Vincenzo Gesmundo - the boss of the bosses of Coldiretti - already on 25.3.21 had announced to his generals / directors that the projects destined for agriculture within the PNRR 'in essence they are signed at the bottom by Coldiretti", "because when Coldiretti makes Coldiretti there is none for anyone!'. (1) Nothing more true, one would say, observing the provisional results of the 30.6.23th call for tenders for supply chain contracts in the agri-food sector, published on XNUMX. #Clean spades.
1) Supply chain contracts, the tender
The call it was introduced by the then Minister of Agricultural, Food and Forestry Policies Stefano Patuanelli with DM 22.12.21 n. 673777, for supply chain contracts with investments of a total amount between 4 and 50 million euros.
The measure it is financed by the investment fund complementary to the PNRR, with a budget of 1,203 billion.
Of these, 350 million financed the scrolling of the rankings of the IV tender and the remaining 850 million should finance the V tender.
1.1) Beneficiaries
The beneficiaries of the loan are both companies that contribute directly to the production, collection, processing and marketing of agricultural and agri-food products, and companies that provide services and means of production.
The facilitation it is reserved for companies that sign a supply chain agreement, in a multi-regional area, aimed at creating an integrated inter-professional program of national importance.
1.2) Investments allowed
Investments admitted concern:
– tangible and intangible assets in agricultural holdings, related to primary agricultural production,
– processing of agricultural products and marketing of agricultural products,
– transformation of agricultural products into agri-food products,
– participation of producers of agricultural products in quality schemes and promotional measures for agricultural products,
– organization and participation in competitions, fairs or exhibitions,
– research and development projects in the agricultural sector,
– participation in fairs,
– production of energy from renewable sources by transformation companies.
2) PNRR and supply chain contracts, Coldiretti 'ace take it all'
It is too early to comment and it will be the administrative judges – following the upcoming appeals – who will evaluate the correctness of the work of MASAF (Ministry of Agriculture, Food Sovereignty and Forestry) in awarding the loans in question.
However, it is easy to note the dominant role of Coldiretti, as the 'ace take it all' of the measures allocated in this PNRR tender. Among the protagonists in the presentation of the projects admitted to funding are the names of some figures of the magic circle of Coldiretti, such as:
– Raffaele Grandolini, the 'King Midas' of Palazzo Rospigliosi (2,3), depositary of 7 approved projects out of a total of 38, in the XNUMXth tender for supply chain contracts,
- David Granieri, president of Unaprol and Op Latium, in addition to the national Coldiretti as well as president of Coldiretti Lazio and Coldiretti Rome (4,5,6). 4 approved projects out of 38.
The stone guest is Alessandro Apolito, former director of the Ministry of Agriculture who has always dealt with and continues to follow supply chain agreements, first at MIPAAF and then in Coldiretti, as we have seen. (7)
3) Premeditated opacity
The opacity of management of the V PNRR tender on supply chain contracts, by MASAF is premeditated. At least starting from its substantial changes, made shortly before the deadline for submitting applications:
– the tender was modified, a month before its closing, in crucial parts such as the intensity of the grants and the requests for bank guarantees. Of absolute importance, taking into account the failed experiences of projects that have drained public resources without being implemented due to the financial incapacity of their beneficiaries,
– the deadline for submitting applications has been extended by one month, one week before the deadline. So that the applications have increased tenfold, from 34 (649 companies) to 309 (6.521 companies), reaching a total of 5,174 billion euros, with 690 million euros of resources available.
4) Programmed arbitrariness
The arbitrariness of the assessments of the applications was in turn scheduled in time:
– the system of criteria and indicators that determine the final score of each project includes in fact three criteria whose estimate is entrusted to the mere subjective evaluation of the evaluation commission, (8)
– the evaluation commission was thus able to assign 12 points at will, (9) which are equivalent to the difference between the first project in the ranking (91,82 points) and the 237th project in the ranking (79,71 points).
5) Covert transparency
The 'transparency' of the procedure was concealed to perfection:
– the Ministry of Agriculture (MASAF), after the closing of the deadlines for presenting the applications, has not divulged official data on the number and consistency of the projects presented. Nor did it disclose the outcome of the first preliminary verification of admissibility and formal admissibility of the applications themselves,
– the ranking published on 30.6.23 does not even indicate the number of projects admitted. It is therefore assumed that they are 38, adding the relative amounts up to reach the 690 million euros indicated for the first time by Minister Francesco Lollobrigida on 24.5.23, in a hearing in Parliament,
– the identity of the members of the evaluation commission is still unknown, seven months after his appointment which should have occurred with DM 5.12.22 n. 621652. Ministerial decree not yet published in the Official Gazette or on the MASAF website.
5) Barriers to the exercise of rights
The Ministry of Agriculture (MASAF) has indicated a very short peremptory deadline - 10 days, instead of the usual 60 days - to present appeals against the ranking published on 30 June 2023. Claiming extreme urgency, after a few years of delay, in managing the PNRR. However, this term seems rather an unacceptable barrier to the exercise of rights. Even more so when you consider that:
– subjects entitled to appeal do not even have the material time to obtain access to the documents, even before being able to prepare adequate appeals,
– the published ranking indicates only the total scores, omitting to communicate the points awarded on an objective basis (on which material errors cannot be excluded) with respect to the arbitrary criteria (see above, paragraph 4),
– the identity of the members of the evaluation commission is still unknown. Those entitled are thus unjustly deprived of the indispensable time to verify possible conflicts of interest, already observed in other anomalous tenders to the same ministry (10,11).
6) PNRR and the organic supply chain, which resources?
'25% of the aforementioned sums [the PNRR resources allocated to supply chain contracts in agriculture, ed.] is intended exclusively for Italian organic production obtained in accordance with European and national sector legislation' (DL 59/2021, article 1.h).
The MASAF coldiretto - in addition to having boycotted the proposal for the reduction of pesticides in agriculture - has already tried to boycott support for the organic supply chain, as reported (12,13). And now, where is the exclusive reserve for organic production of 25% of the appropriations in question?
7) Provisional conclusions
It is better understood why the Italian government managed to obtain the abrogation of the crime of abuse of office, after 93 years of honorable service from the first fascist regime to the second, or third republic, whatever you prefer.
The judiciary Italy must pass the shield of the Agromafie Observatory and investigate independently, in compliance with the law of the State. To verify - even in the administrative office - the possible existence of other crimes, in this great chaos.
Dario Dongo
Footnotes
(1) Dario Dongo. National action plan for pesticides, sustainable agriculture and PNRR. #Clean shovels. GIFT (Great Italian Food Trade). 4.2.22
(2) Dario Dongo. Federconsorzi 2, CAI SpA, AgriRevi, Coldiretti. The dinner of the cretins. GIFT (Great Italian Food Trade). 31.1.21
(3) Raffaele Grandolini, among the many positions in which the possible existence of conflicts of interest has already been pointed out, is also a director of the Agromafie Observatory. Who in turn has recently distinguished himself for an outlaw operation. See Dario Dongo. Coldiretti, the Agromafie Observatory and the Porsche of the Customs Agency. The document. GIFT (Great Italian Food Trade).
(4) Dario Dongo. Coldiretti and Unaprol. The uncertain fate of public funds destined for Italian olive growers. GIFT (Great Italian Food Trade).
(5) Dario Dongo. Germina Campus, the Coldiretti holding company that speculates on farmers. #Clean shovels. GIFT (Great Italian Food Trade).
(6) Dario Dongo. UNAPROL, AIPO and Oleificio Paladino, conflicts of interest like wildfire. #Clean shovels. GIFT (Great Italian Food Trade).
(7) Dario Dongo. Public administration, loyalty to the state or to Coldiretti? #Clean shovels. GIFT (Great Italian Food Trade).
(8) The 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’,
- 'coherence 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 equal to 5, that of the maximum scores is 17. It follows that the subjective evaluation criteria can influence the final score by 12 points (= 17- 5)
(10) Dario Dongo. Breeding system and biodiversity, public disarray. #Clean shovels. GIFT (Great Italian Food Trade).
(11) Dario Dongo. Genetic improvement, the MiPAAF gives 12 million to Coldiretti. #Clean shovels. GIFT (Great Italian Food Trade).
(12) Dario Dongo. Regulation on the sustainable use of pesticides, SUR. The travails of EU reform. GIFT (Great Italian Food Trade).
(10) Dario Dongo. The Ministry of Agriculture boycotts organic products. Open letter. GIFT (Great Italian Food Trade).
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
