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Conseil des Communes et Régions d'Europe

CCRE

The Council of European Municipalities and Regions promotes local government autonomy and represents municipalities and regions in EU institutions.

Lobbying Activity

Meeting with Marie-Helene Boulanger (Head of Unit Justice and Consumers)

20 Jan 2026 · Democracy: Safety in Politics

Meeting with Nicolás González Casares (Member of the European Parliament)

21 Nov 2025 · Energy and climate on regions

Response to Collection of urban mobility data per urban node

19 Nov 2025

The Council of European Municipalities and Regions (CEMR), representing 60 national associations of local and regional governments from 41 countries, welcomes the opportunity to comment on the draft Implementing Act on Sustainable Urban Mobility Indicators (SUMI). As the voice of Europes cities, towns and regions, CEMR works to ensure that EU legislation is realistic, proportionate and aligned with local needs. CEMR appreciates the transparent preparation process and the constructive cooperation within the ad-hoc expert group and EGUM, which helped ensure that practical challenges and proportionality concerns were considered. Urban mobility is primarily a local competence, and municipalities should not face disproportionate reporting obligations. We therefore support the approach whereby Member States remain responsible for data collection and reporting. However, several indicators will require substantial data collection effortssuch as mobility surveys or detailed safety data. Adequate financial and technical support will be essential. CEMR calls for EU guidance on methodologies (survey design, CO calculations, data interoperability) as well as capacity-building for local authorities. CEMR also encourages the Commission to promote innovation and modern data collection tools, including digital mobility data, sensors and automated traffic measurements. These tools can improve data quality while reducing administrative burden, but they also raise challenges related to privacy, data quality, representativeness and interoperability. EU efforts must therefore combine reporting requirements with support for method development and capacity-building. Strong coordination at national level is crucial. Member States should work closely with urban nodes through National SUMP Supporting Frameworks and National SUMP Contact Points when defining data-sharing arrangements and validating data. The TEN-TEC portal should also allow authorities to annotate data to explain methods and limitations. Indicators should help each urban node monitor its own progress; they must not lead to city rankings. Clear communication from the Commission will be important to ensure acceptance at local level and alignment with existing mobility planning frameworks. CEMR also highlights specific technical points: Changes to the geographical coverage of an urban node should be acknowledged by the Commission, not approved. The reporting cycle should better align with national and local timelines; a mid-year deadline would ensure more up-to-date data. Greater transparency is needed on how indicators may be updated in the future. Several indicators require clarification, including CO (SU.1), trips by mode (SU.2), safety indicators (SA.1SA.3), accessibility indicators (AC.1AC.4), and HO3/AC.1 regarding the scope of stops within a LAU. CEMR supports the goal of establishing a coherent, proportionate and realistic SUMI framework. Its success will depend on subsidiarity, adequate resources and continued cooperation between the Commission, Member States and local and regional governments.
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CEMR Urges Local Inclusion in EU Circular Economy Act

6 Nov 2025
Topic — The Circular Economy Act aims to boost EU sustainability through recycled materials.
Message — The group calls for a mandatory opportunity for local involvement and full cost coverage. They also request technical assistance for procurement and harmonised EU-wide end-of-waste criteria.123
Why — This would ensure municipalities recover all waste management expenses and reduce local administrative complexity.45
Impact — Manufacturers and producers would face increased financial responsibilities and stricter design requirements for durability.67
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CEMR demands digital relief for European local governments

14 Oct 2025
Topic — The Commission initiative aims to streamline digital legislation and reduce business compliance costs.
Message — CEMR calls for the initiative to include local and regional governments, not just businesses. They request longer implementation deadlines and a revised small-business definition to include municipal companies. Additionally, they propose a single portal for reporting cybersecurity incidents.1234
Why — Municipal authorities would achieve regulatory parity with businesses and lower administrative costs.5
Impact — Private firms would lose their exclusive access to SME-related regulatory exemptions and benefits.6
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CEMR Demands Local Government Leadership in EU Social Rights

10 Sept 2025
Topic — This consultation addresses the upcoming Action Plan for the European Pillar of Social Rights.
Message — CEMR requests a permanent role for local and regional governments in shaping the Action Plan. They advocate for co-creation and demand simpler reporting requirements for local authorities.123
Why — Local authorities would secure stable funding and greater authority over social services.45
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Response to European Climate Law amendment

4 Sept 2025

The Council of European Municipalities and Regions (CEMR) welcomes the opportunity to respond to the European Commission's consultation on the revision of the EU Climate Law. As the oldest and broadest European association of Local and Regional Governments (LRGs), we highlight the urgent necessity of upholding the EUs climate ambition through the 2040 targets, and the key role of local administrations in carrying out the ground-level implementation of EU climate and energy policy. Local and regional governments are the backbone of EU climate policy implementation, serving as primary drivers of change across European territories. They are responsible for 63% of climate-related public expenditure and 69% of climate-relevant investment, while delivering 70% of climate mitigation measures and 90% of adaptation actions, making them indispensable actors in meeting the EU's commitment to climate neutrality. CEMRs 2024 survey of over 300 LRGs from across Europe shows that, despite their central role, only 11% of local administrations in Europe report confidence in their readiness to implement and enforce green legislation due to significant gaps in funding, capacity, and involvement in multilevel governance frameworks. Successful examples of local climate leadership abound across Europe, showing how LRGs are pioneering innovative solutions tailored to their territorial contexts. The EU Covenant of Mayors for Climate and Energy, which brings together over 11,000 local governments committed to ambitious climate action, demonstrates the readiness of LRGs to exceed EU targets when provided with appropriate support and adequate inclusion in governance structures. A multilevel approach to climate policy is not only a legal requirement according to the principle of subsidiarity enshrined in the Treaties, but also a prerequisite for effective implementation since climate challenges and solutions differ by territory. Hence, it is crucial to avoid one size-fits-all solutions that often fail to capture the multifaceted reality of local climate action. A clearer recognition of territorial specificities and the full inclusion of LRGs as essential partners in the clean transition are thus fundamental building blocks for an EU climate policy that revitalises the economic fabric of our territories while leaving no community behind. At the same time, securing timely and adequate access to both public and private finance for LRGs must be established as a clear priority, as local administrations across Europe are confronted with ever-growing responsibilities while facing increasing budgetary constraints. Without sufficient resources, LRGs cannot fulfil their mandates or deliver climate solutions tailored to the specific needs of their territories, severely undermining the achievement of EU climate objectives. CEMR will continue working with local policymakers and stakeholders to ensure that the European Climate Law fully recognizes the local dimension of the clean transition, empowering local administrations to transform global climate ambitions into tangible actions that drive real change on the ground.
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Meeting with Hugo Sobral (Deputy Director-General Regional and Urban Policy)

14 Jul 2025 · Role of regional and local authorities in future MFF new Cities' Agenda

Meeting with Ana Carla Pereira (Director Justice and Consumers)

8 Jul 2025 · Exchange of views on the future Gender Equality Strategy, CEMR’s European observatory on violence against local and regional political leaders and the possibilities for EU funding and grants.

Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

12 Jun 2025 · Water Resilience Strategy

CEMR urges EU to empower local authorities in AI transition

3 Jun 2025
Topic — A consultation on a strategy for accelerating AI adoption across EU strategic sectors.
Message — CEMR calls for the strategy to empower local governments with resources and frameworks for effective AI adoption. They demand human oversight and realistic expectations for AI's role in public service delivery.123
Why — Local authorities would avoid carrying the financial and technical burden of AI implementation alone.4
Impact — Smaller and rural municipalities risk exclusion due to limited financial means and staff gaps.56
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Response to Policy agenda for cities

26 May 2025

Towards an Inclusive EU Agenda for Cities of Every Size and Context The Council of European Municipalities and Regions (CEMR) calls on the EU to develop a new agenda for cities that is inclusive, decentralised, and tailored to the specific needs of all cities and municipalities. Local and regional governments, responsible for implementing over 70% of EU legislation, are crucial in managing challenges like energy, health, housing, and migration. Their closeness to citizens enables responsive governance and makes local autonomy essential for effective policy delivery. ________________________________________ From Principles to Practice: A Structured and Inclusive Governance Mechanism To ensure quality EU policymaking and effective implementation at local levels, CEMR proposes: Multi-level governance consultation processes for key EU frameworks (e.g., European Semester, Competitiveness Compass), ensuring early and consistent input from local and regional authorities. Mandatory governance impact assessments for all new EU legislation to identify territorial and urban effects and clarify the most suitable governance levelnational, regional, or local. A new steering group under the Commission Secretariat-General to oversee the EU legislative agenda and coordinate multi-level consultations. This group would include EU institutions, national governments, local associations (e.g. CEMR, Eurocities), and the Committee of the Regions. It would also guide targeted consultations using tools like the CEMR TERRI report. ________________________________________ Bridging the Gap: Ensuring Effective Local Implementation of EU Policies Local authorities face growing responsibilities with limited resources. To improve implementation: Introduce a capacity-building pillar in the reforms component next EU structural funds, requiring Member States to assess subnational resource needs and use instruments like the Technical Support Instrument where necessary. Launch regular Implementation Dialogues with local representatives to track policy delivery and address challenges collaboratively. Develop a "one-stop shop" platform to enhance access to EU initiatives, funding, and capacity-building tools, while reducing administrative complexity and overlaps. ________________________________________ Aligning EU Funding Opportunities with Local Needs To make funding more accessible, efficient, and tailored to local realities, CEMR recommends: Setting a 15% earmark in the next Multiannual Financial Framework for sustainable territorial development, using ITI and CLLD methodologies. Ensuring city and regional access to the new Competitiveness Funds, recognising their role in economic resilience and innovation. Simplifying procedures and enabling multi-source funding by harmonising rules, co-financing rates, and application processes, which currently pose barriers, especially for smaller municipalities. Strengthening advisory services and national contact points to offer structured, transparent support to local governments. Reducing co-financing burdens by adjusting thresholds to fit the applicants size and capacity. Incentivising first-time applicants with tools like flat-rate grants or preparatory vouchers to build confidence and capacity. Linking innovation funding with investment programmes to scale up successful projects, including those requiring capital expenditure. ________________________________________ CEMR urges the EU to create a more coherent, accessible, and inclusive urban agenda that strengthens the role of cities and municipalities in policymaking and implementation. By aligning governance, funding, and support structures with local realities, the EU can empower subnational governments to lead sustainable, inclusive, and resilient development across Europe. For the full proposal, see the enclosed CEMR Input Paper for the New EU Agenda for Cities.
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European local governments urge simplification of public procurement rules

5 Mar 2025
Topic — Evaluation of EU directives governing public procurement and concession contracts.
Message — CEMR requests streamlining procedures and increasing flexibility to reduce the overwhelming administrative burden. They also advocate for raising financial thresholds and keeping sustainability criteria strictly voluntary.123
Why — This would reduce their legal expenses and the time spent managing complex tenders.45
Impact — Environmental groups lose a powerful lever for enforcing mandatory green standards across Europe.6
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CEMR urges EU to keep water a public good

4 Mar 2025
Topic — The consultation concerns a plan to achieve water resilience and security across Europe.
Message — CEMR requests legal frameworks to prevent water commodification and guarantee universal access. They demand increased funding for infrastructure and region-specific management strategies.12
Why — Municipalities would lower consumer tariffs and improve service quality through public control.3
Impact — Private operators lose profitable management contracts to local government authorities.4
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CEMR Demands Local Flexibility in National Nature Restoration Plans

7 Feb 2025
Topic — The Commission is consulting on the standardized format for Member States' nature restoration plans.
Message — CEMR calls for the formal involvement of local governments in the development of restoration plans. They request a flexible reporting framework that prioritizes qualitative outcomes over rigid quantitative data.123
Why — This would lower compliance costs and allow cities to choose the best local greening methods.45
Impact — EU oversight bodies may lose granular data and oversight due to simplified reporting requirements.6
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Meeting with Piotr Müller (Member of the European Parliament, Rapporteur) and PETITA I MITJANA EMPRESA DE CATALUNYA

21 Jan 2025 · Evaluation of the Public Procurement Directives

Response to Interim evaluation of the Connecting Europe Facility 2021-2027

24 Sept 2024

The Council of European Municipalities and Regions (CEMR) is the broadest association of local and regional governments in Europe. Its members are 60 national associations of municipalities and regions from 40 European countries. We enclosed our feedback. Overview of CEMR's Recommendations: Increased budget allocation for CEF The expansion of the TEN-T urban nodes and raising of the ambitions these urban nodes have to meet demands a corresponding increase in financial support through CEF. This will ensure that cities and regions can deliver on the ambitious targets of the regulation. Cities currently struggle to find sufficient funding for essential mobility infrastructure projects. Increasing the CEF budget will enable local authorities to move forward with such projects, which are critical to reducing emissions and promoting sustainable mobility. Dedicated budget line for urban nodes A clear, dedicated budget line should be established to support urban nodes in meeting the new infrastructure requirements, including investments in urban mobility infrastructure and collection of urban mobility data. Recently the CEF has dedicated some funding for the development of SUMI criteria, but more is needed. Place-based policy approach to ensure territorial investments Funding mechanisms must prioritize a place-based approach. This approach acknowledges that not all cities and regions face the same challenges or are starting from the same point in their transition towards sustainable mobility. Considering the unique challenges of different territories Europe ensures the development of tailored infrastructure strategies within the broader TEN-T framework. Many cities use cohesion funding for investments in mobility. We recommend aligning the mechanisms of CEF with those of cohesion policy, in particular its place-based approach and partnership principle Strengthened collaboration with local and regional governments in the CEF The success of the implementation of TEN-T network depends on close collaboration between the European Commission, national governments, and LRA that are directly involved in running the transport projects. The TEN-T regulation has recognized the role of LRA in the governance and priorities of the nine TEN-T corridors, and we recommend that it is also reflected in the strategic direction of the CEF programme.
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Response to Directive of the European Parliament and of the Council on a Quality Framework for Traineeships

18 Jun 2024

The detailed version of CEMR's contribution is available attached. The Council of European Municipalities and Regions (CEMR) is the broadest European association of local and regional governments. We are the only organisation that brings together one million democratically elected European politicians in 60 member associations from 40 countries. CEMR also represents local and regional governments as employers before the European Sectoral Social Dialogue Committees on Local and Regional Governments, and Social Services. Municipalities and regions are responsible for several traineeship programmes, together with relevant educational institutions, notably for traineeships that are part of a formal education and training process. The cooperation between local and regional authorities and the respect for social partners autonomy are essential elements to ensure quality learning outcomes and a traineeship system that is tailored to the needs of trainees and the local economy. Therefore, the EU legislative framework must allow sufficient flexibility for social bargaining and/or collective agreement, depending on the respective specific competencies at the local and regional level. CEMR would like to highlight key considerations regarding the proposed Traineeships Directive, particularly on the following points: - CEMR support a directive solely focusing on open-market traineeships leaving national flexibility regarding traineeship status and duration. - The directive must explicitly define its scope to exclude traineeships part of formal education (ECT-traineeships), training processes (MPT-traineeships) and active employment efforts (ALMP-traineeships) - The directive must not include the issues of fair remuneration or access to social protection in such traineeships as they are a competence of Member States under Article 153 of the Treaty on the Functioning of the EU - CEMR calls for a clear definition of traineeships - The directive proposed by the European Commission risks imposing unnecessary administrative and financial burden on Local and Regional Governments
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Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

The Council of European Municipalities and Regions (CEMR) welcomes this initiative aimed at addressing the investment gaps of achieving energy efficiency targets by 2030. CEMR wishes to emphasize that leveraging sufficient funding for energy efficiency will only be successful by fully involving local and regional governments/authorities (LRAs). The implementation of the Energy Efficiency Directive (EED) depends on municipalities and regions, given the high decentralization of energy efficiency policies and competences. Local and regional expertise can channel investments into the most cost-efficient projects in their territories. However, many of the measures require a significant mobilization of capital investments and surpass local and regional public budgets. Therefore, CEMR strongly advocates for encouraging compensation mechanisms to ensure adequate public funding to meet the Directives targets. Energy Efficiency measures are highly decentralized policies CEMR stresses that LRA implement 80% of energy efficiency policies of the public sector in a sole or shared responsibility, such as buildings renovations, public lighting or local cooling and heating (https://www.ccre.org/img/uploads/piecesjointe/filename/NECP_Report_CEMR_2023.pdf, p. 21 ff. ). Therefore, LRAs play a critical role as partners to European decision-makers in increasing energy efficiency ratios, leveraging their local expertise to identify projects, especially public building renovations with the highest marginal added value. CEMR underscores the ambitious targets set for Europe's subnational governments, such as the annual 1.9% energy efficiency objective until 2030 (EED Art. 5) and the 3% annual renovation obligation of public building stock (EED Art. 6), which often entail significant upfront capital expenditures. The current inability to accurately quantify local government energy efficiency investments, particularly evident for local governments of smaller and medium sizes, lacking centralized data collection, poses a challenge. CEMR calls for increased resources to map public buildings' energy efficiency and investment needs, facilitating better understanding of energy usage patterns and efficient resource allocation. Energy Efficiency Targets put serious pressure on municipal and regional budgets in a high-inflation environment The implementation of energy efficiency obligations exacerbates the financial stress on municipalities' and regions' public finances, particularly in the context of a tight fiscal environment and high inflation rates. In 2024, local governments are grappling with substantial operating costs, primarily driven by inflationary pressures, which severely constrain their capacity for investments. This financial pressure significantly impacts areas such as construction, infrastructure development, and energy efficiency initiatives for buildings. The constrained fiscal budgets may jeopardize the ability of local governments to meet co-financing requirements for external funding, potentially halting local investment initiatives in the near future. To generate additional funds for energy efficiency projects, LRAs may need to reallocate resources by reducing current expenditures and downsizing other public services. However, such measures could lead to diminished public acceptance of energy efficiency initiatives, as they may perceive cutbacks in essential services. Encourage compensation mechanisms for LRAs energy efficiency funding to ensure social acceptance CEMR urges the European Commission to encourage compensation mechanisms for LRAs energy efficiency funding to ensure social acceptance a precondition for the Green Deals success. Further evaluating existing EU and national public support programs for energy efficiency, including local heating transition, is essential. For more info see attached file.
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

The Council of European Municipalities and Regions (CEMR) welcomes this initiative aimed at providing guidance to Member States in their implementation of RED III concerning the designation of renewables acceleration areas. CEMR wishes to emphasize that the designation of acceleration areas will be only successful by fully associating local and regional governments / authorities (LRA), given the high decentralization of spatial planning competences as well as municipalities and regions proximity to EU citizens. Therefore, CEMR strongly advocates for respecting the principle of subsidiarity, ensuring alignment with the constitutional distribution of administrative competences within Member States, and emphasizing the need to foster citizens' acceptance of the green transition. This can be achieved by promoting a fair distribution of financial benefits derived from renewable energy generation. CEMR also addresses procedural concerns and recommendations. 1. Respecting the principle of subsidiarity and promoting multilevel governance CEMR stands in support of the overarching objective to streamline permit-granting processes through acceleration areas for renewable energies, thereby facilitating the green transition. However, achieving success in this endeavor depends upon upholding the principles of subsidiarity and proportionality as delineated in Articles 4 and 5 TFEU. Local and Regional Governments are primarily entrusted with competences pertaining to spatial planning and land use within their respective territories, as outlined in the CEMR Climate and Energy Report (2023), p 23: https://www.ccre.org/img/uploads/piecesjointe/filename/NECP_Report_CEMR_2023.pdf It is imperative to prevent acceleration areas from overlapping with existing national initiatives, such as the development of national energy parks, to avoid duplication of efforts and administrative complexities. The work on acceleration areas therefore needs to be amenable to factor in any ongoing efforts to that effect. The introduction of new deadlines poses significant stress on municipal resources, with many municipalities ill-equipped to meet the demands within the stipulated timeframes. To facilitate the timely and decentralized mapping of acceleration areas and permit processing, CEMR advocates for bolstering the capacity of LRAs in municipalities and regions. Adequate staffing for permit processing is imperative to uphold the integrity of this competence and ensure efficient operations. 2. Foster citizens' acceptance and participation in the energy transition LRA play a crucial role in ensuring public acceptance of renewable energy roll-outs as they are the closest decision-makers to the EU citizens. Potential tools for enhancing public acceptance include revenue-sharing or other benefits, such as demonstrated by the 2023 amendment of the Renewable Energy Law in Germany which provides project developers and municipalities the legal possibility to share financial benefits from the energy generation in their territories. Unfortunately, practice shows that many project developers avoid concluding a corresponding agreement. Feedback from smaller municipalities in particular has also shown that the voluntary nature of the payment means that there is an imbalance in negotiations between them and the operators when drafting the contract. 3. Further procedural concerns of Local and Regional Governments and recommendations CEMR raises additional procedural concerns regarding the implementation of acceleration areas, along with pertinent recommendations to address these issues effectively: Preventing Overlap with National Initiatives: It is imperative to ensure that acceleration areas do not overlap with existing national efforts, thereby avoiding duplication and streamlining the overall process. Clarity on New Deadlines and processes: There remains a pressing need to enhance clarity and simplify the process. For more info see attached file.
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European local governments urge streamlined energy efficiency reporting

30 Nov 2023
Topic — The European Commission aims to reduce legislative reporting requirements by twenty-five percent.
Message — CEMR recommends addressing the issue of duplicative regulation and energy efficiency reporting. They propose focusing only on national total contributions to energy savings and efficiency. This approach would involve reporting in relation to GDP or industrial output.123
Why — Streamlining reporting would eliminate redundant efforts and allow better resource allocation.45
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Meeting with Ciarán Cuffe (Member of the European Parliament)

15 Nov 2023 · Speech to members of the Conseil des Communes et Régions d'Europe

Response to Mid-term evaluation of the ERDF, the CF and the JTF 2021-2027

3 Oct 2023

Lessons learned from 2014-2020 period, and the reactions to COVID crisis and war on Ukraine showed that more flexibility in implementation, reporting and monitoring was possible in Cohesion Policy. The RRF showed it was possible to unlock massive investments for the green and digital transitions; smart, sustainable and inclusive growth; social and territorial cohesion; health, social and institutional resilience and education and skills. All objectives that can also be pursued through Cohesion Policy. However, the speed imposed by the RRF, and the multiplication of changes in the rules of Cohesion Policy proved to create additional administrative burden for Managing Authorities and beneficiaries who had to constantly adapt their process to benefit from CRII/CRII+; REACT; CARE/FAST CARE; and STEP; it forced them to make difficult prioritisation choices; and to put in place processes to prevent the risk of double funding. If funds had been channelled directly through Cohesion Policy, it could have avoided this unnecessary complexification. Using Cohesion Policy as a mean to finance changing political priorities (most recent example with STEP), is in fact counterproductive to the rapid and efficient spending on Cohesion Policy funds, and current delays in the start of 2021-2027 programming period are in most part due to urge in spending RRF and REACT EU before starting the implementation of the new period. CEMR strongly advise against the creation of ad hoc funds and new instruments during a programming period, but rather build on existing Cohesion Policy funds and rules, for instance, extending eligibility scope of activities rather than creating a new fund. It should have been possible to integrate the objectives of the Social Climate Fund, within the existing Cohesion Policy funds (European Social Fund Plus in particular) rather than the creation of a new funds with a centralised management (National Social Climate Plans). While the programming of the RRF Facility seemed more efficient and faster than programming of Cohesion Policy funds, it is too early to assess its real efficiency in delivering on its objectives. It has to be recalled that RRF was not submitted to Partnership Principle, and therefore as demonstrated by CoR-CEMR survey, most Member States did not involve representatives of local and regional governments in elaboration of national Recovery and Resilience Plans. In addition, since the scope of RRF is similar to the Cohesion Policy funds (including social, economic and territorial cohesion, green and digital transition), several Member States used RRF to funds projects that were initially foreseen for Cohesion Policy, given the time pressure to implement RRF faster. This contributed to additional delay in start of programming and implementation of the Cohesion Policy funds for 2021-2027. A number of simplification measures have already been introduced in the programming 2021-2027, but Managing Authorities and beneficiaries still report unnecessary administrative burden . This is only aggravated with regularly changing regulations. This could discourage municipalities and regions with less capacities hence with the most potential to benefit from Cohesion Fund to apply for Cohesion Policy funded programmes. Beneficiaries demand harmonisation of rules and processes among the different funds simplification is needed at both EU and national level. While the Policy Objective 5 Europe closer to citizens by supporting locally-led development strategies and sustainable urban development across the EU was introduced in the new period 2021-2027, CEMR research shows that since no mandatory thematic concentration was associated with this Policy Objective, its uptake has been quite low despite possibility to apply this PO in a cross-cutting way. Member States on average are only planning to use 5% of their allocations to PO5 and three Member States decided not to use it at all.
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CEMR Demands Local Autonomy for Net Zero Permitting Processes

26 Jun 2023
Topic — The consultation concerns the Net Zero Industry Act's framework for manufacturing green technologies.
Message — CEMR calls for avoiding detailed EU regulation to ensure local authorities maintain powers. They request removing binding permit time limits and reject the principle of tacit approval. The group also advises against regulating spatial planning or public procurement at EU level.123
Why — Local authorities preserve their decision-making autonomy and avoid increased administrative burdens.4
Impact — Environmental protection and drinking water quality could suffer due to technology prioritisation.5
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Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis), Pim Lescrauwaet (Cabinet of Executive Vice-President Valdis Dombrovskis)

1 Mar 2023 · Economic Governance Review

Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

2 Feb 2023 · TEN-T (Staff Level)

Meeting with Frances Fitzgerald (Member of the European Parliament, Rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

27 Oct 2022 · Proposal for a Directive on combatting violence against women and domestic violence

Response to Strengthening social dialogue

20 Oct 2022

“Please find attached the reply of social partners from the Sectoral Social Dialogue Committee of Local and Regional Governments published in July 2021 on the upcoming communication on social dialogue and particularly on the review of sectoral social dialogue. Already in that formal process, EPSU and CEMR highlighted the urgent need to frame the legislative implementation of social partner agreements in close consultation of social partners (e.g. clear legal framework and criteria, an effective and clear timeline for the EU Commission’s reaction following the principles of good administration); to better consult social partners at an earlier stage, including by making a better use of its political role in legislative processes, to provide national social partner organisations with specific dedicated support to be able to properly engage both at the national and European level; to recall that social dialogue committees representing public sectors should benefit from a strengthened relationship with the European Commission and, last but not least, to maintain a steady level of funding for sectoral social partners. Appropriate and dedicated financial opportunities should aim at supporting both the capacity of European organisations, which often lack sufficient means, and additional activities to reinforce the role of SSDCs. CEMR and EPSU, by replying to the present call for evidence, would like to reiterate the fundamental role of social partners’ consultation in all areas related to social policy. Calls for evidence or public consultations in matters that are also object to social partners’ consultation under art. 154 TFUE should not prejudice nor interfere with the outcome of social partners’ consultations. Even though the engagement and feedback of civil society must always be welcomed, social partners play a radically different role when it comes to social policy.”
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Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur)

11 May 2022 · New European Bauhaus

Meeting with Carole Mancel-Blanchard (Cabinet of Commissioner Elisa Ferreira)

11 Mar 2022 · Discussion on support by local authorities to refugees

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Summary: • more waste handling is expensive, and producers should pay for the impact of their products • possible conflict with state aid rules and polluter pays principle • Extended producer responsibility (EPR) – when well organised – could reduce waste and support circular value chains • local and regional authorities should be a targeted stakeholder The Council of European Municipalities and Regions (CEMR) is the European association of local and regional governments. Our members are the national associations of local and regional governments from 42 European countries representing all levels of territories – local, intermediate and regional. Our response to the call for evidence emphasises how EPR may meet the targets in line with the principles of polluter pays. EPR which does not cover all costs will not have the expected impact on less waste and better material flows. More green jobs follow better material flows. Put the costs where waste may be reduced Measures should be taken as early in the value chain as possible. That is where we find the biggest impact. When a product is wasted, collection should ensure a sustainable treatment.Therefore, European Waste initiatives should first and foremost place responsibility on the producers who may avoid products which are likely to be wasted. All the costs should be covered through Extended Producer’s Responsibility schemes. That includes when waste is collected, sorted and treated by municipalities. It is imperative to give producers incentives to avoid waste and apply sustainability to their products. Paying for all costs is an incentive. Conflict with state aid rules Not putting the costs on the EPR schemes could be in conflict with state aid regulations, as some EPR schemes are competing, and some schemes do not cover all costs which instead are covered by municipalities. Those not covering all the costs for «their» products will receive an advantage compared to those who take their full responsibility. Local and regional authorities as targeted stakeholders All waste occurs in a municipality. Local and regional authorities are stakeholders who bring important knowledge to the consultations. This knowledge may not be brought forward from national authorities, as they are unaware of the local effects of the legislation. Nor will private waste collectors know the role of a responsible local authority. Consequently, CEMR call for local and regional authorities and their representatives to be a targeted group of stakeholders in the coming consultations on the revised waste framework directive. The CEMR intends to provide feedback to the upcoming public consultation and will further contribute to the revision of the waste directive by communicating bottlenecks and good practices to move towards more sustainable waste management.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

CEMR acknowledges the need for increased energy efficiency and energy savings as necessary components to reach EU climate targets for 2030 and carbon neutrality 2050. We support ambitious climate and energy policy and action involving local and regional authorities (LRAs) as forerunners, when accompanied by appropriate frameworks, measures and financial resources. CEMR recalls the necessity to respect the subsidiarity principle, recognising the role of LRAs and multi-level dialogue and avoiding burdensome and inflexible legislation. The proposed absolute reductions in energy use and final energy consumption of all public bodies by 1,7% each year will be a huge challenge for most MS. It will require extensive capacity building in terms of finance, competence, guidance, data, reporting etc. Broad application of both existing and new transformative techniques and practices is necessary. LRAs need to be involved together with other stakeholders. Any target level should consider varying conditions for MS on the need and profitability for energy efficiency, available resources for renovation, population growth and urbanization etc. We question why the requirement for the public sector should be at the same level as the economy at large. The huge efficiency gains from electrification of transport and industry lay mostly outside the public sector. The choice of reference year will also matter, since 2020 saw a sharp drop of energy use in many public activities due to Covid-19. CEMR strongly opposes a requirement to renovate 3% of all public floor area. It does not regard local, regional & national conditions and actual needs for renovation and how long-term energy efficiency work is conducted, e.g. by efficient utilization of buildings, technical building systems and data, long term planning etc. It would be extremely costly and raise serious financial challenges for LRAs and eventually for taxpayers and tenants. It would raise a number of practical difficulties by not considering buildings of historic interest, lack of skilled labour and construction entrepreneurs, displacing effect on private sector renovation, local property markets, incentive to privatize public activities etc. CEMR is convinced that the energy consumption of the building stock can be reduced in more flexible and cost-effective ways. It is also essential to enable a life-cycle approach for GHG-emissions, since construction and materials can account for about half of total building emissions. We strongly advocate for a continued possibility for alternative measures and targets, such as absolute energy savings and increased energy efficiency per square meter. District, neighbourhood and portfolio approaches must also be recognized, to enable LRAs to apply energy efficiency and renewable energy with a wider scope than public buildings. NZEB and MEPS are not appropriate levels to mandate for renovation and for purchase or rent of buildings, since both are defined very differently among MS, in many cases only relevant to new buildings. Purchase of products, services, buildings and buildings with high energy-efficiency performance must be clearly left to the discretion of each LRA, respecting the principle of local self-government enshrined in Art. 4 TEU. CEMR rejects the proposed mandatory requirement for public procurement on LRAs beyond what is foreseen in Directive 2014/24. Instead central government should work in partnership with LRAs to build capacity and further encourage sustainability in public procurement. The present EED reference to cost-effectiveness, wider sustainability etc. should be kept. Any requirements for tyres must also consider winter conditions. (Anx IV) CEMR emphasizes that energy poverty, as other poverty, is primarily an issue for social policy. We support the aim to develop district heating, district cooling and CHP. However, we see a need to combine waste heat and renewable energy on an equal footing in targets.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

CEMR acknowledges the need to increase renewable energy to reach EU climate targets for 2030 and carbon neutrality by 2050. We support ambitious climate and energy policy and action in line with 2050 climate neutrality for the EU, involving local and regional authorities (LRAs) as forerunners, as long as accompanied by appropriate frameworks, measures and financial resources. CEMR recalls the necessity to respect the subsidiarity principle, recognising the role of LRAs and multi-level dialogue and avoiding burdensome and inflexible legislation. Regulation should be restrictive about detailed requirements and subtargets, in order to respect varying national and regional conditions. CEMR supports the increased 2030-target of 40% renewable energy. It is challenging, but there are great untapped potentials. LRAs are willing to contribute through own activities, procurement and public energy companies and by interacting with citizens and society. We object to the increased detailed regulation and reporting requirements for the use of biomass. Present RED sustainability criteria starting from July 2021 should be maintained, along with national legislation, to meet varying regional conditions. New requirements should only be introduced if assessments show that present criteria and risks motivate a more stringent approach. -A cascading principle is totally foreign to a market economy, which already ensures that quality roundwood, saw logs etc are used according to their economic value, and only their waste products as bioenergy. -Introducing a requirement not to harvest stumps & roots, does not appear to be firmly based in science. -Lowering reporting requirements from 20 MW to 5 MW will add a substantial administrative burden on many medium size energy plants. A 49% share of renewable energy in buildings is primarily an issue for the wider energy system and only secondly a building level issue. The indicative target should not need to be introduced in MS building codes if fulfilled in other manners. The same goes for requirements of substantial increases in self-consumption. We question that the usefulness is greater than the administrative costs for the suggested requirements to make available real time data on the share of renewables and greenhouse gas emission content of electricty. We support the aim to increase the shares of renewables and waste heat in the heating and cooling sector, in district heating, district cooling and CHP. However, the targets need to combine waste heat and renewable energy on an equal footing, instead of separate targets. Recovering waste heat should be a preferred activity. Require-ments to increase renewables in MS heat & cool by an additional 0,6%-2,9%/y need to consider the actual level, just as Art 24 counts above 60% as fulfilling the annual increase. Third party access on non-discriminatory criteria and relevant technical and economic considerations is reasonable, just as the non-discrimination and treatment on fair terms of energy communities and prosumers. CEMR supports the shift to reducing GHG-intensity, as a technology neutral approach to increase the share of renewables in the transport sector. We support the need to stimulate demand and market uptake of promising techniques such as green hydrogen and RFNBO. We emphasise the link with other legislative proposals e.g. AFIR and support targets for hydrogen refueling stations along the TEN-T core and comprehensive network. Financial support should not only focus on urban nodes. Much of the spatial planning required for hydrogen infrastructure is done by LRAs. Many LRAs are organised in the EU Hydrogen Valleys Partnership (S3 Platform), as recognised stakeholders in the hydrogen economy. The state aid regime should be revised as not to enable LRAs to co-finance such activities and infrastructure. For green hydrogen an exemption is needed from the additionality requirements, to avoid obstacles to invest in electrysers.
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Response to Delegated act supplementing the Instrument for Pre-accession Assistance (IPA III)

23 Aug 2021

CEMR and its members (national associations) welcome a consultation on IPA III, even if the objectives of this consultation remain unclear and how it is embedded in the overall programming process. Here are the priorities for local and regional governments: 1. Investing in the modernisation of infrastructure and in local economy: improve the public service delivery which ultimately would imply infrastructure projects at local and regional level in line with the regional economic integration. The current context of absence of a clear timeline for EU accession and intensifying regional economic integration in parallel with the EU integration requires the re-invention of a deeper institutional coordination link. Local Governments must have a substantial role in the recently adopted Regional Economic Market, in the Digital Transition Agenda, Economic and Investment Plan and the Green Agenda. Local governments should have direct access to EU funding opportunities 2. Supporting the provision of local public services (water, waste and circular economy, preserving nature, social healthcare, permits to local enterprises, etc.) 3. Support signatories & supporters to further develop Sustainable Energy and Climate Action Plans: NALAS as Regional Ambassador of the Covenant of Mayors promoted since 2009 the Covenant and welcomes the fact that the Commission supports via GIZ the Covenant of Mayors to be extended to the Western Balkans &Turkey starting 2021 4. Increasing local democracy, fiscal decentralisation & the capacity to mobilise local own-resources, and support to the respect of the European Charter of Local Self-Government: Decentralisation is the key pillar of democratisation process, peace building, reconciliation and stability of political systems in candidate countries. The Regional Decentralisation Observatory (https://nalas-observatory.eu/) can serve as a reference point for comparative benchmarking 5. Strengthening local public institutions: Institutional strengthening will contribute to make results of reform processes tangible and visible for citizens at local level. Important to be remembered in this context: 2/3 of EU acquis are implemented by local governments! 6. Support the localisation of the Sustainable Development Goals: IPA should enshrine in its programming and funding mechanism decentralisation as a cross-cutting principle with the obligation of multilevel coordination to provide the local level with adequate human resources & capacity 7. Recognise the need to work hand in hand with national associations of local and regional governments to increase the mobilisation of municipalities and reinforce multilevel governance in the countries as well as with NALAS 8. Supporting the policy dialogue with local governments through their Associations, when discussing accession & public administration reforms with EU institutions 9. Gender equality & the implementation of the European Charter for women and men in local life (CEMR Charter): raising awareness activities or training activities on the issue of gender equality within the local governments are an essential first step, and require EU support 10. The importance of peer-to-peer learning and decentralised cooperation to exchange knowledge and expertise between peers: Promote peer-to-peer learning and support the effective and systematic know-how transfer in peer review and peer learning among villages, towns and cities. Barriers for cooperation should be identified and the ways to overcome these problems need to be put on the agenda and discussed if we are to promote peer-to-peer learning and decentralized cooperation. Need to recognise the relevance &crucial role of decentralised cooperation as an effective & efficient contribution of the subnational level to overall EU development cooperation as well as a strategic tool to build ownership on the principles of inclusive partnership for sustainable development for/with citizens, leaving no place & no one behind
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Meeting with Pia Ahrenkilde Hansen (Director-General Communication) and European Movement International

18 May 2021 · Conference on the Future of Europe

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

19 Mar 2021

OUR MAIN MESSAGES IN SUMMARY 1)CEMR supports ambitious climate and energy targets in line with 2050 climate neutrality for the EU Member States (MS) and in non-EU countries where EU legislation applies. We emphasise the need to involve LRGs in both planning and implementation. Adequate pricing of carbon and energy should be a corner stone of policy along with technology-neutrality and a holistic view on energy systems, in order to reflect varying conditions on local, regional and national levels. 2) CEMR emphasises the importance of proper implementation of the current EPBD, strengthened by non-regulatory measures. Implementation needs to be accompanied by appropriate resources and measures for technical and policy support, as foreseen in the green deal recovery plans, while avoiding over-regulation and administrative burden. CEMR also calls for consistency with the EED and RED, where proposals will be published ahead of the EPBD. 3)On the need for amending the EPBD CEMR more specifically advocates for: ­-LRGs and MS should have the right to use a multi-dimensional approach reducing GHG-from a systems perspective, not only by energy efficiency measures on a building level. -A life cycle perspective on building materials and buildings is needed. -Measuring energy performance should be encouraged. ­-Standards for Minimum energy performance and deep renovation and increased renovation rates for public buildings should only be indicative and leave room for alternative approaches. ­-Renewable energy should be equally treated whether produced on-site at the building or supplied through energy-carriers. ­-MS should be allowed to set determining peak power requirements for buildings. ­-Any extending of requirements for EPCs should regard MS experiences. ­-Address the current overlap of Energy performance certificates and Energy audits. ­-Regulation should use realistic interest rates. ­-Avoid introducing split incentives, such as demands for individual billing of heating. ­-Extending requirements on integrate electrical mobility facilities into the built environment should leave room for a local/regional approach, following the sustainable mobility plans.
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Meeting with Margaritis Schinas (Vice-President) and

25 Feb 2021 · New Migration and Asylum pact

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

General remarks • Local and regional authorities (LRAs) play a significant role in delivering the UN sustainable development goals and EU 2030 climate goals. LRAs are in many MS big investors in buildings, infrastructure for water, wastewater, waste management, renewable energy, roads, mobility and public transport. These are commissioned to comply with EU-legislation, illustrating the need for long-term policy and coherence. Several LRAs have already contributed to the green bond markets, allowing also for small projects in smaller LRAs. • CEMR supports EU efforts to enhance sustainable finances. In this we see the taxonomy as an enabling tool to broaden investments in sustainable activities and increase ambition through a broad market uptake. It must respect the principle of local self-governance enshrined in Art 4.TFEU and not decrease the scope of action granted to LRAs by national or regional constitutions. • The taxonomy criteria must be easy to use for all the actors involved in sustainable finances, including LRAs and recognizing varying local and regional conditions across Europe. Not taking into account their specificities risks further widening existing inequalities. CEMR asks the EC to conduct a territorial IA of its proposals. The draft delegated act risks placing too high demands and a non-proportional administrative burden on many projects and actors. This would not unlock the potential for financing sustainable projects. The scope would be limited to big actors, big projects, and to the categories where demands are very permissive. It does not ensure technology neutrality, would miss out on many sustainable activities and result in a substantial need for alternative standards and frameworks on the market. It is not in line with the aims of the daft delegated act to ”ensure usability and proportionality” and being ”easy for economic operators to use”. Remarks on criteria Many of the proposed criteria are both ambitious and reasonable (for example the main criteria for energy efficiency for new buildings and for major renovations). Also the side criteria (DNSH) such as environmental impact assessment (EIA) and adaptation analysis and plans are relevant in many cases. In other cases the suggested criteria disqualify activities that are in line with sustainability according to other EU-legislation. Also the sum total of all criteria risks resulting in an undue burden. Problematic criteria include for example: • Buildings: Demands for adaptation, restrictions on land use and environmental impact assessments are quite far reaching and could in many aspects be better addressed through national legislation and local planning, than on a building level. The demands for Life cycle analysis and circular design should be implemented gradually. The energy efficiency criteria for acquisition of buildings should not only refer to EPC Class A, for which there is no common EU-standard. • Transport: Vehicles operating on biofuels, fulfilling sustainability and GHG-saving according to the RED, should be accepted. • Wastewater treatment: Demands on net zero-energy consumption and increased energy efficiency on operations have to be balanced vis-à-vis local conditions and the primary purpose to enhance water treatment. • Renewable energy: Requirements should as far as possible be technology neutral, in relation to GHG-savings and sustainability. For example life cycle analyzes should be applied in similar fashion to both hydro, wind, solar and bio energy. Bio energy fulfilling requirements according to the RED should be classified as a sustainable activity, in line with Taxonomy regulation Art 10, and not as transitional. It is also a basis for negative emissions (BECCS). Waste to energy fulfilling BAT-requirements should be included as a transitional activity. Efficient energy recovery is needed from waste that can’t be recycled due to contamination, material fatigue and complex mixtures
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Meeting with Nora Bednarski (Cabinet of Commissioner Helena Dalli)

21 Oct 2020 · Consultation in the context of the upcoming Disability rights Strategy

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Sept 2020

1. CEMR welcomes the priority given by the European Commission to renewable energy. CEMR supports ambitious climate and energy targets in line with 2050 climate neutrality 2. CEMR supports measures and targets for renewable energy on a voluntary basis put forward by MS 3. CEMR supports the implementation of the current directive, accompanied by appropriate resources 4. CEMR supports an appropriate Green Deal financing on renewable energy and energy efficiency 5. CEMR advocates for a focus on overall targets, frameworks and incentives such as adequate pricing of carbon and energy for GHG-reduction while simplifying the administrative burden and avoiding over-regulation 6. We support the transition to a more integrated energy system, regarding the fact that demands for new capacity and conditions for deploying various forms of renewable energy varies across regions in the EU 7. CEMRs wishes to avoid misdirected implementation through regulation and delegated acts 8. LRGs develop energy and climate protection plans incorporating renewable energy and energy efficiency
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Response to Long term vision for rural areas

8 Sept 2020

“Connected” and attractive rural areas: - There is no longer a clear separation between urban and rural areas, but rather an urban-rural continuum. The economic and social uplifting of rural areas will in large part depend on successful connections between the more rural and the more urban areas. This should also be encouraged in the F2F strategy with promotion of local products. - Economic diversification will be essential for development and attractiveness of rural areas. This can be possible thanks to technological developments and broadband access in rural areas, but this trend should be accelerated by public policies at European and national level. - Transport will be a key element for the opening up of most “remote” territories. It will be essential in connecting cities with their surrounding areas and to bring additional opportunities for rural areas inhabitants. The EU should support the development of lacking infrastructure or maintenance of existing ones. - Member States must ensure citizens living in rural areas have a similar access to quality public services than in other parts of the territory, as well as to economic, social and cultural opportunities. Territorial development should follow the principles of the New Territorial Agenda. - Communication on touristic and cultural assets of rural areas should be encouraged. - Local and regional governments must be considered as the key partners for national territorial development policies as well as for the implementation of European policies and instruments that contributes to territorial development. This means the European Commission should target more these specific territories that often don’t have the capacities to get involved in European projects. What the EU and European Commission could do: - A particular attention and specific financial support are needed to unleash the untapped economic, social and cultural opportunities of rural areas. The Structural Investment Funds and particularly the rural development component of the CAP should be EU primary instruments, while other instruments should also be more incentivised to target more specifically rural areas such as Horizon Europe, InvestEU as well as the Erasmus+ and the Connecting Europe Facility - The European Commission should also seek to facilitate the combination of different instruments when a territorial consistency is orchestrated by the local or regional governments (e.g. multi-funding between ERDF or ESF+ and the EAFRD) As a holistic exercise, the long-term vision must look into all EU-policies (Internal Market, Fiscal Policy, Competition etc.). It should draw the right conclusions, e.g. from the facts that a) the market does not provide certain services in areas of demographic decline and b) public procurement should be a tool to support the local and regional economy, not to destroy it. The provision of services is key to attractive rural areas. Responsible authorities have to react in a flexible way to regional needs and need to incentivise the local population to stay. EU-policies often follow a logic of maximising input-output relation, which rural areas per se cannot comply with. - We encourage a specific attention for youth in rural areas which for the Commission could translate in encouraging (via calls for proposals) projects of youth educational, cultural, sport or professional training exchanges from smaller rural municipalities. Which would mean designing programmes to which smaller municipalities could easily apply without additional administrative burden or with additional technical support to build the project and answer European calls for proposals.
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Response to 2030 Climate Target Plan

15 Apr 2020

1.Recognition of the role of Local and Regional Authorities, leadership and multi-level dialogue. In the present corona crisis LRAs are showing leadership, highlighting the importance of LRAs for communicating and mobilising citizens. LRAs can properly engage with the public in a continuous and regular dialogue. In the same way, LRAs need to strengthen the links and dialogue with the business community, civil society organisations, community groups and others. LRAs are key players in providing information to their members and working with the national government to ensure the coordinated action of all levels of government, including swift input for the need for changes in legislation and guidance for local government. This function of LRAs is an added value in making the relevant decision-makers aware of the need for climate change or adaptation. And the current health crisis is another example where we can see the leadership of the LRAs in communicating with the local level. 2.Ambition accompanied by appropriate measures, resources and frameworks. We welcome the Inception Impact Assessment on the roadmap for the 2030 climate target and the opportunity to give feedback to the Commission. This is in line with our commitment to an ambitious climate policy. However, the actions of the local and regional level need to always be accompanied by the appropriate measures, resources and frameworks. The local level cannot cope with all the existing and upcoming legislation without the necessary means. The local level is willing to make a difference and assist Member States and the EU in the implementation phase but we also need to assure that actions are feasible and that the appropriate conditions are well in place. 3.Simplify the administrative burden. CEMR advocates for a focus on overall targets and incentives while simplifying the administrative burden and avoiding over-regulation. We understand that this will be addressed when proposing specific legislative proposals in a next stage. The parallel process of the National Energy and Climate Plans (NECPs) requires local authorities to engage in various types of reporting (at least in some Member States). We therefore ask for a simplified reporting system with appropriate timing. Also, considering the delays in sending he NECPs and their subsequent impact assessments, we think it will be difficult to have an impact assessment on the 2030 climate target by this summer. 4.Delegated acts. Should the Commission need to adopt any delegated acts to implement any measures concerning the 2030 target, we would like the Commission to consult local and regional governments to assure that the act can really be implemented at the local level. Such acts need to respect the diversity of local, regional and national conditions. 5.Appropriate Green Deal financing. The Green Deal’s measures and realisations will be supported by funding and financial tools such as the European Green Deal Investment Plan, the renewed Sustainable Finance Strategy and the Just Transition Mechanism (see CEMR’s analysis of the JTM). We need to make sure that the right funding goes towards the right climate measures. To boost the economy, CEMR calls for investment in green markets. There is an urgent need for investment in a decentralised food market, in local, regional and long-distance public transport and in the expansion of renewable energy sources. The expansion of public infrastructure, renewable energy and the thermal refurbishment of buildings all create regional added value. The current COVID-19 situation will also imply adjustments, therefore CEMR wishes to be involved in these discussions at EU level. The speed and scale of the EU’s and Member States’ reaction to the COVID-19 crisis is heartening and shows that there is capacity to mobilise resources once there is sufficient understanding and political support for the need for transition 6.Flexibility in deadlines to respond to consultations,due COVID crisis
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

10 Mar 2020

The Council of European municipalities and regions (CEMR) welcomes the Commission’s proposal for a regulation to establish the Just Transition Fund, which is in line with the European Union's ambition to achieve carbon neutrality by 2050. We consider that this initiative will be crucial for regions, territories and municipalities that will have to implement radical changes and make significant investments to transition towards a carbon-neutral Europe. The CEMR is also glad to note that the Just Transition Fund is included under the Common Provisions Regulation, which implies that the drawing up of the territorial just transition plans will have to comply with the same rules as the other European Structural and Investment Funds (ESIF), in particular the code of conduct and the Partnership Principle. We strongly believe that local and regional governments should be closely associated with the preparation, implementation and monitoring of the territorial just transition plans. For this reason, CEMR also supports the addition of the reference to the Partnership Principle in the JTF final regulation and proposes to specify that Local and Regional governments directly targeted by the Just Transition Funds, should be represented in the Just Transition Platform. In addition, for an effective implementation of the Partnership Principle, we recommend that the code of conduct should be extended to the European Semester process. We also appreciate that the level NUTS 3 has been identified as the most appropriate level for drawing up the territorial just transition plans. However, in the identification of the territories needing support, CEMR recommends not overlooking territories that have already started their transition, often at considerable cost. These territories should also be supported by the JTF. However, CEMR would like to bring the attention of the Commission on some points of concerns. Firstly, we believe that the proposed €7.5 billion will not be enough to cover all transition costs, and only few territories will be able to benefit from the Just Transition Fund according to the estimation on the basis of the European Commission proposal. CEMR recommends an ambitious budget for both Cohesion Policy and efficient implementation of the Just Transition Fund in complementarity of the budget already foreseen for Cohesion Policy. The Just Transition Fund should only come on top of the foreseen cohesion budget, while we identify a clear risk that the introduction of the new Just Transition Fund will come at the expense of the European Structural and Investment Funds, and of the European Agricultural Fund for Rural Development (EAFRD) in particular. For this, the regulation should be clear that the Just Transition Fund should come with additional budget, and that it will not be detrimental to the budget of the other European Structural and Investment Funds. Secondly, CEMR consider that the compulsory ERDF and ESF+ co-financing principle should not be introduced in the final legislation. In fact, most of the activities proposed to be supported by the JTF (Article 4) would be in practice already possible to finance under the Policy Objectives 1 and 2 through the ERDF and ESF+. Therefore, CEMR recommends to leave the possibility open for each Member States to decide on whether they want to complement their JTF from ERDF and ESF+ or not. This decision will have to be taken in full compliance with the Partnership Principle. Finally, we also recommend that regions and territories that have already engaged a transition process at significant cost in the past years could benefit from the Just Transition Fund.
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Response to Gender equality in the EU

13 Feb 2020

Equality of women and men is a fundamental right and a core value of the European Union, which is reflected in the Treaties and European legislation, yet we are “still far from the finish line”. The promotion of this core European value needs to be mainstreamed in all policies of the EU and reflected in the allocation of resources. There is still a worrisome disparity between the de jure and de facto equality in Europe and significant efforts are still needed to combat the discrimination and inequalities which persist in all spheres of life: political, economic, social and cultural. According to the latest available data from CEMR, women remain underrepresented at all political levels—especially in top leadership positions—while representing 51% of the population of the European Union. There are 1 million local and regional elected officials in Europe, but only about 30 percent of those are women. In light of this stagnation on the one hand, and the demonstrated commitment of European Commission President Von der Leyen and Commissioner Dalli to gender equality on the other hand, CEMR is motivated to ramp up its commitment to building gender equality from the ground up and calls for an ambitious EU Gender equality strategy for 2020-2024 that engages local and regional governments as key strategic partners in its implementation. For nearly thirty years, CEMR has championed the principle of gender equality and actively worked to make it a reality in European towns and cities. In particular, through the engagement of the local politicians in its Standing Committee for Equality and the development and promotion of the European Charter for Equality of Women and Men in Local Life which currently counts 1,800 signatories in 36 countries. The Charter encourages local and regional governments to make a formal commitment to the principle of equality of women and men, and to draw up and implement equality action plans which set out priorities, actions and resources to promote gender equality in all spheres of life, counter gender-based stereotypes and combat related discrimination and disadvantages, including multiple discrimination. CEMR’s members—national associations of local and regional government—represent the municipalities, cities and regions that enhance gender equality in their role as democratic actors, service providers, planners and employers. Local and regional authorities have a key role to play in ensuring gender equality, and in this role, they have an effect on the daily life of EU citizens and advance equality between women and men. While recognising the important progress that has been made, CEMR notes that gender equality is still not achieved and wishes to contribute to the positive social transformation of Europe so that every girl, boy, woman and man can enjoy equal human rights and equal opportunities to pursue their ambitions in all spheres of life. Respect for gender equality, the safety of local residents, equal access to and control of resources, and prevention of gender-based violence are the building blocks of a vital and socially sustainable society. The key targets for an EU Gender Equality Strategy should be linked to sustainable economy, parity in decision-making and safety—starting at the local and regional level. The priorities should also include work-life balance, sexual and reproductive health and economic equality. Special attention should be paid to the situation of immigrants and minority groups. The situation and safety of girls and women must be core values and prioritised not only within the EU, but in external relations as well. The delivery of these priorities requires intersectional analysis of inequalities, a cross-cutting approach and special measures; for maximum impact it should be complemented by town-to-town cooperation for development with other regions. A detailed version of CEMR’s contribution to the Roadmap is attached.
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Meeting with Olivier Smith (Cabinet of President Ursula von der Leyen) and Eurocities and

5 Feb 2020 · Climate Pact, Covenant of Mayors

Meeting with Günther Oettinger (Commissioner)

25 Sept 2018 · MFF local region

Meeting with Marc Lemaitre (Director-General Regional and Urban Policy)

15 Sept 2017 · Futur de la Politique de Cohésion et coopération en général entre la DG REGIO et le CCRE

Meeting with Monika Ladmanova (Cabinet of Commissioner Věra Jourová)

22 Mar 2017 · Gender equality

Meeting with Marc Lemaitre (Director-General Regional and Urban Policy)

29 Nov 2016 · Future of Cohesion Policy

Meeting with Baudouin Baudru (Cabinet of Commissioner Marianne Thyssen), Stefaan Hermans (Cabinet of Commissioner Marianne Thyssen)

23 Sept 2016 · Cohesion policy

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

16 Jun 2016 · The integration of the Compact of Mayors and Covenant of Mayors

Meeting with Maroš Šefčovič (Vice-President)

15 Jun 2016 · Global Covenant of Mayors

Meeting with Alice Richard (Cabinet of First Vice-President Frans Timmermans)

12 Jan 2016 · Better Regulation package

Meeting with Karmenu Vella (Commissioner)

26 Feb 2015 · Environment Policy, Local Authorities

Meeting with Frans Timmermans (First Vice-President)

25 Feb 2015 · Better regulation

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

3 Feb 2015 · Low Carbon Future