Consultation on new policy directions for the Big Lottery Fund: distribution of National Lottery money in England and UK-wide funding programmes

08 August 2016

Summary

We welcome the proposed Directions and this consultation on them. We suggest some changes below, particularly so the proposed Directions better ensure the expertise of both the sector and the people who work at the Fund itself are best utilised, and to ensure the learning and strategic outlook of the funding portfolio is supported. We also highlight the importance of the Fund remaining in its unique position of being independent from government; the necessity of it continuing to Fund international as well as UK-wide work; the importance of ensuring that the monies available are spread across the whole of the UK; and the need to ensure the UK-wide Fund does not grow at the expense of the nations’ Funds. As we outlined in our response to the Big Lottery Fund's 2014 consultation, the Big Lottery Fund must continue to make a difference in this challenging environment for the sector. Therefore, we respond to this UK Government consultation on the proposed Directions for the UK-wide funding portfolio with the aim of seeing the Big Lottery Fund:

• help our sector adapt to austerity and rising demand;
• focus on supporting the sector build on its role in preventative outcomes and early intervention;
• work with our sector strategically to help it improve, learn and strengthen its capacity and infrastructure;
• support our sector to increase digital participation with the people our sector works with – making this a part of the funding package for all organisations funded;
• share learning, data and knowledge across the UK.

Our response

SCVO welcomes the opportunity to respond to this consultation and would like to contribute the following:

Introduction

SCVO, Scotland's largest umbrella body and membership organisation for the third sector in Scotland, knows that the Big Lottery's UK Funding Portfolio is an excellent funder of UK-wide initiatives, and we believe this consultation from the UK Government is a timely and welcome development to seek a broader input into the future Directions of the Big Lottery Fund. Spending £4bn between 2015 and 2021, roughly equivalent to £400m in Scotland, is a considerable investment in good causes. However, much more important than the quantity available, is the unique nature of the Big Lottery Fund. It is not statutory in the same way as government funding as it doesn’t distribute taxpayer money, yet is overseen as a non-departmental public body. This unique combination gives the Big Lottery a number of strengths in comparison to other funding programmes. In particular, as it doesn’t need to prove short-term success, it can aim to fund longer term outcomes beyond immediate policy objectives tied to specific Government departments. It can also form more open, creative and responsive programmes right across the UK which allow an investment in new unanticipated solutions to addressing social problems. The Big Lottery’s independent board gives it the freedom to take risks and invest in ideas for ‘proof of concept’ so they can be tested. This independence and ability to do what others do not must be protected. Finally, its unique international strand allows UK insights to be shared internationally whilst also benefiting practitioners here in the UK through cross-learning and collaboration. All of these positive elements of the Big Lottery should be reflected in the new Directions set by UK Government.

Comments on specific Directions

Below we comment on the draft Directions as outlined in the consultation document. We go through them in numerical order, combining positive comments and points of concern under each proposed Direction, rather than responding to the broad questions put forward in the consultation response form. As a Scottish organisation, we focus on Directions 1(A to C) and 2(A to E).

Section 1A

Bullet point 1. As discussed in the following section under 1C: local engagement, we recommend a broader definition of involving local communities, highlighting the need for support work to be undertaken with those communities who maybe don't in the first instance have the capacity to engage with the Fund. Bullet point 3. We are surprised at the inclusion of bullet point 3(a). There may be some circumstances that arise where projects may not be for a time-limited purpose, and that require some flexibility in that regard; we know the various staff and Board members of the Fund to be competent in assessing occasions when this need arises and responding effectively; ditto 3(b). Therefore, we would remove these two bullet points, as we believe in the competence of staff and Board members to be able to make decisions on these on a case-by-case basis. In terms of financial viability (bullet point 3(c)), we believe that whilst financial viability is indeed desirable and should be a long-term aim of all projects, being unable to show this at the start of the project should not necessarily preclude applicants from being successful. Therefore, we recommend a degree of flexibility is included in this stipulation. Bullet point 4. Whilst a clear business plan for requests for capital funding is sensible for larger projects, in some instances it will not be practical without strong support from Fund staff; the need for this should be highlighted here. Moreover, in other projects, where only a small amount of capital funding is sought, or where capital funding forms only a small part of an application for funding, this requirement perhaps should not be included at all. Furthermore, it is also perfectly possible that running and maintenance costs will not be known in the first instance. Therefore, flexibility around this stipulation should be included. Bullet point 5. This objective seems out of place amongst the others that focus on the process of applying for and distributing the funds, and may quickly become an out-of-date priority. See discussion below on the necessity of these Directions remaining relevant over time. We would suggest it therefore fits in better in section B, alongside the other 'desirable' elements.

What's missing from section 1A?

We note that environmental sustainability (where appropriate for projects) is not included in these proposed Directions; environmental sustainability is, however, in the current set of Directions. Given the necessity for us to move towards sustainability in all walks of life, we believe that a Direction on the environmental sustainability of projects where appropriate, should be included here or in section 1C. Furthermore, there is an important opportunity for the Big Lottery to help increase digital participation. All applicants for Big Lottery funding should be supported (financially) to enable access, develop skills and motivate the people they work with to overcome the digital divide. Evidence has shown that people who do not have basic online skills need significant amounts of support to get online and that the most effective way is through the support of trusted individuals who know what the hooks or motivations are for an individual. Community and voluntary organisations already providing support for their clients are in the perfect position to make this happen, and, given the importance of this agenda for many years to come, we do think it should be included within the new Directions laid down by Ministers, either in this section or in section 1C.

Section 1B

As these are desirable Directions rather than imperatives, we are broadly content with their outline. However, we feel it is essential that the Big Lottery Fund has a focus on supporting preventative outcomes, through ‘upstream’ interventions. This is one of the most important contributions to society that community and voluntary organisations already make, and we feel that it should be included in the new Directions as a broad focus, perhaps in this section alongside the other, more policy-focussed elements.

Section 1C

Variety and innovation: we notice the continued use of the word 'primarily' when outlining that the receipt of funds should go to civil society organisations. We remain concerned that the Fund can provide resources to local government and statutory bodies, and continue to believe that the public would expect all Big Lottery good cause money to go through community or voluntary organisations. Therefore, we would like to see the word 'primarily' removed from this proposed Direction. We would also like to see a clear definition for civil society organisations, akin to the list of organisations given in the current set of Directions, so that it is clear who qualifies for Lottery funds. Furthermore, it is essential that the Scottish Charitable Incorporated Organisation, or SCIO, which is a legal form unique to Scottish charities, is recognised in any explicit civil society definition. Local engagement: we think it's essential to also stress that engagement itself is not enough. As in the current Directions, we would like to see the proposed Directions emphasise the need to work with local communities to improve their capability to engage with the Fund and to remove any barriers which are preventing them to do so (for example, a lack of digital ability, or a limited knowledge of filling out grant applications). This will ensure that the Fund continues to be supported to ensure that all communities are able to benefit from it. This point also is relevant to point 1A1. Long term benefit: we note the change from looking purely at financial viability to some more policy-specific aims. Whilst we recognise the importance of those stated aims, we feel that is more appropriate for these high-level principles to focus instead on the process of distributing the funds and how the Fund should operate rather than highlighting specific policy areas for focus. Keeping away from imperative, specific policy aims will enable the Fund to remain agile in a fast-changing policy environment, whilst also ensuring a fit with the work of the devolved nations. We would therefore in this section prefer a return to the focus on longer term financial viability and resilience where appropriate, whilst also paying attention to environmental sustainability where relevant. Outcomes and impact: we would like to see the additional comment that funds be distributed on need; again, this appears in the current Directions and we would like to see it retained. Additionality and complementarity: we suggest that the word 'government' is replaced with 'other funders and parties' in order to ensure as little unintended duplication as possible, and to continue clarity that it is not the place of the Big Lottery Fund to fund initiatives that government sees as helpful but is unwilling to fund directly.

Section 2

Point A: In addition, we would stress the need to attempt to distribute the funds as evenly as possible, taking into account the variation in applications received UK-wide. It is not enough to ensure that all areas of the UK have the potential to access the money distributed (it is perhaps that the former is the intention of the sentence, in which case it would perhaps benefit from rephrasing). Rather, funds should be spent across the whole of the UK in all nations. Furthermore, it is essential that any growth in the UK-wide Fund does not come at the expense of Funds to individual nations. Points B – E: Points B and C are sentiments that we fully support, alongside E. Point D we would perhaps change slightly: we feel that the UK-wide funding should also have a specific strategic focus to invest in third sector improvement across the UK; this could be added to point D's focus on learning, growing and bringing people and communities together (although we would indicate here that we are not exactly sure what is meant by 'growing'). We would add here just how strongly we support the international element of the Fund. This is unique, and allows excellent learning to take place across borders in a way that benefits organisations and communities UK-wide. We therefore strongly believe this element of the Fund should be retained.

Conclusion

What kind of funder can these Directions support the Big Lottery Fund to be?

The Big Lottery Fund is an excellent body. It continues to be well positioned to provide support to projects which would otherwise be unable to secure funding. This includes:

• capacity and adaptation funding for the sector’s networks and its infrastructure;
• proof of concept funding, and breaking new ground;
• helping the sector spread data, evidence and ideas on what works.

By building on its strengths, we believe the new Directions – with changes made as suggested above – will support the Big Lottery Fund to continue to be indispensable in supporting our sector to support the people and communities it works with.

Contact

Jenny Bloomfield Policy Officer Scottish Council for Voluntary Organisations, Mansfield Traquair Centre, 15 Mansfield Place, Edinburgh EH3 6BB Email: jenny.bloomfield@scvo.scot Tel: 0131 474 8001

About us

The Scottish Council for Voluntary Organisations (SCVO) is the national body representing the third sector. There are over 45,000 voluntary organisations in Scotland involving around 138,000 paid staff and approximately 1.3 million volunteers. The sector manages an income of £4.9 billion. SCVO works in partnership with the third sector in Scotland to advance our shared values and interests. We have over 1,600 members who range from individuals and grassroots groups, to Scotland-wide organisations and intermediary bodies. As the only inclusive representative umbrella organisation for the sector SCVO:

• has the largest Scotland-wide membership from the sector – our 1,600 members include charities, community groups, social enterprises and voluntary organisations of all shapes and sizes
• our governance and membership structures are democratic and accountable - with an elected board and policy committee from the sector, we are managed by the sector, for the sector
• brings together organisations and networks connecting across the whole of Scotland
• SCVO works to support people to take voluntary action to help themselves and others, and to bring about social change.