Project selection

Issue 3.1
The documentation released with the call caused a certain amount of confusion in respect of eligibility. It was unclear as to whether in the first five partners it was permissible to include non city partners. The programme makes it clear that non city partners can be involved(no more than three in a network). Furthermore, the programme made it possible for the involvement of EU networks to also be involved(subject to the agreement of the MC).

The confusion created by the lack of clarity meant that a number of proposals were deemed ineligible by the Secretariat as they included non-city partners. Some of these projects infact wrote to the President of the Urbact Monitoring Committee. Below is the letter sent by one of those effected, which lays out the confusion in the documentation:

Dear Mr. President Metka Černelč
URBACT Monitoring Committee President
RE: URBACT Expression of Interest for establishing a thematic network called Community Regeneration: Capacity Building Exchange

We have learnt that our expression of interest has been declared ineligible by the URBACT secretariat. The reason for ineligibility has been that we have included a European network and the association of municipalities from Malta in the first five partners in our expression of interest.
We have learnt that over 10% of the expressions of interest submitted have the same problem in terms of the initial partnership having one non-city member.

We understand that one of the criteria for eligibility relates to having an initial partnership of five cities, HOWEVER, in respect of this criteria the communications from the URBACT programme have clearly caused some confusion. Hence the large number of submissions that have been deemed to be ineligible. We request that the monitoring committee urgently reviews this decision by written procedure as this matter cannot wait until the next Monitoring Committee in April.
We are also writing to you as there is no appeal procedure outlined in the documentation regarding the programme. This seems to be an oversight that maybe the monitoring committee should also consider.

The grounds for requesting this review is simply that the documentation released are confusing and thus have created a lack of clarity.

As you are aware, the programme issued three documents connected to the first call of proposals. These are:
· The call for proposals
· The guide for applicants
· The URBACT 2 Programme Manual (Technical Annex)

In the call for proposals it is stated:

“Applicants are invited to submit proposals for the creation of a Thematic network or of a Working group, depending on how they intend to deal with their theme and on the kind of partnership they want to set up. Details on these projects are included in the URBACT II Technical Working Document (Fact sheet 2a – Thematic networks, and Fact sheet 2c – Working groups).”

However when you turn to Fact Sheet 2a there is no reference to the eligibility criteria that all five partners have to be cities. Fact Sheet 2a states the following:

“2.4. Building the partnership
Every project proposal shall be submitted to the URBACT Secretariat, in the form of a Declaration of Interest, by an initial core group of 5 partners (including the Lead Partner). Further information on this procedure is available in section 6.3.). a) Beneficiaries”

Section 6.3 goes on to state that:

The beneficiaries of the URBACT II Programme include the following categories of partners:
- Cities (municipalities, infra-municipal bodies and organised agglomerations) of the 27 EU Member and 2 Partner states;
- Regional and national authorities of the Member and Partner states, as far as urban issues are concerned;
- Universities and research centres of the Member and Partner States, as far as urban issues are concerned.

Furthermore in the same fact Sheet it goes on to state:

“In the context of URBACT II, Lead Partners are the target for calls for proposals to be launched under Priority axes I and II. Only public authorities, NORMALLY CITIES, can be Lead Partners.”

This phase lends support to our concern regarding clarity of communication. The phrase “normally cities” suggests that a public body other than a city could be a lead partner. If the eligibility criteria is that all five partners have to be cities, then it is strange to see that a lead partner could in fact be another type of public body eg region or province.

The same document goes on to state:

“2.3 Composition of partnerships

Each thematic network shall consist of not more than 12 partners, plus up to 2 observer cities (non Member or Partner State).
Each network shall have at least 8 partners from at least 3 different Member and Partner States, taking into account the necessity to find a balance between Competitiveness objective and Convergence objective regions.
No more than 3 partners in any thematic network shall be non-city partners (be they beneficiaries of the programme, i.e. regional and national authorities, universities and research centers as defined in section 2.2.a; or other partners as defined in section 2.2.b). These non-city partners will be from 3 different countries.”

Thus this statement also makes clear that non- city partners are eligible to be partners in a thematic network. Furthermore this section makes no distinction between the first and second phase of thematic networks and as such creates further confusion and lack of clarity.

To add to the confusion, in the Guide for applicants it states:

“Partnerships for projects are to be fully developed in the Development phase (first 6 months for thematic networks / first 4 months for working groups). However in order to be eligible, projects should build their Declaration of Interest on a certain number of initial partners:
- 5 partner cities for a Thematic network (including the Lead partner),
- 4 public authorities in the case of a Working group (including the Lead partner).”

This is the first and only time in 218 pages of documentation that this criteria is stated BUT, in the same section the text states:


“A detailed explanation of eligible partners can be found in the URBACT II Programme Manual (Technical Working Document), especially Fact
Sheets 2a and 2c.”

This of course takes you to the text quoted above and which is silent on this criteria.


Finally , we are also of the view that the confused and confusing eligibility criteria for the first five partners may in fact be in contravention of EC Regulation N° 1083/2006 which states that:

“Article 2 of Regulation (EC) N°1083/2006 of 11 July 2006 defines beneficiaries as “an operator, body or firm, whether public or private, responsible for initiating or initiating and implementing operations. In the context of aid schemes under Article 87 of the Treaty, beneficiaries are public or private firms carrying out an individual project and receiving public aid”.

The following categories of beneficiaries can be identified for the URBACT II Programme all of which will be eligible to receive ERDF co-financing:
- Cities (municipalities and organized agglomerations) of the European Union 27;
- Regions and Member States as far as urban issues are concerned;
- Universities and Research centres as far as urban issues are concerned.”

Given the above grounds for appeal we request that under written procedure that it be agreed that given the confusion and lack of consistency in the formal documents regarding this call, that the Monitoring Committee agrees that applications that fail to meet the criteria of having 5 city partners be allowed to proceed to the evaluation phase and be finally judged on the basis of their quality rather than being rejected against a criteria as we have shown is not effectively communicated in the programme documentation.

Here is the response from the Secretariat:

You referred to me the decision of the Secretariat of the URBACT programme to declare ineligible your Declaration of Interest for the creation of a Thematic Network .

The URBACT Secretariat is currently processing the eligibility check of all Declarations of Interest received (91 DoI for Thematic networks and 32 DoI for Working groups).

While a majority of DoI do fulfill the eligibility requirements, it appears unfortunately, that some candidates misunderstood some of the rules relating to partnership building, documents to be provided, etc. even though they were clearly indicated in the Call for Proposals (annex 1:
Eligibility criteria) and the template to be used for the Declaration of Interest (Section 1.3 Partnership).

I deeply regreat this situation. However, I keep in mind that over 400 European cities did apply to this first call for proposals It is a hard competition with clear and written rules approved by the Monitoring Committee and ensuring transparency and equity of treatment.

Eligible DoI are transferred progressively to External Assessment Panel for assessment and ranking. DoI that do not fulfill the eligibility criteria are not transferred to the EAP.

For this reason, it appears to me quite impossible to consider a written procedure aiming to change the rules in the middle of the assessment process.

At the next meeting on 18 April, the Secretariat will provide the Monitoring Committee with a complete and detailed report on this first call
for proposals, outlining the number of applications received, the
nationality of applicants, the thematic coverage, etc. The Monitoring Committee will then be in the position to decide on the next steps.

We shall keep you informed .
Best regards


Having stated the rule, of no city partners in the first five partnership, it was a great surprise to see that a number of projects with non-city partners were deemed eligible by the Urbact Secreatriat. This in effect has meant a double –standard being applied. This is not good practice and raises issues of transparency.

Here is a list of projects deemed eligible by the Urbact Secretariat which included non-city partners:


REPAIR
Medway, Hanseastadt Rostock, Kaunas, Karlskona, Thessaloniki

Medway is NOT a CITY. It is a county council. There is no city called Medway.



Weser
Moncomunidad Intermuniciőal de Sur Este Gran Canaria, Colalition of 21 municipalities of Northern and Eastern Prefecture of Athens, Menidi, Brindisi, Euguera

Neither Moncomunidad Intermuniciőal de Sur Este Gran Canaria, OR Coalition of 21 municipalities of Northern and Eastern Prefecture of Athens are cities. They are associations.


Greening SMEs
Moncomunidad Sagra Alta, Communauté d’ agglomeration Béziers-Mediterranée, Tarnow, Targiviste, Kirklees Metropolitan Council

Moncomunidad Sagra Alta is NOT a CITY. It is an association



SUITE
Santiago de Compostela, Ministry for the Urban Dev. and Env.-Hamburg, Medway, Nantes Metropole, Siemianowice Slaskie

Ministry for the Urban Dev. and Env.-Hamburg, is by definition not a city;
Medway see comment above


DECIFER
Nottingham, Terrassa, Warsaw, Genova, Kmepaida Eco Dev. Agency

Kmepaida Eco Dev. Agency is NOT a CITY


Transition
Malmö, Gijon, Utrecht, South Lanarkshire, Montevarchi

South Lanarkshire is NOT a CITY. It is a county.

STUCA TEAM
ASDA-Association of Municipalities of West Athens, Catania, Kavala, Novara, Stara Zagora

ASDA-Association of Municipalities of West Athens is NOT a CITY. It is as its name says an association.

EISHC
Ios, Samothrace, Moudros, Samso, Western Isles Community Council

Western Isles Community Council is NOT a CITY. Furthermore The only large town in the Western Isles is Stornoway ( Steòrnabhagh ) with approximately 5,600 people. This does not meet the Urbact criteria in this respect also.



4 R’s Rules
Noventa di Piave, Brda, Rence Vogrsko, Baia Sprie, Bistrita

Rence Vogrsko is NOT a city it is a collection of Four villages. Population is just over 6000. This does not meet the Urbact criteria.


Baia Sprie has only a population of 16,000. This does not meet the Urbact criteria.


Issue 3.2

The programme having established an independent evaluation panel and clear criteria for the evaluation of the initial expression of interest is a welcome new development. However, it is far from clear as to whether the procedure has been used in accordance with “good practice” established at EU level in other programmes. To date the Urbact Secretariat has been silent about actually how the evaluations were undertaken. The issues that cause concern are:
It seems that projects were evaluated just by one evaluator. The EU good practice standard is at least two and generally three. As such there was no effective process of moderation in the evaluation process.
The scoring system used seems to have failed to ensure that evaluators scored projects against the specific indicators listed in the documentation for each of the five criteria. Instead, it seems that evaluators simply used “impressionistic” criteria in awarding the total score for each criteria. This is simply bad practice and allows for far to great a level of subjectivity if the process.
An example of the quality of evaluation is provided by the following two case studies:

The City of St Helens Submitted a proposal relating to new methodologies for intergrated Urban Devlopment.
The London Borough of Southwark submitted a proposal relating to creative cities


Issue 3.3

In the guidelines for applicants for the first call , a ceiling has been set for the total budgets of networks and working groups. The limit for working groups is €50,000. Of the eight working group approved , 6 have respected this rule. Two have not respected this rule. Jessica 4 Cities has an expression of interest which shows a budget of €300,000. One could be charitable and say that this is an error, but the same application also shows a request for ERDF funding that exceeds the €150,000 ceiling laid down in the programme documentation. Joining Forces, another approved working group has a budget of €65,361.

The point here is not whether the two working groups are good projects, but simply the principle that applies in all EU programmes, namely that if the application does not respect the limits laid down then it is automatically rejected on technical grounds. Here again we have an example of lack of transparency. Had other candidates known that the limits set in the approved documentation were “flexible” then perhaps they would have entered the programme or presented their proposals with a different budgetary construction.