Programme for Development of the Regions 2021 – 2027 STRATEGIC CONSULTATION REPORT EUROPEAN UNION European Regional Development Fund Programme for Development of the Regions 2021 – 2027 STRATEGIC CONSULTATION REPORT EUROPEAN UNION European Regional Development Fund This report is a product of the International Bank for Reconstruction and Development / the World Bank. The findings, interpretation, and conclusions expressed in this paper do not necessarily reflect the views of the Executive Directors of the World Bank or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. This report has been delivered on October 25, 2019, under the Advisory Services Agreement on Enhanc- ing the Regional Development Process in Bulgaria and Supporting Ministry of Regional Development and Public Works in the Programming Process for the Period 2021-2027, signed between the Ministry of Regional Development and Public Works of the Republic of Bulgaria and the International Bank for Reconstruction and Development on April 8, 2019. It is Output 2 — Report outlining the strategic con- sultation on improving regional development pol- icy in Bulgaria - in the above-mentioned agreement. Budget line BG16RFOP001-8.002-0005 “Budget line of “Strategic planning and programming” Unit, GD “SPPRD” Cover design: Wojciech Wolocznik, Cambridge, United Kingdom Interior design and typesetting: Piotr Ruczyński, London, United Kingdom CONTENTS Acknowledgements   6 Abbreviations and Acronyms   7 Executive Summary   8 Introduction    13 PART 1  Strategic consultations on improving regional development policy in Bulgaria — scope, objectives, approach and methodology   17 Scope and objectives of the strategic consultations   18 Methodology of strategic consultations   18 Activities performed within the framework of strategic consultations    19 PART 2  Key findings from strategic consultations    21 New Integrated Regional Concept    22 Regional Development Councils    26 Regional policy planning and EU funds programming    29 Other findings from strategic consultations   32 PART 3  Recommendations for further actions based on findings from strategic consultations    35 PART 4  New Integrated Regional Concept and its Adaptation — independent reviews of WB team    41 New Integrated Regional Approach — independent review and options to consider    43 Structure of OP RG 2021 – 2027 — independent review and options to consider   46 Guidelines for IP beneficiaries — independent review and recommended steps forward    49 RDC model structure — independent review    51 Draft amendments to RDA and its Rules for implementation — independent review of legal implications   57 Conclusions    63 ANNEX 1 Questionnaire for strategic consultation    66 ANNEX 2 Questionnaire stakeholder mapping    70 ANNEX 3 Schedule of strategic consultations    71 ANNEX 4 List of Participants Strategic Consultations under Operational Programme Regions in Growth 2021 – 2027    74 FIGURES FIGURE I.1 Bulgaria Regional Development RAS timeline   14 FIGURE 2.1 Stakeholders’ stance on the new integrated regional concept — findings from stakeholder mapping   24 FIGURE 2.2 System of strategic and planning documents in Bulgaria (2014-2020)   29 FIGURE 4.1 Implementation of the New Integrated Regional Concept — key decisions, sequencing and implications (‘decision tree’)   43 FIGURE 4.2 Decision-making process under RDC Scenario 1   53 FIGURE 4.3 Decision-making process under RDC Scenario 2.1   54 TABLES TABLE 2.1 RDCs scenarios under consultation   26 TABLE 2.2 Possible solutions for enhancing the quality of strategic development and planning documents   32 TABLE 3.1 Recommendations based on findings from strategic consultations   37 TABLE 4.1 Legal framework for regional policy implementation in Bulgaria   57 5 ACKNOWLEDGEMENTS This report is delivered under the provisions of the Reimbursable Advisory Services Agreement on Enhancing the Regional Development Process in Bulgaria and supporting Ministry of Regional Development and Public Works in the programming process for the period 2021 – 2027. It was prepared under the supervision of David N. Sislen (Practice Manager, Urban and Disaster Risk Management, Europe and Central Asia), and Fabrizio Zarcone (Country Manager, Bulgaria, the Czech Republic, and Slovakia), and technical guidance from Paul Kriss (Lead Urban Specialist, Europe and Central Asia). This report was developed by a team led by Joanna Masic, Senior Urban Specialist (Task Team Leader) and comprised of Eolina Milova (Senior Environmental Specialist), Grzegorz Wolszczak (Operations Specialist), Anna Banaszczyk (Senior Regional Planning Specialist), Yana Georgieva (Senior Public Administration Specialist), Alexandar Hinov (Senior Public Administration Specialist), Atanas Kirchev (Senior Legal Consultant), Bellin Mollov (Senior Advisor on Regional Policy), Zdravko Petrov (Urban and Regional Planner), and Solene Dengler (Urban and Regional Analyst), with guidance from Ivelina Taushanova (Senior Communication Specialist). The team would like to express its gratitude for the excellent cooperation, guidance and feed- back provided by the representatives of the Ministry of Regional Development and Public Works of the Republic of Bulgaria, The Central Coordination Unit of the Council of Ministers, Members of the Reimbursable Advisory Services Steering Committee, and the many stake- holders at national as well as regional, district and municipal level, from government and non-government who provided ideas and inspiration during the national and regional level strategic consultations. Country Manager: Fabrizio Zarcone Practice Manager: David Sislen Task Team Leader: Joanna Masic 6 Strategic Consultation Report ABBREVIATIONS AND ACRONYMS CLLD Community Led Local Development DDS District Development Strategy EC European Council ERDF European Regional Development Fund ESF European Social Fund EU European Union GDP Gross Domestic Product ITI Integrated Territorial Investments IP Integrated Project LAU Local Administrative Unit MA Managing Authority MDP Municipal Development Plan MRDPW Ministry of Regional Development and Public Works OECD Organization for Economic Cooperation and Development OPRG Operational Programme for Regional Development RAS Reimbursable Advisory Services RDA Regional Development Act RDC Regional Development Council SC Steering Committee SCD Systematic Country Diagnostic TAIEX Technical Assistance and Information Exchange ToR Terms of Reference WB World Bank 8 Strategic Consultation Report The new integrated regional concept and its general reception among consulted stakeholders EXECUTIVE The new integrated regional concept un- derstood as adding a more territorial dimen- sion to development policy in Bulgaria and SUMMARY earmarking to this end a portion of sectoral funds under 2021  –  2027 Operational Pro- grams (OPs), generated substantial support across all stakeholder groups both on na- tional and subnational level. Also, the idea This report summarizes the findings from of integrated projects received generally pos- the strategic consultation process on im- itive feedback as a potentially useful tool for proving regional policy in Bulgaria, which effectively tackling territorial development took place between July to October 2019 un- challenges identified in Bulgaria. der the auspices of the Ministry of Region- al Development and Public Works (MRDPW) Insufficient information on the implemen- and Central Coordination Unit (CCU) of the tation framework for the new integrated re- Council of Ministers, with support from the gional concept and a limited understanding World Bank. of the nature of integrated projects were raised across stakeholder groups as important There were two primary goals of the strate- areas to further advance during the process. gic consultations. First, to raise awareness Much greater clarity in these two areas will of key stakeholders on national and subna- help to effectively motivate potential benefi- tional (regional, district and municipal) lev- ciaries to elaborate integrated projects, apply els about the regional policy shift to be in- for funds, and create even greater and broad- troduced by central government within the er-based support for the envisaged policy shift. framework of the 2021 – 20207 EU program- Progress in these two areas would also reduce ming period. Second, to obtain feedback from possible risks to the effective implementation consulted stakeholders on three main topics: of EU Cohesion Policy in Bulgaria under the (i) MRDPW’s new integrated regional concept 2021 – 2027 programming period. for 2021  –  2027 financial perspective; (ii) pos- sible new functions of the Regional Devel- opment Councils (RDC) to be introduced for Regional Development Councils: the purposes of implementing the new inte- new roles, functions, composition, grated regional concept; and (iii) ways of en- and capacity hancing the effectiveness of coordination be- tween regional planning and programming of Delegation of more authority to the re- EU funded investments for years 2021  –  2027. gional (sub-national) level with regard to planning and selecting EU-funded inter- The report also presents the key outcomes of ventions was broadly accepted. However, the World Bank team’s ongoing independent there was no univocal consensus on a sin- reviews of various draft documents, which gle optimal ‘regional model’ to pursue in the constitute the implementation framework of coming years. Both Scenario 1 and 21 for Re- the new integrated regional approach to the gional Development Councils (RDCs) gained 2021  –  2027 programming period. traction during the consultations, with 1. Scenario 1 foresees the RDC executive functions to be performed by the six regional departments of the Ministry of Regional Development and Public Works - providing their enhanced capacity, whereas Scenario 2 envisages these functions to be performed by either an institutionalized RDC Office or new regional entities to be created — e.g. regional development agencies. Executive Summary 9 the latter being generally more preferred. combine guidelines of Managing Authorities Even though Scenario 1 was perceived as a (MAs) (and operational manuals) were seen as more pragmatic choice because of the swift- challenging by some MAs and the adaption of ness and the relative simplicity of its imple- the UMIS to accommodate the requirements mentation, the advantage seen with Scenar- of managing integrated projects as a critical io 2 is that it could potentially create a stron- yet time-consuming task. Beyond these oper- ger foundation towards building fully oper- ational matters, stakeholders believe that CCU ational administrative structures at NUTS 2 and MRDPW will need to take a strong leader- level in the longer-term and a more expedi- ship role in the regional approach to ensure ent route to greater delegation of responsi- the necessary support from all MAs to both bilities in future. RDC development and the technical support to RDCs that will be required for them carry Decentralization was a recurring issue of- out their new functions. ten raised throughout the consultations. In particular, municipalities raised their expec- tations for a renewed effort in this domain. Coordination of regional policy plan- These local stakeholders would like to see the ning and EU funds programming evolution of the role of the RDCs as one of the elements of a broader decentralization Stakeholders perceive that there is substan- agenda to be pursued by the central govern- tial scope to improve the coordination of ment in the coming years. regional policy planning with EU funds programming. Currently these two domains RDCs are broadly perceived as ineffective, are seen as not adequately aligned, failing devoid of competences and sufficient ca- to create synergies and not sufficiently in- pacity, and therefore incapable of playing tegrating local stakeholders. This results in a substantial role under the new integrat- perpetuating a top-down approach to pro- ed regional concept in their current form. gramming, which is not yet complemented To effectively take on the new functions and by such a more bottom-up approach as being roles their capacity would have to be built advocated under the new concept for region- from a low base, which constitutes a signifi- al development. There was a call from local cant challenge given the limited time avail- stakeholders to start the reforms with a bet- able before the 2021 – 2027 programming pe- ter assessment of local needs and create re- riod and in terms of the sustained capacity gional strategies that could bridge between building efforts that would be required during locally prepared municipal and district plans the whole period. However there seems to with centrally commissioned regional plans be substantial — but dispersed — capacity al- and schemes. ready existing on municipal and district lev- el, and amongst government and non-govern- Stakeholders shared their concerns about lim- ment stakeholders, which could be pooled to ited — and therefore insufficient — access to effectively provide a foundation for develop- disaggregated socio-economic data crucial ing the capacity of RDCs. for analysing regional needs and elaborat- ing development strategies that accurately Stakeholders expect that preparations for reflecting the specific situation of a given ter- the 2021 – 2027 programming period would ritory, which should be useful tools support- need to begin promptly given the sophisti- ing well informed, evidence-based decisions cation of the new integrated regional concept. on investment priorities. Specific expectations include establishing a project pipeline and running an intensive Insufficient coordination and synchroni- training and coaching program dedicated zation of activities at the central level (be- to key local and regional stakeholders and, in tween OPs, ministries, agencies, etc.) — as the longer-term, provision of hands-on tech- observed in some areas by the consulted stake- nical support for the creation of partnerships holder under 2014 – 2020 programming period and the formulation of integrated projects. (i.e. lack of synchronized timing for announc- Additionally, at the central level, efforts to ing calls for proposals, protracted assessment 10 Strategic Consultation Report and contracting of projects) — if not adequate- identification and sufficient preparation of ly addressed could have a detrimental impact integrated projects; (iii) conducting an in- on the implementation of the new integrat- tensive training and coaching program ed regional concept, as the integrated proj- dedicated to key municipal, district, and ects are to consist of components financed regional stakeholders, as well as to MAs from different OPs. and regional branches of MRDPW. 3. Designing and putting in place a ‘moti- Key recommendations for MRDPW vation system’ to encourage prospective based on findings from strategic beneficiaries to apply for funding for in- consultations tegrated projects and ensure a more effi- cient uptake of funds (e.g. indicative lists Findings from the strategic consultations led of projects, regional financial envelopes). to the formulation of a number of recommen- dations with a view to supporting MRDPW in 4. Collecting more information on the de- effective implementation of the new integrat- sired thematic scope of potential inte- ed regional concept. grated projects (e.g. by means of an in- ternet survey) and required volume of Given the limited time remaining for the pro- funding to help estimate expected de- gramming process for 2021 – 2027 and the fact mand for financing and to identify areas that integrated projects are to constitute the where expertise will be most needed to very heart of the new approach it is recom- assist potential beneficiaries in the elab- mended that MRDPW takes the following ac- oration of integrated project proposals, as tions dedicated to effectively stimulate the well as to assess them as part of the selec- demand side of the new policy: tion procedure. 1. Prompt preparation of a comprehensive Each of the consulted RDC scenarios holds and detailed implementation framework its merits for enhancing the regional dimen- for the new integrated regional concept, sion of development policy in Bulgaria. For consisting of: (i) a set of unified guide- a final decision on the selected RDC scenario lines for beneficiaries of integrated proj- it is recommended to conduct a holistic as- ects (for horizontal use across OPs), (ii) a sessment of the operational modalities of the user’s manual explaining modalities of EU funds’ management system with a broad- the new integrated regional concept, and er and longer-term view of the future decen- (iii) template(s) of integrated project tralization agenda. In order to ensure a more partnership agreement(s) containing universal buy-in of stakeholders on the sub- key obligatory clauses that regulate rela- national level in supporting and recognizing tions between partners and their roles in the new roles of RDCs, actively engaging them the integrated projects. in a sustained intensive capacity building pro- cess that will require pooling resources and 2. Active support for the process of elabo- providing RDCs with political leverage to ef- ration of integrated project concepts by: fectively represent the regional perspective, (i) making OP RG 2014 – 2020 technical as- it is recommended that MRDPW and CCU for- sistance funding as well as national bud- mulate a longer term, post-2027 vision for get resources available for financing the the RDCs and a credible action plan for its integrated project preparation phase for implementation. This plan will aim to in- local and regional stakeholders; (ii) estab- clude and bring along key central and lo- lishing a project pipeline to ensure timely cal stakeholders in the process. INTRODUCTION 14 Strategic Consultation Report This report — constituting Output 2 of the 2021 – 2027 programming period is evolving, Bulgaria Regional Development RAS — sum- which means that some of the conclusions marizes the findings from the strategic con- from the strategic consultations as well as sultation process on improving regional pol- recommendations, which draw upon them icy in Bulgaria, which took place in July 2019 may no longer be fully relevant or applica- under the auspices of the Ministry of Regional ble in their entirety. However, for the sake of Development and Public Works (MRDPW) and clarity and transparency of the consultation formulates recommendations for further ac- process, they were inserted into this report tions. It also presents the key outcomes of the as they present a complete picture of the ac- Bank team’s ongoing independent reviews complished scope of work, as well as reflect- of various draft documents (at the request of ing on the stance and attitudes of consulted MRDPW) which constitute the implementation stakeholders in the ‘freeze-frame’ moment of framework of the new integrated regional ap- when the consultations took place. proach to the 2021 – 2027 programming period. For easy orientation as to the current phase It is important to acknowledge that the pro- of RAS implementation, the graph below pres- cess of preparing the implementation of the ents the key activities under the RAS, with new integrated regional approach for the their respective timelines. FIGURE I.1 Bulgaria Regional Development RAS timeline Inception (July 26) Strategic Consultations and Initial Review of RDA Mechanisms to involve RDCs in 2021-2027 Proposal to involve RDCs Operational Documents Technical Assistance and Reviews (planning for 2021-2027) Analysis of use of territorial instruments for 2021–2027 Ongoing review of strategic approach for 2021–2027 Proposal for guidelines for territorial and urban projects July Aug. Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. 2019 2020 PART 1  STRATEGIC CONSULTATIONS ON IMPROVING REGIONAL DEVELOPMENT POLICY IN BULGARIA — SCOPE, OBJECTIVES, APPROACH AND METHODOLOGY 18 Strategic Consultation Report In July 2019, MRDPW conducted national and stakeholders that would in the future under- regional level strategic consultations on se- pin some of the new key functions of RDCs i.e. lected issues related to regional policy in Bul- public consultation and mediation of part- garia with the participation of the Central Co- nerships. Regular information exchange and ordination Unit (CCU) of the Council of Min- interaction between key actors is an essen- isters (COM) and support from the Bank team. tial requirement for effective cooperation, This section presents an overview of the objec- which is one of the key enablers of region- tives of the strategic consultation process and al development. its thematic scope, the methodology for the consultations, stakeholders engaged, as well as the consultation activities that took place. Methodology of strategic consultations Scope and objectives MRDPW’s aim was to engage a wide range of of the strategic stakeholders from municipal, district, re- consultations gional and national level administrations, as well as social and economic partners, to en- There were two primary goals of the strate- sure an inclusive nature of the strategic con- gic consultations: sultations and collate sufficiently rich feed- back from different stakeholders. The Bank 1. to raise awareness of key stakeholders on team supported MRDPW in developing a broad national and subnational (regional, dis- and representative list of stakeholders to en- trict and municipal) levels about the re- sure the engagement of all key actors, ranging gional policy shift to be introduced by from institutions responsible for program- central government within the frame- ming and implementation of EU financed work of the 2021 – 20207 EU programming instruments (Managing Authorities [MA] of period, as well as sectoral Operational Programmes [OP]), pro- spective project beneficiaries on the subna- 2. to obtain feedback from consulted stake- tional level (primarily municipal adminis- holders on three main topics: trations), RDCs, business organizations, NGOs, • MRDPW’s new integrated regional con- academia, various associations representing cept for 2021 – 2027 financial perspective, the collective interests of diverse groups of • possible new functions of the Regional stakeholders (i.e. municipalities, Local Ac- Development Councils (RDC) to be intro- tions Groups, business, industry). Such an duced for the purposes of implementing approach was conducive to collecting views the new integrated regional concept, and on the consulted topics formulated from dif- • ways of enhancing the effectiveness of ferent perspectives depending on the scope coordination between regional planning of the engagement of different categories of and programming of EU funded invest- stakeholders in planning and implementing ments for years 2021 – 2027. regional policy in Bulgaria, their capacity, ex- perience, needs and expectations. Strategic consultations were designed to pro- vide the engaged stakeholders with a platform A detailed questionnaire (see Annex 1) — de- to share their opinions, reservations and veloped by the Bank team in consultation ideas during open discussion. This open, in- with MRDPW — was applied throughout the clusive ‘brainstorming approach’ was also a process of strategic consultations to ensure way to engage stakeholders in a meaningful a standardized approach. It was structured in dialogue about the desired shape of Bulgar- such a way to enable an in-depth consultation ian regional policy in the coming years, its on numerous aspects of the consulted topics implementation framework and specific op- and effective collecting of feedback to be used erational modalities. The aim of the strate- for formulating specific recommendations. gic consultation was to also establish a new form of regular communication with all Additionally, with a view to providing MRDPW Part 1 Strategic consultations on improving regional development policy in Bulgaria 19 and CCU with additional information on the initial attitudes towards the proposed policy change across different stakeholder categories, grouped by selected attributes, a stakehold- er mapping exercise was conducted based on a dedicated stakeholder mapping ques- tionnaire (see annex 2). Stakeholder mapping was based on a list of potential stakeholders according to the analysis of the management processes for EU funds in Bulgaria. Stakehold- Meeting for the South-Central region in Smolyan ers were grouped according to their level of involvement, functions and responsibilities in an OP or the project cycle. The question- naire factored in stakeholder knowledge, in- terest, viewpoints, groups they represent, in- volvement in the decision-making process etc. Applying the method of content analysis, all completed questionnaires from meetings were thoroughly examined in order to iden- tify stakeholders’ interests or ‘stakes’ in the newly adopted regional approach, detect po- Municipal representatives in SC region tential misunderstandings and even opposi- tion, and provide MRDPW with information to have more targeted discussions with spe- cific stakeholders. Activities performed within the framework of strategic consultations Meeting with the Mayor of Plovdiv During the three weeks of consultations (July 8 – 26, 2019) a total of 61 consultation meet- ings took place and were attended by more than 500 participants interested in sharing their views on the topics under consultation. The meetings took place at the central level, as well as in different locations in all six re- gions (NUTS 2 level), which made participa- tion in the consultation process easier for sub- national stakeholders. MRDPW made signifi- cant effort to arrange all the meetings with Meeting at Burgas the stakeholders and set up a schedule to al- low the WB team to meet as many stakeholders as possible. The consultation meetings them- selves were led by MRDPW and CCU as cham- pions of the new regional concept and were facilitated by the WB team. MRDPW and CCU participated in the meetings explaining the rationale behind the new regional concept and providing additional information requested on the spot by stakeholders. The full sched- ule of meetings held is included in annex 3. Meeting for the North-West region in Pleven PART 2  KEY FINDINGS FROM STRATEGIC CONSULTATIONS 22 Strategic Consultation Report This section is organized around the three complementarity of development inter- key topics of the consultation process, namely ventions also received generally positive the new integrated regional concept (includ- feedback as a potentially useful tool for ef- ing integrated projects as a vital element of fectively tackling territorial development the new approach), the new roles and func- challenges. However, since the concept was tions envisaged for Regional Development yet to be fleshed out at the time of strategic Councils (at NUTS 2 level), and coordination consultations the idea of integrated projects, of regional policy planning with EU funds elaborated and implemented under partner- programming. Additionally, a separate sec- ship agreements, raised a lot of questions tion is devoted to other issues that were raised and concerns especially from their prospec- in the process of strategic consultations. This tive beneficiaries. section will then be followed by Part 3 that outlines implications and recommendations Some stakeholders at the local level assessed derived from the key findings of the strate- the proposed policy change as too radi- gic consultations. cal, as some of the most basic infrastruc- ture needs observed at the municipal level were still unmet, despite efforts made un- New Integrated Regional der the current programming period. For this group, a preferred arrangement would be Concept to keep a substantial part (ca. 50%) of budget for 2021 – 2027 under the current implemen- General attitude among consulted tation mode (relatively simple projects sup- stakeholders porting the development of new infrastruc- ture and modernization of the existing one, The new regional concept understood as add- pre-defined beneficiaries and projects with ing more of a territorial dimension to devel- predetermined budget allocations). opment policy in Bulgaria and earmarking to this end sectoral funds under 2021 – 2027 For a number of stakeholders, the goal of the OPs seems to generate substantial support, current reform was not fully clear — there although the level of awareness of the new was uncertainty or even confusion whether regional concept is mixed. There appears this was part of a broader decentralization to be widespread conviction across all cate- process or restricted to attempts to increase gories of stakeholders, only with some minor the efficiency of EU funded development in- exceptions, that the current top-down model terventions and regional policy. It is import- of planning and implementing development ant to note that decentralization was a re- interventions in Bulgaria is not generating curring topic during consultations and a sub- the desired results particularly with regards stantial number of stakeholders voiced expec- to effectively addressing regional disparities. tations that the new regional concept and the restructuring and potential institutionaliza- Stakeholders generally agree that there is need tion of RDCs would gradually lead to empow- for a paradigm shift in approach for Bulgaria ering local government both in terms of de- to fully reap the benefits of EU financing under cision-making competences, financial flexi- cohesion policy. There is also general consen- bility to more independently pursue their op- sus that the complexity and gravity of devel- erations, and fill the administrative vacuum opment challenges for the regional tier in between the lowest and highest levels of gov- Bulgaria call for a more integrated, intersec- ernment. Observations were made that the new toral approach in planning and implementa- regional concept is a welcome first step to- tion of projects, more territorial sensitivity wards decentralization but not ambitious (bottom-up) and more actors (both govern- enough and cannot solve some fundamental ment and non-government) acting in concert problems experienced by local authorities: to successfully address them. unreasonably high number of municipalities, huge disparities in size and socio-economic The notion of integrating investments and demographic potential between munic- to ensure sufficient critical mass and ipalities, their financial dependence on the Part 2 Strategic consultations on improving regional development policy in Bulgaria 23 central government and the fact that the dis- 10% of their OPs allocation to be managed trict level (NUTS 3) is not directly elected but exclusively by MRDPW to avoid the foreseen rather appointed by central government and challenges and risks. therefore lacking sufficient legitimacy to pur- sue policies on a subnational level. Stakeholders representing the municipal and district level — as prospective beneficiaries of integrated projects — raised a number of ques- Implementation framework tions specifically related to the nature of Integrated projects and the modalities for As much as ‘the philosophy’ behind the new their elaboration and implementation in regional concept and the rationale for its in- partnership with other entities. The very no- troduction seem to be endorsed by almost all tion of an integrated project and its scope stakeholders it is the feasibility of its imple- of intervention is unclear to, and differently mentation that generates most discussion interpreted by, consulted stakeholders, which as well as concern. created confusion and uncertainty as to ex- actly what types of projects will be eligible The majority of national level stakeholders for funding under the new regional concept. (MAs of OPs set to earmark 10% of their pro- spective allocations for the purposes of the As set out by MRDPW, the structure of inte- new regional concept) raised concerns relat- grated projects may encompass components ed to the potential implementation frame- eligible for financing under different sectoral work. They identified a number of signifi- OPs, which generated concern among stake- cant risks that — if left unmitigated — could holders, who fear additional bureaucratic impact the effectiveness of the absorption of burden and coordination inefficiencies re- EU funding in Bulgaria under the 2021 – 2027 sulting from the need to comply with differ- programming period. The MAs’ attitude to the ent and often inconsistent implementation new regional concept is based on their nega- frameworks of sectoral OPs (eligibility criteria, tive experience with multi-OP projects so procedures, financing systems, targets etc.). far: their complicated nature requires dispro- portionally higher administrative resources in All crucial phases of an integrated project comparison to the funds managed, which can life cycle — project concept, project prepa- lead to inefficiencies and distraction of the ration, project assessment and implementa- MAs from their main tasks. Without the MAs tion — are generally perceived by the munic- embracing the new regional concept, the po- ipal and district stakeholders as complicated, tential integrated project beneficiaries could burdensome, and characterized by a long and face additional risks of heavier communica- sophisticated decision chain. Lack of a com- tion and the need to balance the MAs coordi- prehensive and detailed implementation nation inefficiencies. framework for integrated projects, tack- ling the challenges of multi-OP funding, as Another factor negatively impacting the MAs well as minimal experience (primarily lim- attitude is lack of a clear implementation ited to undertakings within the framework framework for the new regional concept, of the Cross-Border Cooperation (CBC) pro- which would effectively address these iden- grams or Community-led Local Development tified risks. Some MAs perceive the upcoming (CLLD) initiatives) with projects implemented policy change as a top-down decision where in partnership further exacerbating those they have no actual ownership but will have reservations. This could negatively impact to share — and somehow mitigate — the risks the motivation of potential beneficiaries to it will generate. Lessons learned by the MAs elaborate IP proposals and apply for funds, from previous programming perspectives show which — in turn — could generate a number that coordination and synchronization of ac- of risks for the effective implementation of EU tions is difficult without a leading organi- cohesion policy in Bulgaria (e.g. slow uptake zation; where a coordination role alone is of funds, failure to comply with N+2 rule, and not seen as sufficient . Therefore, a number an inability to adequately address territorial of MAs suggested they would rather cede the development challenges). 24 Strategic Consultation Report Potential beneficiaries felt that the obligato- (identification of potential partners), as well ry application of the partnership princi- as expertise (for identifying desired scope of ple in the case of Integrated projects gen- integrated projects, and assessing their ex- erates substantial challenges. Questions pected impact on the development of a giv- were raised regarding the approach to be used en territory). for selecting partners to ensure a viable and lasting project partnership, the scope of part- Stakeholders expect that the preparatory ac- nership agreements, the optimal division of tivities be undertaken as early as possible responsibilities between partners related to by an institution which has the legitima- integrated project elaboration and implemen- cy, sufficient authority and willingness to tation, the exact moment when a partnership play a leading role in facilitating the pro- would need to be established for the purposes cess. However, some consulted stakehold- of the application process, as well as responsi- ers observed that such an institution has yet bilities for project co-financing, financial cor- been identified and this uncertainty about rections and ensuring sustainability through the leader of the new approach could consti- maintaining the projects investments. tute a significant bottleneck for timely im- plementation of interventions under the new During the consultations it became clear that regional concept. if the new regional concept is to be embraced by the prospective beneficiaries and effective- ly used, substantial effort will be needed to Key findings of the stakeholder build capacity for integrated project elab- mapping oration and implementation, stimulate the identification of potential integrated proj- The results of the stakeholder mapping show ects, animate the process of forming proj- that most of the consulted stakeholder ect partnerships, and support the actual groups are moderate supporters of the new implementation process on the municipal, regional concept (27 out of 61 stakeholders district, and regional level. While the biggest consulted) or at least hold a neutral position municipalities to some extent have the ca- towards it (20 out 61). Absolute supporters pacity and resources to prepare the pipeline and opponents are few in number. Cluster- of integrated projects for the next program- ing of stakeholders at neutral and moderate ming period, the smaller municipalities will supporter positions is a sign that there is po- most likely be unable to get prepared on their tential for greater buy-in if adequate steps are own and therefore are in need of substantial taken by the champions of the new approach assistance: financial (i.e. resources for financ- to convince them. ing pre-feasibility studies), legal (i.e. formula- tion of partnership agreements), networking However, it is important to understand how the power2 and knowledge3 of these stakehold- FIGURE 2.1 Stakeholders’ stance on the new integrated regional ers were assessed for the purpose of this exer- concept — findings from stakeholder mapping cise. During the consultations it was confirmed Supporter that information disseminated to stakehold- 7 ers on the new regional concept prior to stra- Moderate Supporter 27 tegic consultations was either not sufficient or Neutral 20 reached incorrect people within each insti- Moderate Opponent 6 tution and was not well targeted to meet dif- ferent stakeholders’ interests. Level of knowl- Opponent 1 edge, therefore, is likely to be correlated or 0 5 10 15 20 25 30 related to the current position taken by in- Number of stakeholders dividual stakeholders towards the concept. 2. Power: the ability of a stakeholder to intervene in the concept implementation (block or support). Power index is a result of resources available (human, financial, technological, political and etc.) and the ability or willingness to mobilize them. 3. Knowledge about the concept and integrated projects in general: to what extent the stakeholder demonstrates knowledge about different aspects of the concept and integrated projects. Part 2 Strategic consultations on improving regional development policy in Bulgaria 25 There are several clusters of stakeholders from approach, such as connectivity and mobility, the same sectors. Most of the MAs are clus- public services, healthcare, tourism, indus- tered in the neutral position with medium trial zones, vocational education, universities, or little knowledge about the concept and digitalization, prevention and response to ​​ cli- integrated projects in general; half of the mate change and natural disaster risk reduc- municipalities are moderate supporters tion, air quality, renewable energy, and water with medium or high knowledge; RDCs tend and sanitation services. The stakeholders are to take neutral or moderate support stance. aware that integrated project proposals must Their members possess a medium to low level be in line with the specific socio-econom- of knowledge of the foreseen policy change. ic situation of a given region and adequately address territorial challenges. Concerns were The most knowledgeable stakeholders (25% shared whether there was sufficient capacity in total) either have a lot of experience with on the local level to see problems in an inte- Community Led Local Development (CLLD), grated way, not as separated thematic projects which involves multi-OP inputs or are very ac- as the stakeholders’ experience so far is pri- tive players within the EU-funds-management marily project-based. A number of stakehold- framework. Almost one-third of all stakehold- ers mentioned that a good starting point for ers have little knowledge of the new region- the accurate identification of integrated proj- al concept. The remaining 46% have a medi- ects could be the already developed (but nev- um level of knowledge. er implemented) Targeted investment program to support the development of North-Western Bulgaria, the Rhodopes, Strandzha-Sakar, border, mountain and Incentives for potential beneficiaries semi-mountainous regions (from 2015), perceived as a good example of an inclusive, targeted A number of consulted stakeholders observed and highly professional approach to integrat- that due to the demands related to the elabo- ed regional planning sensitive to local needs. ration and implementation of integrated proj- ects, potential beneficiaries might be reluc- tant to apply for such funding, choosing Potential risks for implementation instead to take advantage of the ‘easier’ or identified by the consulted ‘non-integrated’ funds available under sec- stakeholders toral OPs. Potential beneficiaries fear that going to the trouble of identifying an integrated proj- Despite the general consensus that a poli- ect proposal, selecting partners and establish- cy change is much needed, and that the new ing a formal partnership, financing necessary regional approach holds substantial merits, feasibility studies might be all for nothing if consulted stakeholders identified a number the chances of obtaining financing are slim. of risks, which it generates. The most com- Therefore, clear incentives would be needed to monly referred risks included: effectively encourage potential beneficiaries to get actively engaged and take advantage of • the time available until the start of the next financing opportunities under the new approach. programming period, which may not be suf- ficient to allow for the creation of new struc- tures at the regional level as the new arrange- Potential areas for integrated project ments would have to be ready from the onset implementation of the 2021 – 2027 programming period, Strategic consultations were instrumental in • focusing on integrated projects is perceived identifying a number of areas where stakehold- as risky from the disbursement viewpoint4 ers see the rationale of applying the integrated (if — possibly large in terms of volume of 4. The estimated funds (EU and national co-financing) planned to be utilized under the new regional approach are approximately 2.8 billion EUR : 1.9 billion Euro (94% OPRD) and 0.9 billion Euro (10% of the other operational programmes except OP Transport and OP for the Most Deprived; Rural Development Programme, as not been part of the scope of the CMD of June 2019, is not included). This constitutes more than 20% of the total budget of all EU co-financed programmes for Bulgaria under Investment for Jobs and Growth goal for the 2021 – 2027 financial perspective. 26 Strategic Consultation Report financing and complex — integrated proj- impact the capacity needed to effectively ects are to be the only modus operandi for prepare for the demands of the new pro- the territorial priority axis (PA) and OP RG gramming period. 2021 – 2027 these resources may not be fully-utilized) with reduced budget com- mitment periods (N+2); Regional Development • higher national co-financing (-> 30%)5 Councils which will put considerable strain on the central budget, Obtaining feedback on the proposed ways of restructuring the RDCs and effectively engag- • complexity of the integrated project elabo- ing them in the implementation of the new ration and implementation process (creation regional concept was one of the key objec- of partnerships, design of multi-funded tives of the strategic consultations. The dis- project components) paired with lack of cussion centred around the four proposed sce- experience so far with these types of proj- narios for restructuring RDCs with a view ects was raised among the vast majority of to entrusting them with new roles and func- potential beneficiaries; tions, the optimal composition of RDCs, as well as the capacity needed to effectively per- • expected delays in project assessment and form new roles. implementation due to the proposed new project approval process engaging a number Given the current limited information avail- of institutions on both regional (RDCs) and able regarding the modalities of the new re- central level (MAs of OPs with funding ear- gional concept at the time of strategic con- marked for the new regional approach); and sultations and a lack of more specific infor- mation related to the scope, volume and es- • the risk of letting go of experienced and timated value of integrated projects — which knowledgeable municipal expert staff (re- will heavily impact the workload to be pro- duced capacity) as a potential consequence cessed by RDCs and shape expectations as to of the forthcoming local elections (October their required expert and administrative ca- 2019) and loss of staff due to the disband- pacity — the opinions collected during con- ing of around 30 intermediary bodies at sultations should be treated with caution municipal level, which both can negatively and perceived as preliminary. TABLE 2.1 RDCs scenarios under consultation New RDC roles Scenario 1 Scenario 2 (2.1./2.2.) Scenario 3 Scenario 4 First level checks of project MRDPW regional RDC office / Regional RDC office / RDA RDC office / RDA proposals and management departments Development Agency (checks) and RDC (checks) and RDC decisions (RDA) Board / Head of Board / Head of RDA (management RDA (management decision) decision) Focus on public consulta- RDCs (Regional RDCs RDC Office / RDA RDC Office / RDA tions and the assessment of Steering Committee) regional impact of projects (and approval of ranking list) Transfer to relevant MAs for MRDPW regional RDC office / Regional RDC Board / Head of RDC Board / Head of further checks departments Development Agency RDA RDA (RDA) Complexity Low Moderate Moderate / high High / Very high Financing Minimal Moderate Moderate Maximum Implementation timeline Short-term Short / mid-term Mid-term Long-term 5. As per the Common Provisions Regulation (COM(2018) 375 final) — Article 106 (May 2018). Part 2 Strategic consultations on improving regional development policy in Bulgaria 27 Preferred RDC scenario(s) 2 is the independence of the RDC Office (or regional development agency — depending The stakeholders were consulted on all four on the selected sub-scenario) from the cen- RDC scenarios as presented to the RAS Steer- tral government , and which could be per- ing Committee (SC) in June 2019, with spe- ceived as a first step to building fully oper- cific focus on the various merits of Scenario ational administrative structures on NUTS 2 1 and 2, which were preferred by RAS Steer- level capable of competently applying a ter- ing Committee members. Such an approach ritorial lens to development policy program- provided the stakeholders with an opportu- ming and implementation. nity to share their opinions on, and prefer- ences for, from a relatively wide spectrum of The majority of stakeholders considered an arrangements aimed at empowering the RDCs evolutionary approach to strengthening the under the new regional concept. Delegation regional tier seen as a gradual move from Sce- of more authority to the regional (sub-na- narios 1 or 2 to Scenarios 3 or 4 over time as tional) level seems broadly accepted. Most the most realistic and pragmatic way forward. of the stakeholders support this development This evolutionary approach should be close- but there was no univocal agreement regard- ly linked to any decentralization efforts to ing a single optimal ‘regional model’. While be undertaken by the central government in many see the value added of strengthening the coming years, providing the RDCs with a the regional (NUTS 2) level, some stakehold- longer term development vision. ers prefer more delegation to the municipal level as it is the only one with political legit- imacy, some to the regional, but not neces- Building the capacity of RDCs sarily all to RDCs. A widespread observation shared by many Scenarios that gained most traction during stakeholders was that regardless of the even- the consultations were Scenarios 1 and 2, tually adopted scenario for the RDCs, the ac- with a preference for the latter. At the na- tual restructuring of RDCs would have to tional level, Scenario 2 (without a strong start from a low base. Currently, the RDCs preference for either of the sub-scenarios) are broadly perceived — even by its mem- seems to be preferred over Scenario 1, and bers — as ineffective, devoid of competenc- some stakeholders also indicated Scenari- es and capacity, and therefore incapable of os 3 and 4 as a preferred way forward. Those playing any substantial role under the new that opted for Scenario 1 presented primari- regional concept without substantial restruc- ly pragmatic arguments related to its relative turing and empowerment. Therefore, capacity simplicity and swiftness to implement when building of RDCs is a major challenge, especial- compared with the other three. ly given the time constraints and low start- ing point . Capacity building efforts would At the regional level, Scenario 2 (with some also need to include support to MRDPW re- preference for sub-scenario 2.2, which envis- gional branches as these are currently small aged that the executive functions of RDCs would teams (with a maximum of seven people with be performed by new regional entities — i.e. no current role in project selection, with two regional development agencies) also found team members co-responsible for running the broader support. Scenario 1 was not favored RDC secretariat), focused primarily on admin- because of a conviction that if implemented, istrative and logistic work. MRDPW would be controlling the RDCs and the delegation of any authority to the regional tier Depending on the chosen scenario, it was would not take place. Scenarios 3 and 4 were widely observed by stakeholders that this ca- perceived as a possible long-term goal not pacity should be significantly strengthened likely to be attained during the current plan- to effectively perform the expected new func- ning process due to its complexity and a need tions and to smoothly process the expected for substantial capacity building at the region- workload. Staff with experience (interdisci- al level. According to the opinions shared by plinary experts and individuals with EU ad- the stakeholders, the advantage of Scenario ministrative experience for project documents 28 Strategic Consultation Report management and selection process) would representation in the RDC could be strength- need to be hired in RDCs to build in-house ened to ensure a closer link between support- capacity. Large scale outsourcing of experts ed projects and actual development needs, should preferably be avoided. If necessary ad- as well as to encourage knowledge transfer ditional experts could be externally mobilized between RDC members. Some stakeholders on demand for selected tasks. In terms of en- also argued that the voices of small munic- suring the effectiveness of capacity building ipalities were not adequately acknowledged at the level of RDCs a number of stakehold- during the RDC meetings, as their represen- ers mentioned the significance of any future tation was not sufficient. decentralization efforts for the fate of RDCs. Without a clear path to decentralization, It was proposed that all municipalities should RDCs are likely to be perceived as entities be represented in the RDC and that the RDC not worth making major investment in, in members should elect an RDC head (preferably terms of institutional capacity building, a mayor) among them, as some stakeholders and therefore remaining purely theoreti- shared an opinion that the district governors cal regional actors with no leverage. had no potential to manage the process as they were selected by the central government and Pooling existing resources from a number of therefore lacked legitimate authority. local and district level entities (such as exist- ing Intermediary Bodies, EU projects munic- The follow key elements to ensure the effec- ipal units, District Information Centres and tive performance of new roles by the RDCs existing agencies for regional development) were raised during the strategic consulta- was mentioned as a possible and potential- tions, namely: ly effective way forward. There is adminis- trative and expert capacity available locally, a. the necessity to institutionalize the RDCs however it is scattered between different sec- (with a permanent office, adequate admin- toral policies, institutions, and stakeholders. istration and a budget, skilled staff, clear District Information Centres have been re- new functions), but also to design an ar- peatedly mentioned as structures which have rangement for mobilizing expert capac- accumulated knowledge and capacity over the ity on demand; last two programming periods, have a gener- al understanding of the scope and modalities b. the rotational chairmanship should be of all operational programs, are aware of the either abolished or the period increased local issues, and understand the local context. to at least 12 months (with some handing over period on either side) to ensure con- Apart from identifying relevant expert re- tinuity of RDC operations; sources and determining an arrangement for supplying the RDCs with expert capacity, an c. RDCs should be entrusted with adequate intensive and comprehensive training pro- administrative and financial powers to gram preparing key stakeholders for the im- take decisions with a real impact on the plementation of the new regional concept is development of the region, and to assert expected to be launched. financial and political responsibility; d. legal changes are needed to empower RDCs RDC composition and structure with new functions; Stakeholders expressed mixed opinions e. RDCs need to have clear political respon- about the representative character and sibility and be publicly accountable. It has composition of the existing RDCs. While to be determined who (which entity) will some claimed that RDCs adequately repre- hold them accountable for the execution sent the variety of stakeholders, others ar- of their new functions; and gued that RDCs were biased, and that not all stakeholders are adequately represented. It f. RDC composition should be further as- was suggested that business and academia sessed to determine the optimal one. Part 2 Strategic consultations on improving regional development policy in Bulgaria 29 Involvement of RDCs would like to see the RDCs more as a facilita- in project selection tor of integrated projects and project partner- ships and not as a mere additional adminis- Most stakeholders raised the crucial need trative layer that checks project applications. for the formulation of clear rules and as- sessment criteria for the selection of proj- ect proposals guaranteeing the objectivity RDCs as knowledge hubs and territori- of the RDC assessment and their subsequent al observatories prioritization of projects. It was felt that this could be ensured through the establishment There is an interest in RDCs playing the role of sufficient expert capacity at the RDC lev- of knowledge hubs (‘one stop shop’ assistance el to assess all integrated project components for prospective project beneficiaries) and ter- and also through setting up a selection mecha- ritorial observatories, but the actual assertion nism ensuring transparent and impartial proj- of these roles was perceived as a longer-term ect assessment and selection based on unam- goal for the RDCs. Concerning the latter, the biguous criteria. The concerns related to the stakeholders broadly agreed that there was no potential for biased or unfair assessment of single entity collecting data specific for a given project proposals due to conflict of interest region nor carrying out regionally-focused so- should also be acknowledged and addressed. cio-economic analyses, which was detrimental to making well-informed decisions on devel- opment investments. However, existing local RDCs as facilitator and mediator entities (agencies for regional development and academia) could potentially be drawn together A number of consulted stakeholders shared to contribute to such an effort, and such pos- the opinion that the RDCs should play an im- sibilities could be further investigated. portant role in identifying potential integrat- ed projects of regional importance and project partners and in facilitating the process of the Regional policy formulation of integrated projects. There is also an expectation that RDCs will act as a per- planning and EU funds manent forum for ongoing discussions among programming key local and regional stakeholders on region- al needs and priorities. However, sufficient This particular topic did not raise nearly as capacity would be needed to ensure effective much interest among stakeholders as the new performance of those roles. The stakeholders regional concept and the possible future role FIGURE 2.2 System of strategic and planning documents in Bulgaria (2014-2020) EUROPE BULGARIA National Regional District Municipal 2020 2020 Strategy Plans Strategies Development for Regional NUTS 2 NUTS 3 Plans Development Integrated Common Partnership Plans Strategic Agreement Framewok 2020 National Regional Regional Projects Concept Municipal Schemes Schemes for Spatial SDP NUTS 2 NUTS 3 Development Sectoral Strategies 2014–2020 Urban Detailed Master Spatial Operational Plans Plans Programs 2014–2020 30 Strategic Consultation Report of the RDCs. The received feedback is limit- programs. This requires a well-functioning ed and different interpretations and expla- mechanism for coordination and cooper- nations could be applied to understand this. ation between the managing authorities of The stakeholders could either have no inter- the operational programs, and the district est in or simply underestimate the signif- and local administration. icance of adequate coordination mecha- nisms for effective implementation of their The basic requirements regarding the struc- development interventions. Other explana- ture, and scope, as well as templates for fi- tions could be the lack of their involvement nancial tables identifying sources of financ- in those processes or a conviction that they ing for strategy implementation are defined cannot be improved in any substantial way for all territorial levels of planning (central, and therefore there was no use in discussing regional, district and municipal) in guide- them. Some stakeholders had problems with lines issued by MRDPW. They are to facilitate fully grasping the complexity of the plan- the process of elaborating strategies and — by ning system, its internal logic and the spe- the obligatory application of unified stan- cific types of planning documents at differ- dards — to create a system of complemen- ent levels. As the graph below shows the cur- tary tools for planning and reallocating rent system of strategic planning is character- public funds. The guidelines are also intend- ized by spatial and sectoral dimensions on the ed to achieve vertical synchronization be- central level, and different types of planning tween documents. However, the current leg- documents on the regional, district and mu- islation does not require verification and as- nicipal level, including integrated urban plans. sessment of the degree of implementation of the guidelines by individual bodies. So Regardless of the actual reasons for limited far, such checks — as to what extent docu- interest in this particular topic some key find- ments of the same level have complied with ings and observations were identified and are the guidelines and have a standardized struc- presented below. ture — have not been performed. Their intro- duction in a more systemic way could lead to The regional development plans are not per- a significant improvement of the quality of ceived by local stakeholders as a useful strate- planning documents and increase their co- gic framework for planning their investments, herence across planning levels. as they are too abstract and general, lacking territorial sensitivity. Integrated plans for Strategic documents can serve as a useful urban regeneration and development that platform to effectively stimulate bottom-up were prepared by 39 cities for the purposes cooperation between different stakehold- of the 2014 – 2020 programming perspective ers. An example of ‘lost opportunity’ in this are seen as relatively useful for municipalities, respect is the fact that District Development although the quality appears to have differed Strategies developed for the period 2014 – 2020 from place to place. The reason why they are do not include an Implementation Program perceived as useful is that they were prepared that would identify a set of key projects to be bottom up and customized to local needs. implemented with beneficiaries both from the district administration and municipalities, in- It was noted, that even though OPs should cluding inter-municipal projects. Stimulating be reflecting development needs identified bottom-up inter-municipal cooperation could in strategic and planning documents at re- lead to identification (and implementation) of gional and local level and providing financ- major integrated projects of strategic impor- ing opportunities for them it is not always tance to a given district. The practice so far the case. In practice a number of investment shows that the implemented inter-municipal priorities as described in strategies and projects reflect the standard projects defined plans remain ineligible for financing un- at national level. For example, inter-munici- der OPs. One of the reasons might be the fact pal projects aimed at creating regional tourism that the package of strategic and planning products or building regional waste manage- documents at regional and local level is be- ment systems represent inter-municipal coop- ing developed in parallel with the operational eration, but in practice they were defined top Part 2 Strategic consultations on improving regional development policy in Bulgaria 31 down by the investment priorities and envis- Targeted investment program to support the development aged financing under relevant OPs. of North-Western Bulgaria, the Rhodopes, Strandzha-Sakar, border, mountain and semi-mountainous regions When planning development measures local Prepared in 2015 by the National Center of Territorial Development with stakeholders rely on their own municipal de- active engagement of municipal and district stakeholders, the targeted velopment strategies and plans but struggle investment program is still perceived — four years on — as a good exam- with a deficit of relevant socio-economic ple of an inclusive, territorially targeted and highly professional approach to integrated regional planning sensitive to local needs, which lead to the data to plan and pursue evidence-based de- identification of clear development priorities and investments. velopment initiatives. Stakeholders observe Key characteristics of the elaboration process included: insufficient data disaggregated at the region- • bottom up approach to identifying project proposals/ideas (more than al, district, or municipal level. The four main 1,000 submitted) — BUT formulation of clear project selection criteria problems encountered relate to: (i) incorrect from the onset of the process and assistance from external experts; format of data available; (ii) data is not de- • searching for integrating elements between projects instead of promot- tailed enough ; (iii) different methods of ing fragmented investments; data collection limit data comparability • clear prioritization of submitted project proposals/ideas: (1) high prior- ity large scale projects, more mature; (2) projects in need of additional and preclude conducting reliable analyses, support to relatively quickly progress to group 1, and (3) ‘bank of ideas’ and (iv) withheld data. There were calls for (further development needed, including feasibility studies) improvement to the quality and availability • a clear framework for achieving ‘project maturity’, which identified con- of locally and regionally disaggregated data secutive steps that had to be taken by relevant stakeholders to ensure their project proposal/idea could ‘move up’ — advancing from one group to support the formulation of evidence-based to another. policies and for local authorities to make in- formed investment decisions. Municipalities and districts shared that they often need to The consulted stakeholders identified a num- purchase some of the required data from the ber of examples of insufficient coordination central statistics office as these are not freely and synchronization of activities on the available in the public domain. Municipalities central level (between OPs, ministries, agen- mentioned they would like to obtain financ- cies, etc.) negatively impacting the implemen- ing from the central government to be able tation of projects on the local level (i.e. timing to acquire more relevant data. for announcing calls for proposals, protract- ed assessment and contracting of projects, Although there doesn’t seem to be much posi- lack of coordination between EU funds and tive experiences with regional policy planning national funds). These problems — if not ad- so far, stakeholders are firm that quality strate- equately addressed — could have a detrimen- gic planning is key to successful and efficient tal impact on the new regional concept and regional policy. The necessity for an accurate its implementation, as the integrated projects analysis of local needs as a basis for developing are to consist of components financed from regional development strategies was widely rec- different OPs. Some municipalities raised the ognized. A number of stakeholders at nation- issue of how to synchronise the different lev- al level and across the country mentioned as els of planning for the next programming pe- exemplary the approach which was employed riod and make them compatible, particular- for the purpose of elaborating a study by the ly with regards the Municipal Development National Center for Territorial Development on Plans, which are currently being developed by the preparation of a targeted investment pro- municipalities. There appeared to some con- gram to support the development of North-Western fusion amongst municipalities about when Bulgaria, the Rhodopes, Strandzha-Sakar, border, and how to prepare the new municipal plans. mountain and semi-mountainous regions. The disap- Perpetuating the problem of poor synchroni- pointment and lack of understanding of the rea- zation between levels of planning is the nar- sons why the targeted investment program was nev- row thematic scope of OPs, which are not seen er implemented (or even endorsed) was shared as being in line with regional needs. by stakeholders in many meetings. There was a view that central government failed to follow The main observations from the strategic con- through with the necessary financing for fea- sultation are about insufficient alignment be- sibility studies and the support needed to pre- tween regional policy planning and EU funds pare the projects identified through this process. programming and lack of adequate and 32 Strategic Consultation Report meaningful involvement of all key stake- Other findings from holders. These two processes seem to be op- erating ‘in parallel’, failing to create syner- strategic consultations gies. Lack of relevance of regional develop- ment plans and data for local strategies might Meetings held within the framework of the have a negative impact on the implementa- strategic consultations provided a platform tion of the new regional concept (e.g. difficul- for stakeholders to share additional obser- ty for measuring regional impact of interven- vations related to other issues they deemed tions, for formulating project selection crite- important for regional policy development ria and prioritization of project proposals ac- and implementation. Some of these are de- cording to their regional impact). scribed below. Table 2.2 provides some observations on the issues with the current regional plan- ‘White spots’ ning process, possible measures to remedy them, and suggestions on the better inte- The problem of municipalities that missed gration between regional planning and EU out on financing opportunities in the last fund programming. programming period because they did not TABLE 2.2 Possible solutions for enhancing the quality of strategic development and planning documents No. Identified issues Possible solutions 1 Mismatch between the measures and projects in Improving coordination between the development of documents and the the strategic documents and the investment priori- definition of investment priorities, eligible activities and beneficiaries in ties/eligible activities under OPs OPs; Preparing resumes of OPs to be used during the process of elaborat- ing strategic documents 2 A lack of clear focus in setting goals and priorities Defining more focused proposals for regional and local development to in plans and strategies, respectively lack of clear gain a more visible and realistic scope for implementation through criti- priority when using accessible public funds, includ- cal mass of more targeted investments; Improving coherence between ing EU funds strategies and existing funding opportunities, including the municipal bud- get, central budget the various EU funds, financial instruments, and private investment 3 Duplication of goals, priorities and measures Hierarchical structuring of strategic proposals so that strategic goals are in a single strategic document for regional divided into sets of priorities; priorities lead to sets of measures; measures development are turned into projects depending on the planning level 4 A lack of specifics in plans and strategy fore- Defining the measures of the strategic documents in accordance with the casts — vague and abstract definitions of mea- content of the operational programs; sures and projects without correlation to a source Supplementing the Guidelines for the municipal plans with a template of of funding, including from OPs the Implementation Program to ensure that the plans contain a set of spe- cific projects, including under the operational programs 5 Large number of measures and projects in docu- Attaining balance between the proposals and the financial frameworks for ments that do not correspond to the administra- implementation of plans and strategies, prepared in accordance with the tive capacity and available financial resources in available financial resources and administrative capacity Bulgaria 6 District strategies lack key projects for inter-mu- Supplementing the contents of the regional plans or district strategies with nicipal cooperation and/or integrated territorial a section on key inter-municipal projects and/or integrated projects with investment. General guidelines instead of specific specific parameters, including financing from operational programs examples do not encourage more partnership proj- ects between the municipalities 7 Implementation Programs for Municipal Plans Defining measures and projects in the municipal plans, so that they cor- often contain a number of vague projects without respond to the local specifics and allow a more flexible ongoing defini- a location, deadline or source of funding, includ- tion of projects, while the projects of the Implementation Program should ing from OPs be a limited and realistic set of the most important tasks. Measures and projects should also reflect OPs; Supplementing the Guidelines for the municipal plans with a template of the Implementation Program to ensure that the plans contain a set of specific projects, including under the OPs; Preparing annual plans for the implementation of the Municipal Plans based on the Implementation Programs but updated with information on current and upcoming procedures of the OPs. Such an approach would reduce inconsistencies if documents are developed prior to the elabora- tion of OPs. Part 2 Strategic consultations on improving regional development policy in Bulgaria 33 meet the eligibility criteria for either OPRG software programming, testing, alpha and 2014 – 2020 or rural development program beta versions, final version, training people (so called ‘white spots’) was identified as one in MAs and at the local level). This technical of the pressing issues to be addressed by cen- aspect is not detailed in the concept develop- tral government. The lack of eligibility of ment, but it is understood that MRDPW and a group of settlements within some non-rural CCU have plans to address this. municipalities for any EU funding was per- ceived as a major obstacle to cooperation on joint development initiatives in the current Financial corrections programming period. Failure to adequately and state aid rules recognize and address this issue could neg- atively impact the potential for implement- Financial corrections were mentioned on nu- ing supra-municipal integrated projects in merous occasions throughout the consulta- the coming years. For these municipalities tions as a major issue for municipalities that investments in basic services seem a priori- are utilizing EU funds for the purpose of fi- ty, including water and wastewater services nancing projects. Changes in interpretation and local roads as examples. There was also of regulations during the current financial call for confirmation of state funding, and perspective and their retroactive application fair funding, for all municipalities, but par- results in beneficiaries being obliged to pay ticularly those facing difficulties. financial corrections at the end of a project. Public procurement procedure failures also contribute to the need for financial correc- UMIS IT system tions. This seems endemic and poses a seri- ous risk to beneficiaries, especially smaller The functionalities of the UMIS IT system for municipalities and reducing their potential EU funds should also be thoroughly examined to elaborate and implement projects in the to ensure compatibility with the new region- coming period. Lack of a consistent approach al approach as far as integrated project ap- (or even a rigid or conservative approach) by plication and monitoring processes are con- the central government to applying and in- cerned. Any changes to the UMIS would re- terpreting the regulations on state aid was quire significant time to procure and imple- identified as a substantial risk for the imple- ment (planning of modifications, preparing mentations of integrated projects, creating the public procurement for an IT company, a deterrent to potential partnership building. PART 3  RECOMMENDATIONS FOR FURTHER ACTIONS BASED ON FINDINGS FROM STRATEGIC CONSULTATIONS 36 Strategic Consultation Report The strategic consultations were an import- building fully operational administrative ant opportunity to raise awareness about the structures at NUTS 2 level and a more expe- new regional concept and possible changes dient route to greater delegation of respon- to RDCs and in this regard, the consulta- sibilities in future. tion process appears to have well achieved this goal. The consultation process also pro- • Decentralization was a recurring issue vided valuable opportunity to hear from local, raised throughout the consultations and regional, and national stakeholders on their municipalities, in particular, raised their ex- views and expectations, which will be cru- pectations for a renewed effort in this domain. cial for MRDPW and CCU in further defining a workable implementation framework of the • The RDCs are broadly perceived as ineffec- new regional approach. tive, devoid of competences and capaci- ty, and therefore incapable of playing any substantial role under the new regional Summary of key findings concept in their current form . To take on the functions and role envisaged un- • The new regional concept understood as der the new regional concept their capac- adding a more territorial dimension to devel- ity would have to be built from a low base, opment policy in Bulgaria and earmarking which constitutes a significant challenge to this end a portion of sectoral funds under given time constraints. 2021 – 2027 Operational Programs (OPs), gen- erated substantial support. Also, the idea of • Stakeholders expect that preparations integrated projects received generally pos- for the 2021 – 2027 programming period itive feedback as a potentially useful tool would need to begin promptly given the for effectively tackling territorial develop- sophistication of the new regional concept. ment challenges. Specific expectations include establishing a project pipeline and running an intensive • Insufficient information on the implemen- training and coaching program dedicated tation framework for the new regional con- to key local and regional stakeholders and, cept and a limited understanding of the in the longer-term, provision of hands-on nature of integrated projects were raised technical support for the creation of part- across stakeholder groups. Much greater nerships and the formulation of integrated clarity in these two areas will be needed to projects. Additionally, at the central level, motivate potential beneficiaries to elabo- efforts to combine guidelines of Managing rate integrated projects and apply for funds Authorities (MAs) (and operational manuals) and to create greater and broader-based sup- was seen as challenging by some MAs and the port for the new regional concept. Progress adaption of the UMIS a critical but especially in these two areas will also reduce possible time-consuming task. Beyond these opera- risks to the effective implementation of EU tional matters, stakeholders believe that CCU Cohesion Policy in Bulgaria. and MRDPW will need to take a strong lead- ership role in the regional approach to coor- • Delegation of more authority to the re- dinate amongst, and ensure the necessary gional (sub-national) level was broad- support from, all MAs to both RDC develop- ly accepted, however there was no univo- ment and the technical support to RDCs in cal consensus on a single optimal ‘regional carrying out their new functions. model’. Both Scenario 1 and 2 for RDCs gained traction during the consultations, • Stakeholders perceive that there is substan- with the latter being generally more pre- tial scope to improve the coordination of ferred. Even though Scenario 1 was per- regional policy planning with EU funds ceived as a more pragmatic choice because programming, as currently these two do- of the swiftness and the relative simplic- mains are seen as not adequately aligned, ity of its implementation, the advantage failing to create synergies and not suffi- seen with Scenario 2 is that it could poten- ciently integrating local stakeholders. This tially create a stronger foundation towards results in perpetuating a top-down approach Part 3 Recommendations for further actions based on findings from strategic consultations 37 to programming, which is not complement- impact the implementation of the new re- ed yet by such a more bottom-up approach gional concept. The WB team — based on key as being advocated as part of the new con- findings from strategic consultations — for- cept for regional development. There was mulated recommendations on future actions call from local stakeholders to better assess to be considered by MRDPW to address or mit- local needs and create regional strategies igate identified risks. It is important to note, that could bridge between locally prepared however, that the MRDPW has already endorsed municipal and district plans with centrally some of these recommendations and is pro- commissioned regional plans and schemes. gressing in their implementation (i.e. elabo- ration of draft integrated project guidelines The consultation also allowed the identi- for beneficiaries, expected launch of public fication of certain risks or ‘blind spots’ consultations on RDA amendments or prepa- which — if not adequately addressed — could ratory works on creating a project pipeline). TABLE 3.1 Recommendations based on findings from strategic consultations Finding Recommendation Insufficient level of knowl- Recommendation 1: edge and awareness of the additional efforts by MRDWP and CCU to disseminate information on the new regional concept and upcoming policy change to raise awareness among national, regional and local stakeholders would be conducive to ensuring a among key stakeholders higher level of stakeholder engagement and buy-in. Findings from the stakeholder mapping exercise could be utilized to design and implement a comprehensive information campaign geared to meet the specific needs and expectations of different stakeholders, as well as the general public. Recommendation 2: MRDPW and CCU could consider continuing the consultation process into the process of planning of the regional development reform to a greater extent as many stakeholders expressed interest in being more involved in, and informed about, planned changes. The consultations could take various forms, from regular meetings, stakeholder working groups, to an online webpage with current information etc. Lack of clear implemen- Recommendation 3: tation framework of the as implementation mechanisms for the new regional concept raised many questions amongst stake- new integrated regional holders at all levels, it is advised that MRDPW prepare in due course and make broadly available a com- approach, which can nega- prehensive and detailed implementation framework , consisting of: tively impact stakeholders’ (1) a set of unified (for horizontal use across OPs) guidelines for beneficiaries of Integrated projects, engagement (2) a user’s manual explaining the strategic and operational modalities of the new regional concept, and (3) template(s) of partnership agreement(s) containing key obligatory clauses that regulate relations between partners and their roles in the project. Insufficient coordination of Recommendation 4: the new regional approach to ensure a more coordinated effort in implementing the new regional concept it is recommended on the central level to give further consideration to the proposed institutional framework for the programing period 2021 – 2027. Delegating the responsibility for managing the funding under the new regional concept (10% allocations) to one entity could significantly streamline the implementation process and firmly assert one entity with competences necessary to ensure a stable and standardized cross-OP imple- mentation framework and a more ‘beneficiary-friendly’ interface. Lack of experience in elab- Recommendation 5: orating and implementing to effectively stimulate the supply side of the new regional concept, namely the process of elaborating integrated projects among integrated project proposals it is recommended that preparatory work for the 2021 – 2027 program - local stakeholders and their ming period begin promptly. Proposals for specific activities that could be initiated by MRDPW include: insufficient capacity to sin- (1) utilize financial resources available under OP RG 2014 – 2020 technical assistance and national gle-handedly cope with proj- budget resources as a source of financing the IP preparation phase for local and regional ect pipeline stakeholders; (2) establish a project pipeline to ensure timely identification and sufficient preparation of Integrated projects; (3) conduct an intensive training and coaching program dedicated to key municipal, district, and regional stakeholders, as well as to MAs and regional branches of MRDPW. Stronger leadership — not Recommendation 6: just coordination — required MRDPW and COM (through CCU) to consider strengthening their alliance and taking a greater lead in in the process of imple- the process of the implementation of the new regional concept for 2021 – 2027 effectively acting as menting the new regional an anchor, coordinating and facilitating the approach together. approach 38 Strategic Consultation Report Finding Recommendation Operational modalities Recommendation 7: enabling smooth implemen- modification of UMIS is necessary to submit and implement integrated projects, thus work on adapt- tation of the new regional ing the system should start promptly to ensure adequate time for conceptualization of changes, the approach must be effec- design process, implementation, testing and retesting. MRDPW should consider drafting a roadmap of tively set up, including e.g. this activity and collaborate closely with CCU on its implementation. the IT system for process- ing Integrated projects Prospective integrated proj- Recommendation 8: ect beneficiaries might be one of the ways to encourage prospective beneficiaries to apply for funding under the new regional reluctant to actively engage concept is to create a ‘motivation system’ — complimenting the IP implementation framework and in the process of integrated intensive training/coaching activities — to effectively incentivize potential beneficiaries. A strong incen- project elaboration given tive would be to increase the probability of obtaining financing for IP proposals through placing them the complexity of the pro- on indicative lists of projects early on once it is verified that they meet eligibility criteria. Another pos- posed approach, therefore sibility would be to establish financial allocations for each of the NUTS 2 regions (‘regional financial incentives are needed to envelopes’ ). Such an approach would reduce the scope of competition (from interregional to intra- effectively encourage them regional — if the competitive rule in project selection is to be upheld) and increase chances for obtain- to do so ing financing. Clear financial framework Recommendation 9: for funding Integrated proj - collecting more information on the desired thematic scope of potential integrated projects and ects (especially estimat- required volume of funding would be conducive to estimating the expected demand for financ- ing approximate volume of ing under the new regional concept. It could also help to identify areas where expertise will be most funding per IP) is needed to needed to assist potential beneficiaries in the elaboration of IP proposals and later on to assess them. allow the potential benefi- It is recommended to conduct a country-wide survey and/or call to generate ideas for integrated proj - ciaries to begin preparatory ects. Such a survey and/or call could also be used as a tool of disseminating information about the works in project concept new regional concept and increasing stakeholder awareness and engagement. elaboration Choice of RDC scenario will Recommendation 10: be crucial in terms of cre- Each of the consulted RDC scenarios holds its merits for enhancing the regional dimension of develop- ating a much needed lon- ment policy in Bulgaria. However, the final decision on the RDC scenario selected for implementation ger term perspective for should be thoroughly considered not just in the context of operational modalities of the EU funds the development of these management system, but within a broader framework of the possible decentralization agenda to entities be pursued in the coming years by the central government. In order to ensure a more universal buy-in of stakeholders on the subnational level in supporting and recognizing the new roles of RDCs, actively engage them in a sustained intensive capacity building process that will require pooling resources and provide the RDCs with political leverage to effectively represent the regional perspective it is recom- mended that MRDPW and CCU formulate a longer term, post-2027 vision for the RDCs and a credi- ble action plan for its implementation, involving and bringing along key central and local stakehold- ers in the process. Clarity on the broader Recommendation 11: framework in which the the recommended way forward would be to: RDCs would operate, includ- (1) clearly define key processes related to the elaboration, assessment, consultation and selection of ing the modalities of inte- integrated projects on the regional level, as well as processes related to project selection on the grated projects, their scope national level in which the RDCs will actively participate, as well as internally within the RDC (rela - and expected volume, is tions between management and expert branches); this should highlight internal and external coordi- needed to formulate spe - nation/communication channels as well as decision making arrangements; cific recommendations on the composition, gover- (2) determine specific RDC roles and tasks to be performed under the identified processes and the nance and capacity of the corresponding responsibilities; restructured RDC (3) determine the resources necessary to effectively perform identified roles and tasks; and (4) based on the above-mentioned findings — design an adequate RDC structure capable of effectively performing the assigned roles and tasks and determine necessary administrative capacity and training needs. Stable legal framework and Recommendation 12: political consensus on new the strategic choice of the RDC scenario to adopt for the purposes of the new programming perspec- RDC roles are some of the tive would need to also take into account legal implications. The adoption of each of the scenarios key enabling conditions requires a different scope of legal change to be introduced in the regulations to make sure they are via- for effective functioning of ble. It is therefore recommended to ensure that the final decision taken on the RDC scenario of choice restructured RDCs will be pre-empted by a legal analysis which will determine the specific scope of changes to be intro- duced into the legal system. Political consensus will have to be effectively sought by MRDPW and CCU to ensure that necessary legal changes are adopted in due time to allow for swift implementation of the RDC scenario of choice. Given time constraints, a ‘fast-track’ approach might be needed. Part 3 Recommendations for further actions based on findings from strategic consultations 39 Finding Recommendation Effective mechanism for Recommendation 13: mobilizing expertise avail- the optimal way to tackle the issue of relatively fast and effective capacity building for the RDCs and able both on central, as well to determine how capable staff could be mobilized to support the functioning of the restructured as regional/district/munic- RDCs is an area that needs further investigation. It would also be useful to consider relevant findings ipal level is needed to rela - and recommendations from the ongoing OECD pilot action on frontloading administrative capacity tively fast ensure adequate related to the strengthening of administrative capacity at the level of central government, and MRDPW capacity of RDCs specifically, as well as at the level of RDCs and project beneficiaries. A number of findings from this note confirm observations formulated in the OECD roadmap for administrative capacity building. Also, OECD recommendations are relevant in addressing needs of key stakeholders related to the prepara- tion and implementation phase of the new regional concept for years 2021 – 2027. It is therefore rec- ommended that specific actions that are to be taken in the second phase of the OECD pilot action also take into account findings from the strategic consultations. This should be conducive to design- ing an effective and adequately targeted capacity building program. Significant risk of conflict of Recommendation 14: interest likely to emerge on one of the most significant challenges related to the restructuring of RDCs will be to reconcile the rep- the level of RDCs, if not mit- resentative and decision making functions of the RDC ‘management tier’ with the project assessment igated it could jeopardize function of the RDC ‘expert tier’, in order to effectively neutralize potential conflict of interest between the transparency and effec- those functions. The risks are relatively high as members of the ‘management tier’ will most probably tiveness of the new regional be project applicants/beneficiaries. In order to neutralize — or at least mitigate — this risk the develop- approach ment of clear and unambiguous rules of operation of the two RDC tiers as well as its units ensuring a functional separation. The need for increasing the Recommendation 15: quality of the strategic plan- A package of actions is recommended including: ning process and its coor- • finetuning current coordination arrangements on the level of OP RG and across OPs to ensure a dination with EU funds more comprehensive coverage and eligibility for financing local development needs with EU programming funding opportunities • introducing arrangements strengthening the role of territorial strategic documents as platforms for to effective stimulation of bottom-up cooperation between different stakeholders • regular verification and assessment by MRDPW of the degree of implementation of the meth- odological guidelines for strategy elaboration to improve the quality of planning documents and increase their coherence across planning levels • addressing — in a systemic way and in conjunction with key stakeholders on the central level — the issue of insufficient data availability, and either providing free public access to the above-men- tioned data or — if not possible — securing a stable financing framework for stakeholders on the sub- national level to obtain the necessary data on their own Keeping communication Recommendation 16: channels open and ensur- Strategic consultations served as an invaluable opportunity to reach out to key stakeholders, get to ing on-going exchange of know their stance on the foreseen policy shift, learn of their reservations, expectations and hopes, and key information with stake- build better common understanding and mutual trust. It is recommended to: holders as a prerequisite for • share the findings from consultations and recommendations formulated as their result with con- the successful implemen- sulted stakeholders and the public (e.g. on the MRDPW’s website) tation of the new integrated regional approach • organize workshop(s) to present the above-mentioned findings and recommendations to local stakeholders as well as to provide them with up-to-date information on the implementation mech- anism for the new regional concept and its operational modalities and the mechanism for involving the regional tier. PART 4  NEW INTEGRATED REGIONAL CONCEPT AND ITS ADAPTATION  — INDEPENDENT REVIEWS OF WB TEAM 42 Strategic Consultation Report Apart from supporting MRDPW and CCU in At the time of the consultation process, the conducting strategic consultations on im- Government of Bulgaria faced a number of proving regional development policy, the WB decisions that would shape the future imple- team also engaged in conducting indepen- mentation model of the new territorial concept. dent reviews of modalities of the new in- These decisions could push the implementa- tegrated approach drafted by MRDPW. Doc- tion model in various directions, such as: i) uments (drafts) submitted by MRDPW to the maintaining the current solution (‘status quo’), WB team for review have included: ii) strengthening the RDCs by making them more permanent bodies (‘regionalization’), iii) • the model structure of RDC; enhancing functions of RDCs but without their • Guidelines for integrated project beneficiaries; institutionalization (‘networking’), and iv) cre- • draft amendments to RDA and RDA Rules of ating a centralized IB with regional branches Implementation; and (‘centralization’). Based on this the team devel- • draft structure of OP RG 2021 – 2027. oped a ‘decision tree’ which in a simplified and synthetic fashion presents key deci- It should be noted that independent reviews sions and their sequencing that will shape of MRDPW’s strategic approach to program- the organizational structure of RDCs and their ming for the years 2021 – 2027 are ongoing capacity to implement new functions under the in parallel to other tasks undertaken by new territorial approach (Figure 4). WB team within the RAS framework. Some of them are very preliminary, as the draft The decision tree has a time horizon of around documents under review are MRDPW’s work 3 – 12 months and depends on the progress in progress and will only be finalized in the and outcomes of the RDA amendment pro- coming months. By conducting those just- cess. While there will be more decisions to be in-time preliminary reviews, the WB team taken and technical details to attend to than aims to provide MRDPW and CCU with in- indicated in the graph, the decision tree only dependent observations and recommenda- intends to focus the attention on key juncture tions to be considered in the process of gov- points in the process. The amendment of the ernment fine-tuning the elaborated arrange- RDA is a key element of the new approach and ments, based on the analysis of the specific if successful it will pave the way for building situation in Bulgaria, but also drawing from stronger RDCs (they could become more per- global models and international experience. manent bodies with staff and a budget). If the RDA is not modified, the RDCs could still The Bank acknowledges the complexity and perform functions envisaged by the MRDPW, multifaceted character of the new integrat- however, their capacity to do so would effec- ed regional approach. Having in mind the tively be limited compared to the scenario limited timeframe for its implementation with institutionalized RDCs (more details on imposed by the upcoming new EU financial that in the legal analysis section below). perspective, the government needs to work on several aspects of the policy change in Maintaining the current status of the RDA parallel to ensure that strategic decisions could also open discussions about setting up are taken before technical details are devel- a central intermediary body for the regional oped, though sometime these processes will development contributions from all relevant go hand in hand or be tightly scheduled. For OPs, as then coordination of such funds would instance, a decision whether the RDCs should be easier. The central IB option could also be be institutionalized (permanent bodies, with possible in a scenario with RDA amendment. permanent staff, functions and budget) will Although, as indicated clearly by MRDPW, this influence their capacity to perform functions is not an option to be considered since they foreseen for them in the new approach and believe it negates much of the new role envis- RDCs’ relations and lines of responsibilities aged for the RDCs. If the RDA is amended, then against the MAs. Identification of key deci- implementation rules for the RDA will be the sion points of the reform process is crucial, next key step as they will define RDCs’ func- as this could guide the work of MRDPW and tions, organization and powers (potential in- other stakeholders involved in the reform. stitutionalization). However, RDCs’ functions Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 43 FIGURE 4.1 Implementation of the New Integrated Regional Concept — key decisions, sequencing and implications (‘decision tree’) Status quo Centralization Networking Regionalization NO RDA amendment YES Decision on: Character of IPs Regional envelopes RDA implementation rules Number of IPs RDCs Central as right now IB with System preparation branches Legal analysis of possibility to carry Guidelines Hiring MAs’ out envisaged RDC: RDC: Regional envelops + capacity decision to functions under building No institutionalization delegate Institutionalization OP drafting the current RDA Selection criteria Project pipeline No permanent staff More permanent Indicative project list Decision on how and budget, delegation character, budget, staff, Etc. to build RDCs’ of tasks to other bodies capacity, functions capacity to allow them fulfilling envisaged tasks and how to finance RDCs Decision on how to build RDCs’ capacity External Internal to allow them fulfilling capacity capacity Capacity building envisaged tasks and how to finance RDCs Smaller Bigger Capacity building RDCs RDCs Hiring + capacity building Source: Authors and organizational structure should also be capacity building at the RDCs, financial deci- a function of the integrated project’s nature. sions on how to finance the RDCs. While the This implies that decisions about scope, size decision tree is not an exhaustive list of deci- and number of integrated projects per regions sions, it could focus discussion on key deci- as well as general assumptions about part- sions, their sequencing and implications. nerships, their establishment and division of roles among partners should come before the RDA implementation rules are established.6 New Integrated Regional One example could be, the more integrated Approach — independent projects expected, the more capacity the RDCs review and options will require to assist projects and partner- to consider ships’ formation, support grant application and implementation, as well as pre-select While recognizing the merits stemming from integrated projects. The details of the RDA the new integrated territorial approach, the implementation rules will shape the RDCs and Bank team — in light of the findings from will guide many other processes, e.g. hiring, strategic consultations, the discussions held 6. Other considerations will also play a role, for instance a selection procedure of integrated projects will determine the workload of RDCs — a competitive selection will require more work than implementing pre-approved indicative projects. Similarly, if the RDCs were to support the implementation of the projects this would require much higher capacity over an extended period of time comparing to a scenario where RDCs’ role ends with project pre-selection. 44 Strategic Consultation Report in the RAS Steering Committee, and the be put in place in the coming year to ensure teams’ own independent review — formu- its smooth implementation. lated an initial proposal for a more phased, gradual mechanism to its implementation Taking into account that roughly 20 percent for discussion with MRDPW. The aim of pre- of Bulgaria’s EU Cohesion Policy funding for senting an alternative proposal was to mit- the years 2021 – 2027 has been earmarked for igate the so far identified risks, while still the purpose of financing integrated projects effectively promoting the integrated terri- (including around 90% of the allocation of torial approach. It was also the intention of OPRG 2021 – 2027 plus 10% from each of the the Bank team to propose an arrangement participating OPs) and that adopting this that would reconcile sometimes opposing approach seems to be highly experimen- views on the specific modalities of the imple- tal given the very limited previous expe- mentation mechanism expressed by differ- rience with integrate projects (that would ent stakeholders. result in ‘learning by doing’ on a large scale), it is the opinion of the Bank team that it is It is well noted that integrated projects are likely to generate significant risks, related the heart of the new regional approach . to all phases of integrated project elabora- Their implementation is conducive to gen- tion and implementation, that could jeop- erating substantial socio-economic benefits ardize the new regional approach. and changing the attitude of many stakehold- ers to development initiatives, proving that Risks are mainly associated with the ambi- development is not ‘a zero-sum game’, but tious and broad definition of an Integrated rather a ‘team sport’, where pooling resourc- Project adopted by MRDPW and CCU, which es, planning and implementing investments requires an integrated project to constitute in a coordinated and synchronized way can at least three interconnected components fi- yield substantial development effects surpass- nanced from different OPs with only one grant ing those generated by isolated, fragmented agreement signed by the lead partner for the projects. In more succinct words, ‘the whole entire integrated project. For the purposes of is greater than the sum of its parts’. designing this ‘phasing-in’ mechanism the Bank team proposed that the definition The integrated approach requires a number of an integrated project could be changed of ‘enabling conditions’ to be effectively to one where there is an ‘umbrella agree- implemented: ment’ between partners as the integrating element, instead of the one grant agreement • First, an accurate recognition of common for all of the integrated project components. development goals among prospective ben- More than one ‘umbrella agreement’ would eficiaries of integrated projects; be required per NUTS 2 region according to • Second, a cooperation platform, with capa- the needs of each region; one municipality ble staff responsible for integrated project could participate in more than one ‘umbrel- proposal preparation; la agreement’ and more than one grant agree- • Third, the ability to formulate bundles of ment (see details below). inter-related and sequenced projects that help achieve the common goals (and can Key elements of the new ‘phasing in’ imple- demonstrate this); mentation mechanism for the integrated • Fourth, streamlined assessment and con- approach as proposed by the Bank team tracting of projects, and are described below:  • Lastly but just as important, a clear imple- mentation framework. 1. Partnership agreement (an ‘umbrella agreement’): Since the integrated approach has only been • this would be signed between partners tested in Bulgaria on a very limited scale (and prospective beneficiaries) (no public (mainly under the CLLD approach and with- procurement procedure or any other competi- in the framework of the CBC programs) the tive one needed to select them); above-mentioned prerequisites will have to • the agreement would determine:  Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 45 – the common development objec- need for the MRDPW (or any other en- tive(s) of the partnership,  tity) to act as a central Intermediary – specific actions to be undertaken by Body as the OP MAs would not relinquish each of the partners to ensure the their competence for project assessment objectives are successfully met, and contracting; – a timeline and chronology of • assessing and contracting projects fi- actions, and nanced from OPRG 2021 – 2027; – a list of projects to be implemented • capacity building at the regional/local by each of the partners. level; • collecting and disseminating good prac- 2. Projects identified in the ‘umbrella agree- tices to promote and facilitate implemen- ment’: tation of the integrated approach; • projects could be financed from differ- • project pipeline for integrated projects; ent OPs involved in the new integrated • hands-on monitoring of indicative flag- approach; ship integrated projects (if any); • projects would be assessed against se- • hands-on support in elaboration and im- lection criteria specific to the relevant plementation of integrated projects in OP (except for assessment of strategic re- marginalized areas; gional importance conducted by the re- • monitoring the progress in implementing spective RDC); integrated territorial approach across OPs.  • projects would be assessed as a bundle or package of projects, which together 5. Managing Authorities of relevant OPs:  and well-sequenced, can demonstrate • responsible for establishing and main- how they help achieve the common de- taining of a ‘fast track’ mechanism for velopment objectives assessing and contracting projects un- • separate grant agreements for each of der the integrated approach (ongoing the projects would be signed by part- calls for proposals under the territorial ners with relevant MA OPs (or its Inter- TAs of relevant sectoral OPs); mediate Bodies — according to each of • providing ongoing expert engagement the OPs implementation system), which in MRDPW’s project pipeline to support also reduces the risk that one failed proj- prospective beneficiaries; ect substantially affects the others; and  • working closely with the MRDPW to en- • full responsibility of the beneficiary sure smooth implementation of the in- for the project implementation and tegrated approach.  its aftermath (no delegation of respon- sibilities to lead partner). 6. RDCs (would have all the new roles as origi- nally envisaged by MRDPW but no pre selection 3. Partnership leader (lead partner):  of projects):  • would act as the ‘interface’ of the inte- • organizing public consultations/hear- grated project to the external world and ings for integrated projects; main counterpart for MRDPW and the • assessing strategic importance of project respective RDC; proposals against regional development • would monitor the implementation of objectives and deciding on a ranking the ‘umbrella agreement’ and each of its list of project proposals based on these package of projects under the terms of criteria; the overall partnership agreement, and • identifying potential integrated projects • would facilitate networking between and partners, networking; partners and knowledge transfer. • facilitating elaboration of ‘umbrella agreements’. 4. MRDPW (different roles depending on the measure under PA2) could be responsible for:  7. CCU  • coordinating ‘fast track’ with MAs of • political oversight to ensure smooth im- relevant OPs to ensure smooth imple- plementation of integrated approach mentation of integrated projects, but no across OPs. 46 Strategic Consultation Report The proposed alternative mechanism was en- strengthening their capacity for pre-selec- visaged to provide all key stakeholders — both tion, public consultation. on central, as well as local, district and region- al level — with ample opportunity to test, • MAs will be able to delegate functions to learn, build capacity for, internalize, and RDCs based on their assessment of the ca- fine-tune (if necessary) the integrated ap- pacity that will be developed in RDCs and proach. This ‘phasing-in’ process will lead to through RDCs demonstrating this increased the establishment of a tried and tested im- capacity. plementation framework that in the com- ing years will be conducive to reaping devel- • MAs will have a regional allocation in their opment benefits of the integrated approach respective OPs but will not be in any way across Bulgaria. obliged to delegate any of their competences to RDCs but rather be convinced of the ben- efits based on plans for increased capacity Feedback from MRDPW of the regional tier. on the above proposal The Bank team discussed with MRDPW on the Structure of OP RG above proposal and MRDPW clarified the fol- lowing issues to the Bank team: 2021 – 2027 — independ- ent review and options • OPRG is fully committed to the existing ap- to consider proach that has been designed and fully in- tends to delegate the planned functions and MRDPW has proposed a future structure of roles to the RDCs to demonstrate the approach the OPRG consisting of two priority axes (PA):  and build the capacity of the regional tier, which is their main priority. • PA 1 dedicated to Integrated Urban Devel- opment with 8 – 10 major Bulgarian cites el- • Other Managing Authorities will begin the igible for funding (6% of OP allocation). This process of becoming involved in the new would be financed by OPRG only; and integrated regional approach and they will need to be further convinced to involve RDCs • PA 2 dedicated to the new Territorial Ap- in the pre-selection process. proach that would finance relevant com- ponents of integrated projects (Integrated • Central government has conducted their projects) with all Bulgarian municipalities review and decided that no new institu- eligible for funding (some restrictions ap- tions, structures or intermediary bodies ply to municipalities supported under PA 1). will be developed at this stage, so the in- The PA would be financed with 94% of OPRG tention is to proceed with Scenario 1 for funds plus 10% from each of the other OPs,7 the RDC structure. The process for amend- except Transport and Food Provision (in to- ing the RDA in line with Scenario 1 will tal approximately Euro 2.8 million)8. begin with the release of the RDA amend- ment in October 2019 for the public con- At this stage, specific measures or sub mea- sultation phase. sures are not foreseen under the proposed OPRG structure to allow for maximum flexi- • The priority going forward will be to fo- bility, which in principle is an understand- cus on the internal rules for the RDC and able and sensible approach. 7. As per the Common Provisions Regulation (COM(2018) 375 final) – Article 106 (May 2018). 8. The estimated funds (EU and national co-financing) planned to be utilized under the new regional approach are approximately 2.8 billion EUR: 1.9 billion Euro (94% OPRD) and 0.9 billion Euro (10% of the other operational programmes except OP Transport and OP for the Most Deprived; Rural Development Programme, as not been part of the scope of the CMD of June 2019, is not included). This constitutes more than 20% of the total budget of all EU co-financed programmes for Bulgaria under Investment for Jobs and Growth goal for the 2021-2027 financial perspective. Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 47 General Assessment due to the significant portion of OPRG allo- cation (ca. 94%) earmarked for PA 2. The Bank team welcomes the scope of inter- vention envisaged under the proposed struc- 3. limited internal flexibility within the ture of the future OPRG, which is a sign of the OP — while seemingly providing flexibility, commitment of MRDPW to consolidate a crit- the approach to PA2 actually reduces the ical mass of financing to support the imple- possibility to conduct internal transfer(s) mentation of the proposed new territorial of allocation in case of unsatisfactory ab- approach with the ultimate aim of addressing sorption rates under PA2. Transfers will be regional inequalities. It should be noted that limited to take place between only 2 PAs. the proposed OP structure marks a clear depar- ture from that of OPRG 2014 – 2020, which con- 4. limited possibility to monitor and assess sists of seven PAs offering a broad, but also progress on achieving development ob- clearly defined scope of financing for selected jectives in selected types of territories types of investments and municipalities. due to the untargeted nature of PA2, and as a result limited possibility to introduce Specifically focusing on the proposed PA 2, necessary policy shifts or adjustments. the Bank team recognizes the merits of the concentrated and seemingly very flexible 5. uneven competition between funding op- (funds in ‘one big basket’) approach adopt- portunities at the expense of OPRG. At ed by MRDPW. However, the team would like this moment it is not clear what type of to draw attention to some risks this creates. measures will be financed by other OPs un- These risks are multifaceted — they effect der the territorial approach. If they are the key stakeholders (both beneficiaries and OP same as the measures the OPs will contin- Managing Authority) and processes (grant ue to finance themselves (outside the terri- contracting and implementation, including torial approach) and/or there is no a “fast absorption rates), as well as the prospects of track” for grant contracting for these mea- meeting the broader development objectives sures under the proposed ‘integrated proj- in the domain of regional policy. The Bank ects’, there may be limited incentive for team have formulated some key proposals for beneficiaries to prepare and submit such consideration, which would address the key projects by going through a difficult pro- risks as set out below. cesses of partnership establishment and project preparation. Key risks related to the draft OP RG 6. need to increase the MA capacity to fa- 2021 – 2021 structure cilitate the processes of projects iden- tification and partnership establish- Risks for the OPRG Managing Authority: ment — this will put more pressure on the MA’s staff, especially on regional branch- 1. a lack of targeted approach to specific es, who will need to actively participate territories (as recommended by the EC in in new concept implementation. The es- Annex D of the Country Report Bulgaria tablishment of human resources and ca- 2019), which could result in continued un- pacity will need to be well managed to balanced growth on the regional level and avoid jeopardizing the processes of clos- further deterioration of socio-economic ing OPRG 2014 – 2020 and the start-up of situation of deprived, marginalized, or next OP 2021 – 2027. lagging behind territories. Key risks for potential beneficiaries (stake- 2. low absorption rates — delayed uptake holders at local, district and regional level) : of funds (which could be expected due to the complexity and untested nature of the 1. uneven competition preventing poten- new regional approach based on integrat- tial beneficiaries from fair access to EU ed projects) will negatively impact OP’s ab- funding and potentially discouraging sorption rate; this risk is especially serious them from applying (e.g. an integrated 48 Strategic Consultation Report project led by a big municipality is much assets and services) on the local level giv- more likely to be able to be in a position en the realities of the demographic crisis to apply for, and obtain, financing than through dedicated measures; that of a grouping of smaller, marginal- ized communities with limited capacity 3. providing the MRDPW with flexibility and experience). to test new instruments under a dedi- cated measure; 2. limited interest of potential beneficia- ries as under the ‘one basket financing ap- 4. systemically addressing the problem of proach’ they will not see measures addressed limited availability of socio-economic specifically to them, which may be read by indicators for the purposes of elaborat- them as a signal that ‘there is nothing here ing and implementing evidence-based pol- for us’ and this would be further empha- icies on the municipal level under a ded- sized by the lack of specific support mea- icated measure; sures for less advantaged municipalities. 5. supporting the elaboration of territorial 3. lack of possibility to bridge remaining strategies for functional areas and Inte- infrastructure where it is needed, espe- grated Projects under a dedicated measure; cially for those municipalities which due to formal restrictions (i.e. the ‘white spots’) 6. addressing substantial capacity building could not take advantage of EU funded in- and networking needs of local stakehold- vestments under OPRG 2014 – 2020.  ers crucial for the effective implementa- tion of the new regional approach under dedicated measures. Possible options of structuring OPRG 2021 – 2027 to consider The decision on the structure of OPRG 2021 – 2027 would be closely followed by the stra- Considering these risks described above, the tegic selection of the types of projects that Bank team propose to consider a number of would be eligible for funding under the re- options that could lead to the potential re- spective measures. Determining this will be structuring of OPRG 2021 – 2027 with a view conducive to: to addressing and mitigating identified risks and adding more value to the envisaged scope • defining the thematic scope and — con- of intervention. These could be considered in sequently — the selection of relevant parts or whole by the Managing Authority as policy objectives supported under the it further elaborates its approach. OPRG 2021 – 20207 (expanding from just two policy objectives currently envisaged Possible options for OP structure to be con- by MRDWP — namely 2 and 5 — might be sidered: necessary); 1. introduction of specific measures un- • precisely defining the demarcation lines der PA2 dedicated to different types of between OPs to effectively support the new territories (e.g. sub regional growth cen- regional approach through complimentary ters, supramunicipal areas, marginalized interventions with a potential to create de- areas) to effectively promote the new in- velopment synergies; tegrated approach in a more targeted way suited to the specific situations of differ- • encouraging potential beneficiaries to start ent types of territories in Bulgaria.  elaborating and applying for the financing of specific project proposals as a clear frame- 2. addressing some problems of a systemic work would be in place addressing the is- nature related to the process of provision sues raised by municipalities in terms of of social services and asset management how they fit in the process of programming (operation and maintenance of existing the funds; Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 49 • more accurate monitoring and assess- years 2021 – 2027 and — as the outcomes of ment of the progress of the OP’s imple- strategic consultations have proven — are in mentation due to the more targeted nature high demand by the prospective IP beneficia- of the framework. ries. By preparing the first draft the MRDPW has acknowledged the importance of the in- tegrated project guidelines as a useful tool for Feedback from MRDPW local stakeholders — the WB team welcomes on the above review this positive development and notes that it clarifies some key points. Based on a discussion with MRDPW on the above review recommendations, MRDPW clar- The elaboration of the final version of inte- ified the following: grated project guidelines will have to be pre- ceded by a number of decisions of strategic, in- • MRDPW considers it too early to discuss de- stitutional and technical nature. It is also im- tails of the structure of the operational pro- portant to note that the IP guidelines should gram and that it is necessary to define the be prepared in such a way as to ensure a hor- regional tier first before setting out the struc- izontal approach to integrated projects across ture of the operational programme and de- MAs is uniformly applied under the 2021 – 2027 fining the risks relating to the programme. programming period. Therefore, the WB team perceives the draft as a work in progress — as • The focus should now be on the regional MRDPW continues to further elaborate the IP model, which is more important than the guidelines as the process moves forward, so programme design at this stage. they can accurately reflect the final conclu- sions on the implementation of the new re- • MRDPW will, however, review and provide gional approach. feedback on the identified risks for the RDC involvement but will not consider those risks identified regarding the programme Structure and logic of the Guidelines at this stage. It is recommended for the next revised ver- • MRDPW does not plan any other split or sub sion of the document to be structured in such measures other than regional envelopes un- a way as to be more useful to the potential der PA2 at this stage but this does not pre- beneficiaries to understand the approach pro- clude some other splits — for example for posed. Thus, it is suggested it be based on the Sofia or for mountain areas. chronological stages of the process of IP prepa- ration, describing respective requirements and • MRDPW advised that the demarcation lines resources. These stages are: identification of between most OPs are well understood based project ideas/concept; establishment of part- on the current program, including for social nership; public consultations; project selec- sector, education, transport, competitive- tion and the RDC decision; detailed assessment ness, environment etc. Only the demarca- and contracting by the MAs; implementation tion lines between the urban and rural pro- by partners (this is particularly important as grammes are to be confirmed. a number of problematic issues can arise once the IP is contracted and the implementation process begins) and reporting and verification. Guidelines for IP bene- The guidelines should provide practical ad- ficiaries — independent vice for potential beneficiaries on how to ad- review and recommended vance from one stage to the next, as well as steps forward references to available support (incl. Techni- cal Assistance/project pipeline/ etc.). The IP IP guidelines will constitute a significant el- guidelines should also aim to avoid ambigu- ement of the implementation framework of ous or unclear statements that can be open the new regional approach envisaged for the to interpretation or potentially misleading. 50 Strategic Consultation Report Rationale and specifics Relation with other funding sources It would be helpful to provide the rationale The relation to other activities or regular or objective for some of the decisions set out business of the OPs that are contributing 10% (i.e. number of partners, components). should be clarified. There may also need to be information on specific cases, such as sup- The next version should ideally include infor- port for PPP projects, combination of grant aid mation on: with assistance from financial instruments, State Aid aspects, etc. 1. approximate number of IPs to be consid- ered for each NUTS 2 region; 2. (indicative) regional financial envelopes; Proposals for next steps 3. indicative IP budgets (minimum and max- imum volume of financing); The WB team recommended: 4. indicative project list (if foreseen); 5. plans for competitive calls (if foreseen), and 1. establishing a networking group for in- 6. project pipeline. tegrated project guidelines preparation consisting of representatives of all MAs There is a need for a clear definition of IP, as involved in the implementation of the the one formulated in the draft is not exhaus- new regional concept (coordinated by tive and unambiguous. The examples are use- the MRDPW); ful, but a more refined definition would be helpful. 2. launching a public survey (i.e. at MRDPW website) aimed at identifying potential concepts for Integrated projects across Partnership agreements the country; There should be clearer information on the 3. involving a sample of local stakeholders expectation of key stakeholders and perhaps (potential beneficiaries and partners) in an outline of the types of information that the process of elaborating and reviewing would form the partnership agreement (not draft guidelines to ensure they are clear, the agreement itself). On the partnerships, exhaustive, and comprehensive; and there is a need for more information on how that will be facilitated and managed, is it lim- 4. reviewing guidelines for integrated proj- ited to three or a minimum of three partners, ects (ITI, CLLD, CBC, and other) from select- scope of flexibility of partnership agreement ed EU countries to identify good practices to allow for e.g. expanding the partnership by to be considered for the integrated proj- adding new partners. ect guidelines. Project Preparation Feedback from MRDPW and Implementation MRDPW provided the following feedback to The guidelines should provide exhaustive the Bank team on the above recommenda- information on the preparatory stage of In- tions and questions on the guidelines pre- tegrated projects elaboration and its financ- sented by the team: ing, as well as modalities of the project pipe- line (if envisaged). It would be useful to add • The integrated project guidelines will pro- as the annex the pilot application form that vide more flexibility and partnerships may was being prepared for the Rodoppi moun- be developed based on sector and/or terri- tains in summer of 2019, once completed, as torial integration and there will be limits an example. on number of partnerships. Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 51 • There will be a minimum requirement for well as their selection method (indicative the number of partners — three — and that projects versus competitive calls for proposals) one of the partners should be an economic will impact the workload to be processed by partner/business. RDCs and should be reflected in their struc- ture, administrative capacity, as well as • There will be no limitations on the scope of internal rules of procedure . The ongoing the projects or partnerships. preparation by MRDPW of the IP guidelines for prospective beneficiaries will shed more light • It is likely that there will be 1 – 2 strategic on the above-mentioned modalities, which in projects per region, which will be identified turn will allow for a more in-depth review of on a top down basis. All other projects will the proposed RDC arrangements and formu- be developed taking a bottom-up approach. lation of more specific recommendations by the Bank team. • It is not clear yet how many (integrated) proj- ects overall will be implemented under the Key conclusions from review of the RDC model 2021 – 27 perspective. The MRDPW assumes structure: that there will be ca. one-third to a half of the number in the current programming • representation of different opinions and period, which is currently around 600. interests seems to be pursued in the current structure, although participation of political • Each region will have a regional financial representatives should be encouraged given envelope and the algorithm for regional allo- no voting rights cation of funds is currently being developed. Other MAs may develop their own regional • design and operational rules of RDCs should financial envelopes if they so wish. encourage consensus (uneven number of voting rights), accountability (election rules and voting right of the chairperson, conti- RDC model structure nuity of the deputy chairperson, nomina- tion and selection of representatives partic- — independent review ularly from civil society) and effectiveness of decision making (differentiated major- The review below is preliminary given there ity thresholds) remains information to be detailed on the broader framework in which the RDCs would • conflicts of interests could arise between operate, their functions, the specific roles and different functions of the management and tasks of the RDC management, the expected project assessment units and within the nature and scope of integrated projects and units, and this risk should be adequate- the division of tasks between the RDC and ly addressed Managing Authorities (MAs) amongst others. Moreover, the level of information provided • the proposed mediation units and public for all elements of the structure and units consultation units could be merged and differs and is in some cases incomplete. It is involved in project preparation (as the cre- important to underline that the structure of ation of partnerships is essential to prepare RDCs should be determined based both on the a project pipeline) processes, as well as the functions envisaged for the restructured RDCs. • RDCs could benefit from a permanent ad- ministrative entity with offices, stable The assessment, public consultations and leadership (control and oversight), clearly facilitation of integrated projects devel- defined roles, an adequate legal mandate, opment and implementation will consti- sufficient capacity and a dedicated budget tute the backbone of crucial RDCs operations. for operations (in line with the complexity The expected number and size (in terms of and expected size of integrated projects and financing, complexity, number of partners, therefore coordination and communication etc.) of integrated projects in each region, as needs); OP Good Governance 2021 – 2027 52 Strategic Consultation Report could be utilized as a potential source of fi- The strategic choice of the RDC nancing along with national resources scenario and its implications for RDC structure • a comprehensive assessment of the existing capacity at the municipal and regional level The role intended by MRDPW for the RDCs should be undertaken (this scope was not under the new regional approach for the years covered by the OECD pilot action on front- 2021 – 2027 is a pivotal one. RDCs are envis- loading administrative capacity) to formu- aged to reinforce the territorial dimension of late capacity building plans; it is essential to development interventions co-financed from build capacity of in house and external staff the EU Cohesion Policy funds, assist prospec- also for the knowledge hub function of RDC. tive beneficiaries in establishing partnerships capable of implementing Integrated projects, Therefore, the Bank team suggests that the assess project proposals against a set of criteria, recommended way forward to ensure that the including those related to the strategic impor- RDC structure adequately reflects their new tance for the development of the region, and to roles and tasks as part of the broader imple- pre-select them for financing, as well as to raise mentation framework for the 2021 – 2027 pro- public awareness on the planned interventions. gramming perspective would be to: The draft RDC structure proposed by MRDPW 1. clearly define key processes related to the is based on Scenario 1 given the involve- elaboration, assessment, consultation and ment of MRDPW in the first phase of the se- selection of integrated projects on the re- lection of projects. As this would be different gional level, the processes related to proj- than the scenario preferred by stakehold- ect selection on the national level in which ers during the consultations (the major- the RDCs will actively participate, as well ity opted for Scenario 2), it would be use- as internally within the RDC (relations be- ful to explain — for the sake of transparen- tween management and expert branches); cy — the rationale behind this decision and this should highlight internal and exter- the longer term roadmap for further devel- nal coordination and/or communication opment of RDCs in relation to Scenario 2, 3 channels as well as decision making ar- or 4 . Moreover, it would be useful to develop rangements (initial visualizations of pro- a short narrative to define the main aspects cesses are included in this report for review); of the RDC functions and composition under the chosen scenario. It would also be useful 2. formulate clear and unambiguous definition to explain how the restructured RDCs would of the rules of operation of the RDC tiers support a better tackling of the issue of lag- (including rules of coordination between ging regions and/or municipalities. regional and OP programming) should be defined and introduced into the ESIF Man- One of the main findings of the strategic con- agement Act and/or CoM Decree 162/2016 sultations was that the process of preparing on Grant Award Procedures; integrated projects would require clear lead- ership and power, while at the same time 3. determine the RDC roles and tasks to be ensuring that the opinions and interests of performed under the identified processes; various stakeholders are taken into account. This review finds that the latter may have 4. determine the resources (human and fi- been emphasized over the former in the cur- nancial) necessary to effectively perform rent proposed structure of the RDCs. identified roles and tasks and transparent guidelines of selection processes for experts; Governance, voting and composition 5. based on the above-mentioned findings of the RDCs — design an adequate RDC model struc- ture capable of effectively performing the Empowering the representatives of local and assigned roles and tasks and determine regional level with voting rights will help the necessary administrative capacity. boost a regional perspective and meet the long Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 53 term goal of RDCs becoming an effective re- and by whom s/he would be elected (the gional policymaking entity. Therefore, politi- RDC members, the citizens, representatives cal representation of municipalities and dis- of entities pre-defined by law, etc.). In the tricts at the RDC management level is necessary. case of the deputy chairperson it is clear that As equal participation was highlighted as an s/he would be elected by the RDC members. important feature during the consultations, To achieve continuity and predictability the new institutional design and operational of RDC operations, it could be considered for rules of the RDCs should encourage efforts to the deputy chairperson to be respectively reach consensus amongst RDC members. It the previous chairperson and the future one would be useful to get more clarification on (elected one year before the start of term), the roles of different RDC units in addition to which is a widespread practice among col- voting rights, for example on accountability lective entities. of the chairperson (i.e. in terms of reporting). • it would be useful to explain the rationale In terms of nomination of representatives and behind removing the voting right from the voting, there are several questions to be raised: chairperson of the RDC; • it appears that the RDC would consist of 20 • the rules of nomination of representatives representatives with voting rights applying from NGOs, local businesses and academia a “one representative — one vote” rule. How- should be clarified as well as the selection ever, it is recommended to have an uneven process of all representatives and the dura- number of voting members. tion of their terms. • it is also important to clarify what the ma- jority rule or threshold for passing de- Decision-making process cisions would be, and — if possible — dif- ferentiate thresholds for different types of The decision and reporting chain could ben- decisions to be taken by the RDC and to en- efit from further clarification in the proposed sure that they guarantee adequate repre- RDC structure and needs further elaboration, sentation of different interests at the same as it will be essential to ensure effective work time (including potential rules on obliga- processes and reinforce the legitimacy of RDC tory personal presence of RDC representa- decisions. tives for certain decisions and/or on pro- viding replacements). Figures 4.2 and 4.3 are the proposed visualiza- tion of the scheme of the decision making • it is not clear whether the chairperson is processes related to project assessment and elected among the members of the council selection for RDC Scenarios 1 and 2.1. FIGURE 4.2 Decision-making process under RDC Scenario 1 Public First level check Assess List of projects consultation Selected regional impact projects by MRDPW regional departments Ranking discussed in public list events or posted online RDCs (steering the public (Project Assessment Units ) RDCs (advisory committee) and all participating MAs * / consultative) * Processing Uphold MRDPW regional departments Discussions, Detailed (administration) Management evaluation, Ranking list decisions and financing and Transfer submitted Resolution contracting Approval of to MAs for decision RDCs changes Relevant MAs Change Head of MRDPW regional department 54 Strategic Consultation Report FIGURE 4.3 Decision-making process under RDC Scenario 2.1 Public Assess regional consultation First level check impact List of projects Selected projects by Ranking discussed in public RDC office list events or posted online RDCs (steering the public Regional Steering committee) (Project Assessment Units) * Committees ** Processing Discussions, Uphold Management RDC office Detailed decisions and evaluation, Ranking list Resolution financing and Transfer submitted Approval of contracting to MAs for decision Regional changes Steering Change Relevant MAs Committees Head of RDC office It also should be clarified what criteria will These would be introduced into the ESIF Man- be applied for the strategic assessment of re- agement Act and/or CoM Decree 162/2016 on gional impact, who would approve these cri- Grant Award Procedures. teria and which level (management or expert) would conduct the strategic assessment. It is important as well to clarify the linkages be- Coordination, RDC administrative tween strategic assessment of regional impact capacity and funding and project eligibility checks. This is partic- ularly important as stakeholders raised con- In order to effectively perform their new cerns throughout the strategic consultations roles, RDCs will need to become a vital ele- about potential conflict of interest between ment of the implementation framework for the preparation and assessment of projects EU cohesion policy in Bulgaria. Therefore, (i.e. unclear separation of functions between the performance of their new roles should management and expert level). be adequately coordinated and synchro- nized as they will have to act in concert Solving possible conflict of interests will with multiple partners at different levels be one of the biggest challenges to resolve. to ensure a streamlined and smooth imple- Addressing this risk is an essential prereq- mentation process. uisite for ensuring effective involvement of RDCs in the assessment of integrated projects As mentioned throughout the strategic con- and the recognition of their decisions. These sultations, there is some expectation that the conflicts could emerge between, for exam- RDCs should be a permanent administrative ple: (i) the representative and decision mak- entity with offices, stable leadership, clearly ing functions of the RDC management level defined roles, an adequate legal mandate, (i.e. members of the RDC management tier sufficient capacity and a dedicated budget being applicants/beneficiaries of Integrated ensuring day-to-day operations. This is in projects); (ii) the decision making at manage- line with the long term goal of institutionaliz- ment level and project evaluation at expert ing the RDCs, but this is not clearly addressed level (e.g. subordination); and (iii) the differ- in the draft RDC structure (because it is based ent units within the expert tier (project pro- on the selection of Scenario 1). motion/counselling, public consultation and project evaluation). The scope of RDC financing and the required human resources need to be in line with The neutralization or mitigation of this risk the expected number and size of Integrated would require the development of clear and Projects to effectively sustain the function- unambiguous rules of operations of the RDC ing of the RDCs. The proposed dispersed ap- tiers and units with transparent functional proach to financing in the short term (the separation as well as specific rules and proce- draft shows two sources of funding: OP Elec- dures for the assessment of Integrated projects. tronic Governance 2021 – 2027 and Technical Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 55 Assistance of relevant OPs 2021 – 2027) could For the mobilization of external experts on create risks for the functioning of the RDC demand it would be recommended to formu- expert branch, negatively impact timely and late and use a list of experts accredited by effective assessment of project proposals and the relevant MAs for the purposes of integrat- constitute an additional administrative bur- ed project assessment (similar to the existing den in terms of obtaining financing from dif- list managed by CCU). The MAs would be re- ferent sources. For the expert level, one possi- sponsible for recruiting experts and providing bility would be to secure the entire financ- them with training on the integrated project ing from OP Good Governance 2021 – 2027 implementation framework and assessment under dedicated (sub)measure(s) which criteria. A national list could be complement- would ensure a horizontal approach to fi- ed by a regional list to ensure effective pool- nancing based on one common set of rules ing and utilization of resources at the munic- applicable to all RDCs. ipal, district and regional level. These experts could be financed from OP Good Governance It is unclear whether the RDC units for media- 2021 – 2027. This approach would streamline tion, public consultation and preliminary se- the process of expert engagement in RDs lection would be administrative units with- operations, reduce the administrative bur- in the District Information Centers or MRDPW den for RDCs and ensure quality control of Regional Departments or whether they will experts as well as horizontal rules for their be functions that will be implemented by the training and financing. District Information Centers and MRDPW Re- gional Departments without allocating these tasks to their dedicated sub-units. This re- RDC management level quires further clarification before any com- ments can be provided. The introduced division between the RDC management and expert level is welcome. In light of the findings from the strategic con- However, the proposed setup of the man- sultations, the existing administrative capac- agement level gives no answer to the con- ity of the RDC Secretariat (Regional Depart- cerns raised during strategic consultations ments of MRDPW) can be assessed as limited that political representatives from ministries (it is also one of the findings from the OECD tend not to participate in RDCs activities. In pilot action on frontloading administrative fact, observers in RDCs are from line minis- capacity). Currently two experts in each of tries, Council of Ministers and other agen- the MRDPW Regional Departments are co-re- cies which could enhance national-regional sponsible for the RDC secretariat but they have coordination but depending on how the ob- no current or only limited (historical) expe- server’s role is structured or other incentives rience with project assessment and selection. as they have no voting right. Clarity is also needed on how the specialized The specific roles and tasks of the RDC man- sectoral OP expertise would be provided and agement level should be clearly defined as mobilized to support the functioning of RDCs they are not referred to in the proposed draft and how (and which) existing administrative RDC structure. Moreover, clarity is needed on capacity at municipal level would be used to how the control or oversight by the RDC man- support the RDC Preliminary Selection Unit. agement level over the District Information It would be useful to conduct a comprehensive Centers (for mediation and consultation) and assessment of the existing capacity at the MRDPW Regional Departments (for project municipal and regional level (as this was not assessment) would be ensured as they are covered by the OECD in the above-mentioned administratively parts of different structures, pilot action, which concentrated primarily not subordinated in any way to RDCs. The on capacity at the central level) and — based structure is missing a description on the task on the findings — formulate preliminary assignment process to RDC Units, as well as plans on how to increase it in the future information and communication channels to and develop in-house expertise to mini- be used to streamline and enhance the effec- mize outsourcing. tiveness of RDC operations. 56 Strategic Consultation Report RDC expert level a project application form. It should be clar- ified who will be responsible for providing Preliminary Selection Unit methodological guidance for the implemen- tation of the mediation and consultation func- The name of the unit and scope of tasks may tions to be executed. need to be clarified. In fact, “ex ante eval- uation” of projects mentioned in the draft It is understood that the Mediation Unit structure is not required by the EC on the would support the creation of IP partner- level of individual projects (only for OPs and ships, which constitutes a very important this may change for the Programming Peri- role in supporting potential project appli- od 2021 – 2027). Moreover, it was understood cants — one advocated by numerous stake- that the unit would be responsible for project holders throughout the strategic consulta- proposal assessment (not selection or ex-an- tion process. This makes this unit an essen- te evaluation), as in Scenario 1 the projects tial one for the successful strengthening of would be selected by the management level the bottom-up approach under the new re- of the RDCs based on the outcomes of the as- gional concept. Feedback from stakeholders sessment and a ranking list prepared by the was unambiguous that there is a critical need experts (although it is unclear who exactly for a quality project pipeline and that local would have the final decision).It would there- and regional stakeholders would need com- fore be recommended to rename this unit to prehensive assistance to prepare for the ab- “(Preliminary) Project Assessment Unit”. sorption of EU funds given their limited ex- perience with Integrated projects. It is a positive development that the current structure would seem to allow for a transi- It is a welcomed that the RDCs would act as tion from scenario 1 to 2, as it would mainly knowledge hubs, in line with proposals of ad- require a change in the composition of the ditional new functions proposed for RDCs, but Project Assessment Unit. it is unclear how this function would fit into the RDC structure and how its required sub- Explicit rules of coordination of regional stantial expert capacity would be supported. programming with the OPs programming 2021 – 2027 should be introduced (i.e. coordi- Therefore, the functions, capacity and power nation of RDA Rules of Implementation with the of this unit should be clarified and prob- CoM Decree 142/2019) and various institutions ably strengthened. Properly equipping the should cooperate to provide unified instruc- unit with human resources is essential: staff tions for programming of integrated projects. from DICs with their knowledge on EU funds should be complemented by technical experts In relation to the already mentioned prob- representing different fields of expertise able lematic aspect of potential conflict of inter- to guide discussions with potential partners, est, a challenging endeavor will be to agree support for concept proposal and the applica- with all concerned MAs on the composition tion. These technical experts should be pre- of the RDC Preliminary Assessment/Selection sumably both permanent staff and external Unit. Therefore, the criteria for in-house staff experts (mobilized on demand to deliver recruitment, the Integrated projects assess- selected tasks). ment and selection procedures as well as the rules of hierarchical subordination should RDC Consultation unit be clarified. The distinction between the Mediation and RDC Mediation unit Consultation Units is not entirely clear. If the Mediation Unit is to concentrate on sup- The process of project proposal preparation porting the establishment of partnerships includes the interdependent activities of iden- and development of project concepts, whereas tification of potential project ideas, facilitation the Consultation Unit focuses on collecting of the establishment of project partnerships, feedback on pre-selected project concepts, public consultations and the preparation of it will be important to clarify at what point Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 57 (understood as the stage of project develop- From a legal perspective, the new regional ment) the consultation phase would start and development approach, prepared by MRDPW, what the next step would be after the consul- has two main inter-related areas of focus: tations are finalized (e.g. whether it would be the direct submission of a project appli- i) Integrated projects will be the main op- cation by the RDC Project Assessment Unit erational modality, though which ESIF- to MA OPRG for further checks and eventual -funded regional development interven- contracting). tions will be implemented in the next MFF 2021 – 2027; Draft amendments ii) In order to reinforce the territorial di- mension of development interventions fi- to RDA and its Rules nanced by ESIF, it is envisaged for the RDCs for implementation  to have a key role in the preparation and — independent review assessment of integrated projects (RDCs will raise awareness and promote the in- of legal implications tegrated approach among stakeholders; as- sist and support prospective beneficiaries The current legal framework of regional pol- in establishing partnership capable of im- icy implementation in Bulgaria comprises of plementing integrated projects; inform the several main acts, as presented in the Table 4.1. public in the region of, and collect public TABLE 4.1 Legal framework for regional policy implementation in Bulgaria Legal act Scope Regional development Regional Development Basic rules for: Act (RDA) 1. planning, programming, management, resourcing, monitoring, control and evaluation of the implementation of the strategies, plans and programs for the implementation of the regional development policy, 2. planning of the spatial development of the territory at national and regional level Rules for Detailed rules for: Implementation of 1. preparation, coordination, adoption, updating and implementation of the National Regional Development the RDA, adopted Strategy, the regional development plans, the district development strategies and the municipal develop- through CoM Decree ment plans; 216/2008 2. the organizational set-up and operation of the Regional Development Councils (RDCs) and the District Development Councils; 3. monitoring of the implementation of the regional development plans and the municipal development plans ESIF programming and management 2014 – 2020 ESIF Management Act The national institutional framework for the management of ESIF in Bulgaria Basic rules for: grant awards; selections of contractors by grant beneficiaries; verification and certification eligi- ble costs; executing payments; financial corrections under OPs CoM Decree 79/2014 Establishment of monitoring committees for the Partnership Agreement and OPs co-financed by ESIF for 2014 – 2020 programming period CoM Decree 162/2016 Detailed rules for the award of grants under OPs funded by ESIF for the period 2014 – 2020 CoM Decree 189/2016 National rules for the eligibility of expenditure on OPs co-financed by the ESIF for the programming period 2014 – 2020 CoM Decree 161/2016 Rules for coordination between Managing Authorities and Local Action Groups (LAGs) and Fisheries Local Action Groups (FLAGs) related to the implementation of the Community-led Local Development (CLLD) approach for period 2014 – 2020 Regulation, adopted Terms, procedures and mechanism for the functioning of the Information System for the management and through CoM Decree monitoring of the funds from ESIF (UMIS) and for conducting proceedings before the Managing Authorities 243/2016 through the UMIS ESIF programming 2021 – 2027 CoM Decree 142/2019 Preparation of the strategic and programming documents for the management of ESIF in Bulgaria for program- ming period 2021 – 2027 58 Strategic Consultation Report feedback on, the planned interventions; as- integrated projects (e.g. the structure, the- sess project proposals against a set of cri- matic scope and the required synergy of the teria, including those related to the strate- separate components of Integrated projects to gic importance for the development of the contribute to a common development objec- region, and pre-select them for financing; tive; the Integrated projects partnerships as support beneficiaries throughout imple- eligible applicants and the roles and respon- mentation, as well as (possibly) take part sibilities of various project partners to inte- in the monitoring of implementation on grated project initiation and implementation; behalf of OP MAs.) the key phases of the integrated projects ini- tiation and implementation; the contractual The current national legal framework is not framework of integrated projects, etc.). The fully compatible with (cannot fully accom- WB team believes that in view of the complex- modate) those two areas of policy focus and ity of integrated projects and the comparative will need to be amended accordingly. lack of experience with integrated projects of both project applicants/beneficiaries and OP MAs, such legal regulation would facilitate Legal regulation of Integrated the initiation, implementation and manage- Territorial Investments ment of integrated projects. It would be most appropriate to introduce this legal regulation Integrated projects are now regulated only in in the RDA Rules of Implementation. the ESIF Management Act and CoM Decree 162/2016. These are defined as ‘project pro- Once the legal regulation of integrated proj- posals for grant funding under two or more ects is introduced, the ESIF Management Act OPs, one of which is designated as leading’. and/or CoM Decree 162/2016 should also be Apart from that definition, integrated proj- amended, to regulate the specific aspects of ects are mentioned only in four instances in integrated projects initiation, application, con- the ESIF Management Act, all of which in the tracting and implementation modalities in context of competitive selection of projects the context of ESIF financing, stemming from through a Call for Proposals (CfP). The ESIF the multi-OP nature of Integrated projects. Management Act does not provide for any specific rules for integrated projects, except that the project selection and grant award of Legal regulation of RDCs integrated projects involves the Managing Authorities of the funding OPs; in practice the The current legal framework, contained in law treats integrated projects as any other proj- the RDA and its Rules of Implementation, pro- ect proposal participating in a competitive CfP. vides for the following main functions of RDCs (related to regional development interven- Integrated projects are currently not regulat- tions, financed by the ESIF): ed by the RDA and its Rules of Implementa- tion. Neither is such regulation included in • to carry out regional coordination of the the amendments of the RDA and Rules of Im- implementation of the OPs co-financed by plementation, drafted by MRDPW. This very the EU funds, impacting the development scarce and blank legal regulation of integrat- of the region; ed projects is insufficient, in view of the im- portance of integrated projects as the main • to participate in the monitoring of the im- funding instrument of regional development plementation of OPs through its represen- interventions in the next MFF 2021 – 2027 and tatives in the Monitoring Committees of is thus regarded a risk for effective introduc- the Partnership Agreement and of the OPs tion of the new regional approach. co-financed by the EU funds; The WB Team recommends to consider the • to review the results and adopt opinions introduction of (i) a more comprehensive legal on the implementation and impact of OPs definition of integrated projects, as well as co-financed by EU funds on the develop- (ii) legal regulation of the essentials of the ment of the region. Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 59 The internal structure of RDCs is scarcely civil servant and three experts. The senior regulated by the RDA and its Rules of Imple- civil servant acts as Secretary of the RDC. mentation. The latter stipulates that the ‘re- gional coordination’ function is implement- The regional units of MRDPW are financed ed through ‘Regional Coordination Com- by the ministry. mittee’ (RCC), established by the RDC, which committee may set-up its sectoral sub-com- mittees, related to public infrastructure, Amendments to the RDA and Imple- competitiveness, human recourses devel- mentation Rules, drafted by MRDPW opment and environmental issues. The RCC is chaired by the chairman of the RDC, oth- MRDPW has drafted amendments to the RDA er members include representatives of the and its Rules of Implementation, which intro- RDC in the Monitoring Committees of the duce the new regional concept and RDCs’ new Partnership Agreement and the OPs, repre- structure and functions. sentatives of the OP MAs and of the CCU, as well as district governors. The proposed amendments are aimed at in- troducing two main changes in the region- The activity of the RDCs is financed from the al development concept and implementation: budgets of the administrations of the dis- trict governors, chairing the RDC during the i) Simplification of the regional development respective year, up to a ceiling of 10% of the programming framework district administration budgets. Currently the regional planning frame- The RDA and its Rules of Implementation also pro- work includes separate spatial and regional vide for ‘regional units for strategic plan- development planning documents: ning and coordination of regional develop- ment’ of the MRDPW. Those regional units • spatial planning documents (spatial con- have the following functions, related to the cepts/scheme at national level, NUTS 2 RDCs operation and ESIF interventions: level and district level (NUTS 3), and • to act as secretariat of the RDC and interact • regional development plans (including with the central and territorial structures national, regional (NUTS 2 level), district of the executive branch in the implemen- (NUTS 3 level) and municipal (LAU level) tation of the RDC’s decisions; development strategies/plans, as well as Integrated Plans for Urban Regeneration • to support the activities of the Regional Co- and Development (IPURDs). ordination Committee at the RDC; The amendments to the RDA envisage the • to ensure coordination and interaction with introduction of two aspects of simplifica- the Central Coordination Unit (CCU) for the tion of planning framework: implementation of regional coordination in the implementation of the OPs co-financed • merging the spatial planning documents by the EU funds; with regional development plans/strate- gies, as the new type of planning docu- • to coordinate and monitor the implementa- ments will combine both aspects. The new tion of measures funded by the ESIF, includ- ‘integrated’ planning documents at NUTS 2 ing through the CLLD approach, with respect level are envisaged to play the role of ‘ter- to their consistency with the priorities set ritorial strategies’, which are a prerequi- out in the Regional Development Plans. site for the implementation of integrated territorial development actions9 (ITI Under the Rules of Implementation of the RDA the and CLLD) under the draft ESIF Common regional units of MRDPW comprise of a senior Provisions Regulation (CPR) 2021 – 2027; 9. Articles 22 – 24 of CPR 2021 – 2027. 60 Strategic Consultation Report • reducing regional planning levels from • Integrated projects ‘preliminary evalu- 5 to 3 — national, regional (NUTS 2) and ation’ (administrative compliance and municipal , thus removing the district eligibility checks of integrated projects, (NUTS 3) planning level10 and IPURDs11. compliance with regional development strategies, ‘preliminary assessment’ of ii) Introduction of the new structure and the capacity of the IP partnership and functions of RDCs of the leading partner) [Projects Prese- lection Unit]; The draft amendments to RDA provide the basic rules for a 2-tier structure and new • public consultation on evaluated Inte- functions of the RDCs. The structure, com- grated projects, aimed at prioritizing position and functions of the RDC’s tiers them based on public feedback [Public and units are developed in detail in the Consultation Unit]; draft new Rules of Implementation of RDA . • decision making on the ‘advisability of The draft amendments envisage the RDCs funding’ (i.e. on preselection) of integrat- structure to comprise of: ed projects [Management tier] • Management tier (political level), con- The draft amendments of the RDA and RDA sisting of voting members (district gov- Rules of Implementation, prepared by MRDPW, ernors and representatives of municipal- seem to be well formulated, with precise, ities, NAMRB, socio-economic partners, but still widely-scoped wording, allowing NGOs, local universities, businesses, etc.) for flexibility of the operational arrange- and non-voting observers (representa- ments between OP MAs and RDCs. tives from ministries, CCU/CoM, NSI and other). The Head of regional unit of The structure, staffing and functions of the MRDPW will act as Secretary of the RDC. two tiers and of the expert tier units of the RDCs are defined in enough detail in the draft • Expert tier (operational level), consist- RDA and RDA Rules of Implementation. The pro- ing of three units: Mediation Unit, Public posed organizational structure seems to fit Consultation Unit and Project Preselec- to the proposed functions. tion Unit. The draft RDA Implementation Rules envisage the first two units to be staffed with experts from the District Legal issues which are not addressed Information Centres, while the Project in MRDPW’s current drafts Preselection Unit will comprise of ex- perts from MRDPW’s regional units and OP From a legal perspective the most significant MAs, as well as contacted external experts. challenge of the proposed new RDC structure is to reconcile the representative, project This two-tier structure accommodates five promotion, evaluation and decision mak- different functions of RDCs: ing functions of the RDCs, as potential con- flicts of interest could arise between those. • representation of local and regional pub- lic and private stakeholders, related to In order to neutralize or mitigate this risk, it initiation and implementation of region- is recommended MRDPW to develop (i) clear al integrated projects [Management tier]; and unambiguous rules of operations of the RDC tiers and units, ensuring transparent • counselling and facilitation of integrated functional separation between the different project preparation, including partner- tasks of RDCs, as well as (ii) specific rules and ship promotion [Mediation Unit] procedures for the assessment of integrated 10. It should be noted that the removal of the district planning level was strongly opposed in 2018 by both CoM/CCU and district governors with formal arguments. 11. Integrated Plan for Urban Regeneration and Development. Part 4 New Integrated Regional Concept and its Adaptation — independent reviews of WB team 61 projects. The basic rules for operation of the Under a ‘no amendments’ scenario the RDC tiers and units, ensuring functional sepa- current regulation of RDCs — if interpret- ration, should be added to the draft RDA Rules ed flexibly — could still be used as legal of Implementation (and be further developed in grounds for RDCs to perform the intended future Operational Manual of RDCs — if envis- new functions, including assessment and pre- aged by the MRDPW). The specific rules and selection of integrated projects. In this case procedures for the assessment of Integrated the Regional Coordination Committee (RCC) projects should be introduced into the ESIF at the RDC could undertake the ‘management Management Act, or in CoM Decree 162/2016 tier’ functions. The sectoral sub-committees if regulatory flexibility is preferred. at the RCC (which the latter is free to form), supported by the MRDPW regional units, Dis- The intended simplification of the regional de- trict Information Centre’s staff and experts velopment planning framework and introduc- seconded from OP MAs could perform the ‘ex- tion of the new functions and structure of the pert tier’ functions. Under the current RDA RDCs would entail collateral amendments in Rules of Implementation, the RCC is authorised other pieces of legislation too. Those amend- to adopt its own rules of operation, which ments will be only technical, easy to identi- can be used to regulate the internal organ- fy and prepare, once a consensus is achieved isation, processes and functional separation between the key actors involved (CoM/CCU, of different tasks. The operation of the RCC OP MAs and MRDPW) on the amendments in could be financed through the dedicated bud- RDA and Rules of Implementation, related to get of the RDC (up to 10% of the budget of the RDCS new functions. district administrations chairing the RDC), as well as from the technical assistance funds of the selected OP(s). Alternative scenario of introducing the new functions of the RDC It should be however noted that while the- (in the case that the proposed RDA oretically possible, this mode of operation amendments are not adopted) of RDCs will create practical difficulties, could be subject to severe budgetary lim- While the recommended amendments to the itations and would not allow for a stable RDA, its Rules of Implementation and the ESIF framework for strengthening the admin- Management Act (CoM Decree 162/2016) are istrative capacity of the RDCs and assert- considered important for the introduction ing their new roles in the longer term. That of the new regional concept and functions is why the non-adoption of relevant amend- of the RDCs, it should be noted that the new ments to RDA and its Rules of Implementation rep- regional concept and planned functions of resents a high risk for the effective intro- RDCs could be applied even if those amend- duction of the enhanced new role of the ments are not adopted. RDCs under the new regional concept . CONCLUSIONS 64 Strategic Consultation Report Regional policy in Bulgaria seems to be at The preparatory phase as mentioned before important juncture considering the scope will have to be followed by an enhanced mon- of development challenges observed across itoring and coordination effort throughout Bulgaria’s regions on the one hand, and the the entire 2021 – 2027 programming peri- foreseen policy shift on the other. The out- od to assess the progress and ensure that comes of strategic consultations clearly show the new integrated approach is effectively that there is widespread sentiment support- implemented across OPs. As it is a new and ing a paradigm change in how to address previously untested policy approach for Bul- regional disparities, as the current devel- garia different bottlenecks and setbacks are opment model has failed to generate all the likely to materialize both on the supply and expected results. This readiness of stake- demand side of the new approach. These in holders to embrace a new approach consti- turn will generate the need for introducing tutes a very well-timed ‘window of oppor- arrangements aimed at finetuning its imple- tunity’ for MRDPW to effectively introduce mentation mechanism. Clear leadership will measures aimed at strengthening the regional be of paramount importance to make sure dimension of development policy and a more there is continued political ownership of the integrated approach to planning and imple- new approach capable of effectively reconcil- menting EU-funded investments. ing the conflicting stakes of different stake- holders on both national and subnational level. The ambitious vision behind the new inte- grated regional concept and commendable Restructuring of RDCs through entrusting efforts undertaken so far by the MRDPW and them with new roles and functions plays an the CCU to introduce it within the framework important role in the overall paradigm shift of the upcoming 2021 – 2027 programming to be introduced under the new integrated period deserve praise. The introduction of approach. For many consulted stakeholders the territorial approach to a substantial por- the new roles envisaged for the RDCs are not tion of sectoral funds is an important step merely considered within the framework of towards a more place-based policy making, the EU-funds management mechanism and sensitive to local challenges and needs and its technical as well as operational modalities. more effective in tapping into local develop- The choice of RDCs scenario to be applied ment potential. under the 2021 – 2027 programming period is perceived as an ‘acid test’ of the central In order to reap the expected development government’s approach to potential future benefits this ambitious vision, however, must decentralization and further regionaliza- be complimented by a clear and comprehen- tion of development policy. sive implementation framework and an in- tensive capacity building effort to equip pro- Taking into account the fact that equipping spective beneficiaries at the local level with the RDCs with sufficient skills, competenc- the competences and skills necessary to ef- es and staff will require substantial capacity fectively take advantage of new development building effort over a longer period of time opportunities. As one of the mayors stated and effective pooling of dispersed resourc- during the consultations: ‘We are open to the es available on municipal and district level new approach, but we need a teacher’. This ex- it would be sensible to invest in a scenar- pectation is justified given the very limited io that would be likely to produce longer and not necessarily positive experience so term positive implications for regional pol- far with integrated projects in Bulgaria and icy in Bulgaria. Therefore, in order to ensure the often insufficient and dispersed capaci- a more universal buy-in of stakeholders on ty of local stakeholders to effectively elabo- the subnational level in supporting and rec- rate and implement such projects. It is im- ognizing the new roles of RDCs, actively en- portant for MRDPW and CCU as champions of gaging them in a sustained intensive capac- the new approach to acknowledge and effec- ity building process and providing the RDCs tively address this need. This report formu- with the political leverage to effectively rep- lates a number of recommended actions to resent the regional perspective in the longer be taken with a view to achieving this goal. term, MRDPW and CCU would benefit from Conclusions 65 setting out a post-2027 vision for the RDCs management system, but within a broad- and a credible action plan with key mile- er framework of the possible decentraliza- stones for its implementation. tion agenda to be pursued in the coming years by the central government . This de- Each of the consulted RDC scenarios holds its cision will carry a lot of weight as it can be merits for enhancing the regional dimension either the first crucial milestone in the pro- of development policy in Bulgaria. However, cess of building fully operational administra- the final decision on the RDC scenario se- tive structures on the regional level, or mere- lected for implementation should be thor- ly a singular technical arrangement of the oughly considered not just in the context EU-funds management framework that can of operational modalities of the EU funds be easily replaced by a different one post-2027. 66 Strategic Consultation Report ANNEX 1  QUESTIONNAIRE FOR STRATEGIC CONSULTATION Memorandum Stategic Consultation Meetings RAS: “Enhancing the Regional Development Process in Bulgaria and supporting Ministry of Regional Development and Public Works (MRDPW) in the programming process for the period 2021 – 2027” SUBJECT OF MEETING: Strategic consultation DATE: PLACE: PARTICIPANTS: MAIN ASSUMPTIONS/PREMISES: Interviewees are familiar with the following recent developments: 1. MRDPW’s concept note on new regional approach to the next programming period, 2. Council of Minister’s decision (#335) on the minimum financial allocations from OPs to im- plement integrated territorial development approaches under the next programming period. Interviewees are familiar with the aim of the strategic consultation, which is to gather information from a range of stakeholders to support MRDPW to: 1. improve regional development policy in Bulgaria; 2. improve awareness of the options for improving the planning, preparation and imple- mentation of regional development planning; and 3. identify possible new functions and responsibilities for regional development councils in regional development. 4. Analyze opportunities to better synchronize and coordinate regional development poli- cy with the programming and implementation of the OPs. Interviewees are familiar with the World Bank’s role in the process: The World Bank is to support MRDPW to enhance the regional development process in Bulgaria during the next programming period 2021 – 2027 and to support MRDPW in building Annex 1 Questionnaire for strategic consultation 67 the capacity of Regional Councils for their involvement in the implementation of a new OP for regional development by leveraging global expertise and the direct work of the Bank in EU countries. From the list of questions on the following table, different questions need to be shared with different stakeholders prior to the meetings (as indicated in the last column) • A multi-stakeholder meeting with simultaneous interpretation lasts at least 3 hrs to allow an in-depth discussion. • For bilateral meetings with consecutive interpretation at least 1.5 hrs have to be planned. Main topics for discussion: • Approaches for improving regional development planning and processes. • MRD’s new concept of regional development (integrated approach to territorial investments) • RDC — possible new functions and responsibilities in regional development. • Regional development implementation and coordination during the next financial per- spective (2021 – 27) muni NGO/ # question MA /distr Busin MRD’s new concept of regional approach to territorial development (integrated investments) 1. Are you aware of the OPRG and MRDPW new regional approach to territorial × × × development? (integrated territorial investments in a broad sense) planned for the next programming period? 2. Do you have experience with any of the following: × × Integrated projects (as per Council of Ministers Decree 162 of 2016) • CLLD projects • Inter-municipal projects • forming partnerships to apply for the EU money • Could you please describe main benefits and challenges of such projects? 3. Have you had project ideas which could not evolve into EU project applica- × × tions, because they were multi-sectoral and could not fit into a single OP? (only for beneficiaries). What kind of project ideas were these? 4. Which areas of intervention, in your opinion, would be the most suitable for × × × developing as integrated territorial projects? 5. How would you assess your capacity for preparing integrated (or multi-sec- × toral) projects? Specifically, what is your capacity in the following areas: needs identifica- tion, solution design, finding partners, preparation of a project application, operationalization of a project, implementation — technical and financial management, monitoring)? 6. Have you collaborated with other actors or used external support to design × × or implement EU-funded projects? If, yes, please share the main advantages and challenges. Have you worked with any regional development agency? 7. How would you describe your capacity to create partnerships to implement × × joint projects? 8. What do you see as the implications for your organization coming from the × × × new regional approach? 68 Strategic Consultation Report muni NGO/ # question MA /distr Busin 9. From your perspective, please list the most important prerequisites to × × × ensure successful implementation of the new regional approach to territo- rial development? At the level of your organization? On a systemic level? (possible areas: capacity building, incentives for effective implementation of the new regional approach, coordination mechanisms, legal changes, proj- ect preparation and implementation capacity, resources — both human and financial etc.). 10. Based on your practical experience, which of the following three stages × × × of designing and implementing an integrated project could be the most challenging? (1) preparation of a concept/project proposal, (2) assessment/selection of projects; and (3) implementation of projects: How could these challenges be overcome? 11. How to ensure effective assessment of project proposals against regional × × × development needs? 12. How would you envisage the process of signing an integrated project × × × between various MAs and a multi-stakeholder partnership? Consider a case where at least two MAs need to sign off on the project pro- posal and are responsible for achieving results? What would need to happen to make such a process possible? RDC –future role 13. In general, what is your view about delegating more roles to the regional × × × level? What are the benefits and risks? 14. How could RDCs assume the role envisaged in the MRD’s new regional × × × development of territorial development? 15. In your opinion, is the current format of RDCs (the current RDC composition, × × × rotational leadership etc.) suitable for developing and managing the imple- mentation of a strategic approach at the regional level? If not, what changes do you see necessary? 16. Would you consider the future RDCs a representative forum for discussing × × × the regional perspective? 17. What new or modified functions would the RDCs have to be empowered × × × with to allow them to play the role envisaged in implementation of integrated territorial investments: • organizational structure • composition • power (tasks/duties) • budget • capacity • other 18. Which of the two proposed scenarios for RDCs do you consider most suit- × × × able to implement in Bulgaria for the next programing period? Why? What are the pros and cons of these two solutions? 19. In your opinion, would it be useful if the RDCs were to fulfil a function of: × × × • regional knowledge hub for local and regional stakeholders (an entity gathering information about the region) • ‘territorial observatory’ — an entity performing analyses about the region and monitoring regional development and various socio-economic aspects 20. How should the members of future RDCs be selected? × × × 21. How could RDCs be effectively incentivized or supported to perform their × × × new roles in an efficient way? Annex 1 Questionnaire for strategic consultation 69 muni NGO/ # question MA /distr Busin Regional development implementation and coordination during the next financial perspective (2021 – 27) 22. In your opinion, to what extent is current regional development policy in × × × Bulgaria coordinated with the EU ESIF programing process for post 2020? Could you please provide examples of mechanisms to demonstrate this coordination ? 23. What are the pros and cons of the current coordination mechanisms? Which × × × specific elements could be improved, if any? 24. Could you indicate any past and current positive experiences or good prac- × × × tices with regional policy coordination in Bulgaria (or relevant to Bulgaria) that could be shared? 25. Are you involved in the formulation of regional development policymaking or × × × regional plans? Are you involved in the formulation of the regional approach for the ESIF post-2020 programing period? 26. Are there any aspects, related to the development of the regional policy and × × × the new integrated regional approach, which were not covered in the meet- ing that you would like to share? 70 Strategic Consultation Report ANNEX 2  QUESTIONNAIRE STAKEHOLDER MAPPING STAKEHOLDER MAPPING RAS: “Enhancing the Regional Development Process in Bulgaria and supporting Ministry of Regional Development and Public Works in the programming process for the period 2021 – 2027” STAKEHOLDER: DATE: PLACE: 1. How strong stakeholder supports such approach? (from strongly support to strongly oppose)  Strongly support          Strongly oppose  If the stakeholder answers that support continue with next questions’ if does not support go to question 4. 2. Which aspects of ITIs does stakeholder finds relevant to territorial needs? Please, elaborate.  3. In what manner would stakeholder demonstrate this support?  • Would they take the initiative in supporting or they prefer to wait for others to do so?  • Do they have financial and human resources available to support this approach?  • What conditions would need to exist for them to express this support?  • Which person/organization do they think share your opinion?  4. Which aspects of IPs do stakeholder find unclear/irrelevant/inadequate?  5. Which person/organization do they think share your opinion? How close are they to them?  6. Under what conditions do they think can change their opinion and support the new approach?  71 ANNEX 3  SCHEDULE OF STRATEGIC CONSULTATIONS Strategic consultations planning at central level Day time Date 9.00 – 11.00 11.00 – 13.00 14.00 – 16.00 16.00 – 18.00 Place 8-Jul 9.00 – 10.30 MA Regions 11.30 – 13.00 MA 14.00 – 15.30 National 16.00 – 17.30 MA OPRG in Growth Cross-border Center for Territorial Science and Education premises Development for Sustainable Growth — not happened 9-Jul 9.00 – 10.30 CCU 11.00 – 12.30 MA Good 14.00 – 15.30 MA Human 16.00 – 17.30 MA Rural counterparts Governance Resources Development premises 10-Jul 9.00 – 10.30 MA 11.00 – 12.30 MA 14.00 – 15.30 MA 16.00 – 17.30 MA counterparts Innovation and Transport Environment Maritime Affairs premises Competitiveness 11-Jul 9.00 – 10.30 National 11.00 – 12.30 Fund of 13.30 – 15.00 16.00 – 17.30 MF — Audit MRDPW Association of Funds Ministry of Finance Authority and Certifying premises Municipalities in the (MF) — Economical Authority Republic of Bulgaria and Financial Policy Directorate 12-Jul 9.00 – 10.30 National 11.00 – 12.30 Fund for 13.30 – 15.00 Regional 15.00 – 16.00 Wrap-up OPRG company Industrial local authorities and gov- Urban Development and planning of the premises Zones ernments (FLAG) and Fund regional consultations the Fund for Sustainable Cities Strategic consultations planning at regional level Day / time WB Date 9.00 – 11.00 11.00 – 13.00 14.00 – 16.00 16.00 – 18.00 Team Region 15-Jul Travelling: North-West Region North-West Region 16.00 – 18.00: Joint WB North- Sofia — Lovech (2h) Meeting — RDC + Meeting — Stakeholders meeting small munici- Common West CEAOEF and RPC not covered by the palities of North-West team: J, RDC: NGOs, busi- and North-Central A, Al nesses, citizens, univer- Regions — Troyan Mayor sities, LCCD, Regional and Sevlievo Mayor (in Development Agencies, Lovech at the premises etc. where RDC meetings are held) Travelling: Lovech – Pleven (0.5h) 16-Jul 9.00 – 10.30: Meeting Travelling: 14.00 – 15.30 — Meeting Travelling: WB North- Pleven Mayor Pleven – Montana Mayor Montana Montana – Sofia (2h) Common West Travelling: team: J, Pleven – Montana (3h) A, Al 17-Jul Traveling: Traveling: 14.00 – 15.30: 16 – 17.30: Meeting: WB South- Sofia – Bojurishte Bojurishte – Sofia (0.5h) Meetings lefts from Regional Department Common West (0.5h) 11.30 – 13.00: Meeting the central level: CLLD of DG SPPRD in South- team: J, 9.00 – 10.30 Meetings Sandanski Mayor in LAG Association West Region A, Y, Al industrial Zone  Sofia at the premises — Bojurishte administra- where RDC meetings tion and investors, and are held the Bojurishte Major 72 Strategic Consultation Report Day / time WB Date 9.00 – 11.00 11.00 – 13.00 14.00 – 16.00 16.00 – 18.00 Team Region 18-Jul 9.00 – 10.30: Meeting Meeting — RDC + Meeting — Stakeholders 16.30 – 18.00: Meeting WB South- Sofia Mayor CEAOEF and RPC not covered by the Kiustendil Mayor in Common West RDC: NGOs, busi- Sofia at the premises team: J, nesses, citizens, univer- where RDC meetings A, Y, Al sities, LCCD, Regional are held Development Agencies, etc. 19-Jul Participation in the Participation in the Participation in the Participation in the WB South- NCTD conference for NCTD conference for NCTD conference for NCTD conference for Common West presenting the results presenting the results presenting the results presenting the results team: J, of the Socio-Economic of the Socio-Economic of the Socio-Economic of the Socio-Economic A, Y, Al Analysis Analysis Analysis Analysis 20-Jul             21-Jul     Travelling Travelling     Sofia – Burgas (4h) Sofia – Burgas 22-Jul 9.00 – 10.30: Meeting — RDC + Meeting — Stakeholders 16.30 – 18.00: Meeting WB South- Meeting — Burgas CEAOEF and RPC not covered by the Pomorie Mayor in Team 1 East Mayor RDC: NGOs, busi- Burgas at the premises nesses, citizens, univer- where RDC meetings sities, LCCD, RDAs, etc. are held 23-Jul 9.00 – 10.30 Meeting Travelling: 14.00 – 15.30: Meeting 16.30 – 18.00: Meeting WB South- Burgass Industrial Burgas – Stara Zagora Stara Zagora Mayor Kazanluk Mayor Team 1 East Zone (administration (2h) Travelling: Stara and investors) Zagora to Kazanluk (0.5h) 24-Jul Travelling: Kazanluk to 11.00 – 12.30 14.00 – 15.30: Meeting 16.00 – 17.30 Meeting: WB South- Plovdiv (1.5h) Meeting — Economic Plovdiv Mayor Regional Department Team 1 Central Zone Trakia (adminis- of DG SPPRD in South- tration and investors) Central Region Travelling: Plovdiv – Kazanluk (1.5h) 25-Jul 9.00 – 10.00 Travelling: Travelling: Pazardjik to 13.30 – 15.00 Meeting Travelling: Peshtera to WB South- Polvdiv – Pazardjik (up Peshtera (0.5h) Peshtera Mayor Smolyan (3h) Team 1 Central to 1h) Travelling: Peshtera to 10.00-11.30 Meeting Smolyan (3h) Pazardjik Mayor 26-Jul 9.00 – 10.30: Meeting Meeting — RDC Meeting — Stakeholders Travelling; Smolyan to WB South- Smolyan Mayor + Committee on not covered by the Sofia (4h) Team 1 Central European affairs RDC: Stakeholders not and oversight of covered by the RDC: the European funds NGOs, businesses, (CEAOEF) and citizens, universi- Regional Policy ties, LCCD, Regional Committee (RPC, Development Agencies, National Assembly) etc.               22-Jul 8.30 – 11.00 Travelling: 11.00 – 12.30 Meeting: 15.00 – 16.30: 17.00 – 18.30: WB North- Sofia – Gabrovo (2.5) Gabrovo Mayor Meeting — Ruse Mayor Meeting — Regional Team 2 Central Travelling: Department of DG Gabrovo – Ruse (2h) SPPRDDG SPPRD in North-Central Region 23-Jul 9.00 – 10.30: Meeting Travelling 13.00 – 15.30: 15.30 – 17.30: WB North- Ruse Industrial Zone Ruse – Razgrad (1h) Meeting — RDC + Meeting — Stakeholders Team 2 Central (administration and CEAOEF and RPC not covered by the investors) RDC: NGOs, busi- nesses, citizens, univer- sities, LCCD, Regional Development Agencies, etc. Travelling: Razgrad – Targovishte (0.5h) Annex 3 Schedule of strategic consultations 73 Day / time WB Date 9.00 – 11.00 11.00 – 13.00 14.00 – 16.00 16.00 – 18.00 Team Region 24-Jul Meeting — RDC + 11.30 – 13.30 14.00 – 15.30 Meeting 16.00 – 17.30 Meeting WB North- CEAOEF and RPC Meeting — Stakeholders Dobrich Mayor in Novi Pazar Mayor Team 2 East not covered by the Targovishte at the in Targovishte at the RDC: NGOs, busi- premises where RDC premises where RDC nesses, citizens, univer- meetings are held meetings are held sities, LCCD, Regional Traveling: Development Agencies, Targovishte – Varna etc. (1.5h) 25-Jul 9.00 – 10.30 Meeting 11.00 – 12.30: 14.00 – 15.30 Meeting Preparatory for the WB North- Varna Mayor Meeting — Regional Varna Industrial Zone MAs joint meeting Team 2 East Department of DG (administration and SPPRDDG SPPRD in investors) North-East Region 26-Jul Travelling Varna – Sofia Travelling Varna – Sofia Travelling Varna – Sofia 16.00 – 17.30: Joint WB North- (5.5h) (5.5h) (5.5h) Meeting with MAs Team 2 East 27-Jul             28-Jul             29-Jul 10.00 – 12.00: Joint           Meeting MAs Abbreviations: RDC — Regional Development Council CEAOEF — Committee on European affairs and oversight of the European Funds RPC — Regional Policy Committee (National Assembly) DG SPPRD — Directorate General Strategic Planning and Programing of Regional Development Contacts: Industrial Zones: http://nciz.bg/za-nas.html Trakia Economic Zone: https://tez.bg/ LAG CLLD: https://vomr.bg/en/home/ Regional Development Agencies Stara Zagora: https://www.szeda.eu/en/ Varna: https://www.veda-bg.eu/bg/ Plovdiv: http://rda-bg.org/index.php/welcome/aboutUs Razlog: http://www.leda-razlog.org/?lang=en Vidin: http://www.bcvidin.org/3-3.html 74 Strategic Consultation Report ANNEX 4  LIST OF PARTICIPANTS STRATEGIC CONSULTATIONS UNDER OPERATIONAL PROGRAMME REGIONS IN GROWTH 2021 – 2027 # Participant’s name Organization # Participant’s name Organization CENTRAL LEVEL July, 11 2019; Sofia July, 8 2019; Sofia N.A. N.A. National Association of Municipalities in the N.A. N.A. OPRG: Strategic devel- Republic of Bulgaria at opment and contracting MRDPW unit, Department of mon- itoring, Financial manage- N.A. N.A. Fund of Funds at ment and control depart- MRDPW ment, Public procurement control department, Unit N.A. N.A. Ministry of for program level evalu- Finance — Economical ation and public aware- and Financial Policy ness at program level Directorate at MRDPW N.A. N.A. Managing Authority N.A. N.A. Ministry of Regions in Growth at Finance — Audit OPRG premises Authority and Certifying Authority at MRDPW N.A. N.A. Cross-border / territorial cooperation Managing July, 12 2019; Sofia Authority at OPRG N.A. N.A. National Company of N.A. N.A. National Center for Industrial Zones at Territorial Development OPRG at OPRG N.A. N.A. Fund for local authori- July, 9 2019; Sofia ties and governments (FLAG) and the Fund N.A. N.A. Central Coordination for Sustainable Cities at Unit at MRDPW OPRG premises N.A. N.A. Regional Urban N.A. N.A. OP Good Governance Development Fund at unit at MRDPW OPRG N.A. N.A. Managing Authority for N.A. N.A. Regional Development Human Resources at Councils MRDPW NORTH-WEST REGION N.A. N.A. Managing Authority for Rural Development July, 15 2019; Lovech, RA July, 10 2019; Sofia N.A. N.A. North-West Region RDC + CEAOEF and RPC N.A. N.A. Managing Authority for Innovation and N.A. N.A. North-West Region Competitiveness at Stakeholders not cov- MRDPW ered by the RDC: NGOs, businesses, citizens, N.A. N.A. Managing Authority universities, LCCD, for Transportation at Regional Development MRDPW Agencies, etc. N.A. N.A. Managing Authority for N.A. N.A. Small municipali- Environment at MRDPW ties of North-West and North-Central N.A. N.A. Managing Authority Regions — Troyan Mayor for Marine and Fishery and Sevlievo Mayor (in Affairs at MRDPW Lovech) Annex 4 List of Participants Strategic Consultations under Operational Programme Regions in Growth 2021 – 2027 75 # Participant’s name Organization # Participant’s name Organization 1 Boryana Voicheva MRDPW 40 Gradimir Penkov ASA 2 Svilen Stoyanov MRDPW 41 Tanya Valova-Petrova ASA 3 Joana Masich WB 42 Vessela Dankova Civil Initiatives Association Lovech 4 Chavdara Pantic translator 43 Borislav Ilevski CEIB 5 Yanko Stoyanov MRDPW 44 Tsvetelina Guneshka BCC Lovech 6 Evelina Parashkevova Academy of Economics — Svistov 45 Rennie Matieva Loznitsa Mun. 7 Maria Stoyanova Academy of 46 Galina Petrova Ecomissia 21 vek Economics — Svistov Association 8 Vera Dobreva Troyan Mun. 47 Galia Shuglyova Knezha Mun. 9 Nelly Miteva Lovech, RA 48 Elenko Nachev Regional Management of Education for Lovech 10 Ivaylo Stoyanov MRDPW 49 Iveta Kriviradeva RIC Lovech 11 Alexander Hinov WB 50 Irina Falpdzhiyska ASA Lovech 12 Margarita Bogdanova Academy of Economics — Svistov 51 Eng. Maria Dimitrova DA Lovech Region 13 Yulian Gospodinov Academy of 52 Georgi Georgiev BCC Lovech Economics — Svistov 53 Stefan Tarnyovski Knezha Mun. 14 Milen Dulev Belene Mun. 54 Petlino Damyanova CRRI Association 15 Albena Georgieva Vidin, RA 55 Tsanko Tanovski LAG Apriltsi 16 Anelia Vlahovski Vidin, RA 56 Darina Docheva Veni plast Ltd. 17 Julia Tzolova MF 57 Maria Nedyalkova Zakrila Association 18 Pencho Penchev TC Lovech 58 Rosen Belchev Montana, RG 19 Miroslav Iliev Pleven Mun. 59 Galia Donova-Ivanova Montana, RA 20 Elena Angelova BCCI Vratsa 60 Evgenia Bodinkova Knezha Mun. 21 Nadia Rabadjieva Lukovit Mun. 61 Dobromir Todorov Montana, RA 22 Stefan Milev Pleven Mun. July, 16 2019; Montana, RA 23 Malina Nikolova Vratsa, RA N.A. N.A. Mayor Montana 24 Varbinka Borisova Vratsa, RA SOUTH-WEST REGION 25 Elia Borisova Lovech, RA July, 17 2019; Bojurishte and Sofia, RA 26 Ralitsa Geshovska Vratsa, RA N.A. N.A. Industrial Zone repre - 27 Lyuba Petrova Nikopol Mun. sentatives, Bojurishte administration and 28 Boyko Beltekov Nikopol Mun. investors, and the 29 Irina Miteva DBL Lovech Bojurishte Major 30 Tsetso Angelov RZS party Lovech N.A. N.A. Sandanski Mayor in Sofia at the premises 31 Alexander Hinov WB where RDC meetings are held 32 Joanna Masic WB N.A. N.A. Central level stake- 33 Teodora Hristova Lovech, RA holders CLLD LAG Association 34 Petko Petkov KNSB N.A. N.A. Regional Department 35 Madlena Boyadjieva Teteven Mun. of DG SPPRD in South- West Region 36 Violeta Nikolova Lovech, RA July, 18 2019; Sofia, RA 37 Pavlina Nikolova Podkrepa CL Lovech N.A. N.A. Mayor of Sofia 38 Hristian Vutov RIC Lovech N.A. N.A. Representatives of RDC 39 Valentin Valev Lovech , area + CEAOEF and RPC 76 Strategic Consultation Report # Participant’s name Organization # Participant’s name Organization N.A. N.A. Stakeholders not cov- 95 Magdalena Stoilova-Tsankova MF ered by the RDC: NGOs, businesses, citizens, 96 Yana Georgieva WB universities, LCCD, Regional Development 97 Anna Banaschuk WB Agencies, etc. 98 Alexander Hinkov WB N.A. N.A. Kiustendil Mayor in Sofia at the premises 99 Emil Slavkov Satovcha Region where RDC meetings are held 100 Joanna Masic WB 62 Lyudmila Stoykova MRDPW 101 Diana Trifonova ME 63 Elitsa Gramadska MRDPW 102 Maya Ninova MES 64 Ivaylo Stoyanov MRDPW 103 Gloria Petrova Vassileva Sofia, RA 65 Alexander Hinov WB 104 Christina Todorova Sofia, RA 66 Jana Georgieva WB 105 Anna Radeva Stroitel (press) 106 Zornitsa Kraleva Blagoevgrad Mun. 67 Yordanka Paunova citizen 107 Maria Grozdanova Blagoevgrad Mun. 68 Petya Donova IPPM 108 Magdalena Ivanova Zlatica Mun. 69 Isabella Tottina R C Consult Ltd. 109 Denitsa Nikolova MRDPW 70 Andreana Andreeva R C Consult Ltd. 110 Zdravko Beshendzhiev MRDPW 71 Boryana Velcheva BIU 111 Milen Minchev MTITC 72 Dimitar Kumanov Balkanka 112 Theodora Mitova ME 73 Petko Kovachev IAE 113 Irena Nikolova ME 74 Angel Burov UUB 114 Biser Mihaylov Regional Governor 75 Lyudmil Ivanov RASTIA 115 Victor Yanev Regional Governor 76 Zdravko Gechov LGRF 116 Pasco Stoilkov Slivnitsa Mun. 77 Dochka Vassileva FMFIB 117 Dimitar Dimitrov MAFF 78 Georgi Nikolov UNWE 118 Boris Borisov Botevgrad Mun. 79 Georgi Hristov Tsolov UNWE 119 Olga Kitanova Dupnitsa Mun. 80 Desislava Ketsorska FMFIB 120 Ivanna Veneva Pernik, RA 81 Svetlina Lomeva ADR 121 Boyko Doychinov non-profit association 82 Sevdalina Voynova ADR 122 Grigor Daulov Chavdar Mun. 83 Nikolai Katsarski Sofia University 123 Marin Pavlev Slivnitsa Mun. 84 Dima Koteva Ecosociety Foundation 124 Ilian Todorov DASD 85 Rennie Alexandrova BCC 125 Nikolay Nikolov DASD 86 Irina Mutafchiiska USB 126 Nikolai Borisov DASD 87 Antonia Shalamova ADR 127 Maya Tsanova DASD 88 Velina Gencheva Renus 128 Desislava Dobcheva DASD 89 Eng. Rositsa Plachkova Kyustendil Mun. 129 Ivaylo Stoyanov Elin Pelin Mun. 90 Tsvetelina Atanasova MRDPW 130 Rumen Dimitrov MK 91 Ivaylo Stoyanov MRDPW July, 19 2019; Sofia, RA 92 Lyudmila Stoykova MRDPW N.A. N.A. Stakeholders at NCTD 93 Andrey Mitov BSN conference (results of the Socio-Economic 94 Borislav Tomirkov Sofia, Vitosha District Analysis) Annex 4 List of Participants Strategic Consultations under Operational Programme Regions in Growth 2021 – 2027 77 # Participant’s name Organization # Participant’s name Organization SOUTH-EAST REGION (AND NORTH-CENTRAL REGION TEAM 2) 160 Georgi Simeonov Stara Zagora Municipality July, 22 2019; Burgas, RA; Gabrovo; Ruse 161 Galia Badeva Nesebar Municipality N.A. N.A. Mayor of Burgas 162 Maria Stoykova Municipality N.A. N.A. RDC + CEAOEF and RPC 163 Zdravko Beshendzhiev MRDPW N.A. N.A. Stakeholders not cov- 164 Ib Mustafa Ib Ruen Municipality ered by the RDC: NGOs, businesses, citizens, 165 Rumen Dimitrov LAG Aitos universities, LCCD, Regional Development 166 Deyan Gospodinov LAG Aitos Agencies, etc. 167 Marusya Lyubcheva Black sea Institute N.A. N.A. Pomorie Mayor in Burgas at the premises 168 Ivelina Petrova Black sea Institute where RDC meetings are held 169 Irene Markovska Asen Zlatarev University 131 Nikolay Nikolov MRDPW 170 Kremena Chilikova LFIG Burgas — Kameno 132 Nikolai Milev MRDPW 171 Nelly Karneva NALAGB Elhovo — Bolyarovo 133 Iveta Krasteva ME 172 Georgi Mitov LAG Tundzha 134 Chavdara Pantic Translator 173 Nikolay Yanev Nikolay Yanev 135 Mirela Georgieva MTITC 174 Kiro Bradzhev Kitso Ltd. 136 Sevdalina Turmanova RA 175 Evelyn Kouzmanov RIC Burgas 137 Zlatka Markova AIKB 176 Venelin Dobrev REDA Stara Zagora 138 Joanna Masic WB 177 Arch. Peter Kiriazov CAB Stara Zagora 139 Alexander Hinov WB 178 Ventsislav Krastev Artstroi L Construction 140 Pavlin Ivanov CEIB Burgas 179 Maria Kupenova Artstroigrup 141 Tsvetelina Atanasova MRDPW 180 Miyryam Mehmet Ib Ruen Municipality 142 Vitka Vulcheva BIA Burgas 181 Tanya Kirova CAB Stara Zagora 143 Mariela Pavlova Yambol , RA 182 Maria Panayotova Burgas Municipality 144 Ruslana Miroslavova Yambol , RA 183 Radko Drenchev BST party 145 Magda Moskova MES 184 Dimitar R. RCSP Lozovo 146 Diana Nikolaeva-Grozdanova А1 185 Nikolay Slavov Reha consult Ltd. 147 Nedelcho Rachev Regional Directorate of the Ministry of Interior 186 Julia Sotyanova Reha consult Ltd. 148 Nana Gencheva Nova Zagora 187 Vanya Yancheva Via Pontica Org. Municipality 188 Georgi Petkov LFIG Pomorie 149 Iancho Iliev Pomorie Municipality 189 Veselin Atanassov Atanchi Ltd. 150 Olga Andreeva Burgas Municipality 190 Tonka Karavidova BCC Burgas 151 Violeta Lazova Burgas Municipality 191 Arch. Banko Banov CAB Stara Zagora 152 Ivan Takov Sredec Municipality N.A. N.A. Mayor of Gabrovo 153 Denitsa Nikolova MRDPW N.A. N.A. Mayor of Ruse 154 Russka Boyadjieva Burgas Municipality N.A. N.A. Regional Department of 155 Juliana Shopova Kanal 0 DG SPPRDDG SPPRD in North-Central Region 156 Nikolai Petrov Kanal 0 July, 23 2019; Razgrad, Hotel Cartoon 5; Stara Zagora; Kazanluk 157 G.M. Stara Zagora, RA N.A. N.A. Representatives of 158 Blaga Stoykova Trakia University Burgas Industrial Zone (administration and 159 Juliana Blagoeva-Yarkova Trakia University investors) 78 Strategic Consultation Report # Participant’s name Organization # Participant’s name Organization N.A. N.A. Stara Zagora Mayor 229 Gyulchin Ahmedova Amilum Bulgaria N.A. N.A. Kazanluk Mayor 230 Shenel Hasanova LAG Tutrakan Slivo pole 192 Lyudmila Stoykova MRDPW 231 Angel Angelov LAG Tutrakan Slivo pole 193 Valeri Nikolov Euro proconsult Ruse 232 Christina Ruseva Razgrad Municipality 194 Stoyan Bonev Silistra , RA 233 Petya Donova IPPM 195 Svetlin Simeonov Razgrad, RA 234 Pavlina Peeva BCC Razgrad 196 Margarita Pernikova Svistov Region 235 Elena Stoyanova RIC Silistra 197 Nourie Tsrangolova Razgrad Region 236 Selvihan Yavash LAG Zavet — Kubrat 198 Orhan Bedihanov Razgrad Region 237 Anna Karadjova RIC Silistra 199 Evgeni Draganov Razgrad Region 238 Brig. Gen. Plamen Bogdanov NMU V. Tarnovo 200 Yordanka Vladimirova Silistra Municipality 239 Galina Ivanova Isperih Municipality 201 Ivelina Pencheva Ruse Region 240 Petya Komitova G. Oryahovitsa Municipality 202 Dilyana Kirova Ruse Region 241 Behidzhe Ahmedova RIC Razgrad 203 Iliana Markovska MAFF 242 Diana Bebetova-Nikolova NPA Paralel Silistra 204 Snezhana Panova ME 243 Hasim Gyuldzhan NPA LAG 205 Graciela Rankova KNSB Zavet — Kubrat 206 Emilia Peneva Ruse Municipality 244 Gabriela Stefanova RIC Ruse 207 Natalia Andreeva Translator 245 Stanka Damyanova Ruse University 208 Tsvetan Balevski OP HRD 246 Diana Avramova RIC Ruse 209 Stefan Dimitrov MAS Dve Mogili 247 Rosen Avramov NPA Zhaneta - Razgrad 210 Bozhidar Borisov Dve Mogili Municipality 248 Ertan Bahar Zavet Municipality 211 Pavlin Petrov Non-profit association 249 Theodor Rolev local business Agrobusinesscenter association Kubrat 250 Lyudmila Totseva Council of Ministers 212 Angel Maysktorski RES Podkrepa 251 Lilia Makaveeva ROMAST 213 Bayesim Rufad Rasim Isperih Municipality 252 Dimitar Karadjov NPA Durostorum 214 Sadet Karova BTA 253 Nihad Kamal Zavet Municipality 215 Dr. Dimitar Stefanov Tutrakan Municipality 216 Kamelia Radeva Ruse Municipality 254 Kamen Makaveev Intergro 217 Anna Banaschuk WB 255 Valentin Atanasov Slivo pole 218 Tsvetan Ivanov Ruse Municipality 256 Ismail Celil Vetovo Municipality 219 Fanya Todorova ES 257 Tsanko Stefanov V. Tarnovo Region 220 Dr. Valentin Vassilev Razgrad Municipality 258 Lubomira Popova V. Tarnovo, RA 221 Milen Dobrev DTIK 259 Anna Banaschuk WB 222 Gyuhay Hyusmem Razgrad Region N.A. N.A. Representatives of Ruse Industrial Zone (admin - 223 Erar Ibrahimov   istration and investors) 224 Diana Petrova Razgrad Region N.A. N.A. RDC + CEAOEF and RPC 225 Emil Gizdov Getsovo village N.A. N.A. Stakeholders not cov- 226 Ivaylo Ivanov Kubrat Municipality ered by the RDC: NGOs, businesses, citizens, 227 Stoyanka Yordanova BTB Bulgaria Corporation universities, LCCD, Regional Development 228 Emilia Germanova Non-profit association Agencies, etc. LAG Isperih Annex 4 List of Participants Strategic Consultations under Operational Programme Regions in Growth 2021 – 2027 79 # Participant’s name Organization # Participant’s name Organization SOUTH-CENTRAL REGION (AND NORTH-EAST REGION TEAM 2) 292 Ivelina Taushanova WB July, 24 2019; Targovishte, RA; Razgrad; Plovdiv; Kazanluk 293 Anna Banaschuk WB N.A. N.A. Representatives of 294 Alexandria Tsvetkova Targoviste, RA Economic Zone Trakia (administration and 295 Svetozar Stefanov Znanie I Biznes Ltd. investors) 296 Daniela Mihaylova Renstroi Ltd. N.A. N.A. Plovdiv Mayor 297 Yavor Milanov ViK Ltd. Targoviste N.A. N.A. Regional Department of DG SPPRD in South- 298 Ekaterina Hristova Targovistki novini Central Region (press) 260 Lyudmila Stoykova MRDPW 299 Denislava Atanasova RIC Targoviste 261 Mirela Georgieva MTITC 300 Angel Breninski ЕUCSI 262 Genoveva Drumeva RIC Dobrich 301 Natalia Andreeva translator 263 Rositsa Yordanova Dobrich Mun. 302 Gregor Volshchak WB 264 Tsvetomira Dontcheva MEW Shumen N.A. N.A. RDC + CEAOEF and RPC 265 Lyudmila Totseva Council of Ministers N.A. N.A. Stakeholders not cov- 266 Desislava Petkova Varna Mun. ered by the RDC: NGOs, businesses, citizens, 267 Petranka Petrova Shumen, RA universities, LCCD, Regional Development 268 Vladimir Bobev ME Agencies, etc. 269 Tsvetan Ivanov OP HRD N.A. N.A. Dobrich Mayor in Targovishte at the prem- 270 Nikolai Dyakov KNSB ises where RDC meet- ings are held 271 Krasimir Kirilov Dobrich, RA N.A. N.A. Novi Pazar Mayor 272 Dorin Dimitrov Targoviste Mun. in Targovishte at the premises where RDC 273 Maya Ivanova Varna Mun. meetings are held 274 Vladimir Minkov Varna Mun. July, 25 2019; Pazardjik, RA; Peshtera; Varna 275 Rumiana Ilieva Omurtag Mun. N.A. N.A. Pazardjik Mayor 276 Yunal Osmanov Omurtag Mun. N.A. N.A. Peshtera Mayor 277 Iliana Markovska MAFF N.A. N.A. Varna Mayor 278 Nevena Stoyanova Targoviste, RA N.A. N.A. Regional Department of DG SPPRDDG SPPRD in 279 Nikolai Nenkov Regional Directorate of North-East Region the Ministry of Interior N.A. N.A. Representatives of 280 Galina Miteva Dobrich Mun. Varna Industrial Zone (administration and 281 Miroslava Ivanova University of Economy investors) Varna July, 26 2019; Smolyan, RA; Sofia (also for Team 2) 282 Miglena Stefanova University of Economy Staneva-Todorova Varna N.A. N.A. Smolyan Mayor 283 prof. Petko Iliev Znanie I Biznes Ltd. N.A. N.A. RDC + Committee on European affairs 284 Snezhana Gecheva BCC and oversight of 285 Galina Stoyanova Mintcheva RIC Shumen the European funds (CEAOEF) and Regional 286 Yordanka Georgieva Popovo Mun. Policy Committee (RPC, National Assembly) 287 Iva Simeonova Popovo Mun. N.A. N.A. Stakeholders not cov- 288 Tsvetelina Vassileva Targoviste Mun. ered by the RDC: Stakeholders not cov- 289 Milcho Bonev RIC Targoviste ered by the RDC: NGOs, businesses, citizens, 290 Ivo Business Initiative Union universities, LCCD, Regional Development 291 Angel Business Initiative Union Agencies, etc. 80 Strategic Consultation Report # Participant’s name Organization # Participant’s name Organization N.A. N.A. Joint meeting Teams 338 Slavka Chakurova Chepelare Mun. 1 and 2 with MAs representatives 339 Miroslav Yanchev Zlatograd Mun. 303 Slaveiko Komsalov Pazardzhik Mun. 340 Rada Kuzmanova Smolyan, RA 304 Stanislava Nikolova OMTA Rodopi 341 Ivanka Mitovska ME 305 Tsvetelina Atanasova MRDPW 342 Dimitar Koverdzhanov ME 306 Bozhidar Strehin Rakovski Mun. 343 Stefan Mirev Pazardzhik, RA 307 Alexander Hinov WB 344 Zdravko Betendzhiev MRDPW 308 Chavdara Pantic Translator 345 Nicola Sanev Kardzhali, RD 309 Joanna Masic Wb 346 Peter Petrov Plovdiv, RA 310 E. Hadzhieva Podkrepa CL 347 Denitsa Nikolova   311 Milen Minchev MTITC 348 Stefan Koychev NEK EAD Dams and cascades 312 Vesselina Troeva NCRD 349 Nedyalko Slavov Smolyan, RA 313 Resmi Murad Ardino Mun. 350 Mariana Ivanova RAZ I SR Ltd. 314 Krasimira Dimitrova Asenovgrad Mun. 351 Krasimira Kiryakova Labor Office Directorate 315 Velizar Petrov Business Support Smolyan Centre for Small and Medium Enterprises 352 Nedyalka Margaritova BCC Smolyan 316 Alexander Tonkov Business Support 353 Velin Indjov Gorubso-Madan Centre for Small and 354 Iveta Petrova Regional Museum of Medium Enterprises History 317 Catherine Godieva RIEW Smolyan 355 Iveta Nikolova Association of Rhodope 318 Nicola Bolishki Panagyuriste Mun. Municipalities 356 Sonia Yosifov CIS Zagreb 319 Gerichka Milanova MLSP Sofia 357 Kostadinka Milanova RRA Smolyan 320 Nikolay Dimov Regional Directorate of the Ministry of Interior 358 Eftima Petkova Smolyan Mun. 321 Snezhana Aleksandrova Plovdiv, RA 359 Zaprinka Halacheva RFD Smolyan 322 Velika Kostadinova MRDPW 360 Victoria Terzieva Chepelare Mun. 323 Yordan Velikov ME 361 Dimitar Stanishev Contracs — Smolyan 324 Dobrina Bradarova National Union of 362 Tsvetanka Gencheva RRA Smolyan worker producers co-operatives Plovdiv 363 Tsveta Koleva Petkova Regional Museum of History 325 Dimitar Gishin AIKB 364 Tinka Belechova Regional Museum of 326 Krasimir Daskalov Devin Mun. History 327 Maria Semerdzhieva MES 365 Yana Tsirkova ViK Ltd. Smolyan 328 Denislav Kostov State Fund Agriculture 366 Elena Keykieva ViK Ltd. Smolyan 329 Katia Dimova Kardzhali, RA 367 Stoyanka Lilcheva NPA New Horizons 330 Sabina Syulnokchieva Kardzhali, RA 368 Antoaneta Nikolova NPA New Horizons 331 Ivan Frenkov MES 369 Vasco Ayvazov ARO Smolyan 332 Petya Nusheva MRDPW 370 Nadezhda Foteva-Ilieva Smolyan Mun. 333 Valentina Dimulska Harmanli Mun. 371 Radka Tunev-Yanchevska ARO Smolyan 334 Desislava Zlateva MRDWP 372 Nadezhda Hristeva Chepelare Mun. 335 Marin Zahariev Smolyan Mun. 373 Radka Kalfova Chepelare Mun. 336 Kiril Asenov CEIB Smolyan 374 Todor K. Mitov ADP Smolyan Ltd. 337 Rumen Pehlivanov Rudozem Mun. 375 Dimitar Dulguchev Mihalkovo Corp. Annex 4 List of Participants Strategic Consultations under Operational Programme Regions in Growth 2021 – 2027 81 # Participant’s name Organization 376 Kostadin Chatalbashev Open society 377 Stanislava Nikolova Fun in the mountain Association 378 Valeri Pazarev Biovet Corp. 379 Georgi Shterev Biovet Corp. 380 Rumen Rossenov Smolyan Mun. 381 Atanas Kaykov NPA Chasten Lesovad 382 Ivanka Georgieva RFD Smolyan 383 Siyka Radeva ARO Smolyan 384 Tsonka Peevska ADP Smolyan Ltd. 385 Zorica Stavreva RIC Smolyan 386 Nikolay Boyadzhiev Regional Museum of History 387 Angel Kirjakov KNSB 388 Momchil Karaivanov Smolyan, RA 389 Elitsa Chavdarova Smolyan, RA 390 Anita Kecheva RRA Rehovo 391 Tanya Vasileva Smolyan, RA 392 Luba Peeva Smolyan, RA 393 Alexandra Radkova Smolyan, RA 394 Stefka Garova Smolyan, RA 395 Milen Belchev Banite Mun.