EC) to revise the 2010 tourism strategy, to launch an integrated EU tourism policy relating to all relevant EU policies, to improve tourist confidence in the tourism sector as a whole, to strengthen the EC’s approach towards seasonality and to propose a multiannual work programme with clear goals, indicators and measures for tourism;

4.

asks the EU Member States, based on the EU tourism strategy, to develop national tourism policies in consultation with local and regional authorities;

5.

asks that a section on tourism be added to all macro-regional strategies  (2). The EC is urged to draw up, together with the CoR, a catalogue of topics with possible tourism objectives for macro-regions;

6.

underlines that tourism is today one of the fastest growing economic sectors in Europe; a sector that drives global growth and development, creates millions of jobs, spurs exports and investment and transforms peoples’ lives; a sector that supports the sharing of cultural diversity and values and actively contributes to gradual consolidation of a European identity among the younger generations;

7.

calls on regions and cities to subsequently devise strategies for tourism which are in line with European and macro-regional strategies, and also calls for public-public cooperation and public-private partnerships to develop, promote and implement new tourism infrastructure bearing in mind the needs of an ageing European population and enabling senior citizens to travel barrier-free across the Union. These strategies must be combined with plans to reinvigorate tourist destinations, by improving both public and private resources and facilities, that make them more competitive. Improvements must also be made in mature destinations where over time, the capacity of existing resources to attract tourist flows has declined;

8.

calls on the Member States and the European Commission to enable and actively support cross-border cooperation of local and regional authorities in the field of tourism;

9.

calls for cross-sectoral local as well as regional platforms  (3) to link, strategically develop and market destinations (4), to pursue the dialogue and exchange of good practices and of the know-how about the use of the EU financial instruments;;

10.

points out that tourism is one of the most important policy areas for cross-border cooperation in Europe. Cross-border cooperation structures including EGTCs and Euroregions are urged to facilitate cross-border, transnational and inter-regional cooperation by means of cross-border tourism strategies (e.g. transport or marketing strategies), thus creating wealth, boosting employment and ensuring regions can offer more to consumers. In so doing they should make use of all possible European funds (e.g. EFSI, ESIF, Interreg, Horizon 2020) involving highly experienced organisations, groupings or networks related to the sector;

Tourism and infrastructure

11.

calls for public and private funds to be used for long-term improvements to travel and tourist infrastructure (5) in outlying regions, mountainous regions, islands and coastal areas, which in many domains also provides services of general interest, so as to secure the accessibility, supply and competitiveness of tourist regions, and calls for

improvements to the system by which Eurostat (or other organisations like the European Travel Commission or the United Nations World Tourism Organisation) collects and processes data on tourist flows (transit and destination-bound tourist traffic)

Eurostat to be involved in providing more territorial breakdowns of information (above NUTS 2(1)) and adjusting to new needs and requirements (e.g. taking on board accessibility variables, CO2 emissions). This will enable destinations to access solid and comparable data to evaluate and improve the use of resources from the sustainability point of view;

capacity and destination management to be supported, so as to deal with the immense transport-related and environmental pressures and the excessive burden on infrastructure in tourist regions at all levels of government;

financial incentives to even out tourist flows and coordinate them across Europe (6), with a clear commitment to levelling out seasonal peaks and troughs;

a review of the EC White Paper for a competitive, Europe-wide transport system, in particular to reduce transit traffic in sensitive regions (including urban population centres and natural regions) and to ensure a fully joined-up door-to-door travel chain, information about public transport and existing services (7), and measures to promote public transport, in particular rail travel (8), as well as measures to promote European and national cycle routes and long-distance footpaths;

12.

calls for issues related to combating terrorism, security, particularly in public places, and civil protection to be included in European, national and regional tourism strategies; in particular emergency communication and management in national, regional and local emergency plans and procedures;

Investment in the tourism sector

13.

calls on the European Commission, when conducting the mid-term review of the Multiannual Financial Framework, to radically rethink its approach to tourism in the ESI Funds, since at present it has in effect excluded support for tourism from these funds in some countries, even though many of their regions have poorly developed areas where tourism is virtually the only possible means of development (national parks, protected areas, and so on);

14.

stresses that investments must be made in the competitiveness of European tourism. SMEs, in particular, need to make better use of the digital single market strategy and its stimulus packages (EFSI, ESI, EMFF, Interreg, URBACT, LIFE, Horizon, COSME, Creative Europe, Erasmus+, EaSI) (9). In this regard, support and training initiatives for SMEs with regard to making more effective use of funding would be welcome;

15.

supports the call to introduce a budget heading for promoting European tourism into the annual EU budget to finance innovative, competitive, sustainable, cross-regional and cross-border projects, and also supports more consideration of investments with relevance to tourism in post-2020 EU regional policy. EU funding must ease the strain on SMEs and the bureaucratic burden that managing funding entails must be significantly reduced;

16.

calls on the Member States and their regional authorities to include tourism priorities in their operational programmes post 2020, to enable public authorities and the private sector to access funds to finance their projects; aware of the rapid pace of the demographic change, recommends to favour initiatives aimed to adapt tourism infrastructure and transport means to the needs of an ageing population;

17.

calls on Member States to

accelerate digitalisation in the tourism sector and in particular to develop high-speed broadband internet in outermost, outlying, sparsely populated and mountainous regions,

recommends that public authorities tap into the potential of Digital Agenda for Europe and use the opportunities it creates to boost their eHealth services for the benefit of citizens and travellers alike,

take measures to guarantee a significant year-round flow of visitors,

promote longer average stays at destinations,

enhance the skills and employability of those working in the sector,

adopt sustainability as one of the main criteria in managing destinations and tourism products, and

set up expert forums on promoting best practices, in particular for SMEs;

18.

regrets that SMEs’ lack of knowledge means that they do not make sufficient use of the EFSI and supports the establishment of regional investment platforms under the EFSI to enable SMEs to have access to information and know-how, following the example of regional development (e.g. ‘the ALPS’ (10)). As part of the implementation of the ‘Invest and Connect’ declaration (11), adopted at the seventh European Summit of Regions and Cities in Bratislava, the CoR thus recommends to the EC and the EIB that they collectively set up a Europe-wide investment platform for tourism-related SMEs and jointly hold local tourism investment forums under the EFSI. Specifically, five pilot projects should be carried out in model regions by 2018 (rural/remote or outermost, mountainous, border, island/coastal regions, and cities), possibly also involving networks such as NECSTouR, the Association of European Border Regions, European Groupings of Territorial Cooperation or Euroregions;

19.

calls on regions and EGTCs, together with the EFSI steering board and the EIB, to motivate banks in their regions to bring in investment programmes facilitating cross-border investment and making it easier for tourism-related SMEs to access EU funding and private sector funds (PPP models);

20.

calls on the EC to support cross-border small and micro-projects in the field of tourism as well as ‘people-to-people’ projects, which make a major contribution to a sense of European identity, especially in border regions;

21.

reiterates its call for the de minimis thresholds in the case of state aid for SGEIs, which often also benefit tourism-related, to be increased to EUR 1 million per case per three tax years. In regions whose economic and social stability depends substantially on tourism and where unemployment is high, these thresholds should also apply to public investment in tourism-related infrastructure, inasmuch as this is also regularly used by the local population. Recalls at the same time that the current General Block Exemption Regulation (EU) No 651/2014 applicable until 31 December 2020 already covers aid for culture and heritage conservation and aid for sport and multifunctional recreational infrastructures;

22.

underlines that tourism is a key strategic element for many less developed regions with significant economic and environmental potential that has not yet been fully harnessed;

Better regulation

23.

draws attention to difficulties with the regulatory framework and recommends that the Member States to avoid unnecessary tightening of EU legislation by means of national regulations (gold plating). Under REFIT, the CoR recommends that the EC should take the following tourism-specific initiatives:

simplify regulations for broadband service providers and move towards taking a market-based and technologically neutral approach;

review the disclosure and information requirements under the EU Consumer Rights Directive;

review and, if appropriate, revise the Package Travel Directive; excessive bureaucracy should be avoided, as should legal uncertainty;

relax the information requirements under the EU Food Information Regulation (No 1169/2011) for the hospitality industry;

simplify the applicable rules relating to taking liquids onto flights (12);

24.

calls for town centre regeneration strategies, when scoping future needs of investment in regeneration or infrastructure, to give careful consideration to the potential impact of such investments in terms of protecting or increasing local attractiveness for tourism activities and improving accessibility for citizens and visitors with reduced mobility;

Thematic tourism

25.

proposes the promotion of thematic tourism projects  (13) in the sense of smart specialisation (smart regions/cities) so as to counteract the negative effects of mass tourism, and also suggests introducing the title of ‘European Capital of Smart Tourism’, to be awarded to up to three EU cities/regions per year by representatives of the tourism industry, the EC, the EP and the CoR. In so doing particular attention should be given to the promotion of sustainable and competitive tourist destinations as an added value to the European Destinations of Excellence (EDEN). Outside city centres and well established urban magnets should be taken into consideration so that urban nodes at peripheries of metropolitan areas or small and medium sized towns also benefit;

26.

emphasises that city tourism creates spatial dynamics for transforming the urban landscape through the rejuvenation of public space, infrastructure and connectivity, development of local amenities and recreational facilities. This benefits not only tourists but also local communities and citizens;

27.

calls for cultural, natural, historical and religious tourism to be supported, which contributes to employment, multicultural understanding and local, regional and rural development, and calls for tourist attractions to be linked so as to create European, national and local thematic trails, like the Unesco-declared World Heritage cities and sites. To this end, a European Network of World Heritage Cities should be set up, and specific measures taken to preserve them and make them better known;

28.

reiterates that health and wellness tourism is one of the fastest growing tourism branches, attracting elderly Europeans and visitors from third countries and recommends strengthening the connection between tourism and the silver economy agenda;

29.

emphasises that rural tourism preserves local communities by creating jobs, stimulating development, protecting the environment, supporting rural culture, arts and handicrafts, and calls

on rural regions to build on regional development strategies to develop integrated and cross-border strategies to expand rural tourism such strategies should focus on seamless transport connections enabling barrier-free mobility to and within rural areas;

for support for SME partnerships to provide a service by means of a broad introduction of innovation coaches advising multiple companies, so as to attract urban guests;

to develop forums and platforms enabling SMEs to generate complementary products of higher value to tourists,

on the rural areas to pay more attention to cultural heritage in their development strategies as it contributes to safeguarding and creating jobs, supporting agricultural businesses, protecting cultural landscapes, supporting rural arts and handicrafts,

in this context, on the Common Agriculture Policy post-2020, to include a tangible support to the tourism-related SMEs in the rural areas to further foster agro tourism;

30.

flags up the major role played by culinary tourism in creating new, sustainable jobs and points out that the development of this sector of tourism aims to promote high-quality traditional and local products. Given that more than one third of tourist spending is devoted to food consumption, the culinary arts are a safe and vital source of revenue;

31.

reiterates its support for the European Capitals of Culture (ECOC) and the European Heritage Label (EHL) initiatives, as well as for the European Heritage Days and the European Union Prize for Cultural Heritage;

Climate change and sustainable development

32.

recalls that tourism safeguards economic growth, incomes and employment in many regions. The CoR calls on the regions to consider sustainability  (14) in their tourism strategies  (15) including innovative tools to monitor and increase the sustainability of tourism in terms of its environmental, social and economic aspects (ETIS), so as to provide a holistic approach that anticipates and deals with increased environmental pressures as a result of tourism-related activities. EU cohesion policy should provide targeted support to the development of these strategies;

33.

calls for a European legislative solution to the collaborative economy trend, which, in addition to positive effects, also carries risks such as a lack of social protection for workers, a lack of provisions in respect of the accommodation of customers/tourists, the transfer of risk from employers to employees and negative fiscal effects and lack of quality control of destinations;

34.

supports development of sustainable cultural tourism in cities which can be a vital catalyst for revenue generation for innovative practices in heritage conservation and management. Tourism in cities also stimulates innovation. Use of information, communication technologies and the smart city concept which not only creates a quality visitor experience but also improves the quality of life of the local population;

35.

invites tourist regions, in the light of climate change, to diversify their economic focus — in particular, conditions in mountain and coastal regions are favourable for renewable energy production (water/wind, solar, geothermal, biomass power) and to invest together with the sector in climate-friendly projects using tools such as the Hotel Energy Solutions (HES) (16) and the Nearly Zero Energy Hotels (neZEH) (17);

36.

calls on the EC to support campaigns to raise awareness in the sector about sustainable management of natural resources (in terms of reducing water consumption, food waste and the use of detergents and hygiene products);

Labour market, education and research

37.

calls for further EC and Member State measures to ensure formal cross-border recognition of tourism qualifications, as well as multi-faceted training to reduce seasonality. The recognition of qualifications must comply with a stringent standard (18);

38.

underlines the need to fight the use of undeclared or under-declared work, which is particularly widespread in the tourism sector (19);

39.

calls on the Commission, under the aegis of the EURES network with national employment agencies, to develop tourism-specific programmes for the Europe-wide placement of qualified workers in tourism-intensive regions;

40.

calls on local and regional authorities and employment agencies to set up qualification partnerships with the tourism industry so as to provide training in the context of lifelong learning, in order to develop quality (sustainability, support, safety, etc.) and marketing (digitalisation) in the tourism sector;

41.

welcomes the adoption of the new Sustainable Development Goals (20) (SDGs) by the United Nations General Assembly at its 70th Session and highlights that among the 17 SDGs tourism explicitly featured in Goals 8, 12 and 14 for its capacity to foster economic growth, inclusiveness and decent work for all, promote sustainable consumption and production and advance conservation and sustainable development of aquatic resources — noting the key lines of action — advocacy and awareness raising, knowledge creation and dissemination, policy making, and capacity building and education;

42.

proposes, in the context of the European education offensive, that

PPP-initiatives should be supported in order to spur the professionalisation of the sector by connecting training and practice (21);

tourism-related vocational schools, vocational colleges and universities should be linked and the influence of Erasmus+ on the tourism sector should be evaluated;

a European tourism academy and a Jean Monnet chair for European tourism research should be established;

43.

calls on the Member States, regions and cities to integrate migrants and asylum-seekers more rapidly into the labour market, and to make use of the language and specialist skills of migrants and develop them through courses;

Tourism and European citizenship

44.

underlines that European citizens engaging in tourism in the EU are consumers protected by EU law and are able to move freely throughout the EU internal market and the Schengen area. Tourism therefore has a very important role to play in forging a sense of European citizenship and promoting mutual understanding. Therefore, incentives should be created to encourage European citizens to take more holidays in Europe. The CoR urges the EC and the Member States to reflect on the following ideas while respecting the principle of subsidiarity and applying multilevel governance:

free InterRail tickets for young Europeans when they turn 18 to enable them to explore and know Europe better, as proposed by the European Parliament (22);

offer EU citizens travelling in the EU reduced prices for public transport (including for bicycle carriage and bicycle hire facilities), museums, etc. by means of a free ‘European Citizen Travel Card’, which Member States, regions and cities can volunteer to participate in; the card should be available on the CoR and EC websites, in all Europe Direct information centres, and from participating tourism associations, and be valid in conjunction with an ID or passport issued by an EU country;

create an electronic European travel badge (social media-compatible GPS‘DiscoverYrope app’);

bring in a ‘European Traveller’s Pass’ containing useful information for EU citizens engaging in tourism (consumer rights, healthcare, addresses of consulates outside Europe, emergency phone numbers, information on the ‘European Citizen Travel Card’);

45.

underlines that tourism makes an important contribution to promoting understanding between peoples and knowledge of different cultures;

46.

proposes a media prize (‘tourism Oscar’), awarded by the EC, EP and CoR, to recognise (print and audiovisual) documentation that transmits knowledge about the European cultural and natural heritage, as well as about regional and local tourist attractions in Europe, and contributes to a sense of European citizenship;

External dimension of tourism

47.

emphasises the role of the internal market and the Schengen area for cross-border tourism and local markets. The CoR urgently appeals to the EU Member States to safeguard the border-free Schengen area;

48.

welcomes the ‘visa package’ (23) adopted by the EC in April 2014 and stresses that visa facilitation is a crucial prerequisite for encouraging tourists to visit Europe (24). Security concerns must be carefully weighed up against the economic contribution made by tourism; the Committee welcomes in this context the introduction of a European Travel Information and Authorisation System (ETIAS) (25) strengthening security of travel to the Schengen area under visa-free agreements;

49.

suggests that issues relating to tourism, and especially measures to improve the safety of European tourists in non-EU states, be addressed in a report by the Euro-Mediterranean Regional and Local Assembly (ARLEM);

50.

supports newly established platforms for cooperation between the EU and international partners like China through initiatives such as the Europe-China One Belt, One Road (OBOR) Culture and Tourism Development Committee (26);

Promoting tourism

51.

fully supports the decision to make 2018 the ‘European Year of Cultural Heritage’ considering that tourism will be a key enabler of all relevant initiatives and calls for a European Year of Tourism;

52.

calls for the joint promotion of tourism in third countries to be coordinated between the umbrella organisation for tourism advertising at national level and the European Travel Commission;

53.

calls for tourism services to be strengthened and targeted both at specific countries and at interest groups, professional groups, etc. while ensuring that information is distributed worldwide in an appropriate and understandable way using the most innovative channels possible. Making information about European tourism products more accessible can boost European tourist flows, as well as those from geographically distant countries;

54.

calls on the Commission to focus more closely on the interferences between tourism and migration/refugee flows, to study their cultural, economic and social impacts and, together with the CoR, to identify opportunities for the affected regions (labour market, etc.);

55.

recommends that the European Commission

should champion the European brand (EU logo) and the development of regional, inter-regional and transnational brand positioning and European marketing platforms (EU marketing programmes, e.g. for the Alpine region or the Mediterranean) in order to promote Europe in distant markets, while reflecting the particular role of towns and regions and the diversity of their natural and cultural heritage (27);

should implement measures to encourage European citizens to take more holidays in Europe; a model for a ‘European Citizen Travel Card’ should be considered providing the travellers with the general information to make their trips easier and safer and with the benefits of travelling inside Europe;

should put an ‘EU tourism roadshow’ and an atlas of European cultural routes on the www.visiteurope.com website (28);

should consider bringing in a standardised European classification and quality assurance system to complement national/regional hotel classifications (e.g. star ratings) and quality standards set at national level;

Interinstitutional cooperation

56.

calls on the EC to include the CoR in the annual European Tourism Forum and the European Tourism Day;

57.

calls for an annual discussion on tourism between the relevant EP and CoR committees and bodies; the discussion could include a joint hearing of sector-related stakeholders;

58.

calls on future EU Council presidencies to put topics relating to European tourism on the agenda and to involve representatives of the CoR;

59.

supports the Tourism for Growth and Jobs Manifesto (29), an initiative by Europe’s public and private tourism actors, and proposes to sign it in order to join the forces to keep Europe as an attractive destination and to ensure that the tourism sector continues to contribute to the economic, social, and territorial cohesion in Europe;

60.

calls on the UNWTO to support its initiative to develop European tourism;

61.

calls for the promotion of responsible tourism policies and practices by governments and the private sector in line with the principles of the UNWTO Global Code of Ethics for Tourism, a comprehensive framework for the development of sustainable, responsible and universally accessible tourism that takes into account all its economic, social, cultural and environmental dimensions;

62.

places a special emphasis on the social accountability of tourism, and calls upon European and non-European citizens to be informed and responsible tourists and travellers and to respect local customs and cultures;

Brussels, 7 December 2016.

The President of the European Committee of the Regions

Markku MARKKULA


(1)  Figures by the United Nations World Tourism Organisation (UNWTO) quoted in the Eurostat regional yearbook 2016.

(2)  COM(2009) 248 final, ‘European Union Strategy for the Baltic Sea Region’ (EUSBSR); COM(2014) 357, ‘European Union Strategy for the Adriatic and Ionian Region’; COM(2010) 715, ‘European Union Strategy for Danube Region’ (EUSDR); COM(2015) 366 final, ‘European Union Strategy for the Alpine Region’ (EUSALP).

(3)  One example of such a platform is the Network of European Regions for Competitive and Sustainable Tourism (NECSTouR).

(4)  e.g. tourism and agriculture, tourism and well-being, tourism and spa, tourism and sports, tourism and local crafts and creative cultural industries, industry and museums.

(5)  Including in outermost and outlying regions, mountainous regions, islands and coastal areas, cross-border regions, regions facing demographic challenges, cultural and nature sites, new as well as mature destinations.

(6)  ‘Green routes’, management by means of toll charges at certain times of the day or week, discounted ferry crossings/tariffs for tourists taking public transport (especially trains).

(7)  Including accessible intermodal transport options and ticketing services.

(8)  E.g. motorail services, carriage of bicycles on cross-border trains.

(9)  ‘Guide on EU funding for the tourism sector 2014-2020’. http://ec.europa.eu/DocsRoom/documents/18164/attachments/1/translations/en/renditions/pdf

(10)  http://www.thealps.travel/en

(11)  COR-2016-02559-00-00-DECL-REF.

(12)  Commission Regulation (EU) No 185/2010 of 4 March 2010 laying down detailed measures for the implementation of the common basic standards on aviation security (OJ L 55, 5.3.2010, p. 1).

(13)  Wine tourism, gastronomy, ecotourism, language-learning, active tourism, cycling tourism, rural life, traditions, religion, art, education, research, various popular sports, business and conference tourism, MICE (meetings, incentives, conventions and events), etc.

(14)  E.g. diversified strategies of what to offer in terms of ‘wellness’, culture, sport, non-seasonal products for year-round business, models to determine the climate impact of various types of holiday and holiday activities.

(15)  Following the example of the NECSTouR Regions.

(16)  http://hotelenergysolutions.net/

(17)  http://www.nezeh.eu/home/index.html

(18)  COM(2016), ‘Mapping and performance check of the supply side of tourism education and training’; COM(2014) 86, ‘A European Strategy for more Growth and Jobs in Coastal and Maritime Tourism’.

(19)  ETUC Resolution on Undeclared work, March 2014 (https://www.etuc.org/documents/etuc-resolution-undeclared-work#.WA9SumeXCUk).

(20)  https://sustainabledevelopment.un.org/

(21)  Parliament Magazine, Issue 437, 27 June 2016, pp. 28-29; example: ‘Youth on the SPOT — Special Partnership of Tourism’.

(22)  The idea of free Inter Rail tickets, which allow unlimited rail travel in and between all participating countries for a given period of time was debated at EP Strasbourg plenary session of 3-6 October 2016.

(23)  COM(2012) 649 final, ‘Implementation and development of the common visa policy to spur growth in the EU’.

(24)  ETC (2015), ‘Improving the Visa Regimes of European Nations to Grow Tourism: A view from the European Travel Commission’.

(25)  Proposal for a regulation of the European Parliament and of the Council establishing a European Travel Information and Authorisation System (ETIAS) and amending Regulations (EU) No 515/2014, (EU) 2016/399, (EU) 2016/794 and (EU) 2016/1624 (COM(2016) 731 final).

(26)  Parliament Magazine, Issue 437, 27 June 2016, p. 28-29.

(27)  European Tourism Manifesto (2016), ‘Tourism for growth and jobs’ (http://www.tourismmanifesto.eu/).

(28)  Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions ‘Towards an integrated approach to cultural heritage for Europe’ (COM(2014) 477 final).

(29)  http://www.tourismmanifesto.eu/the-manifesto


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