Compilation of clarifications received from the EC for the LIPs Labgroup meeting held in Vilnius on 20-21 June 2017
A: The “acquisition of infrastructure” mentioned in the definition of LIPs provided for in the ENI CBC IRs includes not only costs of works and services related to (re)construction, renovation, installation of infrastructure and its supervision but also other activities like, for example, costs of preparation of the technical documentation and costs of supplies related to the infrastructure component, including purchase of fixed assets.
A : Retroactive costs related to studies and technical documentation for projects including an infrastructure component can also include costs for staff, travel and accommodation, office and administration, external expertise and services. However, they will be considered eligible only if they are directly related to the delivery of the said studies and documentation.
Q : In accordance with Article 48.4 of the ENI CBC Implementing Rules, costs incurred by the projects before the submission of the grant application, linked to the preparation of strong partnerships, are eligible provided that the conditions listed are met.
According to EC’s understanding, and applying mutatis mutandis the above provisions, the preparatory costs incurred by the beneficiaries for projects awarded without a call for proposals (which is the case for the majority of LIPs) shall be eligible as of the date of adoption of the programme by the Commission.
There is no link between the provisions in Article 48.4 and the entry into force of the Financing Agreements, so programmes should set no restrictions to the eligibility for preparatory costs both in MS and CBC Partner Countries (subject to their judgment and under their responsibility).
A : The 1 MEUR threshold applies to the individual infrastructure components. Therefore, in your example, only the infrastructure worth 1.5 MEUR shall be subject to Art. 43.2. However, it needs to be borne in mind that a project cannot be artificially split in order to escape the requirements.
A : The capacity building component (article 43.2.b of the ENI CBC Implementing Rules) should be understood as a soft component related to the infrastructure investment. This soft component should be considered although its nature may vary depending on the type of project.
A : Article 43.2(c) of the ENI CBC Implementing Rules defines that the feasibility study should include an independent quality review. Since in most cases the feasibility studies are outsourced (conducted by an external actor), they are “by default” considered independent.
A : There is no template for the feasibility study. The feasibility study (or its equivalent, in line with the applicable national legislation) is a document that analyses the viability of the project (including infrastructure) from the perspective on long-term feasibility, socio-economic conditions and others (for example, impact to environmental conditions). As specifically mentioned in the ENI CBC Implementing Rules, It also should include the options analysis, the results and independent quality review.
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