From: Pauline Bastidon
Sent: jeudi 14 janvier 2010 16:48
To: Christopher John Hull;
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Subject: CREST meeting 21-22 January -
discussion on simplification
Attachments: DiscussiononSimplification.pdf
Dear Madam/Sir,
This
message concerns the CREST meeting on 21 and 22 January 2010, and in particular
item 5 on the agenda on simplification in the EU Framework Programmes and the
related Commission paper on suggestions for the discussion on simplification
(please see attachment).
We have
been unable to identify most of the CREST delegates attending this particular
meeting and would therefore be grateful if you could forward the following
message to your national delegate attending this meeting on 22 January.
Thank you
for your help.
Best
regards,
Pauline
Bastidon, on behalf of Christopher John Hull, Secretary General, EARTO –
European Association of Research and Technology Organisations
Message to
Delegates attending the CREST Meeting on 21st-22nd
January
At your meeting on January 21st-22nd
you are invited to comment on ideas for “simplification” put forward by the
European Commission.
The Commission’s approach to
simplification is increasingly a cause for concern for all of the key FP
participant communities: large and small enterprises, universities, and RTOs.
Permit me to use the opportunity of your forthcoming discussion to alert you to
the essence of these concerns.
As a preamble, may I note that the whole
FP simplification discussion has become somewhat perverted. When first
proposed, and subsequently promoted by Commissioner Potočnik, the intention was
to simplify to the benefit of FP participants. Since then, however,
increasingly we see proposals from the Commission which will make life easier
for the Commission but not for FP participants; indeed, sometimes they
represent a complication for FP participants.
The Commission appears to have forgotten
that the FP is intended to be an incentive programme. It exists to compensate
for market failures and systemic imperfections, by providing FP participants
with a financial incentive to undertake research which otherwise they would not
undertake. The widespread use of lump-sums etc., or “one-size-fits-all”, takes
no account of the fact that in the real world the cost structures of different
FP participants differ substantially: for example, the RTO with sophisticated
plant and equipment necessarily has significantly higher overhead costs than
the typical SME. The result of a “one-size-fits-all” cost-reimbursement regime
would be to offer arbitrarily variable effective rates of cost
reimbursement which would tend to penalise especially the more qualified, but
necessarily more cost-intensive, research performers that presumably policy
should be targeting as a priority. The basis for setting cost-reimbursement
rules and values must always be the real economic cost to the particular
organisation of the research to be performed. In general, full-cost
accounting is the best approach.
Proposals in the Commission’s discussion
paper – such as “one-size-fits-all” – run the risk of giving us a Framework
Programme which is easier for the Commission to administer but which is in
danger of missing the target because the approach fails to start from the
basics:
-
What
market imperfections and systemic failures is EU R&D&I is policy
seeking to address?
-
What,
then, are the varieties of research and types of actor that policy needs to
target?
-
What
kinds and amount of support do those different varieties of research and types
of actor require in order to achieve the necessary minimum incentive effect?
Those are the essential questions that
must condition the design and implementation of incentive programmes.
“Simplification” that ignores them will fail. It is an illusion to think that
you can simplify in abstraction from the objectives and targeting of policy.
We should be grateful if you would bear
these things in mind during your forthcoming CREST discussion.
Christopher John Hull
Secretary General
EARTO
rue Joseph II, 36-38
B-1000 Brussels
Belgium
+32-2-5028698
hull@earto.eu
www.earto.eu
Pauline Bastidon
Policy Officer
EARTO - European Association of Research and Technology Organisations
36-38
Rue Joseph II
1000
Brussels
Tel:
+32-2-502 86 98
Fax:
+32-2-502 86 93
www.earto.eu - bastidon@earto.eu
