Tuesday, September 10, the software application of the Environmental Fund Administration – AFM. dedicated to the registration of applications from the final beneficiaries of the subsidies for PV installation, worked for only six and a half hours. The AFM decided to close it around 4.30 pm, after complaints and suspicions being expressed on the its functioning, that would have allowed the priority registration of some files, to the detriment of others.

In a message published by e-nergia.ro (on September 18), Marian Mândru, campaign coordinator at Greenpeace Romania states that “there are several scenarios circulating in online communities and in the media; the suspicions of installers and citizens are normal as there is no official statement, not even now, a week later, from the institution”. Greenpeace Romania asks the Environmental Fund Authority to clarify the reasons for stopping the project submission process and to resume the process, under fair conditions to all those who participate in the program.

On Tuesday, a group of 22 companies submitted a petition to AFM listing the irregularities found and coming up with a set of proposals (SEE THE DOCUMENT – in RO!). There is still no official reaction from the Administration.

Irregularities in the registration procedure

• The communication of the starting date of the registration (Tuesday, September 10, 2019) was made by AFM no earlier than Saturday, September 7, when one needs 3 working days for obtaining the fiscal certificate ANAF; this would have restricted the right of citizens to access a public program, the petitioners believe.
• Citizens who submitted the files to companies that used a single computer for registration were disadvantaged at the expense of those who submitted the file to installers who used more computers in the introduction of the files. This practice led to discrimination between installers and was not prevented by AFM.

Irregularities related to the software application

• Lack of the CAPTCHA code for protection against “robot” software in the first hours of registration and its late activation. AFM activated the code in the last hours of registration from 10.09.2019, which proves that the protection was available, but was not used.
• Possibility of access from an unlimited number of computers using the same username and password, which was not communicated to installers in the AFM user manual. This created unfair competition between installers who used a computer with a user and a password (as requested by the IT security rules) for registering files and those who used multiple computers with the same user and password.
• Some of the validated installers received very late or did not receive the password and access to the application at all. “AFM could have ensured the access of the installers in the application before the beginning of the program so that they have granted their access at the time of the beginning of the registrations”, say the companies mentioned. According to them, in this way, some citizens were disadvantaged.

Even on September 14, a group of installers from Alba county have reported, according to newsenergy.ro, that the registration process in the AFM grant program has been corrupted for at least three reasons:

• The manual for accessing the application for the registration of the financing applications was changed just one day before the start of the application process for accessing the subsidies from the Casa Verde Photovoltaic program.
• Several installers received the access password very late, some after the closing time of registration, others not at all.
• The application was designed in such a way as to allow the use of software “robots”.

The submission of a request in the computer application, manually, according to the approved procedures, took at least 10 minutes, say the representatives of the installers companies. Some companies used software robots that allowed an enrollment rate of 8 files per minute on average. “Champions” at the speed of registration were the companies interested in the South-West Oltenia and Center regions.

The dissatisfied installers have addressed the AFM and the Competition Council, but they are reluctant to appeal to prosecutor offices or to OLAF; they fear that such involvement would lead to complex and long-standing procedures that would void any chance of the AFM program to materialize.

Requests from the unsatisfied installers

• Cancellation of entries from 10.9.2019, these being corrupted by the mentioned facts.
• Resumption of registration in the program on a date announced by AFM at least 10 days in advance.
• Implementation of a CAPTCHA security code for all registrations in the system and all users (auditable process)
• Limiting the maximum number of computers used simultaneously by an installer in the registration process (auditable process)
• Establishing a maximum number of applications (for example, 50 in 24-hour) that can be introduced into the system by installer, provided that this does not impede with a competitive practice.

The greater the uncertainty, the greater the risk that one of the persons or companies who consider themselves being wronged to send this in investigation procedures that would destroy a laudable intention that has aroused a major interest from companies and individuals.