Consultation on Scotland Rural Development Programme

Our response

Question 1

How would you rate your satisfaction with the budget as a whole? "Disagree" SCVO believes that the balance of funding in the budget continues to be disproportionately skewed in favour of farming and land-based industries and fails to sufficiently recognise the diversity of the rural economy and the vital importance of non-agricultural businesses, community-based enterprises and projects, and rural community development. Funding for farmers can undoubtedly contribute to the priority of vibrant rural communities, but there are many other interventions that would achieve as much or more, and which are given far too little priority in this proposed programme. We are particularly concerned that most or all of the community-related funding now resides with LEADER, which is funded at only 5% of the overall budget - the absolute minimum acceptable under the Regulation. This proportion should be significantly higher, particularly given the proportion of the LEADER budget that will be allocated to administrative costs around animation and applications. Rural community (non-agricultural) interests expected that there would be greater resources allocated to respond to the demand which, in part, has been generated by the availability of Rural Development Programme funding in the last programme. The need for resources to meet this demand is consistent with both Scottish Government and EU strategic policies. Effectively the resources available through LEADER will be reduced given the greater proportion of allocations available to non project-based/administrative activity. We are concerned that directing the majority of community based demand to LEADER will have a negative impact on community empowerment and a detrimental impact on community capacity. The total reliance on LEADER funding will inevitably reduce the opportunity for the development of strategic initiatives with impact within and beyond a particular local community. The proposal to spend £20m on advice is limited to the provision of assistance to 'farmers, crofters, forest holders and land managers, via a dedicated advice helpline, web guidance and publications and links to case officers and operational customer service.' This proposal would specifically exclude community groups from accessing information and advice services. With the exception of the Knowledge Transfer & Innovation Fund, it would appear that the figures quoted in the proposed SRDP budget for all schemes, except LEADER, is the budget amount which will be available for grant distribution. By contrast the £66m allocated to LEADER appears to have to bear the cost of both its administration and advice service. It has been suggested that these costs may be up to 25% of the LEADER budget award and this is yet another drain on an already small LEADER budget. We also note, in this first question, our concerns about the design of this response mechanism, as it apparently invites further comment only if dissatisfaction is expressed. This could either limit responses or drive respondents to express dissatisfaction in order to ‘have permission’ to comment further. A simple tally of numbers satisfied or dissatisfied is not going to produce a coherent result, as some may be dissatisfied because they want more, and others because they want less. We have added comments where we deemed them relevant, whatever level of satisfaction or dissatisfaction was expressed.

Question 2

Are you broadly satisfied with the new application and assessment process for land based investments outlined in section 5? "Neither satisfied nor dissatisfied" The application processes appear to have been improved but there is no recognition in this section that community-based groups and organisations may access this funding as well as farmers and foresters. SCVO's experience with the Rural Direct service of supporting community organisations to apply across a range of measures in the current SRDP, has given us first-hand knowledge of the problems with that application process. For community groups, these were exacerbated by the assumption that only land based businesses would be involved, which is clearly repeated here.

Question 3

Should support for farmers operating in constrained areas be continued through the SRDP? "Other" In SCVO's response to the 2008 consultation on LFASS, we stated that it is:

‘a fundamentally flawed scheme that does not deliver what it is intended to. It is not well targeted geographically, delivering disproportionate help to areas which it is hard to see as "less favoured", and it is not focused on delivering the environmental and socio-economic impacts it is meant to.’

Our view remains the same and we regret the continuation of this scheme, largely unchanged until at least 2018, when much of the money involved could be invested more effectively to benefit our communities, our environment and our rural economy at a time of significant change. The eventual move to the new ANC designation should be a welcome opportunity for a root and branch review and a move to targeting investment and support on a rational basis on areas where it is genuinely needed.

Question 22

How would you rate your broad satisfaction with the proposals for co-operation? "Quite satisfied"

Question 23

How would you rate your broad satisfaction with the proposals for Small Business Support? "Quite satisfied" We are satisfied that these proposals exist, and with the recognition that the economic and social success of Scotland’s rural communities depend on a wide range of economic activities. We also appreciate the specific mention of social enterprises, which are of increasing importance to these communities and range from small local groups engaging in income-generating activities to larger enterprises employing many people and with large turnovers. Our two concerns are that the budget is far too small compared to what is available to the agriculture industry through many other channels, and that the proposal for a simple challenge fund may not be best use of the limited cash that is available. A straightforward challenge fund for £20 million over six years will undoubtedly do some good, but there is a danger that it will quickly be mopped up by particular sectors, particularly those more aware of the SRDP, and that the benefits will not be spread as widely as they could be. We note that there is a proposal to work with a partner on this scheme and believe consideration should be given to a more 'LEADER-like' approach which invests some of these funds in support for the creation and development of new enterprises. This could tie in with the Knowledge Transfer approach elsewhere in the programme. The funding must fit within, complement and add value to, existing support for small rural enterprises, and should be based on an up to date needs assessment and evidence base. We welcome the recognition of the problems caused by paying grants retrospectively and on the basis of defrayed amounts and note that the Scottish Government is "considering making advances in aid available where appropriate”. Given the particular circumstances which community enterprises experience such advances would have a significant impact on the potential success of an award and we would recommend that similar advances in grant aid should be made with LEADER awards.

Question 24

Do you agree with the proposal that we should continue to give significant support to the food and drink sector? "Yes"

Question 28

How would you rate your broad satisfaction with the proposals for LEADER? "Quite satisfied" We are both satisfied and dissatisfied with these proposals. SCVO has long been an advocate for and supporter of the LEADER approach which, at its best, is an exemplar of good practice in integrated rural community development. We agree with the overall approach being taken to LEADER and recognise the development work that has gone into addressing problems and issues arising from the previous programme, and to ensure that the new programme is firmly rooted in effective local partnerships and clearly focused local development strategies. We applaud the intention to ensure that LEADER is more about strategic integrated development and not simply a grant scheme. Issues of audit and bureaucracy in the last scheme have inflicted considerable reputational damage on LEADER as a brand, so it is vital that the new scheme is as successful as possible. Our main concern, however, is that the budget is too small to achieve this. The consultation document states:

“LEADER has a ring-fenced minimum spending requirement of 5% of SRDP spend. Based on budget figures presented in this document, that will entail a budget of £66 million being invested in community driven initiatives across rural Scotland over the next programme period.”

This is an egregious non sequitur: it entails no such thing. A much higher allocation would have been both possible and desirable, and it is the Scottish Government - not the European Commission - which has chosen to keep the proportion of the new SRDP that is targeted on rural community development to the absolute minimum permitted. We question whether this budget allocation is based on an assessment of the potential opportunities and benefits from an improved LEADER programme and the level of investment that would require, or was simply used as the minimum that Scottish Government could get away with spending on community development within a programme that is heavily weighted towards land management interests. Our other concern is that too much will be demanded of LEADER both in terms of continuing bureaucracy and its apparent status as the only source from which community-based activity will be funded. While we welcome an increase in the proportion of the LEADER budget available for administration and animation, the proportion directly available to communities will be consequently reduced. The fact that communities wanting to develop community facilities, local services and land-based projects like paths will now be signposted to LEADER means that the budget will be under severe strain from the beginning and demand for investment will greatly exceed the budget and support available. We would like to see the principle of 'advances in aid' proposed for the Small Rural Business Support Scheme extended to LEADER funding. The Simplified Cost Options which have been recommended by the European Commission should be utilised in the eligible expenditure rules, with the current 'gold plating' identified in the Scottish National LEADER rules removed. Having expressed these concerns, however, and accepting that this consultation is unlikely to engineer any of the changes we would like to see, SCVO will do everything it can to support the new LEADER programme at national and local level and to seek to make it a success.

Question 29

Do you agree with the range of options being included within KTIF scheme? "Yes" We support the intention to build on the success of the SDS and widen the scope of the opportunities available. While we also support the options proposed, we believe that the range should be expanded to explicitly include rural community-based activities that are not solely related to agricultural and land management practice. These could include skills in project development and implementation for rural community facilities and services, and community enterprises. These could be a natural fit for the proposed linkages with the SRN and LEADER.

Question 30

How would you rate your broad satisfaction with the proposals for KTIF? "Quite satisfied"

Question 31

How would you rate your broad satisfaction with the proposals for the Advisory Service? "Neither satisfied nor dissatisfied" The Advisory Service appears to be well designed and capable of providing joined up support to its intended clientele, but we regret that it is exclusively targeted on farmers and land managers, and that there is no provision for the kind of service provided in the last programme by SCVO through Rural Direct, which supported community groups applying across a range of measures.

Question 32

Do you think the tasks set out above are the most appropriate ways for the SRN to add value to the implementation of the SRDP? "Yes" Are there other activities or services you would like to see the SRN provide? We think the scope of activities available within the proposals is absolutely right and – having run the successful events programme for the last SNRN - we are particularly pleased to see that project visits and networking events are to be continued in the new one.

Question 33

Do you agree with the proposal to establish thematic working groups as an approach to supporting the Rural Development Programme priorities? "Yes" We like the idea in principle but we are not wholly convinced that it will work. If it is going to, the process must be very pro-actively managed and the groups must have a clear purpose and direction and be seen to have the potential to make a difference. It needs to be made clear what the benefits of participation in the groups are for already very busy stakeholders. With progress on the new Rural Parliament speeding up, perhaps there could be a cross-over role for these groups in contributing, directly or indirectly, to the deliberations and policy development between the 2014 and 2016 Rural Parliaments.

Question 34

How would you rate your broad satisfaction with the proposals for the Scottish National Rural Network? "Very satisfied" We would raise the following questions and points about the SRN:

• What will membership of the SRN mean, and who will be able to join? Will membership be open to individuals? To organisations without a specifically rural remit? To public sector organisations and private sector businesses? It would be useful to have clarity on these issues before the SRN is launched. Our view is that membership should be as open and inclusive as possible, and entail few responsibilities.
• Who will decide who sits on the Advisory Board? Will it be a process of nomination and election (if so, who are the electorate?) or will it be by recommendation followed by invitation of the Cabinet Secretary as was the case with the Rural Development Council?
• While we accept the sense of having a dedicated Network Support Unit run in-house by Scottish Government, as much of the practical activity of the network as possible should be outsourced. We believe the success of SCVO in delivering the last SNRN website and events programme prove that this can work well, but that these projects would have been even more effective in the context of an overall Rural Network organisation, which was lacking.
• The re-establishment of a dedicated LEADER Network within the SRN is very welcome, but it will have to be carefully managed to ensure that it does not end up being in competition with other aspects of the SRN, and consume a disproportionate level of the available resources. This can probably be best achieved by including its management in the work that is contracted out to external specialists.
• The new Rural Parliament must maintain its independence from Government, but there are opportunities for partnership working with the SRN that could add immense value to the operation of both projects. Early in 2015, there should be a concerted effort by those involved in both areas of work to establish common ground and areas of mutual interest and support, and to ensure there is no unnecessary duplication or clashes in their activities and initiatives.

Question 35

How would you rate your broad satisfaction with the proposals for communicating the new Scotland Rural Development Programme? "Quite satisfied" The proposals make sense, but could be expanded to include even greater emphasis on the use of social media, which is now a commonplace, mainstream and highly effective means of communicating and engaging with a range of organisations and individuals. The new SRN website should provide continuity with the current, highly regarded, site and all the online communication activities should have a clearly stated and understood mission and purpose, and effectively designed mechanisms for assessing their effectiveness.

Question 42

We would welcome comments on the EQIA. 1. Measures to increase the involvement of relevant stakeholder groups and boost the available evidence are weak and should be strengthened. The EQIA rightly identifies an issue around the lack of evidence available for equality issues in rural areas. This evidence gap increases the need for proactive consultation and involvement of relevant stakeholder groups to ensure the evidence used in assessing this policy is as accurate and representative as possible. The EQIA does identify the opportunity for relevant stakeholder groups to input their views during this consultation process, and states that the consultation will be widely advertised and drawn to the attention of a diverse range of people. However, beyond this general aim to raise awareness of the consultation the EQIA does not identify any further specific steps that could be taken to ensure that the relevant stakeholder groups views are gathered during this process. Nor does it identify and address any issues that certain equality groups may have in being able to access and contribute to the consultation. 2. Proposals under stage 3 of the EQIA specific to the duty to ‘advance equality of opportunity’, do not go far enough. The EQIA rightly raises some important issues affecting equality in rural areas, such as the ‘old white male’ bias and issues for women around employment and childcare, and transport. However the EQIA does not go far enough to identify ways in which the various aspects of the SRDP could amend their approach and/or priorities to more effectively address these issues (and therefore advance equality of opportunity in these areas). The EQIA only identifies where there are opportunities, or possibilities, for these issues to be addressed through the current policy proposal, using terms like ‘hope’ and ‘we envisage’. For example, the EQIA identifies that that the old white male bias is as a result of broader structural and cultural issues, but does not go any further into investigating what these issues are or how the SRDP programme could influence these in its design and delivery. Instead, it ‘hopes’ that the existing policy proposals will help to address this. This approach around the duty to enhance equality of opportunity needs to be strengthened.

Contact

Norman MacAskill | Head of Rural Policy | norman.macaskill@scvo.scot | 01463 251731