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DRAFT RURAL DEVELOPMENT REGULATION
ANALYSIS OF RESPONSES TO CONSULTATION

CHAPTER 3 - RESPONSES TO STRATEGY & PROGRAMMING ISSUES (articles 1-18)

Objectives and General Rules on Assistance

The Commission has developed three major objectives for rural development policy for the period 2007-2013 to ensure the sustainable development of rural areas. These reflect the November 2003 Salzburg conference and the outcomes of the Lisbon and Goteborg European Councils. The relevant measures were;

A number of questions were posed in the consultation and consultees were invited to respond to these. These are shown in bold bullet points. The following summaries reflect the written comments received.

• Are the 3 objectives the right ones for ensuring the sustainable development of rural areas in Scotland?

In general there was support for the 3 proposed objectives, although there were some differences in interpretation. While the Scottish Association of Meat Wholesalers wanted more emphasis put on competitiveness, the Council for Scottish Archaeology was not convinced that a separate axis specifically concentrating on the competitiveness of forestry and agriculture was appropriate. Success would depend on which measures were implemented and given priority under each axis, and requests were made for more emphasis on other rural factors and explicit support to encourage co-operative action and solutions. While Quality Meat Scotland did not have any problem with the objectives, it did see problems in terms of delivery. The British Horse Society, while agreeing with the three major objectives, suggested that the equine industry should be included as one of the priority objectives for Scotland. The Institute of Chartered Foresters insisted that a mechanism be in place to ensure cross cutting activities could be supported and encouraged, and the Southern Uplands Partnership argued that the central aim of rural partnership should be to support land use patterns and practice that conserve biodiversity. Scottish Borders Council had a concern that much of the funding for the axes was likely to come from modulation. As farms in the Borders were relatively large in European terms, it was important that the Executive provide additional funding to match fund the measures, or for ring fenced modulated funds to be spent on measures within the Borders.

The dissenting voices were from David Woodhouse (of Isle of Mull Wildlife Expeditions) who felt the objectives were not relevant to modern Scotland, and should focus on eco-tourism, Scottish Crofting Foundation who felt that the three axes would not assist in the development of coherent, integrated rural development measures, and Scottish Natural Heritage who proposed 4 objectives as follows;

"Promoting adjustment of agriculture and associated business, through re-structuring. This corresponds to some extent to the Commission's first objective, but we would prefer it to be worded so as to give less emphasis to simply 'increasing competitiveness'.

Enhancing the environment and countryside by means of support for land management - based at least in part on a system of payment for public goods and taking due account of national and EU priorities.

Enhancing the quality of life in rural areas and promoting diversification into sustainableeconomic activities. This could involve payments both for 'social' public goods and services, some of which might be associated with access to the countryside, and investment to encourage economic activity.

Encouraging the further development of a multi-functional role for agriculture and other land-based activities."

Historic Scotland believed that in general the measures represented a missed opportunity for rural development.

Strategic Approach to Rural Development

The Commission proposed that EU and national strategy documents should be created so that rural development programmes are focussed on EU priorities and complement other EU policies (particularly Cohesion policy) for the programming period 2007-2013. Measures were;

• Do we need both EU and national strategy documents?

• If not, which would you retain and why?

• Should we have a Scottish strategy document?

• How closely should the EU strategy define the UK and/or Scottish strategy?

This produced a fairly varied set of responses. The only organisation to speak against a European strategy was Nation al Farmers Union Scotland, arguing that it was inconsistent with the bottom up LEADER approach. Both NFUS and Quality Meat Scotland were against a national strategy on the grounds that agriculture and rural development are devolved, so there should be no UK policies. The rest seemed to feel they were inevitable, although cautioning that they must reflect the needs of the differing regions and sub regions. A national strategy was felt to be beneficial in light of the huge variety in need between Member States. SNH in fact argued that the Commission's approval of a national strategy could allow it to relax its approach to approving rural development plans.

There was strong support for a separate Scottish strategy, the only dissenting voices being NFUS who believed it was unnecessary in light of the Scottish Rural Development Plan, and Highland Council who argued that there should be a separate strategy for the Highlands and Islands. The Crofters' Commission also favoured a strategy at sub-regional (e.g. Highlands and Islands) level. Organisations in favour included; Aberdeenshire Council who saw it as "essential to enable assessment of the diversity of priorities for sustainable rural development"; Scottish Association of Meat Wholesalers "appropriate to have a distinct Scottish strategy to address Scottish priorities and policies as highlighted in the Forward Strategy document; and Scottish Agricultural Organisation Society "essential that there is also a clearly defined Scottish strategy for rural development which would recognise the importance of factors particular to the Scottish rural economy and the structure of the Scottish economy generally." Midlothian Council was in favour of a Scottish strategy, but suggested that Local Authority involvement should be recognised.

Both Comhairle nan Eilean Siar and Southern Upland Partnership were concerned that there was a danger of too many strategies.

It was generally felt that any EU strategy should act as a framework only and be general enough to allow Scotland to develop policies that met its own priorities. It should be enabling, and not prescriptive. On this basis, Historic Scotland was not concerned whether the Scottish strategy be free standing or form part of a wider UK strategy.

Programming

In the draft regulation it was proposed that Member States' rural development programmes would implement national rural development strategies through a set of measures grouped under the three priority axes. The programmes would articulate the national strategy into a strategy for each axis, using quantifiable objectives and core result indicators. Relevant measures were;

• Should the RDR complement national (i.e. Scottish) policies as well as Community policies?

• If so which ones?

• Is the proposed distribution of resources to each axis the right distribution?

• If not, what should the distribution be?

• Should a minimum level of funding be set for the LEADER axis?

• What should that be?

There was general agreement that the proposed RDR is complementary to, and dovetails with, national and regional strategies. Scottish Estates Business Group stated that the RDR "should not be prescriptive but should allow for implementation as appropriate to regional and local circumstances and needs." Highland Council went further in saying that it was more important to reflect sub-regional (rather than national) needs.

Most organisations said that the particular policies should be those that would further advance the Forward Strategy documents for agriculture and forestry. Future policy should also take account of national and regional forestry strategies and Custodians of Change. SNH summarised the policies it felt should contribute to the basis of any Scottish strategy;

• The Forward Strategy for Scottish Agriculture;

• Custodians of Change (the report of the Forward Strategy Environmental working Group);

• Natural Heritage Futures (Published by SNH);

• The Scottish Biodiversity Strategy and the National and Local Biodiversity Action Plans;

• NPPG 14 - The Natural Heritage;

• NPPG 11 - Sport, Physical Recreation and Open Space;

• Land Reform - public access to the countryside;

• Policy for National Scenic Areas;

• The responsibility of public bodies (under the Nature Conservation Act) for the conservation and enhancement of sites of Special Scientific Interest.

The question of distribution to each axis provoked a wide divergence of views. RSPB "to ensure that agri-environment spend in all Member States is sufficient", Highland Council "to maintain support to LFAs and allow appropriate introduction of Land Management Contracts," and Scottish Natural Heritage wanted to see spend on Axis 2 increased to 50%. Aberdeenshire Council and Scottish Estates Business Group wanted to see it increased to 30%. Southern Upland Partnership felt that Axis 3 was of vital importance and needed to be adequately resourced. Other organisations, including National Farmers Union Scotland, Quality Meat Scotland, Scottish Association of Meat Wholesalers, Scottish Agricultural Society and Council for Scottish Archaeology argued that there should be no minimum spend on the grounds that it would reduce flexibility. Both QMS and SAoMW stated that if minimum spends were to be imposed, they should be the same for each axis. CSA recognised that if no minimum spends were established the axes may become optional. They felt that the problem was defining the individual priorities in each Rural Development Plan and matching them to these axes. Argyll and Bute Council queried how an integrated project which cut across all axes would be dealt with.

With regard to LEADER there was again diverging views. Aberdeenshire Council, Highland Council and Scottish Estates Business Group supported the 7% minimum (SEBG stated that "as there will be pressure for LEADER funding a minimum allocation would ensure that a proportion of bids were successful"). Both COSLA and Argyll and Bute Council supported the ring fencing approach, as the innovation may otherwise disappear. Comhairle nan Eilean Siar wanted the minimum raised to 10% as it argued that LEADER offered opportunities to the most vulnerable communities. Midlothian Council also wanted to see an increase.

Other organisations, such as National Farmers Union, Quality Meat Scotland and Scottish Association of Meat Wholesalers were generally opposed to any minimum being set (SAoMS argued that "the overall aim should be maximum flexibility"). Neither Scottish Natural Heritage nor the Council for Scottish Archaeology felt able to attach any resource requirement at this stage.

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