TA CR´s comments on the first draft of the Framework for state aid for research and development and innovation
Technology agency of the Czech republic (hereinafter referred to as “TA CR”) welcomes the publication of the first draft of the Framework
for state aid for research and development and innovation (hereinafter referred to as “the Framework") and considers that the new concept
will allow better application of the Framework to all providers of state aid.
TA CR apply the following comments.
Comment
No.
Nature of the comment
Comment rationale
1.
We strongly suggest improve the consistency of In the current version, some terms are
definitions with those in the GBER. The definitions defined differently in the first draft of the
should be consistent with the final version of the GBER. Framework than in the latest version of
the GBER.
2.
Article 2.1.1., paragraph 20 - we propose to increase We propose to increase this limit to
threshold from 15 to 20% of the research organisation 20 %*, as we are of the opinion that
or research infrastructure´s overall annual budget.
such small increase in the volume of
economic activities shall not distort the
We would like to propose the alignment of threshold market environment in undue way
basis between second GBER draft and the draft because:
Framework as well (capacity-based vs. budget-based (i) supported infrastructures must allow
thresholds).
at least the possibility of open and
transparent access to infrastructure’s
capacities
(ii) most of the supported infrastructures
(at least in the Czech Republic) will be
Settlement
operated by research organizations
established under the public law, and as
such their orientation on customer
friendly service is generally at a lower
level than is generally attributed to
undertakings.
(iii) if the higher limit will be in fact used
in full, it should be considered as a sort
of enabler for European undertakings to
compete on global markets (because
the open access will be dominantly
used by EU based undertakings), than
causing an undue distortion of the
internal market through increased
innovation
We would also like to propose the
revision of the basis for the percentage
threshold to be in line with the threshold
proposed in the second GBER draft –
i.e. infrastructure capacity, instead of
some sort of infrastructure / institution
budget as the budget is unpredictably
fluctuating
basis
between
years
(especially for public institutions, as its
budgets could be influenced even for
purely political reasons).
3.
Article 2.1., paragraph 19 (b),
we suggest to change formulation:
„...where all income of those activities is reinvested...“
to:
Due to the fact that "technology
transfer" is a non-economic activity, the
request of the reinvestment of all
"income" does not make sense.
„...where all profit of those activities is reinvested...“.
Under these circumstances, it would
have been any activity of "technology
transfer" suppressed for research
organizations, because it could not be
maintained and further developed.
The requirement to reinvest profits is in
our opinion sufficient and consistent
with the existing rules and practices.
4.
We suggest to precise a definition of “Applied We propose to precise the definition of
research”.
“applied research” in such a way, as to
better include the applied research in
the social and economic sciences, as
the societal challenges play important
role even in Horizon 2020.
The current definition included in the
draft Framework, accents more the
“industrial / technological” than societal
challenges, and therefore it could lead
to improper application.
Prague, 10 February 2014
RNDr. Martin Bunček, Ph.D.