Scotland Rural Development Programme (SRDP) 2014-2020

Our response

SECTION 2 : SETTING THE CONTEXT

Question 1: Given the EU’s Common Strategic Framework approach do you agree or disagree that EU funds in Scotland should be marshalled into three funds (paragraph 27)? Agree As a means of driving the integration and more effective targeting of European funding, this approach makes sense in principle. However, it has to be made clear that these so-called ‘funds’ are virtual in nature and exist only as a mechanism to achieve integration. There is a risk that existing confusion and misunderstanding of European funding of all kinds will be increased by this description, and also a risk that the ‘hidden wiring’ required to make this approach work could become over-complicated and result in unpredicted barriers and disincentives to effective use of the funds. In particular, the SRDP funding that is allocated according to these funds must be clearly accounted for and must cover a spread of activities including social and community-based projects and activities. Whatever mechanisms are used to distribute the various types of funding, the most important element that has to be achieved is a robust set of National Rules that are not onerous and over-zealous in their interpretation of the relevant European regulations and which are supported by guidance that is clear and consistent throughout the life of the programme. This was not achieved in the current programme, where many applicants found the burdens of bureaucracy and audit to be at best irksome and at worst highly stressful. Failure to assure potential applicants that this issue has been resolved for the current programme will be a huge disincentive to applications by community groups. Question 2: Do you agree or disagree with the proposed establishment of a single Programme Monitoring Committee to ensure all EU funds are targeted effectively (paragraph 29)? Agree Given the requirement for a Common Strategic Framework and Partnership Agreement, it is probably necessary to have a single PMC. However, there needs to be absolute clarity about the PMC’s role and responsibilities, especiall given that it is variously described as a “Programme Monitoring Committee” and a “Partnership Agreement Monitoring Committee”. Also, there is a strong responsibility on the officials who support and service this Committee to ensure that members are fully informed in depth about all the programmes they are responsible for overseeing, and that information presented to them is comprehensive, easily understandable and timely. The proposed sub-committees or advisory groups must be robust, well supported and enabled to play a full role in ensuring that the PMC is fully informed about the nature of programme delivery. It is essential that specifically rural third sector and community interests are represented on the PMC.

SECTION 3: OUR INVESTMENT PRIORITIES FOR RURAL DEVELOPMENT

Question 3: Given the need to prioritise our spending in the future programme (paragraph 11) which articles do you see as a priority for use within the next programme? We note that Articles 42-45 which cover LEADER are not included in the list given in the consultation. We believe that despite issues around audit and eligibility, which are not the fault of the LEADER approach, LEADER has been proven to be a successful model for rural development investment which should be supported, improved and developed. To this end, the percentage of funding from the SRDP to go to LEADER should not be limited to the obligatory minimum 5%, and these articles should not be treated as separate but should be given priority as part of the overall SRDP. The other article of most immediate importance to third sector and community interests in rural Scotland is 21: Basic services and village renewal in rural areas. This has the capacity to support investment in a wide range of initiatives that will benefit Scotland’s rural communities. Currently, it is largely delivered through the LEADER programme and it would make sense to continue this approach in the new programme. There are also several other articles that are of interest, in particular: 36. Co-operation: this could be used to fund a wide range of collaborative and enterprising projects. 15. Knowledge transfer and information actions: this could be used to invest in a range of rurally based training and skills development, not limited to land management 20. Farm and business development: this measure can be used to invest in non-farm enterprises, including support for social enterprise activity. 16. Advisory services: this should be used to fund advisory services that are not exclusively targeted on farmers and land managers. There is also a range of measures related to forestry and environmental initiatives that will be of vital importance to specific third sector groups who will no doubt respond on those in detail.

SECTION 5: STRATEGIC TARGETING OF INVESTMENTS

Question 4: Do you agree or disagree that we should geographically target our investment to areas where support will make the greatest contribution to our priorities? Agree On balance yes, in principle, for the majority of the SRDP. But the process of deciding on allocation of funding must be rigorous, transparent and accountable to the PMC. The targeting of LEADER funds should, following the allocation of funding according to Local Development Strategies at the start of the programme, be the responsibility of LAGs.

SECTION 7: DELIVERING THE SRDP: PROGRAMME STRUCTURE

Question 5: Do you agree or disagree that support for small local businesses should be provided through LEADER?  In principle, this makes sense but it raises the question of definition of a small business and the allocation of additional funding to LAGs to provide this support. There must be no question of this type of supported simply being shoved in as an extra line in existing LEADER budgets and thus diminishing the funding available for third sectoir and community organisations. The cash from the wider SRDP and other funds must be there to invest and critically to fund the specialised support LAGs will require to provide for such investment. Question 6: Do you agree or disagree to the proposal to disband RPACs and replace with a more streamlined assessment process as explained in Section 8? Agree The experience of both the RPACs and the existing application processes in the current programme has often been an unhappy one, not least for case officers whose capacity and expertise has sometimes been stretched beyond its limits. In designing a more streamlined application process, the Scottish Government must take full account of the experiences of the current programme and seek to build a system based on the needs of the applicant, rather than expecting applicants to fall into line with complex processes that can appear to be designed to serve the needs of bureaucracy supporting the programme. Question 7: Do you agree or disagree that LMOs should be removed from the future programme, given the spending restrictions we are likely to face and the need to ensure maximum value from our spending? Agree There is no justification for the continuation of a non-competitive scheme like this in a new programme with a reduced budget. Question 8: Do you agree or disagree that the Forestry Challenge Funds be discontinued, with WIAT being funded through Rural Priorities and F4P funding being provided via LEADER? Agree As with support for small businesses, any addition funding streams delivered through LEADER, this must be accompanied by the actual funding to be disbursed to applicants, and support for the capacity of LAGs to deliver these specialised priorities. Also, support must not be limited to rural areas and must be available for operations in urban areas, which were a major focus of Forestry for People funding. Question 13: Do you agree or disagree with the proposed replacement of the Skills Development Scheme with an Innovation Challenge Fund? Agree We agree with the proposition that innovation should be at the heart of rural development and support the creation of an Innovation Challenge Fund, as long as it takes, as proposed in the consultation document, a ‘holistic approach’ that includes the third sector. There must be no reduction in the range of support that is offered by the Skills Development Scheme which delivered training for a broad spectrum of land managers, paid and voluntary. On a wider issue of training, there is a serious issue of the eligibility of training activity in LEADER funding, according to Audit Scotland. This is just one of a series of audit and eligibility issues that have to be addressed in the new programme.

SECTION 8: APPLICATION AND ASSESSMENT PROCESS FOR AGRICULTURE, ENVIRONMENT, LANDSCAPE AND FORESTRY

Question 15: Do you agree or disagree with the proposed case officer approach to the assessment of applications? Agree We agree but with reservations. Questions 15, 16, 17, 18 and 19 are predicated on the creation of an application and assessment process for land-based industries that could be seen to exclude those who are not part of that sector. Our concern is that this does not recognise that local communities and enterprises have, in the current programme, sought funding for projects using some of the priorities that will be covered by this scheme, and that the proposed mechanism may create an artificial distinction between private sector land-based business and third sector or social enterprise land-based projects which seek to deliver a wide range of environmental, economic and social public benefits. Not all applicants will fit in to the scheme outlined and there is a risk that their applications could – as undoubtedly happened in some instances in the current programme – be disadvantaged by being assessed by officers with no knowledge or understanding of a particular field. Question 16: Do you agree or disagree with the proposed single entry route for applications with a two level assessment process? Agree The most important aspect of this for us is that the system should be open and transparent, with clear and consistent guidelines on eligibility and on how the scoring system and appeals will work. Question 17: Do you agree or disagree with the proposed negotiation of variable intervention rates rather than setting fixed intervention rates? Agree Question 18: Do you agree or disagree with the proposed setting of regional budgets across the Rural Development Regulation (RDR) articles? Agree Question 19: What support and assistance do you think applicants will need for this application process to work effectively? It is essential that applicants of all kinds are given appropriate support to develop projects and complete applications, that rules and guidance are clear and consistent throughout the programme, and that those who are assessing applications have the knowledge and understanding to do the job fairly and effectively.

SECTION 11: ADVISORY SERVICE

Question 26: Do you agree or disagree that we allocate SRDP budget to advice provision when we move to the next programme? Agree It is essential that sufficient budget is invested in information, advice and support to applicants and in our view it would be a prudent use of SRDP funds that will ultimately save money by increasing the number of successful applications and reducing the risk of audit and eligibility issues arising. Relevant and appropriate support and assistance must be available to third sector and community groups applying for funding across the programme.

SECTION 12: FINANCIAL INSTRUMENTS

Question 27: What are your views on the merits of providing loans for specific purposes and/or specific sectors? Cash-flow issues are one of the greatest barriers to third sector and community groups accessing funds across the SRDP. The development of a rolling loan fund could be a very positive move to mitigate this and increase the number of high quality applications. However, an even more effective change would be for the paying authority to commit to, in some circumstances, paying in advance (which is permissible, and takes place in many other Member States) and to paying grant claims within a much shorter timescale.

SECTION 13: VOLUNTARY MODULATION

Question 28: Do you agree or disagree with the proposal to maintain the current level of transfer from Direct Payments to SRDP in the new programme period? Agree We have ticked the Agree box because we do not want our response to be included in a count of those who want reduced voluntary modulation. However, we believe that the current rate of voluntary modulation should be not just maintained but increased to maximise public benefits from this public money and to ensure that the benefits of investment in rural development are available across a range of rural sectors.

SECTION 14: EQUALITIES IMPACT ASSESSMENT (EQIA)

Question 29: Please tell us about any potential impacts, either positive or negative; you feel the proposals in this consultation document may have on any of the equalities characteristics listed in paragraph 136. None at present, although we may have further thoughts on this in the next consultation.