SCVO was invited to comment on the Scottish Government’s draft Operational Programmes for European funding. This applies to the new European Social Fund and European Rural Development Fund during the next European funding cycle covering 2014 to 2020.
ESF = European Social Fund
ERDF = European Rural Development Fund
- The Operational Programme (OP) documents are incoherent in parts, contradictory in several places and use jargon and language that is inaccessible to most people.
- The financial tables in the ESF OP do not add up and use different sets of figures from previously published papers with no explanation or justification for the change.
- Different figures appear to have been issued to other stakeholders (HIEP) outwith the public consultation.
- Too much provision is planned for pipeline delivery which may not provide the specialist provision required by certain categories of customers.
- Third Sector organisations could potentially have to negotiate with 32 Local Authorities. The process would not represent value for money, nor would it guarantee quality of provision for service users.
- SCVO has proposed a National Employability Fund which would address some of the identified pipeline issues. This has been agreed in principle in a letter from John Swinney but the fund is not referred to in the OP.
- The contention that Community Planning Partnerships are the only legitimate vehicle supporting community sustainability is wrong.
- The constant use of the term Social Enterprise is unhelpful and of great concern as its definition and use is widely misinterpreted.
- The ESF OP document does not say who is leading on social inclusion and poverty. SCVO sought to convene a cross-sector consortium for this theme and expressed an offer to act as a lead partner for Theme 9.
- The outline programmes, particularly for social inclusion, do not seem to adequately address their own analysis of the problems.
- Counting theme eight activities towards theme nine hints at a lack of ambition and understanding on how to address and achieve theme nine.
- All the simplified costs options should be available to maximise service user provision and stakeholder involvement.
- Whilst review is essential it must not create a background of uncertainty and instability in terms of local authority pipeline contracting.