Article 35.1 (a) of the Common Provisions Regulation states that support for Community Led Local Development shall cover the costs of preparatory support. Under the EMFF, preparatory support is one of the measures of Union Priority 4. It plays a very important role in ensuring a level playing field between existing and new partnerships and improving the quality of strategies.
This set of questions will help Managing Authorities to programme preparatory support under EMFF by addressing the following issues:
A: Yes. If the Member State decides to implement CLLD under UP4, then it must provide preparatory support. However, this can be done either via individual grants using UP 4, or via the provision of collective training and awareness raising activities such as training and seminars for all potential applicants using funding under technical assistance from either the 2007-2013 or the 2014-2020 period.
This set of questions concerns the provision of individual grants to potential beneficiaries, which should be foreseen as a measure under UP 4 in the EMFF OP.
FLAGs don't have an obligation to use this support since the more experienced groups may be ready to submit their strategy without applying for preparatory support. The CPR also clearly specifies that this support remain eligible even if the strategy developed by the beneficiary is not selected for funding.
Q2: What can be financed under preparatory support?
A: Preparatory support under UP 4 is intended primarily as grants for existing and potential Local Action Groups to help them strengthen the partnership and develop their local strategy.
Article 35.1 (a) of the CPR specifies that preparatory support consists of “capacity building, training and networking with a view to preparing and implementing a community-led local development strategy”
Q3: When can I start preparatory support?
A: To ensure an adequate quality of strategies, preparatory support should be made available as early as possible. This is particularly important for MS with new, inexperienced FLAGs. It is also important when FLAGs might also benefit from EAFRD funding, to ensure an early involvement of fisheries communities in the preparation of strategies, preventing their voice being lost in a broader approach.
Expenditure under preparatory support is eligible from the 1st January 2014, and some MAs may decide to launch it even before the Operational Programme is approved. MAs planning to start preparatory support before approval of the OP should ensure there is no national legislation in place that prevents them providing support before the OPs have been approved. They should also consult the Commission services about their proposals.
The following steps can be envisaged:
- ensure that the preparatory support is correctly reflected in the OP;
- prepare simple and transparent criteria and procedures for awarding the support in compliance with national law;
- set up a “shadow monitoring committee”;
- have the shadow monitoring committee approve the selection criteria and procedures for awarding preparatory support.
Actions that have been physically completed or fully implemented before the application is submitted for funding from EMFF are not admissible.
Q4: What should I put in place to enable preparatory support?
A: The MA should publish a call for expressions of interest, possibly together with the other EU funds implementing CLLD. The call should cover the following elements:
- Who can apply? The call should be open to existing local action groups as well as new actors who commit themselves to creating a local action group and to developing a local development strategy. The application will have to be led by a legally constituted body which can receive public funds, but the partnership does not have to be constituted before the application for preparatory support.
- Which types of areas are eligible? Managing Authorities may restrict eligibility to certain types of areas, in line with the area selection criteria described in the OP.
- One or more applicant per area? The MA should indicate whether it will accept several applications covering the same area or not, and – if such an overlap is acceptable – how they will decide which applicant will be selected.
- The actions that can be financed (see Q2 above).
- The budget available.
- The time span for implementation.
- An application form for the presentation of expressions of interest (see Q5 below).
- The criteria and procedures for selection (see Q6 below).
Preparatory support is meant to speed up and facilitate the selection of the final strategies, so it is essential that the procedures for selection are simple, transparent and easy to apply. The applications should be in a fairly synthetic and standard form, requiring relatively little qualitative judgement. The MA can either evaluate the applications internally or they can appoint external independent experts to do the job.
The criteria and procedures must be adopted by the Monitoring Committee (the “shadow monitoring committee” before the OP is approved, see Q3 above).
Q5: What should be included in the expression of interest?
A: A short standard form for candidates to express their interest in preparatory support could cover:
- name and contact of the existing partnership or of the local entity that commits to creating the partnership if finally selected;
- evidence of the responsible organisation’s capacity to manage public funds;
- signed expressions of support from other relevant local actors;
- a brief description of the local area of the potential FLAG – to be further defined in the process of preparing the strategy;
- preliminary ideas around which the local strategy may be built and the main participants of the partnership that would be formed;
- an outline action plan specifying the main tasks that will be carried out through preparatory support and an approximate timetable.
Q6: What criteria can I use to allocate preparatory support?
A: Unlike the selection of the final strategies and partnerships, the decisions about preparatory support can be based on simpler criteria, limited to basic information about the suitability of the proposed area and the capacity and representativeness of the proposed partnership. For example, criteria could cover one or more of the following points:
- the coherence of the area proposed for the implementation of the strategy with the priorities of the Operational Programme;
- the commitment of the lead organisation to prepare the strategy and form the partnership as shown by a signed letter of intent;
- evidence provided by the lead organisation of its capacity to manage public funds and experience in local development;
- the interest expressed by representatives of the local community in forming a partnership; one would expect signed expressions of interest from the main representatives of the fishing community and other important local sectors and actors;
- the presentation of a viable plan including the actions to be undertaken and their cost, as well as an indication of who will undertake the drafting of the strategy; special attention should be paid to actions envisaged to ensure the bottom-up character of the strategy;
- a calendar for the use of the preparatory support.
Q7: How should I select applications for preparatory support?
A: In selecting the applicants who will get preparatory support, the MA will have to take decision on the following options:
- standard or variable grant. As most potential FLAGs will have to go through the same process, it may be justified to allocate the same amount of funding to all applicants. An alternative would be to adjust the grant in relation to the size of area, the scope of planned activities or an evaluation score of the application.
- minimum threshold or ranking. The MA may decide to grant support to all applicants meeting a minimum quality threshold, or it may rank the applications by evaluation score and go down the list until the total budget available has been allocated.