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

8 Integrated Investments

8.1 This chapter provides an analysis of responses regarding Section 9 of the consultation document on integrated assessments. The specific questions posed in this section related to the production of a descriptive map of holdings and the possibility of allowing applicants to submit single setting out all investments / projects on their land that they would like to take forward.

Descriptive map of holdings (Q20)

8.2 The consultation document set out the Scottish Government's proposals to complement a national approach to targeting with targeting at the level of a holding, supported by the development of a descriptive map of holdings. The map was intended to give SRDP applicants, advisors and assessment officers information about significant sites that could benefit from action or protection on each particular holding. Respondents were asked the following question:

Question 20: Do you agree or disagree with the value of developing a descriptive map of holdings to help farmers and stakeholders understand the potential ecosystem value of specific holdings? Please explain your views.

8.3 In total, 89 respondents (16 individuals and 73 organisations) answered Question 20. Of these, 84% agreed with the proposal to develop a descriptive map of holdings and 9% disagreed. See Table 8.1.

Table 8.1: Summary of responses by respondent type (Q20)

Type of respondent	Individuals	Organisations	Total respondents	%
Agree	11	64	75	84%
Disagree	4	4	8	9%
Other	1	5	6	7%
Total	16	73	89	100%

8.4 In general, respondents' comments to this question suggested that they were supportive of the idea of developing a descriptive map of holdings.

Views in support of developing a descriptive map of holdings

8.5 Those who agreed with the proposal thought that the development of a descriptive map of holdings would:

• Be useful for farmers, advisors, and other delivery partners
• Support a targeted approach to the allocation of funds, especially in relation to addressing environmental issues
• Contribute to the delivery of the Land Use Strategy
• Improve assessment and monitoring processes.

Caveats and disagreement to developing a descriptive map of holdings

8.6 Caveats and disagreements with developing a descriptive map of holdings were that:

• A "top down" approach is not a panacea: Respondents emphasised that there is no substitute for a "bottom up" understanding of what exists at the farm scale. It was important not to be overly optimistic about what this type of approach could achieve.
• It might divert resources away from the primary purpose of SRDP: The point was made repeatedly that this was a significant undertaking, and would require substantial resource to implement. Many did not support SRDP resources being used for this purpose.
• The underpinning data are not of uniformly high quality: Respondents emphasised that the basic information required was often sparse, of poor quality or unavailable. Filling these gaps would require substantial resources. To be useful, the map would have to be comprehensive and accurate.
• The asset would have to be accessible to all potential users: Respondents wanted to be reassured that any resource which was developed would be provided to all applicants in a form which was suitable for them.
• It could increase complexity and delay decision-making: It was suggested that the implementation of a similar approach within forestry had been problematic and had delayed decision-making.

Other issues

8.7 There was a suggestion that this type of approach might only be appropriate within the context of larger land holdings and / or collaborative bids and applications. One respondent suggested that the approach could be piloted by the National Parks Authority.

Single applications for integrated investments (Q21)

8.8 The consultation documented acknowledged the frustration voiced by applicants in relation to the previous SRDP about the need to apply on multiple occasions to different schemes to secure funding for different priorities. For SRDP 2014-2020, the Scottish Government has proposed to enable single integrated applications allowing applicants to set out all land-based investments / projects they would like to take forward. The consultation document asked the following question about this proposal:

Question 21: Do you agree or disagree with the proposal to allow applicants to submit single applications which set out all investments / projects that the applicant would like to take forward on their land? Please explain your views.

8.9 In total, 91 respondents (14 individuals and 77 organisations) replied to Question 21. Of these, 89% agreed with the proposal and 4% disagreed. See Table 8.2.

Table 8.2: Summary of responses by respondent type (Q21)

Type of respondent	Individuals	Organisations	Total respondents	%
Agree	10	71	81	89%
Disagree	3	1	4	4%
Other	1	5	6	7%
Total	14	77	91	100%

Views in support of single applications for integrated investments

8.10 Those who agreed with the proposal to allow single applications for all the investments / projects an applicant wanted to take forward felt that this would:

• Simplify matters and be more efficient
• Promote strategic, holistic and coherent planning of projects
• Result in better integration of the various SRDP funding streams.

Caveats and disagreement with single applications for integrated investments

8.11 While respondents generally supported the principle of single applications for integrated investments, they also frequently raised concerns about the proposal, including that:

• Integrated applications may not be appropriate for all applicants or circumstances: Such a process may appeal to some applicants but may not be appropriate for others, e.g. small businesses or those in the forestry sector. It was also suggested that such an approach might work well if the business aspects of the farm were closely related to the environmental aspects, but not in situations where these aspects might be quite distinct (e.g. in relation to intensive arable holdings).
• The cost and complexity of developing an integrated application may be prohibitive for some applicants: It was suggested that, to avoid inequalities, support and guidance would need to be made available to applicants.
• There would be a need for flexibility: Some respondents saw the benefit of creating an overall, long-term plan but argued that many applicants, having created such a plan, may still prefer to apply for projects individually according to their own timescales and circumstances. The point was also made that applicants need to be able to respond to changing economic circumstances and market forces which they could not necessarily foresee at the point when they put together a single application.

8.12 Given these concerns, there was a general view among respondents that the single integrated application procedure should be allowed, but should not be required. Moreover, integrated applications should not be given preference over single project applications that address agreed priorities.

8.13 Respondents also highlighted potential difficulties regarding the handling and assessment procedures for integrated applications in terms of:

• Administrative complexity: It was thought that multiple case officers would complicate the assessment process, resulting in delays.
• Time and expertise required: There was a view that it could be difficult for the 'gatekeeper' to decide which agencies should be involved in assessing an application. There was also a concern about whether the necessary expertise would be available within agencies to assess the business elements of an application. The importance of case officer training was raised. Finally, there was a view that there could be difficulties in judging which large applications would be likely to deliver the greatest public good.
• Dealing with the individual elements of a multi-project application: There were concerns that funding may be wasted on non-priority activities simply because they were part of an integrated application. There was a strong feeling that there needed to be the option to remove non-priority or inappropriate activities without failing the entire application.

Other issues

• Local authorities have comprehensive GIS systems which could potentially be put to use in supporting such applications.
• One respondent noted that the current system of multiple applications for different projects had evolved from a single application approach in the past. This had been abandoned because it was perceived not to work. The individual cautioned against making the same mistakes again.