+ All Categories
Home > Documents > Republic of Bulgaria Ex-ante Evaluation of Operational ... Evaluation Final...DG PRD Directorate...

Republic of Bulgaria Ex-ante Evaluation of Operational ... Evaluation Final...DG PRD Directorate...

Date post: 15-May-2018
Category:
Upload: dophuc
View: 217 times
Download: 1 times
Share this document with a friend
215
Operational Program “Regional development” 2007-2013 www.bgregio.eu Investing in your future! This project is financed by the European Regional Development Fund and the state budget of Republic of Bulgaria Ex-ante Evaluation of Operational Program Regions in Growth for the 2014- 2020 programming period (Final Report with updated indicator analysis) Sofia, May 2014 г.
Transcript

Operational Program “Regional development” 2007-2013

www.bgregio.eu

Investing in your future!

This project is financed by the European Regional Development Fund and the state budget of

Republic of Bulgaria

Ex-ante Evaluation of Operational

Program Regions in Growth for the 2014-

2020 programming period

(Final Report with updated indicator analysis)

Sofia, May 2014 г.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming

period

2

Table of Contents

TABLE OF CONTENTS ..................................................................................................................................... 2

LIST OF APPLIED ACRONYMS ...................................................................................................................... 4

LIST OF FIGURES .............................................................................................................................................. 6

ABOUT THE CONSULTANT ............................................................................................................................ 8

SUMMARY ........................................................................................................................................................... 9

I. INTRODUCTION TO THE EVALUATION ......................................................................................... 16

1. OBJECTIVES OF THE EVALUATION ........................................................................................................... 16 2. TEAM MEMBERS AND EVALUATION DEADLINES ...................................................................................... 17

II. ACTIVITIES IMPLEMENTED WITHIN STAGES 1- 4.......................................................................... 18

1. STAGE 1 – INTRODUCTORY PHASE STAGE 1 ............................................................................................ 18 2. STAGE 2 – DRAWING UP DRAFT VERSION OF EX-ANTE EVALUATION OF OPRG 2014-2020 AND STAGE 3 –

DRAWING UP AND SUBMISSION OF FINAL VERSION OF EX-ANTE EVALUATION OF OPRG 2014-2020 ................ 19 3. STAGE 4 - DRAWING UP AND SUBMISSION OF FINAL VERSION OF EX-ANTE EVALUATION OF OPRG 2014-

2020 32 4. CHALLENGES IN IMPLEMENTING THE EVALUATION ................................................................................. 32

III. EVALUATION 1 – ASSESSMENT OF THE EXTERNAL CONSISTENCY OF THE PROGRAM . 33

1. DATA COLLECTION .................................................................................................................................. 33 2. ANALYSIS ............................................................................................................................................... 34

IV. EVALUATION 2 – ASSESSMENT OF THE INTERNAL CONSISTENCY OF THE PROGRAM .. 75

1. DATA COLLECTION .................................................................................................................................. 75 2. ANALYSIS ............................................................................................................................................... 75

V. EVALUATION 3 - ASSESSMENT OF THE HORIZONTAL PRINCIPLES AND OBJECTIVES,

INCLUDED IN THE OPERATIONAL PROGRAM.................................................................................... 105

1. DATA COLLECTION ................................................................................................................................ 105 2. ANALYSIS ............................................................................................................................................. 105

VI. EVALUATION 4 – ASSESSMENT OF THE INDICATOR SYSTEM ................................................ 108

1. DATA COLLECTION ................................................................................................................................ 108 2. ANALYSIS ............................................................................................................................................. 108

VII. EVALUATION 5 – ASSESSMENT OF THE PROGRAM’S BUDGET ............................................. 132

1. DATA COLLECTION ................................................................................................................................ 132 2. ANALYSIS ............................................................................................................................................. 133

VIII. EVALUATION 6 – ASSESSMENT OF THE MANAGEMENT AND MONITORING SYSTEMS

AND ADMINISTRATIVE CAPACITY FOR IMPLEMENTATION OF THE PROGRAM ................... 158

1. DATA COLLECTION ................................................................................................................................ 158 2. ANALYSIS ............................................................................................................................................. 159

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming

period

3

IX. EVALUATION 7 – ASSESSMENT OF THE VALIDITY, RELEVANCE, CONSISTENCY,

APPLICABILITY AND REFLECTION OF THE RESULTS OF THE OPRG 2014-200

ENVIRONMENTAL ASSESSMENT............................................................................................................. 170

X.CONCLUSIONS AND RECOMMENDATIONS ...................................................................................... 179

1. CONCLUSIONS ....................................................................................................................................... 179 2. RECOMMENDATIONS ............................................................................................................................. 184 3. FOLLOW-UP OF THE CONSULTANT’S RECOMMENDATIONS .................................................................... 195

ANNEXES ......................................................................................................................................................... 203

1. LIST OF KEY CONSULTED DOCUMENTS .................................................................................................. 203 2. LIST OF PARTICIPANTS FROM THE FOCUS GROUPS IN THE EVALUATION ................................................. 205 3. RESULTS OF THE ONLINE QUESTIONNAIRES ........................................................................................... 215 4. INDICATOR FICHES ................................................................................................................................ 215

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

4

List of Applied Acronyms

CA Conformity Assessment

CCP Climate Change Policy

CCU Central Coordination Unit

CEACEF Committee for European Affairs and Control over the European Funds

CF Cohesion Fund

CM Council of Ministers

CSF Common Strategic Framework

DCM Decree of the Council of Ministers

DG PRD Directorate General Programming of Regional Development

EAFRD European Agricultural Fund for Rural Development

ECIF European Cohesion and Investment Funds

EE Energy Efficiency

EIA Environmental Impact Assessment

EIB European Investment Bank

EMFF European Maritime and Fisheries Fund

EP Environmental Policy

ERDF European Regional Development Fund

ESEE Ecorys South East Europe Ltd.

ESIF European Structural and Investment Funds

EU European Union

FHR Fund for Housing Renovation

IAWP Indicative Annual Work Program

ICT Information and Communication Technologies

IP Investment Priority

IUPRD Integrated Urban Plan for Regeneration and Development

MA Managing Authority

MAFP Maritime Affairs and Fisheries Programme

MC Monitoring Committee

MEE Ministry of Economy and Energy

MH Ministry of Health

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

5

MLSP Ministry of Labour and Social Policy

MRD Ministry of Regional Development

MRDPW Ministry of Regional Development and Public Works

NDP B2020 National Development Program Bulgaria 2020

NGOs Non-governmental Organizations

NKE Non-key Expert

NRDS National Regional Development Strategy

NRP National Reform Program

NSDC National Spatial Development Concept

NSI National Statistical Institute

NSRF National Strategic Reference Framework

NT National Target

OP Operational Programme

OPDCBE Operational Program Development of Competitiveness of the Bulgarian

Economy

OPE Operational Programme Environment

OPGG Operational Programme Good Governance

OPHRD Operational Programme for Human Resources Development

OPIC Operational Programme Innovations and Competitiveness

OPRD/

OPRG

Operational Program Regional Development/ Operational Program

Regions in Growth

OPSESG Operational Programme Science and Education for Smart Growth

OPTTI Operational Programme Transport and Transport Infrastructure

PA Partnership Agreement

PA Priority Axis

PPA Public Procurement Act

PPP Public-Private Partnership

R&D Research and Development

RDA Regional Development Act

RDP Rural Development Programme

RES Renewable Energy Sources

RIA Road Infrastructure Agency

SCF Structural Funds and Cohesion Fund of EU

SME Small and Мedium Еnterprise

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

6

SO Specific Objective

SP Sub-priority

SR Specific Recommendation

SWOT Strengths, Weaknesses, Opportunities, Threats

TEN-T Trans-Еuropean Transport Network Infrastructures

TL Team Leader

TO Technical Offer

TWG Thematic Working Group

UMIS Unified Management Information System

WD Working Document

ЕC European Commission

ЕЕ Energy Efficiency

КЕ Key Expert

ТO Thematic Objective

ТS Technical Specification

List of Figures

Figure 1: Evaluation approach .............................................................................................................. 20

Figure 2: Relation between OPRG and OPE ........................................................................................ 60

Figure 3: Relation between OPRG and OPIC ....................................................................................... 62

Figure 4: Relation between OPRG and OPHRD .................................................................................. 65

Figure 5: Relation between OPRG and OPTTI..................................................................................... 67

Figure 6: Relation between OPRG and OP SESG ................................................................................ 69

Figure 7: Relation between OPRG and OPGG ..................................................................................... 71

Figure 8: Relation between OPRG and RDP ........................................................................................ 73

Figure 9: Relation between OPRG and PMAF ..................................................................................... 74

Figure 10: Logic of PA1, IP1, SO1 ....................................................................................................... 78

Figure 11: Logic of PA1, IP2, SO1 ....................................................................................................... 81

Figure 12: Logic of PA1, IP2, SO2 ....................................................................................................... 83

Figure 13: Logic of PA1, IP3, SO1 ....................................................................................................... 85

Figure 14: Logic of PA1, IP4, SO1 ....................................................................................................... 87

Figure 15: Logic of PA1, IP5, SO1 ....................................................................................................... 90

Figure 16: Logic of PA2, IP1, SO1 ....................................................................................................... 92

Figure 17: Logic of PA3, IP1, SO1 ....................................................................................................... 94

Figure 18: Logic of PA4, IP1, SO1 ....................................................................................................... 96

Figure 19: Logic of PA5, IP1, SO1 and SO2 ........................................................................................ 98

Figure 20: Logic of PA6, IP1, SO1 ..................................................................................................... 100

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

7

Figure 21: Logic of PA7, IP1, SO1 ..................................................................................................... 102

Figure 22: Logic of PA8 ..................................................................................................................... 104

Figure 23: Questionnaire – applicable horizontal principles .............................................................. 107

Figure 24: Online questionnaire – difficulties of indicators ............................................................... 130

Figure 25: Mechanism for defining the type of financing .................................................................. 140

Figure 26: Financing as per thematic objectives ................................................................................. 145

Figure 27: Questionnaire - needs of beneficiaries in relation to the preparation and management of

projects under OPRG 2014-2020 ........................................................................................................ 161

Figure 28: Questionnaire – areas, where the administrative capacity needs to be improved.............. 162

Figure 29: Questionnaire–areas where administrative capacity should be improved ......................... 163

Figure 30: Questionnaire – necessity of intermediate units ................................................................ 164

Figure 31: Management structure of OPRG - results of the online questionnaire conducted in June

2013 .................................................................................................................................................... 165

Figure 32: Appropriateness of delegation the verification processes on regional departments - results

of the online questionnaire conducted in June 2013 ........................................................................... 165

Figure 33: Assessment of adequacy of procedures - results of online questionnaire conducted in June

2013 .................................................................................................................................................... 166

Figure 34: Sufficiency of human resources in MA - answers to the online questionnaire by June 2013

............................................................................................................................................................ 167

Figure 35: Questionnaire – type of experts needed in MA ................................................................. 169

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

8

About the Consultant

ECORYS South East Europe Ltd. (Ecorys SEE) – is a legal entity registered in Bulgaria in

August 2006. The company is part of the European group of consulting and research

organizations – ECORYS Group, with offices in 10 countries in Europe, and representation

offices in Ukraine, Macedonia, and Serbia. The mission of Ecorys SEE is to provide the full

set of services offered by ECORYS Group in this region. ECORYS has established itself as

one of the most powerful European companies with its innovative, flexible, and integrated

multifaceted solutions and approaches, always and fully conformable to the needs of the

clients as well as to the specificity of the market.

By offering its consulting services to the Bulgarian market Ecorys SEE has gained significant

experience in the implementation of projects in the fields of: monitoring and evaluation,

regional development, transport, environment, human resources, etc.

1, Cherni Vrah Blvd.

1421 Sofia

Bulgaria

Phone: 02 815 56 80

Fax: 02 981 60 32

E-mail: [email protected]

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

9

Summary

This ex-ante evaluation was performed as a part of the mandatory activities of the

programming process of Operational Programme for Regional Development (OPRD) 2014-

2020. Following the ToR and contract requirements, the ex-ante evaluation was performed

during the period June 2012-September 2013.

It should be borne in mind that OPRG 2014-2020 is the first OP whose design undergoes the

approval process by the EC. Despite the accelerated pace at which OPRG 2014-2020 is

developed, in the framework of an ongoing process to develop the Partnership agreement and

uncertainties regarding the budgetary allocations for the next programming period, the

Contractor showed flexibility in reflecting the recommendations of this evaluation, including

on significant issues such as the extension of the scope of the energy efficiency measures

under Priority axis 1. In line with the best practices, the ex-ante evaluation was of "interactive

and iterative" nature, which was manifested in constant contact with the Client and

stakeholders and multiple updates of the evaluation reports, following changes in the text of

the OPRG 2014-2020,

In the evaluation were used both qualitative and quantitative methods, including:

Online questionnaire to beneficiaries, the Managing authority (MA) and participants

in the Thematic working groups (TWG) for development of OPRG

Online questionnaire to the MA with the objective of collecting information for the

administrative capacity

Interviews with experts of the MA, the Central coordination unit, members of the

TWG

2 focus groups with representatives of the TWG

2 focus groups with representatives of the beneficiaries

Stakeholder analysis

Analysis of the intervention logic

Analysis of the causal links

Objectives trees of main strategic documents – visualization

Objectives tree of OPRG – visualization

Quantified SWOT analysis

Analysis of the indicator system (SMART)

Benchmarking of target values of the indicators between programming period 2007-

2013 and 2014-2020

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

10

Indicator fiches

Workload analysis

Review of the environmental assessment of OPRG 2014-2020

The analyses and results of the ex-ante evaluation are structured following the seven groups

of evaluation questions:

External coherence evaluation (Evaluation 1);

Internal coherence evaluation (Evaluation 2);

Horizontal principles evaluation (Evaluation 3);

Evaluation of the system of indicators (Evaluation 4).

Evaluation of the budget of the programme (Evaluation 5)

Evaluation of the management and control systems and the administrative capacity for

implementation of the programme (Evaluation 6)

Evaluation of the validity, relevance, coherence, applicability, and inclusion in the

OPRD 2014-2020 of the results of the environmental assessment (Evaluation 7)

The main conclusions and recommendations are presented below along the above structure:

Evaluation 1: External coherence evaluation

The objectives and priorities of the OPRG 2014-2020 are coherent with the European and

National strategic documents and follow the National and European framework.

Albeit to varying degrees, OPRG 2014-2020 is also related to the three pillars of the Europe

2020 strategy - smart, sustainable and inclusive growth. OPRG 2014-2020 is expected to

have an impact on four of the seven flagship initiatives to catalyze progress under each

priority theme.

Energy efficiency and renewable energy sources and sustainable urban development are

expected to be among the main initiatives at European level during the programming period

2014-2020 expected. OPRG 2014-2020 meets this focus and is consistent with the common

understanding of the concentration of EU funds in order to achieve concrete results. Out of

the proposed total of 11 thematic objectives 6 are selected for OPRG. In spite of this large

range, the selection does not violate the principle of concentration of resources. The strategy,

set out in the OPRG, also fits into the priorities of the Territorial Agenda 2020 of the

European Union.

Reduction of the description of the compliance with national documents would improve the

text of the program. Description of the relevant ex-ante conditionalities should continue to be

updated in line with the progress of the preparation of the Partnership Agreement.

The report identifies opportunities to improve the description of the demarcation and

complementarity between OPRG 2014-2020, and the other programs co-financed by the EU.

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

11

It should be noted, however, that the demarcation and complementarity between the programs

has not yet been clarified at the national level, which is related with the progress of the

Partnership Agreement.

The intention to use financial instruments partially, or fully to finance investments in sports

infrastructure, energy efficiency in buildings, cultural facilities, and areas with potential for

economic development, urban and integrated public transport is in coherence with the

policies promoted by the EC with respect to financial instruments. Experience in the

implementation of financial instruments, however, is still relatively small. For this reason it is

recommended with respect to the financial instruments to provide an assessment of the

financial instruments in the current programming period. It is recommended to perform it

before the start of the OPRD 2014-2020, but if this is not possible - to include it in the ToR of

the evaluation of the financial instruments, which is required by the Regulations.

Evaluation 2: Internal coherence evaluation

The current version of the OPRG 2014-2020, contains a number of improvements to the

internal coherence of the program. The OPRG strategy and the relationship between thematic

objectives / investment priorities, specific objectives envisaged activities and needs are

explained in greater detail as compared to previous versions of the program.

The report provides an overview of the links between: needs and envisaged activities;

envisaged activities and specific objective; specific objective and investment priorities /

thematic objective; and output/result indicators and envisaged activities. The conclusion of

the analysis is that after the changes in the programme the link between these elements is

strong enough.

Evaluation 3: Horizontal principles evaluation

OPRG 2014-2020 describes the application of the principles of sustainable development,

equal opportunities and non-discrimination and equality between men and women.

The description of the principles of equal opportunities and non-discrimination is short, but

adequate and covers the main requirements for this element of the operational program. The

description of the principle of equality between men and women is more general.

Evaluation 4: Evaluation of the system of indicators

The indicator system of OPRG includes the relevant common output indicators listed in

Regulation 1301/2013. As a whole, it may be concluded that all output indicators are relevant

to the activities and provide good measurement for their direct products.

As regards result indicators, it should be taken into account that one of the main specificities

of the OPRG is that it is an infrastructure programme. Hence the meaningful results, e.g. in

the health, social, and education spheres, will be achieved only through accompanying soft

measures and national/regional policies. The evaluation provides comments for each result

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

12

indicator that illustrate the difficulties in identifying indicators, which have as direct as

possible influence on effects that extend beyond the supported entities.

In some cases the baselines and the target values of the result indicators are not in the same

measurement unit, e.g. the baseline is in absolute numbers, whereas the target value is in

percentage. This is due to the fact that the result indicators are formulated in line with the

expected positive outcomes, e.g. “increase of”. Thus, it is recommended to reformulate the

indicators and delete “increase / decrease” in the formulation.

The programmers have developed a methodology for estimation of the baselines and the

target values, which is very helpful and increases the transparency of the calculation methods.

For most indicators there are still some issues (e.g. related to the data used), commented in

the analysis, that need to be clarified in the fiches.

The system of indicators is aiming at using as much as possible official National Statistics

Institute (NSI) data, which is beneficial in terms of methodological clarity and transparency.

In some cases the latest available data from the NSI was not used, so it is recommended to re-

calculate some baselines and unit costs. In two cases there is a discrepancy between the

formulation of the NSI indicator and the OPRG indicator: “Increase of the net annual

revenues from international tourism” and “Increased passenger and freight flow”.

Calculating unit costs is a very useful approach for the definition of target values. Overall this

is the approach followed in the indicator fiches of the OPRG.

On the basis of the above analysis of the indicators, the evaluators recommend review of the

following result indicators:

Reduction of final energy consumption from public administration, commerce and

services

Increase of the net annual revenues from international tourism

Increased passenger and freight flow

Evaluation 5: Evaluation of the budget of the programme

The breakdown of the budget of the program as a whole takes into account the identified

investment priorities and requirements contained in the main national and European strategic

documents, and considers the experience with the current programming period and the risks

of non-compliance of certain thematic ex-ante conditionalities. The financial justification of

the budget of OPRG 2014-2020, provides well-synthesized motivation for the selected

priorities and their weight. The justification meets all the requirements for its elaboration, set

in the guidelines for the development of operational programs for the next programming

period.

In terms of the priorities that will be implemented with the use of financial instruments, the

evaluation concludes that they are correctly identified, but no justification is provided for the

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

13

correlation between grants and financial instruments into the OPRG 2014-2020. In relation to

financial instruments, it should be considered that the Form for the development of

operational programs for the next programming period provides that it is not required to

perform a preliminary evaluation of financial instruments at the time of submission of the

operational program and that it could be undertaken at a later stage after specifying the details

of the use of financial instruments.

As concerns the European regulations, OPRG 2014-2020 provides adequate financial

consideration of the thematic objectives that should be financed primarily with funds from

the ERDF and that are relevant to regional development. This applies mostly to TO 4

"Transition to a low carbon economy."

Significant funding is ensured for integrated actions for sustainable urban development,

which are likely to significantly exceed the 5% national minimum envisaged in the European

framework and also for support of the implementation of TO 9 and 10. The 5% threshold

should not be actively limited in the case of Bulgaria, given the high potential contribution of

this type of investment to achieve higher growth and employment if the investment is focused

on activities with a direct impact on regional economic activity.

In terms of compliance with the formal requirements of the financial plan of the program set

out in the Form of an operational program for the next programming period, the programme

already includes preliminary versions of all required tables (Tables 17-19).

In terms of the currently available national strategic documents (Partnership Agreement

2014-2020, National Strategy for Regional development and National Development

Programme 2020), which have or will have estimates in terms of funding, the programme is

generally coherent with the investment allocations by priorities. Direct comparison of these

documents, however, is virtually impossible, given the long planning horizon in these

documents and the wider range of funding sources.

Evaluation 6: Evaluation of the management and control systems and the administrative

capacity for implementation of the programme

As a part of the implementation of the ex-ante evaluation of the management and control

systems the team of evaluators reviewed the summary action plan for strengthening the

administrative capacity of 36 municipalities - OPRD beneficiaries (version December 2012)

and the Summary Action Plan for improvement of the administrative capacity of the direct

beneficiaries of the OPRD (version December 2012). Both documents contain

recommendations regarding the administrative capacity, which are relevant for the next

programming period.

The need for trainings of the beneficiaries, identified in the above analyses, was confirmed by

the online survey, conducted during the ex-ante evaluation. According to the results of the

study more than 70% of the respondents believe that training in the next programming period

will be necessary. According to the respondents, a key area in which there is a need for

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

14

training is project management, followed by training on reporting and monitoring

performance.

Based on the conducted desk research and focus groups as critical factors in the

implementation of OPRD may be accounted for beneficiaries' capacity for tendering and

implementation of quality inspection of construction supervision. It is recommended that the

text of the OPRG 2014-2020 specifically focuses on the need for training on cross-cutting

themes such as Public Procurement Act and implementation of construction supervision, but

it should be borne in mind that this is a horizontal need that has to be addressed by

Operational programme “Good Governance”.

It can be concluded that the needs of the beneficiaries (the enhancement of competences,

motivation and remuneration, as well as providing the necessary equipment), which are

specified in OPRG, are correct.

The results of the questionnaire and the discussions in the focus groups confirmed the opinion

that establishing intermediate bodies would create more structural and functional difficulties

and obstacles, rather than improvements.

The evaluation of the administrative capacity of the MA shows the need to further clarify the

division of responsibilities between the MA central and regional departments. The most

problematic are the mechanisms for collecting information on the indicators of the program

and the collection of data needed to perform evaluations. Given the even greater importance

that the European Commission pays to indicators and evaluations in the next programming

period, it is necessary for these procedures to be reviewed by the MA of OPRG 2014-2020.

As a whole the human resources for management and implementation of OPRG 2014-2020

are adequate, but additional experts with technical (engineer) knowledge and expertise in

monitoring are needed.

Given the great importance given by the EC to indicators and evaluations during the 2014-

2020 period, in the development of the MA Manual and Guidelines for beneficiaries in the

next programming period it is necessary to review the procedures for gathering information

on Programme indicators and collection of data necessary to conduct evaluations.

Evaluation 7: Evaluation of the validity, relevance, coherence, applicability, and inclusion

in the OPRD 2014-2020 of the results of the environmental assessment

According to the environmental assessment of the OPRG 2014-2020, at the level of priorities

and sub-priorities, the program's impact on the environment and human health as a whole has

a complex positive character. At the level of specific eligible activities, the impact is also

assessed positively as minor adverse effects are expected in the period of construction during

the respective activities.

Only some of the recommendations of the environmental assessment should be reflected in

the text of the OP. Implementing other recommendations should be performed in the

contracting process and the provision of grants, or in the process of implementation. A third

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

15

group of recommendations does not require actions in the programming and implementation,

as compliance is legally defined.

The environmental assessment includes the following recommendation: "Indicators for

monitoring and control of environmental impacts should be integrated in the system of

indicators of OPRG 2014-2020." However, in view of the recommendations of the

Commission for a limited number of indicators that measure the desired effects and

correspond to the size of the budget, which is designated for the individual measures, it is not

appropriate to include in the OPRG 2014-2020 system all of the indicators proposed in the

table provided in the environmental assessment. These indicators should be used in the

monitoring and control of environmental impacts during implementation of the program (e.g.,

in the reports with evaluation of the impact of the OPRG on the environment).

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

16

I. Introduction to the evaluation

1. Objectives of the evaluation

The objectives of the contract indicated in the Contracting Authority’s technical specification

are as follows:

General

objective

Ex-ante evaluation of Operational Program for Regional Development

(OPRG) in the 2014-2020 programming period.

Specific

objectives

To ensure result-driven, well-structured programming document

aimed at overcoming the needs and turning to account the

potentialities for development of the Bulgarian regions.

To guarantee the external consistency of the developed operational

program, and the interventions established therein, with the

documents of importance for the preparation of the programming

document at both national and European level, including the

contribution to the Strategy for smart, sustainable, and inclusive

growth.

To guarantee the correct implementation of the horizontal principles

of the European Union in the fields of equal opportunities, equal

access, non-discrimination, sustainable development, etc.

To guarantee the internal consistency of the Program, the relevance

and the clarity of the proposed indicators and the feasibility of the

quantified target values for the indicators.

To integrate the environmental issues in the preparation of the

Operational Program for Regional Development 2014-2020 and

ensure a higher level of environmental protection and achievement of

sustainable development in Bulgaria.

The evaluation has been implemented as a part of the mandatory OPRG programming

activities and its objectives comply with the requirements of the regulations specifying the

rules for management and spending of the EU funds.

Ex-ante Evaluation of Operational Program Regions in Growth for the 2014-2020 programming

period

17

2. Team members and evaluation deadlines

The following experts took part in the implementation of the evaluation:

Team leader: Mathias Hague

Key expert 1: Ralitsa Simeonova – Ganeva

Key expert 2: Iglika Vassileva

Key expert 3: Tsvetana Naniova

Project Manager: Mariana Stefanova

Evaluation Coordinator: Daniel Nigohosyan

Non-key experts have also been involved in the evaluation, contributing mainly to the

collection of input data for analyses purposes and to specific components of the evaluation.

During the project implementation, the Consultant and the Contracting Authority have shown

flexibility in implementing the project activities while at the same time the essential

evaluation deadlines specified in the table below were met:

Stage Deadline

Stage 1: Introductory phase Not later than 1 month after conclusion of the

contract with the Contracting Authority -

Implemented

Stage 2: Drawing up a preliminary version

of Ex-ante evaluation of OPRG 2014-2020

Not later than 6 months after conclusion of the

contract with the Contractor

Stage 3: Drawing up and submission of a

draft final version of Ex-ante evaluation of

OPRG 2014-2020

Not later than 8 months after conclusion of the

contract with the Contractor

Stage 4: Drawing up and submission of a

final version of Ex-ante evaluation of

OPRG 2014-2020

Not later than 20 working days prior to the

submission of the OPRG 2014-2020 final version to

the European Commission

Last date for submission of the final report containing

a final version of the Ex-ante evaluation – 27.06.2013

Ex-ante Evaluation of Operational Program for Regional Development for the 2014-2020

programming period

18

II. Activities implemented within Stages 1- 4

1. Stage 1 – Introductory phase Stage 1

EVALSED recommends that program evaluations funded by SCF start with an analysis of

evaluability assessment. Accordingly, this evaluation has started with analysis of the

possibilities for evaluation of the OPRG 2014-2020.

This activity included the following elements:

- Meeting of the key experts team (held on 08.06.2012), during which each key expert

presented his initial views on the evaluation approach on the basis of his experience with

evaluation of programs co-financed by the EU, “good practices” and “bad examples” of

evaluations. The meeting concentrated on key European/national documents which

would be necessary for the implementation of the evaluation, and in particular, for the

assessment of internal consistency. Also, the role of each team member was clarified

during the meeting.

- Kick-off meeting (held on 14.06.2012) of team representatives and Contracting

Authority’s representatives with the following objectives:

Discussion of Contracting Authority’s expectations about the evaluation – key

evaluation issues, provision of guidelines on the main areas on which the

Contractor should focus his efforts, data sources, etc.;

“Inventory” of the existing documents relevant to the evaluation;

Schedule of evaluation-related projects;

Context of the evaluation.

During the kick-off meeting the following persons were appointed project coordinators (key

contact persons):

For the

Contracting

Authority :

Mr. Ivan Popov – Head of “Programming and Evaluation” Unit

Directorate General " Regional Development Programming "

e-mail: [email protected]

Tel.: 02 9405 662

Ex-ante Evaluation of Operational Program for Regional Development for the 2014-2020

programming period

19

For the

Contractor:

Mr. Daniel Nigohosyan – Senior Consultant

Ecorys South East Europe

e-mail: [email protected]

Tel.: 02 8155 683

As a result of the kick-off meetings the expert team has upgraded the general methodology

and working plan. The evaluation approach has been finally determined in the framework of

this activity on the basis of:

Re-examination of the context for implementation of the evaluation – European

regulations and guidelines related to the implementation of evaluations, national legal

acts, related projects and national strategies/analyses;

Updates of the project schedule and evaluation implementation sequence.

The main outputs and results of the Introductory Phase (Stage 1) are presented in the table

below:

Outputs Implementation

Analysis of evaluability assessment according to the evaluation issues √

Updated general methodology and working plan √

Key experts team meeting √

Kick-off meeting between the Contracting Authority and the Contractor √

Results Implementation

Approved Inception Report √

Collection of information sources and data needed for the evaluation √

Clear communication channels (contact persons) √

2. Stage 2 – Drawing up draft version of Ex-ante

evaluation of OPRG 2014-2020 and Stage 3 – Drawing

up and submission of final version of Ex-ante evaluation

of OPRG 2014-2020

Our overall strategy and conception for performing Stages 2 and 3 of the Ex-ante evaluation

are outlined in Figure 1.

Ex-ante Evaluation of Operational Program for Regional Development for the 2014-2020

programming period

20

external

consistency

European Strategic

Framework

National Strategic

Framework

European legal

framework

Other operational

programs

Other regional

programs/

interventions

OPRD 2007-2013

Past experience and

learnt lessons

Environmental

assessment report

internal

consistency

OPRD 2014-2020

Assessment of management

and control systems and

administrative capacity

Assessment of Program’s

budget

Assessment of

horizontal

principles

Assessment of

indicators

Other sectoral

programs

Stakeholders

Expert team

Needs of regions and

territories

expertise,

methods and

evaluation tools

National legal

framework

Figure 1: Evaluation approach

As the figure shows, the Consultant aimed to cover all elements of the evaluation by

including all stakeholders and using various quantitative and qualitative evaluation methods

according to the needs and the specificity of the issues evaluated.

The table below presents briefly the evaluation issues, core evaluation criteria, methodology,

documentary sources, and relation to other issues/stages. The sub-strands complementing the

requirements of the Technical specification are added in italics.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

21

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

1) Assessment of the external

consistency of the Program

Consistency with the general and

specific preconditions set by the

European Commission regarding the

Operational Program

Contribution to the EU Strategy for

smart, sustainable and inclusive

growth

Consistency with the National

Reform Program

Consistency of the selected thematic

objectives, priorities and relevant

program objectives with the

Common Strategic Framework, the

Partnership Agreement and the

country-specific recommendations

in accordance with Art. 121 (2) of

the Treaty and the Council

recommendations adopted under

Art. 148 (4) of the Treaty

Relevance

(external

consistency)

OPRG 2014-2020

EU Strategy for

smart, sustainable

and inclusive growth

National Reform

Program

Partnership

Agreement

Integrated

Guidelines Europe

2020

Other OP

NDP Bulgaria 2020

National Regional

Development

Strategy

Regional

Development Plans

Council of Ministers

Desk research

Strategic documents

data encoding

Interviews with

experts of DG RDP

Interviews with

expert/s of the EC

Interviews with

experts of the CCU

Online questionnaire

targeted аt

municipalities,

district

administrations,

specific beneficiaries

and present OPRG

beneficiaries

Participation in

working group

sessions to prepare

Analysis of

stakeholders

Tree of the

objectives of the

main strategic

documents -

visualization

Tree of OPRG

objectives -

visualization

Expert analysis

Conformity

analysis

2

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

22

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

Consistency and coordination with

the other Operational Programs

included in the Partnership

Agreement

Consistency with other program and

strategic documents – National

Development Program: Bulgaria

2020, National Regional

Development Strategy, Regional

Development Plans, National

Spatial Development Concept

Consistency with the national and

European legal framework

Meeting the needs of the regions

and territories in Bulgaria

Web Portal for

Public consultations

National Spatial

Development

Concept

Guidelines and

recommendations of

the EC concerning

the Program

EU Regulations on

SCF for the 2014-

2020 period

National legislation

European legislation

OPRG 2014-2020

Focus group with

representatives of the

working Group

2) Assessment of the internal

consistency of the Program

Internal consistency of the proposed

program or activity and how it

Relevance

(internal

consistency

and

coherence)

OPRG 2014-2020

OPRD 2007-2013

Ex-ante evaluation

Online questionnaire

Desk research

Interviews with

Analysis of the

intervention logic

Causal analysis

Quantitative

All issues

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

23

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

relates to other important instrument

Relevance of the OPRG strategy

including the following analytical

components:

Analysis of previous evaluation

results - Lessons learnt from the

implementation of OPRD 2007-

2013

Scope and focus of the socio-

economic analysis of OPRG

Validity of strengths and

weaknesses analysis and

development potential, compliance

with the socio-economic analysis

findings, the internal and external

background

Adequacy of the proposed vision,

objectives and priorities and

thematic areas to the findings of the

socio-economic analysis and SWOT

and

estimated

impact and

sustainabilit

y

of OPRD 2007-2013

Review of the first

schemes opened

under OPRD 2007-

2013

Mid-term evaluation

of OPRD 2007-2013

Annual

Implementation

Reports of OPRD

2007-2013

Action Plans to

strengthen the

administrative

capacity of OPRG

beneficiaries

Results of the

analyses of

beneficiaries’

capacity

experts of DG RDP

Interviews with

experts of the CCU

Participation in

working group

sessions for

preparation of OPRG

2014-2020

Focus group with

beneficiaries

Focus group with

representatives of the

working group

Participation in

working group

sessions

Participation in

working group

sessions

Participation n

working group

SWOT analysis

Descriptive

statistics methods

Expert analysis

Expert panel

Analysis of good

practices in EU

Member States

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

24

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

analysis

Integration and coordination

between particular priorities as well

as in regard to thematic objectives

Analysis of beneficiaries’ capacity

Grounds for the proposed form of

support

Contribution of the expected

specific results to the general results

National Statistical

Institute

Eurostat

Surveys of UN,

World Bank,

Organization for

Economic

Cooperation and

Development

Socio-economic

analyses of the EC

sessions

3) Assessment of the horizontal

principles and objectives included

in the Operational Program,

Adequacy of horizontal

principles definition in the

Operational Program

Adequacy of the reflection of

horizontal principles in the

established mechanisms for

Relevance

(internal

consistency)

Future

efficiency

OPRD 2007-2013

OPRG 2014-2020

Environmental

assessment of

OPRG 2014-2020

National documents

defining the relevant

horizontal policies –

e.g. NRP Bulgaria

Desk research

Online questionnaire

Focus group with

beneficiaries

Focus group with

representatives of the

working group

Participation in

Analysis of the

intervention logic

Expert analysis

Expert panel

Analysis of good

practices in EU

Member States

2 and 4

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

25

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

programming, management

and implementation of the

Operational Program

Adequacy of the planned

measures to promote equal

opportunities between men

and women and prevent

discrimination

Adequacy of the planned

measures to promote

sustainable development

Climate changes

2020

European

documents defining

the horizontal

policies – e.g.

Europe 2020

EU Regulations

concerning SCF for

the 2014-2020

period

Previous evaluations

and reports dealing

with horizontal

issues

working group

sessions

4) Assessment of the system of

indicators

Relevance and clarity of the

proposed program indicators

Existence of instructions for

calculation and use of

Relevance

(internal

consistency)

OPRG 2014-2020

OPRD 2007-2013

Evaluations of

OPRD 2007-2013

UMIS data on

Desk research

Online questionnaire

Interviews with

experts of DG RDP,

including experts in

the field of OPRG

Analysis of

indicator system

and monitoring

system (SMART)

Development of

indicator fiches

2, 3 and 5

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

26

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

indicators

Scope of the proposed

indicators

Quality of the proposed

indicators

Integration of indicators

between the different levels

Relevance of the calculated

baseline values of indicators

Are the quantified target

values for indicators realistic

regarding the support

provided for by the CSF

Funds

physical progress

Methodology for

calculation of

indicators (if

available)

National Statistical

Institute

Eurostat

Surveys of UN,

World Bank,

Organisation for

Economic

Cooperation and

Development

Socio-economic

analysis of the EC

2007-2013

monitoring

Interviews with

members of the

working group

preparing OPRG

2014-2020 -

representatives of the

socio-economic

partners, regional

and local authorities,

institutions

Focus groups with

beneficiaries

Participation in the

working group

sessions

Expert panel

Expert analysis

Analysis of good

practices in EU

Member States

5) Assessment of the Program’s

budget

Consistency and validity of

budget resources allocation

Relevance

(internal

OPRG 2014-2020

OPRD 2007-2013

Evaluations of

Desk research

Review of data

collected within the

frameworks of

Descriptive

statistics methods

Benchmarking

4

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

27

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

in relation to the program

objectives

Consistency and validity of

budget resources allocation

in relation to the

requirements of the

regulations (integrated

approach, focused

interventions, financial

engineering, etc.)

consistency)

Future

efficiency

OPRD 2007-2013

UMIS financial data

EU financial

regulations

Evaluations 2 and 4

Interviews with

experts of DG

“RDP”, including

experts involved in

the financial

management of

OPRD 2007-2013

Focus group with

beneficiaries

Focus group with

representatives of the

working group

Participation in the

working group

sessions

Analysis of good

practices in EU

Member States

6) Assessment of the management

and control systems and

administrative capacity for

implementing the Program

Relevance

(internal

consistency)

Future

OPRG 2014-2020

OPRD 2007-2013

Procedure Manual

for implementation

Desk research

Online questionnaire

targeted at the

beneficiaries

Workload analysis

Administrative

capacity analysis

Expert analysis of

-

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

28

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

Adequacy of human

resources and administrative

capacity for management of

the Program

Adequacy of the

management structure

Capacity of the beneficiaries

of the program and the

measures provided for its

strengthening

Suitability of the milestones

chosen for the performance

framework

Suitability of the procedures

for monitoring of the

Program and collecting the

data necessary to carry out

evaluations

Suitability of financial

management mechanisms

effectivenes

s and

efficiency

of OPRD 2007-2013

Evaluations of

OPRD 2007-2013

Action plans for

strengthening the

administrative

capacity of the

OPRG beneficiaries

Rules of procedure

and other

administrative

documents

Analysis of MA and

beneficiaries

training needs (if

available)

EU Regulations

concerning SCF for

the 2014-2020

period

Online questionnaire

targeted at the MA

Interviews with

experts of DG

“RDP”

Focus groups with

beneficiaries

Focus group with

representatives of the

working group

Participation in the

working group

sessions

structures and

procedures

Analysis of good

practices in EU

Member States

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

29

Evaluation issues Evaluation

criteria

Main information sources Data collection methods Evaluation methods Relation

to other

issues

7) Assessment of validity,

relevance, coherence, applicability

and reflection of the results of the

OPRG 2014-2020 environmental

assessment

To what extent the Program

takes into account the results

and recommendations of the

OPRG 2014-2020

environmental assessment

Relevance

Future

impact

OPRG 2014-2020

Environmental

assessment of

OPRG 2014-2020

Past evaluations of

OPRD 2007-2013

Desk research

Interviews with

experts of DG

“RDP”

Interviews with

experts involved in

the project for

environmental

assessment of OPRG

2014-2020

Participation in the

working group

sessions

Expert analysis -

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

30

The main outputs and results of the implementation of Stages 2 and 3 are presented in the

table below:

Outputs Implementation

Online questionnaire √

Interviews with experts of DG RDP √

Interviews with experts of CCU √

Interviews with members of the Working Group √

Focus group with representatives of the Working Group √

Focus group with beneficiaries √

Analysis of stakeholders √

Analysis of the intervention logic √

Analysis of the intervention logic (supplemented by the horizontal

principles and objectives)

Causal analysis √

Tree of the objectives of the main strategic documents – visualization √

Tree of OPRG objectives - visualization √

Quantitative SWOT analysis √

Analysis of indicator system and monitoring system (SMART) √

Benchmarking √

Indicator fiches √

Online questionnaire targeted at MA √

Workload analysis √

Review of OPRG 2014-2020 environmental assessment √

Results Implementation

Conformity analysis √

Answers to the questions/issues within Evaluation 1 √

Recommendations related to the external consistency of the program √

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

31

Analysis of the internal consistency √

Answers to the questions/issues within Evaluation 2 √

Recommendations related to the internal consistency of the program √

Analysis of the horizontal principles and objectives included in OPRG √

Answers to the questions/issues within Evaluation 3 √

Recommendations related to the integration of the horizontal principles

and objectives in the program

Analysis of the indicator system √

Answers to the questions/issues within Evaluation 4 √

Recommendations related to the indicator system √

Answers to the questions/issues within Evaluation 5 √

Recommendations related to the program budget √

Analysis of the administrative capacity √

Expert analysis of the structures and procedures √

Answers to the questions/issues within Evaluation 6 √

Recommendations related to the management and control systems and

the administrative capacity

Expert analysis of the results of OPRG 2014-2020 environmental

assessment and their coverage

Expert analysis of the structures and procedures √

Answers to the questions/issues within Evaluation 7 √

Recommendations related to the coverage of the environmental

assessment results

This Report presents analyses and results of the ex-ante evaluation regarding all seven groups

of questions, namely:

Assessment of external consistency (Evaluation 1);

Assessment of internal consistency (Evaluation 2);

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

32

Assessment of horizontal principles (Evaluation 3);

Assessment of indicator system (Evaluation 4);

Assessment of budget program (Evaluation 5);

Assessment of management and control systems and administrative capacity for the

program implementation (Evaluation 6);

The assessment of validity, relevance, consistency, applicability and reflection of the

results of the OPRG 2014-2020 environmental assessment (Evaluation 7).

3. Stage 4 - Drawing up and Submission of final version of

Ex-Ante Evaluation of OPRG 2014-2020

Stage 4 of the Evaluation included two activities as described below.

Drawing up and approval of a final version of the ex-ante evaluation

The final report covers the activities carried out with regards to the evaluation, the answers to

all questions raised in TS on all topics, as well as the relevant recommendations.

Meeting with the Contracting Authority

Prior to the report submission, evaluation results, conclusions and recommendations were

discussed at a meeting between the Contractor and the team of experts that has developed the

evaluation.

4. Challenges in implementing the evaluation

In the course of this evaluation, no challenges jeopardizing the timely and quality completion

of the project, have been encountered. However, the following challenges should be

considered:

OPRG 2014-2020 is the first OP whose draft has passed through the process of

approval by EC, i.e. there is no model to be followed in developing the program;

The development of a Partnership Agreement is a process whose duration hampers

the programming of OPRG 2014-2020 on the basis of clear priorities;

Another lengthy process that impeded the OPRG 2014-2020 programming was the

clarification on the financial allocation of ESIF at early stage;

In a long period of the OPRG 2014-2020 programming process, the program was

much more advanced compared to other operational programs and this makes it

difficult to identify the demarcation lines and complementarity;

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

33

In the technical proposal and the Inception report were included two methods of

analysis with respect to Evaluation 5 for which it was subsequently considered more

appropriate to be replaced by benchmarks that served to evaluate the distribution of

the program budget;

One of the risks provided for in the Inception Phase, “Delay of planned meetings and

interviews over time” materialised. The interviews with experts of the MA and the

scheduled focus groups were shifted to later dates than originally envisaged in order

to discuss a higher maturity draft program with the stakeholders;

Another risk that materialised was “Delay of approval and decisions on

recommendations made” in the reports of ex-ante evaluation. The reason for this

delay might be sought mainly in the above delay of the process of programming at a

national level, as well as the need for frequent update of the OPRG 2014-2020 draft in

order to meet the specific needs of the stakeholders.

III. Evaluation 1 – Assessment of the external

consistency of the program

1. Data collection

The assessment of external consistency of the Program has been carried out on the basis of

desk research of key European and national strategic and legal documents described

below. Most of them have not been definitely adopted yet. For the purpose of this evaluation,

the latest possible versions of the documents accessible to the Contractor have been used.

Europe 2020 – EU Strategy for smart, sustainable and inclusive growth

Proposal for a Regulation of the European Parliament and the Council on specific

provisions concerning the European Regional Development Fund and the “Investment

for growth and jobs” goal, and repealing Regulation (EC) No 1080/2006

Proposal for a Regulation of the European Parliament and of the Council laying down

common provisions on ERDF, ESF, CF, EAFRD and EMFF covered by the Common

Strategic Framework and laying down general provisions on the European Regional

Development Fund, the European Social Fund and the Cohesion Fund and Elements

for a Common Strategic Framework for the period 2014-2020 for the European

Regional Development Fund, the European Social Fund, the European Agricultural

Fund for Rural Development and the European Maritime and Fisheries Fund

Territorial Agenda of the European Union 2020 agreed upon at the informal Meeting

of Ministers responsible for Spatial Planning and Territorial Development

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

34

EU Strategy for the Danube Region

National Development Program: Bulgaria 2020

National Regional Development Strategy 2012-2022

National Reform Program (2011-2015, updated in 2012), Convergence Program of

the Republic of Bulgaria (2011-2014) and recommendations in the conclusions of the

European Commission’s Report on Annual Growth Survey (2012)

Regional Development Act enforced on 31.08.2008 and subsequent updates

Opinion of the Commission on the development of Partnership Agreement and

programs in Bulgaria for the period 2014-2020

Partnership Agreement

Concepts and / or projects of other operational programs included in the Partnership

Agreement

2. Analysis

2.1. Compliance with European strategic and legal documents

Europe 2020 – EU Strategy for smart, sustainable and inclusive growth

According to Europe 2020 Strategy, Europe should be able to ensure smart, sustainable, and

inclusive growth. In order to achieve this goal the Strategy advances three mutually

reinforcing priorities:

Smart growth: developing an economy based on knowledge and innovation;

Sustainable growth: promoting a more resource-efficient, ecological and

competitive economy;

Inclusive growth: fostering a high-employment economy delivering social and

territorial cohesion.

Although to a different extent, OPRG 2014-2020 is related to all three pillars of Europe

2020 Strategy – smart, sustainable, and inclusive growth. Current measures are relevant to

the development of economy based on knowledge (smart growth), the promotion of greener

and more resource-efficient economy (sustainable growth) and social and territorial cohesion

(inclusive growth). Given its infrastructural profile, the Program is focused on sustainable

growth.

The European Commission puts forward seven flagship initiatives in order to stimulate the

progress under each priority theme:

1. “Innovation Union”

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

35

2. “Youth on the move”

3. “Digital agenda for Europe”

4. “Resource efficient Europe”

5. “Industrial policy for the globalization era”

6. “Agenda for new skills and jobs”

7. “European platform against poverty”

OPRG 2014-2020 is expected to impact on four out of the seven flagship initiatives to

stimulate progress under each priority theme:

“Youth on the move” — one of the objectives of this initiative is to enhance the

performance of education systems. OPRG will help to ensure efficient investment in

education and training systems at all levels (from pre-school to tertiary), which is set

out in Europe 2020 as objective at national level. This has been set out under PA1 in

connection with Investment Priority 3: Investing in education, skills and lifelong

learning by developing education and training infrastructure, and Priority Axis 2 “State

Education Infrastructure.”

“Resource-efficient Europe” — Modernizing the transport sector (PA1, Investment

Priority 5, Specific Objective 1: Improvement of urban air quality) and promoting

energy efficiency of all public buildings whose renovation is funded under OPRG

2014-2020, are among the objectives of this initiative. In particular, it is expected that

the following activities set out in Europe 2020 will be funded under the OPRG 2014-

2020: submission of proposals to modernize and build a decarbonised transport sector,

grid infrastructure of electrical mobility, intelligent traffic management, better logistics,

action for energy efficiency and promotion of substantial program in resource

efficiency supporting households, emphasis on transport in urban environment where

much of the congestion and emissions are generated; use of Structural Funds for

investments in energy efficiency in public and residential buildings. Similar activities

are expected to be implemented under PA1 in connection with Investment Priority 1:

supporting renewable energy use in public infrastructures, including public buildings

and the housing sector.

“Industrial policy for the globalization era” — this initiative is aimed at improving the

business environment, especially for SMEs, and supporting the development of a strong

and sustainable industrial base able to compete globally. To a certain extent, the

activities intended under PA1, in connection with the implementation of IP2 and

Specific Objective2 – Improvement of urban economic activity, are expected to

contribute to this initiative.

“European platform against poverty” — this initiative aims to ensure social and

territorial cohesion so that the benefits of growth and jobs would be widely shared

and people experiencing poverty and social exclusion would be enabled to live in

dignity and take an active part in society. In particular, Europe 2020 states that at

national level Member States should define and implement measures addressing the

specific conditions of groups at particular risk and fully deploy their social protection

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

36

and pension systems so as to ensure appropriate income support and access to health

care. The activities set out in OPRG 2014-2020 which are expected to help the

implementation of this initiative, have been provided mainly in PA 1, in connection

with IP4 and 5, PA2 “State Education Infrastructure”, PA3 “Regional Health

Infrastructure” and PA4 “Regional Social Infrastructure”.

OPRG 2014-2020 does not provide for activities in the field of Initiative 3 of Europe 2020

Strategy - “Digital Agenda for Europe”.

Europe 2020 Strategy sets 5 headline targets for the European Union by 2020.

1) The employment rate of the population aged 20-64 should increase from 69% to at

least 75%, including greater involvement of women, older workers and the better

integration of migrants in the work force (Bulgaria’s national target – 76 %);

2) Keep the current target of investing at 3% of GDP in R&D while taking account of

the R&D and innovation intensity at the same time (Bulgaria’s national target –

1.5%) ;

3) Reduce CO2 emissions by at least 20% compared to the levels of the 90s; increase the

share of renewable energy sources in the final energy consumption to 20%

(Bulgaria’s national target – 16%), and a 20% increase in energy efficiency

(Bulgaria’s national target – 25%);

4) Reduce the share of early school leavers to 10% compared to the current 15%

(Bulgaria’s national target – 11%) whilst increasing the share of the population

aged 30-34 having completed tertiary education from 31% to at least 40% (Bulgaria’s

national target – 36%);

5) Poverty and social exclusion – reduce people living in poverty or at risk of poverty

and social exclusion by at least 20 million. (Bulgaria’s national target - by 260

thousand people by 2020).

OPRG implementation is expected to contribute to the achievement of four of the objectives

(1, 3, 4 and 5) of the Europe 2020 Strategy, the most direct contribution being the

improvement of energy efficiency.

With a view to the implementation of the objectives of Europe 2020 Strategy and the

achievement of smart, sustainable and inclusive growth, the European Commission has

proposed a Common Strategic Framework. It covers the management of the European

Funds: the European Regional Development Fund (ERDF), the European Social Fund (ESF),

the Cohesion Fund (CF), the European Agricultural Fund for Rural Development (EAFRD),

and the European Maritime and Fisheries Fund (EMFF). These Funds will be the main source

of investments at EU level supporting the Member States to relaunch and boost growth and to

guarantee recovery matched by employment growth whilst at the same time ensuring

sustainable development.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

37

Proposal for a Regulation of the European Parliament and of the Council laying down

common provisions on ERDF, ESF, CF, EAFRD and EMFF covered by the Common

Strategic Framework and laying down general provisions on ERDF, ESF and CF, and

Elements for a Common Strategic Framework 2014-2020 for the European Regional

Development Fund, the European Social Fund, the European Agricultural Fund for Rural

Development and the European Maritime and Fisheries Fund

The proposal aims at establishing a common strategic framework for ERDF, ESF, CF,

EAFRD, and EMFF, which will ensure the integrated use of the funds for the achievement of

the Europe 2020 Strategy objectives. A key element of the CSF is the set of 11 thematic

objectives commented further in the text of the Ex-ante evaluation describing the investment

priorities and objectives relevant to ERDF.

One specific element of CSF is that Member States are expected, where appropriate, to

combine CSF Funds into integrated packages at local, regional, or national level,

specifically tailored to meet particular needs in order to achieve the national targets set by

Europe 2020. Member States can use integrated operations in the form of integrated territorial

investments (Art. 99 of the proposed General Provisions Regulation) and/or joint action plans

(Art. 93:98 of the proposed General Provisions Regulation). The program provides for the

implementation of 67 Integrated Territorial Investments (IPURD) which will be supported by

other operational programs and coordinated by the Managing Authorities, including:

OP Environment for construction/rehabilitation/reconstruction of the water and

sewerage infrastructure (network), and

OP Human Resources Department – for supporting the implementation of “soft

measures”, equipment and furniture of social and education institutions financed

under OPRG 2014-2020, specially focusing on the socially disadvantaged, vulnerable

and minority groups of people, and supporting qualification of SMEs;

Operational program “Science and Education for Smart Growth” – for

supporting the implementation of “soft measures”, equipment and furniture of social

and education institutions financed under OPRG 2014-2020.

The draft OPRG provides for (in accordance to Art. 32 - Financial Instruments of the General

Provisions Regulation) partial or full application of financial engineering for financing of

investments in sports infrastructure, energy efficiency of housing buildings, cultural

infrastructure, as well as areas with potential for economic development, urban environment

and integrated public transport.

In this respect, the draft OPRG 2014-2020 follows the stipulations of the proposed General

Provisions Regulation on the use of financial instruments.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

38

Proposal for Regulation of the European Parliament and the Council on specific

provisions concerning the European Regional Development Fund and the ”Investment for

Growth and Jobs” goal and repealing Regulation (EC) No 1080/2006

This document will set the basis of the European regional development policy and the main

rules for its funding during the 2014-2020 period. The Proposal for a Regulation states that

the notion of concentration of funding is commonly agreed. The document further stipulates

that the building of infrastructure should be funded in less developed regions where public

authorities do not have sufficient resources for investments and investment costs cannot be

recovered as the population is low income. Energy efficiency and renewable energy

sources as well as sustainable urban development are expected to be a major focus of the

2014-2020 programming period. OPRG 2014-2020 takes into account these focuses and is

consistent with the notion for concentration of EU funds to achieve specific results.

The proposed Regulation on the ERDF gives description of the Fund’s investment priorities

corresponding to the eleven thematic objectives defined by the SCF. The objectives and

investment priorities consistent with OPRG 2014-2020 are indicated below:

1. Thematic objective – Strengthening research, technological development and

innovation: not expected to receive funding under OPRG 2014-2020

2. Thematic objective – Enhancing access to and use and quality of ICT: not expected

to receive funding under OPRG 2014-2020

3. Thematic objective – Enhancing the competitiveness of SMEs – not expected to

receive funding under the Program

4. Thematic objective – Supporting the shift towards a low-carbon economy in all

sectors: included in OPRG

Supporting energy efficiency and renewable energy use in public

infrastructures, including in public buildings and in the housing sector;

Promoting low carbon strategies for all types of territories, in particular for

urban areas, including the promotion of sustainable multi-modal urban mobility

and mitigation relevant adaptation measures.

5. Thematic objective – Promoting climate change adaptation, risk prevention and

management:

Promoting investment to address specific risks, ensuring disaster resilience and

developing disaster management systems

6. Thematic objective – Protecting the environment and promoting resource

efficiency: included in OPRG.

Conserving, protecting, promoting and developing natural and cultural heritage

Action to improve the urban environment, revitalisation of cities, regeneration

and decontamination of brownfield sites (including conversion areas), reduction

of air pollution and promotion of noise-reduction measures

7. Thematic objective – Promoting sustainable transport and removing bottlenecks

in key network infrastructures: included in OPRG

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

39

Enhancing regional mobility through connecting secondary and tertiary nodes to

TEN-T infrastructure;

8. Thematic objective – Promoting employment and supporting labour mobility: not

expected to receive funding under the Program

9. Thematic objective – Promoting social inclusion and combating poverty:

included in OPRG

Investing in health and social infrastructure which contribute to national,

regional and local development, reducing inequalities in terms of health status,

promoting social inclusion through improved access to social, cultural and

recreational services and the transition from institutional to community-based

services

Support for the physical, economic and social regeneration of deprived

communities in urban and rural areas;

10. Thematic objective – Investing in education, skills and lifelong learning by

developing education and training infrastructure: included in OPRG.

Six out of the eleven proposed thematic objectives have been selected for the OPRG. Such

comprehensive coverage of thematic objectives is not surprising given the complex needs of

the territorial development. OPRG 2014-2020 does not, at the same time, violate the principle

for concentration of funds as it is limited in territorial scope compared to OPRD 2007-2013.

The draft Regulation on ERDF (Art. 4) sets out special requirements about the amount of

funds allocated at national level to support the shift to low-carbon economy (energy

efficiency and renewable energy sources) which illustrates the emphasis that the EC lays

upon this sphere. Energy efficiency is a key area of concern for the OPRG 2014-2020 as well.

In order to give a greater focus on the sustainable urban development, the proposed

Regulation on the ERDF (Art. 7) provides for at least 5% of the ERDF resources allocated at

national level to be allocated to integrated actions for sustainable urban development through

strategies which set out integrated actions to tackle economic, environmental, climate and

social challenges affecting urban areas. It also puts in place the requirement (Art. 7 (2)) to

draw up in advance a list of cities where integrated actions for sustainable urban

developments are to be implemented and an indicative annual allocation for these actions at

national level. The draft OPRG has provided for funding of activities in the framework of

IPURD in 67 cities under PA1 “Sustainable and integrated urban development”. A listing

proposal has been drawn up based on analysis and criteria system included in the National

Spatial Development Concept.

In the light of the above, it can be concluded that OPRG 2014-2020 is consistent with the

emphasis placed on the sustainable urban development.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

40

Territorial Agenda 2020 of the European Union agreed at the Informal Meeting of

Ministers responsible for spatial planning and territorial development

The aim of Territorial Agenda 2020 is to provide strategic guidelines for territorial

development within different policies at all management levels and ensure the

implementation of Europe 2020 Strategy in accordance with territorial cohesion principles.

Urban regions are described as “assets” for the development of the entire European territory,

provided that other regions benefit from their dynamism and are connected through networks.

The Territorial Agenda stipulates that “ecological values, environmental quality and cultural

assets are crucial to well-being and to economic prospects and offer unique development

opportunities.” It also points out that urbanisation and mass tourism threaten cultural and

environmental heritage. Regions and cities are encouraged to develop and adopt integrated

spatial strategies and plans to enhance the effectiveness of all actions on a particular territory.

The Agenda identifies the following territorial priorities:

Support for polycentric and balanced territorial development – urban centres

should contribute to the development of their wider regions. At the same time, the

polarisation should be avoided and small to medium-sized cities may play a

crucial role at regional level.

Encouragement of integrated development in cities, rural and specific regions –

supporting the cities to become “engines of smart, sustainable and inclusive

development” and attractive places to live, work, visit and invest. The urban-rural

interdependence should be influenced on the basis of a broad partnership.

Territorial integration in cross-border and transnational functional regions

Ensuring of global competitiveness of the regions based on strong local

economies - including the use of local assets, social capital, strategies and other

activities which rather fall beyond the scope of OPRG

Improvement of territorial connectivity between individuals, communities and

enterprises – including the use of energy from renewable energy sources

Management and connecting of ecological, landscape and cultural values of the

regions – protection and improvement of cultural and environmental heritage are

considered essential for sustainable development. Protection, rehabilitation, and

utilization of the cultural heritage are supported to this effect.

As stated in the text of OPRG 2014-2020, the strategy set out in the Program fits into the

priorities of the EU Territorial Agenda 2020.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

41

Position paper of the Commission services on the development of Partnership Agreement

and Programs in Bulgaria for the period 2014-2020

The position paper of the EC sets out the fundamental specific challenges for Bulgaria and

presents the Commission services’ preliminary views on the central priorities for funding the

growth-enhancing public expenditure in Bulgaria. Presented below are the fundamental

priorities/challenges outlined in the Position Paper of the Commission services, with which

OPRG 2014-2020 is consistent:

National and Trans-Еuropean Transport Network infrastructures (TEN-T) are not well

connected nor sufficiently rehabilitated and maintained;

Urban public transport infrastructure is in a poor technical condition and the transition

from car mobility to high-quality public transport should be facilitated;

Energy intensity of the Bulgarian economy is very high, especially in urban areas.

Energy efficiency measures should focus on buildings that can serve as an example;

Insufficient capacity to cope with risks of natural and man-made disasters;

Modernization of education and training requires significant investments in the

infrastructure;

Continuous enhanced support from SCF Funds is needed for a further transfer from

institutional to community-based facilities for children, people with disabilities and

mental problems, elderly people, including targeted infrastructure investments;

Investments shall contribute to remove barriers to access in order to allow the

integration of disabled people into education and labor market;

In addition to the extensive use of financial engineering instruments to support SME

investments, they should be used more widely for investments in projects where there

is a proven capacity to return all or part of the input, including promoting the

transactions for integrated urban development and the promotion of energy efficiency;

Need for investments focused on reducing early school drop-outs (more specifically of

Roma people), acquiring technical and business skills, promoting effective access to

primary, secondary and pre-school education, and in the absence of discrimination,

enhancing the quality, effectiveness and accessibility of higher education;

Investments in renewable energy sources (RES) and energy efficiency improvements

in the sectors of services, industry, renovation of residential buildings, agriculture,

fisheries and aquacultures should be supported, thereby increasing the share of RES in

final consumption energy;

Investing in the desegregation of school infrastructure with special emphasis on

education and care in early childhood, particularly in the most populous municipalities

which are faced with lack of capacity, taking into account the need for sustainable

funding;

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

42

Support sustainable integrated urban development, including measures against soil

sealing and rehabilitation of contaminated sites. Support for the rehabilitation of areas

in decline and creation of green urban infrastructure. Improving the urban environment

while preserving and enhancement of the cultural and historical heritage;

The initial Position of the Commission staff states that no ERDF funding of tertiary roads

will be provided, but subsequently in the so-called Negotiating box it has been pointed out

that "Based on the developed methodology and specific criteria, support for first, second and

third class roads will be limited to key pre-determined sections of roads that connect major

urban centers and tourist sites of TEN-T network, thus exploiting the potential for growth and

employment at regional level.”

As the list of priorities/challenges clearly shows, OPRG 2014-2020 covers many of the

infrastructure investment priorities.

The CSF in the period 2014-2020, puts in place requirements for joined-up policies,

integrated approaches, and result-driven use of the CSF Funds which shall maximise their

combined effect1. In this respect, the activity “Support for modern social housing of

vulnerable, minority and socially weak groups of the population and other disadvantaged

groups” under sub-priority 7 should be implemented in synergy with programs funded by the

CSF Funds in support of the national education, health care, and social service policies to

desegregate Roma people.

OPRG 2014-2020 has been aligned with the general requirement of the new Common

Strategic Framework and the Commom Provisions Regulation for cordination and

complimentarity of interventions supported by the CSF Funds. Тhis concept has been

applied to PA1 of the Program, which will be implemented by means of integrated territorial

investments, in conjunction with OP “Environment” and OPHRD, and coordination between

several thematic objectives within the framework of the OPRG. The proposed Common

Provisions Regulation advances different forms and mechanisms for coordination of

cooperation activities funded by different Funds. The OPRG has opted for a parallel

funding approach through “coordinated launch of different schemes of the Managing

authorities, with the assisstance of CCU, by enabling the submission of one project proposal

under several schemes”.

The intention to use financial engineering partly or in full to fund investment in sports

infrastrucutre, energy efficiency in public buildings, health and cultural infrastricture, and

areas with potential for economic development, urban and integrated urban transport, is

consistent with the policies promoted by the Community in respect of the financial

instruments (proposal for Common Regulations, reviews of DG "Regional and urban policy"

of the first draft of OPRG 2014-2020). Given the limited experience and results delivered

during the current planning period, it is advisable to provide for a feasibility study on this

1 Integrated approaches are promoted in the Proposal for Common Provisions Regulation and the Position paper of the Commision services on the development of Partnership Agreement and Programs in Bulgaria for the period 2014-2020.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

43

issue or evaluation of the financial engineering schemes operating during this planning period

(Funds under Jessica, FJO). It is recommended that this be done before the start of the OPRG

2014-2020, but if this is not possible, an ex-ante evaluation of financial instruments required

under the Regulation should be included. The study/evaluation will help to identify barriers to

the effective use of financial instruments, respectively, obtain recommendations for

improving the design of schemes for the implementation of this mechanism, and limit the risk

of failure to achieve targets within deadlines - interim and final, of the program period.

2.2. Compliance with national strategic and legal documents

National Development Program Bulgaria 2020

The National Development Program Bulgaria 2020 (NDP B2020) is the leading strategic and

programming document specifying the objectives of the country’s development policies to

2020 and revealing the relation between EU priorities within Europe 2020 Strategy and

Bulgaria’s national priorities.

The implementation of the OPRG is expected to contribute for the achievement of two out of

the three targets set out in the NDPB 2020:

1. Enhancing the standard of living through competitive education and training,

creating conditions for quality employment and social inclusion and ensuring

accessible and quality health care.

2. Construction of infrastructural networks to provide optimal conditions for

development of the economy and quality and healthy environment for the

population.

OPRG 2014-2020 covers six out of the eight formulated priorities as follows:

1. Improving the access to and enhancing the quality of education and training and the

quality characteristics of the workforce – the Program is expected to contribute.

2. Reducing poverty and promoting social inclusion – the Program is expected to

contribute.

3. Achieving sustainable integrated regional development and use of local potential –

the largest expected contribution of the Program to this priority.

4. Developing the agricultural sector to ensure food safety and production of high value-

added products through sustainable management of natural resources – the Program

is not expected to contribute.

5. Supporting innovation and investment activities to raise competitiveness of the

economy - the Program is not expected to contribute.

6. Energy security and increasing resource efficiency – the Program is expected to

contribute.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

44

7. Improving transport connectivity and market access – the Program is expected to

contribute.

Тhe consistency of OPRG 2014-2020 with particular priorities and sub-priorities of NDPB

2020 is examined below:

Priority 1. Improving the access to and enhancing the quality of education and training and

the quality characteristics of workforce

P1) Sub-priority 1.1 The providing for affordable and quality education for personal

development through modernization of the education system and the ensuring of its

adaptability to labour market needs include activities for Improving the material and

technical basis for education, training and youth activities. Such activities are included in

OPRG 2014-2020 in terms of educational infrastructure of regional importance by PA1

(Investment Priority 3: Investing in education, skills and lifelong learning by developing

educational and training infrastructure) and Priority Axis 2 "State educational infrastructure.

P1, Sub-priority 1.4 Enhancing the quality and effectiveness of health services, includes

activities to improve the quality of health care services and ensure access to health care for all

citizens (incl. health infrastructure - carrying out works and purchasing equipment for

health care facilities).The activities under PA 3 correspond to this sub-priority.

P1, Sub-priority 1.5 Development of culture and arts, cultural and creative industries,

extending access to art and developing culture of the population (improving the material

and technical basis). Available compliance with envisaged activities in PA 1, in connection

with IP 3 and PA 5.

P1, Sub-priority 1.6 Developing sports and increasing physical education of the population.

PA 1, IP4 correspond to this sub-priority.

Priority 2. Reducing poverty and promoting social inclusion

P2, Sub-priority 2.2 Providing of sustainable, high quality and affordable cross-sectoral

services with the aim of preventing social exclusion includes improving the housing

conditions for vulnerable groups and supporting the homeless which will be covered under

PA 4 “Regional Social Infrastructure”. SP in NDPB 2020 enables the construction of social

housings “improvement of the material basis and/or construction of a new one.”

Priority 3. Achieving sustainable integrated regional development and use of local potential

P3, Sub-priority 3.2. Fostering urban development and improving the integration of the

Bulgarian regions on national scale is a SP corresponding to PA1 under OPRG 2014-2020.

The target areas for integrated sustainable urban development and strengthening of the

functions of the polycentric city network are covered. The aim is to develop large and

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

45

medium-sized cities in the country, to improve the integrated sustainable urban development,

urban environment, transport, and communication connectivity, to create areas with potential

for development, to improve the access to public services, the standard of living of the

population. List of consistencies as per planned activities:

Improvement of urban environment – PA1, Investment Priority 2 by upgrading the

physical environment (SO 1), by restoring the urban areas (SO 2), investments in

sports infrastructure (IP4)

Protection, promotion and development of cultural and natural heritage -

Investment Priority 4 of PA1

P3, Sub-priority З.4 Support for effective and sustainable utilization of the tourism potential

of the regions and development of cultural and creative industries in the regions

The areas of impact related to the implementation of the sub-priority are as follows:

Development of infrastructure for specialized forms of tourism, including cultural

tourism

Marketing of tourist regions and forming of regional tourism products

There is consistency with PA5 Regional Tourism of OPRG, particularly with respect to

activities that will allow for restoration and preservation of cultural sites of national and

international significance and for increasing their attractiveness to visitors with a view to

turning them into generators of growth and jobs.

P3, Sub-priority З.5 Creating the conditions for protecting and improving the environment in

the regions, adapting to changes in the climate and achievement of sustainable and efficient

use of natural resources. The objectives of this sub-priority will be supported by investment

priority 2 of Priority Axis 1: Actions to improve the urban environment, including

regeneration of brownfield sites and reduction of air pollution of OPRG.

Priority 7. Energy security and increasing of resource efficiency

P7, Sub-priority 7.2 Increasing of energy efficiency includes measures to increase the

efficiency of energy consumption in the public sector and households, as well as increase the

energy efficiency of buildings. This sub-priority is consistent with Investment Priority 1 of

PA1 of OPRG which provides for targeted investments in improvement of energy efficiency

of residential and public administrative buildings. In addition, the requirement for inclusion

of measures to improve the energy efficient renovation of all other buildings funded under

OPRG 2014-2020 has been established as a horizontal principle.

OPRG 2014-2020 will contribute to the Sub-priority 7.3 Reaching 16% of energy from

renewable sources in gross final energy consumption by 2020 with planned activities related

to implementation of installations using renewable energy in commercial and residential

buildings under PA1.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

46

Priority 8. Improving transport connectivity and access to markets

Sub-priority 8.2 Effective maintenance, modernization and development of the transport

infrastructure is focused on the construction, modernization and maintenance of transport

infrastructure which makes part of the European transport corridors in order to integrate the

Bulgarian transport system into the European one.

Sub-priority 8.6 Improving the connectivity and integration of Bulgarian regions on national

and international scale and the connectivity with the big urban centers in the neighboring

countries will be implemented by improving connectivity and accessibility of the network of

cities and sites of cultural and natural heritage of TEN-T network under Priority Axis 6

"Regional road infrastructure".

National Regional Development Strategy 2012-2022

The National Regional Development Strategy (NRDS) for the period 2012-2022 is the

fundamental document formulating the strategic framework of the public policy for achieving

balanced and sustainable development of the regions in the country and overcoming the

intraregional and interregional differences/inequalities.

In the interim evaluation of NRDS, the regional development policy has been formulated as

an integrated cross (multi)-sectoral approach for defining objectives and implementing

measures to stimulate the development and the social inclusion on different territorial levels.

The regional development policy ensures territorial dimension of the sectoral policies and

fosters the achievement of more effective and sinchronized effect of their implementation.

The Strategy lays down 4 strategic objectives:

Strategic objective 1: Economic cohesion on European, national and intraregional scale

through development of the very potential of the regions and environmental protection.

Priority 1.1., Specific Objective 1: Stimulating the economic development of the regions of

NUTS 2 through improvement of access to production zones and their infrastructure – the

indicative activities under PA 1 in connection with Investment Priority 2 and the

implementation of SO2 – improvement of urban economic activity; coverage of the activities

envisaged under this specific objective;

Priority 1.2., Specific objective 1: Stimulating region-specific types of tourism based on

natural landscape and cultural values and activities – consistency with PA5;

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

47

Priority 1.2., Specific objective 2: Protection, valorization, digitization”2, presentation of

immovable, movable, and intangible cultural values – consistency with Investment Priority 4

of Priority Axis 1 and PA5 “Regional Tourism”;

Priority 1.2., Specific objective 3: Development, regional marketing, and advertising of

regional tourism products based on local potential – consistency with PA5;

Priority 1.3., Specific objective 5: Natural risks prevention – in full consistency with PA6.

Strategic objective 2: Social cohesion and reduction of regional disparities in the social

sphere by generating conditions for development and realization of the human capital

Priority 2.1. Specific objective 1: Upgrading of the educational infrastructure of schools of

arts and culture – as mentioned above, these activities are expected to be covered under

Priority “State educational infrastructure” by the Ministry of Culture as specific beneficiary

under the OPRG 2014-2020.

Priority 2.1. Specific objective 2: Improving the state and municipal cultural

infrastructure – corresponds to the activities planned under PA1 and PA4 as regards the

sites of environmental and cultural heritage.

Priority 2.1. Specific objective 4: Construction and reconstruction of sports infrastructure

for professional and recreational sport – PA1 (Investment Priority 4 and PA1) is consistent

with this specific objective.

Strategic objective 3: Territorial cohesion and development of transborder, interregional and

transnational cooperation – the activities will not be covered by OPRG 2014-2020

Strategic objective 4: Balanced territorial development through strengthening of metropolis

network, improving the connectivity in the regions and the environment quality in the

populated areas.

Priority 4.1. Specific Objective 1: Integrated renovation and development of cities and

improvement of urban environment quality – the activities have been covered by the PA1.

Priority 4.1. Specific objective 2: Improving public works, transport, and communication

connectivity in the agglomeration areas of the large cities – such activities have been

provided for under PA1 (in connection with the implementation of Investment Priority 5:

Promoting low-carbon strategies for all types of territories, in particular for urban areas,

including the promotion of sustainable urban mobility and mitigation relevant adaptation

measures).

Accordingly, there are priorities and objectives in NRDS 2012-2022 which have not been

covered by OPRG 2014-2020. The reason for this is that they are expected to fall in the scope

of other programs or funding sources.

2 More information on the digitization of the cultural heritage can be found on the following website: http://europa.eu/legislation_summaries/culture/l29018_en.htm

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

48

NRDS, respectively the regional plans for development, define the territorial focus of the

sectoral policies and lay down the territorial basis for their effective coordination in the

regions.

National Reform Program (2011-2015, updated 2013), Convergence program of the

Republic of Bulgaria (2011-2014), and recommendations in the conclusions of the EC’s

report on the Annual Growth Survey (2012)

The measures proposed in NRP are aimed at overcoming the existing challenges to optimal

development of the key factors for Bulgaria’s ecomonic growth and achieving the national

targets in implementing the Europe 2020 Strategy. NRP is closely related to the Convergence

Program of the Republic of Bulgaria (2011-2014) and directly addresses the

recommendations made in the conclusions of EC report on the Annual Growth Survey.

The implementation of the OPRG 2014-2020 will contribute to achieving the following

national targets:

National Target 1 - Reaching 76% employment rate for population aged 20-64 by 2020.

PA5 “Regional Tourism” of the Programme is expected to contribute to the NT1

where the implementation of activities will create conditions to maintain / increase

employment in the sphere of services in cities / regions, in which natural and cultural

heritage attractions will be renovated and promoted.

Toward the implementation of NT1 is targeted IP2 of PA 1 of the Programme, within

the scope of implementation are included activities in support to areas with potential

for economic development.

National Target 3 under the “Climate-energy” Package – “Achieving 16% share of

renewable energy sources in the gross final energy consumption and increasing energy

efficiency by 25% by 2020”.

Direct contribution to NT3 is expected from the implementation of PA 1 "Sustainable

Integrated Urban Development", in relation to IP1, which comprises measures to

improve energy efficiency ( EE) in residential and public buildings.

IP 5 and PA1 will ontribute to greenhouse gas emissions reduction and the

improvement of resource efficiency by measures on public transport and alternative

forms of transportation.

It is expected that all priority axes to have an indirect contribution to the achievement

of NT3, taking into consideration the horizontal requirement for the implementation

of energy efficiency measures in all types of the Programme intervention.

National target 4 “11% share of the early school leavers by 2020, and a 36% share of the

people aged 30-34 with higher education by 2020”. PA1 and PA 2 of the Program will

contribute to the implementation of this target.

National target 5 “Reducing the number of people living in poverty by 260 000”.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

49

Contributing to the implementation of NT5 will have PA1, IP4 – “Investing in health

and social infrastructure,” PA3 “Regional Health Infrastructure” and PA4 “Regional

Social Infrastructure” of the Programme, through measures ensuring adequate living

conditions for vulnerable groups of the population and improving the quality of social

and health infrastructure, and hence of social and health services.

IP2 of PA1 provides also the creation of an accessible architectural environment,

including improving access for people with disabilities to public administration

buildings, which corresponds to the planned measure NT5 (1) of NR, updated 2013.

NDP (updated 2013), presents the government's planned measures, necessary in different

areas and policies for the implementation of Specific Recommendations (SR) of the

Council. Below are listed those for which funding is provided under the OPRG:

SR 3 “To reduce poverty, improve the efficiency of social benefits and access for children

and adults to quality social services, and to implement the National Strategy for

Integration of Roma.” IP 4 under PA 1 of the Program and PA4 “Regional social

infrastructure” aim at improving living conditions (and the underlying technical

infrastructure) of groups at risk of social exclusion (including Roma), the Programme

contributes to the implemenation of the “National Strategy for integration of Roma,” quoted

in Specific Recommendation 3 of the Council.

SR 4 “To speed up the reform of legal acts regulating the school and universities’ activities

and measures, focusing on modernizing curricula, improved training and provision of

effective access to education for disadvantaged groups. To improve access to finance for

start-ups and SMEs, in particular those involved in innovative activities.” IP 3 under PA1 and

PA2 the OP address to a certain extent the SR 4 of the Council “provision of effective access

to education for disadvantaged groups,” through the implementation of measures for

accessible architectural environment for people with disabilities. Expected contribution of

interventions under PA 1 within the areas of social impact of cities-beneficiaries, since there,

often are concentrated representatives of disadvantaged groups.

SR 7 “Improve connections of electricity and gas networks, to increase energy efficiency

and to strengthen capacity with respect to supply disruptions.” IP 1 under PA1 “Supporting

energy efficiency, smart energy management and renewable energy use in public

infrastructures, including in public buildings and in the housing sector” is specifically aimed

at increasing energy efficiency. It is important to note that the implementation of energy

efficiency measures is foreseen in the implementation of all priority axes of the operational

program.

The indicated consistencies of ORPG, version 09.09.2013, to RS4 - effective use of resources

and Priority 3 AGS 2013 “Promoting growth and competitiveness of today and tomorrow”

should be removed as irrelevant to NDP update 2013. However, in the program should be

mentioned its contribution to the promotion of growth and employment in 67 cities through

the implementation of integrated urban plans for regeneration and development (IUPRD) -

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

50

measure DA 4-5 of NDP. The necessary changes are provided in the latest version of OPRG,

16.09.2013.

Regional Development Act, effective as of 31st of August 2008 and subsequent updates

The Regional Development Act regulates the government policy for regional development

and creates conditions for balanced and sustainable integrated development of regions,

reduction of interregional and intraregional disparities regarding the level of economic,

social, and territorial development. The regional development policy is based on the

principles of uniform approach towards planning and programming, concentration of

resources, coordination with other structural policies, tools, and activities.

OPRG 2014-2020 relies on the same principles:

- The integrated approach and concentration of resources – fully set out in PA1;

- The uniform programming approach – has been reflected in the fact that the entire

PA1, for which the major part of the Program’s resources is planned, will be

implemented on the basis of IPURD, developed at local level;

- The principle of coordination with other policies and tools has been reflected in the

planned coordination of the interventions with other operational programs.

Compliance with the National Spatial Development Concept for the period 2013-2025

The National Spatial Development Concept for the period 2013-2025 is a mid-term strategic

document whose main function is to lay the foundations for spatial orientation and

coordination of sectoral policies. Together with the National Regional Development

Strategy 2012-2022, it is a fundamental document and instrument for integrated planning and

sustainable spatial, economic, and social development.

The Concept defines the guidelines of the regional policy and the spatial planning policy,

guides the MA in the selection of cities to support under OPRG, and coordinates the sectoral

policies by redirecting them to the national space. It is on the basis of NSDC that a selection

has been made of 67 cities to be supported under PA1 OPRG 2014-2020. As stated in the

NSDC “the selection criteria are: suitable location in districts, good transport accessibility,

demographic size, presence of functions beyond municipal level in the fields of economic,

social, health, education and culture.” NSDC is also discussed and agreed by the thematic

working groups, including with one of the key stakeholders - the National Association of

Municipalities. In this sense, the territorial scope of the program is justified in terms of

national strategic documents and is discussed with key stakeholders.

Among the strategic objectives of NSDC relevant to OPRG 2014-2020, are:

Strategic objective 1 “Integration into the European space” – development of

national and trans-border transport, energy, urban, cultural and ecological corridors

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

51

with a view to achieving territorial cohesion, cooperation and integration in the region

and the European space.

The overall strategic framework of the OPRG 2014-2020 corresponds to this strategic

objective.

Strategic objective 2 “Polycentric territorial development” – strengthening of a

moderately polycentric metropolis network with improved urban environment quality

enabling the achievement of balanced territorial development and decrease in

disparities between the central urban and peripheral rural areas.

PA1 “Sustainable and integrated urban development” corresponds most fully to this strategic

objective. The choice of cities to be supported by the program is based on the strategy

described in NSDC for development of the territory of this country by strengthening the

balanced polycentric network of cities and peripheral rural areas

Strategic objective 3 “Spatial connectivity and access to services” – development of

the national technical and social infrastructure to improve the spatial connectivity of

regions and urban centers, and the access to education, health, social and cultural

services.

In order to achieve SO3, three main priorities have been worked out. OPRG 2014-2020

supports the implementation of Priority 3.3 Uniform coverage of the national territory with a

network of objects at the high level of the public services in health care, education, social

assistance and culture – and improving the access to quality services.

The activities under PA1 (Investment Priority 3 and 4), as well as the activities under PA 2, 3

and 4 correspond to this priority.

Strategic objective 4 “Preserved natural and cultural heritage” – preservation and

development of the national system of protected natural and cultural values to maintain

the biodiversity, spatial natural and cultural identity and to integrate their values into

modern life.

PA 1 (IP 4) and PA 5 “Regional Tourism” correspond to this strategic objective.

Coherence with the Partnership agreement

The Draft Partnership agreement of the Republic of Bulgaria and EU stipulates that in the

programmes finances by the European Structural and Investment Funds (ESIF) Bulgaria will

follow all 11 thematic objectives of the funds (Dec. of the Council of Ministers

328/25.04.2012).

At the same time, the Partnership agreement outlines the thematic objectives in the following

major, complementing funding priorities:

1. Strategic priority 1: Education, qualification and employment for inclusive growth

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

52

2. Strategic priority 2: Scientific research, innovation and investments for smart growth

3. Strategic priority 3: Connectivity and green economy for sustainable growth

4. Strategic priority 4 (horizontal): Good governance and access to quality public

services

5. Strategic dimension (territorial): Spatial dimension and place-based policies

а) interventions according to the territorial specifics (towns, rural areas and such

depending on fishery, territories with tourism potential);

b) additional territorial dimension of the sector policies in the programming process,

applicable to a certain degree to all funding priorities (e.g.: health, educational, social,

environmental infrastructure with regional and local importance).

The relationship between thematic objectives of ESIF and the Draft Partnership agreement of

the Republic of Bulgaria and the EU is demonstrated in the table below:

PA strategic priorities for funding Thematic objective of the ESIF

Education, qualification and

employment for inclusive growth

8) Encouraging employment and support for work force mobility;

9) Promoting social inclusion and combating poverty;

10) Investments in education, skills and life-long learning;

Scientific research, innovation and

investments for intelligent growth

1) Strengthening research, technological development and innovation;

2) Enhancing access to, and use and quality of, information and

communication technologies (different from e-government);

3) Enhancing the competitiveness of small and medium-sized

enterprises, the agricultural sector (for the EAFRD) and the fisheries

and aquaculture sector (for the EMFF);

Connectivity and green economy for

sustainable growth

4) Supporting the shift towards a low-carbon economy in all sectors;

5) Promoting climate change adaptation, risk prevention and

management;

6) Protecting the environment and promoting resource efficiency;

7) Promoting sustainable transport and removing bottlenecks in key

network infrastructures;

Good governance and access to

quality public services

2) Enhancing access to, and use and quality of, information and

communication technologies (different from e-government);

11) Enhancing institutional capacity and an efficient public

administration.

Spatial dimensions and place-based

development policies

Place-based approach according to the BARCA report (2009), the

Fifth Cohesion report and art. 174 from the Treaty on the Functioning

of the European Union.

Territorial agenda

Source: Draft Partnership agreement of the Republic of Bulgaria and EU outlining the support from the

European structural and investment funds for the 2014-2020 period, version 3.0 from August 2013.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

53

In addition, the strategic priorities, on their turn, are divided in sub-priorities. OPRG 2014-

2020 addresses the priorities and sub-priorities of the Partnership agreement, as shown in the

table below:

PA Strategic

priority for funding Sub-priority

Areas from PA with relation

to planned interventions in

OPRG 2014-2020

Priority axes in

OPRG 2014-2020

Strategic priority 1:

Education,

qualification and

employment for

inclusive growth

Employment and work force

mobility

None Not addressed

Social inclusion

Investments associated with

promotion of active life among

elderly citizens, provision of

accessible environment –

physical, institutional and

informational, and accessible

transport;

Integrated measures for

investments in early childhood

development;

Substitution of the institutional

model for care and

development of integrated

intersectoral services for social

inclusion;

Provision of essential services

(health and social services,

accommodation, services for

homeless people and people

living in bad living condition,

internet services) and

education

Priority axis 1.

Sustainable and

integrated urban

development

Priority axis 3.

Regional health

infrastructure

Priority axis 4.

Regional social

infrastructure

Education, training and life-

long learning

Investments in state and

municipal educational

infrastructure

Priority axis 1.

Sustainable and

integrated urban

development

Priority axis 2. State

educational

infrastructure

Strategic priority 2:

Scientific research,

innovation and

investments for

intelligent growth

Boosting competitiveness of

SMEs from key sectors of

the economy

None Not addressed

R&D and Innovations

Access to and use of ICT

Strategic priority 3: Connectivity (internal and Development of eco-friendly Priority axis 1.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

54

Connectivity and

green economy for

sustainable growth

external) transport systems for

promotion of sustainable urban

mobility.

Road infrastructure with

regional significance

Sustainable and

integrated urban

development - 1.5.

Priority axis 6.

Regional road

infrastructure

Shift to low-carbon

economy, energy and

resource efficiency

Promoting energy and resource

efficiency and increasing the

use of renewable energy

sources

Priority axis 1.

Sustainable and

integrated urban

development - 1.1.

Climate and climate change,

risk prevention and

management

Prevention/protection from

floods through implementation

of investment measures

Priority axis 7. Risk

prevention

Environment and protection

of natural resources

Measures associated with

protection, popularization and

development of cultural and

natural heritage

Priority axis 5.

Regional tourism

Strategic priority 4

(horizontal):

Good governance

and access to

quality public

services

Administrative effectiveness

and quality of the judiciary

system

None Not addressed

Access to qualitative public

services and effective

application of electronic

governance and justice

Strategic dimension

(territorial):

Spatial dimensions

and place-based

development

policies

Place-based development

policies:

- Sustainable and

integrated urban

development

- Rural areas

development

- Fishing area

development

- Areas with potential

for tourism

development

Spatial dimension of

strategic priorities for

sustainable, intelligent and

inclusive growth

Construction, rehabilitation

and reconstruction of state

road network, regardless of

road class, infrastructure;

Development of tourism

through support of

preservation, popularization

and development of cultural

and natural heritage;

Urban development;

Priority axis 6:

Regional road

infrastructure

Priority axis 5:

Regional tourism

Priority axis 1:

Sustainable and

integrated urban

development

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

55

OPRG 2014-2020 mentions the following reference to the Partnership agreement: OP

“Regions in Growth” 2014-2020 is oriented directly towards the achievement of the

objectives of strategic territorial priority 5: “Regional development and place-based

potential” and more specifically to sub-priorities “Sustainable and integrated urban

development” and “Territorial dimensions of the sectoral policies” of the Partnership

agreement.

The text of OPRG 2014-2020 needs to become more precise in view of better transposition of

the amendments of the Partnership agreement and better explanation of how the priorities of

the Partnership agreements are reflected in OPRG. Concrete proposals are given below.

It needs to be stressed that OPRG 2014-2020 is one of the leading sectoral programmes with

regards to the Strategic territorial priority: “Spatial development and place-based

development policies” and more specifically of sub-priority “place-based development

policies” in parts “Sustainable and integrated urban development” and “Areas with potential

for tourism development”, as well as of “Spatial dimension of the strategic priorities for

sustainable, intelligent and inclusive growth”.

The description of the cohesion with the PA needs to be complemented with information

regarding the supporting functions of OPRG in regard to Priority 1 “Education, qualification

and employment for inclusive growth”, Priority 2 “Scientific research, innovation and

investments for intelligent growth” and Priority 3 “Connectivity and green economy for

sustainable growth”.

With regards to the mentioned challenges, the amendments in the wording of the specific

challenges needs to be reviewed using Table 8. “Relation between the challenges from the

analysis, strategic priorities, thematic objectives and the list of Programmes” from the last

version of the Partnership agreement from 13 August 2013.

The challenge ”Insufficient economic activity of the population and entrepreneurship

(NEET, Active Aging)” mentioned in OPRG 2014-2020 has been formulated as

“Insufficient economic activity of the population (youths, elderly people, women)”;

The challenges ”Inefficient use of resources” and ”Inefficient use of energy”

mentioned in OPRG 2014-2020 have been consolidated in the current version of the

PA;

The challenge ”Low level of healthcare” mentioned in OPRG 2014-2020 has been

formulated as “Last but one ranking in Europe for healthcare”;

The challenge ”Insufficient sectoral and geographical mobility of the work force“ is

not present in the current version of the PA;

In addition to the remarks mentioned above, in the text of OPRG other challenges need to be

addressed for which in the PA is indicated that OPRG would act as a supporting programme,

such as:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

56

Unsatisfactory quality of the educational system, increase of the illiterate population

and increase in the share of young people not attending school lessons;

One of the highest standardized coefficients for all death causes

Ineffective systems for prevention, management and addressing risk consequences (if

Priority axis 7. Risk prevention is included);

In case these recommendations are taken under consideration, information concerning how

the OP will respond to them has also to be provided.

The recommendations above are taken into account in the latest version of OPRG,

16.09.2013.

Evaluation of the description, applicability and the degree of implementation in OPRG

2014-2020 of the ex-ante conditionalities and description of the actions taken

In accordance with the Common Provisions Regulation requirements, the operational

program text should point out the ex-ante conditionalities, relevant to all priority axes whose

performance or failure will affect the program. With reference to each applicable

conditionality, the specific priority to which it relates is indicated, and it is explained which

of the criteria are met and which are not. This information is filled out in Table 24 in the text

of the program. A description of the measures to be taken is required and, respectively, the

responsible institutions and terms for implementation.

Based on the review of the conditionalities set out into the OPRG text (version 13.05.2013)

and the requirements for Bulgaria in the Partnership Agreement, version 3.0. from 13 August

2013, the following was established:

The description in Table 24 includes the applicable thematic ex-ante conditionalities, as set

out in Annex 3 of the PA and are relevant to the implementation of OPRG 2014-2020 with

the two exceptions, listed below.

The description in Table 26 should include actions that will be taken to implement the

outstanding criteria with respect to applicable conditionalites and correspond to the

descriptions in Annex 4 of the PA.

The applicable ex-ante thematic conditionalities that are included in the program (Table 24)

refer to the following:

• 7.1. Road transport;

• 9.1. Early school leaving;

• 9.2. Higher education, and

• 10.3. Health.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

57

There is an indication for the criteria for assessing the performance, the actions to be taken

and the responsible institutions.

In Table 24 (OPRG 2014-2020, 09.09.2013), there is no relevant precondition with respect

to 4.1. - "Actions have been carried out to promote cost-effective improvements of end-use

energy efficiency and cost-effective investments in energy efficiency when constructing or

renovating buildings". In the latest version of OPRG, 16.09.2013, the table is updated.

At the same time, in PA, Annex 3, this ex-ante conditionality is listed as partially met, in

particular due to not implemented foreseen action, including “measures to ensure minimum

requirements are in place related to the energy performance of buildings Articles 3, 4 and 5

of Directive 2010/31/EU”. This text should find its place in Table 24.

In addition, at the extent to which the Programme aims to contribute to the implementation of

the National Strategy for Integration of Roma, it may be considered as relevant ex-ante

conditionality “10.2. National strategic policy framework for Roma integration has been

introduced” (Annex 3 PA, aforementioned version). The condition as specified in PA is met,

but its inclusion in Table 24 is necessary for the completeness of the information.

With the removal of these shortcomings, the list of applicable ex-ante conditionalities would

be comprehensive and would correspond to those given in Annex 4 of Draft PA version 3.0

of 08/13/2013 conditionalities relating to the implementation of OPRG 2014-2020.

In separate Table 26 of OPRG in accordance with the requirements, a description of the

actions to be undertaken for the implementation of relevant thematic conditionalities with

respect to the outstanding criteria is made. Deadlines and responsible institutions are

indicated.

There are inconsistencies between the OPRG and PA texts. It is difficult to make an

exhaustive list since many terms and descriptions are mixed, such as: Annex 4 of the PA is

quoted as benchmark under 7.1. “Existence of comprehensive transport plan (s) or frame(s)

for transport investments .......” but as planned actions - Strategy for development of road

infrastructure in the Republic of Bulgaria 2014-2020. Meanwhile, in the OPRG 2014-2020,

Table 26 indicates the development of a general transport actions plans.

Below are listed some of the more important inconsistencies that were identified in

OPRG 2014-2020, 09.09.2013:

Discrepancies related to listed ex-ante conditionalities:

In Table 26, there is no conditionality 4.1. – "Actions have been carried out to promote cost-

effective improvement of end-use energy efficiency and cost-effective investments in energy

efficiency when constructing or renovating buildings."

In Annex 4 of the PA it is included because of benchmarks. Specifically: “measures to ensure

minimum requirements are in place related to the energy performance of buildings consistent

with Articles 3, 4 and 5 of Directive 2010/31/EU”. Actions (directly affecting MRD) which

have to be taken are listed, namely:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

58

o Action 1 with responsible institutions MEE and MRD and deadline 01.09.2013:

Update of the “Regulation for energy efficiency audits, certification and

assessment of energy savings in buildings, which will be repeal Regulation №

RD-16-1057 of 2009 on procedures for conducting energy audits and certification

of buildings” and “Regulation for amending and supplementing Regulation № 5

of 2006 on buildings’ technical passports”

o Action 2 with responsible institutions MEE and MRD and deadline 31.12.2013:

Amendment of Regulation № RD 16-1058 of 10 December 2009 on indicators for

energy consumption and energy performance of buildings, taking into account the

Delegated Commission Regulation № 244/2012 requirements, which supplements

Directive 2010/31/EU, published on 21 March 2012 in "Official Gazette" of the

European Union.

o Action 3 with responsible institutions MEE and MRD and deadline December

2013: Amendment of Regulation № 7 for energy efficiency, heat and energy

savings in buildings.

It is necessary these texts to be incorporated in the description of Table 26.

Inconsistencies regarding Actions that should be undertaken

Regarding 7.1. Transport: the text of the OPRG does not include “Action 2 - Mid-term review

of the Strategy for the development of the transport sector of the Republic of Bulgaria 2020”

with deadline December 2015.

Regarding 9.1. Early school leaving: in the OPRG text are not included Action 1 “Adoption

of a Strategy on prevention and reduction of dropouts and early school leavers (2013 -

2020)” with deadline October 2013 and Action 2. Adoption of Updated National Youth

Strategy (2013-2020) with deadline December 2013. Instead it is envisaged the

“Development of a National Strategy for Lifelong Learning for 2014-2020”, which is not

consistent with action 9.1.

Regarding 9.2. Higher education: in the OPRG text it is not included Action 1 - Adoption of a

separate strategy for higher education with period of implementation- May 2014

Non-compliance with the periods/terms

There is inconsistency regarding 7.1: in OPRG is stated June 2013, in PA - November 2013.

In general, the following conclusions can be made:

o Tables 24 and 26 regarding thematic ex-ante conditionalities and their

implamentation should be prepared in accordance with the updated information set

out in Annexes 3 and 4 of the PA;

o Conditionality provisions relate to priority national policies on energy efficiency,

transport, education and health, the implementation of which OPRG plans to support.

According to Annex IV of the General Regulation, 9.1 and 9.2 are ex-ante

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

59

conditionalities relating to the ESF. However, given the scope of the OPRG 2014-

2020, in the opinion of the assessment team, these conditions are also relevant to

OPRG;

o Indeed, the performance of these thematic ex-ante conditionalities, however, with

partial exceptions (referring to 7.1 and 4.1), is related to the sectors for which other

institutions are responsible, respectively, line ministries and departments. For this

reason, the commitments of MA are not direct, but refer to monitor progress and

coordination under the Partnership Agreement so that the program or separate

priority axes would not be jeopardized.

The inconsistencies listed above are corrected in the latest version of OPRG 2014-2020,

16.09.2013.

Complementarity and demarcation lines regarding the other operational programmes

On the following pages we present commentaries on the complementarity and demarcation,

described in Section 9 of Operational Programme “Regional Development” (OPRG) 2014-

2020. Only the programmes on cross-border cooperation have not been commented since the

evaluation team does not have a version of these programmes.

As discussed during the focus group in June 2013 with representatives of the managing

authorities and the central coordinating unit, the demarcation and the complementarity

between the separate programmes has not been clarified yet at national level, including in the

Partnership Agreement. A large part of the commentaries below were discussed within the

focus group.

Operational Programme Environment (OPE)

OPE

Priority Axis 1: Water

1.1. Protection and enhancement of the state of the water resources

1.2. Improvement of the conditions for reduction of the risk of flooding and drought

1.3. Increase of the innovations for resource efficiency and cleaner environment

Priority Axis 2: Waste

2.1 Sustainable management of waste for a resource-efficient and green economy

2.2 Increase of innovations for resource efficiency and cleaner environment

Priority Axis 3: Natura 2000 and biodiversity

3.1 Reducing the loss of biodiversity

The relation between OPRG and OPE is presented at the chart below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

60

OPE

OPRD

Sustainable and integrated urban development

1.1 1.2 1.3 1.4 1.5 1.6

State educational

infrastructure

2.1

Regional health

infrastructure

3.1

Regional social

infrastructure

4.1

Regional tourism

5.1

Regional road

infrastructure

6.1

Risk prevention

7.n

Water

1.1 1.2 1.3

Sewerage

1.1 1.2

Natura 2000 and

biodiversity

1.1

Figure 2: Relation between OPRG and OPE

Complementarity/

Demarcation

Reflection in the text of OPRG Recommendation

Priorities 1.1, 1.2, 1.3, 1.4,

2.1, 3.1, 4.1. and 5.1

complement Priority 1.3 of

OPE. The replacement and

construction of water supply

and sewerage systems for the

different types of

infrastructure will support,

albeit to a limited extent, the

intervention in the innovative

technologies for supporting

the water saving and reuse

measures.

Complementarity: Not reflected. It is

pointed out that the identified water

supply and sewerage systems in the

integrated plans on urban restoration

and development will complement the

measures under OPE.

Demarcation: Not reflected

To point out in the Complementarity

Section of OPRG that the investments

in building water supply and sewerage

systems along with the energy

efficiency measures will support

interventions for promotion of water

consumption in public and private

(multifamily residential) buildings and

in enterprises as well as introduction

of other water saving methods:

development and applying of

technologies for water recycling and

reuse in accordance with the Ministry

of Environment and Water

instructions for integration of the

environment and the climate change

policy in funds for the Cohesion

Policy, the Common Agricultural

Policy and the Common Fisheries

Policy for 2014-2020, as of February

2013.

To point out in the Demarcation

Section that the measures for

building/replacement of water supply

and sewerage systems in the buildings

are not supported under OPE.

Priority 7 (activities within

Priority Axis 7 have not been

specified yet) will support the

efforts of OPE to improve the

conditions and reduce the risk

of flooding through

infrastructure investments for

Complementarity: Not reflected.

Demarcation: It is pointed out that

OPRG will complement the measures

under OPE regarding prevention of the

risk of landslides. It is not pointed out

that, likewise, OPRG will complement

No specific recommendation can be

made as at the present moment given

that the activities under Priority

Axis 7 of OPRG have not been

finalized yet.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

61

prevention purposes. OPE with measures for prevention of

flooding through investments in such

infrastructure. It is also indicated that

OPRG will invest in the promotion and

development of the cultural and natural

heritage on the territory of the whole

country of national and world

relevance, including the sites of

NATURA 2000, on the basis of a list of

priority sites for financing.

Priority 1.2 is indirectly

related to Priority 1.1 of OPE

in terms of the need of

synergy between the

construction of pavements in

the population centres and the

laying of water pipes,

supported under OPE.

Complementarity:

OPRG reads: The construction/

rehabilitation/ reconstruction of the

water supply and sewerage

infrastructure (network) identified in

the integrated plans on urban

reconstruction and development –

within the impact areas in 39 towns of

1st, 2nd and 3rd level, and on the whole

urban territory of the towns of the 4th

level, as well as the territory of the

whole town for level 1-3, where the

activities for integrated public

transport are coordinated;

For the sake of clarity, it is

recommended to change the text as

follows:

The activities for the rehabilitation of

the urban road network supported

under Priority 1.2. of OPRG

complement and should be

coordinated with the activities for the

construction/ rehabilitation/

reconstruction of the water supply and

sewerage infrastructure (network),

supported under OPE within the

impact areas in 39 towns of 1st, 2nd

and 3rd level, and on the whole urban

territory of the towns of the 4th level.

Operational Programme Innovations and Competitiveness (OPIC)

OPIC

Priority Axis 1: Innovations and enterprise

1.1 Promotion of investments in research and innovation and promotion of relations between the

business and the research centres and provision of support for improved production capacities and

pilot production of key base technologies.

Priority Axis 2: Competitiveness and resource efficiency

2.1 Provision of support for enhancing the capacity of SMEs to increase their contribution to the

economic growth and the development of the innovation processes.

2.2 Promotion of the energy efficiency and the use of renewable energy sources (RES) in the

enterprises.

2.3. Development and construction of LW and MW smart distribution networks.

2.4. Promotion of the use of high-efficient combined production of heat and electricity.

Priority Axis 3: Financial instruments

3.1. Promotion of enterprise through support of the development of new business ideas and the launching of new

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

62

companies.

3.2. Promotion of investments into business innovations and enhancing the energy efficiency of enterprises.

The relation between OPRG and OPIC is presented at the chart below:

OPIC

OPRD

Sustainable and Integrated urban development

1.1 1.2 1.3 1.4 1.5 1.6

State educational

infrastructure

2.1

Regional health

infrastructure

3.1

Regional social

infrastructure

4.1

Regional tourism

5.1

Regional road

infrastructure

6.1

Risk prevention

7.n

Innovation and

Entrepreneurship

1.1

Competitiveness and resource

efficiency

2.1 1.2

Financial

instruments

3.23.12.2 2.3 2.4

Figure 3: Relation between OPRG and OPIC

Complementarity/ Demarcation Reflection in the text of

OPRG

Recommendation

Priority 1.2 of OPRG is related to the

activities, which will be assisted under

priorities 1.1, 2.2 and 2.4 of OPIC– the

relations are shown in the table below.

While some of the activities under OPRG

complement ones, envisaged in OPIC,

such as improvement of the conductive

and connecting infrastructure to business

zones, others overlap – building of

industrial zones, implementation of

measures for energy efficiency of business

buildings; production of energy from RES

and energy audits. The overlapping

between the two programmes is presented

in the table below.

Complementarity: There is

no text for complementarity

with OPIC.

– Demarcation: It is

pointed out that

OPRG supports the

development of

areas with

potential for

economic

development within

the Integrated Plan

for Urban

Reconstruction and

Development

(IPURD). OPIC

supports the

development of

economic areas

outside the scope

of IPURD of the 67

towns,

technological

parks of national

relevance.

The OPIC text does not

To establish the complementarity

and eliminate all possible

overlapping between the two

programmes in a discussion with the

experts working on the OPIC texts.

The text in the Demarcation Section

should be rendered more precise in

terms of what would be supported

under each of the two programmes.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

63

make it obvious that the

development of the

economic areas will be

outside the scope of the

urban development plans

and outside the towns.

Priorities 1.3 and 5.1 complement Priority

2.1 of OPIC.

Priority 1.3 of OPRG envisages measures

for development and building of culture-

related infrastructure.

The infrastructure measures in culture

have tourist potential. These measures will

be supported by the tourist campaigns

under OPIC.

Priority 5.1 of OPRG supports the

development of cultural attractions and

tourist infrastructure, including

information centres, as well as non-

infrastructure activities, related directly to

the supported attractions (organizing of

events in the area of the attractions,

marketing and advertising activities).

Priority Axis 2.1 of OPIC envisages

activities for tourist information services,

promotion and marketing of tourism

(events, initiatives, campaigns) at national

and regional level (Marketing,

Advertising and Information in Tourism

Directorate and Tourist Policy Directorate

at the Ministry of Economy, Energy and

Tourism).

Complementarity: There is

no text for complementarity

with OPIC

Demarcation: It is pointed

out that OPRG supports the

development of regional

tourist marketing as well.

OPIC supports national

tourist marketing.

There is a possibility for

duplication of activities,

related to tourist advertising

and marketing.

A text describing how the

construction of cultural and tourist

infrastructure will support the

activities under OPIC should be

added in the Complementarity

Section.

A discussion with the experts

working on the OPIC texts should

define clearly the demarcation line

between the two programmes

regarding tourist advertising and

marketing.

The text regarding differentiation of

tourist marketing in the two

programmes in the Demarcation

Section should be rendered more

precise (OPIC points out events at

national and regional level).

Relation between Priority 1.2 of OPRG and priorities 1.1, 2.2 and 2.4 of OPIC

Priority 1.2 of OPRG envisages support for:

Improvement and reconstruction of the existing or

construction/ development of new technical

infrastructure, related to business, such as

communication links, construction/ reconstruction/

rehabilitation of streets providing access to industrial

and business zones, electricity supply, public lighting,

connections to the main gas supply, water supply and

sewerage network, placement of signs and

information boards, security systems by or within the

business zones and terrains, etc. within the areas with

At the same time OPIC envisages:

Within 1.1

Support for the development of technological parks,

coordinating centres, offices for technological transfer,

laboratories for proving of concepts and certification

laboratories.

Within 2.2

Support for enhancement of energy efficiency of

enterprises: includes conducting of energy audits,

feasibility studies and technical specifications;

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

64

potential for economic development within IPURD;

Construction, renewal, rehabilitation, reconstruction

and repair of business and industrial zones in areas

with potential for economic development within

IPURD, including buildings;

Implementation of energy efficiency measures in the

above buildings/premises, including heating

insulation, replacement of door and window frames,

local installations and/or connection to the heat

supply, gas supply systems, etc.;

Setting into operation of plants for power generation

from RES in the above buildings to meet the own

needs of energy, where this is technically feasible and

economically expedient;

Energy audits and construction audits in the above

buildings.

introduction of technologies resulting in enhancement

of energy efficiency or reduction of the energy intensity

of production; improvement/replacement of start-up

engines and systems; improvement of energy systems

and replacement of the energy input; utilization of

waste heat; supply of equipment, related to the more

efficient use or recycling of waste products as well as

equipment for the manufacture projects subject to

recycling; construction and installation works leading

to reduction of the energy intensity of the building stock

of the enterprises; introduction of RES systems;

introduction of energy management systems.

Within 2.4.

Drafting of an energy audit driven project, feasibility

studies and technical specifications;

Operational Programme Human Resources Development (OPHRD)

OPHRD

Priority Axis 1: Improvement of access to employment and quality of jobs

1.1 Access to employment for job-seeking and non-active persons, including local employment

initiatives, and support for workforce mobility

1.2 Sustainable integration of young people, aged 15 to 24, into the labour market, in the sectors of

employment, education and training and, in particular, in the context of the Guarantee for Youth.

1.3 Self-employment, enterprise and establishment of enterprises.

1.4 Improvement of the access to life-time learning, enhancing workforce skills and qualification and

better coordination of the education and training system and the labour market.

1.5 Adjustment of workers, enterprises and entrepreneurs to change.

Priority Axis 2: Reduction of poverty and promotion of social inclusion

2.1 Integration of marginalized communities, such as the Roma

2.2 Active inclusion

2.3. Promotion of social economy and social enterprises.

Priority Axis 3: Modernization of labour market institutions, social inclusion and healthcare

3.1. Investments in the institutional capacity and the efficiency of public administrations and public

services in view to implementing the reforms and achieving better regulation and management.

3.2. Capacity building regarding interested parties implementing policies in the field of employment,

education and the social sphere, as well as sectoral and territorial agreements for mobilization with

the purpose of implementation of reforms at national, regional and local level.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

65

Priority Axis 4: Transnational cooperation

4.1 Promotion of transnational cooperation in the field of labour market, social inclusion and

strengthening of institutional capacity.

4.2. Promotion of cooperation of the interested parties from the region of the Danube river in the

area: “Investing in People and Skills”, of the EU Strategy for the Danube Region.

The relation between OPRG and OPHRD is presented at the chart below:

OPRD

Sustainable and Integrated urban development

1.1 1.2 1.3 1.4 1.5 1.6

State educational

infrastructure

2.1

Regional health

infrastructure

3.1

Regional social

infrastructure

4.1

Regional tourism

5.1

Regional road

infrastructure

6.1

Risk prevention

7.n

Reducing poverty and promoting social

inclusion

2.1 2.2 2.3

Modernization of the labor market institutions, social inclusion and health care

3.1 3.2

Transnational

cooperation

4.1

Improving access to and quality of

employment

1.1 1.2 1.3 1.4 1.5 4.2

Figure 4: Relation between OPRG and OPHRD

Complementarity/ Demarcation Reflection in the text of

OPRG

Recommendation

Priority 1.2 of OPRG complements the

activities under Priority 1.4 of OPHRD.

The investments in business structure

complement the investments in human

resources in the industrial zones and high-

tech enterprises.

Complementarity: The text

of OPRG reads: Assisting

SME for qualification and

infrastructure measures

under OPRG in support of

the separate areas with

potential for economic

development, the said

measures being oriented

towards establishment of

business zones.

Demarcation: There is no

OPRG text involving any

differentiation between the

two measures.

The text regarding complementarity

is not very precise and needs to be

clarified as follows:

The investments in business

infrastructure under OPRG (support

for the establishment of separate

areas with potential for economic

development and business zones)

are supported by investments in

human resources under OPHRD for

the purpose of the provision of

possibilities to enhance the

qualification of the workforce. This

mutual support is expected to

promote the development of

business and SMEs.

The Demarcation Section should

also be supplemented by pointing

out that OPRG invests in business

infrastructure, while OPHRD

provides support for measures for

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

66

investments in human resources.

Priorities 1.4, 3.1 and 4.1 of OPRG –

investments in health and social

infrastructure – complement the measures

within OPHRD under priorities 2.1

(provision of access and rendering of

social and health services to marginal

groups), 2.2 (support for local and social

activities, development of the capacity of

providers of social and health services)

and 3.1. (investments in institutional

capacity and the efficiency of public

administrations and public services in the

area of social services and healthcare).

Complementarity: The

OPRG text reads: Support

for the implementation of

“soft measures”, equipment

and furnishing for the social

sector facilities financed

under OPRG 2014-2020;

Support for training,

qualification and re-training

within the impact areas in

39 towns of 1st, 2nd and 3rd

level, and on the whole

urban territory of the towns

of the 4th level, with a

special focus on socially-

disadvantaged, vulnerable

and minority groups of

people;

There is no relation between

OPRG and the training and

qualification of unemployed,

socially disadvantaged and

minority groups.

Demarcation: The OPRG

presents very clearly the

demarcation line between

the two programmes

regarding support in the

health and social sphere.

The text regarding complementarity

is not very precise and needs to be

clarified as follows:

The investments in the social and

health infrastructure in the

municipalities and at local and

regional levels promote the

provision of social and health

services under OPHRD.

Operational Programme Transport and Transport Infrastructure (OPTTI)

OPTTI

Priority Axis 1: Development of road and railway infrastructure along the “main” trans-European

transport network (TEN-T)

1.1 Development of road infrastructure along the “main” Trans-European transport network (TEN-T);

1.2 Development of railway infrastructure along the “main” Trans-European transport network (TEN-

T).

Priority Axis 2: Development of road and railway infrastructure along the “extended” TEN-T

2.1 Development of road infrastructure along the “extended” Trans-European transport network

(TEN-T);

2.2 Development of railway infrastructure along the “extended” Trans-European transport network

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

67

(TEN-T)

Priority Axis 3: Improvement of intermodality in passenger and freight transport and development of

sustainable public transport

3.1 Improvement of intermodality in freight transport;

3.2 Improvement of intermodality in passenger transport.

Priority Axis 4: Innovations and management of services – installation of upgraded infrastructure for

traffic management, enhancement of safety and security of transport

4.1 Introduction of modern traffic management systems;

4.2 Purchase of locomotives and rolling stock;

4.3 Supply of specialized ships.

The relation between OPRG and OP Transport is presented at the chart below:

OPTTI

ОПРР

Sustainable and urban integrated development

1.1 1.2 1.3 1.4 1.5 1.6

State educational

infrastructure

2.1

Regional health

infrastructure

3.1

Regional social

infrastructure

4.1

Regional tourism

5.1

Regional road

infrastructure

6.1

Risk

prevention

7.n

Development of road and railway

infrastructure in the "extended"

TEN

2.1 2.2

Improvement of passengers

and cargo intermodality and

development of sustainable

urban transport

3.1 3.2

Innovations in management and services -

Introduction of modernized infrastructure

for traffic management, enhancing safety

and transport security

4.1

Development of road and railway

infrastructure in the “main” TEN

1.1 4.2 4.31.2

Figure 5: Relation between OPRG and OPTTI

Complementarity/

Demarcation

Reflection in the text of OPRG Recommendation

Priority 1.5 complements

priorities 1.1 and 2.1 of

OPTTI as far as improvement

of the road transport

infrastructure is concerned.

Complementarity: not reflected.

Demarcation: It is pointed out in the

opinion that as far as OPRG is oriented

towards improvement of the connections

between the national road network and

TEN-T, OP Transport finances road

projects within TEN-T. Main and

secondary roads outside TEN-T are

financed under the programme.

Information about the

programme's contribution to the

overall transport infrastructure and

the relation with the European

transport network should be added

to the OPRG text, Demarcation

Section.

Sustainable urban mobility Complementarity: Not reflected. The In the Complementarity Section,

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

68

under Priority 1.5 of OPRG

has potential common ground

with priorities 3.1 and 3.2 of

OPTTI regarding construction

and reconstruction of railway

station complexes and the

underground in Sofia.

common ground concerns intensified

participation in electric transport (and,

respectively, improvement of ambient air

quality), reduction of traffic jams,

development of infrastructure route

network with new destinations, etc. The

improvement of the intermodality in

passenger transportation and, respectively,

the extension of the Sofia underground are

directly related to these processes.

Demarcation: Not reflected.

it should be pointed out that in the

course of the implementation of

projects on sustainable urban

mobility under Priority 1.5 of

OPRG the projects/results of

priorities 3.1 and 3.2 of OPTTI

regarding construction and

reconstruction of railway station

complexes and the Sofia

underground will be taken into

account in view to ensuring

synergy.

The differences between the

interventions under OPRG and

OPTTI in the area of urban

transport infrastructure should be

described in the Demarcation

Section.

Operational Programme Science and Education for Smart Growth (OPSESG)

OPSESG

Priority Axis 1: Research and technological development

1.1 Strengthening of the infrastructure needed for research and innovation activity, enhancing the capacity for

implementation of the achievements in research and development, enhancing the capacity to implement the

achievements in research and innovation and promotion of the competence centres and, in particular, centres of

interest for Europe.

Priority Axis 2: Education for actual employment, mobility and enterprise

2.1 Access to employment of job seekers and non-active persons, including local employment initiatives, and

support for workforce mobility.

2.2 Modernization and strengthening of the labour market institutions, including education and training systems,

which cover strengthening of transnational workforce mobility.

Priority Axis 3: Promotion of education, skills and life-time learning

3.1 Reducing of early school leaving and promotion of equal access to high-quality pre-school, primary and

secondary education;

3.2 Improving the quality, efficiency and access to tertiary or equivalent attainment with the purpose of

increasing of involvement and improving education levels.

3.3 Enhancing the access to possibilities for life-long learning, enhancing workforce skills and qualification and

enhancing the adequacy of the education systems and training against the requirements of the labour market.

Priority Axis 4: Educational environment for active social inclusion

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

69

4.1 Active inclusion;

4.2 Integration of marginalized communities.

Priority Axis 5: Educational and information and communication technology (ICT) infrastructure

5.1 Investments in education, skills and life-time learning through building of educational and training

infrastructure;

5.2 Improving the access to ICT and their use and ensuring quality through intensive use of ICT-based

applications.

Priority Axis 6: Transnational cooperation

The relations between OPRG and OPSESG are presented at the chart below:

OPSESG

OPRD

Sustainable and integrated urban development

1.1 1.2 1.3 1.4 1.5 1.6

State educational

infrastructure

2.1

Regional health

infrastructure

3.1

Regional social

infrastructure

4.1

Regional tourism

5.1

Regional road

infrastructure

6.1

Risk

prevention

7.n

Education for actual

employment, mobility

and entrepreneurship

2.1 2.2

Насърчаване на образованието, уменията и ученето през целия живот

3.1 3.2

Promote education,

skills and lifelong

learning

4.1

Research and

Technological

Development

1.1 4.2

Educational and

ICT infrastructure

5.1 5.2

Transnational

cooperation

3.3

Figure 6: Relation between OPRG and OP SESG

Complementarity/

Demarcation

Reflection in the text of OPRG Recommendation

Priorities 1.3 and 2.1 for

investments in the educational

infrastructure are

complemented by priorities

3.1, 3.2, 5.1 and 5.2 of

OPSESG, which envisage

measures for improving the

quality of education and the

access to education (3.1),

improving the quality and

access to higher education

(3.2) and investments in

educational infrastructure –

schools and universities (5.1)

Complementarity: It is reflected as

support on the part of OPSESG for the

implementation of “soft measures”,

equipment, furnishing and ICT for

financing under OPRG 2014-2020 of

facilities in the educational and research

spheres.

Demarcation: Reflected

There is a possibility of overlapping of

Priority 2.1 of OPRG and Priority 5.1 of

OPSESG. Both programmes envisage

investments in the building of educational

It is good to extend and

supplement the text regarding the

complementarity focusing on ICT

infrastructure.

Apart from the pointed measures,

OPSESG supports the building of

educational infrastructure with the

exception of cities supported in

terms of integrated urban

development under OP Regions in

Growth 2014-2020. There is a

possibility for overlapping, i.e.

financing of the same activities

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

70

and information and

communication technologies

(5.2).

infrastructure in the country.

under both programmes, which is

inefficient and should not be

allowed. Section 3, mechanisms

for coordination of funds under the

Common Strategic Framework

(CSF) of the Regulation laying

down common provisions 2014-

2020 says that duplication should

be avoided.

Operational Programme Good Governance (OPGG)

OPGG

Priority 1: Enhancing the institutional capacity, effectiveness and efficiency of the public administration

and the judiciary.

1.1 Measures enhancing the institutional capacity, effectiveness and efficiency of the public

administration;

1.2 Measures enhancing the capacity, effectiveness and efficiency of the judiciary.

Priority 2: Provision of high-quality services to citizens and business and development of e-governance and

justice

2.1 Measures, related to the provision of integrated administrative services, including e-governance;

2.2 Measures, related to e-justice

Priority 3: Effective and efficient absorption of the EU funds

3.1 Measures, related to maintenance, development and optimization of the management,

coordination, monitoring, control and audit of the EU funds;

3.2 Measures, related to the development and improvement of the information systems for EU funds

management.

The relation between OPRG and OPGG is presented at the charter below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

71

OPGG

OPRD

Sustainable and integrated

urban development

1.1 1.2 1.3

1.4 1.5 1.6

State educational

infrastructure

2.1

Regional health

infrastructure

3.1

Regional social

infrastructure

4.1

Regional

tourism

5.1

Regional road

infrastructure

6.1

Risk

prevention

7.n

Providing quality services for the citizen and

businesses and developing e-government

and e-judiciary

2.1 2.2

Enhancing the institutional capacity,

effectiveness and efficiency of public

administration and judiciary system

1.1

Effective and efficient absorption

of EU funds

3.1 3.21.2

Technical

assistance

Figure 7: Relation between OPRG and OPGG

Complementarity/

Demarcation

Reflection in the text of OPRG Recommendation

The main relation between the

two programmes is related to

enhancing the administrative

capacity, i.e, Priority Axis,

Technical Assistance, of

OPRG and, respectively,

priorities 3.1. and 3.2 of

OPGG.

Complementarity: Not reflected.

Demarcation: Reflected as difference

of the scope of OPRG and OPGG.

While OPRG, in its section about

capacity strengthening, is oriented

towards the Managing Authority and

the beneficiaries of the programme,

OPGG supports in general public

administration and public services,

related to the European Regional

Development Fund and the European

Social Fund.

It should be pointed in the

Complementarity Section of OPRG

that the programme contributes to the

attainment of the OPGG goals and

that through the technical assistance

strengthens the administrative

capacity of the Managing Authority

and the beneficiaries.

Rural Development Programme (RDP)

RDP

Priority 2: Enhancing farm viability and the competitiveness of all types of agriculture and promoting

innovative technologies in agriculture

Priority area 2A: Improving the economic performance of all farms and facilitating the restructuring and

modernization of farms, in particular, with a view to increasing market participation and orientation and

diversification in agriculture.

Priority area 2B Promoting the entry of qualified farmers in agriculture and, in particular, the continuity of

between the generations in the agricultural sector.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

72

Priority 3: Promoting food chain organisation, humane treatment of animals and risk management in

agriculture

Priority area 3A: Enhancing competitiveness by better integrating primary producers into the food chain

through quality schemes to add value to farm products, promotion in local markets and short supply circuits,

producer groups and inter-branch organisations.

Priority area 3B: Supporting farm risk prevention and management of farms

Priority 4: Restoring, preserving and enhancing ecosystems, related to agriculture and forestry

Priority area 4A: Restoring, preserving and strengthening of biodiversity, including in Natura 2000 areas and

high nature value farming, areas facing natural or other specific constraints and the state of European

landscapes.

Priority area 4B: Improving water management, including management of fertilizers and pesticides

Priority area 4C: Prevention of soil erosion and improving of their management

Priority 5: Promoting resource efficiency and supporting the shift towards a low carbon and climate

resilient economy in agriculture, food and forestry sectors

Priority area 5A: Increasing efficiency in water use by agriculture.

Priority area 5B: Increasing efficiency in energy use in agriculture and food processing.

Priority area 5C: Facilitating the supply and use of renewable sources of energy, of by-products, wastes,

residues and other non-food raw material for purposes of the bio-economy.

Priority area 5D: Reducing greenhouse emissions in agriculture.

Priority area 5E: Fostering carbon conservation and sequestration in agriculture and forestry.

Priority 6: Promoting social inclusion poverty reduction and economic development in rural areas

Priority area 6A: Facilitating diversification, creation of new small enterprises and job creation.

Priority area 6B: Fostering local development in rural areas.

Priority area 6C: Enhancing accessibility to, use and quality of ICT in rural areas.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

73

The relation between OPRG and RDP is presented at the charter below:

RDP

OPRD

Sustainable and integrated urban development

1.1 1.2 1.3 1.4 1.5 1.6

State educational

infrastructure

2.1

Regional health

infrastructure

3.1

Regional social

infrastructure

4.1

Regional tourism

5.1

Regional road

infrastructure

6.1

Risk prevention

7.n

4.А 4.Б 4.В5.А 5.Б 5.В 5.Г 5.Д

2.А 2.Б 3.А 3.Б 6.А 6.Б 6.В

Figure 8: Relation between OPRG and RDP

Complementarity/ Demarcation Reflection in the text of

OPRG

Recommendation

Priorities 1.1. and 1.5. of OPRG and priorities

5C, 5D and 5E of RDP contribute to the

promotion and use of RES and reduction of

greenhouse emissions.

Priority 1.2 of OPRG and Priority 6B of RDP are

complemented in terms of improving the urban

(OPRG) and rural environment (RDP). Priority

5.1 of OPRG also complements the activities

under Priority 6B of RDP regarding the

development of tourism.

Enhancing of mobility is supported under Priority

6.1 of OPRG through improvement of the

infrastructure of road junctions connecting

secondary secondary roads to TEN-T and the

municipal road infrastructure in the rural regions

under Priority 6B of RDP.

The investments in the regional health and social

infrastructure under Priority 3.1. of OPRG are

complemented by measures improving local

services, related to healthcare, education and

security under Priority 6B of RDP.

Complementarity: Not

described in OPRG,

09.09.2013.

Demarcation: The

complementarity with

RDP is described.

OPRG, 16.09.2013, contains a

description of the

complementarity between

OPRG and RDP.

Maritime Affairs and Fisheries Programme (MAFP)

MAFP

Priority Axis 1: Promotion of sustainable fisheries and aquacultures including the related processing

entailing efficient use of resources

1.1 Promotion of the shift to maximum sustainable fishing, phasing out of discards; reduction of the

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

74

impact of fishing on the marine environment and adjustment of fishing to species protection

1.2 Mitigation of the consequences of climate change

1.3 Services for environment and organic production

Priority Axis 2: Promotion of innovative, competitive and knowledge-based of fisheries and aquacultures,

including the related processing

2.1 Promotion of competitive fisheries

2.2. Promotion of competitive aquacultures

2.3 Granting of powers to producers and provision of better coordination along the value chain

Priority Axis 3: Promotion of the implementation of the Common Fisheries Policy through the pursuit of

specific goals

3.1 Provision of high-quality data collection and analysis, respectively

3.2. Provision of efficient control, monitoring and law enforcement system

Priority Axis 4: Increasing of employment and territorial cohesion

4.1. Increasing growth, employment and territorial cohesion in the fisheries areas

4.2. Promotion of local and international cooperation

Priority Axis 5: Strengthening of the implementation of the Integrated Maritime Policy

5.1. Supporting integrated maritime surveillance

5.2. Promotion of the protection of the marine environment

The relation between OPRG and MAFP is presented at the chart below:

PMAF

OPRD

Sustainable and integrated urban development

1.1 1.2 1.3 1.4 1.5 1.6

State educational

infrastructure

2.1

Regional health

infrastructure

3.1

Regional social

infrastructure

4.1

Regional tourism

5.1

Regional road

infrastructure

6.1

Risk prevention

7.n

1.1 1.2 1.3 3.1 3.22.1 2.2 2.3 4.1 4.2 5.1 5.2

Figure 9: Relation between OPRG and MAFP

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

75

Complementarity/ Demarcation Reflection in the text of

OPRG

Recommendation

The measures for energy efficiency and

promotion of the low-carbon strategies under

priorities 1.1. and 1.5 of OPRG in 67 priority

population centres are complemented by the

measures for introducing low carbon

technologies and solutions and increasing the

energy efficiency of the activities in the sectors of

fisheries and aquacultures, including fishing

vessels, ports, farms for aquacultures and

processing of fishery and aquaculture products

under Priority 1.2 of MAFP.

Complementarity: not

reflected

Demarcation: It is pointed

out that investment and

territorial overlapping

between OPRG and MAFP

is not envisaged.

To point out the

complementarity between

priorities 1.1 and 1.5 of

OPRG and Priority 1.2 of

MAFP regarding low-carbon

economy and energy

efficiency.

IV. Evaluation 2 – Assessment of the internal

consistency of the Program

The analysis of indicators in this section was updated in May 2014 in order to cover the

significant changes in the system of indicators.

1. Data collection

Evaluation 2 was carried out in parallel with Evaluation 1. For analysis purposes, it has used

the information obtained through the desk research described above and the online

questionnaire. The questionnaire includes questions targeted at the (potential) beneficiaries

as regards their capacity and views on the strategy of OPRG 2014-2020. The internal

consistency of the Program has also been discussed in interviews with experts of DG RDP.

This issue has been among the topics of the impending working groups and interviews.

2. Analysis

Overview of the needs identified in ORDP 2014-2020

The inclusion of the needs’ description is a basic element of each program as the objectives

are defined on the basis of the needs and consistency with regional, national, and European

documents. Under this form for OP development, item 2.1 should contain the following:

A description of the OP strategy regarding its contribution to achieving the objectives

of Europe 2020 Strategy and the achievement of economic, social and territorial

cohesion.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

76

Description of the relevant regional and, where appropriate, national development

needs, including the challenges identified in the specific recommendations of the

Council for the country (Art. 121 (2) and Art. 148 (4) TFEU)

Description of how OP will address these needs and challenges, and thus will

contribute to achieving the Europe 2020 strategy, where appropriate, with reference to

existing national or regional strategies for convergence, corresponding to the Europe

2020 Strategy, including the National Reform Programme where applicable, and a

preliminary assessment.

Also, the Form indicates that the OP strategy should be in accordance with the General

Strategic Framework, the Partnership Agreement and the applicable elements of the views of

the Commission.

Within the program compliance has been fully described with respect to:

National Reform Programme 2012-2020;

National Development Programme Bulgaria 2020 (NPRB2020);

National Strategy for Regional Development 2012-2022;

The National Spatial Development Concept for the period 2013-2025, the (NSDC);

Territorial Agenda 2020 of EU;

Partnership Agreement.

Some of the descriptions are too exhaustive and could be shortened. In this regard, some

additional concrete proposals for cutting the text were sent to the Contracting Authority.

Specific comments/recommendations regarding OPRG 2014-2020 Table 1 are:

Separation of investment priorities, although they belong to the same thematic

purpose - thus greater clarity about the strategy of the program will be achieved and it

will be easier to meet the restrictions of the OP Form.

The quoted need to overcome the "low energy efficiency, which negatively affects

competitiveness" has no direct relation with the program measures as it refers to

industry, as quoted in NDPB 2020 "outdated machines used in enterprises." In this

sense, it should be pointed out another need that is relevant to OPRG strategy 2014-

2020 in terms of energy efficiency.

The table does not specify any needs regarding Investment Priority "Actions to

improve the urban environment, including regeneration of brownfield sites and

reduction of air pollution." The indicated compliance with Sub-priority 3.2.

“Promotion of cities and improvement of the integration of Bulgarian regions

nationally (NDP Bulgaria 2020) is general in nature, while the investment priority is

more specific.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

77

With respect to IP "Improvement of regional mobility through connecting secondary

and tertiary nodes to the infrastructure of the trans-European transport network" is

referred to as a specific need, but the need to improve the connections with the TEN-T

network was not mentioned.

The text of the program is to clarify how the 2014-2020 OPRG will address the needs

identified in the Table under Thematic Objective 9, for instance, how OPRG 2014-

2020 will address the identified insufficient economic activity of the population and

entrepreneurship. This also applies to the needs identified in the Table under

Thematic Objective 10, such as how OPRG 2014-2020 will help to reduce the number

of early school leavers.

Intervention logic

Comments on the intervention logic of all priority axes OPRG 2014-2020 are presented

below. The analysis examines in parallel the needs, planned activities, objectives, investment

priorities and thematic objectives, as well as the output and results’ indicators (general and

specific).

As pointed in the text of the OPRG 2014-2020, a horizontal element among the planned

activities is the obligation to include measures for improving energy efficiency in renovation

of buildings, funded under the Programme. In the analysis below, it is noted that for these

activities are not provided indicators. Given that they are concomitant, it is difficult and not

necessary to add indicators in the OPRG system of indicators because of the difficulty in

setting a target value. At the same time, the monitoring of the program and especially the

upcoming reports on environmental impacts, these activities should be reported with

indicators.

Priority Axis 1, Investment Priority 1.1

The understanding of the assessment team of the connections between the elements of OPRG

strategy 2014-2020 under PA1, IP1.1 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

78

Figure 10: Logic of PA1, IP1.1

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

79

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and planned

activities

Strong There is a direct connection between the

planned activities and needs.

Planned activities and

Specific Objectives

Strong Planned activities will contribute to the

achievement of the Specific Objectives.

Improving of access for people with

disabilities is not directly related to energy

efficiency, but it is included as a

horizontal principle. In the context of

program implementation, the surveys on

energy efficiency and the activities on

constructive strengthening are closely

related to energy efficiency.

Putting into operation of installations for

the production of energy from renewable

energy sources will not contribute to the

specific objective, but will contribute to

achieving the investment priority. In this

sense, the scope of the specific objective

could be expanded.

Specific Objective and

Investment Priority/

Thematic Objective

Strong The specific objectives will contribute to

the implementation of the investment

priority.

Indicators of output/result

and

Planned activities /

Specific objectives

Strong/It should

be improved

For Specific objective 1 there are good

links between the activities – output

indicator - result indicator - specific

objective.

For Specific objective 2 there is a good

link between the activities and the output

indicator, but the result indicator has a

very large range and is only partly linked

to the activities, the output indicator, and

the specific purpose.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

80

Priority Axis 1, Investment Priority 1.2, Specific Objective 1: Improving the quality of the

urban environment

The understanding of the assessment team of the connections between the elements of OPRG

strategy 2014-2020 under PA1, IP1.2, SO1 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

81

Figure 11: Logic of PA1, IP1.2, SO1

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

82

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and planned

activities

Should be

improved

As shown on the graph, there is a direct

connection for part of the activities

(restoration of recreational areas and

physical elements of urban environment).

The needs in terms of measures against

crime and controlled access systems in

pedestrian zones are not specified, but it is

assumed that they are part of the elements

of the urban environment.

Planned activities and

Specific Objective

Strong Planned activities contribute to the

Specific Objective.

Specific Objective and

Investment

Priority/Thematic

Objective

Should be

additionally

clarified

To avoid confusion, we recommend that

the text of the Programme give a brief

explanation as to the scope of the concepts

of urban environment / urban physical

environment.

Output/result Indicators

and

Planned activities /

Specific objective

Strong There is a clear link between the output

indicator and most activities. The result

indicator is linked to the output indicator

and the specific objective.

Priority Axis 1, Investment Priority 1.2, Specific Objective 2: Improving the economic

activity in the cities through regeneration of areas with potential for economic development

The understanding of the assessment team of the connections between the elements of OPRG

strategy 2014-2020 under PA1, IP1.2, SO2 is presented in the graph below:

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

83

Figure 12: Logic of PA1, IP1.2, SO2

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

84

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and

Planned activities

Strong The connection between the identified

poor state of the economic zones and the

planned activities in industrial zones is

strong.

Planned activities and

Specific objectives

Strong/

Satisfactory

The connection between construction and

reconstruction activities and the Specific

Objective are clear.

The other activities may potentially have

an indirect effect.

Specific Objective and

Investment Priority/

Thematic Objective

Should be

clarified

The specific objective is changed in the

latest version of OPRG, 16.09.2013.

Output/result indicators

and

Planned activities /

Specific objective

Satisfactory Most activities under the SO are covered

by the indicator system.

Indicators for activities related to energy

efficiency, renewable energy and

improving access for people with

disabilities are not provided.

The result indicator is linked to the

specific objective, but the link between the

output and result indicators depend on

many external factors.

Priority Axis 1, Investment Priority 1.3

The understanding of the assessment team of the connections between the elements of OPRG

strategy 2014-2020 under PA1, IP1.3 is presented in the graph below:

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

85

Figure 13: Logic of PA1, IP1.3

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

86

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong Clear connection between the indicated

needs and the planned activities (except

for the needs of people with disabilities,

which is defined as horizontal need)

Planned activities and

Specific Objective

Strong The connection is clear.

Specific objective and

Investment

Priority/Thematic

Objective

Strong Direct connection

Output/result indicators

and Planned activities /

Specific objective

Strong There are good links between the activities

– output indicator - result indicator -

specific objective.

Priority Axis 1, Investment Priority 1.4

The understanding of the assessment team of the connections between the elements of OPRG

strategy 2014-2020 under PA1, IP1.4is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

87

Figure 14: Logic of PA1, IP1.4

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

88

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the connection Comments/Explanations (if

necessary)

Needs and Planned

activities

Should be clarified As can be seen from the graph, in

the text of the OPRG 2014-2020,

are not presented clearly the needs

with respect to the provision of

social services

Planned activities and

Specific Objective

Should be completed Most of the activities have a direct

connection with the Specific

Objective.

In OPRG, version from

09.09.2013, the activities with

respect to the following objectives

have not been described:

cultural infrastructure.

installations for the

production of energy from

renewable sources

energy efficiency audits

improve access for people

with disabilities

The activities are described in the

version of OPRG from

16.09.2013.

Specific objectives

and Investment

Priority/Thematic

Objective

Strong The connection between the

Specific objectives and the

Investment Priority is direct.

Output/result

indicators and

Planned activities /

Specific objectives

Satisfactory For Specific objective 1 there are

good links between the activities –

output indicator - result indicator -

specific objective.

For Specific objective 2 there is a

good link between the activities

and the output indicator. There is

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

89

no hierarchical link between the

output and result indicators. There

is a direct link between the result

indicator and the specific

objective.

For Specific objective 3 there are

good links between the activities –

output indicator - result indicator -

specific objective.

Priority Axis 1, Investment Priority 1.5

The understanding of the assessment team of the connections between the elements of OPRG

strategy 2014-2020 under PA1, IP1.5 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

90

Figure 15: Logic of PA1, IP1.5

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

91

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong In the analysis for this investment priority

are included a number of needs that are

related to the planned activities. A short

statement on the sources of the analyses,

which have been used, could be provided.

(feasibility studies of cities- beneficiaries

for integrated urban transport in the

current programming period).

In the version of the Programme from

09.09.2013, the recommendation has

already been implemented.

Planned activities and

Specific Objective

Should be

clarified

The specific objective is narrowed in

terms of content in the version of the

Programme of 13.05.2013. Therefore

many of the activities are not linked to the

specific objective and it should be

reformulated. Possible way of

reformulation is to link it more closely

with the investment priorities and in

particular the achievement of sustainable

urban mobility.

In the 09.09.2013 version of the

Programme, the specific objective is now

redefined.

Specific objective and

Investment

Priority/Thematic

Objective

Strong The connection between the Specific

objective and the Investment Priority is

direct.

Output/result indicators

and Planned activities /

Specific objective

Strong There are good links between the activities

– output indicator - result indicator -

specific objective.

Priority Axis 2

The understanding of the assessment team of the connections between the elements of OPRG

strategy 2014-2020 under PA2 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

92

Figure 16: Logic of PA2

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

93

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong The needs analysis contains specific needs

in the education sector that are linked to

planned activities (with the exception of

the needs of people with disabilities, but

they are defined as horizontal).

Planned activities and

Specific Objective

Strong The connection is clear, but as with PA1,

IP4, SO1, the achieving of a specific

objective is linked to many factors beyond

infrastructure.

Specific objective and

Investment

Priority/Thematic

Objective

Strong Direct connection

Output/result indicators

and Planned activities /

Specific objective

Strong There are good links between the activities

– output indicator - result indicator -

specific objective.

Priority Axis 3

The understanding of the assessment team of the connections between the elements of OPRG

strategy 2014-2020 under PA3 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

94

Figure 17: Logic of PA3

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

95

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong There is a clear connection between

indicated needs and planned activities

(with the exception of horizontal activities

- energy efficiency, renewable energy and

measures for people with disabilities).

Planned activities and

Specific Objective

Strong Planned activities are expected to

contribute to the achievement of the

specific objective.

Specific objective and

Investment

Priority/Thematic

Objective

Strong Direct connection

Output/result indicators

and Planned activities /

Specific objective

Satisfactory There is a good link between the activities

and the output indicator. There is no

hierarchical link between the output and

result indicators. There is a direct link

between the result indicator and the

specific objective.

Priority Axis 4

The understanding of the assessment team for the connections between the elements of

OPRG strategy 2014-2020 under PA4 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

96

Figure 18: Logic of PA4

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

97

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong As a whole, planned activities comply

with the identified needs.

Planned activities and

Specific Objective Strong

All planned activities comply with the

specific objective

Specific objective and

Investment

Priority/Thematic

Objective

Strong Direct connection (with regards to social

infrastructure)

Output/result indicators

and Planned activities /

Specific objective

Strong There are good links between the activities

– output indicator - result indicator -

specific objective.

Priority Axis 5

The understanding of the assessment team for the connections between the elements of

OPRG strategy 2014-2020 under PA5 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

2014-2020 г.

98

Figure 19: Logic of PA5

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

99

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong The connection between the identified

needs and planned activities is direct.

Planned activities and

Specific Objective

Strong Planned activities will directly contribute

to the identified specific objective (with

the exception of horizontal activities on

energy efficiency and renewable energy).

Specific objective and

Investment

Priority/Thematic

Objective

Strong Direct link

Output/result indicators

and Planned activities /

Specific objective

Strong There are good links between the activities

– output indicator - result indicator -

specific objective.

Priority Axis 6

The understanding of the assessment team for the connections between the elements of

OPRG strategy 2014-2020 under PA6 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

100

Figure 20: Logic of PA6

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

101

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong The connection between the identified

needs and planned activities is direct.

Planned activities and

Specific Objective

Strong Planned activities will directly contribute

to the identified specific objectives (with

the exception of horizontal activities on

energy efficiency and renewable energy

measures provided for people with

disabilities).

Specific objective and

Investment

Priority/Thematic

Objective

Strong/Should be

clarified The connection of the Specific Objective 1

with the Investment Priority is direct.

Specific objective 2 is not directly related

to the thematic objective, but it is rather

the result of the measures on conservation,

promotion and development of natural and

cultural heritage.

Output/result indicators

and Planned activities /

Specific objective

Strong There are good links between the activities

– output indicator - result indicator -

specific objective.

Priority axis 7

The understanding of the assessment team for the connections between the elements of the

OPRG strategy 2014-2020 under PA7 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

102

Figure 21: Logic of PA7

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

103

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong Direct connection between needs and

planned activities.

Planned activities and

Specific Objective

Strong Direct connection

Specific objective and

Investment

Priority/Thematic

Objective

Strong Direct connection

Output/result indicators

and Planned activities /

Specific objective

Strong There are good links between the activities

– output indicator - result indicator -

specific objective.

Priority 8

There are no indicators under Priority axis 8 in the updated version of the OPRG 2014-2020.

The understanding of the assessment team for the connections between the elements of

OPRG strategy 2014-2020 under PA8 is presented in the graph below:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

104

Figure 22: Logic of PA8

The graph is also available at the following address:

https://drive.google.com/folderview?id=0B5OBgJzwame-dnNsNmhxMkJ1YTA&usp=sharing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

105

The interconnection between the elements of the graph has been examined in the table below:

Connection Strength of the

connection

Comments/Explanations (if necessary)

Needs and Planned

activities

Strong Direct connection

Planned activities and

Specific Objectives

Strong Direct connection

Specific Objective and

Investment

Priority/Thematic

Objective

- -

Output and result

indicators and Planned

activities

- -

V. Evaluation 3 - Assessment of the horizontal

principles and objectives, included in the

Operational Program

1. Data collection

Evaluation 3 brought to light the way in which the horizontal principles and objectives have

been included in the text of the OPRG. The main documents taken into account in the

documentary analysis are:

OPRG 2014-2020

Draft of General Regulations

Guidelines of the EC for ex-ante evaluation

Moreover, this report has used data of the online questionnaire, the focus group with

beneficiaries and the focus group with representatives of the working group.

2. Analysis

According to Art. 48 of the proposed General Regulation (of November 2012) repealing

Council Regulation (EC) No. 1083/2006, the ex-ante evaluations shall assess “the adequacy

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

106

of the planned measures to promote equal opportunities between men and women and prevent

discrimination.” Art. 87 of the same Regulation specifies that each OP, except for those

concerning technical assistance, should include the following, depending on the discretion of

the Member State of the relevance of the horizontal principles to the content of the program:

1. „A description of specific actions for taking into account environmental protection

requirements, resource efficiency, climate change mitigation and adaptation, disaster

resilience and risk prevention and management, in the selection of operations;

2. A description of the specific actions for promoting equal opportunities and

preventing any discrimination based on sex, racial or ethnic origin, religion or belief,

disability, age or sexual orientation during the preparation, design and implementation

of the operational program, and in particular, in relation to access to funding, taking

into account the needs of the various target groups at risk of such discrimination, and

more specifically, the requirements for ensuring accessibility for disabled persons;

3. A description of its contribution to promoting equality between men and women

and, where appropriate, the arrangements to ensure the integration of gender

perspective at operational program and operation level.”

There is a description of the three main horizontal principles that are included in the specified

form of OP in OPRG 2014-2020

In terms of sustainable development, the program describes OPRG Compliance with the

guidelines for integration of the Environmental Policy (EP) and the Climate Change Policy

(CCP). As stated in the OP form, when some or all of the required information is included in

the Partnership Agreement, links to it may be provided. In this sense, the text of OPRG 2014-

2020, can make reference to "polluter pays" principle described in the Partnership Agreement.

Also, a short description (similar to that in PA, version 3.0, point 1.5) can be added regarding

the way that will ensure compliance with the principle of sustainable development in the

implementation of the program, namely:

• Assessment of OPRG projects (already mentioned in the text of the program);

• Monitoring on observing the horizontal principles;

• Role of the Monitoring Committee;

• Evaluation of the program.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

107

Figure 23: Questionnaire – applicable horizontal principles

According to 80% of the respondents in the online survey – representatives of the

beneficiaries and the working group, and according to 74% of the respondents -

representatives of MA of OPRG, it is the principle of sustainable development that is most

applicable to OPRG 2014-2020.

The program also includes a description of the measures to implement the principle of equal

opportunities and non-discrimination. Improving access for people with disabilities is one of

horizontal activities under the program and it is included in most priority/ sub-priorities of the

program. This fact is explicitly included in the text of the program itself. Accordingly, this

action is appropriate for including a horizontal indicator to measure performance at the

program level – e.g. "Percentage of facilities financed under OPRG 2014-20203, including

measures to improve access for people with disabilities" or "Provide physical access to public

buildings, housing, open spaces, etc. (number of adapted sites)4." Due to the new regulations

concerning indicators, the possibility of including this indicator should be further discussed.

As in sustainable development, the text of OPRG 2014-2020 should include more details

about the "measures for monitoring and evaluation to ensure subsequent implementation of

these principles, and how the results of monitoring and evaluation” (as per the OP Form)

should be taken into account.

In terms of equality between men and women, the program states that "all projects under

OPRG 2014-2020 will include a description of measures to promote gender equality and

prevent gender and other discrimination." As stated in the program, the potential contribution

of OPRG 2014-2020 could be expressed in interventions related to educational infrastructure

and technical support, but at the same time, it should be noted that OPRG is a program of

investment in infrastructure. Compliance with this principle in interventions for educational

infrastructure and technical support can be seen in a similar manner with the requirement of

4 Included in NDP B2020

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

108

MA to provide information on the number of created new jobs for men and women as a result

of the project implementation. These interventions may also require information on the

number of men and women who have been trained under PA7 of OPRG 2014-2020, and the

number of men and women in supported universities.

In describing the measures for monitoring and evaluation of the horizontal principles required

by the OP Form, the following conclusions/recommendations of the Interim Evaluation of

OPRD 2007-2013 should be considered in the development of the program:

Inclusion of the horizontal indicators in the MA Annual Report;

Paying special attention to the horizontal principles in the MA Annual Report.

As discussed in Evaluation 3, the inclusion of horizontal indicators in terms of energy

efficiency, renewable energy and improving access for people with disabilities should be

considered in the development of a form and actual completion of the annual reports of the

MA in the next programming period.

VI. Evaluation 4 – Assessment of the indicator

system

1. Data collection

The data collection methods used in Evaluation 4 are identical to those used in the other

activities. Data collection started with desk research of: the most recent guidelines of EC in

this field, the indicators currently applied, as well as the available official statistics relevant to

the establishment of indicator system for the next programming period. Besides the desk

research, interviews with experts of DG “RDP” which were carried out at the beginning of

the evaluation had major role, given the character of the issues to be solved by Evaluation 4.

As the evaluation of indicators advanced, focus groups with beneficiaries and representatives

of the working group were conducted in order to obtain their opinion on the indicators. The

online questionnaire also included basic questions on the indicator system.

This section was updated in May 2014 following a major revision of the indicators and of the

indicator fiches.

2. Analysis

The indicator system is among the main topics of the Mid-term evaluation of OPRD 2007-

2013 as well. The recommendation of the previous evaluation to decrease the number of

indicators has been to a great extent taken into account in the programming of the OPRG

2014-2020 indicators.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

109

The indicator system has been based on the already established European practices for

formulation of indicators on one hand, and the newest guidelines in this field, on the other

hand.

The formulated indicators follow a structure of two levels – output indicators and result

indicators. The output indicators are related to and measure the progress of the specific

interventions measure. As a whole, the result indicators are linked to the specific objectives.

The number of indicators included in the system under OPRG 2014-2020 meets the

recommendations for a limited number of indicators.

In accordance with the EC guidelines for the programming period 2014-2020 - Monitoring

and Evaluation of European Cohesion Policy – ERDF and Cohesion Fund, Concepts and

Recommendations, March 2014:

Output indicators should describe the “physical” product of spending resources

through policy interventions. For common and programme-specific output indicators,

baselines should be set at zero

Results are specific dimensions of improvement of well-being of people and

consequently result indicators should describe a specific aspect of a result. Result

indicators should have baseline values.

As stated in the Guidance document on ex-ante evaluation for ERDF, CF, and ESF from

January 2013:

The values of result indicators should be influenced in as direct way as possible by the

actions funded under the priority axis.

ERDF result indicators should aim to measure a change in the situation of a Member

State, a region, an area, a sector, a population targeted by the programme, i.e. result

indicators should not be limited to the supported entities

The extent to which these requirements for the output/result indicators are followed in the

system of indicators in the draft of the OPRG 2014-2020 is commented in the tables below.

The analysis focuses on: pros/cons of using the indicators; links to the activities and specific

objectives; and methodological issues.

Priority Axis 1: Sustainable and Integrated Urban Development

Investment Priority 1 of Priority Axis 1: Supporting energy efficiency, smart energy

management and renewable energy use in public infrastructure, including in public

buildings, and in the housing sector

Specific objective 1: Raising energy efficiency in the housing sector

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

110

I.D. Type Indicator Comment

1.1.1 result

indicator

Reduction of final

energy consumption

from households in %

Pros: the indicator is measured and verified

by the NSI. It is in line with the activities, the

output indicator and the specific objective.

Cons: final energy consumptions from

households is linked with economic

prosperity – usually the higher the growth,

the higher the energy consumptions from

households. This is why this external factor

(economic prosperity or the lack of it) should

be taken into account in the future

evaluations of the programme. A potential

issue is that the unit cost is calculated on

envisaged budget and expected results, rather

than actual results, which is due to the lack of

other available data.

Other issues:

The baseline value is correctly taken from the

NSI database, but NSI has also data for 2012

and it is preferable to use the most recent

year.

The indicator represents a desired change

(reduction), but for greater clarity, it is

recommended to simplify it – “final energy

consumption from households”.

There is a mismatch between the specified

unit of measurement, which is toe and the

measurement unit of the target value (%).

The following issue in the indicator fiches

should be clarified:

It seems the data for the 2007-2013

budget calculation is also coming

from scheme BG161PO001/1.2-

03/2011 (in the indicator fiches the

overall financial resources for 2007-

2013 are calculated as a sum of the

budgets of procedures

BG161PO001/1.2-01/2011 and

BG161PO001/1.2-03/2011, while the

description specifies only the first

procedure). If this is the case, the

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

111

expected results for this scheme,

should also be added.

1.1.2

common

output

indicator

№ 31

Number of households

with improved energy

consumption

classification

Pros: use of a relevant common output

indicator

Other issues:

A challenge that may lead to incorrect

assessment of the target value of the indicator

is that the unit cost is calculated on envisaged

budget and expected results, rather than

actual results, due to the lack of other data. It

is noteworthy that the expected results are

based on a pilot project of the UNDP.

Specific objective 2: Raising energy efficiency in public buildings

I.D. Type Indicator Comment

1.1.3 result

indicator

Reduction of final

energy consumption

from public

administration,

commerce and services

in %

Pros: follows the same logic as the result

indicator for Specific objective 1.

Cons: The indicator “Reduction of final

energy consumption from public

administration, commerce and services in %”

is much broader than the specific objective. It

also includes commerce and services, which

is not relevant for the activities, and the

specific objective. The rationale for this is

that through “expanding” the scope of the

indicator, the indicator would capture

changes that extend beyond the effects for the

beneficiaries. If this indicator is used, future

evaluations will have to take into account this

extended scope of the indicator.

Energy savings are used both for primary and

final consumption of energy, thus the result

and output indicators are similar.

Other issues:

The baseline value is correctly taken from the

NSI database, but NSI has also data for 2012

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

112

and it is preferable to use the most recent

year.

The indicator represents a desired change

(reduction), but for greater clarity, it is

recommended to simplify it – “final energy

consumption from public buildings”.

1.1.4

common

output

indicator

№ 32

Decrease of annual

primary energy

consumption of public

buildings

Pros: use of a relevant common output

indicator

Other issues:

Due to the lack of data, the unit cost is

calculated on envisaged budget and expected

results. It is possible that the actual data are

different than the expected, which would lead

to incorrect definition of the target value of

the 2014-2020 indicator.

Priority Axis 1: Sustainable and Integrated Urban Development

Investment Priority 2 of Priority Axis 1: Taking action to improve the urban

environment, to revitalise cities, regenerate and decontaminate brownfield sites

(including conversion areas), reduce air pollution and promote noise-reduction

measures

Specific objective 1: Improving the quality of the urban environment

I.D. Type Indicator Comment

1.2.1 result

indicator

Increase in population

benefitting from an

improved urban

environment in % of

total population

Pros: the indicator is directly linked to the

activities, the specific objective, and the

output indicator. It provides information on

the scope of the intervention results.

Cons: Difficulties operationalizing the

indicator in terms of: added value of

improved urban environment and scope of

the population (directly, or indirectly

affected; cities, or regions).

Other issues:

Demographic statistics for 2013 are already

available from the NSI and it is preferable to

use them, which would slightly change the

target value.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

113

In the indicator fiches it should be clearly

specified that by population is meant

“inhabitants of the supported cities” and there

should be a definition (examples) of urban

environment in order to define the scope of

the indicator.

The following issues in the indicator fiches

should be clarified:

The population of Veliko Tarnovo is a

0 (F189).

The benefiting population for Varna is

60 000, whereas for Kameno

municipality it is 46 286 although the

whole population of the municipality is

around 12 000.

The indicator represents a desired change

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Population benefiting from improved

urban environment”.

1.2.2

common

output

indicator

№ 38

Open space created or

rehabilitated in urban

areas

Pros: use of a relevant common output

indicator

Other issues:

The following issue in the indicator fiches

should be clarified:

The value of Yambol’s project is too

big and it is an outlier - BG161PO001-

1.4.05-0036-C0002 (‘OPRD

Results’G201)

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

114

Specific objective 2: Improving investment activity in the cities through regeneration

of areas with potential for economic development

I.D. Type Indicator Comment

1.2.3 result

indicator

Increased expenditures

on acquisition of

tangible fixed assets in

%

Pros: the indicator is measured and verified

by the NSI. It is meant to capture the

expected increase in economic activity.

Cons: the indicator is dependent on too many

external factors that in case it is used, should

be taken into account in future evaluations.

Other issues:

The indicator represents a desired change

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Expenditures on acquisition of tangible

fixed assets”.

The target value should be in the same

measurement unit as the baseline (Euro).

The following issue in the indicator fiches

should be clarified:

The methodology says that “according to

the experience from the implementation

of JESSICA the invested OP funds are

about 30 % from the entire JESSICA

investments”, but it should be taken into

account that not all the funds lead to the

acquisition of tangible fixed assets.

1.2.4

common

output

indicator

№ 22

Total surface area of

rehabilitated land

Pros: use of a relevant common output

indicator

Other issues:

The following issues in the indicator fiches

should be clarified:

Are the results of grant schemes of

OPRD 2007-2013 BG161PO001/1.4-

02/2008 “Support for Improvement of

the Urban Environment” and

BG161PO001/1.4-05/2009 “Support for

Integrated and Sustainable Development

through Improvement of Urban

Environment” relevant in this case (e.g.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

115

for brownfields)?

The target value is based on rehabilitated

playgrounds and alleys in 2007-2013,

while in 2014-2020 it will cover

economic zones. The unit cost might

therefore be different. It is not clear if

the scope of the activities will be

sufficiently similar in order to allow the

use of these results in the

implementation of the programme in

2007-2013 for the definition of the target

value of the indicator in the next

programming period.

1.2.5

common

output

indicator

№ 39

Public or commercial

buildings built or

renovated in urban areas

Pros: use of a relevant common output

indicator

Other issues:

The following issues in the indicator fiches

should be clarified:

Are the achieved results of grant

scheme of OPRD 2007-2013 Scheme

BG161PO001/1.4-08/2010 “Joint

European Support for Sustainable

Investment in City Areas (JESSICA)”

relevant in this case?

The data is for actual results, or

expected results?

Priority Axis 1: Sustainable and Integrated Urban Development

Investment Priority 3 of Priority Axis 1: Investing in education, training and

vocational training for skills and lifelong learning by developing education and

training infrastructure

Specific objective: Improving conditions for modern educational services

I.D. Type Indicator Comment

1.3.1 result

indicator

Increase of the share of

modernized educational

institutions in %

Pros: the indicator is measurable and directly

linked to the activities and the specific

objective. It provides information on the

scope of the intervention results.

Cons: the output and result indicators are

very close in scope. Although, the indicator

would provide contextual information on the

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

116

scope of the achieved results the result does

not show what the improved conditions will

bring. The difficulty with the result indicator

for this specific objective is that OPRG

provides infrastructure, but for example the

Europe 2020 targets of decreasing early

leavers from education and training depend

also on soft measures and policies.

Other issues:

The indicator represents a desired change

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Share of modernized educational

institutions”.

There scope of “modernised” should be

defined in the indicator fiches.

The following issue in the indicator fiches

should be clarified:

There are differences between target

values and unit costs in the fiches and

the text of the programme

1.3.2

common

output

indicator

№ 35

Capacity of supported

childcare or educational

infrastructure

Pros: use of a relevant common output

indicator

Other issues:

The following issues in the indicator fiches

should be clarified:

From the indicator fiches it is not

clear enough if for the calculations

were used the achieved results for

2013 and the absorbed funds.

The target value in the text of the

programme is higher than in the

indicator fiches.

Priority Axis 1: Sustainable and Integrated Urban Development

Investment priority 4 of priority axis 1: Investing in health and social infrastructure

which contributes to national, regional and local development, reducing inequalities in

terms of health status, promoting social inclusion through improved access to social,

cultural and recreational services and the transition from institutional to community-

based services

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

117

Specific objective 1: Improving the housing conditions for marginalised groups of the

population including the Roma

I.D. Type Indicator Comment

1.4.1 result

indicator

Increase of the

representatives from

marginalised groups,

including Roma, with

improved housing

conditions in %

Pros: the indicator is measurable and directly

linked to the activities, the specific objective,

and the output.

Cons: From the baseline it is clear that here

are meant only the marginalised groups with

improved housing conditions as a result of

OPRD. However, if data allows it, this

indicator would be even more meaningful, if

it captures the improvement of housing

conditions for all marginalised groups in

urban areas.

Other issues:

The measurement unit is in percentage and

the unit cost is in absolute numbers. Although

this approach shows the method of

calculation, the baseline and the target values

should be in the same measurement unit

(persons).

The indicator represents a desired change

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Representatives from marginalised groups,

including Roma, with improved housing

conditions”.

From the indicator fiches it is not clear

enough if for the calculations were used the

achieved results and the absorbed funds.

1.4.2

common

output

indicator

№ 40

Rehabilitated housing in

urban areas

Pros: use of a relevant common output

indicator

Other issues:

It should be specified in the indicator fiches,

if for the calculations were used the achieved

results and the absorbed funds

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

118

Specific objective 2: Improving conditions for modern social services

I.D. Type Indicator Comment

1.4.3 result

indicator

Increase in modernized

facilities for social

services as a share in

total number of social

institutions

Pros: the indicator is measurable and directly

linked to the activities and the specific

objective. It provides information on the

scope of the intervention results.

Other issues:

The difficulty of finding a result indicator for

the improvement of social services is also

manifest in the OPHRD programme. Result

indicators for OPHRD 2014-2020 (Priority

axis 2 – Decreasing poverty and social

inclusion) are:

Participants above 18 receiving social

and health services in the community

Children receiving social services in

the community

Participants above 65, unable to serve

themselves, with improved access to

services

In order to underlie the complementarity

between the two programmes, a similar result

indicator might be used also for OPRG, e.g.

population using social services. The logic

between these indicators and the indicators

for Priority axis 4 should be aligned, if

possible.

There is probably a technical mistake in the

calculations (in Excel). As it is, only a part of

the 2014-2020 budget is reduced by 10%.

1.4.4

specific

output

indicator

Population covered by

improved social services

Pros: The indicator is appropriate and it

follows the logic of the common indicator

“Population covered by improved health

services”.

Other issues:

The following issue in the indicator fiches

should be clarified:

For Gabrovo municipality the

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

119

population is 0 (F46).

There is probably a technical mistake

in the calculations. As it is, only a part

of the 2014-2020 budget is reduced

by 10%.

Specific objective 3: Improving the conditions for sports for all and cultural life in

cities

I.D. Type Indicator Comment

1.4.5 result

indicator

Increase of the share of

modernized cultural/

sport objects

Pros: The indicator is measurable and

directly linked to the activities and the

specific objective, which is to improve the

conditions (having in mind the infrastructure

character of the programme). It provides

information on the scope of the intervention

results.

Cons: Although it shows the outcomes of the

programme activities in relation with the

overall conditions of cultural and sport

facilities in the country, this indicator is

another measurement for the achieved output.

Other issues:

If this indicator is used, it should be

reformulated to “Share of modernized

cultural/sport objects”. Thus, the target value

would not be 560,8%, because this is above

100%.

There is probably a technical mistake in the

calculations. As it is, only a part of the 2014-

2020 budget is reduced by 10%.

1.4.6

specific

output

indicator

Number of promoted

objects of sport and

cultural infrastructure

Pros: The indicator is directly linked to the

activities.

Cons: the scope of “promoted” is unclear

(could be modernized).

Other issues:

It is better to use “sites” or “facilities” rather

than “objects”.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

120

The following issue in the indicator fiches

should be clarified:

if for the determining of the unit cost

were combined sport and cultural

infrastructure

if for the calculations were used the

achieved results and the absorbed

funds

The common indicator - “Increase in

expected number of visits to supported sites

of cultural and natural heritage and

attractions” is not completely relevant,

because it does not include sport

infrastructure. Besides, the common indicator

would not capture the visits of mass sports

facilities.

There is probably a technical mistake in the

calculations. As it is, only a part of the 2014-

2020 budget is reduced by 10%.

Priority Axis 1: Sustainable and Integrated Urban Development

Investment Priority 5 of Priority Axis 1: Promoting low-carbon strategies for all types

of territories, in particular for urban areas, including the promotion of sustainable

multimodal urban mobility and mitigation-relevant adaptation measures

Specific objective: Improving the urban mobility

I.D. Type Indicator Comment

1.5.1 result

indicator

Increase of the travels

with public urban

transport

Pros: the indicator is linked with the output

indicator and the activities. It captures the

intended effect.

Cons: no baseline value is included.

1.5.2

specific

output

indicator

Total length of

supported urban

transport lines

Pros: the indicator is linked with the

activities and follows the logic of the

common urban transport indicator “Total

length of new or improved tram and metro

lines”.

Cons: no data is included on the values of the

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

121

indicator

Other issues:

The indicator could be reformulated to

“improved” instead of “supported”.

Priority Axis 2: Regional Education Infrastructure

Investment Priority 1 of Priority Axis 2: Investing in education, training and

vocational training for skills and lifelong learning by developing education and

training infrastructure

Specific objective 1: Creating conditions for modern education services

I.D. Type Indicator Comment

2.1 result

indicator

Increase in the

modernized regional

educational institutions

as a share of total

number of educational

institutions

See the comments for indicator 1.3.1.

Other issues:

The target value seems unrealistic.

The difference between regional educational

institutions and the ones that will be

supported under PA1 is not clear in the

methodology for the calculation of indicators.

The indicator represents a desired change

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Share of modernized regional educational

institutions”.

There scope of “modernised” should be

defined.

2.2

common

output

indicator

№ 35

Capacity of supported

childcare or education

infrastructure

Pros: use of a relevant common output

indicator

Other issues:

The following issues in the indicator fiches

should be clarified:

Are these the achieved results for

2013?

How is the number of persons in the

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

122

educational infrastructure determined

– capacity of the institutions, or actual

number of students?

Only the indicators of

BG161PO001/1.1-07/2009 are taken

into account whereas the budget for

the calculations includes also 2 other

schemes.

There are differences between target

values and unit costs in the indicator

fiches and the OP.

Priority Axis 3: Regional Health Infrastructure

Investment Priority 1 of Priority Axis 3: Investing in health and social infrastructure

which contributes to national, regional and local development, reducing inequalities in

terms of health status, promoting social inclusion through improved access to social,

cultural and recreational services and the transition from institutional to community-

based services

Specific objective: Improving the conditions for modern healthcare services

I.D. Type Indicator Comment

3.1 result

indicator

Increased share of

modernized healthcare

establishments

Pros: the indicator is measurable and directly

linked to the activities and the specific

objective.

Cons: the output and result indicators are

very close in scope. The difficulty with the

result indicator for this specific objective is

that OPRG provides infrastructure, but for

example the increase in the health status of

the population depends on the overall health

policy in the country.

Other issues:

The indicator represents a desired change

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Share of modernized healthcare

establishments”.

The indicator fiches do not include this

indicator.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

123

3.2

common

output

indicator

№ 36

Population covered by

improved health

services

Pros: use of a relevant common output

indicator

Cons: The unit cost is based on just one

project, but it seems there is no other relevant

available data.

Other issues:

Although it is a common indicator, there are

difficulties operationalizing it. It is

recommended that the indicator fiches

describe what is meant by “population

covered” and “improved health services”.

Priority Axis 4: Regional Social Infrastructure

Investment Priority 1 of Priority Axis 4: Investing in health and social infrastructure

which contributes to national, regional and local development, reducing inequalities in

terms of health status, promoting social inclusion through improved access to social,

cultural and recreational services and the transition from institutional to community-

based services

Specific objective: Deinstitutionalization of social services

I.D. Type Indicator Comment

4.1 result

indicator

Decrease of the people

in institutional social

care in %

Pros: The indicator captures the intended

effect and is in line with the specific

objective.

Cons: The achieving of the target value also

depends on the OPHRD programme and the

overall national policy for

deinstitutionalisation.

Other issues:

The indicator represents a desired change

(decrease), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “People in institutional social care”.

There is a different logic (in this draft of the

indicators) between Specific objective 2:

Improving conditions for modern social

services (of Priority axis 1) and Specific

objective: Deinstitutionalization of social

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

124

services (Priority axis 4).

Indicator measurement unit is number and the

target value is set in percent.

4.2

specific

output

indicator

Number of supported

facilities of social

infrastructure in the

process of

deinstitutionalization

Pros: The indicator is directly linked to the

activities and represents the outputs that are

expected to be achieved.

Cons: the indicator does not follow the logic

of the common indicators. For the social

infrastructure an indicator, following that

logic would be: “Capacity of supported social

infrastructure”.

Other issues:

It is better to use “facilities” rather than

“objects” in the measurement unit.

Priority Axis 5: Regional Tourism

Investment Priority 1 of Priority Axis 5: Conserving, protecting, promoting and

developing natural and cultural heritage

Specific objective 1: Increasing the tourist offer of cultural monuments of national and

world significance

Specific objective 2: Promoting the local economic potential and new forms of

employment in the regions

I.D. Type Indicator Comment

5.1 result

indicator

Increase of the net

annual revenues from

international tourism

Pros: the indicator is relevant to the intended

effects.

Cons: There is a discrepancy between the

formulation of the NSI indicator (internal

tourism consumption) and the OPRG

indicator.

The indicator’s measurement unit is mln.euro,

which makes the baseline value too big.

Increasing the value of the indicator with

0,12% is a rather insignificant effect.

Other issues:

The indicator represents a desired change

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

125

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Net annual revenues from international

tourism”.

The unit cost is calculated on the basis of just

2 projects. Thus, it is actually not

recommended to use unit costs for

determining the target values of this indicator,

because there is not enough data.

Furthermore, the description in the

methodology - “Net annual revenues from

international tourism under OPRD 2007-2013

are 90 754 euro with invested funds 2 355

714 euro” shows inefficiency.

The measurement unit should be changed to

percent.

5.2

common

output

indicator

№ 9

Increase in expected

number of visits to

supported sites of

cultural and natural

heritage and attractions

Pros: use of a relevant common output

indicator

Other issues:

The following issues in the indicator fiches

should be clarified:

There is no description of the used

data for determination of the target

value.

Why is BG161PO001/3.1-02/2009 not

included?

Are these results already achieved, or

they are expected?

Why is the target value divided by 7?

There are inconsistencies in the

calculation methodology in terms of

budget and target value

Priority Axis 6: Regional Road Infrastructure

Investment Priority 1 of Priority Axis 6: Enhancing regional mobility by connecting

secondary and tertiary nodes to TEN-T infrastructure, including multimodal nodes

Specific objective: Improving connectivity and accessibility of the network of cities

and sites of cultural and natural heritage with the TEN-T network

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

126

I.D. Type Indicator Comment

6.1

result

indicator

Increased passenger and

freight flow

Pros: the indicator is relevant to the intended

effects and is aligned with the specific

objective

Cons: there is a discrepancy between the

measurement unit (thousands of tons) and the

indicator, which includes passengers. This is

due to the discrepancy between the NSI

indicator ("Goods carried by type of journeys

and type of carriage") and the formulation of

the indicator.

Other issues:

The calculation is not based on 2007-2013

results.

The indicator represents a desired change

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Passenger and freight flow”.

The target value and the baseline should be in

the same measurement unit.

It should be clarified, if the source of data

will be the NSI, or the Road Infrastructure

Agency.

6.2

common

output

indicator

№ 14

Total length of

reconstructed or

upgraded roads

Total length of

reconstructed or

upgraded 1st and 2nd

class roads

Pros: use of a relevant common output

indicator. The division between the indicators

specifies the length of the different road

classes.

Other issues:

The indicator “Total length of reconstructed

or upgraded roads” should provide

information on the cumulative length of the

reconstructed or upgraded roads, including 1st

and 2nd class.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

127

Priority Axis 7: Risk Prevention

Investment Priority 1 of Priority Axis 7: Promoting investment to address specific

risks, ensuring disaster resilience and developing disaster management systems

Specific objective: Preventing the risk of landslides

I.D. Type Indicator Comment

7.1 result

indicator

Increased share of the

population not at risk of

landslides

Pros: the indicator is in line with the

activities, the output indicator, and the

specific objective. It provides information on

the scope of the intervention results.

Other issues:

It should be clarified what is meant by “The

population expected to be covered in the

period 2014-2020” in the description of the

methodology.

The indicator represents a desired change

(increase), but for greater clarity, in case it

will be used, it is recommended to simplify it

– “Share of the population not at risk of

landslides (or population not at risk of

landslides)”.

The target value and the baseline should be in

the same measurement unit.

The NSI already provides demographic

statistics for 2013, which should be used in

the calculations.

7.2

specific

output

indicator

Reinforced landslide

area

Pros: the indicator is in line with the

activities and is within the control of the

programme managers

Cons: the indicator does not follow the logic

of the common output indicators on Risk

prevention and management (e.g. Population

benefiting from flood protection measures).

Other issues:

The following issues in the indicator fiches

should be clarified:

No data for Madan municipality

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

128

The data for Velingrad is inconsistent.

Sources of data

Output indicators are based primarily on UMIS and the statistics generated in the operating

records of the beneficiaries under OPRG. Therefore, in preparing UMIS for the new

programming period, extension of its scope must be embodied and mandatory precision and

specifics regarding information on the physical progress should be provided. Thus an

adequate, effective and efficient way to use modern information technology for reporting the

physical progress and impact of the MA will be provided. Although the preparation of UMIS

for the new programming period is beyond the powers of MA of OPRG, we recommend to

pay attention to this information needs of the competent authorities in case an opinion on this

issue by MA is requested.

The territorial scope of the existing indicators is essential for future evaluations, especially

regarding the integrated urban development. NSI currently publishes a very limited number of

indicators at local and district level. Therefore, the team of the Contractor together with

representatives of the Contracting Authority held a series of consultations with NSI and four

focus groups with representatives of TWG and the beneficiaries for identifying the options for

providing statistical information at district, municipality and urban area level. Thus, a

preliminary analysis was carried out as to what extent difficulties might arise in the

measurement of the program achievements proving the effectiveness of one or another project

in a specific impact area.

In general, NSI can present demographic information for measuring the achieved results

within the Program implementation. Thus a considerable part of the necessary information on

result indicators will be provided. In terms of future impact assessment, it has been

established that policies set in the Program will contribute not only to long-term effects on the

social and economic development of the specific areas of impact, but to the overall

development of the city, municipality or neighbouring municipalities.

Regarding the indicators (both output and result) to be generated by the UMIS version that

should be developed for the purposes of the new programming period, they should

automatically report the progress and allow at the same time the implementation of impact

assessment at all times at a relatively much lower cost and much higher quality (compared to

the data collection cost and data quality obtained through ad-hoc surveys). Therefore, the

Contractor team recommends that the Contracting Authority requires mandatory integration

of the physical progress indicators in UMIS in a form that allows automatic aggregation and

reporting.

In addition, it should be noted that the inclusion of the physical indicators in UMIS at project

and beneficiary level that can be automatically aggregated, will allow for a possible future

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

129

microeconometric modelling and counterfactual analysis of the net impact (in the case that

such a need occurs) 5.

In conclusion, it should be noted that a need for macroeconometric modelling of net long-term

impact of OPRG may arise in the future. In order to serve for assessment of the long-term

impact, the indicators should be included in a specific macroeconomic model (e.g.

SIBILA). Each project under the program and accordingly, each procedure should provide

sufficiently comprehensive information on which of the components of the aggregate demand

it is particularly focused on. This information can be provided by including indicators of

physical progress in the new UMIS system. Indicators must contain additional information

that complies with the technical features of macroeconomic models (as regards their focus on

the individual components of the aggregate demand and individual factors within the

macroeconomic production function), and the very models should take into account (insofar

as it is possible) the set indicators. Since the scope of these components is limited, it should be

possible to explicitly indicate which of the following elements will be promoted by OPRG:

o Production facilities/ physical capital;

o Infrastructure – road, water and sewage, etc.

o Human capital – training, education, health, sports, culture, etc.

o Employment

o Technologies – ICT, R&D, etc

Indicator fiches

Based on all the findings above, as well as on previous experience in programming and

reporting of indicators for the period 2007-2013 it can be recommended to the MA of OPRG

to develop specific indicator fiches. This need is also found in the Mid-term Evaluation of

OPRD 2007-2013 and is illustrated by the results from the online survey within the

assessment. As can be seen from the Figure below, 21% of the experts of the beneficiaries

5During the next programming period, EC will significantly strengthen the role and place of the counterfactual

analysis in measuring the result of the Program implementation. The realization of quality and adequate

assessment by counterfactual analysis requires alignement of the indicators to the requirements of this method,

namely:

1. Clear distinction of the target group which shall be impacted through the instruments of the

operational program that is provided in the programming and refining of the interventions;

2. On this basis, it will be possible already at this stage of programming to identify “treated” and

“control” group with a view to implement in the future comparative statistical analysis based on the

counterfactual analysis methods.

3. Defining a data collection method for the purposes of counterfactual analysis and/or a data source -

ad-hoc research or reference from administrative registers (according to the guidelines of EC).

4. Defining of indicators that will be compared in both treated and control groups, and these are the

already formulated result indicators or equivalent indicators at beneficiary level (representative of

the treated group) and at potential beneficiary level (representative of the control group, that has

been a potential beneficiary under the Program)

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

130

declare that sometimes they have difficulties in the accounting of indicators, while 44% of the

MA staff declare that they often face problems in reporting the indicators.

11% I do not face difficulties

17% Rarely

21% Sometimes

5% Often

46% N/A

17% I do not face difficulties

11% Rarely

17% Sometimes

44% Often

11% N/A

Figure 24: Online questionnaire – difficulties of indicators

The structure of the indicator fiches should include the following components:

names of indicators

number

definition and description

baseline and target value

calculation methods

data sources

unit costs information (if applicable to the indicator)

staff responsible for maintaining the indicator fiches

Following discussions between the evaluation team and the client, drafts of indicator fiches

have already been developed by the MRD. Their content was taken into account in the

analysis of the indicators provided in this section.

Overall conclusions on the indicators

The indicator system of OPRG includes the relevant common output indicators listed in

Regulation 1301/2013. In some cases where there are no relevant output indicators, the draft

of the OPRG 2014-2020 includes output indicators, which follow closely the common

indicators’ logic – “Population covered by improved social services” and “Total length of

supported urban transport lines”. As a whole, it may be concluded that all output indicators

are relevant to the activities and provide good measurement for their direct products. The

baselines of the outputs are set to 0.

As mentioned, result indicators have to fulfil at the same time two conditions - they need to

be directly attributable to the programme and they should not be limited to the supported

entities. One of the main specificities of the OPRG is that it is an infrastructure programme.

Hence the meaningful and tangible results, e.g. in the health, social, and education spheres,

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

131

will be achieved only through further soft measures and national/regional policies. OPRG will

provide the necessary infrastructure for the expected results, but the results themselves will

depend also on many other external factors and policies. For example, the difficulty with the

result indicator for the health infrastructure is that OPRG will provide infrastructure, but the

increase in the health status of the population depends on the overall health policy in the

country and on other external factors like aging. The difficulties in identifying indicators that

have as direct as possible influence on effects that extend beyond the supported entities are

commented for each indicator in the above analysis. It is clear from the analysis that in the

identification of result indicators for each specific objective in most cases there should be a

choice of different compromises between “direct attribution” and “overall influence”.

All result indicators have baseline values (except “Increase of the travels with public urban

transport”). However, in some cases the baselines and the target values are not in the same

measurement unit, e.g. the baseline is in absolute numbers, whereas the target value is in

percentage. This is largely due to the fact that the result indicators are formulated in line with

the expected positive outcomes, e.g. “increase of”. Yet, the values of these indicators might

increase, or decrease depending on external factors. In order not to report negative values in

cases where instead of increase there is a decrease in a certain indicator, it is recommended to

reformulate the indicators and delete “increase / decrease” in the formulation.

The programmers have developed a methodology (indicator fiches) for estimation of the

baselines and the target values, which is very helpful and increases the transparency of the

calculation methods. For most indicators there are still some issues, commented in the

analysis, that need to be clarified in the fiches. In some cases the unit costs are calculated on

the basis of envisaged budget and expected results, rather than actual results. Since at the

moment of indicator development for the OPRG 2014-2020 the implementation of a large

number of the projects have not been finalised, in many cases this is the only possible

approach.

It is worth mentioning that the system of indicators is aiming at using as much as possible

official NSI data, which is beneficial in terms of methodological clarity and transparency. In

some cases, identified in this section, the latest available data from the NSI was not used, so it

is recommended to re-calculate some baselines and unit costs. In two cases there is a

discrepancy between the formulation of the NSI indicator and the OPRG indicator: “Increase

of the net annual revenues from international tourism” and “Increased passenger and freight

flow”.

Calculating unit costs is a very useful approach for the definition of target values. Overall this

is the approach followed in the indicator fiches of the OPRG. However, inflation also needs to

be taken into account in the calculation of the target values. Possibly, this is why the target

values for 2014-2020 have been reduced by 10%.

On the basis of the above analysis of the indicators, the evaluators recommend review of the

following result indicators:

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

132

Reduction of final energy consumption from public administration, commerce and

services – due to the relatively low expected influence of the OPRG on this indicator.

It is suggested, if feasible, to ask NSI for data on the final energy consumption from

public administration

Increase of the net annual revenues from international tourism – due to the

discrepancy between the NSI and OPRG formulation. Another source of data for this

indicator is the Bulgarian national bank (Balance of payments, income from travel).

Increased passenger and freight flow – due to the discrepancy between the NSI and

OPRG formulation

VII. Evaluation 5 – Assessment of the Program’s

budget

1. Data collection

The main objective of Evaluation 5 is to analyze whether the budget allocation of OPRG

2014-2020 meets the general objectives of the program. According to the Guidelines of the

European Commission on carrying out ex-ante evaluations for the period 2014-2020, the

analysis of allocation of financial resources should assess whether allocated resources are

focused on the most important identified goals:

1. in accordance with the requirements for concentration of resources for specific

priorities identified in the European (and national) law.

2. in accordance with the outlined challenges and needs.

Also, in a purely formal aspect, it should be checked whether the information required

under the General Regulation on ESIF regarding the financial plan of the program is set

throughout the program document.

In order to assess the budget of OPRG 2014-2020, this chapter describes the results of the

following activities performed:

Overview of the financial framework set in the programming document of OPRG

2014-2020

o Structure of the financial framework for investment priorities;

o Allocation of funds according to the form of funding, beneficiaries, territorial

aspect and thematic objectives.

Benchmarking against financial allocation and implementation of OPRG in the current

programming period, taking into account the change in the program scope.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

133

Analysis of the results of the online survey and focus groups with beneficiaries,

representatives of the working group for OPRG 2014-2020 and MA for the allocation

of financial resources of OPRG 2014-2020,

Analysis of the extent of consistency of the financial allocation under OPRG 2014-

2020 to the requirements of European regulations.

o Degree of compliance with the formal requirements in the description of the

financial framework in the program document and co-financing;

o Consistency and validity of the allocation of budgetary resources to satisfy the

thematic concentration in European regulations.

Compliance of the financial allocation under OPRG 2014-2020 with the objectives

and priorities set in the major national strategic documents.

2. Analysis

Financial Framework of Operational Program “Regions in Development” 2014-2020

The current version of OPRG 2014-2020 presents the financial allocation, which is clearly

and well justified both in terms of national goals and priorities, and in terms of compliance

with the relevant EU legislation.

As a whole, the financial justification of the current version of OPRG 2014-2020, is

presented in accordance with the requirements regarding the content and format of the

financial statement of the guidelines for the development of operational programs in the new

programming period. It is written by thematic objectives, the information in it is presented in

percentages and qualitative indicators and it is concise and concentrated (although a little

longer regarding the number of characters according to the requirements of EC).

The Financial justification contains relevant links to major European and international

documents and provides information on the ability to attract investments that are not financed

by ESIF or the national co-financing. In the case of OPRG 2014-2020, they are limited to the

ability to attract private capital through the use of financial instruments.

From the point of view of contents, the financial statement gives a good synthesized

presentation of the main socio-economic challenges and needs in the thematic areas where

measures will be implemented to support OPRG 2014-2020.

For the purposes of this ex-ante evaluation, the team of evaluators examined the more detailed

financial statement of OPRG 2014-2020, which was presented and discussed by the thematic

working group. It gives a complete picture of projected financial allocation of the funds under

the program in various breakdowns, taking into account the correct conditions and limitations

in relation to the relevant European and national documents and the socio-economic

conditions in which the program will be implemented.

In this more detailed statement the major assumptions in the working out of the financial

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

134

framework of the program are outlined, the relevant conclusions of the mid-term evaluation of

OPRD 2007-2013, as well as the experience of the current programming period, the degree of

project readiness, the requirements of the draft European regulations, the logic OPRG

intervention, assessment of applicability of prior contingencies and risks of non-compliance,

the rationale of the financial allocation as per thematic objectives and priority axes, according

to the form of financing and in territorial aspect, and as per beneficiaries and compliance with

funding set in other strategic documents.

Structure of the financial framework as per investment priorities

For achieving the objectives of OPRG 2014-2020, 1 170 270 000 Euros of EU funding (or €

1,376,788,235 total funding) is provided in the current version of the program. Given that all

measures under OPRG are focused on underdeveloped regions as per the definition of EU, the

share of EU co-financing is set at 85%. The majority of these funds (62%) are intended for

urban development based on Integrated plans for urban reconstruction and development.

The amount of funds allocated to Priority 1 meets the identification of cities as key drivers of

growth and regional development (including the update of 2012 National Reform Program).

Also, this distribution corresponds to the European approach, set out in the Europe 2020

Strategy for focused support of EU funds.

The measures to improve energy efficiency in administrative and residential buildings have

the largest share of urban finance, equal to about 20% of the total budget of OPRG 2014-

2020. This priority is directly related to the requirements set at EU level for priority financing

of activities under Thematic Objective 4 "Transition to a low carbon economy," as well as to

Specific Recommendation 7 of the Council on Energy Efficiency.

Substantial funds (about 17% of the total budget of OPRG 2014-2020) are also provided to

improve urban environment in compliance with the common European goals set in the EU

Territorial order. Based on the experience of the current programming period, this type of

investments accounts a good performance and is considered to have an integrating role that

allows the realization of the sectoral policies at territorial level. Although investments in

urban areas are not directly related to economic growth and the achievement of long-term

employment, the implementation of activities to improve the urban environment should have

a significant effect on the improvement of living conditions in cities, which, in turn, will

contribute to increase economic activity in them.

A significant amount is also provided for regional road infrastructure, although in the next

programming period less money on this investment priority are set. The current financial plan

of the program (in Euros) is presented below

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

135

Priority/Investment Priority/

Intervention Area

Program

Document

2014-2020 (EU

funding)

%

Budget

OPRG

2014-20

Form of Financing Territory Thematic Objective

Grant Aid

Financial Tools

(without risk and

share capital)

Financial

Tools, with

risk and

share capital

Code Name Code Name

Priority Axis 1. "Sustainable

and integrated urban

development" 724 397 130 62% 566 605 725 148 273 209 9 518 196

1.1. Supporting energy efficiency,

smart energy management and

renewable energy use in public

infrastructures, including in public

buildings, and in the housing

sector

234 054 000 20% 187 243 200 46 810 800 0 01 Urban 04

Support for the shift towards low-

carbon economy

Energy efficiency in the

renovation of public infrastructure

78 018 000 7%

Energy efficiency in the

renovation of the existing housing

stock

156 036 000 13%

1.2 Acting to improve the urban

environment, to revitalise cities,

regenerate and decontaminate

brownfield sites (including

conversion areas), reduce air

pollution and promote noise-

reduction measures 198 945 900 17% 168 128 790 27 735 399 3 081 711 01 Urban 06

Environmental protection and

promotion of resource efficiency

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

136

Integrated schemes for urban

development 152 135 100 13%

Business infrastructure

(including industrial parks and

playgrounds) 15 603 600 1%

Rehabilitation of industrial

sites and contaminated land) 31 207 200 3%

1.3 Investing in education,

training, including vocational

training for skills and lifelong

learning by developing education

and training infrastructure 54 066 474 5% 54 066 474 01 Urban 10

Investments in education, skills and

lifelong learning

1.4 Investing in health and social

infrastructure which contribute to

national, regional and local

development, reducing inequalities

in terms of health status,

promoting social inclusion through

improved access to social, cultural

and recreational services and the

transition from institutional to

community-based services 132 006 456 11% 67 641 606 57 928 365.00 6 436 485 01 Urban 09

Promoting social inclusion and

combating property

Housing infrastructure 19 192 428 2%

Another social infrastructure

conducive to regional and local

development 112 814 028 10%

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

137

1.5. Promoting low-carbon

strategies for all types of

territories, in particular for urban

areas, including the promotion of

sustainable multi-modal urban

mobility and mitigation relevant

adaptation measures 105 324 300 9% 89 525 655 15 798 645 0 01 Urban 04

Supporting the shift towards a low carbon

economy

Clean urban transport

infrastructure and promotion 73 727 010 6%

Intelligent transport systems

(including the introduction of

demand management and tolling) 31 597 290 3%

Priority Axis 2. State education

infrastructure 54 066 474 5% 54 066 474 01 Urban 10

Investments in education, skills and

lifelong learning

Investment in education by

developing education

infrastructure 54 066 474 5% 54 066 474 01

Urban

10

Investments in education, skills and

lifelong learning

Education infrastructure

(higher, vocational and adult

education) 18 022 158 2%

Education infrastructure

(primary, secondary) 36 044 316 3%

Priority Axis 3. Regional Health

Infrastructure 46 810 800 4% 46 810 800 01

Urban 09 Promoting social inclusion and

combating poverty

Health infrastructure 46 810 800 4% 46 810 800 01

Urban

09

Promoting social inclusion and

combating poverty

Priority Axis 4. Regional social

infrastructure 35 108 100 3% 35 108 100 01

Urban 09 Promoting social inclusion and

combating poverty

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

138

Other social infrastructure contributing

to regional and local development 35 108 100 3% 35 108 100 01

Urban

09

Promoting social inclusion and

combating poverty

Priority Axis 5. Regional tourism 105 324 300 9% 52 662 150 47 395 935 5 266 215 01 Urban

06 Environmental protection and

promotion of resource efficiency Development and promotion of public

tourism and services for the cultural and natural heritage. 105 324 300 9% 52 662 150 47 395 935 5 266 215 01

Urban

06 Environmental protection and

promotion of resource efficiency

Priority Axis 6. Regional Road

infrastructure 143 241 048 12% 143 241 048 01 Urban 07

Promotion of sustainable transport

Enhancing regional mobility by

connecting secondary and tertiary

nodes to the infrastructure of the

trans-European transport network 143 241 048 12% 143 241 048 01 Urban 07

Promotion of sustainable transport

Secondary roads to the TEN-T

network and nodes 71 620 524 6%

Other national and regional roads 71 620 524 6%

Priority Axis 7. Risk prevention 14 511 348 1% 14 511 348 01 Urban 05

Promoting adaptation to climate

change, prevention and risk

management

Adapting to climate change and

prevention of natural risks 14 511 348 1% 14 511 348

Priority Axis 8. Technical assistance 46 810 800 4% 46 810 800 - n/a -

TOTAL 1 170 270 000 100% 959 816 445 195 669 144 14 784 411

Source: Operational Program Regions in Growth 2014-2020 г. (September 2013 Project)

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

139

(c) Allocation of the funds under OPRG 2014-2020 according to the form of financing

Extending the use of innovative financial instruments within the new programming period

2014-2020 aims at activating additional resources for the implementation of priority actions in

the context of economic crisis. However, this form of public-private partnership should lead

to increased efficiency, effectiveness and management of the funds invested. In particular, the

Fifth Cohesion Report of the European Commission highlights the possibility of extending the

use of financial engineering for sustainable urban transport, innovation, local development,

environment, etc. Last but not least, the possibility to use repeatedly public funds through

financial instruments for the implementation of various projects should be mentioned.

The measures including possibilities of using financial instruments should be directed to

projects with potential economic benefits and they can be granted in the form of loans,

guarantees, equity and other risk bearing options. Regarding the choice of the particular form

of financing, the areas of intervention where it will apply, and the way of completing this type

of financing with other forms of financing, Member States are free to determine any flexible

solutions according to the specific cases. In general, three types of financial instruments can

be applied: (1) joint financial instruments - established at a general European level and

managed centrally by EC, (2) pre-defined tools (off-the-shelf), and (3) tools addressed to

specific needs (tailored). The latter two instruments should be managed by the respective

Member States.

The figure below shows the general logic for specifying the way of financing at a project

level. Financial instruments are applicable in cases where there is a potential for generating

revenue. If the project is economically viable, it should be financed entirely with private

funds. However, when it is not economically viable and is associated with high risk, but it still

generates income, financial instruments can be used to make social priority projects beneficial

for implementation by the private sector.

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

140

Figure 25: Mechanism for defining the type of financing

Source: http://www.ieep.eu/assets/1177/Use_of_financial_instruments_-_the_way_forward_in_the_2014-2020_EU_MFF.pdf

Given the foregoing general parameters of the use of financial instruments, when choosing the

way of financing the interventions under OPRG 2014-2020 the following factors should be

taken into account:

Within the next programming period it is planned to extend the use of financial instruments

The possibility to increase the maximum rate of EU co-financing by 10 percentage points

when there is a separate priority axis that is fully realized through financial instruments, or

through community-led local development, represents an additional incentive for the use of

financial instruments. This possibility, however, is not relevant to the current version of

OPRG, since there are no separate axes based only on funding with financial instruments, or

those based on community-led development.

The possibility of forming a separate priority axis with co-financing up to 100% if it supports

activities implemented through the financial instruments created at EU level and managed

directly or indirectly by the EC, is irrelevant for OPRG.

The decision to use financial instruments for each investment period should be based on a

thorough assessment

IP

proprproproИнвестицио

нен проект

Negative economic rate of

return

Positive economic rate of

return

Negative internal

rate of return

Positive internal

rate of return

(Internal RR)

High risk/

No potential for

revenue

generation

Average risk/

Poor potential

for revenue

generation

High risk/

Average potential

for revenue

generation

Low

IRR

RRRRа

ВътрНВ

High

IRR

ВътрНВ

Lack of public

intervention

Grant aid Financial instruments Private

investments

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

141

o the typology of the projects - the respective activities need to generate revenue,

but they should not be economically viable and should be associated with high

risk;

o potential interest in using this type of financing by the private sector.

Within OPRG 2014-2020 the use of financial instruments is provided as an option in the

projects on:

Energy efficiency. Regarding the improvement of energy efficiency, the use of

financial instruments is justified by the fact that the majority of buildings subject to

remediation are privately owned, which defines the private interest for this type of

projects.

Urban environment. OPRG 2014-2020 provides financial instruments to finance all

investment activities of this priority, and most areas with potential for economic

impact are realized with a combination of grants and financial instruments.

Sports infrastructure. Within the health and social infrastructure projects related to

improving sports infrastructure are to be financed entirely with financial instruments.

It will be possible to fully grant Community centers and libraries.

Promoting low-carbon strategies and sustainable urban transport. There is a

possibility to support through financial instruments the implementation of revenue-

generating projects for integrated urban transport of municipalities from the first to the

third level.

Tourism and preservation of cultural heritage. Due to the ability to generate revenue,

cultural and tourist sites and activities are to be financed partially or wholly with

financial instruments.

Grant aid

Financial

instruments,

with the

exception of

risk and equity

capital

Financial

instruments,

with risk and

equity capital

1. " Sustainable and integrated urban development" 78% 20% 1%

1.1 Providing support for energy efficiency and use of

renewable energy in public infrastructure, including public

buildings and housing

80% 20% 0%

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

142

1.2 Actions to improve the urban environment, including

regeneration of brownfield sites and reduction of air

pollution

85% 14% 2%

1.5 Investment in health and social infrastructure 51% 44% 5%

1.6 Developing environmentally friendly and low-carbon

transport systems and promoting sustainable urban mobility

85% 15% 0%

5. Regional tourism 50% 45% 5%

TOTAL 82% 17% 1%

Source: OPRG 2014-2020 (Project of September 2013), own calculations

Interventions under OPRG 2014-2020, for which there is no application of financial

instruments are in the field of education, health and social infrastructure, with the exception of

sports infrastructure and regional road infrastructure, where the potential for return on

investment is weak and beneficiaries are state or municipal structures.

The proposed areas of investments with financial instruments are consistent with the types of

urban development projects defined by Kreuz (2010) that are supported through financial

instruments, namely, energy efficiency projects, investment in urban infrastructure,

investment in environment, investment in “smart cities"(for urban environment) and terrain

restoration projects6. In summary, it can be concluded that the types of activities and

projects that can be realized with the use of financial instruments are correctly

identified.

With regard to the relationship between grant funding and financial instruments, it is hard to

find reference points for each investment priority, because of the relatively low use of

financial instruments in the current programming period. According to a research of the

European Commission, in the current period (to 2011 incl.) about 5% of ERDF funds have

been used for the implementation of financial instruments7, and most of them were designed

to support businesses.

The managing authorities of operational programs have a strong incentive to allocate more

funds for financial instruments in order to increase the utilization of funds under the program

and to increase the resources for the respective activities through the so called leverage effect,

as well as because of the revolving character of the financial instruments.

6Kreuz C., 2010,„JESSICA – UDF typologies and governance structures in the context of JESSICAimplementation”, Report to the EIB and European Commission. 7European Commission, 2012,„Financial instruments in Cohesion Policy”, Commission Staff Working Document, SWD (2012) 36 final, DG REGIOnal Policy, Brussels.

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

143

However, the determination of the amount for financial instruments should take into account

the existing market failures, to be based on an assessment of potential interest for participation

by the private sector and identification of the target beneficiaries, i.e. to be determined after a

thorough assessment of the possibilities for the use of financial instruments in this context.

According to the current version of the European regulations regarding the use of financial

instruments within the programs funded by ERDF, there is no requirement that such

evaluations should be ready at the time of submission of the operational programs, they

should be worked out when planning the introduction of the respective financial instrument.

Regarding financial instruments for urban development, the main challenges for their use in

the next programming period are: 1. this approach is relatively new and has not been

developed sufficiently in comparison with the tools for helping businesses, for example, and

2. According to a study of the results of the implementation of financial instruments,

commissioned by EIB, because of the integrated nature of urban development, the design and

implementation of such projects require good coordination and a sufficiently high return on

investment for the project to be eligible to financial instruments8. At the same time it is stated

that the development of urban development projects needs more time, it is not clear whether

the projects for urban renewal could generate sufficiently high financial returns to justify their

implementation in financial instruments.

Beyond these substantive issues in the implementation of financial instruments for urban

development, there are regulatory uncertainties at EU level to be determined and will have an

effect on the decision of the proportion of financial instruments in the respective priorities of

OPRG 2014-2020. During the next programming period, the strategic EC documents provide

a number of measures to facilitate the use of financial instruments, but still it is not clear how

the rule on the automatic loss of funds (N+3/2 rule) will be applied for the financial

instruments.

Due to the above reasons, it is recommended to carry out further in-depth analysis of the use

of financial instruments for urban development. In order to limit the risk, it is recommended

to consider reducing the financing instruments of interventions related to cultural and natural

heritage and tourism. There are two reasons: 1. a considerable share of the financial

instruments (about half of the total resource) is provided for these activities, and 2. lack of

information on potential interest in financial instruments, especially in terms of cultural

heritage.

Given the experience with the Fund for housing renovation in the current programming

period, a higher share of financial instruments could be set for energy efficiency. However,

given the high share of this investment priority in the budget of the program, it is also eligible

to save 20% share of the financial instruments to reduce the risk of non-utilization of funds

under OPRG 2014-2020.

8 Mazars, Ecorys and EPRC, 2013, Financial Instruments:A Stock-taking Exercise in Preparation for the 2014-2020 Programming Period, Final Report,http://ec.europa.eu/regional_policy/thefunds/instruments/doc/fls_stocktaking_final.pdf

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

144

Territorial allocation, allocation by beneficiaries and thematic objectives under OPRG

2014-2020

Most of the financial resources are intended to be used by 67 municipalities identified in the

Concept of spatial development. In addition to the 62% percent of the resources that are

provided by PA1 "Sustainable and Integrated Urban Development", investments under the

program in these communities will be made under the other priority axes as well. Agency

"Road Infrastructure" will also have access to substantial financial resources under PA6

"Regional Road Infrastructure", given the resource consuming activities funded under this

priority axis. Other beneficiaries include the Ministry of Education and Science, Ministry of

Culture, Ministry of Health, universities and research centers, etc.

Taking into account the concentration of large amounts of financial resources under OPRG

2014-2020 over the 67 cities, the regional allocation of resources, in general, is consistent

with the distribution of these cities on the territory of Bulgaria. The concept of spatial

development gives the distribution of cities by region, as they are relatively evenly distributed

throughout the country.

According to the thematic objectives, the interventions under OPRG 2014-2020 address

mainly thematic objectives 6, 7 and 4. It should be noted that, given the impossibility to fund

projects under thematic objectives 1-3 through the program, the high share of thematic

objective 4 is justified both for the needs identified in the socio-economic analysis, and for the

requirements for thematic concentration of interventions in the project on ERDF Regulation.

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

145

Figure 26: Financing as per thematic objectives

In the figure above, it is clear that the main focus of OPRG 2014-2020, will be the

environment because of the urban environment, and the low-carbon economy. However, the

program aims to address infrastructure and other aspects of important social issues such as

education and social inclusion, which should have a positive impact on growth and

employment.

Benchmarking against Operational Program “Regional Development” in 2007-2013

(i) Comparison with budget OPRD 2007-2013 on investment priorities

According to the current version of OPRG 2014-2020, the funds under OPRG for the next

programming period would decrease by over one fifth in real terms. In the current

programming period 2007-2013, Operational Program "Regional Development" budgeted

1.361 million (EU funding), which represents 42% of the total ERDF allocation for Bulgaria

and 20% of all budget commitments under the Structural Funds and the Cohesion Fund in

Bulgaria.

The table below provides an overall comparison of European funding under OPRD in the

current and next programming period:

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

146

2007-2013 2014-2020 Difference

OPRG, budget commitments, EURO mln., current prices

(EURO)

1 361 083 545 1 170 270 000 -15%

OPRG, budget commitments, EURO mln., 2011 prices

(EURO)*

1 473 280 602 1 170 270 000 -22%

Share of funding under OPRG by ERDF for Bulgaria 42% ??? ??? п.п.

Share of funding under OPRG by SCF for Bulgaria 20% ??? ??? п.п.

Source: National Strategic Reference Framework of Bulgaria 2007-2013 and the Operational program "Regions of growth

2014-2020," (Project of December 2012)

*Budgetary commitments as per 2011 prices are calculated as those under current prices of 2007 are indexed for inflation of

2% per annum, corresponding to the European average annual change in the CPI and the provisions of Article

83 Paragraph 1 of the General Regulation of SCF.

The structure of the program's funding reflects the identified importance of cities as a key

driver of economic and social development of the EU. The greater importance of investments

in integrated actions for sustainable urban development in the next programming period can

be seen from the comparison of resource allocation of OPRG under Priority Axes, which is

presented below.

Program document

2014-2020

Budget

structure

of

OPRG

2014-

2020

Budget

structur

e of

OPRD

2007-

2013

Amendment

ОPRG 2014-

2020/ OPRD

2007-2013

Amendment

ОPRG 2014-

2020/ OPRD

2007-2013

In real terms

Energy efficiency 234 054 000 20% 6% 175% 154%

Urban environment and risk prevention 213 457 248 18% 14% 13% 5%

Sports, culture, education, health and social

infrastructure

322 058 304 28% 24% -2% -10%

Education infrastructure 108 132 948 9% -

Health and social infrastructure 213 925 356 18% -

Integrated urban transport 105 324 300 9% 13% -41% -46%

Tourism 105 324 300 9% 13% -43% -48%

Regional road infrastructure 143 241 048 12% 20% -47% -51%

Information and communication networks and

services

- - 1% - -

Local development and cooperation - - 6% - -

Technical assistance 46 810 800 4% 3% 2% -6%

Total 1 170 270 000 100% 100% -15% -22%

Source: Operational Program Regional Development 2007-2013 (October 2010) and Operational Program Regions in

Growth 2014-2020 (Project of September 2013), own calculations

In most cases the direct comparison of the priority axes of OPRG for 2007-2013 and the draft

OPRG 2014-2020 is not possible, but the rough comparison made within the framework of

this evaluation gives a good idea of the financial expression of the change in prioritization

within the operational program. The scope of the defined priorities for the purposes of

comparison is given in the table below. No direct matches with the measures of OPRG 2014-

2020 were found for sub-priorities 2.2, 4.1 and 4.2 of OPRD 2007-2013

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

147

Priority OPRG 2014-2020,

Priorities and

subpriorities

OPRD 2007-2013,

Priorities and

subpriorities

Energy efficiency 1.1 1.2, 2.3

Urban environment and risk prevention 1.2 1.3

Sports, culture, education, health and social infrastructure 1.3-1.5, 2, 3, 4 1.1

Integrated urban transport 1.6 1.5

Tourism 5 3

Regional road infrastructure 6 2.1

Technical assistance 7 5

Although rather general, the comparison of the allocation of the program's budget in the

current and next programming period gives a good idea of the change in the policy of regional

development. Some of the differences in the share of the priorities and the total budget of the

Program is determined by the new EU-wide priorities, and some are probably associated with

the experience of the Managing Authority of the period 2007-2012.

The most significant difference is observed in terms of investment related to the improvement

of energy efficiency which in the next programming period will be in a separate investment

priority; 20% of the total program budget are expected to be spent for them. As mentioned

above, this type of investments are directly related to Thematic Objective 4 "Transition to a

low carbon economy" and should have a significant contribution to meeting the requirement

of the draft ERDF Regulation related to the requirement for financing activities under this

Thematic Objective in less developed regions with at least 10% of the total ERDF funding.

The overall investments of sports, cultural, educational, health and social infrastructure

and the urban environment and risk prevention are expected to increase slightly, which,

given the overall reduction OPRG 2014-2020, will increase their share by 4 percentage points.

This type of measures are mainly related to Thematic Objective 6 (environment) and partly

with Thematic Objectives 9 (social inclusion) and 10 (education). These thematic objectives

are not priorities for ERDF funding outlined in Art. 4 of the draft Regulation of ERDF, but

they have an important regional dimension and potentially greater positive impact in the

socio-economic aspect as well as on the integration of sectoral policies at territorial level. The

importance of social inclusion and education specifically acquire financial impact in Article

84 of the General Regulation of ESIF where limit is set between 20 and 25 % of the Structural

Funds to be invested for achieving the Thematic Objectives 8, 9 and 10.

Regarding measures for risk prevention in the next programming period allocated funds are

expected to significantly reduce. It is noted in the program document OPRG 2014-2020 that

this is due both to the probability of not meeting the thematic preconditions. Additionally,

probably for the purpose of this investment priority not sufficient resources can be allocated

to achieve the necessary level of fund concentration so that they could have a tangible effect.

Instead, it is planned to finance a small number of landslides prioritized on the basis of a

specially designed methodology.

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

148

Significant decrease is observed in the financing of transport projects. Projects in the field

of tourism will also receive less funding in real terms compared with the current

programming period, in spite of the guidelines in the draft of EFRD Regulation for promoting

sustainable tourism, cultural and natural heritage in order to maximize the contribution of

interventions for generating growth based on employment. The lower share of the funds

allocated to tourism development could be partly explained by the relatively low level of

payments under Priority 3 (sustainable tourism) of OPRD 2007-2013. As of October 2012, 15

% of the budget commitments are paid under it, compared with 31% on average for the

program. These results are due to the delay at the start of the implementation of the activities

for development of tourism and can have a negative impact on the results under Priority 3 for

the whole period of 2007-2013.

(ii) Overview of EU funds utilization under OPRG in the current programming period

In terms of effectiveness and efficiency of utilization of funds under OPRG in this period and

potential implications for the next one, only a few general observations can be made. A

thorough study of this issue requires detailed information on the financial and physical

performance of the individual projects supported under OPRG to date, which is not subject to

this evaluation.

Under OPRG 90% are contracted as of October 2012, but less than 30% are paid. Highest

rates of payment are observed under PA 2 "Regional and local accessibility" where nearly

half of the planned budget funds are already paid. The reasonably good financial result is not

fully consistent with the performance of the progress indicators; at present the rehabilitated/

reconstructed roads in kilometers are just over 1/3 of the program's targets. This discrepancy

could be partly due to the specifics of the activities under PA2 in which there could be a time

lag between spending the funds and reporting the physical progress.

Under PA 4 "Local Development and Cooperation" there is also a good financial and physical

performance. Here, however, it seems that the target values of the indicators are set too

conservatively as 36% of the financial resources are actually exceeded targets in terms of

physical progress.

These two different examples show that in terms of successful implementation of the program

in 2014-2020, regarding the connection between financial allocation and indicators, it is

necessary to ensure well-founded logical connection between resources and objectives,

whether at cost principle or based on a benchmark against similar activities in the previous

programming period or such other operational programs.

Only for comparative purposes, the table below presents the financial and physical

implementation under OPRD 2007-2013, at the end of 2011 (data as of October 2012, which

are publicly available, are shown in brackets):

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

149

% total budget

of OPRG

Contracted Disbursed Certified Achieved so far Target

value

Type of

indicator

Indicator: period of reporting

1. Sustainable

and integrated

urban

development

52% 72%

(91%)

20%

(28%)

11% At least 2 years

17 789 (29 293)

33 800

няма пр.д-ри

565 346 (760 000)

Н/П

Н/П

7 (43)

Н/П

0

101 (173)

20 (55)

8

Н/П

0

56

189 000

10 000

600 000

230 000

800

5

200

20

32

45

90

70

10

36

Impact

Result

Result

Result

Result

Result

Result

Output

Output

Output

Output

Output

Output

Output

Output

1. Reducing greenhouse gas emissions (kt)

2. Saving energy renovation of buildings (MWh / yr).

3. Students benefiting from improved educational infrastructure (number)

4. Patients benefiting from improved health infrastructure (number)

5. Population benefiting from refurbished buildings (with the exception of education and

health institutions) (number)

6. Children benefiting from the process of deinstitutionalization (number)

7. Use of urban public transport (incl.people with disabilities) (% increase of population)

8. Projects improving the physical environment, attractiveness of cities and risk

prevention

9. Renovated multifamily buildings and social housing

10. Improved health infrastructure

11. Improved educational infrastructure

12. Improved cultural infrastructure

13. Improved social infrastructure

14. Constructed/reconstructed social institutions/centers as a result of de-

institutionalization of child care (number)

15. Developed/implemented integrated urban plans

2. Regional and

local accessibility

25% 78%

(90%)

27%

(47%)

15% At least 2 years

At least 2 years

няма пр.д-ри

At least 2 years

няма скл.д-ри

Н/П

161.19 (454)

39

208 000

20%

27

500

50

1300

Impact

Result

Result

Result

Result

Output

Output

Output

1. Reducing greenhouse gas emissions (kt)

2. Value of time savings in Euro/per annum resulting from reconstructed roads for passengers and

freight

3. Additional population covered by broadband access (key indicator) (%)

4. Increase traffic of passengers and freight on the rehabilitated roads (base 2006) (%)

5. Developed ICT network (km)

6. A gas infrastructure with neighboring countries on the territory of Bulgaria (km)

7. Reconstructed roads (km)

3. Sustainable

development of

tourism

14% 51%

(93%)

4%

(15%)

0.5% няма пр.д-ри

няма пр.д-ри

няма пр.д-ри

няма пр.д-ри

няма пр.д-ри

няма пр.д-ри

няма пр.д-ри

няма пр.д-ри

Н/П

1 475

45%

500 000

80%

1 050

129

95

34

70% вкл. в

мрежа

Impact

Impact

Result

Result

Result

Output

Output

Output

Output

1. Net annual income from international tourism (million Euro)

2. Bed occupancy rate

3. Additional annual number of visitors to supported attractions

4. Visitor satisfaction of attractions and information services

5. Annual number of participants (organizations, companies) in international, national and regional

tourism fairs and exhibitions

6. Total number of projects for tourism development

7. Number of developed tourist attractions/sites

8. Number of national marketing programs iand advertising and projects for product development

and marketing of destinations

9. National operating network of TICs

Ex-ante Evaluation of Operational Program for Regional Development in the 2014-2020

programming period

150

4. Local

development and

cooperation

6% 91%

(93%)

34%

(36%)

24% 122

622 000

109

61

80

166 000

250

40

Result

Result

Result

Result

1. Innovative practices exchanged and applied on the basis of inter-regional cooperation

2. Population benefiting from small-scale investments

3. Completed projects for small-scale investments

4. Interregional cooperation projects

5.Technical

assistance

3% 53%

(65%)

11%

(21%)

6% 0

1 328

6 448

10

184

2

40%

15 500

4 500

14

60

10

Result

Output

Output

Output

Output

Output

1. Level of public awareness about OPRG

2. Technical support, advice, etc. (man-days)

3. Trained employees of the MA (including regional departments) and beneficiaries

4. Meetings of the Monitoring Committee

5. Conducted information campaigns and public events under the Communication Plan

6. Evaluations performed

TOTAL 100% 71%

(90%)

20%

(31%)

11%

Source: Annual Report on the Implementation of OPRD 2007-2013 for 2011, CEAOEF, Report on EU fund management in the Republic of Bulgaria for 2012. own calculations

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

151

Results of a survey on the allocation of financial resources of OPRG 2014-2020

The survey conducted among beneficiaries, representatives of the Managing Authority and

other stakeholders is a useful source of information on the allocation of financial resources

against the objectives of the program. Responses to the survey show a large dispersion of

individual assessments on how to allocate the program budget, but grouped in beneficiaries

and representatives of MA, in an average ratio they approach one another, as well as the

proposed allocation in the current version of the OP. Allocation of financial resources based

on the conducted online survey and according to the current draft of OPRG 2014-2020, is

presented below:

Indicative types of interventions Beneficiaries and

working group MA OPRG9

Energy efficiency in public (administrative) buildings and

houses 16% 12% 20%

Improving the urban environment (public recreation

areas), with the exception of the technical infrastructure

related to business and industrial zones

18% 19% 13%

Preventing floods and landslides

7% 4% 1%

Improving access for people with disabilities as a

horizontal measure

5% 4%

Construction/rehabilitation of technical infrastructure

related to business and industrial zones

7% 4% 4%

Infrastructure development in the field of culture and

development of tourism 13% 15% 9%

Development of education and scientific infrastructure 8% 10% 9%

Development of social infrastructure 8% 5% 14%

Development of health infrastructure 9% 14% 4%

Development of urban transport infrastructure 8% 14% 9%

Regional road infrastructure 12%

Technical assistance 4%

Source: Online questionnaire

9 The questionnaire does not present the issue of budget allocation under PA 5 and PA7

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

152

Based on the results of the consultation with beneficiaries and MA of the program, increased

fund allocations are found against the responses in the questionnaire within the OPRG 2014-

2020, only in terms of energy efficiency and social infrastructure.

As already mentioned several times, the larger share of thе investment priority for energy

efficiency should contribute to Thematic Objective 4, which is a priority for the

implementation of EFRD. In terms of social infrastructure, the current version of OPRG

includes also sports and cultural infrastructure that expands the scope of this investment

priority against the questionnaire and contributes merely technically for its increased share.

The funds allocated for improving the urban environment are lower than the aggregated

responses to the questionnaire, again mainly due to the relocation of the sports and cultural

infrastructure of the urban environment to the social infrastructure.

It can be concluded that the indicative fund allocation under OPRG 2014-2020 as a whole

does not contradict the average responses of the online survey conducted for the project

among representatives of MA, beneficiaries and other stakeholders.

Analysis of the extent of conformity of the financial allocation under OPRG 2014-2020

as per the requirements of the EU regulations.

(iii) Degree of compliance with the formal requirements in describing the financial

framework in the program document and co-financing;

According to the current version of the Common Strategic Framework for EU (Article 87,

item 2 (d)) from November 2012, the financial plan for each operational program must

contain at least two tables:

1. Table of the financial commitments by year under each of the Funds financing the

operational program, in accordance with Art. 53, 110 and 111 of the General

Regulation of ESIF. According to the regulation, the amount of co-financing under

the relevant priority axes of the

operational programs will be

determined by EC. Regarding

OPRG, it cannot exceed 85% (for

the less developed regions of the

Member States whose average

GDP per capita for the period

2007 to 2009 was below 85% of

the average EU-27 for the same

period and for the outermost

regions).

A table with the breakdown of

budget commitments under

OPRG 2014-2020 by year is

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

153

presented in the current version of the operational program (Table 17), but it will

probably be changed when the total financial allocation for OPRG is clarified.

In the current profile of the budget commitments, many low targets for the first two

years of the new programming period are identified, and relatively steady increasing

but higher budgetary commitments thereafter.

On the assumption of applying the N+2 rule for automatic loss of funds, this means

that at the end of 2019 a risk of losing money can be expected, which gives enough

flexibility for maximum utilization of funds, taking into consideration the long

average period of implementation of most projects which will be financed under the

operational program for the next programming period.

2. Table specifying for the whole programming period of the operational program and

for each priority axis, the amount of the total financial budget commitments for each

fund providing resources to the program, and the amount of national co-financing as

well. Regarding priority axes that affect several categories of regions, the table is

necessary to indicate the amount of total financial budget commitments by funds and

national co-financing rate for each category of regions. Regarding priority axes that

combine investment priorities of different thematic objectives, the table indicates the

amount of the total financial commitments of each of the funds and the national co-

financing for each of the respective thematic objectives. When the national co-

financing is made up of public and private financing, the table provides indicative

breakdown between the public and private sectors. It indicates information on the

planned participation of EIB.

Such a table of indicative targets has already been presented in the section related to

the financial plan of the program (Tables 18 and 19). It gives information about the

area of planned interventions, forms of funding and their territorial and thematic

dimension. In the tables, the private national co-financing, EIB contribution and other

financing are not set because at present these types of financing are not planned.

(iv) Consistency and justification of the allocation of budgetary resources as per the

requirements of the European regulations

With the changes of the financial framework for the next programming period, at EU level a

greater importance is given to a number of measures and approaches inherent to the types of

interventions financed by OPRG, such as strengthening the role of cities as centers of growth

and promotion of integrated territorial investments. Generally, a new territorial dimension of

cohesion policy is added, whose aim is to ensure better compliance with and focus on

cohesion policy in response to the specific needs and opportunities arising in specific areas.

A brief description of the most important European priorities and requirements

relevant to OPRG 2014-2020

Strengthening the role of cities, focusing on the priorities defined in Europe 2020

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

154

Strategy and the adoption of integrated approach in supporting by European funds, are

the basis of EU Cohesion Policy 2014-2020. Art. 16 of the General Regulation of SCF

postulated concentration of support financed by European funds on interventions that

would have the greatest added value for the realization of the objectives of Europe 2020

Strategy for smart, sustainable and inclusive growth, using the effective potential of

specific areas and taking into account national and regional needs.

Based on this more general framework for the prioritization of interventions funded by

ESIF, the ERDF Regulation projects set minimum requirements on the thematic

concentration of interventions financed by ESIF funds. The project of general

regulation of ESIF (Article 84, item 3), however, sets the target for investments aimed

at youth integration, employment, knowledge, and social inclusion. According to it, in

the less developed regions, and all Bulgarian regions are considered such, between

20% and 25% of the structural funds should be directed to the Thematic Objectives 8

(employment), 9 (social inclusion) and 10 (education ).

The General Regulation for ESIF also determines 0.2% of the resources available

under EFRD for growth and employment to be focused on innovative actions for

sustainable urban development. Achieving this financial goal is not a responsibility of

the Member States, and it is supposed to be implemented on the initiative of the

European Commission.

The ERDF Regulation project sets certain restrictions on the thematic concentration of

aid financed by the Fund. Art. 4 of the Regulation sets minimum thresholds of

financing some thematic objectives that are different for the developed and transition

regions of the EU, on the one hand, and in less developed regions, on the other. Since

all regions in Bulgaria at present belong to the less developed regions, requirements for

them are less restrictive, given that these regions are facing many challenges in the

development and should have greater freedom in determining the various types of

investments as a priority. According to the Regulation, the following is required for less

developed EU regions:

(i) at least 50% of the total funds financed by ERDF nationally, are to be spent on one or

more of the following thematic areas:

(1) Strengthening research, technological development and innovation;

(2) Improving access to ICTs and their use and quality;

(3) Improving the competitiveness of SMEs;

(4) Supporting the shift towards a low carbon economy in all sectors.

(ii) at least 10% of the total funds financed by ERDF nationally, are to be spent for the

fourth thematic area, namely the shift to a low carbon economy.*

The project of ERDF Regulation (Article 5) provides a description of the investment

priorities that can be supported in conjunction with each of the thematic objectives. In

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

155

particular, the following objectives are defined as priority for urban investment:

* Thematic Objective 4: Transition to a low carbon economy, including promotion of

sustainable urban transport;

* Thematic Objective 6(f): Protection of the environment - improving the urban

environment;

* Thematic objective 9 (c): Promoting social inclusion - support for physical and

economic regeneration of deprived urban communities.

Considering the complex interconnection of different types of investments needed to

address the key challenges for cities in the next programming period, a new

management mechanism is introduced - Integrated Territorial Investments (ITI), which

provide synergy between different types of measures, often from different sources of

funding. For this purpose, Member States are required to set aside at least 5% of the

available ERDF resources for integrated actions for sustainable urban development,

the management of which will be provided by the cities**.

According to Art. 7, Para 1a of the draft ERDF Regulation, this requirement can be

fulfilled either by ITI or by integrated priority in the Operational Programme, the

second approach being set out in OPRG. Some additional 0.2% of the available

ERDF funds can be spent on innovative measures to ensure sustainable urban

development.

* For comparison, for the more developed and transition regions the minimum thresholds are

respectively 80% for TO 1-4 and 20% for TO 4.

** To this end, Integrated plans for urban regeneration and development (IPURD) have been currently

developed in Bulgaria in 36 towns of the 1-3 hierarchy level, according to the new concept for spatial

development 2013-2025. A new scheme for grants to prepare IPURD for the towns of level 4 should be

launched in January 2013

Above are described specific restrictions on the types of activities to be financed by ERDF

funds in each Member State, depending on the degree of development of its regions. Since

the overall financial framework for Bulgaria for 2014-2020 is unknown, and the financial

allocations to activities under other operational programs to be financed by the ERDF are also

unknown, at present the evaluation of the specific minimums and ceilings set out in the

project of EFRD Regulation is indicative.

Between 20 % and 25 % of the structural funds should be directed to the Thematic

Objectives 8 (employment), 9 (social inclusion) and 10 (education). OPRG 2014-2020

is related to the construction of adequate infrastructure under TO 9 and TO 10. For

this purpose, 20% of the total budget of the OPRG (including health care) have been

allocated, which should be more than a sufficient contribution to observing this

requirement of the General Regulation, given the presence of other ESF operational

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

156

programs that should provide the major funds for implementing the interventions at

national level under these thematic objectives.

At least 50% of ERDF funds should be earmarked for financing activities under

Thematic Objectives 1-4. Of thematic objectives 1-4, OPRG is related to TO 4

"Transition to a low carbon economy." In this allocation of resources under OPRG

2014-2020, about 29% are provided under TO 4 covering both energy efficiency

measures and investments for sustainable urban transport. It should be borne in mind

that most of the activities on priority set Thematic Objectives 1-4 are expected to be

included in the scope of the future Operational Program "Development of

Competitiveness of the Bulgarian Economy" (OPDCBE).

At least 10% of the total funds financed by the ERDF nationally are to be spent on the

transition to a low carbon economy. In terms of available OPRG information, this

requirement is expected to be satisfied. Probably activities under this thematic

objective will be funded under a future OPDCBE.

At least 5% of the total funds financed by the ERDF to be allocated nationally for the

implementation of integrated territorial investment. Currently, virtually all budgeted

funds under PA1 "Urban development" or 62% of all resources of the program are

intended for the implementation of PA1. It should be borne in mind that these funds

are likely to be completed by funds for the realization of PA1 by the future OPE and

OPHRD. While OPHRD is entirely financed by ESF, in OPE 2007-2013, about 30%

of the funding is by ERDF. In this sense, the requirement currently looks like it will

be executed without any difficulty.

Compliance with the funding, set in other strategic documents

With respect to the national strategic documents, the current draft of the Partnership

Agreement of the Republic of Bulgaria, outlining the assistance of EU structural investment

funds for the period 2014-2020, the National Development Program 2020 and the National

Strategy for Regional Development, as these three documents provide information about the

financial security of the proposed measures National Development Programme 2020 and

National Strategy for Regional Development are mainly discussed as these three documents

contain information on the financial security of the measures envisaged.

The strategic priorities of the funding under ESIF are set out in the draft Partnership

Agreement of the Republic of Bulgaria, outlining the assistance of EU structural

investment funds for the 2014-2020 period. The support of EU funds which are generally

implemented within OPRG should be thematically and territorially concentrated, as the

program is focused mainly on the integrated actions within 67 towns in the country identified

in the new Concept of spatial development 2013-2025.

In terms of thematic objectives, given the wide range of measures for regional development,

the program still focuses on 6 Thematic Objectives and more than 2/3 of the total resources of

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

157

the program are allocated for TO 6 (environment), TO 4 (low-carbon economy) and TO 7

(sustainable transport).

Given the identification of strategic territorial dimension of the interventions planned in the

Partnership Agreement and the important complementary role of OPRG 2014-2020,

especially in terms of priorities for education and social inclusion, the successful

implementation of the investments provided by the program has a vital role in achieving the

national objectives in the context of Europe 2020 Strategy and in addressing the key

challenges facing the country in socio-economic terms.

A separate Priority 3 "Achieving sustainable integrated regional development and use of local

potential" is formulated in the National Programme for 2020. There is also a calculated

value of the implementation of measures envisaged in the document. It amounts to 28.347

billion BGN, of which nearly ¾ should be secured by EU funds, 20% - by national and 6% -

by other sources of funding. Obviously the lack of funds compared to the measures referred

to in NDP 2020 on regional development is great. There is no further breakdown of the

valuation on measures, which does not allow a direct comparison with the financial resources

provided by OPRG.

In the National Strategy for Regional Development there is also an estimate of the

resources necessary to achieve the objectives of the strategy. With respect to financing with

funds of ERDF as per priorities supported by OPRG, there is a greater funding for integrated

sustainable urban development, improvement of connectivity of regions and improvement of

access to education, health, social and cultural services, and sports infrastructure. They

generally correspond to the financial priorities of OPRG 2014-2020, but as a share of the total

ERDF resources they are incomparable because operational programs other than OPRG are

also financed by ERDF funds.

EFRD

P 1.1 Activating the specific potential of local and regional economies. 10%

P 1.2 Development of sustainable forms of tourism 7%

P 1.3 Development of the infrastructure for environmental protection (it will be financed mainly by OPE) 17%

P 2.1 Improvement of access to education, health, social and cultural services, and sports infrastructure

11%

P 2.2 Support of labor geographical mobility 1%

P 2.3 Capacity development 4%

P 3.1 Development of cross-border cooperation 5%

P 3.2 Development of interregional and transnational cooperation 2%

P 4.1 Integrated sustainable urban development 31%

P 4.2 Improving the connectivity of regions 14%

P 4.3 Improving life quality in rural areas. (to be financed mainly by OP DRA) 0%

Source: National Strategy for Regional Development of the Republic of Bulgaria for the period 2012-2022, own calculations

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

158

VIII. Evaluation 6 – Assessment of the

management and monitoring systems and

administrative capacity for implementation of

the Program

1. Data collection

Evaluation 6 is based mainly on a desk study of documents, including analysis of the

administrative capacity, namely:

“Assessment of the administrative capacity of OPRG Beneficiaries”

Analysis of the capacity and capability of municipalities to manage and implement

projects, comprising an element of the overall project for preparing a social and

economic analysis for the needs of OPRG 2014–2020

Report by the Committee for European Affairs and Control over the European Funds

(CEACEF) for 2012.

Medium-term evaluation of Operational Programme Regional Development 2007–

2013.

Annual report on the implementation of OP “Regional Development” 2007–2013 in

2011.

The online questionnaire was also one of the ways to take into account the beneficiaries’

opinion of their own capacity to implement OPRG projects, as well as of the capacity of the

MA. At the focus groups held with beneficiaries and representatives of the Working group

for development of OPRG 2014–2020 issues were also discussed related to the administrative

capacity of the MA and the beneficiaries.

What is specific for Assessment 6 was that an online questionnaire was also carried out

among officials from the Directorate General “Programming of Regional Development”

(DG PRD) for the purpose of self-assessment of the administrative capacity, workload,

procedures, training needs, etc. To achieve greater thoroughness, in the course of the

individual interviews held with experts from DG PRD questions falling within Assessment 6

were also discussed.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

159

2. Analysis

(b) 2.1 Analysis of the beneficiaries’ capacity

In Section 3.B.1. of OPRG 2014–2020 the following summarised needs of the beneficiaries

to be addressed through the measures under PA 7 were identified:

continuing need to increase the competence of staff involved in the preparation and

management of projects;

need to increase the motivation and remuneration of experts involved in preparation

and management of projects;

need to provide the units involved in the preparation and management of projects with

facilities and equipment, including computer equipment, specialised software,

vehicles, etc.

In the course of development of this report, the documents containing assessment of the

administrative capacity of beneficiaries were examined for the purpose of establishing how

well they are identified in the OPRG 2014–2020 problem areas.

The General Action Plan to Enhance the Administrative Capacity of 36 Municipalities –

OPRG Beneficiaries (December 2012 version) contains recommendations with regard to the

administrative capacity, related to the next programming period. Some of the conclusions and

recommendations of relevance to OPRG 2014–2020 are specified below.

Conclusions:

“With regard to most beneficiaries the number of staff in the units involved in OPRG

projects is assessed as insufficient, and the workload – as very big

The educational degree of the officials involved in OPRG is assessed in most cases as

appropriate / relevant, and the level of competencies is assessed as meeting the

requirements

There is an acute shortage of funds for training and a critical need for additional, more

targeted specialised training for officials, including training by the OPRG MA

The main difficulties in the awarding of public procurement contracts for projects

co-financed from OPRG are related to:

o development of technical specifications / terms of reference, formulating

criteria for participation, and evaluation of tenders;

o ambiguous interpretation of the Public Procurement Act by various control

and law enforcement agencies;

o increasing the duration of the period for ex-ante control;

o appeals against acts issued by the Contracting Authority.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

160

No problem areas are established in the partnership with other organisations /

municipalities

As a whole, municipalities declare readiness to use PPPs for the implementation of

revenue generating infrastructural projects and for the implementation of JESSICA,

but do not have any specific project ideas for them”

Recommendations

“To analyse the opportunities for using technical assistance (to finance training and

computer equipment, information and communication technologies) from existing

programmes, co-financed by the EU, for increasing the motivation of the staff

To assess the workload of the individual units, involved in projects co-financed from

EU Funds, and the number of staff in relation to the functions and activities in the

administrative units, and to make the corresponding recommendations for

reorganisation of human resources or other changes in the structural units

To improve the capacity for preparation of income generating projects, including

through additional training on the opportunities offered by financial engineering

instruments, Cost-benefit analysis and financial analyses.

Municipalities to be identified during the next programming period as eligible specific

beneficiaries of most operations under Priority Axis “Technical Assistance” of OPRG

for preparing technical / working designs and feasibility studies for infrastructural

projects, as well as for preparation and monitoring of the GDPs of municipalities.”

Source: General Action Plan to Enhance the Administrative Capacity of 36

Municipalities – OPRG Beneficiaries

The General Action Plans to Enhance the Administrative Capacity of the OPRG Specific

Beneficiaries (December 2012 version) contains conclusions recommendations, similar to

these in the general action plan specified above. Some of the conclusions of relevance to

OPRG 2014–2020 are specified below.

Conclusions:

“The majority of the specific beneficiaries have the structural units required for the

implementation of OPRG projects;

As a general trend with regard to the specific beneficiaries the need to increase the

number of staff involved in work related to OPRG is observed;

All specific beneficiaries define the need for more training in connection with OPRG

projects;

The most frequently identified measures for increasing the motivation include:

increased remuneration, ensuring a better work environment, provision of modern

computer equipment and updated software for project management.”

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

161

Source: General Action Plan to Enhance the Administrative Capacity of the OPRG

Beneficiaries

With a view to the above the conclusion can be made that the summarised needs of the

beneficiaries identified in Section 3.B.1. of OPRG 2014–2020 are correct.

The training needs of the beneficiaries, identified in the analyses, was also established in the

course of the online survey carried out within the preliminary assessment. According to the

results of the survey, over 70% of the respondents are of the opinion that the training events

will be a necessity during the next programming period.

Figure 27: Questionnaire - needs of beneficiaries in relation to the preparation and

management of projects under OPRG 2014-2020

As becomes clear from the figure below, the strengthening of the capacity of the beneficiaries

themselves is identified as a main area where strengthening of the capacity for the

implementation of OPRG 2014–2020 is required. This need is also included in the

recommendations of the CEACEF report (2012), namely: “Strengthening the capacity of

specific beneficiaries – government institutions for preparation and implementation of

projects under OPRG” and “Strengthening the capacity of OPRG beneficiaries for

implementation and reporting of projects, as well as for applying financial engineering

instruments”.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

162

Figure 28: Questionnaire – areas, where the administrative capacity needs to be

improved

Over 70% of the beneficiaries and members of the working group, which participated in the

survey, are of the opinion that the administrative capacity of beneficiaries needs to be

enhanced, and the MA shall provide more information and support in the course of the

programme implementation. The participants in the online survey identify the following

qualifications as the ones with the highest priority during the next programming period:

Project management (82%)

Financial Management and Control (68%)

Project preparation (54%)

Language skills, as well as ability to work with software applications, are not identified

among the main qualifications that must be strengthened for the 2014–2020 programming

period. At the same time, the 2011 annual report of the OPRG MA reports the capacity of

beneficiaries to conduct tender procedures as a critical factor in the programme

implementation. It is exactly public procurement that is expected to be the most important

component of the implementation of OPRG projects during the next programming period.

This expectation was confirmed by the focus group held with representatives of beneficiaries

in June 2013. In addition to training related to the PP Act as horizontal training for all

beneficiaries, the participants in the focus group recommended that training is also organised

for enhancing the quality of construction supervision. A more general recommendation by the

participants in the focus group is than UMIS is used to a larger extent, mostly with regard to

electronic invoices and disbursements.

The figure below presents the results with regard to the needs for strengthening the

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

163

administrative capacity, which in the opinion of the participants in the online questionnaire

(beneficiaries and representatives of the working group) need to be reflected in OPRG 2014–

2020.

Figure 29: Questionnaire–areas where administrative capacity should be improved

Project management is once again identified as a main area where training needs to be

organised, followed by training in reporting of implementation. According to the participants

in the survey, the guidelines and manuals are not a basic instrument influencing the

administrative capacity.

A specific issue is how municipalities – specific beneficiaries under priority axis 1 can

assume the responsibility, that can be delegated to them pursuant to Article 113 (6) or

Article 113 (7) of the draft CPR, in accordance with Article 7 (2а) of the draft ERDF

Regulation. Pursuant to Article 113 (6-7) CPR, Member States can formally identify

intermediate bodies, to which the management of part of the programmes can be delegated.

Respectively, as stipulated in Article 7 (2а) of the draft ERDF Regulation, towns or regional

authorities shall be responsible at least for the selection of operations. With regard to OPRG

2014–2020, this responsibility for selection of operations is realised by municipalities

through the development of IPURDs and within the discussions of the TWG, where they

have representatives. For the purpose of supporting the capacity of municipalities to develop

IPURDs, under OPRD 2007–2013 two grant schemes are implemented: BG161PO001/1.4-

07/2010 “Support for Integrated Plans for Urban Regeneration and Development” and

BG161PO001/5-03/2013 “Support for Integrated Plans for Urban Regeneration and

Development II”.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

164

(c) 2.2 Analysis of the MA capacity

With regard to the management structure of OPRG 2014–2020, one of the recommendations

in the medium-term evaluation of OPRD 2007–2013 is that during the next programming

period the functions related to the management and implementation of the programme be

assigned to individual organisations, i.e. the MA to be responsible for the policies, and the

IBs to be responsible for the management and implementation of projects. Regardless of this,

neither the majority of the members of the working group for the development of the

programme and the beneficiaries nor the majority of the MA representatives deem it

necessary to include interim bodies in the management structure.

Figure 30: Questionnaire – necessity of intermediate units

As becomes clear from the figures above, 46% of the respondents – representatives of the

working group / beneficiaries and 53% of the MA representatives do not believe that it is

necessary to establish an IB. The advantages of IB, identified by the participants in the online

survey, are the greater efficiency of such a structure in terms of the easier communication

with beneficiaries and the reduction of the time required to process the application

documentation and reporting of project results. Nevertheless, both the results from the

questionnaire and the discussions within the focus group confirmed the opinion that the

setting up of intermediate bodies would create more structural and functional difficulties and

hindrances than improvements in the work.

The absence of clear need for changing the management structure of the programme is also

evidenced by the fact that the beneficiaries / the participants in the working group do not

believe that the structuring of the OPRG management is a priority area for strengthening the

administrative capacity.

Nevertheless, the results from the additional online survey among MA officials, conducted in

June 2013, demonstrate that it is necessary to clarify the allocation of the responsibilities

between the MA at central level and the regional departments of the MA.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

165

Figure 31: Management structure of OPRG - results of the online questionnaire

conducted in June 2013

As becomes clear from the figure above, 32% of the respondents find the allocation of

responsibilities between the central and regional level of the MA not good or excellent. The

opinion on this question of respondents from the central level of the MA is more negative.

The results with regard to the clarity of the allocation of responsibilities among the MA

departments are similar. The allocation of responsibilities among the sectors within the MA

can be considered relatively clearer.

In the report on the medium-term evaluation of OPRD 2007–2013 the conclusion is made

that the established management and control system, applied by the MA, is effective, but

problems are reported in the tracking of the values of indicators. The report identifies as a key

moment the delays in payments resulting from the requirement for 100% checks of the

verification at regional and central level. In this connection the recommendation is made that

the process of verification of requests for payment shall be entirely delegated to the regional

departments. This question was also asked in the questionnaire sent to the MA, and the

results are presented in the figure below:

Figure 32: Appropriateness of delegation the verification processes on regional

departments - results of the online questionnaire conducted in June 2013

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

166

As becomes clear from the figure, over half of the respondents do not think it is suitable to

delegate entirely the process of verification of requests for payment to the regional

departments. In this sense, the current situation related to the verification of requests can be

regarded suitable.

In order to take into account the opinion of the MA officials with regard to the main existing

procedures, the following question was included in the questionnaire:

Figure 33: Assessment of adequacy of procedures - results of online questionnaire

conducted in June 2013

The figure shows that the mechanisms for obtaining information about the indicators under

the programme are most problematic – 37% of the respondents are of the opinion that this

mechanism is “poor” of “satisfactory”, and 32% of the respondents think it is “good” or

“excellent”. The results regarding the obtaining of data required for conducting evaluations

are similar. Bearing in mind the even greater importance the EC attaches to indicators and

evaluations during the next programming period, these procedures need to be reviewed by the

OPRG MA.

Within this evaluation information was obtained through an online questionnaire about how

sufficient the human resources of the Managing Authority are for carrying out the main

activities entrusted to the MA. The figure below shows the results from the online

questionnaire, excluding the answers that the specific activity is not applicable to the

respondent.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

167

Figure 34: Sufficiency of human resources in MA - answers to the online questionnaire by June 2013

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

168

Based on the results from the questionnaire the conclusion can be made that as a whole the

human resources for the management and implementation of the programme are adequate.

Except for a few areas (listed below), over 50% of the OPRG MA officials, who participated

in the survey, are of the opinion that the human resources are sufficient or “mostly

sufficient”.

The areas in which resources are to a large extent in/sufficient are listed below:

The MA resources can be considered sufficient to the highest degree in the following

5 areas:

o Preparing decisions / orders / contracts for awarding grants

o Preparing payment documents to beneficiaries and contractors

o Receiving and registration of project proposals

o Preparing, conducting and drafting the minutes of the meetings of the MC

o Accounting

The MA resources can be considered insufficient to the highest degree in the

following 5 areas:

o Monitoring of the overall implementation of projects, including through

review of reports, meetings, discussions with beneficiaries, etc.

o Carrying out on-the-spot verifications and follow-up of the implementation of

the recommendations from these verifications

o Developing and updating of procedures, manuals, etc. (this area is identified

by the participants in the survey mostly due to the fact that the developing and

updating of procedures / manuals can be regarded as an accompanying

activity, which results in additional, not envisaged workload)

o Management of document turnover and of the archive within the MA

o Financial control

Therefore, based on these results the recommendation can be made for enhancing the

administrative capacity in the areas where it is regarded as insufficient. The following are

part of the recommendations for enhancing the capacity of the MA:

Involvement of the experts, who actually work using the manuals, in their updates,

and conducting training events for the entire MA staff following the update

Reliance on internal training

More civil engineers or specialists in the specific scheme to be involved in the

evaluation of project proposals in order to reduce possible omissions or confusions in

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

169

the project proposals, which are revealed later in the process of construction10

Simplifying the procedures with regard to document turnover

Introducing electronic document turnover so that documents are not printed and

checked in hard copy

Beneficiaries to be informed in detail of the need for information and publicity

activities so that they do not attach too little importance to these activities

In the medium-term evaluation of OPRD 2007–2013 it was recommended “to develop the

technical capacity of the regional departments through training in the field of public

procurement, financial control and monitoring procedures, use of UMIS and legal

requirements, related to the execution of works contracts”. The need for experts in specific

(technical) areas is also illustrated in the figure below, which shows the MA needs for experts

according to the MA officials, who participated in the online questionnaire. This need was

also identified by the participants in the focus groups with beneficiaries, held in June 2013.

Figure 35: Questionnaire – type of experts needed in MA

In the online questionnaire a question was also included regarding the human resources

management (HRM) at the MA. The results show that improvement of HRM is possible

mainly with regard to encouraging experts in the event of achieving good results (68% of the

respondents are of the opinion that improvements in this area are “very necessary”). The

improved remuneration is also an area for which 85% of the respondents claim that

improvements are “very necessary” or “necessary”. From the point of view of the facilities of

the MA, based on the results from the questionnaire the needs for improvements in the work

premises and the archiving and access to files and information can be identified as most

pressing, but these results were obtained prior to the MA moving to new offices.

With regard to the MA capacity, in the 2011 Annual Report of the OPRG MA it was stated

that mostly because of the exercising of ex-ante and ex-post control of public procurement 10In the course of the focus group with beneficiaries, held in June 2013, the poor bills of quantities and the poor investment design were identified as a serious problem in the implementation of OPRG projects during the current programming period.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

170

procedures and processing of received irregularity alerts, it was necessary to create additional

positions in Directorate General “Programming of Regional Development”. As demonstrated

by the results from the online questionnaire, ex-ante control of public procurement

procedures and participation in evaluation committees for tenders received under the PP Act

are not among the areas considered by the majority of the MA officials as areas where

increase in human resources is most required.

IX. Evaluation 7 – Assessment of the validity,

relevance, consistency, applicability and

reflection of the results of the OPRG 2014-200

environmental assessment

Evaluation 7 has a very specific scope and answers the question to what extent OPRG 2014-

2020 takes into account the results and recommendations of the environmental assessment of

the OPRG. There are two main sources of information:

OPRG 2014-2020;

Environmental assessment of OPRG 2014-2020.

The Environmental assessment assessed the impact of the draft OPRG 2014-2020 on the

environment at two levels: (1) impact at the level of priority axes and sub-priorities, (2)

impact at the level of “eligible activities for funding.” This gives an idea on the nature and

possibilities for positive or negative impact on the components of the environment,

respectively the recommendation of appropriate measures for limiting the negative impact

and monitoring by priorities and eligible activities.

The environmental assessment report makes the following general conclusions regarding the

impact of OPRG 2014-2020 on the environment:

At priority axes and sub-priorities level, the impact of OPRG 2014-2020, on the

environment and human health, as a whole, has a comprehensive positive character. The

implementation of priorities and sub-priorities will lead to reduction of greenhouse gas

emissions, improved quality of air in populated areas, reduced noise by public transport in

populated areas and raise of the standard and quality of living;

At the level of eligible activities for funding, the impact is also positive, equivalent

to the impact on priority axes and sub-priorities level. Minor negative impact is expected in

the period of construction under the respective activities, as they are related with an increase

in the air pollution with dust, noise increase, and construction waste. The impact, given the

small scale of each particular activity is temporary and local- within the construction sites

and premises, and reversible;

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

171

At both levels of the evaluation (eligible activities and PA / sub-priorities) exist the

possibility for impact on some the priorities and eligible activities - mainly related to

regional road infrastructure, protected territories and areas, population and human health.

These sites are subject to EIA ( for the specific investment construction project, rehabilitation

or road reconstruction) and to procedure for environmental assessment ( for plot plans for

road projects) under the Environmental Protection Act, as well as to conformity assessment

procedures with the subject and aims of the preservation of protected areas under art. 31 of

the Biodiversity Act.

The analysis of the relevance, validity, applicability, coverage and consistency of the

recommendations of the Environmental Assessment in OPRG is presented below.

Relevance defines whether EAR recommendation is valid for OPRG 2014-2020

Validity defines the extent to which the recommendation continues to be valid to the

changed text of the Operational Programme.

Applicability defines the extent to which the recommendation can be implemented

and at what stage of the Programme.

Coverage and consistency defines the extent to which the recommendation is reflected

in the Operational Programme and coherent with the other elements of the

Programme.

Only some of the recommendations should be reflect in the text of the Operational

Programme. Others should be taken into account only during the contracting process, grant

awarding, or in the process of implementation. The third group of recommendations does not

require a specific action in the programming or implementation processes, as compliance is

legally defined.

The table below provides a detailed assessment of the EAR recommendations and their

coverage.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

172

EAR recommendation Relevance Validity Applicability Coverage and consistency Recommendation

Measures on prevention, reduction and compensation of adverse effects

During construction works related to the implementation of activities under Priority Axis should be taken into account:

Effective implementation of the measures

and conditions of developed Decisions

and / or Opinions on EIA, EE and CA

for the construction phase on the

respective eligible activity

Relevant Valid Applicable in the

implementation of

measures

Not addressed directly in the

text of the OPRG.

It is part of the EIA, EE and

CA regulations, which

ensures its coverage.

No need to address it in

the OPRG text.

During construction on behalf of the

beneficiary, effective control on the

implementation of measures for relevant

action should be ensured to limit

emissions of dust and pollutants in the

atmosphere ( site sprinkling, loading ,

unloading and transportation of

generated construction waste and

construction materials according to

applicable measures and requirements

under Art. 70 of Decree 1 on emissions

of harmful substances (pollutants )

emitted into the atmosphere from

stationary sources of emissions) ,

respectively, to report how the measures

have been implemented

Relevant Valid Applicable in the

implementation of

measures

Not addressed directly in the

text of the OPRG.

Appropriate levels of coverage

are: in the application

guidelines / call for grants and

the grant contract.

No need to address it in

the OPRG text.

With regard to the building's plumbing

systems – prioritize construction of

modern water supply and sewerage

systems, their maintenance in good

condition, eliminating losses and leaks

Partly relevant - construction of water

and sewerage systems for buildings is

based on common technical

requirements. Maintenance of the

plumbing system of the building is not

covered by the OPRG. The

Applicable in the

planning process

Addressed in point 3.А.2.1

Description of the typology

and indicative activities for

financing and their expected

contribution to the relevant

specific objectives, such as

Point 3.A.2.2. Guiding

principles for the

selection of operations

(Article 87 (2) (b) (iii) of

the General Regulation)

needs to be

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

173

EAR recommendation Relevance Validity Applicability Coverage and consistency Recommendation

recommendation should be viewed in

the following way: "With regard to the

buildings’ water and sewerage systems

- saving water technology and use of

recycled water, where appropriate

should be given priority"

investment water supply and

sanitation in buildings, are

defined as eligible for

financing under the respective

priority.

complemented with a

description of the

principle of sustainable

development, implying

that in the selection of

program operations the

use of water-saving

technologies and use of

recycled water will be

encouraged.

Restriction of construction activities only

within the scope of the projects. Using

existing access roads.

Relevant Valid Applicable in the

implementation of

measures

Not addressed directly in the

text of the OPRG. It is

appropriate to take it into

account in the process of

implementation.

No need to address it in

the OPRG text.

Storage of building materials and waste

disposal only in the designated for this

purpose places

Relevant Valid Applicable in the

implementation of

measures

Not addressed directly in the

text of the OPRG. It is

appropriate to take it into

account in the process of

implementation.

No need to address it in

the OPRG text.

The investment projects of all types of

construction must include an analysis of

noise sources on site and a description of

the measures to reduce noise during

construction, depending on the selected

location of the building, distances to

places with normalized noise regime,

duration and phases of construction,

duration of the work per day and week,

as well as construction machinery and

Relevant Valid Applicable in the

implementation of

measures

Not addressed directly in the

text of the OPRG.

It is appropriate to take it into

account in the investment

projects of the beneficiaries. In

this regard, it is necessary to

specify it as a requirement in

the application instructions (in

the case of construction and

No need to address it in

the OPRG text.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

174

EAR recommendation Relevance Validity Applicability Coverage and consistency Recommendation

vehicles in use reconstruction, for which no

EIA is required).

Coordination of the Transport plan with

local governments and mayors

Relevant Valid Applicable in the

implementation of

measures

Not addressed directly in the

text of the OPRG. It is

appropriate to take it into

account in the process of

implementation.

No need to address it in

the OPRG text.

Construction equipment should not be

left to idling

Relevant Valid Applicable in the

implementation of

measures

Not addressed directly in the

text of the OPRG. It is

appropriate to take it into

account in the process of

implementation/ contracts for

grants.

No need to address it in

the OPRG text.

The tourism development activities under Priority axis should be allowed when:

Compliance with the recreation norms of

the territory

Relevant –

Priority axis 5

Valid Applicable in the

programming process

Not addressed directly in the

text of the OPRG. Compliance

with the recreation norms is a

legal requirement under

Ordinance No 5 on the rules

and regulations of spatial

planning. Its implementation

is guaranteed.

No need to address it in

the OPRG text.

Priority development of ecotourism and

alternative forms of tourism

Relevant –

Priority axis 5

Valid Applicable in the

planning and

programming processes

Not addressed in the text of

the OPRG.

Priority development of

ecotourism and

alternative forms of

tourism can also be added

to the description of the

sustainable development

as a guiding principle for

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

175

EAR recommendation Relevance Validity Applicability Coverage and consistency Recommendation

the selection of

operations for PA 5.

During the preparation of projects for

new tourist facilities measures must be

earmarked to reduce the negative impact

on water quality and take into account

the need to build a system for the

collection, treatment and disposal of

waste water streams formed and

implementing a system for waste

management

Relevant –

Priority axis 5

Valid Applicable in the

programming process

Addressed in section 3.A.2.1.

Description of the typology

and indicative activities for

financing and their expected

contribution to the relevant

specific objectives (Art. 87 (2)

(b) (iii) of the General

Regulation) of OPRG as

eligible activities.

No need to address it in

the OPRG text.

When developing tourist packages, it

should be taken into account that

activities such as "safari" walks, "off-

road" routes, monitoring of rare and

endangered species of animals are

unacceptable and lead to significant

damage to the environment and

biodiversity

Relevant –

Priority axis 5

Valid Applicable in the

programming process

Not addressed in the text of

the OPRG.

The recommendation for

environmental

assessment may also be

added to the description

of sustainable

development as a guiding

principle for the selection

of operations.

Regarding the activities of Priority Axis 5:

For the location of each new road object

to be offered and discussed options

consistent with the arrangements for the

use of protected territories, protected

areas, protection of cultural heritage,

respect for sanitary protection zones and

sites subject to health protection;

Relevant - Priority

Axis 6

Valid Applicable during the

implementation of the

measures.

Not addressed in the text of

the OPRG.

It can be included in the Calls

for Applications/ the selection

of the predefined projects.

The inclusion in the text

of the OPRG is not

necessary.

The Noise protection measures, if there

is such necessity should be subject to

Relevant - Priority

Axis 6

Valid Applicable during the

implementation of the

Not addressed in the text of

the OPRG.

The inclusion in the text

of the OPRG is not

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

176

EAR recommendation Relevance Validity Applicability Coverage and consistency Recommendation

additional, separate project including

acoustic, architectural and structural

part.

measures. necessary.

The activities under Priority Axis 6 "Risk

Prevention" should provide

environmental risks associated with

possible future flooding and for this

purpose to be considered the developed

Estimates of the risk of flooding by the

Basin Directorates that identify certain

areas that are potentially at risk from

flooding.

Relevant - Priority

Axis 7

Valid Applicable during the

implementation of the

measures.

Not addressed in the text of

the OPRG.

To be included in the

description of the main

principles (sustainable

development) for

selection of operations on

PO 7, if the Risk

Prevention measures are

included in OPRG.

During activities near or within

protected areas, protected territories and

historical monuments the Beneficiaries

should be required to monitor and report

on the observation of the regimes and

restrictions set by the management plans

/orders declaring the relevant territories

and zones.

Relevant Valid Applicable during the

implementation of the

measures.

Not addressed in the text of

the OPRG.

It can be addressed in the

Application Guidelines/

Contracts for Implementation.

The inclusion in the text

of the OPRG is not

necessary.

The boundaries of the areas of water

protection in accordance with Art. 119a

of the Water Act and the relevant

measures provided for their conservation

in the RBMP of the four basin

directorates should be taken into

consideration during the implementation

of activities.

Relevant Valid Applicable during the

implementation of the

measures.

Not addressed in the text of

the OPRG.

It can be addressed in the

Application Guidelines/ Grant

Contracts.

The inclusion in the text

of the OPRG is not

necessary.

Description of the necessary measures related to the monitoring of the implementation of the OPRG 2014-2020

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

177

EAR recommendation Relevance Validity Applicability Coverage and consistency Recommendation

The Indicators on monitoring and

control of the environmental impact

should be integrated and included in the

OPRG 2014-2020 system of indicators.

Partially relevant Valid Applicable in the

planning process as well

as during the

implementation of the

measures.

Some of the indicators are

integrated in the OPRG.

In view of the

recommendations of the

Commission for a limited

number of indicators to

measure the desired

effects and correspond to

the size of the budget ,

which is designed for the

individual measures it is

not appropriate to include

all the indicators

proposed in the table

provided in the EAR in

the indicator system of

OPRG 2014-2020.

At the same time, these

indicators should be used

in the monitoring and

control of environmental

impacts during the

implementation of the

program (e.g., in the

evaluation reports on the

environmental impact of

the results of the OPRG).

The Managing Authority of OPRG 2014-

2020 should require from the

Beneficiaries periodically submission of

information on these indicators, as well

as on the implementation of the measures

Relevant Valid Applicable in the

planning process as well

as during the

implementation of the

measures.

Not addressed in the text of

the OPRG.

It can be addressed in the

Application Guidelines/ Grant

The inclusion in the text

of the OPRG is not

necessary.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

178

EAR recommendation Relevance Validity Applicability Coverage and consistency Recommendation

of art. 7of the EC report relevant to its

activities.

Contracts.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

179

X. Conclusions and recommendations

1. Conclusions

This section presents the conclusions of the Ex-ante evaluation on:

External coherence evaluation (Evaluation 1);

Internal coherence evaluation (Evaluation 2);

Horizontal principles evaluation (Evaluation 3);

Evaluation of the system of indicators (Evaluation 4).

Evaluation of the budget of the programme (Evaluation 5)

Evaluation of the management and control systems and the administrative capacity for

implementation of the programme (Evaluation 6)

Evaluation of the validity, relevance, coherence, applicability, and inclusion in the

OPRD 2014-2020 of the results of the environmental assessment (Evaluation 7)

External coherence evaluation

The objectives and priorities of the OPRG 2014-2020 are coherent with the European and

National strategic documents and follow the National and European framework.

Albeit to varying degrees, OPRG 2014-2020 is also related to the three pillars of the Europe

2020 strategy - smart, sustainable and inclusive growth. OPRG 2014-2020 is expected to

have an impact on four of the seven flagship initiatives to catalyze progress under each

priority theme.

Energy efficiency and renewable energy sources and sustainable urban development are

expected to be among the main initiatives at European level during the programming period

2014-2020 expected. OPRG 2014-2020 meets this focus and is consistent with the common

understanding of the concentration of EU funds in order to achieve concrete results. Out of

the proposed total of 11 thematic objectives 6 are selected for OPRG. In spite of this large

range, the selection does not violate the principle of concentration of resources. The strategy,

set out in the OPRG, also fits into the priorities of the Territorial Agenda 2020 of the

European Union.

Reduction of the description of the compliance with national documents would improve the

text of the program. Description of the relevant ex-ante conditionalities should continue to be

updated in line with the progress of the preparation of the Partnership Agreement.

The report identifies opportunities to improve the description of the demarcation and

complementarity between OPRG 2014-2020, and the other programs co-financed by the EU.

It should be noted, however, that the demarcation and complementarity between the programs

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

180

has not yet been clarified at the national level, which is related with the progress of the

Partnership Agreement.

Internal coherence evaluation

The current version of the OPRG 2014-2020, contains a number of improvements to the

internal coherence of the program. The OPRG strategy and the relationship between thematic

objectives / investment priorities, specific objectives envisaged activities and needs are

explained in greater detail as compared to previous versions of the program.

The report provides an overview of the links between: needs and envisaged activities;

envisaged activities and specific objective; specific objective and investment priorities /

thematic objective; and output/result indicators and envisaged activities. The conclusion of

the analysis is that after the changes in the programme the link between these elements is

strong enough.

Horizontal principles evaluation

OPRG 2014-2020 describes the application of the principles of sustainable development,

equal opportunities and non-discrimination and equality between men and women.

The description of the principles of equal opportunities and non-discrimination is short, but

adequate and covers the main requirements for this element of the operational program. The

description of the principle of equality between men and women is more general.

Evaluation of the system of indicators

The indicator system of OPRG includes the relevant common output indicators listed in

Regulation 1301/2013. As a whole, it may be concluded that all output indicators are relevant

to the activities and provide good measurement for their direct products.

Result indicators have to fulfil at the same time two conditions - they need to be directly

attributable to the programme and they should not be limited to the supported entities. One of

the main specificities of the OPRG is that it is an infrastructure programme. Hence the

meaningful results, e.g. in the health, social, and education spheres, will be achieved only

through further soft measures and national/regional policies. The evaluation provides

comments for each result indicator that illustrate the difficulties in identifying indicators,

which have as direct as possible influence on effects that extend beyond the supported

entities.

In some cases the baselines and the target values of the result indicators are not in the same

measurement unit, e.g. the baseline is in absolute numbers, whereas the target value is in

percentage. This is due to the fact that the result indicators are formulated in line with the

expected positive outcomes, e.g. “increase of”. Thus, it is recommended to reformulate the

indicators and delete “increase / decrease” in the formulation.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

181

The programmers have developed a methodology (indicator fiches) for estimation of the

baselines and the target values, which is very helpful and increases the transparency of the

calculation methods. For most indicators there are still some issues, related to the data used,

which need to be clarified in the fiches.

The system of indicators is aiming at using as much as possible official NSI data, which is

beneficial in terms of methodological clarity and transparency. In some cases the latest

available data from the NSI was not used, so it is recommended to re-calculate some

baselines and unit costs. In two cases there is a discrepancy between the formulation of the

NSI indicator and the OPRG indicator: “Increase of the net annual revenues from

international tourism” and “Increased passenger and freight flow”.

Calculating unit costs is a very useful approach for the definition of target values. Overall this

is the approach followed in the indicator fiches of the OPRG. However, inflation also needs

to be taken into account in the calculation of the target values.

On the basis of the above analysis of the indicators, the evaluators recommend review of the

result indicators, listed in the table below.

Evaluation of the budget of the programme

The breakdown of the budget of the program as a whole takes into account the identified

investment priorities and requirements contained in the main national and European strategic

documents, and considers the experience with the current programming period and the risks

of non-compliance of certain thematic ex-ante conditionalities. The financial justification of

the budget of OPRG 2014-2020, provides well-synthesized motivation for the selected

priorities and their weight. The justification meets all the requirements for its elaboration, set

in the guidelines for the development of operational programs for the next programming

period.

In terms of the priorities that will be implemented with the use of financial instruments, the

evaluation concludes that they are correctly identified, but no justification is provided for the

correlation between grants and financial instruments into the OPRG 2014-2020. In relation to

financial instruments, it should be considered that the Form for the development of

operational programs for the next programming period provides that it is not required to

perform a preliminary evaluation of financial instruments at the time of submission of the

operational program and that it could be undertaken at a later stage after specifying the details

of the use of financial instruments.

As concerns the European regulations, OPRG 2014-2020 provides adequate financial

consideration of the thematic objectives that should be financed primarily with funds from

the ERDF and that are relevant to regional development. This applies mostly to TO 4

"Transition to a low carbon economy."

Significant funding is ensured for integrated actions for sustainable urban development,

which are likely to significantly exceed the 5% national minimum envisaged in the European

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

182

framework and also for support of the implementation of TO 9 and 10. The 5% threshold

should not be actively limited in the case of Bulgaria, given the high potential contribution of

this type of investment to achieve higher growth and employment if the investment is focused

on activities with a direct impact on regional economic activity.

In terms of compliance with the formal requirements of the financial plan of the program set

out in the Form of an operational program for the next programming period, the programme

already includes preliminary versions of all required tables (Tables 17-19).

In terms of the currently available national strategic documents (Partnership Agreement

2014-2020, National Strategy for Regional development and National Development

Programme 2020), which have or will have estimates in terms of funding, the programme is

generally coherent with the investment allocations by priorities. Direct comparison of these

documents, however, is virtually impossible, given the long planning horizon in these

documents and the wider range of funding sources.

Evaluation of the management and control systems and the administrative capacity for

implementation of the programme

As a part of the implementation of the ex-ante evaluation of the management and control

systems the team of evaluators reviewed the summary action plan for strengthening the

administrative capacity of 36 municipalities - OPRD beneficiaries (version December 2012)

and the Summary Action Plan for improvement of the administrative capacity of the direct

beneficiaries of the OPRD (version December 2012). Both documents contain

recommendations regarding the administrative capacity, which are relevant for the next

programming period.

The need for trainings of the beneficiaries, identified in the above analyses, was confirmed by

the online survey, conducted during the ex-ante evaluation. According to the results of the

study more than 70% of the respondents believe that training in the next programming period

will be necessary. According to the respondents, a key area in which there is a need for

training is project management, followed by training on reporting and monitoring

performance. Beneficiaries' capacity for tendering is a critical factor in the implementation of

the program in the current programming period.

It can be concluded that the needs of the beneficiaries (the enhancement of competences,

motivation and remuneration, as well as providing the necessary equipment), which are

specified in section 3.B.1 of the OPRG, are correct.

The results of the questionnaire and the discussions in the focus groups confirmed the opinion

that establishing intermediate bodies would create more structural and functional difficulties

and obstacles, rather than improvements.

The evaluation of the administrative capacity of the MA shows the need to further clarify the

division of responsibilities between the MA central and regional departments. The most

problematic are the mechanisms for collecting information on the indicators of the program

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

183

and the collection of data needed to perform evaluations. Given the even greater importance

that the European Commission pays to indicators and evaluations in the next programming

period, it is necessary for these procedures to be reviewed by the MA of OPRG 2014-2020.

As a whole the human resources for management and implementation of OPRG 2014-2020

are adequate, but additional resources are needed for:

Monitoring of the project implementation, including through review of reports,

meetings communication with beneficiaries and so on

On-the-spot checks, on-the-spot check reports and follow-up

Development and updates of procedures and manuals

Management of documentation and archives within the MA

Financial control

In addition to these spheres, there is also the need of additional experts with technical

(engineer) knowledge.

Evaluation of the validity, relevance, coherence, applicability, and inclusion in the OPRD

2014-2020 of the results of the environmental assessment

According to the environmental assessment of the OPRG 2014-2020, at the level of priorities

and sub-priorities, the program's impact on the environment and human health as a whole has

a complex positive character. At the level of specific eligible activities, the impact is also

assessed positively as minor adverse effects are expected in the period of construction during

the respective activities.

Only some of the recommendations of the environmental assessment should be reflected in

the text of the OP. Implementing other recommendations should be performed in the

contracting process and the provision of grants, or in the process of implementation. A third

group of recommendations does not require actions in the programming and implementation,

as compliance is legally defined.

The environmental assessment includes the following recommendation: "Indicators for

monitoring and control of environmental impacts should be integrated in the system of

indicators of OPRG 2014-2020." However, in view of the recommendations of the

Commission for a limited number of indicators that measure the desired effects and

correspond to the size of the budget, which is designated for the individual measures, it is not

appropriate to include in the OPRG 2014-2020 system all of the indicators proposed in the

table provided in the environmental assessment. These indicators should be used in the

monitoring and control of environmental impacts during implementation of the program (e.g.,

in the reports with evaluation of the impact of the OPRG on the environment).

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

184

2. Recommendations

The recommendations in this report, along with their relevant conclusions, are presented in

the below table. The table also includes the indicative weight of the recommendation (1 –

“significant”, 3 – “recommended”).

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

185

№ Conclusion Recommendation Weight

Evaluation 1

1. The text of OPRG 2014-2020 has significantly improved as concerns

the external coherence, but some of the texts on the coherence with

National and European documents are very detailed.

During the uploading of the programme in SFC some

of the texts on the coherence with National/European

documents should be shortened.

3

2. The text on the coherence with the Partnership agreement needs to be

amended in order to consider the latest changes in the Partnership

agreement

Changes in the text are needed with regards to:

o changes in the formulation/deletion of specific

challenges (“Insufficient economic activity of the

population and entrepreneurship (NEET, active

aging)”; “Ineffective usage of resources” and

“Ineffective energy usage”; “Low quality of the

health system”; “Insufficient sector and

geographical mobility of the labour force”)

o adding of challenges, which are relevant to OPRG

2014-2020: Insufficient quality of the education

system, increasing of the illiterate population and

increasing of the share of children not going to

school; One of the highest standardized mortality

coefficient; Ineffective systems for prevention,

management and addressing the consequences of

risks

The recommendation is taken into account in the

3

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

186

№ Conclusion Recommendation Weight

latest version of OPRG 2014-2020 from

09.09.2013.

3. The intention to use financial instruments partly or in full to finance

investments in sports infrastructure, energy efficiency in buildings,

cultural facilities, and areas with potential for economic development,

urban and integrated public transport is in accordance with the

promoted Community policies with respect to financial instruments.

The experience in the implementation of financial instruments,

however, is still relatively small.

As concerns the financial instruments, it is

recommended to perform an evaluation of the

procedures of the 2007-2013 period. It is

recommended to perform this evaluation before the

start of OPRG 2014-2020, but in case this is not

possible, such an element should be included in the

ToR for the evaluation of the financial instruments

It should be taken into account that the Ministry of

Finances announced a tender for “Ex-ante

evaluation of the implementation of financial

instruments of the national Operational programmes

in the 2014-2020 period”, which is expected to

contain such an analysis.

2

4. The tables for the thematic ex-ante conditionalities are properly filled

in accordance with the Common Regulation and the Partnership

Agreement. The description in Table 24 includes applicable ex-ante

conditionalities, and the description in Table 26 includes relevant

actions that will be taken to implement the outstanding ex-ante

conditionalities, but it is possible to make additions to the text of the

program. It is also necessary to eliminate disparities between Table 26

The missing information for ex-ante conditionalities

4.1 and 10.2 should be filled in Table 24

The inconsistencies with the Partnership agreement

in Table 26 on the actions with regards to the ex-ante

conditionalities 4.1, 7.1, 9.1 and 9.2 should be

corrected

2

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

187

№ Conclusion Recommendation Weight

and the text of the Partnership agreement. The recommendation is taken into account in the

latest version of OPRG 2014-2020 from 09.09.2013.

5. The description of the demarcation and synergies between OPRG

2014-2020 and the remainingprogrammes, co-financed by the EU is not

complete

In parallel with the clarification of the demarcation

and synergies between the programmes at national

level, the MA should update Section 9 of OPRG, also

taking into account the recommendations of the ex-

ante evaluation (Section 2.2. of Evaluation 1).

2

Evaluation 2

6. There is need for improvements in Table 1 "Synthesized overview of

the rationale for the selection of thematic objectives and investment

priorities".

Chapter IV, section 2, Review of the identified needs

in OPRG 2014-2020 of this report contains specific

recommendations for changes in Table 1.

o Separation of the investment priorities,

o Identification of another need, which is relevant to

the strategy of OPRG 2014-2020 as concerns

energy efficiency

o Identification of needs for investment priority

"Actions to improve the urban environment,

including regeneration of brownfield sites and

reduction of air pollution"

o As concerns IP “Improving regional mobility

1

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

188

№ Conclusion Recommendation Weight

through connecting secondary and tertiary nodes

infrastructure of the trans-European transport

network” – clarification of the link with the TEN-

T

o Specification of the way OPRG 2014-2020 will

address the identified needs as concerns Thematic

objectives 9 and 10

7. The link between the elements of the strategy of the program

(activities, objectives, needs and indicators) is strong enough for most

of the specific objectives of the program. However, some of the links

should be further clarified.

Additional clarifications in the OPRG 2014-2020 on

specific elements of the strategy of the programme,

which are identified in Chapter IV, section 2, Logic

of intervention:

o Add clarification on the scope of the urban

environment / physical environment – The

recommendation is taken into account in the

latest version of OPRG 2014-2020 from

16.09.2013

o Add to the description of PA1, IP4, SO1 after

expanding its scope – The recommendation is

taken into account in the latest version of OPRG

2014-2020 from 16.09.2013

o Rephrase specific objective 1 of PA1, IP6 – The

3

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

189

№ Conclusion Recommendation Weight

recommendation is taken into account in the latest

version of OPRG 2014-2020 from 09.09.2013

o Specify shortly the sources of the analyses, used

for PA1, IP6, SO1 (feasibility studies of the cities

that are beneficiaries of projects for integrated

urban transport in the current programming

period) - The recommendation is taken into

account in the latest version of OPRG 2014-2020

from 09.09.2013

Evaluation 3

8. There is a description in OPRG 2014-2020 of the principles of (1)

sustainable development (2) equal opportunities and non-

discrimination, and (3) gender equality. Possible improvements could

be added to the text on the measures to ensure compliance with these

principles in implementing the program.

Add a short description (similar to that in the

Partnership agreement) of the way to ensure during

the implementation of the program keeping of the

principles of sustainable development, equal

opportunities and non-discrimination – The

recommendation is taken into account in the latest

version of OPRG 2014-2020 from 16.09.2013

3

Evaluation 4

9. The programming and reporting of indicators is among the serious

problems in the implementation of operational programs for the period

2007-2013. Challenges with the indicators are also reported in the mid-

Development of a specific methodology / indicator

fiches for the indicators with the aim of overcoming

some of the difficulties in the programming and

1

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

190

№ Conclusion Recommendation Weight

term evaluation of OPRG. reporting of indicators - The recommendation is

taken into account and such fiches have been

developed.

10. In previous versions of OPRG 2014-2020, the evaluation identified the

following opportunities for improvement in the system of indicators in

order to enhance the relationship between the indicators and activities:

Some output/result indicators (identified in Evaluation and the

developed indicator fiches) are very similar in scope and

definition.

Specification of the wording of the indicators

Possible additions, replacement and transferring of output

indicators to result indicators and vice versa.

In the development of the indicator system could be

used the fiches, elaborated in cooperation between

the evaluation team and the Contractor - The

recommendation is taken into account

Taking into account the changing requirements

towards the indicator system, (on the basis of the

recommendations of this report – Evaluation 2,4, and

the fiches) it is recommended to continue the

discussions on the output/result indicators: (1) within

the Working group for development of OPRG 2014-

2020 and (2) in cooperation with the NSI and the

potential beneficiaries - The recommendation is

taken into account

1

11. The system of indicators of OPRG 2014-2020, includes result

indicators that depend on a number of social factors and investment

activities beyond the program activities. This could hinder their

reporting and the identification of the contribution of the program on

these indicators.

The use of result indicators should be coordinated

with MAs of other OPs for the next programming

period, including during the development of the

Partnership Agreement, as well as with other

institutions. In particular, it is recommended that

indicators be discussed with:

1

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

191

№ Conclusion Recommendation Weight

o Ministry of Labour and Social Policy

o Ministry of Education

o Ministry of Transport, Information

Technologies and Communications / ARI

o Ministry of Health

o Ministry of Culture

12. The number of indicators for outputs and results in the OPRG 2014-

2020 is the same.

Reduce the number of result indicators – The

recommendation is taken into account in the version

of OPRG 2014-2020 from 16.09.2013

2

13. In some cases the baselines and the target values of the result indicators

are not in the same measurement unit, due to the that the result

indicators are formulated in line with the expected positive outcomes,

e.g. “increase of”, or “decrease of “.

Reformulate the indicators and delete “increase /

decrease” in the formulation

Use target values and baselines with the same

measurement units

1

14. For most indicators there are still some issues, commented in the

analysis, that need to be clarified in the fiches.

Clarify in the indicator fiches the identified issues,

e.g. scope of the indicators, operationalization, data

used, and some methodological issues

1

15. In some cases the latest available data from the NSI was not used. It is recommended to re-calculate some baselines and

unit costs for the indicators identified in the analysis

2

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

192

№ Conclusion Recommendation Weight

(Chapter VI on Evaluation 4)

16. Due to the relatively low expected influence of the OPRG on some

indicators and/or discrepancies between the NSI and OPRG

formulation, the result indicators listed in the recommendation need to

be reviewed.

Review the following result indicators:

o Reduction of final energy consumption from

public administration, commerce and services –

if feasible, request from NSI data on the final

energy consumption from public administration

o Increase of the net annual revenues from

international tourism – it is recommended to use

the NSI formulation (Internal tourism

consumption, Tourism characteristic products)

o Increased passenger and freight flow – if this

indicator is selected, the NSI indicator is only

partially relevant. So, if available, it is preferable

to use data from the Road Agency, which

includes passengers’ information.

1

Evaluation 5

17. Significant resources (9% of the indicative budget of the program) are

envisaged for regional tourism, but so far the rate of absorption of this

priority under OPRD 2007-2013 is relatively low.

Identify in the text of OPRG the identified measures

for overcoming potential problems, which might lead

to delays in the implementation of the priority in the

next programming period.

3

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

193

№ Conclusion Recommendation Weight

18. The financial justification of the OPRG 2014-2020, does not contain an

explanation of the principle of estimation of the proportion of financial

instruments in the total financing of the investment priorities. The

experience in the use of financial instruments is still limited and there is

no enough information on the demand this type of financing.

Provide additional justification of the chosen amount

of the contribution of the financial instruments to

each investment priority

Consider reducing the proportion of financial

instruments in the investment priorities related to

natural and cultural heritage and tourism, due to the

risk associated with the allocation of substantial

resources for financial instruments (about half of

their total resources) and lack of information about

potential interest in financial instruments,

particularly in terms of cultural heritage.

The recommendation can be considered after the

implementation of the above-mentioned evaluation of the

financial instruments.

3

Evaluation 6

19. Based on the conducted desk research and focus groups as critical

factors in the implementation of OPRD may be accounted for

beneficiaries' capacity for tendering and implementation of quality

inspection of construction supervision.

It is recommended that the text of the OPRG 2014-

2020, specifically focus on the need for training on

cross-cutting themes such as PPA and

implementation of construction supervision. It

should be borne in mind that this is a horizontal need

that needs to find its place in OP Good Governance.

3

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

194

№ Conclusion Recommendation Weight

20. В

т

е

Although the overall human resources of the MA of OPRG can be

considered to be sufficient, it is recommended to increase the human

resources especially in the areas of monitoring and engineering

disciplines.

Include in the OPRG text specific needs for

increasing the administrative capacity of the MA,

also taking into account the findings of this report

(Evaluation 6, section 2.2)

1

21. The evaluation identified as problematic the procedures for gathering

data on the indicators of the program and for collecting information

needed to conduct evaluations.

Given the great importance given by the EC to

indicators and evaluations during the 2014-2020

period, in the development of the MA Manual and

Guidelines for beneficiaries in the next programming

period, it is necessary to review the procedures for

gathering information on Programme indicators and

collection of data necessary to conduct evaluations.

2

Evaluation 7

22. Overall, the compliance with the recommendations of the

environmental assessment of the OPRG 2014-2020, should be done in

the process of contracting, or in the process of implementation.

A recommendation, which may be included in the

text of the OPRG 2014-2020, because it is related to

sustainable development that is referred to as a

guiding principle for the selection of operations in

the program is:

Prevent the development of tourist packages for

surveillance activities of rare and endangered

species because they lead to significant damage to

the environment and biodiversity

3

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

195

№ Conclusion Recommendation Weight

The recommendation is taken into account in the

latest version of OPRG 2014-2020 from

09.09.2013, which says that “the programme does

not contain activities, which may lead to mass

tourism becoming a threat for the cultural and

natural heritage”.

23. The environmental assessment includes the following recommendation

"The indicators for monitoring and control of environmental impacts

should be integrated in the system of indicators of OPRG 2014-2020”,

but given the EC's recommendations for a limited number of indicators

it is not appropriate to include in OPRG 2014-2020 all of the indicators

proposed in the table provided in the environmental assessment.

The indicators suggested by the environmental

assessment of OPRG 2014-2020 should be used in

the process of monitoring and control of the impact

on the environment during the implementation of the

programme (e.g. in the reports for assessment of the

impact of OPRG on the environment).

2

3. Follow-up of the Consultant’s Recommendations

In order to monitor the implementation of recommendations included in the First Interim Report and the first version of the Second Interim

Report (submitted in January 2013), this report reflects their status as of October 2013.

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

196

No Recommendation Reference to the

report

Status Comment (if available)

1. To add additional brief explanatory elements regarding the compliance

of the Program with the following strategic documents:

NDP B2020

National Strategy for Regional Development

Evaluation 1 Implemented

2. In view to certain discrepancies between the criteria for targeted

support of regions, within the national/European framework, the

rationale needs to be completed.

It should be also determined what constitutes the targeted support.

Evaluation 1 Not applicable The current version of OPRD does

not include an explicit text in terms

of targeted support for the

Northwest region.

3. Given the limited experience and results achieved during the current

planning period, it is advisable to briefly describe in the Program the

steps to implement Art. 32 of the General Regulation, namely –

implementation of ex-ante evaluation.

Evaluation 1 Implemented

4. Inclusion of thematic objective 5 in p. 2.5

Inclusion of Investment priority “Enhancing regional mobility

through connecting secondary and tertiaty nodes to TEN-T

infrastrucutre” in the description of thematic objective 7 in p. 2.5.

Evaluation 1 Implemented

5. More attention to be paid to the Territorial Agenda 2020 in the

description of the identified needs of the Program (p. 2.1. of OPRG

Evaluation 1 Implemented

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

197

No Recommendation Reference to the

report

Status Comment (if available)

2014-2020).

With a view to the identified risks in the Territorial Agenda 2020

(Section II, p. 23), to add an explanation that PA4 “Regional

tourism” does not contain activities which may in some way result

in a mass tourism becoming a threat for the cultural and natural

heritage.

6. The specific requirements to the prerequisites identified in the

present report need to be specified in the subsequent versions of the

Program, including the commitment to develop Draft National

Program for Renovation of Residential Buildings in Republic of

Bulgaria 2011-2020 (the commitment is mentioned in the version of

the NRP updated in 2012).

Evaluation 1 Outdated

7. In order to take account of risks in the implementation of Sub-priority

1.1. “Energy efficiency in administrative and residential buildings”, the

MA of the OPRG should provide for the following options:

To provide for a Mid-term evaluation of the results achieved

under Sub-priority 1.1., where necessary, to undertake adjustment

measures, including modification of OPRG 2014-2020.

Evaluation 2 Discussed during

the evaluation

It is expected to take into account

this recommendation during

programme implementation

8. To mention all data sources of used for analysis purposes Evaluation 2 Not applicable The text of the social and economic

analysis is not a separate part of

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

198

No Recommendation Reference to the

report

Status Comment (if available)

To use the most recent available statistical data OPRG 2014-2020 anymore

9. Specific needs related to the OPRG should be presented in the

text 2014-2020

Some of the elements of the analysis should be removed

Evaluation 2 Not applicable The text of the social and economic

analysis is not a separate part of

OPRG 2014-2020 anymore

10. The specific link between the chosen thematic

objectives/relevant investment priorities and the identified needs

should be included in the text of the Program.

Evaluation 2 Implemented

11. The SWOT analysis should be revised and should take into

account the options for improvement identified in this report.

To discuss the opportunity for inclusion of quantitative SWOT

analysis in the Program.

Evaluation 2 Implemented

12. To briefly indicate more specific objectives/needs in the

intervention logic

Evaluation 2 Implemented

13. To redefine/remove/add some of the specific objectives

mentioned in this report

It is necessary to include in the text of OPRG 2014-2020

additonal reasoning for the links between some activities,

investment priorities and specific objectives.

Evaluation 2 Implemented

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

199

No Recommendation Reference to the

report

Status Comment (if available)

14. The rationale and the description of the specific objectives

should be worked out in more details in OPRG 2014-2020

Evaluation 2 Implemented

15. In order to further reinforce the logical link between investment

priorities, specific objectives and indicators, it is recommended

to add/revise/redefine some of the indicators, in accordance

with the proposals made in the report.

Evaluation 2 Under discussion The issue of indicators will

continue to be discussed at sessions

of the working group

16. To add the specific objectives as well as:

Main identified target groups

Specific territories which will be subject to interventions (where

applicable)

Use of financial instruments

Evaluation 2 Implemented Information about the use of

financial instruments and

beneficiaries has been included in

the subsequent versions of OPRG

2014-2020.

17. There should be mentioned in the description of the horizontal

principles that improving the access for disabled people is among the

horizontal activities of the Program

To consider the inclusion of a horizontal indicator which shall

measure the results achieved at program level towards the access for

disabled people

To take account of the conclusions/recommendations of the Interim

Evaluation 3 Partly

implemented

The issue of the inclusion of

horizontal indicator to measure

performance in terms of access for

people with disabilities at program

level will be discussed at the

meetings of the Working Group

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

200

No Recommendation Reference to the

report

Status Comment (if available)

evaluation of OPRD 2007-2013 on horizontal principles

To pay special attention to the measures provided for inclusion of

vulnerable groups at risk of dicrimination, such as ethnic minorities,

migrants, elderly and younger people

18. The implementation of the partnership principle can be explicitly

explained in the text of the Program. It may be also specified in

Item 1.1. what mechanism is used for reflecting the comments of

the working group members.

Evaluation 3 Implemented

19. The formulations of part of the indicators should be further specified Evaluation 4 Under discussion The issue of indicators will

continue to be discussed at sessions

of the working group

20. Development of specific Manual of indicators in order to overcome

the difficulties in the programming and reporting of indicators

(outside the text of OPRG 2014-2020).

Evaluation 4 Under discussion The issue of indicators will

continue to be discussed at sessions

of the working group

21. Other output indicators should be developed

Some of the mentioned output indicators could be added to the table

containing result indicators

To add new result indicators according to the proposals made in this

Evaluation 4 Under discussion The issue of indicators will

continue to be discussed at sessions

of the working group

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

201

No Recommendation Reference to the

report

Status Comment (if available)

report

22. When setting the baseline values, a review of Eurostat databases

should be carried out and/or more recent data should be required

from NSI

Evaluation 4 Implemented

23. It is recommended that the number of indicators under SP1 be

reduced.

Evaluation 4 Implemented

24. To re-examine the conclusion drawn about the existence of

difficulties and delays in implementing projects only in 6.1% of

the municipalities

When analyzing the needs in terms of administrative capacity,

the identified issues/difficulties under PPA in the programming

period 2007-2013 should be considered

Among the needs in terms of administrative capacity, the need to

inform the local authorities on the new Cohesion Policy should

be included

Evaluation 6 Not applicable The text referring to the

administrative capacity of

beneficiaries and MA is no longer a

separate part of the Program.

25. After approval of these two documents by MA of OPRG, the

conclusions and recommendations that will be addressed within

OPRG 2014-2020, should be included in the program text

Evaluation 6 Implemented

26. The need of training can be identified in the text of OPRD 2014-2020, Evaluation 6 Not applicable The text referring to the

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

202

No Recommendation Reference to the

report

Status Comment (if available)

mainly in the field of:

• project management

• reporting and accounting on implementation

administrative capacity of

beneficiaries and MA is no longer a

separate part of the Program.

27. In the inclusion of the text under 8.1., the measures for reducing the

administrative burden for beneficiaries should be considered and

indicated in:

The summarized action plan for strengthening the

administrative capacity of 36 municipalities - OPRD

beneficiaries

The summarized action plan for strengthening the

administrative capacity of the direct beneficiaries of the OPRD

Law on the Management of EU Funds

Evaluation 6 Implemented

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

203

Annexes

1. List of key consulted documents

№ Name of the document

1. Various versions of OPRG 2014-2020

2. National Development Program: Bulgaria 2020

3. National Reform Program 2012-2020

4. National Regional Development Strategy of Republic of Bulgaria (NRDS) for the

period 2012-2022

5. Ex-ante evaluation of OPRD 2007-2013

6. Review of the first opened schemes under OPRD 2007-2013

7. Socio-economic analysis for the purposes of the OPRG for the period 2014-2020

8. National Spatial Development Concept of Bulgaria

9. Analysis of the beneficiaries’ capacity under the project “Preparing action plans to

strengthen the administrative capacity of the beneficiaries under the OPRG”

10. Interim evaluation and interim report on the implementation of the National

Regional Development Strategy for the period 2005

11. Regional plans for development of the regions at level 2 for the 2014

12. Interim evaluations and reports on the results of the interim evaluations of the

implementation of the Regional plans for development of the regions at NUTS 2 for

the period 2007

13. Mid-term evaluation of OPRD 2007-2013

14. Environmental assessment of OPRG 2014-2020

15. Europe 2020 - A strategy for smart, sustainable and inclusive growth

16. Proposal for a regulation of the European Parliament and of the Council on specific

provisions concerning the European Regional Development Fund and the Investment

for growth and jobs goal and repealing Regulation (EC) No 1080/2006

17. Regulation of the European Parliament and of the Council laying down common

provisions on the European Regional Development Fund, the European Social Fund,

the Cohesion Fund, the European Agricultural Fund for Rural Development and the

European Maritime and Fisheries Fund covered by the Common Strategic

Framework and laying down general provisions on the European Regional

Development Fund, the European Social Fund and the Cohesion Fund and repealing

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

204

Council Regulation (EC) No 1083/2006

18. Territorial Agenda of the European Union 2020: Towards an Inclusive, Smart and

Sustainable Europe of Diverse Regions, agreed at the Informal Ministerial Meeting

of Ministers responsible for Spatial Planning and Territorial Development

19. EU Strategy for the Danube Region

20. National Reform Programme (2011-2015, update from 2012), Convergence

Programme of the Republic of Bulgaria (2011-2014 ) in the conclusions and

recommendations of the report of the European Commission's Annual Growth

Survey ( 2012)

21. Regional Development Act in force from 31.08.2008 and subsequent updates

22. Partnership Agreement

23. Concepts and/or projects of other programs included in the Partnership Agreement

24. Position of the Commission Services on the development of Partnership Agreement

and programmes in Bulgaria for the period 2014-2020

25. Annual reports of the MA on the implementation of OPRD 2007-2013

26. Reports of the Committee on European Affairs and Oversight of the European Funds

27. Guidance Document On Monitoring and Evaluation – European Regional

Development Fund And Cohesion Fund – Concepts and Recommendations

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

205

2. List of participants from the focus groups in the

evaluation

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

206

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

207

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

208

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

209

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

210

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

211

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

212

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

213

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

214

Ex-ante Evaluation of Operational Program Regions in Growth in the 2014-2020 programming period

215

3. Results of the online questionnaires

The results of the online questionnaires were electronically delivered to the Contracting

Authority.

4. Indicator fiches

The indicator fiches were electronically delivered to the Contracting Authority.


Recommended