Ref. Ares(2015)3047182 - 20/07/2015
EUROPEAN COMMISSION
DIRECTORATE-GENERAL MIGRATION AND HOME AFFAIRS
Directorate E – Migration and Security Funds
Unit E1 – Programming
Brussels,
Subject:
Observations on the third version of the multiannual national
programme under the Internal Security Fund for Italy
Dear
Thank you for the amended version of the national programme under the Internal
Security Fund for Italy, submitted on 30 June 2015, following the observations made by
the Commission on the 24 June 2015.
Please be informed that the Commission has initiated the approval process of the national
programme. However, before proceeding to the next step of the formal approval by the
Commission, a few outstanding issues still have to be addressed.
We would therefore like to invite you to take into account the additional observations and
kindly ask you to modify the draft programme accordingly.
In order to proceed smoothly with the final stage of the approval process, an amended
version of the programme has to be submitted as soon as possible.
Kindly note however, that the programme could still be subject to modification
throughout the final stage of the approval process.
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
The national programme is now practically ready for approval, with only a few pending
issues still needing to be addressed.
Section 1: Executive summary
1.
We would appreciate if the executive summary could be redrafted in the sense of
presenting a coherent text with clear policy strategies, objectives and actions, rather than
just an enumeration of actions/activities.
Section 2: Baseline situation in the Member State
2.
Italy still needs to provide information on what are its needs with respect to first
reception, as requested before.
3.
The information on the state of play is appreciated; however, the information
provided on the needs as regards the implementation of Eurosur is still insufficient.
Section 3: Programme objectives
4.
The operational priorities where the bulk of the ISF/B allocation will be focused
are not yet clearly presented. Please revise the draft to provide more clarity on this
aspect.
SO1 – Support a Common Visa Policy
5.
Please note that the ICT systems related actions have a broader scope than just
Schengen Visa processing, therefore at implementation phase Italy should pay attention
to appropriate cost claims (proportionate to the share of workload related to Schengen
visa processing). Moreover, the ICT development should concern Schengen visa
processing.
SO2 – Borders
National Objective 2 – Information Exchange
6.
Please note that only illegal activities which are linked to the movement of
persons are relevant for ISF-Borders. Therefore, please, include a reference to
compliance with article 3.3 b), as discussed during the recent meeting in Brussels.
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7.
Please note that, in light of the identified need for increased inter-agency cooperation in
EU borders management, as indicated in the 2013 Guidelines for cooperation between Border
Guards and Customs Administrations, Spain is invited to provide information on the existing
customs cooperation in the baseline, as well as to include a strong component of inter-agency
cooperation in the actions planned under the national programme (i.e. structured exchange of
information, risk analysis, training, equipment, investigations, operational activities at Border
Crossing Points).
National Objective 4 - Union Acquis
8.
Please remove the reference to Annex 5 (additional document) which will not
form part of the national programme.
National Objective 6 - National Capacity
9.
Please note that the development of Smart Borders is already covered by the
Smart Borders envelope. Therefore, the activities that can be funded through the National
Program are limited to:
a) Border equipment, such as ABC gates (average price should be around € 200k), self-
service kiosks, equipment at Consulates such as fingerprint readers, equipment taking
facial image, mobile kits, etc. (I see that the use of ABC gates is already mentioned
under SO2 NO3)
b) Additional staff for project management, procurement, change management, helpdesk,
design, analysts, trainings for border guards and consulates/embassies etc., additional
staff to support law enforcement.
c) National infrastructure, such as end-user adaptation of border control applications for
EES/RTP, hosting space for national EES/RTP, network to connect the national
uniform interface to the national EES/RTP, connecting border control posts to the
national EES/RTP through national mobile communication network, security
infrastructure, etc.
SO3 – Operating Support
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Please replace “management of migration” by “border management”.
11.
As regards our previous observation n°40, which Italy did not take on board, we
would like to note that, as you know, for Italy's External Borders Fund annual
programmes 2007 – 2010, a 5% flat-rate financial correction was applied to the EU
contribution to the Fund on the basis of a finding of the European Court of Auditor's
performance audit on the EBF. According to this finding Italy had experienced
deficiencies in providing a solid justification for the financing logic and apportionment of
the costs for actions related to fibre-optic infrastructure providing communication
channels between the offices of Polizia di Stato. The same financial correction was
recently proposed by the Commission for the closure of the EBF Annual Programme
2011 on the basis of similar findings.
We note that in the draft ISF national programme, under the SO3 NO2 "
Operating
support for borders", Italy has included an action relating to technical assistance and
maintenance for fibre-optic infrastructure of Polizia di Stato (i.e. task 4.2 in Annex 7
"Operating Support Frontiere"). In order to prevent the risk that the eligibility of such
activities is put into question as in the case of the External Borders Fund, and that
financial corrections are consequently applied in the future in accordance with Art 47 of
the Regulation No 514/2014 of the European Parliament and of the Council, we strongly
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recommend that Italy establishes an apportionment key for the financing of this action,
which reflects the actual use of this infrastructure for the objectives of the ISF – Borders
and Visa. An alternative option could also be to simply remove this action from the
national programme.
Section 6: Framework for preparation and implementation of the programme by the
Member State
12.
Reference should be made also to coordination with ESF funded actions in general,
and in particular in the field of institutional capacity. The programme should also better
explain the demarcation line between actions funded through it and ESIF funded actions, in
particular the OP Legality.
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