Shadow report on implementation of the IPARD programme in Croatia 2010 - 2012

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Shadow report on implementation of the IPARD programme in Croatia 2010 - 2012

Edited by: Croatian Rural Development Network - HMRR and

                  ODRAZ - Sustainable Community Development

                  Zagreb, 2013


This report is based on the remarks and comments of 74 beneficiaries of IPARD measures, potential beneficiaries (32 LAGs) and 22 consultants who took part in a survey organized within the project "Together for sustainable development in Croatia" implemented from March 2011 to March 2013. Project was realized in partnership of ODRAZ as project leader, HMRR, SMART and Mileukontakt International. It was co-financed by the European Commission through the 1st component of IPA 2008 / Developing capacities of civil sector organisations for systematic monitoring and advocacy of sustainable development policies.


Based on the assessment of the interviewees, collected for the purposes of drafting this report, potential beneficiaries of rural development programmes are poorly prepared and unaware of what lies ahead concerning project application and implementation of measures. Preparations were insufficient and need to be strengthened and expanded. A far greater portion of activities related to animation, preparation and support in implementation needs to be transferred to the county and local administrative units.

The interviewees are satisfied with the improvements that are being introduced by the Ministry and the Agency. They point out guidelines for the implementation of measures, the list of most common mistakes, improved procedures and forms, the possibility of supplementing the application, decrease in the share of ineligible claims and increased support from responsible civil servants.   

According to the beneficiary assessment, the range of eligible investments in all IPARD measures is unjustifiably limited. When determining the eligibility criteria, real needs and various conditions in different parts of Croatia have not been taken into consideration. In line with the comments on behalf of the interviewees, the limitations are especially inappropriate when compared to the coastal and island parts of Croatia - for exp. the specific shape (scatteredness) and size of agricultural land plots, traditional disposition of farm facilities conditioned by climate and quality of fertile soil in rocky terrain and similar. Use of criteria which have not been based on primary IPARD goals, but have been defined in line with other purposes (for exp. criteria related to tourist areas, exclusion of areas A and B) has been pointed out as inappropriate. When the goal is to decrease the demand for assistance in a specific sector, i.e. eliminate too great a number of applications, more professional criteria based on IPARD goals should be sought out in that case. 

The fact that during the three years of implementation there have not been any contracted projects in six sectors[1], points to the need for analysis and revision of the relevant parts of the programme. Implementing bodies are investing efforts into removing the obstacles that are impeding the usage of assistance in some sectors, but for the purposes of an all-encompassing assessment and finding appropriate solutions potential beneficiaries should be included in the relevant processes.

Interviewees point to the absence of certain sectors which are specific to Croatian agriculture - for instance floristry and production of honey. The range of investments on offer also lack many additional features - for exp. creative possibilities to supplement activities and create additional income for agricultural households. In EU member states examples of such rural development projects are common. Judging by the collected responses, the beneficiaries of the measures under the 3rd priority also consider that the content of possible investments is too narrow and that rural communities should have a greater role to play in the choice of activities that should contribute to the creation of better living conditions in rural areas. This should be taken into consideration when defining priorities and measures for the new programming period.  

A great interest of project applicants and potential project applicants for the measures under the 3rd priority in comparison to a rather poor response to the measures under the IPARD 1st priority which had started with implementation first and have had the most frequent invitations to tender[2] is rather indicative. It can be assumed that the part of the reason lies with a more developed awareness and a higher level of informedness, or rather a higher education attainment level of the 3rd priority measures' beneficiaries. Nevertheless, the fact that the interest of the rural development stakeholders encompasses a much wider number of questions than those specifically related to agriculture and fisheries and that this framework should be broadened, should not be neglected[3].

It is unfortunate that the measures 202 - LEADER and 501 - Technical Assistance will start to be implemented at the end of the IPARD implementation period. The first LAGs, registered in the period between 2009 and 2011 could have been today more competent and ready for the role of the development generators in their areas and to transfer and exchange their experiences further. By postponing the implementation of the LEADER measure, one of the basic ideas of local partnership - joint activity of the local administrative units which otherwise do not have sufficient human and financial resources for the development of their own micro regions was negated.   

Coordination between the administrative bodies which take part in IPARD implementation is dissatisfactory on all levels in the sense of vertical connectivity. Civil servants in different governmental offices show lack of sufficient IPARD knowledge, do not understand the demands on behalf of potential beneficiaries, the glossary of commonly used terms has not been harmonised, the names and forms of certain certificates issued have not been unified etc. Disorganised cadastre and land registry data have shown to be an insurmountable obstacle in many cases. Overlaps and duplication of grants and subsidies have been noted, including loan schemes, awarded by different administrative and implementing bodies, which has confused potential beneficiaries. A certain portion of such overlaps has been addressed "along the way" with uncertain results, which in any case, even in the event of a favourable outcome, has still caused damage to the applicant or beneficiary.  

Interviewees believe that a certain part of the documentation that needs to be provided in line with the provisions of relevant ministries is in some cases too demanding - for exp. regarding environmental studies. Many complaints further refer to unjustified focus on unnecessary details in some of the provisions, which slows down the process significantly. Remarks regarding the insufficient level of trust among all the stakeholders in the proceedings seem justified, while the consequence of this are multiple checks of steps which have already been approved or authorisations on behalf of the relevant authority or service previously issued. 

The webpages of the Ministry and the Agency have been significantly improved which can be confirmed by the increasing number of visits and positive feedback on behalf of the interviewees. It is however a pity that there is still no general overview of improvements made to the programme, guidelines, implementing procedures and overall implementation in line with the changes to the IPARD programme.

Furthermore, dialogue, information exchange and communication with the beneficiaries, potential beneficiaries and all relevant rural development stakeholders has not been sufficiently developed. Two-way communication is missing, as well as more direct involvement of stakeholders into improvements made to the programme, along with the acquired experiences with regard to assisting new beneficiaries. Moreover, participants in the survey point to the lack of information which is important to them - deadlines by which their application will be processed, novelties in the range of eligible investments, reliable timeline with dates of publications of calls for proposals etc.

COSs have been unjustifiably excluded from IPARD, although they have demonstrated that they can contribute when it comes to provision of information, overall promotion, inclusion of all the relevant beneficiaries and provision of assistance in programme implementation. Removal of this obstacle should not be boiled down to including LAGs registered as CSOs into rural development programme implementation, but rather create the opportunity for the CSOs on the overall to participate in the programme and use programme assistance where appropriate. 

Insufficient clarity, as well as, it might be put so, incompleteness of national policies and programmes creates difficulties in the harmonisation of its guidelines at the operative implementation level. Implementation of rural development has been impeded due to incoherent or mismatched measures in the area of spatial planning, environmental protection, energy efficiency and renewable resources usage, legal ownership issues, water management and many other.

The issue of sufficiency of baseline analyses used in the development of the IPARD programme has not been taken into account within the scope of this report. The same applies to the lessons learned from the previous SAPARD programme. Nevertheless, bearing in mind the estimates and proposals made by the interviewees, it can be concluded that the analytical base is incomplete, especially with regard to specific requirements and limitations influencing rural development in certain parts of Croatia.  

Similarly, even from a quick look at the analytical base of IPARD, it can be concluded that the rural areas in Croatia have not been explored enough, moreover even regarding the basic definition of a rural area having a density of 150 inhabitants per square kilometer, which is too broad a definition in case of Croatia. A widely accepted differentiation between rural and urban areas at the level of Croatia is missing, and once set, it should be implemented in all of the relevant documents and data on population, settlements, employment, trends, economic indicators etc. Simply put, we do not know enough about our rural area. This crucial lack of knowledge should be dealt with promptly.   

The evaluation of the success of the IPARD programme implementation will be made only after the implementation has been fully completed. The main question at hand is: "Has IPARD adequately met the needs and expectations of the small and medium sized beneficiaries, or in other words, has it improved the living conditions in smaller rural communities, or has it largely benefited those who could have met their needs even without IPARD assistance?".

Suggestions and recommendations

Rural development in practice occurs on the lower levels - county and local. However, the institutions at these levels have not been included enough, or not even familiarised enough with IPARD. This should be changed.

It would be useful to find a way to continuously exchange the acquired practical experiences of the beneficiaries and the consultants, in order for them to be useful for the future beneficiaries of the rural development programmes. A possible solution is a specialised web-page, or using social networks created for that purpose.

It is necessary to increase the capacities for the provision of services related to the implementation of the rural development programme, especially regarding information, animation and promotion activities and expert leadership. CSOs can significantly contribute to information exchange and communication development, as well as intersectoral dialogue, which should have as its goal continuous monitoring and improvements of the rural development programme.

Information flow and publishing of practical information and guidelines should be significantly improved to create an environment for continuous communication, provision of short and clear responses to the beneficiaries' questions - such as, for example, what about the VAT, why is it eligible under some measures but not under others, how many loans have been granted, by which banks and under which conditions etc.

LAGs need to be capacitated to be able to act as local focal points of rural development in their areas. In the short remaining period of IPARD implementation, all available capacities should be used to make up for the late activation of measures 501 and 502:

- LAGs should be enabled to acquire the required knowledge and skills to carry out their functions of generators of local development - to follow the publication of invitations to tender, provide information, reply to questions to do with local development, support project preparation, offer technical assistance in project preparation, evaluate project proposals, involve local stakeholders into the drafting and implementation processes of the local development strategies etc.,

- ensure the participation / support to CSOs and other stakeholders who can help LAGs in strengthening their roles in line with the experiences of the European LEADER.

Drafting of new programme measures should effectively involve their potential beneficiaries from all parts of Croatia, so as to avoid the noted weaknesses of the IPARD programme - unjustifiable exclusion of certain sectors, possibilities to invest into activities for which there was no interest, conditions and criteria unsuitable for certain parts of Croatia (Istria, Dalmatia, islands). The way in which stakeholders are included should be changed, for instance - "reading the contents of regulations at workshops will not help reach the desired results", as pointed out by the interviewees.

The preparations for the following programming period should include consultants and beneficiaries who have gained valuable practical experiences; examples of good practice should be collected and published, and more so, in the language of the beneficiaries, and not the language of the regulations, since these would present the best type of promotion; CSOs should be further engaged in this area since they can reach the beneficiaries in the rural areas much more directly, as well as media and other professional providers of communication and information services.

The beneficiaries interviewed have proposed a range of smaller improvements which can be easily implemented, for example: more frequent publication of calls for proposals; when planning the timeline of publications of invitations to tender, taking into account the real circumstances - agricultural and construction work season, end of fiscal year and similar, shortening of the time necessary to process applications, creation of possibilities for joint investments, setting the obligation of being in line with the European standards at the end, rather than at the beginning of an investment, accepting smaller amendments which do not change the cost of the investment, without applying special procedures for that purpose, etc. 

According to the evaluations and comments of the beneficiaries of the measure 301, a number of smaller steps has been suggested relating to point 3.3., which could significantly improve the implementation procedure of public procurement according to PRAG rules, which has been a significant obstacle in earlier tendering procedures.

Regarding other points under chapter 3, the beneficiaries of the measures and consultants have also proposed a whole range of practical improvements in the content of the measures and implementing procedures which would surely improve the implementation and speed up the process flow, all of which will not be repeated in this report at this point.

Other simple improvements can also be implemented in coordination of programme implementation with other responsible official bodies, for example, by training the personnel in charge of issuing or verifying the necessary documents and certificates, extending their validity period, harmonising the formats and names of required attachments and wherever possible, accepting electronical submission of documents and certificates.  

What remains to be further addressed are the coordination tasks between ministries and other administrative and implementation organisations, whose achievement will require a longer period of time. This includes:

- land ownership issues - faster resolving needs to be supported;

- environmental protection demands - should be brought down to a reasonable level, corresponding to the extent of the planned investment and actual expected impact on the environment;

- harmonise the standpoints with regard to the use of grants and subsidies for the same or similar investments - overreaching cases, especially at measure level, should be dealt with promptly, unlike the one involving the use of renewable energy sources under measure 302, when the responsible bodies were still trying to reach a decision, while the potential beneficiaries, some of which have already prepared and submitted applications, did not know what they should do;

- the role of the banks should be clarified and presented in a way which is understandable to the beneficiaries - which terms and conditions are obligatory, what still needs to be negotiated etc.

We believe that the administrative body responsible for the implementation of the rural development programme should take over the responsibility of the coordinator of all the relevant activities, and unify all elements of implementation, regardless of the specific areas of responsibility. The beneficiary and potential beneficiary should receive all the necessary information and instructions on the practical steps they need to undertake in order to receive assistance.  

[1] 103.6 Olive oil sector, 301.3 Heating plants sector, 301.4 Fire prevention paths with forest roads' elements sector, 302.3 Direct sales sector, 302.7 Services sector, 302.5 Mushroom production sector.

[2] Eight implementation invitations to tender for measures 101 and 103 respectively, and only three tenders for measure 301 and four for measure 302 in the period 2010-2012. 

[3] Current preparation of the Rural Development Programme 2014-2020, as far as the insight the authors of this report have had thus far, does not prove existence of such a direction of the programme. 


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