23.7.2011

EN

Official Journal of the European Union

C 218/46

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Opinion of the European Economic and Social Committee on the ‘Proposal for a Regulation of the European Parliament and of the Council on the effective enforcement of budgetary surveillance in the euro area’

COM(2010) 524 final — 2010/0278 (COD)

2011/C 218/08

Rapporteur: Mr FARRUGIA

On 6 December 2010 the Council of the European Union decided to consult the European Economic and Social Committee, under Articles 136 and 121 of the Treaty on the Functioning of the European Union, on the

Proposal for a Regulation of the European Parliament and of the Council on the effective enforcement of budgetary surveillance in the euro area

COM(2010) 524 final — 2010/0278 (COD).

The Section for Economic and Monetary Union and Economic and Social Cohesion, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 8 April 2011.

At its 471st plenary session, held on 4 and 5 May 2011 (meeting of 5 May 2011), the European Economic and Social Committee adopted the following opinion by 139 votes to 10 with 33 abstentions.

1.   Conclusions and recommendations

1.1   The EESC acknowledges that reforms to the Stability and Growth Pact (SGP) are needed to address the problems following the 2008 crisis as well as long-standing problems which were obvious even before the crisis. Furthermore, the EESC notes that the SGP was not successful at preventing and containing fiscal imbalances originating from other sources including macroeconomic imbalances and insufficiencies in banking and financial practices and regulation.

1.2   While welcoming the proposal for a regulation of the European Parliament and of the Council on the effective enforcement of budgetary surveillance as one step in the direction of much-needed reform, the EESC expresses the need for adequate review in the preventive and corrective elements of this proposal.

1.3   The EESC believes that fiscal rules should take into strong consideration:

—	the issue of quality of fiscal activities, in terms of enhancing the contribution of revenue and expenditure mechanisms to the supply side of the economy;

—	that the sustainability of fiscal financial positions is best ensured through a stronger emphasis on preventive rather than corrective approaches; and

—	that mechanisms which are based on incentives are most likely to be successful than those based solely on punitive measures.

This viewpoint does not diminish from the importance of the corrective arm which is essential to promote fiscal discipline.

1.3.1   Such an approach is viewed to be congruent with the Europe 2020 objectives of smart, sustainable and inclusive growth.

1.4   With regards to the preventive element, and in consonance with the targets outlined in the Annual Growth Survey, it is proposed that the establishment of numerical targets for fiscal performance be based on a two-pronged system with top-down and bottom-up elements. The top-down element would focus on the establishment of a target determining the fiscal consolidation effort required for the entire euro area while the bottom up approach would entail the distribution of such effort into actions to be undertaken by individual Member States. This would reinforce, through a formal approach, the Commission’s efforts towards a stronger focus on country-specific circumstances in the application of the SGP.

1.5   Within this approach, the positive credibility externalities expected out of a monetary union may require that members would be called to make fiscal consolidation efforts in a manner consistent with their relative size and ability to undertake such efforts.

1.6   The EESC further suggests that the imposition of interest bearing deposits, non-interest bearing deposits and fines is effected in a manner that these are directly funded, first and foremost, through the correction of policy elements which are leading to unsustainable fiscal positions. The latter would be determined through an assessment of deviations of revenue and expenditure elements from the convergence path as determined through the preventive arm. Furthermore, their value would be computed relative to the magnitude of expenditure and/or revenue elements which can be identified to be directly leading to the unsustainability of fiscal policy. This approach would be conducive to the enhancement of the quality of fiscal policy.

1.7   It is furthermore suggested that penalties undertaken under the corrective arm are accompanied by a rigorous impact assessment so as to monitor an effective improvement in the quality of fiscal policy.

1.8   In order to foster a balance between incentives and punitive approaches in the corrective arm, the EESC proposes that interest on non-interest bearing deposits can be obtained by the Member State concerned once a reduction in public debt, which is at least equivalent to such interest and which is likely to be sustained in future, is achieved. Fines, on the other hand, would be directed to the European Stability Mechanism.

1.9   The EESC believes that the proper reform of budgetary surveillance will be a cornerstone in strengthening governance and restoring credibility in the euro area.

2.   Effective enforcement of budgetary surveillance in the euro area

2.1   The 2008 global financial and economic crisis has led to a sharp increase in fiscal deficits and debt. These have exacerbated longer term concerns on fiscal sustainability. The uneven fiscal performance of Member States, with the real possibility of debt default in some instances, coupled with the lack of sufficient fiscal coordination and compensating mechanisms, is another major challenge. Such concerns are compounded by insufficiencies in the financial and banking systems and regulatory infrastructures, and the related possibility of defaults.

2.2   The SGP, a rules-based framework for the coordination of national fiscal policies in the economic and monetary union, was specifically set up to ensure fiscal discipline but recent experience has revealed remaining gaps and weaknesses in the system which could seriously undermine the stability of the euro. This has spurred a debate on the importance of EU economic governance (1) whereby in September 2010, the Commission presented a legislative package of six communications. The package consists of:

—	strengthening the SGP with prudent fiscal policy making (2),

—	preventing and correcting macroeconomic imbalances (3),

—	establishing national fiscal frameworks of quality (4), and

—	stronger enforcement (5).

2.3   This opinion focuses specifically on enforcement in terms of the Proposal for a Regulation of the European Parliament and of the Council, on the effective enforcement of budgetary surveillance in the euro area (6). It is to be also noted that the EESC is currently drawing up an opinion on COM(2010) 527 final (7).

3.   Context

3.1   The key instrument for fiscal policy co-ordination and surveillance in the euro area is the SGP which implements the Treaty provisions on budgetary discipline. The European Council in June 2010 agreed on the urgent need to reinforce the coordination of economic policies and in doing so agreed on:

(i)	strengthening both the preventive and corrective aspects of the SGP, including sanctions, while taking due account of the particular situation of the euro-area Member States;

(ii)	giving, in budgetary surveillance, a much more prominent role to levels and evolutions of debt and overall sustainability;

(iii)

ensuring that all Member States have national budgetary rules and medium term budgetary frameworks in line with the SGP;

(iv)	ensuring the quality of statistical data.

3.2   With respect to effective enforcement of budgetary surveillance in the euro area, the proposal for a Regulation of the European Parliament and of the Council is seeking further amendments to Regulations No 1466/97 and EC No 1467/97 which lay down the foundations of the SGP (8). In particular, the proposed regulation aims to substantiate the preventive arm and reinforce the corrective arms of the SGP.

3.2.1   In terms of the preventive arm, the proposed regulation indicates that the current medium term objective (MTO) outlined in the stability and convergence programmes and the 0,5 % of GDP annual convergence requirement will be maintained, but will be made operational through the provision of a new principle of prudent fiscal policy making. This principle, according to the proposal, indicates that annual expenditure growth should not exceed a prudent medium term rate of growth of GDP unless the excess is matched by increases in government revenues or discretionary revenue reductions are compensated by reductions in expenditure. In case of deviations from prudent fiscal policy making, a recommendation will be issued by the Commission backed with an enforcement mechanism under Article 136 of the Treaty, through the imposition of an interest bearing deposit, amounting to 0,2 % of GDP.

3.2.2   The corrective arm is linked to the obligations for euro area Members States to avoid excessive deficits and debt against a numerical threshold of 3 % of GDP in terms of the deficit and 60 % of GDP in terms of debt, whereby a sufficient decline towards the debt criterion is also deemed acceptable.

3.2.2.1   The Commission proposal recognises that the emphasis on the annual budget balance may result in excessive focus on shorter-term considerations and that debt deserves more consideration as an indicator of longer-term fiscal sustainability.

3.2.2.2   In the corrective element, the proposed regulation states that enforcement would be strengthened by means of the introduction of a new set of financial sanctions for euro area Member States which would apply earlier in the process and according to a graduated approach. A non-interest bearing deposit amounting to 0,2 % of GDP would be applied upon a decision to place a country in excessive deficit. In the event of non-compliance, the deposit will be turned into a fine.

3.2.3   The operational aspects of the enforcement of the preventive and corrective arms is proposed by the Commission to be undertaken through a procedure of reverse voting whereby a recommendation would be made by the Commission to the Council rendering the Member State liable for the provision of the deposit. This recommendation would hold unless the Council decides to the contrary by qualified majority within ten days of the recommendation presented by the Commission.

3.2.4   The Commission's proposed regulation states that the Council could reduce the amount of the deposit unanimously or based on a specific proposal by the Commission on grounds of exceptional circumstances or a reasoned request by the Member State. In the case of the preventive arm, once the Council is satisfied that the Member State has addressed the situation, the deposit will be returned with the accrued interest to the Member State concerned. In terms of the corrective arm, the Commission's proposed regulation states that the non-interest bearing deposit will be released upon correction of the excessive deficit while the interest on such deposit and fines collected will be distributed among euro area Member States which do not have an excessive deficit and which are not the subject of an excessive imbalance procedure either.

3.2.5   The proposal is made within a wider call for a broader macroeconomic assessment including the determination of structural imbalances which exert a negative impact on competiveness. Towards this end, a proposal for a Regulation on the European Parliament and of the Council on enforcement to correct excessive macroeconomic imbalances in the euro area (9) as well as a proposal for a Regulation of the European Parliament and of the Council on the prevention and correction of macroeconomic imbalances (10) has also been published.

3.3   Effective budgetary surveillance at the euro area level needs to be complemented by a focus on the national budgetary frameworks.

3.4   These proposals are part of a broader reform of economic governance spurred by the objectives outlined in Europe 2020 strategy. Economic policy coordination including surveillance of the fiscal position through adherence to fiscal rules and to structural reforms is expected to be integrated in the European Semester which outlines a period of time during which the Member States' budgetary and structural policies will be reviewed to detect any inconsistencies and emerging imbalances as well as to reinforce coordination while major budgetary decisions are still under preparation (11).

4.   General comments

4.1   Reforms to the SGP to tackle the weaknesses of the system are needed to address the weaknesses which became evident out of the exceptional 2008 crisis, but also to address problems that had emerged before then.

4.2   Indeed, for a number of years prior to the crisis, some euro area countries had run fiscal deficits above the reference value of 3 % and had increasing public debt ratios (12). The onset of the financial and economic crisis resulted in significant widening of the fiscal position such that the average deficit in the euro area is expected to reach 6,3 % of GDP by the end of 2010 and the ratio of debt to GDP is expected to reach 84,1 % (13). The SGP was not directed to prevent such imbalances which in many instances occurred also as a result of severe tensions in the wider macroeconomic and financial milieu.

4.3   There are two main observations that need to be addressed with respect to the SGP. The first refers to improvements that may be implemented to enforcement mechanism. The second relates to the excessive reliance on the fiscal deficit criterion with limited consideration to debt. The economic cycle did not feature sufficiently in the application of the SGP.

4.3.1   In terms of the lack of enforcement, a number of countries have over the years violated the deficit and debt criterion. Lack of sanctions led to fiscal behaviour which not only ignored fiscal sustainability at the level of the Member State but also failed to take into account the impact of unsustainable fiscal behaviour by any one Member on the entire monetary union. Lack of enforcement in the past has weakened the SGP and dented its credibility.

4.3.1.1   Reforms to the preventive and corrective arms of the Pact, backed by a new set of tougher financial sanctions, are expected to address this shortfall. However, the extent to which credible enforcement will be practised remains to be seen.

4.3.1.2   From one perspective it can be argued that this time, the stakes of an ineffective package are extremely high. More than ever, the financial market will exhibit heightened caution with respect to euro area countries monitoring fiscal and macroeconomic balances. Lack of credible enforcement would signal the failure of the SGP and would thus seriously undermine the stability of the euro area.

4.3.1.3   At the same time, consideration must be taken of the fact that proposals for enhanced surveillance are being undertaken in the wake of an unprecedented crisis where economic growth remains weak. Governments have had to intervene through capital injections pumped into banks to prevent a total collapse of the financial system. They have also had to intervene to contain the economic and social costs of the crisis.

4.3.2   In terms of the excessive reliance on the deficit criterion, it is noted that the 2005 revision of the SGP tried to shift the focus to structural deficits to take into account the cyclical situation of each Member State. Such emphasis however failed to take into account fiscal discipline from a longer term perspective. Increased emphasis on the debt criterion will to an extent address this shortfall.

4.3.2.1   The mechanism however needs to consider the underlying reasons for the accumulation of debt. Debt-financing of public capital projects which render a high rate of economic and social return cannot be viewed in the same manner as the financing of expenditure which renders a low rate of return.

4.3.2.2   Furthermore, while reform to the surveillance mechanisms is expected to take into consideration country specific features such as the composition of debt, risks linked to the debt structure, private sector indebtedness as well as liabilities related to ageing, it is important that a distinction between foreign and domestic debt whereby the latter contributes towards macroeconomic stability is also undertaken.

4.3.2.3   A further criticism of the surveillance mechanism is linked to the emphasis on specific reference values, which are essentially arbitrary (14). Notwithstanding, there is acknowledgment that the reference value approach has important merits in terms of simplicity, transparency and the facilitation of governance.

4.3.2.4   On the other hand, the divergences of individual Member States from such reference values indicates the extent to which convergence in the EU is as yet elusive. A rapid convergence between countries is desirable and the recent emphasis placed by the European Council in this regard is appropriate. This, on the other hand, requires a careful balance, at the country level, between the necessary commitment to fiscal discipline, and the specific needs for restructuring, investment and growth which may need to be sustained through fiscal interventions.

4.4   It is important to reiterate that fiscal sustainability cannot be considered in isolation from macroeconomic imbalances. Consequently, broader macroeconomic surveillance to monitor the correction of imbalances is highly warranted.

4.5   The drive towards the setting up of national budgetary frameworks as a complement to the SGP rests on recognition of the fact that while fiscal discipline is a matter of common concern among euro area countries, the legislative power of fiscal policy lies at a national level.

4.5.1   The extent to which a more decentralised approach to fiscal discipline can be undertaken may on one extreme depend on relevant changes to the Treaty which would limit national interest over common interests, but could also be operated through more flexible arrangement at the level of agreement of the Member State. Unless such changes are undertaken, no matter how justified common interests are, national interest may tend to prevail (15). It is thus important to consider the role which fiscal responsibility laws at the national level can play in sustaining fiscal discipline which through their successful implementation can serve as a spur to the promotion of fiscal sustainability across the euro area.

5.   Specific comments

5.1   While the aims of the proposed Regulation based on the strengthening of the SGP through the provision of tools leading to effective enforcement are to be commended, there are specific details in terms of the preventive and corrective arms of the Pact which the EESC feels that require reconsideration.

5.2   The expenditure target, outlined in the preventive arm, based on a prudent medium term rate of growth of GDP fails to take into account the different elements of government expenditure – albeit an overall expenditure target is useful for the purposes of simplicity and facilitating governance. This is also the case with fiscal rules which focus solely on overarching indicators such as the deficit and debt criterion. Such criteria fail to take into account the long-term supply-side growth induced by certain categories of government expenditure as well as the development in the quality of fiscal expenditure and revenue generating mechanisms in general.

5.2.1   Consequently, there needs to be emphasis on the quality of public finances through an assessment of the composition and efficiency of public expenditure. This can be particularly relevant for investment in human capital through expenditure on education and health, expenditure on research and development, on public infrastructure and on the development of institutions (16)  (17). It is thus proposed that this type of expenditure is excluded from the expenditure ceiling, especially when it consists of outlays which are financed by EU funding programmes and their national co-financing elements. In the interest of preserving the quality of social expenditure, the non-discretionary elements of unemployment benefits could also be excluded. Furthermore, the implementation of fiscal targets must be fully in line with the attainment of the Europe 2020 objectives which focus on smart, sustainable and inclusive growth whereby the attainment of such goals may require higher government outlays (18).

5.2.2   Furthermore in order for the regulation not to be shrouded in uncertainty the EESC suggests a clear definition of the terms ‘prudent fiscal policy making’, ‘prudent medium term growth rate’ and ‘exceptional circumstances’.

5.3   The enforcement mechanism should not be triggered solely on account of deviations from numeric values but rather wider considerations such as the economic, political and social conditions prevailing in the Member State should also be considered. This proposal is not intended to water down the preventive mechanism but rather to allow for specific considerations prevailing in euro area Member States to be taken into consideration. Indeed, this is congruent with the proposed regulation on macroeconomic imbalances whereby following the alert mechanism, an in depth review on the Member State is carried out.

5.4   It is further suggested that the imposition of interest bearing deposits, non-interest bearing deposits and fines is in each case effected in a manner so that these are directly funded through the correction of policy elements which would be causing an imprudent and unsustainable fiscal position as determined through deviations from the provisions of the preventive arm. Furthermore, their value would be computed relative to the magnitude of expenditure and/or revenue elements which can be identified to be directly leading to the unsustainability of fiscal policy. Such an approach would avoid the risk that deposits and fines are funded through government expenditure which renders a high rate of return. While it is acknowledged that the identification of unsustainable behaviour is not an easy feat, efforts should be directed towards deriving clear and operationally feasible definitions which can be useful in this context.

5.4.1   Moreover, it is imperative that the deposit is only released once a commitment is made by the Member State involved to redirect such funds towards productive expenditure. In this regard, the use of cost benefit approaches which are similar to those applied in the allocation of Cohesion and Structural Funds (19) could be warranted.

5.5   Furthermore, due consideration must be given to the implications of enforcement whereby the imposition of the non-interest bearing deposit and sanction would be imposed at a point in time wherein the economic and social framework of the Member State may be considered vulnerable. As a result, any recommendations made by the Commission towards the triggering of the corrective arm should be subject to an impact assessment to inform on the manner in which its application would be effectively leading to improvements in the quality of fiscal policy within individual Member States concerned and in the euro area in general. It is important for enforcement to not generate more failure than it is trying to resolve.

5.6   Article 7 of the Regulation refers to the distribution of the interest and fines earned by the Commission, in proportion to the share in the gross national income of euro area Member States which are not liable to an excessive deficit or excessive imbalance. Towards this end, the distribution system may cause greater imbalances within the monetary union potentially resulting in wider divergences between euro area Member States running counter to the requirements of a monetary union.

5.7   In order to foster a balance between incentives and punitive approaches in the corrective arm, the EESC proposes that interest on non-interest bearing deposits can be obtained by the Member State concerned once that a reduction in public debt, which is at least equivalent to such interest and which is likely to be sustained in future, is achieved. Fines, on the other hand, would be directed to the European Stability Mechanism.

5.8   The premise behind this suggestion is that the SGP should serve as an incentive towards the promotion of sustainable behaviour rather than as a strictly punitive mechanism.

5.9   While it is recognised that the goal of the pursuit of fundamental economic and fiscal convergence must be based on common targets, it is argued that a ‘one size fits all’ target may need to be flexibly implemented in gauging fiscal sustainability in the immediate short term, at least until sufficient fundamental economic convergence between countries has been attained, but also in consideration of the asymmetric way in which the recent recessionary episode has impinged upon different Member countries.

5.9.1   It is also important to create framework conditions whereby individual Member States would benefit from the positive credibility externalities expected out of the existence of a large monetary area. It may be thus considered that the countries would be called to make fiscal consolidation efforts in a manner consistent with their relative size within the monetary area and ability to undertake such efforts, so that the common overarching target for the euro area is consistently achieved. This approach would directly benefit all countries, through the economic credibility which is established in the area as a whole and especially in the policy-making of the better performing ones.

5.9.2   The effectiveness of such an approach strongly depends on the surveillance mechanism as proposed by the Commission which would ensure that countries lagging behind are making all the effort possible to achieve convergence at an optimal speed. There is also need for consistent emphasis on correct statistical measurement and that statistics and reporting are improved in a manner which ensures reliable and timely availability of credible data.

5.9.3   Consequently the Committee suggests that, for the immediate short term and until sufficient economic convergence between different member states is achieved, a two-pronged system having a top down and a bottom up approach is used to reinforce and complement the efforts currently under way aimed at restoring fiscal sustainability in the euro area by introducing within them necessary elements of flexibility in a planned and well-regulated manner.

5.9.4   The top down approach is based on the establishment of a target for the entire area determining fiscal consolidation effort required at that level. The attainment of such a target enhances the credibility of the euro area in general and all countries would individually benefit from it. The bottom up approach would entail the distribution of the effort to be effected by the entire area into actions to be undertaken by individual Member states. The distribution would take into consideration a number of objective economic criteria such as state of development, investment needs, extent of pension reform, extent of structural reform, the quality of public finances and the efficiency of taxation systems. Furthermore, this approach would prevent an excessively restrictive approach to the SGP from causing permanent damage to growth in the cases of certain countries.

5.9.5   This approach would on one hand introduce an element of justifiable solidarity across euro area countries, while on the other hand serving as a step towards improved coordination and fiscal integration. In the presence of sufficient fundamental economic convergence, the bottom up distribution of effort among Member States is tantamount to a situation where the different countries would be pursuing common numerical goals. In the interim, the exercise of the necessary flexibility on a country-by-country basis would no longer happen, as has often occurred in past, on apparently ad hoc and perhaps unjustifiable bases, but would form part of a coherent and consistent system to effect the necessary fiscal consolidation efforts at the euro area level. This approach could go a long way towards sustaining credibility in the system.

5.9.6   Such an approach is in nature similar to that adopted in the derivation of targets for the Europe 2020 Strategy, whereby Member states set their own national targets which are congruent with the arching targets set for EU. Indeed Annex 1 of the Annual Growth Survey which presents provisional varying Member States targets refers to the fact that an important element of the strategy is that each Member State sets its own level of ambitions as regards the overall Europe 2020 targets. It is argued that such targets are more likely to be adhered to given the internal political debate required to establish such targets whereby the target is established by taking into consideration starting positions and national considerations. In this context, it can also be proposed that explicit transition periods within a realistic consolidation timeframe, are set for countries requiring particularly large consolidation efforts.

5.9.7   This proposed approach is not tantamount to a watering down of the proposed preventive mechanism in the Commission's proposal as it is based on long term convergence to the same numerical targets by all euro area members. It is however intended to allow for a formal framework to justify different speeds of convergence at the level of individual euro area Member States in the same spirit of the country specific approaches being proposed by the Commission itself. This is also seen as an important way to enhance the credibility of the system by formally embedding flexibility in country specific convergence plans.

5.10   Finally it is important to note that social dialogue has an important role to play. At a national level, social dialogue is important for the development of a national policy framework which focuses on fiscal policy and macroeconomic surveillance. Mature and comprehensive political and social dialogue allows for the confrontation of social and economic challenges particularly those of a long term nature such as pension reform and health expenditure. In order for governments to achieve objectives such as fiscal sustainability and macroeconomic balance, there must be a strong degree of social partnership and collaboration, including political consensus.

5.10.1   The EESC also has an important role to play through the provision of effective dialogue amongst its members on fiscal sustainability. Towards this end, the EESC may provide in close coordination with the national social dialogue recommendations and suggestions for reforms. As suggested in the Opinion on Enhancing economic policy coordination for stability, growth and jobs – Tools for stronger EU economic governance the EESC could hold dedicated annual sessions to discuss recommendations and suggestions for reforms. Furthermore, the EESC has a role to play in ensuring that social partners and other civil society organisations are attuned with Community objectives that are conducive towards social and economic development.

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(1)  See EESC Opinion in OJ C 107 of 6.4.2011, p. 7.

(2)  COM (2010) 522 final and COM (2010) 526 final.

(3)  COM (2010) 527 final.

(4)  COM (2010) 523 final.

(5)  COM (2010) 524 final and COM (2010) 525 final.

(6)  COM (2010) 524 final.

(7)  EESC opinion on Macro economic imbalances See page 53 of this Official Journal.

(8)  The regulations were amended in 2005 by Regulations (EC) No 1055/2005 and (EC) No 1056/2005 and complemented by the Council Report of 20 March 2005 on ‘Improving the implementation of the SGP’.

(9)  COM(2010) 525 final.

(10)  COM(2010) 527 final.

(11)  The European Semester has been launched through the Annual Growth Survey published in January 2011 (COM(2011) 11 final). The Annual Growth Survey brings together the different actions which are essential to strengthen the recovery in the short terms while also focusing on the Europe 2020 objectives.

(12)  Eurostat Statistics, 16.12.2010.

(13)  European Commission, European Economic Forecast, Autumn 2010.

(14)  C. Wyplosz (2002), Fiscal Discipline in EMU: Rules or Institutions?, Graduate Institute for International Studies, Geneva and CEPR.

(15)  Directorate General for Internal Policies - Policy Department A: Economic and Scientific Policies, Economic and Monetary Affairs, Multilateral Surveillance (Charles Wyplosz).

(16)  Salvador Barrios and Andrea Schaechter (2008), The Quality of Public Finances and Growth, European Commission Economic Papers 337.

(17)  António Afonso, Werner Ebert, Ludger Schuknecht and Michael Thöne, (2005), Quality of Public Finances and Growth, ECB Working Paper Series No 438.

(18)  See EESC Opinion in OJ C 107 of 6.4.2011, p. 7.

(19)  EU Commission (2008), Directorate General Regional Policy, Guide to Cost-Benefit Analysis of Investment Projects, June 2008.

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