- relevant documents
18.06.2013 Consultation on the Draft General Block Exemption Regulation (the GBER) on state aid measures HT.3365-SAA-GBER review
The Cross-border Cooperation Programme Italy-Slovenia 2007-2013 is participating in the Consultation on the Draft General Block Exemption Regulation (the GBER) on state aid measures HT.3365-SAA-GBER review.
Our proposals were:
1) The draft GBER foresees an exemption for SMEs cooperating in ETC (Article 18: Aid for SMEs’ cooperation costs linked to ETC projects). Many ETC programmes have pointed out that this is already a big success but we need to try to open this up to all partners in ETC, not only SMEs.
2) The maximum co-financing rate of 50% is too low and contradicts maximum co-financing rates in ETC.
3) The wording and concepts used in the draft GBER must be aligned with ETC rules, including the planned cost categories. In our response, we tried to find all the contradictions and provide possible solutions
4) The draft GBER foresees an exemption for investments in some regions (Article 15: Regional investment aid). This Article is rather unclear and its application to ETC seems problematic. In our response we tried to suggest solutions to make it useful and bring it in line with ETC. For example the Article should not be limited to investment but should cover all cooperation activities in ETC. We did not suggest deleting the Article as there is still a chance it can be made useful.