Scotland Rural Development Programme 2014-2020 - Consultation on Stage 1 Proposals : An Analysis of Responses

7 Application and Assessment Process for Agriculture, Environment, Landscape and Forestry

7.1 This chapter presents an analysis of respondents' views regarding Section 8 of the consultation document. This set out the Scottish Government's proposals for new assessment processes for agricultural, environmental, landscape and forestry investments. The proposals concerned three schemes - LFASS (to become the new ANC scheme), CCAGS (or the replacement crofting scheme) and Rural Priorities. Views were sought on four proposals: (i) a case officer approach to assessment of applications; (ii) a single entry route for applications with a two level assessment process; (iii) variable rather than fixed intervention rates; and (iv) the setting of regional budgets across Rural Development Regulation articles.

7.2 Section 8 also sought views on the support and assistance applicants would need in pursuing applications. These views are discussed in Chapter 10 together with other findings related to advice services for SRDP 2014-2020.

Case officer approach to assessment (Q15)

7.3 The consultation document set out proposals to develop a case officer assessment network, supported by a 'gatekeeper' who would judge whether an application requires assessment by the network. It was suggested that this would ensure that applications are assessed with appropriate knowledge and expertise. Respondents were asked:

Question 15: Do you agree or disagree with the proposed case officer approach to the assessment of applications? Please explain your views.

7.4 In total, 97 respondents (14 individuals and 83 organisations) answered Question 15. Of these, 65% agreed with the proposal to adopt a case officer approach to assessment and 14% disagreed. See Table 7.1.

Table 7.1: Summary of responses by respondent type (Q15)

Type of respondent	Individuals	Organisations	Total respondents	%
Agree	6	57	63	65%
Disagree	3	11	14	14%
Other	5	15	20	21%
Total	14	83	97	100%

7.5 The figures in the table above should be treated with caution. In the consultation document, this question sat within a section that described the application and assessment process for agriculture, environment, landscape and forestry investments. However, respondents did not necessarily limit their answers to these sectors, offering comments instead on SRDP processes more generally.

7.6 In general, respondents' comments to this question suggested that they were supportive of the principle of the proposed case officer approach to the assessment process. However, substantial concerns were raised with how this proposal would be implemented in practice.

Views in support of the case officer approach to assessment

7.7 Those who agreed with the proposal thought that the case officer approach to assessment would, as set out in the consultation document:

• Provide a simplified and streamlined approach
• Increase the efficiency of the application process
• Allow a personalised service, with a single case officer allocated to each application.

Caveats and disagreement with the case officer approach to assessment

7.8 Caveats and disagreements with the case officer approach referred to the following issues:

• The skills and expertise required by 'gatekeepers' and case officers: This aspect attracted comment from many respondents. Respondents were not convinced that the current complement of case officers had sufficient skills and expertise to provide high quality, consistent advice. Moreover, the skills and expertise required of 'gatekeepers' had not been fully defined. There was concern about how this would be addressed and how it would be funded.
• The importance of an open and transparent assessment process: Respondents highlighted the importance of transparency and specifically wished to emphasise: the value of site visits and having an early indication of the likelihood of success; constructive feedback on all applications; a clearly defined appeals process; and a scoring system which commanded support.
• The need for improved collaboration between agencies and organisations: Respondents wanted to know that there would be a holistic assessment process and a shared understanding across agencies and organisations of what constitutes a 'good' application. Respondents suggested that much could be learned from the LEADER programme.

Other issues

7.9 Some respondents believed that this seemed like an overly bureaucratic approach, especially for small projects. The forestry sector did not think the 'gatekeeper' approach was appropriate within forestry.

7.10 It was suggested that responsibility for all applications within its geographic area could be given, on a pilot basis, to the National Park Authority.

7.11 There was a widespread view that there was not enough information to allow more than 'in principle' support to be given. Respondents required more detail about how the system would operate including: what criteria would be used to decide whether the case officer network was utilised; how local accountability would be arranged; how potential conflicts of interests for case officers would be handled; how single objective applications from the agricultural sector would be handled; and the level of flexibility which would be available.

Single entry route with two level assessment (Q16)

7.12 The consultation document set out the Scottish Government's proposals to develop a single entry route, with two levels of assessment depending on the cost / complexity of proposals. This was intended to achieve a competitive approach across all SRDP grants and provide maximum value for money. Respondents were asked:

Question 16: Do you agree or disagree the proposed single entry route for applications with a two level assessment process? Please explain your views.

7.13 In total, 87 respondents (13 individuals and 74 organisations) answered Question 16. Of these, 84% agreed with the proposal and 8% disagreed. See Table 7.2.

Table 7.2: Summary of responses by respondent type (Q16)

Type of respondent	Individuals	Organisations	Total respondents	%
Agree	11	65	76	84%
Disagree	2	2	4	8%
Other	-	7	7	8%
Total	13	74	87	100%

Views in support of the single entry with two level assessment process

7.14 Those who agreed with the proposal thought that the single entry with two level assessment process would, as set out in the consultation document:

• Be better and simpler for the applicants
• Increase the efficiency of the application process and reduce the costs
• Provide better value for money through the use of competitive grant funding mechanisms.

Caveats and disagreement with the two level assessment process

7.15 Caveats and disagreements with two level assessment process were that:

• Clarity is required about where the threshold between Level 1 and Level 2 applications is set: This was the main specific issue raised by respondents. Some suggested a figure of around £10,000 would be appropriate, whilst one suggested £25,000. Respondents from the forestry sector wanted 'delegated authority' to continue and for the threshold to be raised above its current level of £750,000. Some respondents thought that the threshold should not be determined financially, but by the level of complexity or contentiousness.
• The assessment process should be open and transparent: Respondents highlighted the importance of transparency and specifically wished to emphasise: the importance of a properly resourced assessment process with fully qualified and competent assessment officers; high quality guidance with clear indications of the timetable for assessment; rules for defining conflicts of interest and how these would be managed; the undertaking of site visits to establish the merit of an application at an early stage and the potential for collaboration; and a broad-based panel offering a range of expertise for Level 2 applications.
• Bureaucracy should be minimised: Respondents wished to be reassured that the amount of bureaucracy associated with Level 1 applications would not be disproportionate. They favoured a 'light touch' for Level 1 applications in relation to reporting requirements.

Other issues

7.16 It was suggested that Level 2 assessments should be made on a regional basis (by the replacement for RPACs), not on a national basis. There was comment about the merit of ring-fencing of funds for Level 2 budgets and the requirement for regional budgets to make this approach work.

7.17 Some respondents from the forestry sector thought that this kind of approach had not worked for forestry in the current SRDP programme. One respondent provided a rationale for a 3 level (rather than 2 level) assessment process.

Variable intervention rates (Q17)

7.18 The consultation document set out the Scottish Government's proposals for intervention rates (i.e. the percentage of a project's cost to be funded from SRDP) to be negotiated (by the case officer) rather than set at a fixed amount. Respondents were asked:

Question 17: Do you agree or disagree with the proposed negotiation of variable intervention rates rather than setting fixed intervention rates? Please explain your views.

7.19 In total, 85 respondents (12 individuals and 73 organisations) answered Question 17. Of these, 74% agreed with the proposal for the negotiation of variable intervention rates and 18% disagreed. See Table 7.3.

Table 7.3: Summary of responses by respondent type (Q17)

Type of respondent	Individuals	Organisations	Total respondents	%
Agree	9	54	63	74%
Disagree	3	12	15	18%
Other	-	7	7	8%
Total	12	73	85	100%

7.20 Although the consultation document explained that variable intervention rates were relevant in the context of commercial investments only, respondents to the question did not necessarily take this as read. There is, therefore, a lack of clarity in relation to the context in which responses were offered, with many emphasising that it was not appropriate to assess projects for public benefit in this way.

Views in support of variable intervention rates

7.21 Those who agreed with the proposal thought that variable intervention rates would:

• Improve cost effectiveness
• Allow limited resources to go further
• Align this element of SRDP funding with other EU, Common Strategic Framework (CSF) and SRDP funding mechanisms (including LEADER).

Caveats and disagreement with variable intervention rates

7.22 Caveats and disagreements with variable intervention rates were that:

• It could increase the complexity of decision-making: It was suggested that this change could introduce uncertainty, increase bureaucracy, slow down decision-making and generate many complaints and appeals. One of the strengths of the current arrangement was seen to be its relative simplicity. This change would have to be accompanied by very clear guidance to make the process of decision-making and review transparent.
• Case officers would require training for this task: The point was made that case officers do not necessarily have sufficient expertise for this and consistent decision-making would require an investment in training and development. A system of reviewing decisions would also be needed.
• The negotiation should be done by a central team: There was a view that, rather than have this negotiation done locally by case officers, a central team should undertake the negotiation of intervention rates.
• Other models and implementation approaches should be considered: A range of other models and implementation approaches were suggested including: applying variable intervention rates for larger grants only; fixing a maximum rate; allowing applicants to suggest an appropriate rate which could be reviewed by case officers; combining a minimum (standard) intervention rate with the potential for uplift in certain defined circumstances.

Other issues

7.23 A forestry organisation stated that this approach would not be acceptable within forestry. This organisation said that the Scottish Government could be enabled to change intervention rates in specific cases without requiring a full blown revision of the scheme.

Regional budgets (Q18)

7.24 The consultation document set out the Scottish Government's proposal to allocate budgets across articles, and to give an indication of the resources (based on evidence) available to each of the Rural Priority regions. This arrangement was intended to address problems identified in the previous SRDP related to the lack of effective budget allocations, profiling and management arrangements. The new arrangement would be linked to regular central budgetary oversight to ensure allocations were being spent as forecast. The following question was asked:

Question 18: Do you agree or disagree with the proposed setting of regional budgets across Rural Development Regulation (RDR) articles? Please explain your views.

7.25 Altogether, 91 respondents answered this question (14 individuals and 77 organisations). Of these, 66% agreed with the proposal and 22% disagreed. See Table 7.4.

Table 7.4: Summary of responses by respondent type (Q18)

Type of respondent	Individuals	Organisations	Total respondents	%
Agree	9	51	60	66%
Disagree	3	17	20	22%
Other	2	9	11	12%
Total	14	77	91	100%

Views in support of regional budgets

7.26 Those who supported the proposal to set regional budgets thought it would:

• Make better use of local knowledge
• Encourage priority-setting and a more focused, targeted delivery strategy
• Result in better local outcomes
• Enable better monitoring of spend and thus a better return on investment
• Give applicants a clearer idea of what resources were available and the likelihood of success when applying.

7.27 Respondents agreed that a weakness of the current SRDP had been a lack of effective budgetary control and management arrangements and so welcomed the Government's efforts to address these issues.

Caveats and disagreement with regional budgets

7.28 Many of those who agreed with this proposal said they did so in principle only. Respondents often set strong conditions upon their agreement, including that:

• The mechanism for allocating regional budgets must be transparent and fair: Regional budgets must be allocated on the basis of evidence of need, and should be linked to regional objectives and targets.
• There would need to be a good monitoring system (regionally and centrally) and a mechanism for re-allocating underspend from one region to another: Respondents repeatedly emphasised the need for flexibility. It was also suggested that budgets could be set annually so that funding would not run out in the final years of the programme.
• Adequate management resources must be available with local responsibility for allocating budgets: There was a concern that if RPACs were to be disbanded and replaced by a centralised assessment process, there would be no local mechanism for prioritising applications.
• The recommendations of the Mid Term Evaluation in relation to the current Rural Priorities scheme should be addressed.

7.29 Those who disagreed with the proposal argued that:

• It would lead to increased administrative complexity: Respondents believed strongly that the Scottish Government should avoid this
• It would result in a lack of flexibility: Respondents were concerned that regional budgets could prevent funding going where it should go
• Regional allocations must be based on evidence of need: Some respondents were not confident this would happen. Others thought substantial resources would be needed to make it happen, thus diverting resources away from the schemes themselves.

7.30 Irrespective of whether they agreed or disagreed with the proposal, respondents expressed concerns that:

• Regional budgeting was inappropriate for certain types of projects: For example food and drink, water quality, forestry and bio-diversity projects relating to protected species
• Regional budgets could result in inconsistency in decision-making: For example larger projects of poorer quality may be funded because a particular region has the budget available, whereas better quality projects in a different region may be refused if the budget has all been allocated.

Other issues

7.31 Other points made by respondents included the following:

• SRDP and Structural Fund budgets should be aligned
• Regional budgets should be indicative only, with overall central control
• A seven-year (farming-oriented) grant programme was thought to be inappropriate for forestry. Consistent, longer-term support was needed for the forestry sector.
• Budget allocations under each article should be determined locally
• Some budget should be set aside for national initiatives which could be delivered across all regions.

7.32 There was a strong view that, without further information, it was not possible to say whether regional budgets would be workable. Respondents wanted details about:

• The proposed number of regions
• How regional allocations would be determined and what level of funding would be available to each region
• How to identify, and the role(s) of, appropriate regional 'experts'
• How regional budgets would be administered and monitored
• How underspends would be reallocated.