Frequently Asked Questions about the LIFE 2014 Call for Integrated Project Proposals version 02/03/2015 1

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1 Frequently Asked Questions about the LIFE 2014 Call for Integrated Project Proposals version 1 Please also see the general FAQ for issues that may be applicable to any LIFE projects A. Questions raised before the invitation to submit a full proposal. Question Answer Date published on-line 1 What does the 'large territorial coverage' foreseen for IPs mean in practice in the case of waste management plans? Could the IP be implemented in some separate provinces or should it be a geographically uniform/continuous area? 2 If the partners of the integrated project are preparing also LIFE traditional project applications as well as Horizon 2020 projects, parallel to the integrated one will this synergy contribute to a position evaluation of the integrated project? Is mentioning the complementarity between an integrated project and a traditional one necessary or not? Where and how should it be reported in It is up to the applicant to decide upon its choice of regions or provinces to be covered by the IP but they should correspond to the plan(s) targeted by the project. Thus if the plans target noncontiguous areas, the project may also be implemented in these areas. In any case, large territorial coverage means the full or a substantial coverage of the territory covered by the relevant waste plan. The coverage should be designed in a way to ensure that in the long term the plan may be implemented in the whole area it covers. Synergy with other EU funds is encouraged for integrated project proposals. While of course it is good to ensure complementarity between a LIFE IP and a running/future LIFE traditional project, it is primarily the complementarity with actions financed by other EU funds (including Horizon 2020 funds, regional development funds etc.) that would be positively evaluated. The information should be indicated in the concept note, under 10/2/201 10/2/201 1.

2 the concept note? 3 Are projects scored less for not having a transnational partner? 4 Can a Public Body (i.e. Regional Administrations) directly award a financial contribution to its Regional Agency for the Environment for the implementation of some project activities? If yes, what is the maximum amount? Can the concept note refer to a River Basin Management Plan that has not yet been agreed with the EC? 'complementary actions' and 'funds requested' (forms CNe and CNg). A transnational approach is not required for an integrated project (or for any LIFE project). A transnational project will only be considered for extra points where sufficient arguments for an added value of the transnational approach are provided. Yes it is possible if this amount is not part of the LIFE IP budget. To the contrary, if this amount is intended to cover costs for actions budgeted under the LIFE IP, then the corresponding costs by the Regional Agency will be considered as eligible only if the agency is an associated beneficiary to the project. A specific mechanism is foreseen to grant limited amounts to third parties for specific actions (see section of the Application guide0) but this is limited to a total of EUR or to max per grantee.. As indicated in the Application guide (p.14), if the formal adoption has not taken place at the time of the submission of the Concept Note, the applicant should explain the status of the adoption and demonstrate that this adoption will take place before deadline for submission of the full IP proposal. 10/2/201 10/2/201 10/2/201

3 B. Questions raised by applicants after the invitation to submit a full proposal 6 In the letter of the EC on the Concept Note, it is indicated that we should include two specific NGOs as associated beneficiaries: in this case these NGOs will have to co-finance and implement concrete actions. Selecting just one of the main stakeholders as cobeneficiary might create a sensitive issue for the other stakeholders involved in the implementation. Therefore we would like to receive further clarifications this may help us giving arguments to the other groups: what the reason is behind this request; is this a prerequisite for a possible selection of the project? (cfr comment on form B guidance doc pg 61: Also provide your arguments in case main stakeholders are not involved as associated beneficiaries. )- Both of the NGOs that were mentioned in our letter appear to be key stakeholders for your Nature IP as they are expected to have a significant role in the practical implementation of the PAF (as they own and/or manage a large proportion of Natura2000 sites and other areas allocated to nature conservation). However, these NGOs did not even specifically appear among the key stakeholders. In fact, for the reasons mentioned above, both NGOs are considered to be primary candidates for being associated beneficiaries. It is of course clear that several other public entities and NGOs are also key stakeholders as rightly mentioned in the Concept Note. Chapter 1.7 of the Application guide defines the requirements and expectations regarding the level of involvement of key stakeholders. The applicants should take these provisions into account when deciding on the setting up of their partnership, in particular addressing the need to: " actively involve the key stakeholders ", " beneficiaries should bring an added value to the project ", " the project partnership should also take into account the long term sustainability of the project results and activities as well as the requirement for capacity building ensuring the eventual implementation of the entire plan/strategy." The guidelines also states that" the project applicants should avoid exceeding a reasonable number of beneficiaries In case the number of stakeholders is found to be beyond this reasonable level, a form of involvement other than as associated beneficiary needs to be sought." The choice of whether to include a key stakeholder as an associated beneficiary of the IP or "only" as a 10/2/201

4 7 The guidelines are not very accurate about the minimal contribution of each associated beneficiary. If an NGO is associated, what should be its minimal contribution? 8 Would it be possible to define more accurately and to specify the difference between sub-contractors, external assistance ( p.20) and third parties ( p.20)? What is the link between the limits of payment under and ? Do they apply to the same actors? collaborating/benefitting stakeholder will largely depend on the composition of the project actions and expected results also keeping in mind in this regard the complementary actions. We strongly advise you to clarify in form B the reason behind the choices that you make regarding the form of involvement of the key stakeholders, including those mentioned in our letter. While all beneficiaries have to contribute financially to the project (as per Article II.11.1 (g) of the Model Grant Agreement) indeed there is no requirement from our side as to the minimum financial contributions of the various beneficiaries to the project costs. It is up to the project partners to agree on this aspect. The amount and percentage of their own contributions may therefore differ even substantially depending on their financial capacities; hence the various individual project beneficiaries may benefit more or less than the overall co-financing rate of 60%. It is expected however that the financial contribution of each beneficiary corresponds to a certain element of proportionality in view of their budget share and financial capacity. A symbolic contribution, while formally possible, may indicate a low level of commitment and ownership that will be considered during the evaluation process. Sub-contractors are natural or legal persons providing external assistance to the project beneficiaries. For more details please also see Article II.9 and II.10 of the model grant agreement for IPs. Third parties referred to in are not subcontractors but stakeholders that may receive a grant from the beneficiaries of the IPs under the conditions laid down in that chapter and under the provisions of Article II.11 of the model grant agreement for 10/2/201 10/2/201

5 9 Complementary projects: project applications (under Interreg, RDP, ) are at this moment in concept phase can those actions be included? For projects that are already granted: from which date are those acceptable to be included as complementary in the IP? Can actions mentioned in the CN, but already started after submission CN in October 2014 but before the full proposal is submitted, be included as complementary actions? 10 Are preparatory actions limited to the first phase of the project? 11 Our Nature IP proposal (cf. Concept Note) is mainly focused on the development and improvement of different tools and methods needed for the PAF's implementation, such as capacity-building, innovative funding, awareness-rising, conception of sites management plans and specific habitats & species action plans, design of turnkey projects... On the other hand, guidelines for applicants insist on the fact that concrete actions with tangible and measurable environmental benefit should be the core activities of the IP. In a very restrictive point of view, some IPs. The proposal may describe and refer to complementary actions that are already on-going or that are planned. As regards mobilisation of funds for complementary actions, please see the details on pages 9-11 of the Guidelines for applicants. You are advised to pay particular attention to the requirement that " such funding has not been granted to or spent by one of the beneficiaries of the IP before the launch of this call for applications. Under no circumstances would funds that were granted or spent before the start of the programming period on 1 January 2014 be accepted " Accordingly, actions starting after October 2014 but before the submission of the full proposal are likely acceptable if they meet the conditions on the timing of the grant. While preparatory actions should normally have a limited timeframe, they may commence and be implemented at any time during the project period, as needed. a) It is important to note that an IP should be based on a thorough analysis of gaps and needs, thus a varying proportion of concrete (or other) actions is expected in different IPs. It is for this reason that there is no specific requirement regarding a minimum percentage of actions that must be concrete in IPs (in contrast to the 2% requirement for 'traditional' projects.) However, it is expected that when implementing the targeted plan/strategy, most IPs would allocate a significant share of their budget to concrete actions with tangible results in accordance with the priorities of the plan/strategy. This aspect will be taken into account during the evaluation of the proposals. Concrete 10/2/201 10/2/201 10/2/201

6 activities (pilot-projects on the field) fit with this definition, but most of the activities listed in the Concept Note do not. They ensure durability and transferability and will of course lead on a longer term to environmental benefit, but all of them will not necessarily have evident tangible and measurable environmental effect during the time frame of the IP. The indicators for these activities could be the number of action plans ready to be implemented, the number of stakeholders involved in Natura 2000 sites management... The question is thus : a) Can we consider activities such as conception of management plans and actions plans for habitats and species targeted by PAF, capacity building, development of efficient databases for storage and processing of biological and management data, development of innovative funding tools as concrete actions, even if their direct environmental benefit is not so directly observable? b) Or should we consider them as preparatory actions and thus limit them to the first phase, and mainly focus on concrete restoration and management of habitats and species in other phases in order to have direct environmental improvement during the IP, which means the IP would be much more like a traditional Life? 12 In particular, improvement of art 17 Monitoring is an official issue identified in our PAFs. It should be implemented throughout the project time frame, and implementation actions must have a tangible and measurable environmental benefit which must be demonstrated in the description of the action. The preparation of management or actions plans and the development of databases should appear among the preparatory actions as indicated in of the Application guide. The results of these actions would be used e.g. during the actual implementation of the plans within the IP itself or - unlike in the case of traditional projects - via complementary actions financed by other sources during or after the IP. At the same time it has to be noted that actions not leading towards the actual implementation of the PAF should in general not be included in the IP. Capacity building activities may be considered as concrete implementation actions within an IP as mentioned in the third paragraph of of the Application guide, but depending on the specific capacity they target, they can also appear as preparatory or dissemination actions. b) Preparatory actions, as stated above in question 10, while normally being limited in their timeframe, do not have to commence or be completed during the first phase of the IP. Depending on their scope they may be implemented throughout the project period or may commence during a later phase of the project. Setting up of monitoring systems, including the improvement of the Art. 17 monitoring, is considered to be a preparatory action as indicated in of the Application guide, but again it can be 10/2/201

7 cannot be limited to the first stages. It is thus not a preparatory action, and not really a monitoring of the effectiveness of the IP actions. Can we consider the activities related to a better knowledge of our habitats and species distribution and conservation status as a concrete action (action C)? 13 Form A7 says: "Have you or any of the associated beneficiaries submitted any request for financing for actions or part of this project to other European Union financial instruments?" Project applications are still in concept phase can those projects be included? Is it imperative that all project proposals already indicate that they contribute to the implementation of the IP? 14 Form B1: Do we have to list the planned actions for each of the main objectives as in the CN or re-organize the actions per type of action? More details are requested under point 4 for the outcomes of actions for the short term and long term; should indication of short term/long term of the actions also be given under point 3 these details have already to be described in forms C? 1 Form B2a: In order to list the names of project areas(s), should we include the overall Natura 2000 network (cfr PAF) as shown in the CN or also identify specific sites where field actions will be carried out? 16 Form B2c : what is meant by 'institutional and technical capacity having impact on the plan'? Are we expected to describe the capacity building actions carried out throughout the project as needed. The monitoring itself would be best placed in the D actions. The achievement of better knowledge could also be considered also as a type of capacity building. The primary purpose of the questions on this form is to ensure that there is no double funding from the EU for the actions that are planned under the IP itself and can also help to see if LIFE is indeed the best option for financing. You should include all relevant project applications that are ongoing and all projects that are already receiving EU finance, regardless of whether or not they make reference to the IP. This form is in fact similar to CNe as its purpose is to provide an overall view of the IP and of the complementary actions. The applicants may therefore present and group the IP actions on form B1 as they consider it best to serve this purpose. Details of IP actions and various other aspects will have to be included in the subsequent B and C forms. Form B2a: You should include both an overview description and map(s), and also indicate specific sites where field actions will be implemented. Site specific maps need to be annexed as per instructions in of the guide. Form B2c: In this case the targeted plan is the PAF. This form should describe your overall strategy and the logic behind the project, including how your choice of actions would achieve the 10/2/201 10/2/201 10/2/201 10/2/201

8 foreseen under the IP, or the overall gaps in knowledge and capacity required for full implementation of PAF? 17 Form B3: Concerning the 'contribution to the objectives of LIFE' iit is not clear what is meant here: the objective of LIFE is to support the implementation of the whole EU Environmental and Climate Change policy? 18 Form B4: Does the question on the top of this form refer to the character of specific project actions or of the IP project in general? The project can include different types of characters depending on the type of the actions included: some actions can be demonstrative, other actions can be best practice or innovative. 19 C forms, With reference to the F actions - financial audit by coordinating beneficiary : is an audit also required for interim payment requests or just for the final cost claim? If the audit is carried out by the independent audit office of the public authority, are costs eligible?; filling of the gaps and needs you have identified. The explanation should also cover the impact of the present state of institutional/ technical background and capacity on the implementation of the plan (the PAF). This explanation should reflect the situation with regard to the responsible authorities and main stakeholders. Lack of existing capacities among the beneficiaries or other stakeholders would provide the reasons for your capacity building efforts. Form B3: Indeed, the objective of LIFE is to contribute towards the overall objectives of the EU environmental and climate policy and legislation (see article 3 of the LIFE regulation for precise working). In this form, you should argue the degree to which you are doing this. In the case of Nature IPs please bear in mind the provisions of of the Application guide together with the corresponding section 4.3 of the Evaluation guide. Form B4: Here the proposal should include information on the basis of section 2.2 (and 3.3.2) of the application guide at the overall level of the project, making reference to individual project actions, as needed. Not all individual actions have to be categorised here in an exhaustive manner. Yes, in line with II.23.2.d) of the model grant agreement, an audit certificate is required for both the final and all interim payments. The costs of the audits are eligible under "other costs" in accordance with the II.19.2.e) of the model grant agreement. The audit may be conducted by the audit office of the public authority provided that it is indeed entirely independent of the 10/2/201 10/2/201 10/2/201

9 20 C forms, For the interim and final report it is required to complete an indicator table that should include quantitative and qualitative indicators: is a format for such an indicator table available? In the guidance document reference is given to the MYPOW but the relevant chapter does not give concrete indicators. 21 Financial forms, durable goods: for Nature IP projects, durable goods are eligible at a 100% depreciation rate. Does this mean the same as the actual cost? Could this be clarified? 22 Financial form F7 in the guidance document on page 78, it is mentioned that the auditor costs should be included under other costs but on pg 70 giving information on the form C1 F (project management) is mentioned that auditor costs should be included under external assistance? Under which type of costs should the audit be included? 23 Financial forms, other costs: Concerning financial support to third parties to implement certain actions cfr guidance doc pg 22, such support actions are allowed with max /party, and a maximum of for total IP. Such a restrictive rule will not allow enhancing cooperation with stakeholders. What is reason behind this restriction? Can actions + beneficiaries. Regarding indicators, please follow the guidance in and 2.4. of the Application guide. Please take note of the remark there that "Further guidance on indicators will be issued by the date of grant signature." This should be read together with the "General comments on Forms F4.a, F4.b and F4.c Durable goods" where it is indicated that the 100% eligibility (i.e. the full purchase costs are eligible) is an exception to the normal practice where only the depreciation costs are eligible up to a maximum of 2 % for infrastructure and 0% for equipment, except for prototype costs which is also 100% eligible. The correct category for audit cost is under "other costs". Please disregard the text on p. 70. The financial support to third parties should be understood as a grant within the grant that can be paid by the beneficiaries to third parties (eg. stakeholders) under certain and strict conditions (as per the referred of the guide). Note in this regard, that normally those stakeholders that are expected to incur substantial costs in relation to the implementation of the IP should become associated beneficiaries of the IP instead of 10/2/201 10/2/201 10/2/201 10/2/201

10 payments be allocated to stakeholders under subcontracts as indicated in Art. II.19 of the Model Agreement? 24 Financial Form FP concerning the overview of complementary actions: In the guidance doc, page 79 indicates that we must list their contribution to direct co-financing of LIFE IP project: could it be clarified whether a complementary fund can co-finance actions under the LIFE IP? 2 Can you confirm that the complementary actions do not have to be described in the full proposal? expecting to receive grants distributed by the project beneficiaries. Also note that this facility is in addition to external assistance costs that are paid to sub-contractors, on the basis of normal tendering rules. Any non-eu fund (e.g. national, private or international) can either directly co-finance the LIFE IP itself thus covering a part of the 40% "own contributions" from the beneficiaries; or it can finance complementary actions, depending on the conditions set by the relevant donor. Funds from other EU sources, on the other hand, can only be used for complementary actions. The complementary actions must be described to a degree that provides sufficient information to demonstrate the strategy and intention of the applicant to implement the targeted plan. Please see the instructions in the Application guide regarding the B forms and in particular those for form B1. Also note that these actions should be linked into the overall strategy underpinning the Integrated Project; we expect the beneficiaries of an IP to be able to monitor how these actions contribute to the overall plan implementation. Thus a complementary action is not only a list of additional actions carried out using other financial means that may be considered as interesting for the implementation of the plan, but they must be built and linked to the IP in a way to ensure they effectively contribute in a measurable way to this strategic goal. We advise avoiding listing complementary actions unless the beneficiaries are reasonably confident that they will be able to have a good overview of how these will be implemented in time and how they will contribute to the general objective of the IP. 10/2/201 10/2/201

11 26 The last application form sent includes both the forms of the concept note and those of the full proposal. Does the final project that has to be submitted in April have to contain both concept note and full proposal, or only the full proposal? 27 Our project partnership is composed of only national entities in our country and the project (text) will have to be distributed to a large number of entities/actors. It is important that those actors/entities understand correctly the contents of the project. Could an application written in our language be accepted? Should it be necessary, we could provide you with an abstract in English of part B of the application, as well as of every single action. 28 May the text of form B1 of the full proposal (Summary description of the project) be similar/the same as the text of form Cne of the concept note, if adequately updated? 29 In the case where entities that do not form part of the project partnership (e.g. municipalities or associations) carry out complementary actions that require cofinancing, is it possible to transfer to those entities funds earmarked as "aid to third parties" as per paragraph of the Guidelines for applicants, to cover the needed co-financing? If so, how are they to be declared in the application? As Other costs? And to which level of detail do the costs incurred using those Only forms related to the full proposal, without the concept note forms, have to be submitted. As indicated in 3.3 of the application guide, we strongly recommend that applicants complete the proposal in English. The reason for this is to facilitate its evaluation. In case you decide to write your application in another EU language (for the reasons you mention) we would appreciate that you also submit English abstracts as you suggest. The title of the proposal and form B1 ("Summary description of the project") must always be submitted in English. Yes, form B1 should in principle have similar information as form CNe with updates where necessary. However, the level of detail in form B1 can be less than in form CNe for items (e.g. stakeholders, sustainability, etc. for which you will now be providing more information in dedicated forms in the full proposal. No, the special facility "aid to third parties", should only be used in exceptional cases meeting the conditions of of the Application guide and Article II.11.1 of the Model Grant agreement. Take also note that its total amount is capped at EUR. 10/2/201 10/2/201 10/2/201 10/2/201

12 funds need to be declared? 30 Is it possible to form a partnership for complementary actions with entities that are not yet partner in the project? If so, can those entities be beneficiary of LIFE funds? 31 Eligibility of personnel costs: Our Nature IP Project brings together different types of beneficiaries. For some associated beneficiaries, the personnel that shall work partly on the LIFE project, is actually already partially (e.g. 0% or 80%) co-financed by the Ministry of Environment on the basis of specific national legislation. Are those nationally co-financed personnel costs eligible for the LIFE project or is only the part eligible that is not co-financed by the Ministry (e.g. 20 % or 0 %)? Eg. in the case of the Chamber of Agriculture, the staff (e.g. agricultural consultants) is being co-financed by the Ministry of Agriculture via a national program related to the rural development program (RDP). The RDP has to be approved by the EU Commission because it is linked to the FEADER but the personnel costs are not directly financed via the FEADER. Would those personnel costs, nationally cofinanced by the Ministry of Agriculture, be eligible for the LIFE Project? At the time the coordinating beneficiary submits the proposed planning for each project period, proposals for a change in the partnership may be introduced, including adding new partners as associated beneficiaries. Entities which are not associated beneficiaries may not benefit from the LIFE finance. In general, LIFE provides co-financing for any costs that are eligible under the terms of the grant agreement, with the full cost being the basis for the financing. In this respect please read carefully the provisions under Article II.19 of the Model grant agreement for IPs, with special regard to point a) of II.19.2 on personnel costs. Accordingly the costs of any personnel of the beneficiaries could be eligible as long as that cost is incurred in relation to the implementation of the project so if somebody works a certain percentage of his/her time on the project, the same percentage of the relevant personnel costs would be eligible. Please note that the total EU contribution to a project cannot exceed 60% of the eligible costs. For this reason, LIFE and another EU fund cannot both contribute to any of the project's costs. So, for example, if LIFE pays 60% of the costs of a person's eligible salary for time worked on the project, the other 40% of the costs for that time cannot come from the EU co-funded RDP, even indirectly via the Ministry. The 40% must be paid by money that is entirely national (i.e. non-eu). It is up to you to verify, on the basis of the above, the cases you present. If the salary costs are met by the beneficiaries and cofinanced by the Ministry, using 100% national money then there appears to be no problem. However, if the Ministry money is 10/2/201 10/2/201

13 32 Question about "external assistance": The Ministry of Environment, as coordinating beneficiary of the LIFE project, intends to engage a project manager as well as administrative staff via a new "Economic Interest Grouping" that our Government is setting up together with a University. This new staff would work directly for the ministry and under the responsibility of the ministry and be bound to it by a work contract. A specific staff member of the ministry will be in charge of directing/supervising the project manager who will be part of the core LIFE IP team. We would not consider this type of setup as an outsourcing or an external assistance. Can you confirm our position? 33 To achieve the objectives of our project we need to : Recruit, train and coordinate about 30 technical staff with a degree in agronomy / biology, who will operate from the local N2000 site managing entities Transform the monitoring plan into an operational coming from FEADER then you cannot also ask for 60% finance from LIFE. Take note that the project must respect the 2% rule for public beneficiaries. In case the "Chamber of Agriculture" is not a public body, the beneficiary should declare the contribution from national public bodies as co-financing to the project (in case these public bodies are not beneficiaries but co-financers), in order for us to check if the project is in a profit situation. In any case the funding of their staff from LIFE budget cannot exceed 60% of the personnel costs. Answer: Yes, based on this information this scenario may meet depending on the specific conditions - the provisions of Article II.19 a) of the Model grant agreement for IPs which says that "The costs of natural persons working under a contract with the coordinating beneficiary or an associated beneficiary other than an employment contract may be assimilated to such costs of personnel, provided that the following conditions are fulfilled: " But, do make sure that all conditions listed there are met. Take also note that beneficiaries have to demonstrate good value for money for all costs, whether or not they are reported under external assistance. Based on the information provided and its key role in the project, FXY should become an associated beneficiary to the project. This would also ensure its project-related costs are potentially eligible 10/2/201

14 manual, define individual specific "work packages" per area / species / habitat, identify the individuals who would undertake the monitoring activities, coordinate the field work and organize the data collected. For these activities we would like to make use of an entity affiliated to the Coordinating beneficiary (CB) of the project and, to this end, we have identified the Foundation for the XY (FXY). It should be noted that: a) the statute of the FXY must be approved by the CB, b) three of the five members of the board of the FXY shall be appointed by the CB, c) The Board of Directors is appointed by the decree of the government, d) two of the three members of the Board of Statutory Auditors (which controls the administration of the FXY and oversees compliance with the law and the statutory rules) are appointed by the Council of the Region. We would therefore like to know: Q1 ) If FXY meets the definition of an affiliated body. Q2 ) How to insert the affiliated body within the project and how expenditure incurred by that body will have to be accounted for in the project. 34 We are now preparing descriptions of Actions. The description of Actions for phase 1 is more or less as Please refer to the text in bold at the beginning of sections and of the application guide (p6, p64).

15 detailed as in the previous applications for LIFE funding. But how detailed should the description of Actions for phase 2 and 3 be? Is it enough to write 2-3 sentences in answer to the questions on the form, or should it be more specific? 3 Will it be possible, once the financing of the project is confirmed and once phase 1 is finished, to modify phase 2 and 3 in justified cases (for instance by adding / removing an action, changing project location, making corrections ("reality check") of the project indicators)? 36 Can we have an Action "Making more detailed plans for next stages of the project". This action would involve making more detailed plans for next phases of the project by the project staff in cooperation with stakeholders and taking into account problems encountered and lessons learnt. We think this kind of action could make the project management much easier and it would not be very expensive (it would only be personnel costs, meetings, obtaining regional management plans and other documents). 37 Can we submit the application for a project that has a longer duration than the duration indicated in the concept note? Now that we think about it and taking into account suggestion to make sure there is a sufficient time margin, we would like to submit an application for a project lasting 8. years (instead of 6. years). Yes, as indicated in of the application guide (p22). Yes. It should have the detailed plans as a deliverable/expected result. Please note that this task will be a normal activity of the project management of every IP. As such it does not require to be specified as a single action. The plan for each stage is a normal deliverable part of the scheduled reporting. If you wish to highlight this activity as a single action you may however do so. Yes.

16 38 What will be the possibilities to modify the projects? How often will it be possible to modify the project? Will it possible only after each phase is finished? 39 According to the Model Grant Agreement Article I.4.1. we are going to get 20% of the pre-financing payment after signing the agreement. After that in the end of first phase we will get another 20% of interim payment after reporting what has been done during first phase and describing what we want to do in second phase in details. We want to ask what would happen if we won't spend the whole 20% during the first phase? Will we need to give it back or will the second payment be cut down by the unspent amount? We are aware that in the "traditional" projects that the beneficiary to get the interim payment needs to spent 10% of the previous payment. I didn't find such information in Model Grant Agreement for Integrated Projects. Could you confirm that this rule does not apply to Integrated Projects? 40 Complementary funding sources: a) The IP will last approx. 10 years. The OPs for some complementary funding sources (e.g. financed via the EAFRD) only have a runtime for the upcoming 6 years. As indicated in of the application guide (p22), an amendment to the grant agreement will be signed after a phase ends to cover the detailed work plan for the subsequent phase and also reflect all changes agreed. Amendments are also possible during a phase, but only in very exceptional cases and if the formalisation of the change requested cannot be postponed till the next "routine" amendment. At the end of each phase you will have to submit the foreseen report, and may ask for an interim payment. The actual amount of the interim payment will be established as per II.24.3 of the Model Grant agreement, on the basis of the eligible costs incurred. If the co-financing rate is 60%, then the interim payment will amount to 60% of the eligible costs of the phase just finished, with a maximum not exceeding 20% of the maximum EU contribution for the project as a whole. If the unlikely event that you have not spent all of the pre-financing payment, you will not be asked to reimburse it at that point in time, but at the final report stage an appropriate adjustment may be made (based on the total eligible costs, the co-financing rate and the total payments already received). a) For the complementary activities you should indicate where you foresee the funding will come from. This should be supported by a letter of intent from the relevant funding body. It is true that other European funds (eg EAFRD) are established for a 7 year

17 Therefore the complementary funding can only be secured/indicated for this very period, not for the whole runtime of the IP. Is this o.k. and how/where do we indicate the time limitations of some complementary funding sources? b) Ref p. Guidelines for Applicants: Will we need a letter of intent for each funding source listed, or only for one? c) Will there be two different kinds of letter, o one stating the actual approval of funding for a complementary action, o the others only stating the general possibility to submit the actions listed for funding in this programme (eligibility for funding)? 41 Ref LIFE Technical Forms revised (after CN) Coordinating Beneficiary declaration In our version of the Coordinating Beneficiary declaration, the following phrase is deleted (mode track changes): I am aware that my organization is solely legally and financially responsible to the Contracting Authority for the implementation of the project Could you please confirm, whether a) this deletion is correct or b) whether this sentence has been deleted by accident and it is part of the Coordinating Beneficiary declaration period (as is LIFE). The funds must be committed to projects during the relevant period, currently , but the expenditure may be incurred thereafter in accordance with the rules of the given funds. b) and c) In order to be eligible, a proposal must include at least one letter of intent where the funding is unambiguously confirmed. For other funding sources, the letter shall at least confirm that the complementary action in question is in principle eligible, indicating whether the expected financing form that found is realistic and at what stage the applications for that fund are, and, if possible indicating the likelihood of funding. During the evaluation of the full proposal, one of the many elements taken into account is the amount and level of commitment of funding for the complementary actions. This deletion is correct, as it now corresponds to Article II.1 of the model grant agreement for integrated projects. 42 C-Actions concrete implementing actions Ongoing refers to activities being implemented before the project starts (at the same level of intensity and frequency as proposed

18 On p. 23 of the Guidelines for Applicants section you specify that Actions already ongoing before the start of the project are not eligible. Could you please specify, what you mean by ongoing? Which phase of the project is relevant: permit application is submitted, permit is granted or if the implementation is already secured, e.g. via a binding contract under public law? 43 A actions and related C actions Do concrete (implementation) actions following an A (preparatory action) always have to be presented as a separate action, that is how generalized or summarized can we present C actions, which cannot be further specified unless the respective A action is finalised? 44 Within the framework of a water IP, In case of land purchase by a public authority from a private owner, is the cost eligible in case this respective public authority transfers this land to another public authority? In our region this kind of transfers are common practice in view of landscaping and management of the land. 4 We can read in the guide for applicants that where public bodies are involved as coordinating and / or associated beneficiaries in a project the sum of their financial contributions to the project budget must exceed (by at least 2%) the sum of the salary costs for the IP). Please also refer to article II.19 of the model grant agreement regarding the eligible costs. C actions are different from A actions. For all actions the description should be as precise as possible. If the content of a specific C action depends on the outcome of an A action, you should provide as much details as is possible at this stage, and describe the correlation between the two actions. You should also clearly explain how the cost of the C action was estimated, given that you don't yet know what you are going to do. This applies in particular for C actions foreseen during the first implementation phase, for C actions foreseen for subsequent phases their description may obviously be less detailed. Yes such transfer is possible, noting that land purchase is only eligible in case all conditions of Article II.19.2(i) of the Model Grant Agreement and of the Application guide are fulfilled, in particular point II.19.2.(i)(ee): "the Member State concerned shall, by way of transfer or otherwise, ensure the long term assignment of such land to nature conservation purposes." a. As mention in the text you quote, this rule relates to the sum of contributions compared to the sum of salary costs for permanent staff working on the project, i.e. for all public beneficiaries lumped together.

19 charged to the project for staff who are not considered as additional. In regard to this our questions are: a. Does this rule apply for each public beneficiary or ALL public beneficiaries (CB + AB) counted together? b. Given that a public beneficiary delegate permanent staff to do project specific work to the cost of e.g. 100 euro (which will also be a part of the co-funding from that beneficiary), then will it also need to put in 102 euros in co-funding in cash? Or will it suffice with a cofunding in cash of only 2 euros? c. If a public AB or CB only choose to co-finance with cash and no own work from permanent staff, then that cash funding have no exact ratio and may be as large or small as judged suitable to show a true interest and commitment in the project, or not? 46 On the 19 th of December 201 the European commission forwarded to us a letter which stated that the deadline for the submission of projects within the framework of LIFE tender is 17 th of April 201 till 4 PM. On the other hand the Guidelines for applicants state (on page 18) that the deadline for the submission of projects within the framework of LIFE tender is 1 th of April 201 till 4 PM. Could you please clarify which deadline for the submission of projects within the framework of LIFE tender is the correct one? 47 The Guidelines for applicants (on page 20) state»there is no pre-determined project duration for a LIFE b. In your example, the extra co-funding should be at least 2. c. As indicated in the answer to question a, the ratio is calculated for all public beneficiaries together, so you might have the case where a public beneficiary does not have permanent staff time costs. In the Guidelines it is specified that "The deadline for the submission of the full proposal will be specified in the relevant invitation". As you say the letter inviting you to submit a full proposal states that the deadline is 17 April 201 at 4p.m. That is therefore the deadline. As stated, the plans that IP should help implement are complex, but it is up to you as a potential beneficiary to estimate how

20 Integrated Project. However, considering the project's direct link with long term plans and strategies most Integrated Projects are expected to last between 6 and 10 years. The duration of our project is less than years according to the Concept Note. Could you please provide us your recommendations? 48 On the 14 th of January 201 you have forwarded an to us that included a document entitled»updated LIFE 2014 Integrated Projects Technical forms«. The mentioned application form differs from the one published on the LIFE online page. Could you please provide us the clarification which application form is the correct one? 49 Within the context of the 1 st phase (Concept Note) we have specified specific project activities. When reviewing individual activities some project partners expressed a desire to replace specific project activities defined in the Concept Note with activities not specified in the 1 st phase (Concept Note). Could you please provide us the explanation, whether it is possible to replace individual project activities? 0 In the application form we have determined individual project activities. Could you please provide us the explanation, whether it is possible to replace, after the start of the project approved by the European commission, individual project activities if the project activities realization does not meet the relevant project objectives/outcomes? 1 Guidelines for applicants paragraph 3.4 Financial Application Forms mentions that: All costs must be much time you need to carry out the actions in your project. As you state, the document ed contains the updated LIFE2014 Integrated Projects Technical forms. These updates have in the meantime been published on the website (replacing the previous version). Yes, it is possible to change specific/individual project activities between the Concept Note phase and the Full Proposal stage. Please refer to question 38. a) The non-recoverable part of VAT can be reported as a direct cost if there is a valid VAT certificate which confirms the

21 rounded to the nearest Euro and must exclude valueadded tax (VAT) when the beneficiary can recover this cost from its national authorities. If a beneficiary: a) according to its activities and relevant national laws, can recover only a percentage of VAT and not VAT as a whole, does this mean that VAT is not eligible at all or just the recovered part of it; b) is a Public body (e.g. University), constituting it as a beneficiary which cannot recover this cost from its national authorities thus VAT is regarded as eligible cost, but its staff (personnel participating in the project) can recover VAT, how could this case be managed? Would that make VAT not eligible for both the University and its staff, or only for its staff? 2 Can the composition of Associated Beneficiaries at the stage of Full Proposal be different from the submitted Concept Note? Please note that this doesn t concern the coordinating beneficiary, who will be the organization having submitted the Concept Note. 3 One of the core measures of our Air Quality plan are subsidies for the new household heating appliances and new connections to the district heating system in order to replace outdated over polluting solid fuel fired appliances, which are common in the region. The complementary measure in our Air quality plan is subsidizing the improvement of the thermal insulation of the buildings, thus simultaneously addressing excessive energy consumption, greenhouse gas emissions and air quality improvement. Both measures percentage of non-recoverable VAT. b) It is not clear why invoices should be issued in the name of personnel if the beneficiary is the University. If it is about travel costs which are directly paid by the staff members, this part of VAT is always eligible as there is no procedure for the beneficiary to recover it. Yes. LIFE IPs are in principle not intended to finance such subsidies paid to individual households. As the guidelines for applicants state in 2.2,"LIFE IPs should facilitate the building of capacities of the beneficiaries and stakeholders with special regard to competent authorities in order to ensure the implementation of the complementary actions and of the entire plan targeted by the project as well as the sustainability of the investments made by the IP". There can be actions that apply best practices, or actions of a demonstrative or innovative/pilot nature if those are needed to find the best solution to a problem, but this seems not to be

22 are already in the implementation phase. The subsidies for households are granted by a state fund for the replacement of the heating systems and thermal insulations of the buildings and are in this region, due to air quality issues, higher than in other parts of the country. However, due to specific social circumstances in this region, where inter alia, the decline in the coal mining and energy intensive industry resulted worsening the social status of many households and also energy poverty, the replacement of the outdated solid fuel appliances and improvement of the thermal insulation of the buildings is not proceeding at the satisfactory rate. We would like to ask Commission, if, to what extent and under which conditions, subsidies to the households for the replacement of the outdated heating appliances and improvement of the thermal insulation of the buildings are eligible LIFE project expenditure. We would like to emphasise, that those subsidies will be additional to those provided by the state. 4 All seven adopted air quality plans in our country require improvement of the air quality assessment system including the quantification of the contribution of different sources to the excessive air pollution and assessment of the effects of the implemented or planed polices and measures. The existing air quality assessment system, which is operated by our Environment Agency, is planned to be modernised and upgraded in this respect. The upgrade of the system applicable to the situation that you describe. a): No, in principle there are no such limits set. Please take note, however, of the general requirements that actions within the IP itself cannot be financed by other EU funds and that LIFE should not finance actions that are better financed by other EU funding programs. Furthermore, according to of the guidelines, Air Integrated Projects should be designed to support the application, development, testing and demonstration of integrated approaches for the implementation and monitoring of air quality plans. Air quality assessement including the