Ref. Ares(2015)2649069 - 24/06/2015
Ref. Ares(2018)3430863 - 28/06/2018
EUROPEAN COMMISSION
DIRECTORATE-GENERAL MIGRATION AND HOME AFFAIRS
Directorate E – Migration and Security Funds
Unit E1 – Programming
Brussels,
Subject:
Observations on the proposed multiannual national programme
under the Internal Security Fund for Italy
Dear
Thank you for the second version of the national programme under the Internal Security
Fund for Italy, submitted on 8 June 2015, following the observations made by the
Commission on 6 February 2015.
Following the re-examination of the national programme by the Commission, we would
like to provide you with additional observations on this amended version, and invite you
to present us with a modified programme as soon as possible.
The Commission stands ready to assist you in the drafting process in order to facilitate
the approval of the national programme.
The period of six months, set for the approval of the multiannual national programme by
the Commission, referred to in Article 14(7) of Regulation (EU) No 514/2014, is hereby
suspended until an amended version of the programme is provided.
Yours sincerely,
(e-Signed)
Head of Unit
Encl.: Annex: Observations on the proposed national programme
Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.
ANNEX: Observations on the proposed national programme
General
1. The mostly used acronyms need to be first introduced in the programme (not the
glossary) as long as this is allowed by the character limit.
2. In line with Art. 9.4 of the ISF/B Regulation, the Commission consulted Frontex
on this version of the draft NP. The Commission took the appropriate and
relevant suggestions of the Agency into account.
Identification of the designated authorities
No further comments.
Section 1: Executive summary
3. With regard to the text of the executive summary:
a) Could you avoid the use of abbreviations?
b) Could you structure the text using the names of the Specific Objectives?
4. The executive summary does not summarise actions in: SO1/NO3, SO2/NO5,
SO2/NO2, SO3 and it only summarises a part of the SO5/SO6 actions. The whole
section needs to be carefully redrafted (eventually removing also the first two
paragraphs) given the high number of actions foreseen in the programme.
5. The summary states that the programme intends to improve “
the prevention and
combating of organised crime, including through the extension and reinforcement
of the strategy of confiscation of mafia assets in the context of cooperation
between Member States against transnational crime;” and “
strengthening of the
prevention activities and supervision of attempted Mafia infiltration in public
procurement and intensification, to protect the legal economy, measures to
combat the laundering of illicit proceeds acquired by cosche”. It is to be noted
that the 2014-2020 (Italian) National Operational Programme on Legality also
includes investments for the rehabilitation of confiscated assets in favour of
immigrants and actions to improve public procurement. Possible synergies and
overlaps should be clarified (in section 6).
6. Within a sentence in the end of the ISF Borders part of the executive summary,
please indicate the allocations for the different Specific Objectives as well as for
Technical Assistance (for ISF Borders including the allocation for the Specific
Actions). Same for the ISF Police part. In both cases the percentages should add
up to 100%.
Section 2: Baseline situation in the Member State
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7. The statistics/figures in the Visa/Crime/Risks part needs to be as recent as
possible (2014 ones). The Borders part is OK.
8. SO5/SO6: There are no needs mentioned regarding THB, illegal waste trafficking
and food chain protection.
9. The information for SO6 is provided together with the one for SO5. This element
should be made more explicit.
10. The needs/gaps analysis and description for the Borders part needs to be
reinforced (Italy to apply the logic of intervention - e.g. for the Information
Exchange NO).
11. National spending in the area of border management needs to be clarified. It is
appreciated that Italy provided some figures per type of activity. It is indicated
that the amount spent on internal security is 398 M euro, but is would be useful to
have a total one for border management in particular.
12. Please, provide information on the state of play of Italy’s first reception capacity.
13. SO2 Borders, NO1 Eurosur: Which national authorities cooperate in the NCC?
What are the operational needs related to purchase of equipment? How are the
existing maritime surveillance systems interconnected?
Section 3: Programme objectives
14. It should be clear reading the National Objectives what are the areas of
intervention where Italy intends to put its focus, with particular reference to the
most important (also in terms of allocation) national objectives (e.g. Eurosur,
Information exchange, National capacity) where, besides the list of all possible
actions to finance, those where Italy intends to focus should be highlighted.
Moreover, per National Objective, it needs to be made explicit and clear which
actions will be financed via ISF and which with national funds. The funding
priorities under each National Objective need to be indicated so that the focus of
the EU financing is well demonstrated.
15. It seems that some Policy Dialogue identified funding priorities are not pursued
with actions in the programme. Please provide an appropriate explanation for the
cases where Policy Dialogue funding priorities have been dropped or otherwise
please indicate how the programme considers them. We make reference to the
following funding priorities:
Trafficking in human beings – all funding priorities
Anticorruption policy – the first four (out of 5)
Financial investigations - the first one (out of 2)
Information exchange mechanisms - all funding priorities
EU policy cycle - the last one (out of 3)
Cybercrime - the last four (out of 5)
Radicalisation – the first and the last three (out of 5)
EUROSUR – the 4th, 5th and 7th (out of 7)
SO1 – Support a Common Visa Policy
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16. The presentation of the national strategy should be improved so as to clarify
priorities with further details and distinguish between national actions and
funding priorities. It refers still to the Stockholm Programme.
17. The ICT systems related actions have a broader scope than just Schengen Visa
processing, therefore at implementation time Italy should pay attention for
appropriate cost claims (proportionate to the share of workload related to
Schengen visa processing). Moreover, the ICT development should concern
Schengen visa processing.
National Objective 1 National Capacity
18. For National Objective 1 (and SO2/National Objective 6) there's no prioritisation
regarding the actions foreseen and the fund allocations are considerable. Italy
should provide in a separate document (not part of the programme to be adopted)
an approximate breakdown of funds assigned to the actions of these National
Objectives (either in absolute amounts or in percentages of the total allocation to
the National Objective).
National Objective 3 Consular Cooperation
19. Since no actions are planned for ISF funding in the area of consular cooperation,
National Objective 3 should either remain empty or only explicitly refer to
actions funded via national funds only. The part currently present in National
Objective 3 can be moved either to the strategy part of SO1 (eventually some part
of it in the Baseline).
Specific Action Consular Cooperation
20. The programme makes reference to two specific actions lead respectively by BE
(CCM) and NL (RSCO).
a. Concerning CCM: the description does not mention the fact that this
action will be implemented at the central level and in the field, and also
that there will be deployment of joint document verification officers, both
quite important aspects. Also, it isn't mentioned that Italy will participate
financially (although it is not entirely clear from Belgium's description
whether this has been agreed upon already).
b. Concerning RSCO: it should be explained in the text what an RSCO is i.e.
a person working on behalf of partner MSs and also the role of Italy as
Participant MS and whether Italy will participate with a financial or in
kind contribution.
SO2 – Borders
21. On the strategy for border management, the Commission appreciates the
information provided in the additional documents. More information on the
implementation of IBM model are still necessary: practical mechanism to
improve coordination and cooperation between internal stakeholders, practical
measures for improving border management based on a thorough needs analysis
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and the future plans as well as coordinated communication with the aim of
improving risk analysis practices.
22. Please describe in more details the cooperation, communication and coordination
mechanisms between the national authorities dealing with border control – checks
and surveillance (Polizia di Stato, Guardia di Finanza, Guarda Costiera, Navy,
local authorities – chesturas).
23. Although cooperation agreements with third countries are described in the
Strategy, there are not related actions described later on in the national objectives
(except the one on experts).
National Objective 1 EUROSUR
24. In case there are actions proposed here which are maintenance related, it is
suggested to move them under SO3 so as to optimise Italy's financing as to these.
National Objective 2 Information Exchange
25. For certain ICT systems cases (e.g. SATM) it should be noted that the funding
allocated will be proportional to the usage of the system related to Border
management. Please indicate in the text of the programme that the border
management related aspects of these systems will be financed with the ISF/B.
26. For the various ICT systems mentioned, it should be clarified in the programme
what measures exactly will be funded with ISF/B.
27. Regarding the equipment used for SAR: the phrasing should be such so as to
indicate that the equipment is purchased for border management activities and
will also be used for SAR operations (see Article 3.5 of the ISF/B Regulation).
National Objective 3 Common Union Standards
28. Please provide in a separate document the possible locations of the planned ABC
gates as well as an indication of their number. Please, note that this information is
indicative (not binding).
National Objective 4 Union Acquis
29. Please provide more information regarding the last bullet point (best practices) in
order to clarify what exactly is meant and in the case this action is maintained
please rephrase.
30. Italy is encouraged to consider setting up a continuous training concept based on
the train-the-trainer approach in areas such as first and second line of control,
screening and debriefing.
National Objective 5 Future Challenges
31. In the 1st bullet point reference to PNR should be removed.
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32. The 2nd bullet point needs to be rephrased to become more specific as to what it is
intended to fund. If still early to provide more details at this stage, please indicate
that these will be instruments and national systems for border control.
33. In the last paragraph it should be specified that the indicated measures relate to
crime linked to the movements of persons, and not cross-border crime in general
(see Art 3.3(b) of the ISF Borders Regulation).
National Objective 6 National Capacity
34. For National Objective 6 (and SO1/National Objective 1) there is no prioritisation
regarding the actions foreseen while the fund allocations are considerable. Italy
should provide in a separate document (not part of the programme to be adopted)
an approximate breakdown of funds assigned to the actions of these National
Objectives (either in absolute amounts or in percentages of the total allocation to
the NO).
35. Given the purposes of EURODAC, please clarify its usage, noting that ISF/B
could only finance measures relevant to Border management and used at the
border.
36. Financing SAR measures need to be in line with Article 3.5 of the ISF Borders
Regulation.
37. Regarding the cooperation with 3rd countries, the Commission appreciates the
extensive information provided in the annex. However, it is still needed to define
in the programme the priorities, objectives and concrete actions for the initiatives
to be undertaken vis-à-vis 3rd as well as the limits (scope) of financing such
activities within the cooperation agreements (e.g. these are actions only on Italian
territory, mostly related to the exchange of best practices and information as
opposed to purchasing equipment to be used by 3rd countries' authorities).
38. In the last paragraph, please add an explanation so as to be clear whether the
experts mentioned are ILOs or not.
39. Italy is encouraged to strengthen its capacities as regards screening and debriefing
activities at the border in order to improve and systematise the interviewing,
fingerprinting and registration of migrants with the aim of better managing
migration flows and gathering additional information which could further feed
into risk analysis activities.
SO3 – Operating Support
40. National Objective 2: for the same reasons expressed in our letter
Ares(2015)1967740 sent to your services on 8 May, we suggest removing the
action related to the fibre-optic infrastructure as there is a high risk that problems
concerning the eligibility of the expenses related to such action might arise.
SO5 – Preventing and combating crime
National Objective 1 Prevention and Combating
41. There is no mention regarding the desired outcome(s)/result(s).
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42. Regarding whistle-blower protection it should be stated whether the programme
will fund any actions or not.
43. Please provide more details regarding the action on hardware and software for
anti-corruption units at the police: "acquisizione di HW/SW per il potenziamento
delle Sezioni/Unità Anticorruzione delle Squadre Mobili di PS".
National Objective 4 Victim Support
44. Italy declares that no funding from ISF is necessary for this National Objective.
However, some actions undertaken with national funds should be mentioned
within these two national objectives. In addition the possibility for future
introduction of actions (so as to avoid the need for revision) should be indicated.
Same comment for National Objective 5 Threat and Risk assessment.
SO6 – Risks and crisis
National Objective 4 Victim Support
45. Italy declares that no funding from ISF is necessary for this National Objective.
However, some actions undertaken with national funds should be mentioned
within these two national objectives. In addition the possibility for future
introduction of actions (so as to avoid the need for revision) should be indicated.
Indicative timetable
46. We take note that (as confirmed by you in the 15/6 meeting) no actions start in
2014.
47. SO2/National Objective 6: only two actions are mentioned under this important
National Objective: please list at least the three most important ones.
Section 5: Common Indicators and Programme Specific Indicators
48. Specific Objective 1 / C1: value is still 4 but should be 0.
49. Specific Objective 1 / C3: please clarify what the figure of 40 refers to.
50. Specific Objective 1 / C4.2 indicates that 99% (172) of Italy's consulates will
benefit from the fund. However, the focus of the fund should be on Schengen
issuing consulates. Please clarify.
51. Specific Objective 2 / C2 & C3.1 & C3.2: values to be updated in the next
programme version. For C2, a breakdown should be provided by category.
52. Specific Objective 2 / C5: please give an estimate based on past years
information.
Section 6: Framework for preparation and implementation of the programme by
the Member State
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53. Observations 27 and 28 on version 1.0 need to be addressed in the next
programme version.
Section 7: The financing plan of the programme
54. The amount for SA1 should be removed.
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