ELIMINATE FOR GOOD THE "FIRST COME FIRST SERVED" RULE
To
The Government of Romania,
Management Authority of the Region Operational Program
From all the provisions regulating the allocation of public funds and, in particular, from the provisions of the "Applicant's Guide — Specific conditions for accessing funds" from the Regional Operational Program 2014-2020, Priority Axis - Improving the competitiveness of small and medium-sized enterprises, Investment Priority 2.2 , through which it is proposed to grant non-refundable amounts between 2,000,000 and 6,000,000 euros to small and medium-sized enterprises, in percentages of 50%, 60% or 70% of the total eligible investment, (guide as of May 25, 2020, the date of this, in the version subject to public consultation), please remove the "first come, first served" rule provided for in point 2.1.:
"This call for projects is a competitive one, with deadline submission. Projects can only be submitted during the period mentioned in subsection 2.2. from this document. The selection of projects will be carried out according to the provisions below.
Funding applications are checked and evaluated in the order they are submitted. Non-compliant/ineligible funding applications will no longer be evaluated (scored). Thus, applicants will be notified either of the score obtained (in the case of compliant and eligible projects), or of rejection on grounds of non-compliance/ineligibility. Funding applications that score less than 50 points are considered rejected.
For the pre-contractual stage, the compliant and eligible funding requests that obtain the highest scores will be selected, depending on the budget available for this call."
If you don't remove the absolutely non-transparently disguised "first-come, first-served" rule in the previous provision, which in reality/more correctly/essentially says that any funding request awarded more than 50 points in the assessment will be selected for contracting within the limits of available funds (instead of having provided, from the very beginning, clearly and transparently, that the call for projects is of the "first come, first served" type for all funding requests that will obtain a minimum of 50 points), then this call for projects will also suffer from the following Romanian habits:
- The MySMIS application will crash in the first few seconds after the call is launched (from the moment it is available for uploading funding applications) or will work very badly, because all applicants, in the number of several hundred or even more than 1,000, will try to access it from the first second.
- The quality of the projects will be poor because almost all of them will be carried out in order to:
2.1. The funding request can only obtain a minimum of 50 points.
2.2. The funding request should be completed quickly in advance (especially for projects with a construction work execution), to be ready the first second the MySMIS platform is available for upload. (Thus, even if applicants in a region were only 100 (and not hundreds) against funding available of 40 projects, all those who submitted their funding applications in the first seconds/minutes after the start would win, to the detriment of many with projects of clearly superior quality.)
It is very difficult for us to understand how, regarding the profoundly uncompetitive "first come, first served" system, after so many arguments that have been brought to you, after so many failures, after so many negative public experiences, even shocking, of both the applicants and the authorities and even of the final beneficiaries (those who have implemented extremely hard such projects "made on their knees" to be ready ultra-fast regardless of how they correspond to the economic-social-administrative expectations and the established selection criteria), continue to insist that such type of call is one ... "competitive"!!!
Specifically, according to the "first come, first served" rule, applicants are told by consultants (external or internal):
- The only thing that matters is to be sure that we get at least 50 points (55, let's say, to have a margin in case of depicts).
- We will provide many workstations (computers) and personnel to be ready to start loading and/or give the loading command, in the shortest possible time (seconds, minutes maximum). "We are faster and get your financing" (as if this is how public money should be allocated!!!).
- If there are problems with shortages, insufficiency, ambiguities, etc. of information and documents in the funding application and/or the attached documents: "we are not focusing on them now; we resolve them afterward, upon requests for clarification from the evaluators".
- In the case of funding applications that were submitted quickly and evaluated with at least 50 points, many consultants have the habit of telling clients: "we had relations with the funding authority and we managed to have your application registered online ahead of other financings".
- For each funding application that was not evaluated as a result of the suspension of the call for reaching the total funding ceiling allocated (by region or national), the applicant will suspect, or even be convinced (especially in the case of funding applications whose scores self-assessed selection would have been high) that the computer system for online registration of the moment of submitting the funding request was not correct.
Of course, for you, as the authority/authorities managing public funds granted in a non-reimbursable system, applying the "first come, first served" rule (which is the fastest way to process any selection of requests), it is much easier this way to report that you have fulfilled the quota "per hectare" of attracted European funds.
But, in this context, Romania's priority is not to give comfort to its officials, but to attract European money for quality projects.
If you will understand that "first come, first served" means hazard and not competitiveness, then you will return to the methods of assessment with deadlines and decreasing score thresholds, which, by the way, we strongly urge you to do.
And if this maidan rule "first come, first served" will remain unused forever, in the case of any allocation of public funds, everything will go back to normal, and applicants for funding will be able to focus on quality projects, on clear rules, transparent and proactively transmitted, of course within reasonable deadlines, which will lead to quality projects and, further, to sustainable and economically sustainable development, simply.
AIM Board of Directors
