[L. n. 135 del 2012] Convertito il decreto-legge sulla cd. spending review. Aggiornamenti su funzioni fondamentali dei comuni ed esercizio associato di funzioni e servizi

Il decreto-legge sulla cd. spending review è stato convertito, con modifiche, nella legge 7 agosto 2012, n. 135. In merito ad alcune disposizioni delle quali si era già dato conto in questo sito, si deve osservare che le modifiche sono state minime: ciò sia per l’art. 19, in tema di funzioni fondamentali dei comuni ed esercizio associato di funzioni e servizi comunali; sia per l’art. 20, in tema di incentivi per la fusione di comuni e la razionalizzazione dell’esercizio delle funzioni comunali.

1. La novità di maggior rilievo riguarda l’art. 19 e il programma, ivi previsto, di costituzione delle forme associative mediante le quali i comuni fino a 5000 abitanti devono esercitare le funzioni fondamentali. La tempistica è invariata: tre funzioni fondamentali devono essere esercitate in forma associata entro il 1° gennaio 2013; le altre entro il 1° gennaio 2014 (così il novellato art. 14, comma 31-ter, del d.l. n. 78 del 2010). La novità è che, secondo l’attuale previsione, «[i]n caso di decorso dei termini di cui al comma 31-ter, il prefetto assegna agli enti inadempienti un termine perentorio entro il quale provvedere. Decorso inutilmente detto termine, trova applicazione l’articolo 8 della legge 5 giugno 2003, n. 131»  – vale a dire, la norma generale in tema di poteri sostitutivi dello Stato.

Altre modifiche sembrano di minore rilievo, prevalentemente formali o di coordinamento:

– si è precisato che le funzioni comunali in tema di edilizia scolastica sussistono solo «per la parte non attribuita alla competenza delle province»;

– si è specificato che le unioni speciali tra comuni fino a 1000 abitanti (ai sensi del novellato art. 16 del d.l. n. 138 del 2011) assumono tutte le funzioni e tutti i servizi pubblici degli enti di base e «inoltre» – nell’aggiunta di questo avverbio consiste la modifica – con riferimento a tali funzioni, assumono anche le competenze di programmazione economico-finanziaria e gestione contabile, nonché la potestà impositiva (sui tributi comunali) e patrimoniale;

– si è chiarito un riferimento normativo interno all’art. 20.

Le modifiche sono essenzialmente frutto dell’attività della Commissione Bilancio del Senato. Infatti, non solo il Governo è stato vigile e severo anche in questa fase; ma, nelle successive, com’è ormai tristemente consueto, ha irrigidito i lavori parlamentari con un doppio emendamento interamente sostitutivo, blindato con la fiducia (tra l’altro, in questo modo il DDL di conversione ha assorbito contenuti del d.l. n. 87 del 2012).

2. Oltre agli esiti, meritano attenzione alcuni passaggi dei lavori parlamentari.

Ad es., pur con le note riserve quanto all’uso dei lavori parlamentari come criteri di interpretazione, è degno di nota come, tra gli emendamenti all’art. 19 presentati presso la Commissione Bilancio del Senato, ve ne fosse uno (emendamento 19.4) orientato ad ampliare le funzioni fondamentali e a includervi, tra l’altro, il «coordinamento delle attività commerciali», la «gestione dell’ambiente», la «costruzione, gestione e manutenzione delle strade comunali», nonché la «gestione dei beni e dei servizi culturali». L’emendamento, sottoscritto da numerosi senatori, è stato inizialmente accantonato – presumibilmente, perché la sua approvazione sembrava possibile e meritevole di approfondimento – ma poi ritirato. È lecito dedurne che si è voluto espungere queste funzioni da quelle per cui non solo è obbligatorio l’esercizio associato, ma è anche prevista una perequazione basata sulla copertura integrale del fabbisogno secondo costi standard, ai sensi della legge n. 42 del 2009 e dei decreti attuativi (d.lgs. n. 216 del 2010; d.lgs. n. 23 del 2011, sp. art. 13)?

Comunque – e anche questo è degno di nota – pare ormai chiaro che la nuova definizione delle funzioni fondamentali è destinata a incidere sull’edificio in costruzione del cd. federalismo fiscale municipale. Lo ha rilevato il Servizio Studi della Camera, nelle schede conoscitive predisposte per l’esame dell’art. 19. Riprendendo tali rilievi, uno degli ordini del giorno presentati alla Camera (9/5389/103, Causi) impegna appunto il Governo a «valutare l’opportunità, nel rispetto degli equilibri di finanza pubblica, di garantire, se necessario con appositi atti, che sia portato a compimento il primo ciclo di calcolo dei fabbisogni standard degli enti locali, attualmente in avanzata fase di elaborazione sulla base di quanto stabilito dal decreto legislativo n. 216 del 2010, a partire dalla classificazione provvisoria delle funzioni fondamentali recata dalla legge n. 42 del 2009, così evitando che la diversa classificazione introdotta dal [d.l. n. 95 del 2012], la quale dovrà essere utilizzata a partire dal secondo ciclo, possa avere l’effetto indesiderato di interrompere l’esercizio statistico e conoscitivo in corso».

3. I dibattiti parlamentari hanno poi messo a fuoco alcuni problemi in merito ai consorzi socio-assistenziali tra comuni – tema travagliato anche negli anni scorsi, come pure in questa sede si è notato.

Interessano, in particolare, gli ordini del giorno, presentati alla Camera, 9/5389/110 (Bobba, Calgaro, Osvaldo Napoli) e 9/5389/108 (Fiorio, Lovelli). Gli atti di indirizzo sottolineano come questi consorzi siano uno strumento assai diffuso di gestione dei servizi sociali da parte dei piccoli comuni: «nelle realtà più piccole l’assistenza socio-assistenziale è spesso delegata a consorzi fra comuni, comunità montane, ASL o convenzioni fra Comuni, dando vita ad una rete di solidarietà che spesso identifica lo stesso territorio» (ODG Bobba).

In passato ci si era chiesti se tali organismi fossero da annoverare tra i consorzi di funzioni, dei quali era obbligatoria la soppressione ai sensi della legge finanziaria 2010 (si rinvia alla segnalazione cit. sopra di Corrado D’Andrea). Il tema è stato oggetto di dibattiti giurisprudenziali. In seguito, elementi a favore della sopravvivenza di organismi simili sono venuti dalla stessa legislazione, che, ad es., li ha esentati dal patto di stabilità: come ricorda l’ODG Fiorio, «l’articolo 25, comma 2, lettera a), della legge 24 marzo 2012 n. 27 di conversione, con modificazioni, del decreto-legge 24 gennaio 2012, n. 1 (…) ha disposto che dall’anno 2013, le aziende speciali e le istituzioni siano assoggettate al patto di stabilità interno, ma ha espressamente escluso da tale prescrizione le “aziende speciali e istituzioni che gestiscono servizi socio-assistenziali ed educativi, culturali e farmacie”».

Ora, sulla materia irrompe il d.l. n. 95, con disposizioni variegate e, almeno a prima lettura, non perfettamente raccordate:

– l’art. 9, al comma 1, prescrive a regioni, comuni e province, la soppressione, l’accorpamento o la riduzione degli oneri finanziari per enti, agenzie e organismi di qualsiasi natura giuridica a essi riconducibili; ma subito dopo, al comma 1-bis, esclude dall’applicazione di tali disposizioni aziende speciali, istituzioni ed enti che gestiscono servizi socio-assistenziali, educativi e culturali;

– tuttavia, lo stesso art. 9, al comma 6, vieta agli enti locali di istituire enti, agenzie e organismi comunque denominati, di qualsiasi natura giuridica, per l’esercizio di funzioni fondamentali o funzioni amministrative loro conferite ai sensi dell’art. 118 Cost.;

– infine, l’art. 19 include le funzioni assistenziali tra quelle fondamentali, per le quali è prescritto l’esercizio obbligatorio mediante convenzione, unione ai sensi dell’art. 32 TUEL, o unione speciale ai sensi dell’art. 16 del d.l. n. 138 del 2011 – e non mediante organismi diversi.

Considerato ciò, i due ODG citt. impegnano il Governo, rispettivamente, «nel rispetto degli equilibri di finanza pubblica, a considerare i consorzi socio-assistenziali tra gli enti fatti salvi dal comma 1-bis dell’articolo 9 (…), così come già indicato dall’ODG G/3396/39/5 allo stesso decreto, approvato presso la commissione Bilancio del Senato; a promuovere un riordino complessivo dell’attuale disciplina che regola le politiche sociali attraverso finanziamenti adeguati e strutturali, che permettano l’erogazione di servizi più efficienti ed equamente distribuiti sul territorio, sempre di competenza dei consorzi socio-assistenziali, quale punto di riferimento per i cittadini» (ODG Bobba); nonché «a valutare, nel rispetto degli equilibri di finanza pubblica, gli effetti applicativi delle disposizioni richiamate (…) allo scopo di prevedere espressa esclusione delle aziende speciali e delle istituzioni che gestiscono servizi socio-assistenziali, educativi e culturali anche dall’applicazione del comma 6 dell’articolo 9 del decreto in esame» (ODG Fiorio).

In effetti, le disposizioni citate sopra se, da un lato, confermano la legittima sopravvivenza – sino ad ora – degli organismi cui si riferiscono, dall’altro, però, potrebbero aprire la via a una loro radicale riorganizzazione. Infatti, come si è detto, per i comuni fino a 5000 abitanti, le forme di cooperazione ammesse dal d.l. n. 95 del 2012 sono tassative: unione e convenzione. Ma ci sono altri vincoli: applicabili a tutti i comuni, a prescindere dalla dimensione. Es. è tuttora in vigore la norma (art. 14, comma 29, d.l. n. 78 del 2010) secondo cui «[l]a medesima funzione non può essere svolta da più di una forma associativa»; quindi, un’unione, titolare di funzioni socio-assistenziali, non può aderire a un consorzio per lo svolgimento delle stesse funzioni. Inoltre, mentre non ci sono limiti al numero di funzioni che si possono attribuire alle unioni, ciascun comune può partecipare a uno solo di tali organismi, benché questi possano poi stipulare convenzioni tra loro e con i comuni (art. 32, comma 2, TUEL, nel testo novellato dal d.l. n. 95 del 2012).

In breve, la legislazione statale sembra attendersi un riesame dell’assetto degli organismi esistenti di cooperazione intercomunale cui partecipino piccoli comuni, che raggiunga la massima semplificazione istituzionale. A tutta prima, la spinta pare essere anzitutto verso unioni con un ampio ventaglio di funzioni; poi, verso convenzioni, per misurare l’efficienza delle quali sono predisposti appositi strumenti di controllo (si rinvia al commento all’art. 19 originario, cit. all’inizio).

4. In realtà, più ancora del d.l. n. 78 del 2010 e del d.l. n. 138 del 2011, il d.l. n. 95 del 2012 sembra voler stimolare una revisione della geografia funzionale locale che sia ampia e organica, non limitata ai piccoli comuni.

Infatti, alle regioni, previa concertazione con i comuni attraverso i CAL, è demandato il compito di individuare, nelle materie di cui all’art. 117, commi terzo e quarto Cost., la «dimensione territoriale ottimale e omogenea per area geografica» per lo svolgimento, in forma obbligatoriamente associata, da parte dei comuni delle funzioni fondamentali. Così dispone l’art. 19, comma 1, lettera d), del d.l. n. 95 del 2012, convertito senza modificazioni, che novella l’art. 14, comma 30, del d.l. n. 78 del 2010. E dal nuovo testo del comma 30 è sparita l’esenzione dei comuni capoluogo di provincia, e di quelli con oltre 100000 abitanti, dall’obbligo di esercizio associato che eventualmente scaturisca dalle descritte decisioni regionali.

A prima lettura, dietro questo blocco di legislazione statale pare di scorgere una certa interpretazione delle competenze costituzionali rilevanti, che qui si può iniziare a descrivere come mera ipotesi di lavoro:

– ai sensi dell’art. 117, comma secondo, lettera p), Cost., la legge statale individua le funzioni fondamentali e identifica gli enti il cui profilo istituzionale richiede, di per sé solo, l’esercizio associato di queste funzioni;

– nelle materie di cui all’art. 117, commi terzo e quarto, Cost., la legge regionale – come fonte sostanziale regolatrice delle funzioni, anche fondamentali, ricadenti in tali settori – garantisce che l’obbligo di esercizio associato sia conforme ai precetti emanati dallo Stato ai sensi dell’art. 117, comma secondo, lettera p), Cost.; ed eventualmente estende ulteriormente lo stesso obbligo, quando ciò sia opportuno per le caratteristiche della funzione o del territorio;

– la legge statale non può disciplinare l’ordinamento degli organismi associativi, ma può dettare norme orientate ad assicurare il contenimento delle spese all’interno di questi organismi, esercitando la competenza di coordinamento finanziario (art. 117, comma terzo, e art. 119, comma secondo, Cost.). I confini di questa competenza possono essere controversi, così come la riconducibilità a essa di singole disposizioni; ma certo nei suoi confronti la Corte costituzionale si è mostrata, anche di recente, comprensiva (es. sent. 151 del 2012: la gratuità delle cariche amministrative in organismi associativi locali si qualifica come principio di coordinamento finanziario in virtù del puro e semplice fatto di costituire una scelta di fondo della relativa disciplina di settore; senza che rilevino in contrario il carattere permanente del vincolo, la specificità del settore e delle voci di spesa considerate, la sostanziale inesistenza di margini di discrezionalità attuativa per gli enti territoriali).

Michele Massa

Foto | Flickr.it

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57 risposte a [L. n. 135 del 2012] Convertito il decreto-legge sulla cd. spending review. Aggiornamenti su funzioni fondamentali dei comuni ed esercizio associato di funzioni e servizi

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