UVT, Alm.del - 2010-11 (1. samling) - Bilag 215: Høringssvar vedr. grønbogen "Fra udfordringer til muligheder: Mod en fælles strategisk ramme for EU-finansiering af forskning og innovation", KOM (2011) 48 af 9/2-11, fra videnskabsministeren

1) Introduction and main prioritiesThe Danish government supports the European Commission’s plans to integrate instruments from theCompetitiveness and Innovation Framework Programme (CIP), the Framework Programme forresearch and development (FP7) and the European Institute of Innovation and Technology (EIT)within a Common Strategic Framework (CSF). A future Common Strategic Framework should becoherent, streamlined and fulfil the ambition of significant simplification. Programmes under theframework must have clear European added value and their effectiveness and impact should beclosely monitored with valid output and outcome measures.In the green paper the Commission outlines three main challenges for Europe: Tackling societalchallenges, strengthening competitiveness and strengthening Europe’s science base and theEuropean research area. These are fundamental challenges the common strategic framework shouldaddress and therefore a valuable starting point for discussing the common strategic framework.Denmark is favourable to a structure of the common strategic framework mirroring these threeoverall challenges. The fourth challenge outlined in the green paper - working together to deliveron Europe 2020 - is also a key political focus point.Fundamental questions to discuss include priority setting in terms of relative budget for the variouspillars and priority setting in terms of which challenges and key enabling technologies that should bein focus. In general Denmark is particularly favourable to increasing the relative budget for theEuropean Research Council, research infrastructure and commercialisation and demonstration oftechnologies within the common strategic framework for research and innovation.This mirrors the fact that it is a key Danish priority that any future programme structure for researchand innovation funding should contribute positively and targeted to promote productivity, growth andcompetitiveness of European companies. In this respect the instruments supporting SME access tofinancing innovation and growth play an important role and should be prioritised which should alsobe reflected in the design of future governance structures to handle innovation measures in the EU.

2) Working together to deliver on Europe 20201) How should the Common Strategic Framework make EU research and innovation funding moreattractive and easy to access for participants? What is needed in addition to a single entry pointwith common IT tools, a one stop shop for support, a streamlined set of funding instrumentscovering the full innovation chain and further steps towards administrative simplification?The European Commission’s continuing efforts to streamline and simplify the frameworkprogrammes are crucial to ensuring the greatest possible benefit from the EU’s research funding aswell as attracting applications from excellent researchers and innovative businesses. Easing theapplication and executive burden for users has to be a core focus for the future common strategicframework. The users should spend their time on their core business, not on administration.Therefore the abovementioned instruments – a single entry point, a one stop shop for support, astreamlined set of funding instruments and further steps towards administrative simplification – areimportant steps in order to make the EU research and innovation funding more easy to access forparticipants.The European Commission has taken an important step towards simplification under FP7, butadditional initiatives are needed. Consequently, the next framework programme should first of allbe based on less administration. At the same time, Denmark supports the suggestion in the midtermevaluation of the seventh framework programme of a moratorium on new instruments and that theframework programme is made more userfriendly.Less administrationReporting requirements should be simplified by reducing the number and size of reports and theirscope. In particular, Denmark recommends reducing the number of so-called periodic reports whichcontain both financial and scientific parts.Another heavy administrative burden for participants is the time recording system. The EuropeanCommission must accept the various time recording systems and methods of calculating cost ofeffort in projects in the institutions of grant holders. A simplification of the time recording systemwould contribute to a significant simplification of the reporting requirements.Time-to-grant should be significantly reduced. In relation to SMEs, time-to-grant can be reducedvia SME certification schemes in Member States. If national SME certification schemes areintroduced in Member States the Commission does not have to verify the status of the SMEs andthe negotiation stage is thereby shortened. When relevant it should be possible to start up theproject during the negotiation phase with the European Commission with the applicants bearing thefinancial risk until negotiations are finalized.

More trustThe next framework programme should shift from a control based approach to a more trust basedapproach, which would also be enabled through simplification of the framework programme. TheCommission’s proposal of increasing the tolerable risk of error should be considered so as toachieve the right balance between trust and control.More flexibility in project managementMore flexibility is needed in order to raise the degree of freedom for participants in themanagement of projects when creating, building and adjusting consortia. The involvement of newbeneficiaries must be made easier in particular the ones ensuring capitalisation of innovativeresults. Simplifying administration in order to ease affiliation of new beneficiaries and ensureflexibility is a key objective.The principle of allowing grant beneficiaries to choose between having their overhead calculatedbased on the actual costs or based on a fixed percentage rate of 60% should be upheld. It is alsoimportant that the applicants clearly understand whether this choice is available to them or whetherthey need to establish systems for calculating the actual costs in case the fixed percentage rateoption is eliminated.Fewer and more coherent instrumentsAs has been pointed out in the Innovation Union Flagship Initiative and the mid-term evaluation ofthe framework programme, the high number of uncoordinated instruments is problematic.Duplication of instruments should be avoided. The aim should be fewer overlaps and no newinstruments should be established without clarifying the area covered by existing instruments. TheERAC reports on synergies and ERA-related instruments should be taken into consideration.Fewer special rulesThe number of special rules applicable to the individual research programmes and project types istoo large. It is important not to introduce additional special rules and exceptions, but rather toreduce them to make the framework programme significantly more user friendly. The same set ofrules and the same procedures should, to the greatest extent possible, be used in the frameworkprogramme as well as in the implementation of programmes such as ERA-NET plus, Article 185and the JTIs.Ensure stability of rulesThe Commission should avoid as much as possible changes in the rules of participation during theframework programme. Stability of rules is a measure of simplification itself.More uniform interpretation of the rules within the programmes and across the programmesIt appears to be relatively common for the same set of rules to be interpreted differently throughoutthe Commission. For instance rules regarding the calculation of working hours and determinationof exchange rates are interpreted differently by different units in the Commission under the Peopleprogramme. A uniform internal interpretation and administration of the rules must be ensured.The rules for intellectual property rights should be made more understandable and uniform for allresearch programmes and project typesThe rules for intellectual property rights are extremely complex. The users of the frameworkprogramme are therefore often forced to seek expert help to interpret the rules and to ensure thattheir interests are taken into consideration. Furthermore, the provisions for intellectual propertyrights differ depending on the rules for participation that govern the programmes as well as on thegrant agreements upon which they rest. The rules for intellectual property rights should therefore

be made simpler, more understandable and uniform for all research programmes and project typeswith the aim of reaching generally accepted IPR rules in all research programmes and project types.More user friendly communication and guidance for applicantsThe access to EU research and innovation funding should be approved through better and moreuser friendly guidance for applicants. The differing rules and requirements for applicants indifferent programmes cause confusion and resignation especially for novel participants.Ways to improve access could for example be to provide a concrete overview of the process andrequirements within an EU project. The one stop shop and single entry point already proposed bythe Commission could also contribute to a better overview of the possibilities and requirements inthe EU research and innovation funding programmes.Furthermore better guidance supporting applicants during the application phase is required e.g.through user oriented step-by-step guides or templates and case descriptions for draftingapplications. The use of a user friendly language that takes into consideration that the terminologyin the funding programmes is unfamiliar for many participants is another important measure toimprove access to EU research and innovation funding.

2) How should EU funding best cover the full innovation cycle from research to market uptake?A key challenge for Europe is to transform its high quality research into innovation. Denmarksupports the idea of increasing the focus on the whole value chain from basic research to themarket. When research results are available, the next step towards the market is often testing ordemonstrating the results. However, this is often very costly and therefore difficult for businesses,especially for SMEs, to execute. Future projects should be able to address this challenge byreceiving funding for this stage in the development of new innovative solutions. The scope of thesupport for demonstrations and testing should be adjusted to accommodate the fact that theactivities take place relatively close to the market so significant private co-financing should berequired, as is also the case in the current framework programme.The major share of EU funding for research and innovation is currently allocated to the early stagesof the innovation cycle (research), while only relatively few resources are allocated to late-stageinnovation activities. The Common Strategic Framework should aim at achieving a better balancebetween funding available for early and late stages of the innovation cycle by increasing the share ofEU funding available to late stage innovation activities such as demonstration, testing,commercialisation and non-technological innovation.Global competitors such as the United States are already funding demonstration andcommercialisation activities in strategic industries and technology domains. To match its globalcompetitors, the EU needs to ensure that enterprises in Europe, in particular SMEs, have access tofunding for demonstration and commercialisation activities.In addressing the full innovation cycle the synergies and complementarities with the cohesion policyshould be addressed in accordance with the place based approach, cf. remarks on question 8.

3) What are the characteristics of EU funding that maximise the benefit of acting at the EU level?Should there be a strong emphasis on leveraging other sources of funding?We live in a time of serious strain on public sector budgets and increasing global competition.Europe’s competitiveness and the future standard of living depend on our ability to support anddevelop innovation in products, services and trade as well as in societal processes and models. TheEU Framework Programme is one of the largest research and innovation investment platforms inthe world, and it is therefore vital that the programme is rethought and planned in accordance witha growth-oriented agenda.Europe must work together in areas where individual Member States lack the sufficient capacitiesand the critical mass to solve a given challenge by themselves. This especially applies to solvinggrand societal challenges.Other key characteristics of EU funding that maximise the benefit of acting at EU level includescross border cooperation, lesser duplication of national research and innovation investments andincreased excellence through increased competition.Incentives for increasing private investments in EU research and innovation programmes should beconsidered in the design of the Common Strategic Framework. Also, the synergies between theCommon Strategic Framework and cohesion policy funds should be explored.Denmark stresses the importance of continuing to monitor impacts of programmes and initiatives toensure that public funding is directed towards programmes and initiatives that provide most valuefor money.

4) How should EU research and innovation funding best be used to pool Member States resources?How should Joint Programming Initiatives between groups of Member States be supported?Denmark supports EU financing of research and innovation through the instruments ERA Net,ERA NET+ and Article 185 initiatives. This support is based on the assumption that it is ensured,that these instruments are supplementary to the strategic focus areas decided upon in the futureCommon Strategic Framework and to other initiatives like e.g. the Joint Programming Initiatives.EU-topping-up as a bonus for using the common pot model in transnational cooperationEU resources (co-funding and topping-up) could function as an incentive for Member States toengage in transnational and regional research programmes. Co-funding and topping-up could be abonus that would be activated when countries coordinate their research activities and open up theirnational funding schemes to other countries. If there was to be a bonus activated when transnationalcooperation and common pot is realised, then a model could in some cases be a mixed-modecommon pot, which gradually could evolve into a real common pot.

7) What should be the measures of success for EU research and innovation funding? Whichperformance indicators could be used?Demark generally supports the use of valid output and outcome indicators as the relevant measureof the effects of European research and innovation funding. Regarding the selection of morespecific indicators to measure the success of the long-term goal Denmark would suggest thefollowing:The Commission should develop the indicators on FP-funded projects furtherThe existing system containing updated E-CORDA data thrice a year should be continued thusallowing Member States and other to monitor success-rates and patterns of participation etcetera.Compared to the situation during previous framework programmes the present situation providesfar better data. Nevertheless, there is still a need to develop the basic statistics that are available.Today it is easy to monitor a country’s success-rate in e.g. the Health programme but nearlyimpossible to get hold of a list of successful applicants to IMI calls. Thus application and fundingdata from ERANETs, ERA-NET+, Article 169/185 initiatives, JTIs and EIT-initiatives need to bean integrated part of the statistical packaged provided by the Commission to Member States whenthe FP8-monitoring system is set up.Current Danish studies highlight international networks, cutting-edge knowledge, and access tonew international markets as additional outcomes of explicitly international EU programmes suchas FP7. It appears less clear, however, how these measures are to be converted into performanceindicators, and how these indicators could be compared and qualified by e.g. national measures.Nevertheless, international networks, knowledge and access to new markets are among theforemost reasons why e.g. Danish SMEs choose to engage in international science and researchcollaborations. It would be extremely useful to highlight these potential benefits by means of harddata rather than just surveys and interviews.Measurement of long term effects of FP-participation should be developedUsing the Unique Registration Facility the Commission should keep track on those companies thathave participated in an FP-funded project in order to monitor the medium and long term effects ofparticipation. The innovation performance of EU funded research and Innovation could bemeasured by looking at the number of patent applications generated by projects co-funded by EUfunding. To what extent do companies contribute to greater economic growth? Do companies thathave participated in an FP-funded project generate more trade and exports? Do they increase theiremployment of highly skilled and/or non-nationals? Preferably the monitoring could be carried outin countries that have nationwide central business registers thus avoiding the costly use ofquestionnaires.

A pilot study could be conducted within the Nordic countries using the differences in methods (acontrol group and a group exposed to treatment (FP-participation) compared before and after).European Integration should be regularly monitored using available information about EU-fundingacknowledgements from within the scientific publicationsThe number of publications in scientific journals which contains “funding acknowledgements” hasincreased rapidly within the last few years - thus allowing for improved monitoring without longand painful collections of lists of FP-funded publications from previous lists. Presently Web ofScience contains more than 2800 publications published in 2010 that enlists either “ERC” or“European Research Council” as funding agency.Co-publication patterns between Member States, FP-associated countries and others should bemonitored regularly using such bibliometric data.Monitoring of interplay between national and EU funding for R&D and innovationInterplay between funding from national research councils and universities on one hand andEuropean funding on the other hand should be monitored more systematically. Presently a total of22 EU Member States are partly or fully providing data to EUROSTAT regarding the proportion ofthe nationally performed R&D that was funding by EU-funding. A number of national statisticalagencies within the Member States also hold information at the level of individual universitydepartments and companies regardingotherR&D– funding sources. Thus it would be possible tomonitor the interplay between different sources of funding. Using data on micro-level within some(or all) of the national statistical agencies studies should be done on the additionality of EU-funding. To what extend was it the same university departments and companies that participated inboth various national funding schemes and in FP-funded projects? How many and which type ofresearch active SMEs are participating in national funding schemes and in FP-funded projectsetcetera?Monitoring of European Research excellenceThe ERC is a key instrument in fostering and supporting research excellence. The further scientificcareers of ERC grant holders should be monitored on a regularly basis using register data, surveysand bibliometric sources.EUROSTAT should conduct a common Public Research Commercialisation SurveyHarmonized common European statistical information on 1) the number of university spin-outcompanies, 2) number of university patent applications and 3) university income from licencesshould be collected regularly. Presently there is only a limited and scattered statistical evidence ofthe innovative effects of Europe’s universities. Comparative data is only available for around athird of the Member States. Thus there is room for a much needed statistical improvement here.Development of joint/coordinated ex post program evaluations between national/regional researchfunding institutions (e.g. research councils) and Commission ServicesNational and/or regional research councils should work together with Commission services on ajoint or parallel ex post evaluation of e.g. EU and national funding schemes, research areas, orfunding instruments within a specific program area such as ICT, biotech or social science andhumanities. Presently there are very few European examples of joint research evaluationsconducted across borders. Evaluations like the 2009 evaluation of clinical medical research carriedout in parallel in both Finland and Sweden by the same panel should be used increasingly, andrelevant parts of the European Framework programmes should be included together with aselection of those Member States and associated countries that choose to participate. Such a set upcould be modelled using the Open Method of Coordination (OMC) – employed with success inERAC.

8) How should EU research and innovation funding relate to regional and national funding? Howshould this funding complement funds from the future Cohesion policy, designed to help the lessdeveloped regions of the EU, and the rural development programmes?The research and innovation policy and the cohesion policy use different tools when addressinggrowth based on research and innovation. Where the research and innovation policy focus on projectsat the European level and often with the participation of transnational actors and with a focus onresearch excellence, the cohesion policy focus on growth, based on the region’s strengths andopportunities (a place based approach) and projects often involve many regional actors, which createsa partnership and a broad commitment. Both tools have advantages and are needed to reach the goalsof EU2020.In implementing the cohesion policy, the priorities of other European policies should be taken intoaccount where relevant. Wherever possible, synergies have to be pursued. Ideally, European policiesshould be mutually reinforcing.Regarding research activities, the cohesion funds could, with complementary investment,support research and innovation infrastructures and ICT infrastructure especially in the lessdeveloped regions.In addressing the full innovation cycle from research to market uptake, the two policy-areas addresssome of the same issues and synergies are possible. The cohesion policy could – if it is consistentwith the place based strategies – support activities that involve SME more (for instance throughmatch-making SME with research and innovation projects) and can help spread new knowledge,establish demonstration facilities or create local networks.From a cohesion policy perspective it is however important that these effort builds on regionalstrengths and opportunities. In order to take the priorities of the research and innovation policy intoaccount on the ground, Member States must coordinate the place based elements of thepolicy with existing regional partnerships.Administrative burdens must also be reduced to increase the effectiveness of future EU projects, forinstance trough a standardisation of project management requirements across the various EU-programmes. It is however important to remember, that the place based approach have to berespected. Furthermore it is important that a strategic discussion on synergies and complementaritiesshould not result in obligations to fence cohesion funding for specific actions.

3) Tackling Societal Challenges9) How should a stronger focus on societal challenges affect the balance between curiosity-drivenresearch and agenda-driven activities?European research cooperation ought to focus on the common grand challenges in Europeansociety.To secure cohesion between the different initiatives launched to address grand challenges should bea central objective in the framework programme. A central aspect in this regard is to establish astrong link between the joint programmes and European innovation partnerships and the strategicfocus areas of the framework programme.Denmark agrees with the assessment set forth in the mid-term evaluation of the frameworkprogramme that the many strategic partnerships under the Cooperation Programme represent animportant and valuable contribution to realising the European Research Area. However, the currentthematic structure lacks the flexibility needed to target the strategic research projects to a limitednumber of grand societal challenges. As it stands, the current thematic structure faces a challengein implementing the interdisciplinary approach needed to address grand challenges. Social sciencesand humanities - and their link to natural sciences for instance - play an important role in thisprocess.The increased focus on grand challenges and thereby agenda-driven activities should becomplemented by an increased budget for curiosity-driven research through an increased budget forthe European Research Council to ensure the right balance between the two.

10) Should there be more room for bottom-up activities?The short timeframes in which businesses operate make it crucial that short-term instruments are inplace that can accept applications more often, such as twice a year. This is difficult for SMEs underthe thematic programmes as they are forced to wait for a call that is appropriate for their project. Inorder to address this issue, the number of non-thematic, bottom-up driven funding opportunitiesaimed at SMEs should be increased significantly.One point of criticism concerning the calls for application under the Cooperation Programme is thefact that these calls have been too narrowly defined. This can make it difficult for businesses toparticipate. At the same time, the narrowly defined calls for applications make it more difficult toexecute interdisciplinary projects and leave less room for researchers to define their projects.Therefore, an effort to broaden calls for application is needed in future strategic researchprogrammes. Broader calls would most likely require a new composition of evaluation committeeswhere interdisciplinary competences play a bigger role.

The next framework programme should comprise a strong strategic programme with a primaryfocus on a limited number of grand societal challenges. The main societal challenges to be tackledby the EU are already outlined in the Europe 2020 strategy and in Innovation Union. Denmarkproposes that a coming strategic programme focuses on at least the following grand societalchallenges: Climate change; Reduction on the dependence on fossil energy sources; Improvementof ressource efficiency including raw materials such as minerals and metals but also soil, water, air,biomass and eco-systems; Improvement of the state of health of the European population andthereby decreasing health sector costs; Sufficient and healthy food in Europe and globally;Improvement of European competiveness through the development of effective productionsystems; Enhancing cultural understanding and social coherence; And the ageing society.

13) How could EU research and innovation activities attract greater interest and involvement ofcitizens and civil society?To ensure a broad understanding of research and innovation it is important to work towardsstrengthening the public interest in these areas and to spread the knowledge of the positive effectson society that research and innovation have.A number of measures can contribute to this development. First of all, an increased focus onscience's ability to contribute to the solution of grand challenges will in all probability contribute toheightening the public interest, since these challenges are seen as relevant and topical. In thiscontext Denmark encourages that communication of the fact that research and innovationcontribute to economic growth is given political priority. The European Parliament with its popularlegitimacy can play a role in this task.Denmark furthermore recommends the involvement of citizens in a number of other areas. Forexample citizens and interest groups should be involved in defining strategic research areas toensure the rooting of research in society. Denmark also recommends that summits betweenresearchers and citizens are held where ethical dilemmas concerning new technologies are broughtup for discussion so that citizens' concerns are taken seriously and researchers get an insight in thepublic's position on new research.To stimulate dialogue, research projects that actively involve interest groups, businesses etc. in theresearch process itself should be encouraged. Likewise, researchers should be encouraged to look atscience communication as more than merely an appendix to a research project. Denmark is of theopinion that the earmarking of funding for research in science communication and involvement ofcitizens should be considered.Initiatives that can contribute to bringing science to the public in tangible ways should beprioritized. Among these, science festivals and websites dedicated to communicating the interestingdiscoveries from the world of research deserve a mention. In connection with this, Denmark

4) Strengthening Competitiveness14) How should EU funding best take account of the broad nature of innovation, including nontechnological innovation, eco-innovation and social innovation?In the Green Paper, the Commission points out that innovation requires many competencies andactivities beyond research, which by its nature are not directly linked to research initiatives. Itcovers for instance design, creativity and combination of existing technologies, new businesspractices, user involvement, etc. This is a view that Denmark fully supports as long as thesesources deliver on the overall growth targets in EU2020. Statistical evidence from Denmark showsthat 47 percent of innovative enterprises neither perform nor purchase research. A CommonStrategic Framework should therefore take this large segment of innovative activities – for exampleemployee driven innovation – into consideration in order to maximise the impact of funding forinnovation.As regards eco-innovation global resources will be increasingly scarce as a result of growingpopulation and living standards. Eco-innovation should be in the form of developing new resource-efficient and green technologies which contributes to global sustainability and Europeancompetitiveness.Experience from the Danish User Driven Innovation programme suggests that user-driveninnovation is most successful when it is integrated into other types of innovation. Therefore non-research based innovation should also be made possible within the research based programmes.

15) How should industrial participation in EU research and innovation programmes bestrengthened? How should Joint Technology Initiatives (such as those launched in the currentFramework Programme) or different forms of 'public-private partnerships' be supported? Whatshould be the role of European Technology Platforms?The path from research to innovation is not a linear process, but a dynamic one that involves manydifferent paths and detours. Research needs also arise in the business community and should bepartnered with relevant research at research institutions. A prerequisite for dynamic cooperationbetween research institutions and businesses is getting businesses involved in defining the researchprojects from the beginning in partnerships. Design of future partnership models should be basedon the extensive experience with partnerships in the form of Joint Technology Initiatives, Public-Private Partnerships, Knowledge and Innovation Communities and the positive experience underthe Cooperation Programme with SME-oriented instruments with high requirements for industryand SME participation combined with close contact to end-users. An increased use of partnershipswill contribute to increasing the level of industrial participation. A new spirit of cooperationbetween research institutions and business life is needed. Research institutions and businessesshould consider each other as natural partners of cooperation in research and innovation projects.

Concerning the Joint Technology Initiatives, Denmark supports the continuation of the instrumentson the premise that these instruments are supplementary to other initiatives in the future CommonStrategic Framework, and to other initiatives e.g. the Joint Programming Initiatives and theEuropean Innovation Partnerships. Future Joint Technology Initiatives should build upon theexperiences from the existing ones. They should make use of the same rules as in the rest of theCommon Strategic Framework and information about JTI participation should be available at thesame level as of the rest of the future Common Strategic Framework and equally easy accessible.To ensure synergy between the instruments European Innovation Partnerships could function as abridge-builder.The European Technology platforms have functioned as an important platform for primarily theindustrial actors, and they have been an important driving force to implement the Joint Technologyinitiatives. In the future Common Strategic Framework the focus on involvement of industry andSME’s will be rightly intensified and these platforms could help this development on the way.

16) How and what types of Small and Medium-sized Enterprises (SME) should be supported at EUlevel; how should this complement national and regional level schemes? What kind of measuresshould be taken to decisively facilitate the participation of SMEs in EU research and innovationprogrammes?As part of a growth-oriented agenda, both the Member States and the EU should focus on theoutput of the research and innovation funding. The new framework programme should ensure astronger link between research and innovation, with growth as the ultimate objective and greaterbusiness involvement. Research findings should be applied quickly within companies and publicsector institutions. In this quest both research producing and research acquiring SMEs areimportant participants when it comes to securing innovation, better knowledge transfer betweenscience and industry and commercialisation of the output.As SMEs operate within a short time frame it is often difficult for SMEs under the thematicprogrammes as they are forced to wait for a call that is appropriate for their project. In order toaddress this issue, the number of non-thematic, bottom-up driven funding opportunities aimed atSMEs should be increased significantly. Denmark therefore supports greater business involvementthrough more non-thematic funding and broader calls for applications.In the current Capacities Programme funding is granted to non-thematic, bottom-up driven projectproposals from SMEs through the Research for the Benefit of SMEs and Eurostars programmes.Denmark supports an increase in the amount of funding earmarked for these two programmes.Businesses, including SMEs in particular, generally operate with tight timeframes within narrowlydefined fields and in close proximity to the market. Participation in joint European research andinnovation projects should reflect this reality to a greater extent in order to increase theinvolvement of businesses in the framework programme. As a result instruments, rules andprocedures of the framework programme need to be simplified significantly and instead of viewingcontrol as the starting point, the coming framework programme should have a more trust basedapproach.In order to attract more SMEs to participate in the framework programme there is a need for athorough reduction of the administrative burdens imposed on applicants and participants in theframework programme. Ways to reduce the administrative burdens on applicants and participants

could be a step-by-step guides, templates and case descriptions for drafting applications as well asproviding a concrete overview of the process and requirements for all stages of an EU project1.Applied to the Framework Programme this type of information would make it easier for businessesto weigh costs and opportunities against each other leaving them with a clearer picture of their rolein a FP project. This will in turn encourage more SME to apply for the programmes making iteasier to attract high quality applications to the Framework Programme. See also the answer toquestion 1 for further details.Further steps should be taken to strengthen dissemination of research and innovation results fromEU funded projects. Research and innovation results could benefit many more companies –especially SMEs – than is the case today, primarily by accelerating the pace to which it is broughtto market. This could be done by integrating project partners with special responsibility to andexpertise in knowledge dissemination. The role as knowledge dissemination partner could be takenfor instance by the many European Research and Technology Organisations (RTOs) or by relevantcluster organisations.

17) How should open, light and fast implementation schemes (e.g. building on the current FETactions and CIP eco-innovation market replication projects) be designed to allow flexibleexploration and commercialisation of novel ideas, in particular by SMEs?Administrative burdens associated with the management and implementation of research andinnovation projects may keep European enterprises and in particular SMEs from applying forfunding. Denmark welcomes the Commission’s ambition of reducing administrative burdens forparticipants in research and innovation projects. It is of particular interest to speed-up the process tomake the CSF relevant in a globalised world with a still shorter time-to-market.Denmark considers eco-innovation to be an inspiring example of how the EU can best support latestage innovation activities to strengthen global competitiveness and meet grand societal challenges.Future EU funding for late stage innovation activities should consider the experiences gained withlate stage innovation funding in the field of eco-innovation as well as international experiences withlate stage innovation funding.

It is important to strengthen the effects of the existing instruments. Therefore it could berecommended to conduct a review of their effectiveness with a particular focus on simplification ofadministrative procedures and optimising value for money.In the next programming period both loan guarantees and equity investments should be prioritised.Furthermore proposals for a new European Venture scheme as envisioned by the European Councilconclusions of February 2011 should be considered carefully. Furthermore, potential futureinstruments should be anchored within the European Investment Fund to avoid institutionaloverlap. They should be based on a general market-based approach for the benefit of innovativeand high-growth SMEs and without selecting specific sector interests. This means that funds shouldbe invested through a market-based investor principle. EU financial instruments should increase thecost-effectiveness, simplify application procedures and focus on increasing growth and productivityby targeting SME’s with a growth potential. The long term goal of a self-sustaining market meansthat all financial measures should be temporary.

19) Should new approaches to supporting research and innovation be introduced, in particularthrough public procurement, including through rules on pre-commercial procurement, and/orinducement prizes?The modernization and simplification of the existing EU public procurement framework shouldprovide better, more efficient and cost effective procurement outcomes with more flexibility, lesspossible transaction costs and administrative burdens. This should be achieved through simple,flexible and efficient procedures that ensure a high degree of competition among suppliers and atthe same time allows for procurement of innovative goods and services where relevant.Denmark therefore generally supports increasing and improving the use of innovative public (pre-commercial) procurement andon a voluntary basisto use procurement budgets for pre-commercialprocurement which under the right circumstances can ensure that better, more cost-efficient andmore innovative products and services are procured.

20) How should intellectual property rules governing EU funding strike the right balance betweencompetitiveness aspects and the need for access to and dissemination of scientific results?Access to and dissemination of scientific results should be pursued to the largest possible extentwhen drawing up intellectual property rules governing EU funding. However, this should be donewithout preventing the possibility of patenting scientific results and provided that the legitimateinterests of all partners in the consortia are not adversely affected and in full respect of MemberStates’ national rules regarding intellectual property rights.See also the answer to question 1, underling that a reduction of the complexity of the existing ruleson intellectual property rights is necessary.

5) Strengthening Europe’s science base and the European research area21) How should the role of the European Research Council be strengthened in supporting worldclass excellence?Denmark places great importance on maintaining a strong and independent ERC in the futureCommon Strategic Framework. The ERC has proven to be a strong contribution to the promotionand stimulation of world class excellence within the European research communities. It is thereforevital that the role of the ERC is strengthened in the future CSF, which inevitably will enableEurope to further reinforce its science base. This can be done by increasing the ERC’s proportionof the Common Strategic Framework’s total budget. This would allow the ERC to increase thesuccess rates of the current Advance Grant and Starting Grant schemes to a level more equal toother comparable funding organisations. A larger budget for the ERC would also give the ERCenough funds to initiate new innovative support schemes, e.g. the Proof of Concept schemeintroduced in the ERC’s 2011 work programme.The status of excellence as the only ERC selection criterion must be maintained. This is vital toensuring that Europe continues to have researchers who are among the best in the world and thatEurope is able to retain the most talented researchers.Denmark supports the new ERC+ Grant scheme, which will be introduced in the 2012 workprogramme, giving small groups of Principal Investigators and their teams the possibility to bringtogether complementary skills, knowledge and resources in new ways, in order to jointly addressresearch problems. Denmark looks forward to seeing the demand and results of this new scheme,and if it is deemed a success, Denmark would strongly recommend that it becomes a permanentgrant scheme within the ERC portfolio.Finally, a strengthening of the ERC could be done by looking into ways and means of furtherconsolidating the independence of the ERC. This will have to depend on an evaluation of theeffects of the measures already implemented as a follow-up on the review of the ERC structuresand mechanisms published 23 July 2009.

22) How should EU support assist Member States in building up excellence?Denmark is of the opinion that excellence is a fundamental prerequisite for enabling Europe to facethe grand societal challenges and to reinforce Europe’s competitiveness. It is important that EUsupport underpins holistic approaches to both research and innovation food chains, i.e. “fromprimary school to Nobel prize winners” and “from ideas to market”. It is essential that the EUassists in building up excellent educational systems in order to educate the next generations ofresearchers and entrepreneurs. This could for instance be done through the Initial TrainingNetworks (ITN), which is one of the most important Marie Curie actions as it supports researchcareers at an early stage. The ITNs support young researchers’ access to established research teams,thereby improving their career options. The training of young researchers within transnationalenvironments is a key to boosting the level of excellence in Europe (EU12) and should therefore bestrengthened in the next framework programme. Additionally, new initiatives to support talentdevelopment and enhance the attractiveness of research careers in Europe could be explored.Moreover, a holistic approach to stimulate the food chain “from ideas to market” could besupported through better links between researchers and access to capital in order to ensure thatideas generated in course of research projects to a greater extent can be commercialised. At the

23) How should the role of Marie Curie Actions be strengthened in promoting researcher mobilityand developing attractive careers?Researcher mobility and training are crucial for creating world-class European researchenvironments. Researcher mobility within Europe must be strengthened and Europe needs to attractmore researchers from countries outside Europe. Many different employment structures and careerpaths across Europe pose significant barriers to researcher mobility in Europe. Strong Europeanmobility programmes are therefore vital.The status of the People Programme as a specific research programme in the next frameworkprogramme should be maintained to ensure continued focus on mobility. Furthermore, the freedomof research within the actions should be maintained to make them independent of various themes ina future framework programme.More funding for Initial Training NetworksThe Initial Training Networks (ITN) initiative is one of the most important Marie Curie Actions asit supports research careers at an early stage. The ITNs support young researcher’s access toestablished research teams, thereby improving their career options. The training of youngresearchers within transnational environments is key to boosting the level of excellence in Europe(EU12) and should therefore be strengthened in the next framework programme.The Marie Curie Actions should focus more on cooperation between the business community andpublic-sector research institutionsCooperation between the business community and the public sector research institutions should befurther increased via the Marie Curie Actions. The Marie Curie Actions should therefore be mademore visible to industry, which should be actively involved in the training of researchers, also witha view to improving career paths within and across sectors. This is a good example of how theknowledge triangle (research, education and innovation) can be further specified.Consideration should be given to making the European Industrial PhD pilot project permanentThere must be focus on all aspects of the knowledge triangle, especially education, in order tostrengthen entrepreneurship. The business community should be involved in defining the need foreducation and supporting researcher training. Denmark has many years of success with a nationalIndustrial PhD scheme in which businesses and universities join forces to plan and finance PhDprogrammes.It is vital for a European Industrial PhD scheme to maintain knowledge transfer from researchinstitutions to businesses as the main objective. Furthermore, it is important to ensure that aEuropean Industrial PhD scheme is complementary to existing national schemes. The current pilot

25) How should research infrastructures (including EU-wide e-Infrastructures) be supported at EUlevel?In order for the EU to continue to be able to attract and retain the most talented and the bestresearchers in the face of intensifying global competition, it is vital that the framework and facilitiesoffered are attractive. Investment in research infrastructures is therefore a central part of the effort toreinforce the future position of European research and strengthen the capacity building of theEuropean research environments.Experience from previous framework programmes and current collaborations in the area of researchinfrastructures in Europe demonstrates that a joint effort in this particular area can boost Europeanresearch and create genuine European added value.The financial crisis has presented a challenge in recent years to existing collaborations on Europeanresearch infrastructures and the ambitious targets for realising the European research infrastructuresthat have been prioritised by the European Strategy Forum on Research Infrastructures (ESFRI). Thisplaces high demands for a focused and prioritised effort in areas where the need and benefit aregreatest from a European perspective.The financial framework for research infrastructure should be expandedIn recognition of the importance of research infrastructures to the EU’s competitiveness, thedevelopment of the ERA and increased European cohesion, it is vital to expand the financialframework for the research infrastructures programme. The utilisation and development of researchinfrastructures must be given a higher priority in the framework programme than previously.Based on a general requirement for scientific excellence, better cohesion should be establishedbetween the framework programme and other sources of funding, such as the EU’s structural andcohesion funds. The development of distributed research infrastructures organised with nodes locatedin different countries as well as the enhanced use of e-Infrastructure within all scientific fields and IT-based remote accessing should be explored

26) How should international cooperation with non-EU countries be supported e.g. in terms ofpriority areas of strategic interest, instruments, reciprocity (including on IPR aspects) orcooperation with Member States?Denmark emphasises the importance of a strong international dimension of the European R&Ifunding programmes. Europe is dependent on strong links to the most advanced research andinnovation regions of the world and it also becomes more and more important to develop therelationships with emerging economies. The future Common Strategic Framework should thereforebe kept as open as possible for third country participation – keeping the EU funding programmesthe most open in the world.Furthermore, Europe should put more efforts into utilising S&T collaboration with third countries.A strong focus on scale and scope should encompass these efforts. By doing so, Europe will gain astronger position in negotiating S&T collaboration agreements with countries outside the EU,including IPR issues, aspects of reciprocity and access to markets. This can be achieved in severalways. First, Europe should develop better methods of coordinating Member States and EU actionswith and in third countries. Secondly, there should be stronger agreement between the EU and itsMember States on which areas of common strategic interest focus should be given vis-à-vis thirdcountries – reflecting what areas of and with whom S&T collaboration should be prioritized.Thirdly, the instruments that are applied should be supporting the identified focus areas. Fourthly,funds at EU and national level for international cooperation should be coordinated better in order toreach critical mass.The above suggestions could be developed within the Strategic Forum on International S&TCooperation (SFIC) and could all be incorporated into an overall European strategy on internationalS&T cooperation.

27) Which key issues and obstacles concerning the ERA should EU funding instruments seek toovercome, and which should be addressed by other (e.g. legislative) measures?Successful coordination and integration of research funding in the EU is closely linked to thefacilitation of cooperation and operation of research actors across Member State borders. Despite aclear need for cooperation and cross-border operation of research actors, hurdles exist at three levels;Firstly,the political level,hereunder the need for political will to pool national resources into jointEuropean initiatives; Secondly,the structural level,hereunder the incompatibility between nationalresearch and innovation systems, and resistance of Member States to commit to teaming up resourcesinto "joint" schemes; thirdlyThe managerial/organisational level,hereunder an absence of a set ofcommon definitions and principles between the EU and Member States, which would allow bettercooperation among the various national actors for the design, selection and implementation of cross-border projects and programmes.