European Structural and Investment Funds – second stage consultation 2014

Implications of the current proposals

• The current governance arrangements for the European Structural and Investment Funds (ESIF) are of great concern. Representation on the Programme Monitoring Committee (PMC) and subsequent decision-making structures should not only reflect a better balance between the public sector and social partners but should also enable genuine democratic participation in its functioning.
• The proposed strategic interventions lack vision in their scope and do not sufficiently address the critical challenges facing Scotland. ESIF cannot operate in isolation. They are out of step with current strategies on the state of the economy and the role and contribution of public services.
• The European Commission have explicitly told UK governments that they must do more to address youth unemployment and combat poverty, yet the proposals are dismissive of key third sector public services and interventions that directly address them.
• We strongly challenge the unsupported, evidence-free assertion that top down, big projects are necessary to minimise risk and that small projects are inefficient
• It is essential that the third sector have equal access to the Technical Assistance money available to Scotland in order to influence strategy, to support and improve the quality of proposals and project delivery, and to ensure that relevant and useful information and advice is provided to participating third sector organisations.
• The third sector’s experience of working with Community Planning Partnerships (CPPs) has largely not been good, as was evidenced in the SCVO report The role of the Third sector in ESIF in Scotland. The CPPs are inconsistent, not representative and often a poor example of community involvement. In some places they do not even exist or function. It is of great concern that the current proposals believe that CPPs = community led local development (CLLD).
• Combating poverty is a fundamental aim of the new programme and is a growing problem in Scotland and across the EU. If we are serious about reducing poverty, then all projects must demonstrate and prove how they are contributing to reducing poverty. All projects across all funds must have measures and indicators to reduce poverty.
• The consultation makes the following sweeping statement, again without supporting evidence:“Community Jobs Scotland, graduate recruitment, various initiatives aimed at development and capacity building in social enterprise and the third sector, domestic energy efficiency and advice and promoting cultural heritage all deemed lacking in strategic fit with EU 2020 and domestic funding and did not represent value for money”. This statement is of grave concern and its consequences will cause a large portion of vital public services delivered by the third sector to collapse.

• Third sector employability services have an excellent record and their unique and dynamic approaches are hailed across Europe as the most effective solution to unemployment and growing poverty in our communities. Yet there is no place for them to play a leading role in the current proposals. This must be corrected.
• Integration of the Funds is in principle a good idea but the current proposals are not clear on how this will work in practice. There is great concern that applicants, lead agencies and all beneficiaries will be subjected to inconsistent application and contracting processes, inconsistent appraisal and monitoring processes, and different interpretation of rules.
• As we approach the final weeks of activity within the current programme, existing projects will begin to come to a close. A range of activity currently supported through the current programme provides essential on-going services supporting and developing some of the most challenging client groups. Organisational capacity, breadth of knowledge and experience are all essential elements in the success of the ESF and ERDF programmes to date.The risks associated with loss of key experience and knowledge following a gap in available finance can have a significant impact on the effectiveness of the support provided. These risks can be particularly acute in remote and rural areas where replacing extensive knowledge and skill sets quickly can be challenging. Action to address these risks could have a positive impact on the early success of the new programmes and their ability to deliver effectively during their early stages. Transition funding is essential until all the issues and processes are sorted out.
• Health inequalities are not addressed in the current proposals. There are significant and long-standing health inequalities in Scotland, and public spending should be used more effectively to address these challenges. Poverty is the key determinant of health inequality and this resource should be used to make a significant impact.
• How the finances will work is central to the equal participation of the third sector. The new programme must implement the recommendations of the SCVO report on “How to simplify administration and ensure maximum cost recovery in European funding”.

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