Vincenzo Gesmundo – the head of Coldiretti’s chiefs – had already announced to his generals/directors on 25.3.21 that the projects earmarked for agriculture within the PNRR ‘in essence are signed at the bottom of the page by Coldiretti,’ ‘because when Coldiretti does Coldiretti there is none for anyone!‘ (1) Nothing could be truer, one would say, looking at the provisional results of the Fifth Call for Supply Chain Contracts in the Agribusiness Sector, published on 6/30/23. #CleanSpades.
1) Supply chain contracts, the announcement
The notice was introduced by then Minister of Agriculture, Food and Forestry Stefano Patuanelli by DM 22.12.21 no. 673777, for supply chain contracts with investments totaling between 4 and 50 million euros.
The measure is financed by the NRP Supplementary Investment Fund, with an allocation of 1.203 billion.
Of this, 350 million financed the sliding of the rankings of the Fourth Call, and the remaining 850 million is expected to finance the Fifth Call.
1.1) Beneficiaries
The beneficiaries of the funding are both enterprises that directly contribute to the production, harvesting, processing and marketing of agricultural and agri-food products and enterprises that provide services and means of production.
The facility is reserved for enterprises that sign a supply chain agreement, in a multi-regional territorial scope, aimed at implementing an integrated interprofessional program of national significance.
1.2) Allowable investments
Eligible investments include:
– tangible and intangible assets on farms, related to primary agricultural production,
– Processing of agricultural products and marketing of agricultural products,
– Processing of agricultural products into agri-food products,
– Participation of producers of agricultural products in quality schemes and promotional measures for agricultural products,
– Organizing and participating in competitions, fairs or exhibitions,
– Agricultural research and development projects,
– Participation in trade fairs,
– Energy production from renewable sources by processors.
2) NRP and supply chain contracts, Coldiretti ‘ace picker’
It is too early to comment, and it will be the administrative judges-following the anticipated appeals-who will assess the propriety of the actions of the Ministry of Agriculture, Food Sovereignty and Forestry (MASAF) in awarding the funding under consideration.
It is easy, moreover, to note the dominant role of Coldiretti, as the ‘ace picker’ of the measures allocated in this PNRR call. Among the protagonists in the presentation of projects eligible for funding are the names of some figures from Coldiretti’s magic circle, such as:
– Raffaele Grandolini, the ‘King Midas’ of Palazzo Rospigliosi (2.3), custodian of no less than seven approved projects out of a total of 38, in the Fifth Call for Supply Chain Contracts,
– David Granieri, president of Unaprol and Op Latium, on the board of national Coldiretti as well as president of Coldiretti Lazio and Coldiretti Roma (4,5,6). 4 projects approved out of 38.
The stone summoner is Alessando Apolito, a former director of the Ministry of Agriculture who has always been involved in and continues to follow supply chain agreements, first at MIPAAF and then at Coldiretti, as seen. (7)
3) Premeditated opacity
The opacity of MASAF’s handling of the Fifth NRP call on supply chain contracts is premeditated. At least as of its substantive changes, made just before the deadline for submitting applications closed:
– the notice was amended, a month before it closed, in crucial parts such as the intensity of non-repayable grants and the requirements for bank guarantees. Of absolute importance, given the failed experiences of projects that have drained public resources without being implemented due to the financial inability of their beneficiaries,
– the application deadline was extended by one month, one week before both deadlines. So that applications increased tenfold, from 34 (649 companies) to 309 (6,521 companies), to reach 5.174 billion in total demand, with 690 million in available resources.
4) Planned arbitrariness
The arbitrariness of the assessments of the questions was in turn planned in time:
– in fact, the system of criteria and indicators that determine the final score of each project includes three criteria whose estimation is left to the mere subjective assessment of the evaluation committee, (8)
– the evaluation committee was thus able to award 12 points at will, (9) which equals the difference between the first ranked project (91.82 points) and the 237th ranked project (79.71 points).
5) Covert transparency
The ‘transparency’ of the procedure was concealed to perfection:
– the Ministry of Agriculture (MASAF), after the deadline for submitting applications closed, has not released official data on the number and size of projects submitted. Nor did it disclose the outcome of the first preliminary verification of admissibility and formal admissibility of the applications themselves,
– the ranking list published on 6/30/23 does not even indicate the number of projects accepted. Thus, they are assumed to be 38, adding up the relevant amounts to reach the 690 million euros first indicated by Minister Francesco Lollobrigida on 5/24/23 in a hearing before Parliament,
– the identity of the members of the evaluation committee is still unknown, seven months after its appointment, which should have occurred by DM 5.12.22 no. 621652. Ministerial decree still not published in the Official Gazette or on the MASAF website.
5) Barriers to the exercise of rights
The Ministry of Agriculture (MASAF) has given a very short peremptory deadline-10 days instead of the ritual 60 days-to submit appeals against the ranking list published on June 30, 2023. Alleging extreme urgency, after some years of delay, in dealing with the PNRR. However, this term seems more like an unacceptable barrier to the exercise of rights. All the more so where one considers that:
– parties entitled to appeal thus do not even have the material time to obtain access to the records, even before they are able to prepare appropriate appeals,
– the published ranking indicates only the total scores, failing to disclose the points awarded on an objective basis (on which clerical errors cannot be ruled out) with respect to the arbitrary criteria (see section 4 above),
– The identity of the members of the evaluation committee is unknown to date. Claimants are thus unfairly deprived of the time essential to check possible conflicts of interest, already observed in other anomalous calls to the same ministry (10,11).
6) NRP and organic supply chain, what resources?
‘Twenty-five percent of the aforementioned sums [PNRR resources allocated to supply chain contracts in agriculture, ed.] shall be allocated exclusively to Italian organic production obtained in accordance with European and national sector regulations‘ (DL 59/2021, Article 1.h).
MASAF coldiretto-in addition to boycotting the proposal to reduce pesticides in agriculture-has already tried to boycott support for the organic supply chain, as reported (12,13). Now, where did the exclusive reservation for organic production of 25 percent of the allocations under consideration go?
7) Interim Conclusions
It is better to understand why the Italian government managed to get the crime of abuse of office repealed, after 93 years of honored service from the first fascist regime to the second, or third republic as it may be.
The Italian judiciary must overcome the shield of the Agromafie Observatory and investigate with independence, in accordance with state law. To check – even administratively – for other crimes, if any, in this great welter.
Dario Dongo
Notes
(1) Dario Dongo. National pesticide action plan, sustainable agriculture and NRP. #CleanSpades. GIFT (Great Italian Food Trade). 4.2.22
(2) Dario Dongo. Federconsorzi 2, CAI SpA, AgriRevi, Coldiretti. The dinner of jerks. GIFT (Great Italian Food Trade). 31.1.21
(3) Raffaele Grandolini, among the very many positions in regard to which the possible existence of conflicts of interest has already been reported, is also an advisor to the Agromafie Observatory. Who in turn recently distinguished himself through an outlaw operation. V. Dario Dongo. Coldiretti, the Agromafie Observatory and the Customs Agency Porsche. The document. GIFT (Great Italian Food Trade). 25.6.23
(4) Dario Dongo. Coldiretti and Unaprol. The uncertain fate of public funds intended for Italian olive growers. GIFT (Great Italian Food Trade). 6.2.21
(5) Dario Dongo. Germina Campus, Coldiretti’s holding company speculating on farmers. #CleanSpades. GIFT (Great Italian Food Trade). 13.6.21
(6) Dario Dongo. UNAPROL, AIPO and Oleificio Paladino, spot conflicts of interest. #CleanSpades. GIFT (Great Italian Food Trade). 13.1.22
(7) Dario Dongo. Public administration, loyalty to the state or to Coldiretti? #CleanSpades. GIFT (Great Italian Food Trade). 27.6.21
(8) Subjective and arbitrary project evaluation criteria pertain to:
– ‘impact of the program on the target market‘,
– ‘ability of the program to intercept, develop and enhance the specificities of the supply chain‘,
– ‘consistency between specific requirements and roles assigned to the beneficiaries by the supply chain agreement‘.
(9) The sum of the minimum scores for the three subjective criteria above is 5, that of the maximum scores is 17. It follows that subjective evaluation criteria can influence the final score to the extent of 12 points (= 17-5)
(10) Dario Dongo. Livestock system and biodiversity, public disbandment. #CleanSpades. GIFT (Great Italian Food Trade). 31.3.21
(11) Dario Dongo. Genetic improvement, MiPAAF gives 12 million to Coldiretti. #CleanSpades. GIFT (Great Italian Food Trade). 26.8.21
(12) Dario Dongo. Regulation on the sustainable use of pesticides, SUR. The travails of EU reform. GIFT (Great Italian Food Trade). 20.12.22
(10) Dario Dongo. The Ministry of Agriculture boycotts organic farming. Open letter. GIFT (Great Italian Food Trade). 30.12.22
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
