Analysis of Responses to the Second Consultation on the Scottish Rural Development Programme 2014-2020 Summary Report

3 Summary of Responses by Question

Budget and Delivery Partnership

Question 1 - How would you rate your satisfaction with the budget as a whole?

3.1 There was general dissatisfaction with the balance of the budget across all interest groups. Including the campaign response, 87% of respondents were dissatisfied with the budget. Excluding the campaign responses, 60% were dissatisfied. This dissatisfaction tended to relate to three issues, the first two of which were not measures proposed through the SRDP consultation:

• The amount of the budget allocated to Scotland from Europe was too small
• The amount transferred from Pillar 1 of CAP (direct payments) was contentious, with farming organisations tending to argue that 9.5% was too high and those with environmental and community interests arguing that 9.5% was too low
• The amount allocated to specific interests within the programme. Most dissatisfied respondents argued for more money for their area of interest and less for other interests with the strongest view being from the environmental interests (and including the campaign response) who requested a minimum of £60million per annum for agri-environment measures.

Question 2 - Are you broadly satisfied with the new application and assessment process for land based investments outlined in section 5?

3.2 The balance of opinion (47%) supported the change in proposals, although there was a substantial minority (33%) that were dissatisfied or very dissatisfied.

3.3 Positive comments related to the fact that the Scottish Government had recognised that the previous system was too onerous and had made attempts to streamline the process and make it more accessible. The single application was generally thought to be a good idea. However, caveats were expressed around whether this process would work in practice and would bring forward high quality applications. For example, concerns were expressed on whether the application form would be easy to complete, whether case officers would be suitably knowledgeable and trained, whether there would be a consistent approach applied across the country and whether targeting would be appropriate. Several respondents suggested an even simpler fast-track approach for grants below £10,000 to encourage a wider range of farmers to apply.

Less Favoured Areas Support

Question 3 - Should support for farmers operating in constrained areas (LFASS) be continued through the SRDP?

3.4 The balance of opinion was in favour of support for farmers operating in constrained areas being continued through the SRDP with 64% saying it should, 11% saying it should not and 25% saying 'other'. Farming and crofting, land management and local authority interests were most likely to be in favour of support staying within the SRDP. Environmental organisations were the most likely to answer 'other' and generally made points about the need for the support to be more directly connected to environmental benefits. The most common point raised by a cross-section of respondents from across the sectors, and from a cross-section of respondents answering 'yes', 'no' or 'other', was that the definition of a constrained area needed to be reviewed because the funding was not reaching its target. Linked to this, several respondents asked for the move from LFASS to Areas of Natural Constraint to be progressed as fast as possible because this was seen as a step in the right direction.

Support for New Entrants

Question 4 - How would you rate your satisfaction with the proposals for the New Entrants Scheme?

3.5 The balance of opinion was satisfied (44%) or neutral (25%) to the proposals for the New Entrants scheme. Many individuals and organisations with an interest in forestry were less satisfied and requested that the scheme should be broadened to encompass new entrants to forestry. There was also commentary around whether the scheme was targeting new entrants or agricultural succession (inter-generational renewal). Respondents, including the NFUS and STFA, generally acknowledged a need for both but proposed that they should be treated differently and that priority should be given to 'real' new entrants. Suggestions included lower intervention rates for inter-generational renewal compared to new entrants.

Crofting and Small Farm Support

Question 5 - Should a scheme be expanded to provide capital support to small farmers?

3.6 The overall view from all respondents was in favour of expanding capital support to small farmers with 52% saying yes, 31% saying no and 17% not expressing an opinion. While two thirds of each organisation grouping tended to agree with the extension of capital support to small farmers, the 118 farming individuals who responded were less convinced with 43% saying yes and 51% saying no. This was a closed question but further views were provided in response to Question 8 (see below).

Question 6 - Is a 3 to 50 hectare range appropriate for defining a small land holding?

3.7 The overall view from all respondents was in favour of the proposal, however, there was a substantial minority against the proposal (33%). The main views provided were:

• The scheme should just be made available to crofters and should have no upper or lower limit.
• The minimum should be 2 (or even 1 hectare) rather than 3 hectares to ensure that small crofts and small horticultural and market garden units were eligible.
• Several respondents, particularly environmental organisations, thought that the maximum of 50 hectares was too large. Scottish Water recommended an upper limit of 20 hectares and Scottish Organic Producers Association (SOPA) an upper limit of 30 hectares. Scottish Environment Protection Agency (SEPA) noted that 50 hectares was too large but did not suggest an alternative. Others, such as the Scottish Tenant Farming Association, noted that it depended on the type of land with one farming organisation suggesting that 30 hectares was more appropriate for improved or arable land and 50 hectares for upland and rough grazing.

Question 7- Do you agree with the proposal for grants of £500 to be available to assist the establishment of Grazing Committees?

3.8 The overall view from all respondents and all groupings was in favour of the proposal with 7% objecting. Although comments were generally supportive, some respondents did note that additional funding may be required for the first year of office of new committees to cover basic administration, accounting and training costs; some also recommended that funding should be available to existing committees to help with training costs.

Question 8 - How would you rate your broad satisfaction with the proposals for the Crofters and Smallholders Scheme?

3.9 The overall view from all respondents and all groupings was split with 35% saying they were satisfied, 37% saying they were neutral (neither satisfied nor dissatisfied) and 27% saying they were dissatisfied. This split was true across individuals and organisations and across most groupings. The most common views related to the expansion of the scheme to small farms as well as crofts. Views included:

• Crofts were different from small farms due to their regulated tenure.
• The expansion of the scheme would dilute the uniqueness, social and cultural importance of crofting.
• The Crofting Commission argued that farms could become regulated crofts if they wanted to access this grant scheme. Allowing both crofts and farms to access the scheme could encourage further decrofting.
• NFU Scotland supported the expansion of the scheme but only within the crofting counties.
• Several argued that the budget was too small to support both crofting and smallholdings as demand could treble.

Agri-Environment Climate Scheme

Question 9 - How would you rate your broad satisfaction with the proposal for the Agri-Environment Climate Scheme?

3.10 The overall view from all respondents and all groupings was split with 39% saying they were satisfied, 19% saying they were neutral (neither satisfied nor dissatisfied) and 42% saying they were dissatisfied. Farmers and land managers tended to be slightly more satisfied than other groupings. Environmental, forestry and local authority interests were the most dissatisfied.

3.11 There was a general view, including from NFU Scotland, that the options needed to be simpler, streamlined and more accessible with improved targeting and advice/support and an enhanced focus on co-operative action to ensure there is landscape scale improvements.

3.12 Royal Society for the Protection of Birds (RSPB) and others welcomed many of the plans, however, they noted there was insufficient details on the options, insufficient clarity on targeting and insufficient budget for the scheme as a whole.

3.13 Many respondents provided very detailed comments about the range of options. Some felt that the options were too heavily focussed on birds rather than a full range of biodiversity e.g the brown hare. Others asked for support for grey squirrel control, rhododendron and bracken control, native orchards, hedge creation as well as the inclusion of local biodiversity sites and constructed farm wetlands and more options for dealing with water pollution.

3.14 Organic farming interests noted that payment rates should rise to EU average as a minimum.

Forestry Grant Scheme

Question 10 - It is proposed to support forestry under six main areas. Please identify whether you agree with these broad areas?

3.15 Overall there was wide agreement with all of the six areas identified: woodland creation; agroforestry; tree health; woodland improvement grant; process and marketing; and sustainable management of forests. Individuals with an interest in forestry were, however, mixed in their support for agroforestry and forestry organisations were largely against its inclusion.

3.16 Although in principle, the new options of agro-forestry and tree health were welcomed, there was concern that no additional funding was provided which may have detrimental implications for other areas of forestry support.

Question 11 - We propose nine woodland creation options with support through standard costs. Please identify whether you think these should be included or excluded.

3.17 There was widespread support for all nine proposed woodland creation options with the lowest support for creating conifer woodland on land that is suitable for timber production and that is accessible for timber transport. The support for conifer was especially mixed amongst organisations with environmental/nature/heritage conservation and farming or crofting interests. It was suggested that, although single-species conifer plantations may be efficient, their impact on the wider landscape setting and ecology was too high.

Question 12 - Are there any other woodland types that should be supported?

3.18 Almost half of respondents to this question thought that other woodland types should be supported (42%). Examples included separate categories for community woodlands, shelter belts, fruit trees and coppice planting, riparian woodland & green networks and grazed woodland.

3.19 However, many of the responses related to refining the existing support and ensuring that productive woodland was supported and that planting was not encouraged on peatlands.

3.20 Others noted that public access and tourism should have been recognised within forestry support and that support should be geared towards management as well as creation of woodlands. There was also concern that creating the woodland options would restrict flexibility to support planting of woodlands that did not fit neatly into any category.

Question 13 - Should the Central Scotland Green Network be allowed an 'Additional Cost Contribution'?

3.21 The balance of opinion was supportive (67%) of the additional cost contribution believing it was justified by the particular challenges and higher costs involved, although a substantial minority (37%) were opposed. Reasons for opposition tended to be that other areas also had high costs, that match funding could be found from other sources and that, with a reduced budget, this was not a priority for spend.

Question 14 - What is your preferred option for Income Foregone in SRDP 2014-2020?

3.22 Most respondents (60%) preferred option 2 (remove income foregone payments with enhanced woodland creation and maintenance payments and Pillar 1 payments allowed on the same area of land). It was widely felt that this was the simplest option to administrate, offering the greatest transparency for farmers and incentivising farmers to create woodlands by maintaining Direct Payments. It was also considered that support through an up-front set up grant could help reduce risk to the landowner. There was some reservation about endorsing any option till more was known about the grant rates for the SRDP programme.

Question 15 - It is proposed to support woodland creation through other means. Do you agree with the range of 'other support' for woodland creation?

3.23 There was majority support for all four options but support was most convincing for tree shelters and fencing (90% support) and bracken contribution (79%). Community woodland had 75% support but improved stock for sitka spruce had only 50% support with 30% no opinion and 20% saying 'no'. Individuals and organisations with a forestry interest were strongly in favour of Improved stock for Sitka Spruce. Local Authorities were also mostly in favour. However, environmental / nature / heritage conservation bodies and farming/crofting organisations tended to be more against than in favour. The concern was largely about Scotland's reliance on Sitka Spruce and the desire to increase the resilience to potential pest/disease/climate change through species diversification.

Question 16 - Should agroforestry be funded through the SRDP 2014-2020?

3.24 Findings here were in line with Question 10 where the majority agreed with the inclusion of agroforestry within the SRDP, however, those individuals or organisations with an interest in forestry were more likely to disagree.

Question 17 - Should tree health be funded through SRDP 2014-2020?

3.25 The majority supported the inclusion of tree health (64%) in the SRDP, although some concerns were raised that the support should be restricted to non-routine tree pests causing significant impacts. This concern related to a desire to not take a disproportionate amount of the budget away from woodland creation or management funding.

Question 18 - Do you agree with the range of Woodland Improvement Grants?

3.26 Close to or more than 75% of respondents supported the inclusion of long term forest planting (both new and renewal), woodland habitats and species, restructuring regeneration, natural regeneration and reducing deer impact. There was still a majority but slightly less support for non-woodland habitats and species and woodland in and around towns (both around 65% support).

Question 19 - We propose to offer support to forest owners, micro-enterprises and SMEs for investment which enhances forestry potential or relates to processing and marketing or adding value to forest products. Should these areas be supported through the SRDP?

3.27 More than half of respondents supported all three options proposed, that is small scale premium processing sector (69% support), equipment to increase harvesting in under-managed woods (64% support) and equipment to increase capacity for steep ground harvesting (59% support).

Question 20 - We propose six Sustainable Management of Forest options. Do you agree with the range of Sustainable Management of Forest grants?

3.28 There was overall support for all options, however, most consistent support was for native woodlands (89%), public access (74%) and low impact silvicultural systems (71%). Woodland grazing (69% support), public access to woods near to towns (63% support) and livestock removal (59%) received slightly less support. There was a suggestion that the options on livestock removal and woodland grazing could be amalgamated. There was some concern around the definition of "high use" with regard to public access, in case this discriminated against sites located in areas with low population numbers.

Question 21 - How would you rate your broad satisfaction with the proposals for the Forestry Scheme?

3.29 Half of the respondents to the forestry scheme were satisfied with the proposals, 25% were neutral and 25% were dissatisfied. There was some general commentary that it was a good start and that there were positive elements for woodland creation and management, however some suggested that there should be equal support for new planting and restocking and management of existing woodlands. It was widely felt (by both those who expressed satisfaction and dissatisfaction) that the budget was too limited to support achievement of set targets and that inclusion of new dimensions to the scheme, although welcome in principle, added pressure to an already tight budget and were unrealistic. There were also views that non-forestry related options should be funded from other schemes. Conversely, there were respondents who thought that the budget was too large and disadvantaged farmers.

Co-operation and Business Support

Question 22 - How would you rate your broad satisfaction with the proposals for co-operation?

3.30 Around 65% of respondents were satisfied with the proposals for a new fund to support co-operative action in order to secure improvements at an ecosystem or landscape scale. Only 6% were dissatisfied. There was, however, a call for more detail with issues of simplicity, flexibility and eligibility raised and concern about how this would operate in practice.

Question 23 - How would you rate your broad satisfaction with the proposals for Small Business Support?

3.31 The largest proportion (46%) were satisfied overall with the proposals for small business support but approximately a third expressed a neutral view. There was widespread support in principle for having a fund set aside specifically to provide support to small rural business, and this was across the range of those responding satisfied, dissatisfied or neutral. The range in response types was reflective more of concerns over particular aspects of the proposal, such as the requirement for clarifications on issues such as eligibility and fund administration. There was widespread support, especially from local authorities for using Business Gateway for administration. The need for clear sign-posting between what is supported by LEADER versus Small Business Support was mentioned by some respondents

Question 24 - Should the Scottish Government continue to give significant support to the food and drink industry?

3.32 There was a large majority in support of this proposal (76%) with forestry organisations being the key objectors.

Question 25 - Should selection criteria apply to the Food and Drink scheme?

3.33 There was widespread support for all four options overall (contribution to the Scottish Government's strategies for economic development and the rural economy 75%; making a contribution to national policies for food and drink 70%; assisting the Scottish Government with wider social policies 63%; supporting export targets for food and drink 63%).

Question 26 - Should steps be taken to streamline processes for food companies including a one stop shop for public support?

3.34 Of the 113 respondents to this question that expressed an opinion, 86% agreed with the proposal. A further 61 respondents did not express any opinion (35%).

Question 27 - How would you rate your broad satisfaction with the proposals for food and drink support?

3.35 There was a very low level of dissatisfaction with this proposal (11%). The greatest proportion were either quite satisfied or very satisfied (51%), with a large proportion expressing a neutral opinion (38%). For some of those who were either dissatisfied or neutral about plans to support the food and drink sector through SRDP, it was felt that this was not justified with the constrained resources available. The sector was either seen as successful and not in market failure or in need of support or it was argued that the sector should be supported from elsewhere. Comments were made about the need to make the application process fairer for smaller businesses and to ensure that more than just business development, i.e. wider social and environmental benefits, was being funded. A range of priorities and application criteria were suggested and views were variable on how to administer the grant.

LEADER Support

Question 28 - How would you rate your broad satisfaction with the proposals for LEADER?

3.36 Half of respondents were satisfied with the proposals, with just over 10% expressing dissatisfaction. A large percentage (40%) were neither satisfied nor dissatisfied. Respondents noted that LEADER was a good exemplar of integrated rural community development and were specifically positive about the proposal to support cultural heritage, the ability to combine LEADER and EMFF (European Maritime and Fisheries Fund) under one Local Development Strategy and the focus on community action on climate change. Dissatisfaction tended to relate to budgets with respondents concerned that the 5% allocation was inadequate. This criticism was particularly strong amongst local authorities and community bodies. Others called for improvements on the previous Programme to the administrative, audit, compliance and payment procedures. Some LEADER Action Groups (LAGS) specifically requested that robust guidance be available and implemented at the start of the programme. Those with a stated interest in farming were more likely to respond that too much priority was given to LEADER projects.

Knowledge Transfer and Advice Services

Question 29 - Do you agree with the range of options being included within the Knowledge Transfer and Innovation Fund (KTIF) scheme?

3.37 There was broad support for including skills development (93%), vocational training (88%) and monitor farms (75%) within the KTIF scheme, however only half supported the idea of setting up a European Innovation Partnership (EIP). This was the least popular option amongst both individuals and organisations, with individuals with a stated interest in farming or crofting most likely to be neutral about the EIP proposals.

Question 30 - How would you rate your broad satisfaction with the proposals for Knowledge Transfer and Innovation Fund (KTIF)?

3.38 The majority of respondents (66%) were in favour of the proposals. Just 7% expressed dissatisfaction and 27% were neither satisfied nor dissatisfied. There was no difference between individuals and organisations in the way that they responded to the question. There were some warnings related to the promotion of the scheme and duplication with other initiatives, with some respondents, particularly those from local authorities, calling for a clear distinction to be made between the activities supported under this scheme and those that can be supported under LEADER.

3.39 There were mixed views in relation to funding, whereby some respondents welcomed the increase in the budget allocation whilst others questioned whether this scheme should in fact be SRDP funded.

3.40 There were positive comments in support of the intention to link the KTIF more closely with Skills Development and the Advisory Service.

3.41 A number of respondents had particular views on what the focus of the proposed training and development should be. These included:

• A need to train young people in rural areas to enable them to remain locally.
• Exchange visits and international best practice should be part of the learning process.
• Greater emphasis on knowledge transfer between farmers pioneering innovative measures.

Question 31 - How would you rate your broad satisfaction with proposals for the Advisory Service?

3.42 Around 44% of respondents were satisfied with the Advisory Service while a quarter were dissatisfied. Almost a third were neutral to the proposals. Comments made revealed mixed feelings amongst respondents. While some welcomed the development of a co-ordinated Advisory Service, others raised concerns around whether the service would duplicate existing commercial advice services, with forestry individuals and organisations most likely to raise concern about this issue.

3.43 Stakeholders also noted what they would like the Advisory Service to include. Some of the suggestions made were:

• A clearer route to support for rural social enterprises, community-owned enterprises and other forms of co-operative business.
• A greater focus from RPID offices supporting rural businesses in maximising output rather than regulating.
• Advisors who were aware of crofting legislation and in particular grazing regulations.
• An environmental advice service based on sustainability and not purely on economics.

Communications and Scottish Rural Network

Question 32 - Do you think the tasks set out above are the most appropriate ways for the Scottish Rural Network (SRN) to add value to the implementation of the SRDP?

3.44 At almost 80% support was highest for an SRN website. Support was also high for disseminating information to the public (75%), gathering of good programme examples (74%), and organisation of events (69%). Respondents gave a large list of other tasks they would like to see included within the SRN, including: funding for training, better links with commercial as well as community rural issues and more focus on environmental projects. Individuals and organisations with a stated interest in forestry would like to see the inclusion of forestry elements within the SRN.

3.45 Some commented that there was potential for duplication between the SRN, the Advisory Service and the KTIF.

Question 33 - Do you agree with the proposal to establish thematic working groups as an approach to supporting the Rural Development programme priorities?

3.46 Around 60% agreed with the proposal to establish thematic working groups, 13% disagreed and just over a quarter had no opinion. Some respondents, while recognising the potential of the thematic working groups, expressed reservations about duplication of work and the danger that they may just become 'talking shops'. Others were more strongly against and asserted that they were a waste of resources and questioned their likely effectiveness.

Question 34 - How would you rate your broad satisfaction with proposals for the Scottish Rural Network?

3.47 Overall, half of respondents were satisfied with the proposals for the SRN; 14% expressed dissatisfaction and over a third were neutral about the proposals. Some respondents were positive about the potential role of the SRN and outlined a number of services they would like to see provided by the network. Other respondents were critical of the proposals, arguing that they were complicated and over-bureaucratic; lacked a grass roots approach; overlapped with LEADER, Advisory Service and KTIF; and seemed particularly focused on community issues, which would provide little benefit for other groups, in particular farmers.

Question 35 - How would you rate your broad satisfaction with the proposals for communicating the new Scotland Rural Development programme?

3.48 Exactly half of respondents were satisfied with the communication proposals; 17% were dissatisfied, while a third were neither satisfied nor dissatisfied. Respondents were critical of a number of issues around communications including: perceived bias towards communicating farming issues, the absence of good rural broadband which acts as a barrier to accessing communications; and the inability to access guidance in a user friendly format.

3.49 Respondents made several suggestions for improvement including the need for complex terminology to be avoided, greater emphasis on press and media relations, clear on-line advice, direct contact with case officers, a single initial point of contact as well as better communication of the aims of the Programme and not just the grant mechanisms. There were also requests for improved guidance relating to the grant schemes, in particular the facility to access and print PDF versions of guidance on the website.

Monitoring and Evaluation of the SRDP

Question 36 - Information used to monitor and evaluate the SRDP will be gathered from a mixture of data sources. Three key data sources required to capture monitoring and evaluation data are outlined in the consultation document. We would welcome feedback on the approach outlined.

3.50 There were mixed views on the monitoring and evaluation section with some respondents thinking that it looked a good, practical and proportional approach. However, some noted that evidence from the monitoring and evaluation of the current Programme had revealed many difficulties in accessing good quality data and suggested that more bespoke/specific surveys would be needed to measure 'on the ground' change.

3.51 Many respondents gave views on the framework saying that it should aim to show contribution to outcomes, value for money of grants and long term impacts. Monitoring and evaluation should also be proportional to the grant level and there needs to be recognition of the capacity of grant recipients to provide information.

3.52 There was also commentary around the necessity to have the monitoring framework firmly in place before the commencement of the new Programme.

Question 37 - Are there any other data sources which could inform the impact of the programme?

3.53 Less than half (43%) of those responding stated that there were other data sources which could be included. Respondents provided examples of potential data sources including: specific publications, documents, statistics and organisations. Respondents were also keen on gathering customer satisfaction type information from users and non-users of the SRDP process and grants.

Question 38 - The Scottish Government has identified a number of gaps in the indicator requirements and has set out plans for addressing these gaps. We would welcome feedback on the proposed approach to filling the gaps in the data (including other data sources) required by the European Commission.

3.54 There were less than 50 responses submitted to this question. Comments centred around gaps in the proposals, including a lack of social or economic indicators; concerns about levels of bureaucracy; and a need for more localised and specific 'enhanced' data. Other respondents specifically mentioned the absence of some indicators, for example: in assessing greenhouse gas emissions, biodiversity and animal welfare.

Question 39 - Are there any other gaps that you wish to make us aware of?

3.55 A third of respondents noted gaps in the framework. Some of these were strategic, for example the impact of the SRDP on the aims and principles of other key strategic documents such as the Land Use Strategy and the European Landscape Convention, or on the general sustainable position of the rural economy. There were also some concerns about whether the proposals would meet any requirements from Audit Scotland. A range of detailed subject-specific gaps were also noted.

Question 40 - Are there any other data sources which could help us fill the data gaps?

3.56 Around 40% of respondents stated that there were additional data sources available to help fill the data gaps. Some respondents identified specific data sources whilst others gave more general comments including: the need for greater consideration of biodiversity indicators, the need for an improvement to the collection of forestry data, that greater use should be made of GIS for environmental indicators, and that a Monitoring and Evaluation expert Panel be convened to assist in drawing up the framework.

Impact Assessments

Question 41 - We would welcome comments on the Business and Regulatory Impact Assessment (BRIA).

3.57 There were 30 comments to this question and the responses were quite diverse. Some respondents noted that the BRIA was a positive step to look at the wider impact of the SRDP upon businesses and other stakeholders, and that the aspirations set out in the BRIA were commendable. Other respondents were critical of the BRIA saying that because it was 'partial' it did not identify all of the potential negative impacts and did not consider how the SRDP distorts the rural economy, hence negatively impacting on non-public funded businesses and the price of land.

Question 42 - We would welcome comments on the Equalities Impact Assessment (EQIA).

3.58 There were 31 comments on the EQIA and again these were quite diverse. Some respondents referred specifically to the content of the EQIA, while others listed particular equalities groups that should be targeted by the SRDP. Commentary included: targeted support for young people to enable them to remain in rural areas; foreign language skills for rural dwellers and English language classes for migrants, both of which would facilitate successful integration of migrants in rural areas; increasing IT skills which may help address isolation amongst the disabled and the elderly; and initiatives to address the 'older white male bias' in rural Scotland.