EFF Applications Process must be Reformed

25th June 2013 in Domestic Fisheries Policy

The experience of NFFO members, not just the NFFO, would seem to suggest that the MMO team dealing with the EFF is currently under-resourced.

MEMO FOR THE EFF PMC MEETING ON 12 JUNE 2013

INTRODUCTION

The experience of NFFO members, not just the NFFO, would seem to suggest that the MMO team dealing with the EFF is currently under-resourced.

In general, this has resulted in negative experiences for NFFO members with respect to:

• The length of time that lapses before a response is received to a query or request for information;
• A tendency for applicants to receive “last minute” notifications relating to information requests and panel meetings;
• Inconsistencies between information provided on the web-site and the actual information required from applicants;
• The lack of standardised documentation.

As a result the perception of the utility of applying for EFF funding, particularly among small businesses, is extremely negative.

POSSIBLE EXPLANATIONS

There would appear to be a number of possible explanations beyond the purely resource related factors.

These could include:

• Pressure to avoid de-commitment leading to an excessive concentration on developing new applications;
• The complexity of the whole application process;
• The initial lack of experienced personnel following the move to Newcastle;
• The precedent setting nature of some proposals;
• The impact of the negative report by the European Court of Auditors
• The lack of standardised documentation;
• The absence of a clear, public statement of audit policy requirements.

In this respect it would be helpful for the PMC to receive details of the average length of time, from initial contact through application, the completion of documentation, project completion, verification and disbursement by category of project (value / life of asset / Axis). It would also be desirable for such figures to cover the trend over time on an annual basis to establish whether matters had improved.

NFFO’S EXPERIENCE

Whilst the NFFO’s experience is chiefly coloured by the PFD project, there are also other projects with which is concerned.

The points that it would like to highlight are:

• Inconsistencies in the information provided relating to both information requirements and matched funding rates;
• Difficulties over pan-UK projects (which effectively do not exist);
• Delays in response to queries (particularly with respect to documentation);
• Disparity between asset life and length of audit trail (e.g. a consumable that would be written off in one year is subject to the same or more stringent treatment as a harbour installation depreciated over 25 years);
• Absence of a de minimis exemption for small value consumables leading to disproportionate audit requirements.

IMPLICATIONS

The net effect of these negative experiences is to underline the impression that the EFF is not designed for the SMEs in the catching sector and that it is not worthwhile wasting time applying for funding.

Given this situation, and the likely shape of EMFF, something needs to be done to simplify the process and speed up response times, or, alternatively, to consecrate more resources to assisting SMEs in the application process (particularly in dealing with discards). Otherwise interest in the EMFF will be minimal.

07/06/2013

The NFFO would be interested in receiving members' comments on their experience with the EFF application process.