UPDATED ON 29/06/2018
Here are answers to the most frequently asked questions by users, e-mail at: firstname.lastname@example.org
1) In Action 1.A. - Transformation, marketing and enhancement of the fished product, is it permissible to stipulate a contract with a company that is already processing the fished product instead of purchasing the equipment? Adding the purchase of the necessary material, into the project, for the correct transformation?
With regard to Measure 5.69 of the EMFF "Transformation of fishery and aquaculture products" costs relating to the construction of buildings or extraordinary maintenance or modification based on particular productions are allowed. The purchase of equipment for processing/transforming process operations of fishery and aquaculture products is also admissible. Costs relating to the management of the company or classifiable as running costs such as those mentioned in the application are not eligible.
2) Still in Action 1.A, is the "research" item also applicable to the "transformation" category or only to "marketing"?
The research activity is not part of the concept of structural investment typical of Measure 5.69 of the EMFF and it does not fall within promotion activities.
3) In Action 2.A. - Innovative techniques for managing production in marine farming and development of seed management systems in the lagoon, is the cost of the seed admissible? And the operating costs (for example electricity, gas, drinking water) essential to carry out a pre-fattening project within a fishing canal?
The supply of seeding material (fry or molluscs) does not constitute admissible expense except for small quantities and for research and experimentation purposes. Running and management costs such as the supply of electricity, gas and drinking water are costs pertaining to the management of the plant and are therefore not eligible for funding with the EMFF contributions.
4) In Action 4.A. - To revitalize transitional environments at risk with poor hydrodynamics and consequent effects, should the recipient be in possession of the authorizations already at the time of submitting the grant application?
In the case studies highlighted, the creation of works in lagoon basins or public waters necessarily entails the possession of specific authorizations, the obtainment of which is difficult or requires timing that is not compatible with the need to to know in advance the expenditure for FEAMP programming. If this requisite is included in the tender criteria when published, this requirement must obviously be respected. However, it is necessary to highlight that projects lacking the prerequisites of viability will not respect the necessary timescales in order to ensure the progress of programming. It is therefore necessary to to give precedence to initiatives that can be readily established and already have the specific authorizations. In no case may the failure to obtain the authorizations constitute a right to obtain extensions to the terms for the execution of the project.
5) In Action 5.A. - Support for the management of discards as per Reg. (EU) 1380/2013 and to the implementation of ecosystem services, given the nature of the intervention, is it possible to obtain a 100% public contribution?
The nature of the interventions, envisaged by the tender and the recipient to whom it is aimed, does not allow for contribution estimates exceeding the standard rate of 50% of the value of the allowed expenditure.
6) In Action 5.B. - Promote shared governance measures for Maritime Space Planning within 12 nautical miles, are there also plans to manage inland areas such as lagoons and/or canals?
The identification of the "maritime space within 12 miles" is relevant, for the purposes of granting the EMFF contribution, for activities carried out in marine waters, not in the internal maritime state waters (lagoons and fishing canals). In the EMFF there is a clear separation of the two areas, therefore we recommend reading art. 44 of Reg. (CE) 508/2014 which is for specific interventions for inland waters, clearly distinguishing them from similar initiatives to be implemented in the marine waters.
7) The Consortium for the Development of the Polesine having its registered office in Rovigo, or outside the area of competence of the GAC Chioggia e Delta del Po, may be a subject eligible for co-financing
This Consortium can be the recipient of EMFF contributions based on the tenders issued by the FLAG only if it carries out initiatives in the territory pertaining to the FLAG. It is deemed necessary to stress that any activities of said Consortium, focused on promotion, cannot identify commercial brands or specific products of specific areas.
8) The Consortium for the Development of the Polesine is to be considered a "Public Body" pursuant to Implementing Measures and therefore a recipient of tender notices in question, as confirmed by the Agro-environmental, Hunting and Fishing Directorate of the Veneto Region in relation to the Measure of intervention 5.68 (PO FEAMP) (DGR nr. 213 of 28 February 2017)?
The Consortium is considered a Public Body and necessarily, when carrying out initiatives funded by the EMFF, must apply the rules of the procurement law (Legislative Decree 18 April 2016, n. 50 and s.m.i.).
9) In Action 5.B, is it possible to consider the expenditure incurred for the salaries of internal personnel as eligible expenditure? And any design costs incurred in favour of third parties?
The FEAMP, among its objectives, also provides for employment growth. As a general rule, personnel costs are not allowed, but the costs of personnel hired for a specific project are eligible. Design costs must be included at the time of tendering a proposal and must be functional to the type of project financed, the relative cost must be reasonable compared to the amount of the investment in order to maximize the effectiveness of the contribution in favour of the initiative with respect to the costs of design.
10) In Action 4.A. - To revitalize transitional environments at risk because of poor hydrodynamics and consequent effects, at point 1.6 there are 3 distinctions of interventions (each with its own ceiling and minimum) is it possible to present a single project that includes all three types of intervention? If not, then can the same entity submit several projects on the same Action but containing different interventions?
For the sole purpose of a rational management of the projects, it is considered that the presentation of three separate requests, one for each sub-measure, facilitates the preliminary stages and the the ranking which must necessarily be distinguished by measure/action.
11) In Action 5.A. - Support for management of discards as per Reg. (EU) 1380/2013 and to the implementation of ecosystem services, the objectives of the measure (point 1.2) are to implement adjustments in the boats and at the landing points, in relation to the introduction of the EU landing rules, but among the eligible interventions none is attributable to adjustments at the landing points.
In the tender concerning this measure no structural interventions are foreseen on the ground at landing points. Therefore, the types of initiatives that can be financed must be respected.
12) Still in Action 5.A, point 1.6 speaks of discard management systems, but eligible interventions are all aimed at reducing discards, not managing those that will inevitably continue to be produced. In point 7 "selection criteria" also the score table does not contain any criteria relating to the management of discards or interventions at landing points.
The discard management systems referred to in paragraph 1.6 refer to interventions on board fishing vessels, there is no reference to ground facilities and therefore scores cannot be assigned for initiatives not relevant to the Action/Measure.
13) In point 8 "Intensity of Help" it is specified that "in derogation from par. 1, the Implementing Subject can apply for public aid equal to 100% of the eligible expenditure of the intervention when the recipient is a body governed by public law or a company entrusted with the management of services of general economic interest ”. This contrasts with the fact that the eligible subjects are Producer Organizations, Consortia, Cooperatives, Fishing and Aquaculture Companies. Furthermore, this also contradicts what was presented at the meeting held in Porto Tolle, in which it was stated that the maximum aid is 80%.
What is highlighted in paragraph 8 has a generic value, therefore it is necessary to evaluate the types of recipient and the nature of the project presented by them based on the provisions of the tender. In the case of Action 5.A, the "fishing companies" and the "Consortia and Cooperatives" can obtain a 50% contribution calculated on the allowed expenditure for financing, this contribution rate can be raised to 80% only in the case of initiative presented by a recognized Producer Organization with generalized benefits in favour of all members. In no case is it possible to finance a project presented by an O.P. when there is a direct repercussion on the associated companies (Example: a consortium plant for packaging shellfish can obtain 80% contribution, the purchase of equipment destined to individual companies cannot benefit from this contribution rate).
14) Taking into account that the projects will be vetted by external evaluators (as envisaged by point 6 of the Internal Regulations), the ranking list proposal prepared by them will then be sent to the BoD for acknowledgment and subsequently transmitted to the Region/O.I. for final approval; can the members of the GAC belonging to the Board of Directors submit an application for a contribution?
The FLAG members may produce applications for contributions based on the measures/projects that the FLAG intends to carry out, however the aforementioned members may not participate in the preliminary and/or decision-making phases for the rankings.
15) The submission of applications for assistance is provided only by PEC. Is it possible to send files in any format? Or are there the same restrictions as the regional protocol?
The files for tender applications issued by the FLAG must be sent via PEC and in a non-editable format. According to regional standards, the sending of documents in .pdf format is required.
16) In Action 5.B. - Promote shared governance measures for Maritime Space Planning within 12 nautical miles, in the case of a Public Entity recipient, is VAT included in the amount of eligible expenditure and therefore included in the 100% contribution foreseen by tender notices?
In the case of public recipients, VAT may constitute eligible expenditure if not recoverable by the recipient. In this case it will be necessary for the project to be supplemented by a specific declaration made according to Presidential Decree 445/2000 by the legal representative of the recipient entity.
17) Who or what is meant by "recognized research institutes"? Do they have to be registered on any specific list?
"Recognized Research Institutes" means those Institutes attached to the competent Ministries, university institutes or public entities that carry out scientific research activities.
18) Again in Action 5.B, the Public Entity that presents an application may decide to use a specific Research Institute already in the planning phase, or do you identify the institution that will carry out the project by public tender?
The public entity submitting the application for a contribution must select the research institute using the procedures provided by the code of the contracts pursuant to Legislative Decree 50/2016 and s.m.i..
19) Is it possible to request advance payments and/or progress reports (SAL)?
Advances on projects will be stated in the tender which also states the rules for their management. If not included, then it is not possible.
20) In Action 1.A. - Transformation, marketing and enhancement of the fished product, is a company that owns a fishing canal farming 5 species of mullet (golden grey mullet, thin-lipped grey mullet, thicklip grey mullet,) bass, bream and eel extensive fish farming (ie in a completely natural way without the use of feed or medicines) considered an eligible recipient?
A fishing canal is classified as aquaculture. The assigned ATECO code is presumed to refer to the breeding activity of fish species, if the intention is to transform the fish products, action will have to be take to obtain an ATECO code relevant to the latter activity, otherwise access will not be available to specific measures intended to stimulate processing and marketing.
21) To enhance its product, a company would like to open a direct sales channel to the consumer through e-commerce: work on the product (evisceration), pack it in trays and ship it. Is this an eligible project? If yes, are only the costs of purchasing the equipment (scales, sealer, labeling machine) or also the costs of outsourcing some transformation phases eligible ? (at least for the depreciation)?
The processing of the product and its packaging are typical processing and marketing activities. All equipment designed to support these phases may be eligible. Costs related to outsourcing of transformation phases are not admissible since the investments are irrelevant but can be classified as running costs.
22) Still in Action 1.A, is the purchase of diesel generators permissible? And the costs for buying containers for handling fish?
The purchase of a generator constitutes admissible expense if it is necessary for the functioning of the plants in an emergency, the costs for the purchase of containers destined for processing of fish products are also admissible.
23) Are the costs for containers used for processing/packaging or storage of the product admissible?
The processing/packaging of fish products requires non-identifiable environments such as containers, the purchase of such structures may constitute admissible expense if destined for the temporary storage of products (refrigerated containers).
24) In Action 2.A. - Innovative techniques for managing production in marine farming and development of seeding management systems in the lagoon, can a Producer Organization submit a project that includes collaboration (through stipulation of an appropriate agreement) with a University?
An OP may apply to this Action; if required by the tender notice, it may stipulate agreements with third parties for carrying out the projects envisaged by the project. Please read the provisions of Action 2.A which mainly concerns investments.
25) In Action 4.A. - Revitalize transitional environments at risk with poor hydrodynamics and consequent effects, in the case of projects related to environmental monitoring, since it is not possible to make "estimates" which attachments must be produced?
If the project is presented by a public body, it must comply with the contract code for carrying out the work and must necessarily possess the qualifications to carry out work on the areas affected by the project. For monitoring purposes, the ownership of the areas to be monitored is not envisaged but the entity which carries out the monitoring (consultant or research institute) must be selected according to the rules of the contract code. Any documentation concerning the chosen selection must be equipped to support the project.
In the case of environmental monitoring, the companies potentially interested in participating in the tender for the assignment of the project a detailed technical/scientific report with price analysis may be produced as an estimate.
26) In Action 2.A. - Innovative techniques for managing production in marine farming and development of seeding management systems in the lagoon, there is a producer of bivalve molluscs that intends to submit a request for assistance. To carry out the project referred to in the aforementioned action, it is necessary to insert the item of expenditure for the purchase of sowing which represents for the producer a quantity less than 1% of the annual production requirement. With reference to the announcement of action 2A and the FAQ n. 3 (published on your site) is it possible to consider the expenditure for sowing as an eligible expense, which represents a percentage of approximately 50% of the total project expenditure aimed exclusively at research and experimentation?
The purchase of seeding material (fry or molluscs) does not constitute eligible expense as it refers to the phases of management of the breeding activity. However, if the project involves a scientific research activity, it is considered that the purchase of a modest quantity of subjects destined exclusively for experimentation may be admissible, in no case may this material be sold.
27) In Action 1.A. - Transformation, marketing and exploitation of the fished product, the list of eligible expenses includes the heading "new construction limited to the area of the production site": in the case of an oyster farming plant it is correct to understand that there is the possibility of building a new portion of the plant?
The aims of Action 1.A are not intended for the construction of breeding facilities but rather are aimed at eventually completing breeding with processing and marketing activities. Therefore the expansion of an oyster farming system is not in line with the aims of the tender.
28) Still referring to the same eligible expense, is it correct to understand "new construction limited to the production site" the construction of a fixed platform (already provided with the necessary authorizations and already under construction) for the purpose of exploiting and marketing the product?
The "fixed platform" must necessarily be built within an already operational production site. The interpretation is correct.
29) Also in Action 1.A, among the eligible expenses there is the item "boat adaptation": is it possible to present a project to have the product authorized for sale directly from your boat?
This is possible even though there are concerns about obtaining specific authorizations.
30) In the event that, for some expense items that are part of a project presented on Action 1.A., the recipient has benefited from a contribution given by CONSVIPO with LNG funds (therefore private), the same is to be considered public contribution? Or is it enough to specify it among the private funds in the presentation of the request for support?
The CONSVIPO is classified as a Public Body, therefore the contributions provided by it are classifiable as public aid, even if the origin of these funds is from a private Consortium that has not in any case directly disbursed them to private individuals but turned over to the CONSVIPO which has subsequently identified the recipients and payment.
The utmost attention must be paid to the retroactive nature of the expenses and to the observance of the maximum contribution limit established by the tender if there is a connection between the former LNG and the EMFF funds.
31) In Action 5.A. - Support to the management of discards according to Reg. (EU) 1380/2013 and to the implementation of ecosystem services, the recipients foreseen in the tender are: Producers Organizations, Consortia, Cooperatives, Fishing and Aquaculture Companies; can an S.p.A. fish trading company participate equally in the tender notice?
If this is not possible now, is there a possibility, with the modification in 2019, to extend these tenders to companies that sell fresh and frozen fish products? The reason for this proposal is influenced by the fact that subjects such as fishing companies and consortia are not structured (at the moment) to support very complex projects such as those sought. Secondly, to exclude the most developed companies in the production cycle, such as aquaculture ones and wholesalers for example, takes away the possibility of accessing more long-range specialist knowledge on the entire production cycle of our District.
The type of objectives of the Measure is not relevant to the activities of companies engaged in the wholesale trade of fish products that are not included among the possible recipients of the tender notices. It is also out of place to extend the codes ATECO 10.2 - 46.38.1 - 46.38.2 (processing and marketing of fishery products and fish farming) as they are not directly involved in the problem of discards under Reg. U E 1380/2013.
32) In Action 3.A. - To aid fishing companies in the process of diversification of production and management, the recipients envisaged in the tender are: Producer Organizations, Consortia, Cooperatives, Fishing and Aquaculture Companies; respecting the objective of diversifying the activities of fishing and aquaculture companies by focusing on tourism, can Agricultural Companies / Companies that carry out aquaculture activities also participate?
Still in Action 3.A. can fishing companies based outside the GAC territory apply if the intervention is carried out within the GAC territory?
The announcement concerning the Measure is for the provision of aid for the diversification of income, including aquaculture businesses; if the applicant for the contribution is in possession of an appropriate AT ECO activity code (03.21 and 03.22), can access the aid provided for the implementation of initiatives among those highlighted in paragraph 2 of the announcement.
The acceptance of projects presented by fishing companies based outside the GAC territory must be evaluated with appropriate caution as an economic and social impact on the FLAG's territory must be guaranteed while a fishing boat can be easily diverted from the territory concerned, in particular if the fishing company has its registered office outside the region. The approach with aquaculture companies that have plants permanently active in the territorial area pertaining to the FLAG is different.
33) In Action 3.B. - Strengthening of cultural exchange initiatives with other national and European territories, among the recipients foreseen in the tenders are Organizations that promote equal opportunities and the accredited private Operators that provide professional training services; is there a list of the former? For the latter, is the Regional List of Accredited Training Organizations issued by the Veneto Region and updated to 05/16/2018 valid? (downloadable at the following link: http://www.regione.veneto.it/web/lavoro/accreditamento-lavoro-formazione)
There are no official lists of organizations that promote equal opportunities, but instead lists of accredited bodies for the provision of vocational training services can be found as highlighted in the question asked.
34) In Action 6.A. - Services to support the community in the fishing port areas, in the case of a Public Body (Municipality) which has the ownership of several port spaces (understood as: fishing ports, landing sites and fishing shelters) on which it intends to intervene, must present a single cumulative project of the various interventions? Or does it have to present several distinct projects, one for each port space in which it intends to intervene?
In the same Action, where it is indicated as eligible expenses "interventions of physical requalification of fishing ports (renovation of pavements, lighting systems, street furniture, construction under services, plant engineering)" and "restructuring of existing docks or landings" is it also possible for replacing the already present but now deteriorated mooring tripods?
Also in Action 6.A., the Municipality of Chioggia intends to carry out an intervention aimed at improving the lighting equipment of the landing area adjacent to the Fish Market. The works would be carried out by Veritas S.p.A. in-house subsidiary of the Municipality of Chioggia and which is currently the manager of the public lighting system in the municipal area. Considering the provisions of point 3 of the tender "CONSTRAINTS AND LIMITATIONS (TYPES OF EXCLUDED EXPENSES)" where it is indicated that the expenses relating to "goods and services provided by subsidiaries and / or associated companies and / or with substantially connected owners" are not eligible for reporting; can the expenses related to the goods and services paid by the Municipality and carried out by the aforementioned Company be included?
The Local Authority that has various port areas is required to present a single project; this avoids bypassing any maximum spending limit set for a single recipient. In the specific case highlighted, the Municipality of Chioggia will be able to use design and execution of works with an in-house subsidiary. However, it is understood that the Municipality of Chioggia will have to prove that it has complied with the contract code and have incurred the costs of the work performed on its behalf by the in-house company.
35) In Action 3.B. - Strengthening of cultural exchange initiatives with other national and European territories, among the recipients envisaged in the tender notice are the accredited private Operators who provide professional training services; in the Regional List of Accredited Training Organisms, issued by the Veneto Region and updated to 19/06/2018 (downloadable at the following link: http://www.regione.veneto.it/web/lavoro/accreditazione-lavoro-formazione ) there are 4 areas of accreditation: OT-Obligatory Training / HE-Higher Education / CT-Continuous Training / OR-Orientation. Which of these is to be considered suitable for participating in the tender?
The operator who provides a professional training service must necessarily be accredited by the Veneto Region as a provider of the type of training service provided for in the tender notices. The EMFF management procedures do not provide for a specific form of accreditation but the non-financiability of purchases and / or services rendered mandatory by current legislation must be taken into consideration.
36) In Action 6.A. - Services to support the community in the fishing port areas, the Municipality of Porto Viro, owner of the regional concessions, built 8 piers for mooring and stopping for professional fishing boats in Porto Levante along the right bank of the Po di Levante many years ago. Now, the municipal administration intends to intervene for the replacement of the now obsolete mooring poles, to carry out an overhaul of the existing electricity and drinking water lines at the service of the various piers, in addition to the modernization of the water supply columns (one for each pier) and electricity; is this feasible? Can they take advantage of a 100% contribution on the works (including VAT) and on the "SUMS AVAILABLE" (general expenses, unforeseen events, etc.) and on the final and executive design, including social security charges and VAT?
In Measure 1.43 and 1.44 par. 1 letter F, whose purposes are referred to in Action 6.A, interventions are provided of the nature highlighted in your request. These interventions must be extraordinary maintenance. As regards the extent of technical and planning/construction management costs (costs related to the professional services of a technician registered in a specific professional register), these are eligible up to a maximum of 5% of the costs pertaining to the works and purchases, such as required by the notice issued by the FLAG. Regarding VAT, this is eligible expenditure only if it is a final non-recoverable cost for the recipient; this eventuality must be self-certified by the recipient.