It is not a full consultation but it offers a further chance to comment before the Partnership Agreement and Operational Programmes (I talked about them last time) are submitted to the European Commission.

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SCVO has produced a briefing on the consultation. Read it here.

For once it is quite an easy read and even if you don’t like some of the content it is less vague and opaque than it normally is. The Government has accompanied the consultation with its own blog, which gives a good overview of the issues.

I will let you read it for yourself but there are one or two areas that I am going to think about a bit more and I would like you to do the same.

Firstly there is much talk of lessons learned and what the problems are in the current programme. We would all be in agreement with the administration burden, the inconsistent interpretation of audit compliance and the constant wrestling with risk-averse civil servants to get money out the door to the people who need it. So yes, a solution to all this is much needed, but especially for small organisations.

But the answer is not to stop funding small organisations and small projects. The update suggests that small organisations and small projects produced fragmented outputs and limited impact. I would wave a health warning at that assumption.

Small projects and organisations will be the key to economic recovery and combating poverty in some communities.

Small projects and organisations will be the key to economic recovery and combating poverty in some communities. Perhaps it was the lack of policy ownership in the current programme that resulted in it not being strategic. I will let you think about that.

Then there is the area of horizontal themes that gets a mention but nobody really knows what to do with them. I am very interested in the relationship between the horizontal theme of equalities and the growing inequality in our society. We are witnessing a (slow) economic recovery that is exacerbating poverty and increasing income and health inequality. The European Commission and the European Parliament are clear that we must have growth and social cohesion. I mentioned that last time too. So why in this current state do we have equality as a horizontal theme but not as a clear investment priority that has policy ownership? Where is the relationship with Scotland’s National Action Plan that my colleague Matt Tyrer told us about last week on Human Rights Day?

What I do know is that the capacity of some beneficiaries to be involved in structural funds is a real issue. We hope our sector’s interests will be represented in the Programme Monitoring and Advisory Committee (PMAC) for Scotland and it is not just the one seat. We have been involved in the Strategic Delivery Partnerships (SDPs) but if they are to have day-to-day roles in monitoring progress how will our sector fund this level of participation? Government and public agencies can fund themselves.

The decline of these funds being accessed by the third sector is noted in our own report to the Scottish Government and it is of no surprise that some of the most marginalised people in society were not helped more. There is a direct correlation between the two. We need a programme architecture that enables our sector to fully utilise its potential through practical interventions such as third sector technical assistance – similar to the rest of the UK.

Finally I want you to read the last paragraph on page 21 about Community Jobs Scotland, graduate recruitment initiatives, capacity building in our sector, energy efficiency and advice and how they and other proposals were not deemed a fit with EU2020. It is a small paragraph but a most enlightening one. Is youth unemployment not our biggest generational problem? Is it not by investing in the capacity of third sector organisations to deliver their core aims, such as reducing poverty and giving voice to those without any, that we achieve social cohesion? Is that not a strategic fit with EU2020? Why is any of that not value for money?