Alcuni problemi di costituzionalità sulla possibile articolazione in più comuni del comune capoluogo all’interno della città metropolitana

Sulla possibilità prevista dall’art. 18, comma 2 bis, della legge n. 135/2012 (di conversione del decreto-legge sulla spending review), ossia che lo Statuto della Città metropolitana possa contemplare l’articolazione del Comune capoluogo in più Comuni, si pongono, a mio avviso, alcuni problemi di costituzionalità sui quali è doveroso soffermarsi.

Dalla lettura dell’art. 18, comma 2 bis, pare che l’istituzione di più Comuni, quali articolazioni del Comune capoluogo, sia rimessa alla scelta dello Statuto.

La Costituzione, però, in materia, stabilisce che l’istituzione di nuove realtà comunali è rimessa a una legge-provvedimento regionale (art. 133, comma 2, Cost.), indipendentemente dal fatto che ci si trovi in presenza o meno di una Città metropolitana.

Nel testo della legge di conversione del decreto sulla spending review, invece, alla Regione è affidato solo il compito di revisione delle circoscrizioni territoriali dei Comuni che fanno parte della Città metropolitana, e non anche la loro istituzione. Ipotesi che, nel Testo costituzionale, sono considerate distinte ed entrambe affidate alla competenza legislativa del Consiglio regionale. Inoltre, nell’evenienza di più articolazioni territoriali, l’art. 18, comma 2 bis, prevede, previo parere della Regione, l’indizione di un referendum tra tutti i cittadini della Città metropolitana, volto ad esprimere il loro punto di vista in merito alla nuova configurazione territoriale. Referendum che, secondo la normativa statale, sembra perdere quel carattere consultivo che gli attribuisce la Carta costituzionale, poiché, precisa sempre l’art. 18, “in conformità al suo esito (se positivo), le Regioni provvedono con proprie leggi alla revisione delle circoscrizioni territoriali dei Comuni che fanno parte della Città metropolitana”.

Sul punto, tuttavia, si ritiene che l’esito del referendum non vincoli il legislatore regionale il quale deve rimanere libero di adeguarsi o meno alla volontà delle popolazioni interessate, pena il venir meno della sfera di autonomia della Regione nella determinazione del proprio indirizzo politico.

Infine, la previsione di un quorum di validità della consultazione, a seconda che il parere regionale sia favorevole o contrario, non è un ambito sul quale può intervenire il legislatore statale, trattandosi di un settore di esclusiva competenza della Regione a meno che, come ha precisato la Corte costituzionale, non manchi una puntuale disciplina regionale in materia.

Daniele Trabucco

Foto | Flickr.it

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