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APPENDIX A

VIEWS: 4 PAGES: 13

									 EUROPEAN SOCIAL FUND 2007-2013 - A FRAMEWORK FOR
               THE EAST MIDLANDS
CONSULTATION DOCUMENT

Background

The ESF Competitiveness Programme for the East Midlands will run from
2007-2013 and has an indicative allocation of approximately £168.6 million
funding. The draft regional ESF Framework has been developed within the
context of the England ESF 2007-2013 Operational Programme, the Regional
Economic Strategy and the Employment, Skills and Productivity partnership
(esp) action plan.

All information and supporting documents can be downloaded from the
GOEM website at http://www.goem.gov.uk/goem/euro/struct-funds/ESF07-
13/devesf0713/

We would welcome views from stakeholders on the issues set out in the
questions below. Please respond to any questions which you feel are
relevant using the boxes provided - you can answer as many or as few
questions as you wish.

CONSULTATION QUESTIONS

Strategic context
The purpose of ESF frameworks is to set out how ESF spending will support
regional skills and employment needs and add value to existing regional
strategies and plans, within the context of the national ESF programme.

1. In light of this, do you feel there are currently any major gaps in provision
which could be addressed through ESF funded intervention? If so, please
provide details below.


A key weakness in the draft regional framework is the lack of baseline figures
and strategic targets. Targets, including qualitative and meaningful
quantitative targets, outputs, and indicative sub-regional allocations need to be
included if the framework is to help applicants and Co-Financing Organisations
(CFO’s) Crucially, an evaluation of the previous ESF programme is missing. A
proper evaluation of the outgoing programme is essential, in order to learn
lessons, build on good practice and avoid repeating any mistakes or
shortcomings. For clarity and increased transparency, a breakdown of funding
allocations by sub-region and the proposed methodology for allocating
funding should also be part of the Framework. Derby would wish to see some
flexibility in financial targets within the region, so that priorities at a local level
can be supported.

For the ESF programme to be properly targeted, the region / sub-regions and
localities must know and understand the baseline figures relating to all targets, what
ESF will deliver over and above current provision, how these figure relate to local



                                           1
communities and how much money is available to do this. Without this information
the added value of the programme is questionable, and the feasibility of the targets
cannot be assessed. In addition, a regional evaluation of the current ESF Objective
3 programme should be undertaken as a matter of urgency. The start of the new
programme should not be delayed for this. Rather we ask that the new ESF
Committee commission an evaluation as one of its first tasks, and implement its
recommendations as far as possible early in the new programme. The new
Programme should agree a clear evaluation process set out from the start to make
sure that the region continues to learn and improve the programme during its lifetime.
Performance around the delivery of ESF should also be included in the evaluation
process.

Another key gap is that activity to increase the pool of higher level skills is still
lower than what is needed in the region to ensure stable economic growth. At
the same time, there is an emphasis on lower level skills that could perpetuate
the regions ‘low skills low wages’ equilibrium. It is crucial that partners and
employers focus on increasing the higher level skills of the workforce to equip
local people to meet future employment demands. Recent experience in Derby,
has shown the potential of new developments in the city to generate a large number
of new jobs. A key challenge is to ‘capture’ a larger share of these vacancies for local
people in order to retain wealth in the city but also to help address issues of
disadvantage and deprivation. Low skill levels are recognised as a major potential
inhibitor to the success of the region in the RES1. Over the past 3 years, demand for
skilled, qualified and experienced labour has significantly exceeded supply in many
sectors and is set to increase. Increasing the proportion of economically active
adults at level 4 or above, capturing and utlising these skills will be crucial to the city
and region’s growth. If this cannot be done within the scope of the ESF Framework
due to national regulations, the region must come up with a clear strategy of how this
issue will be addressed outside of the programme.

The changing demographics for the East Midlands and the forecast of a rapidly
ageing population will have a big impact on our economy and labour market.
Actions to prolong the working life and use the skills of older people should be given
greater priority in the Programme. The impact that this demographic change will
have on household poverty in particular for households without an occupational
pension, needs to be taken into account. These households will need assistance to
reskill and access new training opportunities. There is likely to be a spatial
dimension to this, which could exacerbate the problem of multiple deprivation in
some of our communities. If we don't address this issue over the programme period
we will be simply shifting the problem of exclusion from one group to another and a
number of issues, including the problem of underemployment of older workers, will
emerge.

More emphasis should be put on targeted activities to help disabled people
access employment. Research from the Commission for Social Care Improvement
Partnership has shown that only 4% of disabled people in the region are in
employment but 40% would like to work. There are many hidden unemployed people
among the 10,000+ people on Incapacity Benefit in Derby. Activities to support
specific gaps in the Framework therefore include addressing the skills development
needs of disabled young people; flexible packages of support for people with learning
disabilities; engagement of socially isolated people, more bridging activities to
support disabled people leaving college and entering work and development of
opportunities in the intermediate labour market.
1
    Regional Economic Strategy


                                             2
Delivery of personal, social and cultural issues around learning should be
addressed through a community development approach which has a proven
track record for engaging hard to reach groups. This is a gap in the programme
as it stands and should be embedded in the Community Empowerment Strategy (for
further details see response to Q5). Initial confidence building and the development
of other ‘soft’ skills by a trusted individual working within a community is key before
certain vulnerable groups will take the next step towards more mainstream training
and skills development. This type of activity should be included in both priorities of
the programme, and appropriate milestones attached that recognises the importance
of these skills in the moving on process.




2. To what extent do you feel that the Regional Context section (building on
the evidence in the Regional Economic Strategy and esp skills priorities)
accurately reflects the employment and skills issues and challenges facing the
region?

Clearly, any ESF strategy developed within the region must sit within the framework
of the RES, plug the skills and productivity gaps in the region and provide value for
money with a sustainable framework.

However much of the evidence provided is at the regional level and identifies
regional trends and issues. It fails to adequately reflect and capture the diversity and
inequalities within the region. The Framework only presents a regional ‘snapshot’ of
employment and skills issue and this evidence has limitations. In reality the sub-
regional picture is much more complex We believe that local and sub-regional
employment and skills issues are not adequately taken into account in the ESF
Framework, and is a fundamental problem for local communities. There is a real
need for the ESF Framework to recognise its limitations and commit to working
with local partnerships – including Derby City Partnership and the Jobs and
Skills Group of our City growth Executive - to pick up local priorities and
target groups through the CFO 2 planning process. Only by doing this will CFO
policies and plans be properly tailored to local needs, and complement and build on
our existing and developing DCP strategies especially the Sustainable Community
Strategy and the Local Area Agreement.

In addition, the Regional Context section fails to properly take some key
developments such as the 3 Cities Growth Point into account at all. This may be
because of its dependence upon the flawed RES Evidence Base, which also fails to
consider the full impact of these types of initiatives. Hence, we feel that this section
misses out some major initiatives that will impact on the employment and skills needs
for the region.

E would want to see flexibility to target priority 1 and 2 activities most appropriately,
and get the right balance between them. For both priorities, the demand for skills as
well as the supply of skills must be increased, for ESF to make the strongest impact.
There is also the need for the right balance between producing quantity and quality in
programme indicators, outputs and outcomes. In some government funded

2
    Co-Financing Organisation


                                            3
programmes, there has been an emphasis on producing quantities of outputs and
outcomes, and this can be to the detriment of delivering quality programmes. Real
recognition of the value of soft indicators should be given, and the impact that
increasing these types of skills can have on a target disadvantaged group and/or
community, for example less crime/ anti-social behaviour. Impact evaluation at a
regional and local level taking into account less quantifiable outputs should be
encouraged, so that less tangible benefits of ESF support can be assessed.


Priorities
The Framework aims to set out an East Midlands focus within the national
ESF programme Priorities – Extending Employment Opportunities and
Developing a Skilled and Adaptable Workforce. It is important that ESF is
targeted effectively to tackle the region’s specific employment and skills
challenges within the parameters of the national programme.

3. Priority 1 – What are your views on the relative importance of the proposed
activities set out in Section 3?

Derby supports a holistic and integrated approach to priority 1, which aims to
tackle the full range of barriers that target disadvantaged groups face in
moving into employment or mainstream learning provision. All projects
delivered under priority 1 and 2 should also be centred on the individual needs to
provide a tailored support package for each beneficiary. Projects should be flexible
around these individual needs, rather than trying to fit the individual into a pre-
programmed, rigid structure. Given the reduced amount of funding to the region for
the programme, and the need to target the funding most effectively, we would
support a focused approach for priority 1, demand led in line with employers
needs and targeting the hardest to reach groups with multiple disdavantage.
These groups should include the underemployed as well as the unemployed.
This approach would help to underpin the crosscutting theme of sustainable
development, making sure that people are trained in sectors where there are jobs to
move on to, supporting social inclusion and helping to diversify the workforce. In
particular adequate funding needs to be available to cover participation costs for
disabled people and people with learning difficulties, for example carer support,
equipment to overcome physical and sensory impairments and appropriate transport.

For priority 1 beneficiaries proper work experience, job seeking skills and aftercare
support are key elements of the employment package to help support the cultural
shift from unemployment into work. This is especially important for the people who
have never worked. Aftercare seems to be missing from the indicative activities
and needs to be built in. Support for employers should be prioritised, to encourage
them to work with people with new and different needs. There has been limited
employer engagement in the outgoing programme - employers need to be brought
into the new programme and have a greater role in its direction and delivery.
There should be more focus on 'bridging' opportunities to engage businesses with
disadvantaged groups, and work with employers to change perceptions of some
target groups, such as some groups of NEET young people.

There has been a shift in learning provision away from first rung training towards
qualifications at level 2, in the current ESF programme. Whilst there is a need to
focus on gaining level 2 qualifications, first rung training has an important role to
play in impacting on social inclusion and lifelong learning, bringing people



                                          4
furthest from the labour market into it. We therefore feel that first rung provision
should be built in more explicitly for all priority 1 target groups. Organisations need to
work with some disadvantaged groups offering a range of activities over an extended
period in order to see results. For example, for people with learning disabilities a
longer-term and more intensive programme is required, to overcome barriers to
employment. This whole issue of appropriateness of targets and timescales needs to
be recognised when developing tender specifications and that indicators around
lower-level, basic and key skills should be included to reflect the value of this activity.


4. Priority 2 - What are your views on the relative importance of the proposed
activities set out in Section 4?


Priority 2 should not be seen as a lesser priority within this Framework. The
development of ‘a skilled and adaptable workforce’ should be as important as
bringing people into the labour market, otherwise the region will continue down the
‘high employment, low skill’ equilibrium path that it is currently stuck in. It is also
important to focus on these higher skills as part of the Lisbon Strategy. We are not
alone in the region in demanding greater development of employees with level 3 and
4 skills.

Again under priority 2 a holistic and integrated approach should be taken,
which addresses the range of barriers that target groups face. Activities should
be demand led, focusing on growth sectors and clusters within the region and those
at most disadvantage entering or in the workforce. The ESF Framework needs to be
broad and flexible enough to make sure it can address and respond to the key needs
of the region and our local communities. For Derby, a crucial omission in this
respect is creative industries which is a key sector identified in our City
Growth Strategy and needs to be included in the ESF Framework. This is also
the case in Nottingham and Leicester. Another omission is the financial and business
services sector at a sub-regional level, there are some significant employers in the
East Midlands such as Capital One, Barclaycard and Egg, who employ thousands of
people.

As stated in our response to Q1, in order to maintain competitiveness for local
economies adequate provision for higher skills is needed in priority 2. This will help
to raise the demand for skills and encourage those from lower/ intermediate skilled
jobs to move on. If support for higher skills dries up there will be no real progression
routes for the lower/ intermediate skilled groups.

Given the growth in migrant workers in Derby, there is a need for the inclusion
of activities to certify the skills of migrant workers, in the Framework. Again,
when referring to the need to increase the skill levels in the region to meet our
demand and in anticipation of physical and economic growth, the presence of what
we know to be a large pool of skilled and talented workers (often from the new
accession states of the EU), should be viewed as an untapped resource that should
be harnessed. To place a Polish teacher in a factory is a waste of economic
potential. Certifying skills of people whose qualifications may not be easily translated
ensures that every worker will have the opportunity to make the most of themselves,
and in so doing, will increase the productivity of labour within the region.

The activities set out in section 4 form part of the package to help develop a
skilled and adaptable workforce. However, the needs of employers are


                                            5
paramount, and employers don't always feel that NQV qualifications are right for their
business environment. Other non-assessed vocational qualifications such as short
courses and foundation programmes are equally if not more, relevant to employer
needs and these need to be included in priority 2. Community based and informal
programmes delivered by local authorities and the VCS sector have an invaluable
role to play in providing accessible and appropriate training, and as expressed below
this type of activity should not just be restricted to priority 1.

Again work with employers is critical. There is a perception among some
employers - especially SMEs - that investing in training will encourage employees to
move onto another job, once they are trained. Evidence shows this is not the case,
but it is still a real fear for employers and a barrier to investing in training. At the
same time, employers should be encouraged to fully utilise skills within their
workforce, helping to create better quality and higher level jobs.

In some growth sectors, the rate of change is displacing people within the industry
and they are becoming vulnerable to unemployment and redundancy. This is a
particular issue with older workers aged 45 and over. In this case ESF intervention
could help to identify and renew transferable skills of these target groups, allowing
them to move within an industry and retain their knowledge within it. Activities to
prolong the working life should be given greater priority.

Derby would also support the specific inclusion of the childcare sector within the
Framework, as growth in the number and quality of childcare places available
underpins the overall growth of the economy. Making childcare places available in
certain geographical areas, such as our prioirity neighbourhoods, and training
workers from specific groups, such as BME groups is also an equal opportunities
issue. Encouraging carers from diverse communities into childcare will help the
labour market become more inclusive and support the equal opportunities objectives
of the programme.

In terms of outputs and indicators, demonstration of skills is often more important to
employers than qualifications. In focusing on skills shortages, outputs need to be
related to both experience as well as being qualification driven. More recognition
should be given to the value of soft outcomes. Capacity building of individuals
and organisations should not be overlooked in the drive for qualifications.


The framework suggests using a community empowerment approach to
working with the most excluded people who are furthest from the labour
market. This approach was developed in the region during the 2000-2006
ESF programme. The national programme contains a proposal for a
Community Grant scheme worth 2.5% of the funding within Priority 1;
however some of the wider activities within Priority 1 could also use a
community empowerment approach.

5. What are your views on the use of a community empowerment approach
for some of the activity within Priority 1? How significant a part of Priority 1
should this be when it comes to allocating funding?

Derby strongly supports the principle of a community empowerment approach
to support the delivery of the ESF Framework. It will be essential for reaching
the hardest-to-reach groups targeted by the programme. However the



                                            6
Partnership could see no reason for limiting the CES 3 to Priority 1, and
benefits in extending it to priority 2. If it is to be effective, the proportion allocated
for community grants programme should be increased from 2.5%, and maximum
flexibility should be used in the rest of programme to make a strong impact.
           Community-based activity was limited in the outgoing programme by
              procedural problems, including the need to develop VCS / public
              consortiums. Where grass roots involvement is required, CFOs should
              not be driven by the desire to handle a limited number of contracts,
              but by the ability of each organisation to deliver. The region needs to
              learn from experience of the outgoing programme if the CES is to be
              effective. We have commented elsewhere in this response that the
              outgoing programme needs to be evaluated so that the new programme
              learns from good and poor practice. The operation of Global Grants and
              related mechanisms will be an important part of this evaluation.
           Local partners need to align action they take under the CES with the
              priorities of their LAA.
           A wide variety of agencies will be working to the CES, from large CFOs to
              small grass-roots community organisations. Because of this variety, and
              the importance of effective VCS engagement, the regional framework
              needs to provide a clearer definition of scope, and set out a firm basis to
              underpin constructive working relationships.


Cross cutting themes
There are two cross cutting themes in the ESF programme: equal
opportunities and sustainable development. The framework aims to set out
an East Midlands focus for the cross cutting themes.

6. What are your views on the regional issues identified within the cross
cutting themes? How can the cross cutting themes be effectively integrated
into the programme?

Derby supports the dual approach to Equal Opportunities in the draft Regional
Framework, of integrating Equal Opportunities across programme
management, as well as delivering specific projects. Systems and procedures
need to be accessible to all and the tendering process needs to be set up in such a
way that small community groups have a chance of being funded. Consortium
approaches may be appropriate in some circumstances but not all. It may also be
appropriate to commission particular activities related to the voluntary and community
sector.

For effective integration of Equal Opportunities into the programme, we need
to know and understand our baseline position. The programme needs to be set
up in a way that allows accurate Equal Opportunity data to be extracted at a project
level, for example measuring the take-up levels by organisations supporting
particular EO target groups. The biggest impact that could be achieved in terms of
equal opportunities outputs, is getting people from the disadvantaged groups into
jobs. Again, the needs and role of employers are critical. Training has a key role to
play, to make employers aware of relevant up-to-date legislation but also to raise
awareness among employers of the potential supply of labour among EO target
groups and the positive impact that they these groups can make in filling skills gaps

3
    Community Empowerment Strategy


                                            7
and diversifying the workforce.

 Systems and mechanisms for accessing funding should also be set up with the
needs of Equal Opportunity groups in mind. At each stage of planning and delivery,
equality implications should be considered and remedial measures put in place
where imbalances take place. All partners including voluntary and community
organisations, should play a full and equal role in the development and delivery of the
programme, and views from this sector and users and managers of the programme
should be given full consideration at all stages.

Derby strongly supports the implementation of a strong and aspirational
sustainable development theme across the new ESF programme. However, we
have some concerns about the approach, and without sustainable development
targets there is no guarantee that organisations will be committed to delivering
against sustainable development themes. Firstly, it is important that there is a
dual approach to sustainable development so that it not only applies to projects but
applies to the management and delivery of the programme.

Fundamentally, the sustainable development theme needs to link to market demand,
it is no good training people in sectors where jobs are declining. ESF needs to focus
on new and growth areas where there are skills gaps, so that strong and focused
economic development can take place. It also needs to translate into helping people
stay in jobs once they have got them, through aftercare support both for employee
and employer. More specifically in terms of environmental issues, investment in
level 3 and higher skills needs to be strengthened, as many of the environmental
technology jobs (developing low carbon technologies, renewable energy, energy
efficiency, recycling etc) will require higher level skills. We would like to see that
consistency carried across into the Priority 2 work.

A key gap in the current programme is the need for projects (and the
programme) to develop clear exit strategies linking into this theme to
encourage applicants to think about and plan for how they will support
beneficiaries in the longer term. This is important for all beneficiary organisations,
but particularly for the VCS who are still marginalised from many mainstream and
longer term funding programmes. The process for mainstreaming of best practice
projects should be clear and strongly encouraged so that they are not lost and
sustainability is ensured. It is our view that this should be clearly indicated within the
draft Framework.


Innovation
An element of funding within Priorities 1 and 2 will be set aside to support
innovative approaches to delivering ESF priorities. (NB Please note that the
term “innovation” is used in ESF in a different sense to that used in the East
Midlands Innovation Strategy. In ESF it means trying new and/or creative
ideas or approaches to address skills and employment needs). Dedicated
innovative projects will be encouraged to establish trans-national links.
Themes for innovative projects will be chosen from a national list. The East
Midlands ESF framework proposes themes for inclusion in this list based on
views expressed in earlier consultation with stakeholders.

7. What are your views on the proposed themes to be addressed through
innovative and/or trans-national activities?


                                            8
It is important that innovative activity is part of an overall cohesive package of ESF
support, which fits within the strategic package in the region, aims to successfully
solve a problem in a new way, learn from that process and implement what works
into mainstream provision. It is important that there continues to be a flow of
new and original solutions to economic and employment problems.

While we support the view that all transnational activity should be innovative, we do
not believe that innovative activity should be contingent on the need to work
transnationally. For projects that do work transnationally, the added value of doing
so needs to be explicit.

Projects that are truly innovative at a local level may take longer to achieve results
and cost more. Targets may need to be amended and need to be meaningful and
relevant. This needs to be recognised at a programme level. Particularly in terms of
innovative projects, the region needs to learn from what has worked in past
programmes and build on this best practice. We have many innovative projects and
practice that has already been evaluated – the problem has been how to ensure this
best practice can be effectively mainstreamed.

One way of delivering the innovative aspect of the programme, could be by engaging
people in learning through other agendas. This has proved to be successful in the
region with particular groups, for example using arts, fitness and healthy living to
switch them onto learning. There may be an important role for the VCS in this
activity by reaching out to new groups that statutory agencies tend not to attract, and
delivering activity in less conventional ways.


Links with other funding streams
The ESF programme should complement and add value to other funding
streams available to the region - it should not displace or duplicate other
funding programmes.

8. To what extent will the proposed areas of activity in the framework allow for
consistency and alignment with regional, sub-regional and local initiatives e.g.
Local Area Agreements, Neighbourhood Renewal programmes?

As stated in our response to Q2, the Framework presents a rather one dimension
regional view, whilst in reality the sub-regional picture is much more complex.
Strong mechanisms to work with local partnerships need to be set out in the
Framework, to identify sub-regional ESF activities and make sure that they
work alongside and complement local initiatives. The vision and aspirations of
the ESF strategy must be based on deliverability at a local level.

Derby supports the idea of aligning ESF with our Local Area Agreement and we are
pleased that an option for doing this is on the table. In order to maximise
effectiveness of the funding available it is vital that ESF spending can be co-
ordinated with our Sustainable Community Strategy and the Strategies and Action
Plans of our City Executives, especially City Growth, but also with the Children &
Young People, Cultural City and Safer & Stronger Community themes. There is a
strong argument for using ESF to add value to LAAs and help us to get best value for
money in delivery of local services. It is possible that ESF investment could be used
to support the enhancement of the LAA, for example by rolling out the benefits



                                            9
delivered under one of the LAA blocks to other target groups or areas. On this issue
we urge regional partners to take forward thinking around this by engaging in
discussions with representatives involved in delivering LAAs without delay.
We would be happy to work with the ESP and local CFOs to explore how this might
work in practice taking into account proposals for future development of LAAs, such
as the Multi-Area Agreements proposed in the Local Government White Paper. The
programme also needs to keep pace with developments in the labour market, the
end of current funding programmes such as the NRF and new government initiatives
such as a possible Round 3 Local Enterprise Growth Initiative (LEGI) bid. Better
longer terms planning needs to take place to prepare for the phasing out of the
programme towards the end of the programme period in 2013, and a clear exit
strategy developed.

In the last programme there has been a trend towards developing regional tenders to
provide local services. This can lead to organisations with a regional remit but no
local knowledge being appointed. Local organisations are best placed to deliver
local services tailored to the needs of local areas. Regional tenders that do not
allow for discrete local areas to be supported should therefore only be developed
where there is a clear rationale for such intervention.


9. How can ESF be effectively integrated with the European Regional
Development Fund programme in the East Midlands, in terms of strategy and
implementation?

Derby strongly supports the option of setting up a joint ERDF/ESF regional
committee, to properly join up the strategic and delivery arrangements for the
two programmes. ESF and ERDF are part of the European Competitiveness and
Employment Objective, and have to deliver against the same Lisbon Agenda for jobs
and growth. One single Committee will help to ensure complementarity between the
programmes. Though the region may intend to join the programmes up by other
means, without a joint Committee, the programmes could drift away from each other
over time, and potential duplication and gaps in provision could emerge.

In terms of the make up of such Committee, it should be fully representitive and
agreed by regional partners with a fair balance reflecting the thematic and
geographic coverage of the programme, as well as inclusive of elected members and
employer representatives and specific sector groups. Derby feels strongly that any
Committee structure should include a Local Authority representative from each part
of the region, to input local views to the programme and speak on behalf of their
area. A reduction in the numbers of local authority reps will mean that the strategic
overview for the programme will become more distant from the delivery.

A true value added ERDF/ESF programme should be guided by strong regional
structures. Derby suggests that rather than 'standing alone', this Committee is
embedded in existing structures, and information is disseminated to Local Strategic
Partnerships and SSPs 4. Mechanisms for feedback and communication need to be
strengthened, and this should form part of the Terms of Reference for the Group. A
key role of the Committee should be to ensure effective integration of the
programmes with local priorities such as those contained within our Sustainable
Community Strategy and LAA as well as the DDEP Investment Framework.


4
    Sub regional Strategic Partnerships


                                          10
In terms of effective integration of the programmes, we wish again to raise the
issue of the divergence between ESF and ERDF programmes in terms of skills
needs. This issue still has not been addressed and the region needs an answer to
the question over the provision of higher level skills to support the implementation of
the ERDF programme. If this cannot be done within the scope of the ESF Framework
due to national regulations, the region must come up with a clear strategy of how this
issue will be addressed outside of the programme.

Those who require support through ESF are often in the sectors which are not
mentioned in the ERDF and RES, therefore there is an issue with regards to aligning
these initiatives. More clarity around how ESF can be used to impact effectively on
ERDF is needed.

We feel strongly that implementation arrangements should be based on the
streamlining of processes and paperwork. ESF bureaucracy is still too complex and
this can exclude certain groups from applying, and put an unnecessary burden on
CFOs and applicants.      Equal Opportunities should apply to the implementation
arrangements and systems and procedures should be set up with Equal Opportunity
considerations in mind. There should also be a strong mechanism to ensure that
Outputs and Outcomes are not double counted.


Co-financing
All ESF funding in the East Midlands will be delivered through the co-financing
system. Co-financing was introduced in the 2000-2006 ESF programme and
channels ESF through public bodies that match ESF with domestic public
funding and then let contracts to organisations to deliver projects.       Co-
financing organisations will develop co-financing plans based on the priorities
identified in the framework. These plans will set out in more detail how ESF
will be delivered locally.

10. To what extent does the framework give a sufficient strategic steer to co-
financing organisations?


The regional ESF strategy should include a clear mapping of current initiatives and
gaps in provision, from which local CFO plans can be produced for both priorities. In
this respect the Framework does not give enough strategic steer to CFOs. It is
important that ESF support is distinct but complementary to other key programmes.

As mentioned earlier, local CFO plans need local input to address the needs and
priorities of Derby and should work together, not independently. We would like to
see the consultation arrangements for the development of CFO plans set out
explicitly as part of (i.e an Annex to) the ESF Framework. We would suggest as
a minimum, that Derby City Partnership is formally consulted.

Other comments we wish to make on the ESF tendering process are…
 A fairer and more transparent system for appraising and selecting projects should
   be set up. The mechanism should be democratic and representative and it
   should be clear to all parties who the decision-makers are. Learning from the
   implementation of similar grant schemes should be taken into account.
 There should be some mechanism to allow applicants with match funding to
   count this into the programme as leverage, and therefore draw down a lower



                                          11
   percentage of ESF funding in relation to their project.

Finally, it would be useful to include an ESF section on the DCP website allow local
people to find out what ESF-funded projects are being run in the city, and in which
they can get involved. Too often, projects are aimed at one particular 'community'
and because there is no information point which allows people from other
communities to find out about the project, ESF funding is not as inclusive as it could
be.




Your details

Your name: Alec Shelton

Your organisation: Derby City Partnership

Address: DCP Centre, 7th Floor, St. Peter’s House , Gower Street

County: DERBY

Postcode: DE1 1SB

Email: alec@derbycitypartnership.co.uk



How to Respond

The closing date for this consultation is 5pm on 27 July 2007. Please submit
your response by email to: goem_esf_consultation@goem.gsi.gov.uk

Whilst electronic responses are preferred, hard copies can be sent to:

Meryl Whittington
New European Programmes Development Officer
Government Office for the East Midlands
The Belgrave Centre
Stanley Place
Talbot Street
Nottingham
NG1 5GG




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Confidentiality and Data Protection

Information included in responses to this consultation, including personal
information, may be subject to publication or disclosure in accordance with the
access to information regimes (primarily the Freedom of Information Act 2000
(FOIA), the Data Protection Act 1998 (DPA) and the Environmental
Information Regulations 2004 (EIR)). If you want other information that you
provide to be treated as confidential, please be aware that under the FOIA,
there is a statutory Code of Practice with which public authorities must comply
and which deals, amongst other things, with obligations of confidence.

In view of this, it would be helpful if you could explain to us why you regard
the information you have provided as confidential. If we receive a request for
disclosure of the information, we will take full account of your explanation, but
we cannot give assurance that confidentiality can be maintained in all
circumstances. An automatic confidentiality disclaimer generated by your IT
system will not of itself be regarded as binding on GOEM.

GOEM will process your personal data in accordance with the DPA and in the
majority of circumstances this will mean that your personal data will not be
disclosed to third parties.

If you have any queries regarding the consultation or any issues regarding
data protection, please email us at: goem_esf_consultation@goem.gsi.gov.uk




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