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2 Summary of Findings

This chapter summarises the main findings from the consultation. A more detailed analysis is provided in Chapters 7 to 10.

Consultation responses to the content of the SRDP Consultation document

Less Favoured Area Support Scheme ( LFASS)

Q.1. Do you agree with the "historic payments" system proposed for LFAs?

1.1. Those who agree with the proposed historic payments system, state that such an approach gives a period of stability/continuity following CAP changes and before further changes in 2010. However, others argue that this 'stability' is short-lived.

1.2. Those who disagree with the historic payments system feel that:

• it will lead to a decline in the number of cattle being kept by farmers, with direct, negative environmental implications;
• such a system will create less flexibility, especially for new entrants; farming will be stagnant, with less opportunity for innovations;
• it will not address the genuinely fragile rural areas, since much of the resourcing appears to go to the "standard" LFAs;
• as well as reducing flexibility at the farm level, the proposed system will hinder flexible reallocation of funds between Axes of the new Rural Development Regulation, in particular for wider rural development purposes.

1.3. Recommendations from respondents include that :

• the period between now and 2010 should be used to gather evidence, and to re-consider objectives and options, particularly within a period of reduced EU funds; and,
• LFASS should target 'genuinely disadvantaged' areas of rural Scotland.

Q.2. Do you agree with the suggested approach for ensuring that payments are only made in respect of land that is being actively farmed?

2.1. Those who agree feel that:

• the approach supports the environmental and socio-economic objectives of the Gothenburg and Lisbon agendas respectively;
• it results in wider benefits upstream (such as agricultural suppliers) and downstream (such as local food processors in the rural community).

2.2. Those who disagree feel that:

• there needs to be an area payment based on public benefits instead, since it is felt that the current proposal is ineffective for wider development objectives;
• there are infrastructural and market issues which will remain unaddressed by this approach.

2.3. Recommendations from respondents include that:

• the definition of "actively farmed" requires urgent clarification;
• the definition should include land that is actively "managed" not only actively "farmed";
• there should be a re-think as to whether LFA support should be addressing wider socio-economic objectives in addition to those of "actively farmed" areas.

Q.3. Do you agree with the proposals to give greater weight to "very fragile areas" and to increase the minimum payment?

3.1. Those in agreement feel that "very fragile areas" are disadvantaged in terms of infrastructure, more adverse weather and therefore shorter growing seasons. Farmers and crofters need support in facing these significant challenges.

3.2. Those respondents who have reservations about the proposal state that:

• it is a relatively minor (non-strategic) adjustment;
• standard areas may become disadvantaged if payments are taken from them to support very fragile areas;
• such a system perpetuates a focus on disadvantage rather than a shift towards supporting sustainable farming systems;
• the proposal does not address a more fundamental question - that is, why a significant proportion of the overall budget available for rural areas continues to be channelled through the LFA support system.

3.3. Those who disagree with the proposal state that:

• there is insufficient evidence to justify such a shift;
• other geographical areas of Scotland are fragile, and shifting of funds from one disadvantaged area to another is not appropriate;
• such a proposal is not radical enough;
• rethinking should be carried out in the wider context of other payment sources.

3.4. Recommendations from respondents include the need to :

• have a better working definition of LFAs;
• establish an ongoing evidence base;
• link LFASS with specific objectives (including a focus on High Natural Value farming systems);
• look at alternative funding sources for crofting counties.

Land Management Contracts ( LMCs) (including Forestry)

Q.4. Do you agree with the national objectives identified in Annex C?

4.1. Respondents who agree with the national objectives feel that:

• the centrality of economic development to overall rural development must continue to be recognised;
• a healthy land-based sector is a prerequisite for a thriving and self-sustaining rural economy and society.

4.2. Those who disagree argue that:

• the use of the term "Land Management Contracts" precludes engagement with wider rurally-related policies and objectives;
• LMCs are largely inappropriate for achieving wider social objectives;
• the objectives omit a wide range of rural issues.

4.3. Recommendations from respondents include :

• the objectives of LMCs could be cross-referenced with those of relevant sectors;
• recreation and tourism assets need to be highlighted;
• climate change needs should be addressed;
• Community Planning Partnerships should be integrated within the LMC framework;
• objectives should be holistic and interlinked;
• sustainable territorial development needs to be addressed;
• all types of rural businesses should be considered, including beyond the farming sector.

Q.5. Do you agree with the proposed integration of schemes into LMCs?

5.1. The views of those who agree relate primarily to the potential for greater joined-up policy implementation, a holistic perspective and a simplified single gateway with less paperwork.

5.2. Those who disagree set out a range of reasons. These include that:

• it could compromise currently high environmental standards relating to woodlands, and the Natural Care and Organic Aid schemes;
• LMCs would be inappropriate for schemes on timber transport, cattle improvement and processing and marketing, and for the Woodlands In and Around Towns initiative and the Farm Business Development Scheme;
• it would be inappropriate to have to compete for Tier 3 funds;
• the benefits of the LEADER approach will be lost;
• the Scottish Rural Partnership Fund is not appropriate for integration;
• the very terminology of " LAND Management Contracts" will confuse the wider public in terms of eligibility;
• rural childcare will no longer meet new priorities for funding.

5.3. Recommendations from respondents include that :

• a diversity of approach should be maintained, since rural Scotland is itself diverse;
• support under Axis 3 should be kept separate;
• guidance from SEERAD is required, particularly in terms of eligibility;
• the production of whole farm plans should reflect the integration espoused by the SRDP;
• integration with wider regional objectives, plans and stakeholders should be maintained, and this should be expected to increase over time.

5.4. Recommendations from respondents on the mechanics and structure of the integration include that :

• training is needed for those involved in drawing up Tier 3 plans;
• flexibility between Tiers should be ensured;
• the balance of funding between Tiers 2 and 3 should be revised;
• a range of schemes should be excluded from LMCs;
• support should be maintained for the cultural/historic environment;
• there should be provision for specific activities such as equestrianism and goose management.

5.5. Some respondents indicate that clarification is required, in order to be able address Question 5. The following questions arise:

• How will administration be funded?
• How will the trade-off between administrative simplicity versus local input be made?
• How will the cross-sectoral assessment groups be made up?
• How will the complexities of integrating LFASS and the future Scottish Forestry Grant Scheme ( SFGS) and its relationship to the Scottish Forestry Strategy, be addressed?
• How will the issue of tenancy and timeframe of agreements be addressed?
• What are the (even approximate) funding levels for the SRDP?
• What is the situation in relation to IACS numbers and the associated Single Unit ruling?

Q.6. Are the proposed lists of Tier 2 and Tier 3 measures in Annexes D & E suitable for the delivery of LMC objectives on: (i) economic issues; (ii) social issues; (iii) environmental issues?

Note: these figures do not sum to 100 because some respondents ticked some but not all of the boxes on economic, social and environmental issues.

6.1. General comments:

• the tiers of LMCs are aiming for too many measures, especially with the given (decreasing) budget;
• there is a need for targeting and prioritisation;
• there is a need for a much-improved balance between economic, environmental and social/wider rural community targets, "beyond the farm gate";
• there is an apparent disjointedness with LEADER, particularly given its underpinning role as outlined in the new RDR;
• there is a lack of explicit mechanisms and approaches for integration with other measures, policies and priorities;
• there are concerns that the wider remit identified within the SRDP will lead to much-needed funds leaving agriculture.

6.2. Annex D (Proposed Types of Measures for LMCs):

• For those who agree, the measures represent continuity with a "bigger picture" within the RDR framework. The non-competitive Tiers are an important management tool and will assist in the meeting of the SRDP's objectives.
• Disagreement centres on the disjointedness and separateness implied by the exclusion of certain tasks (for example, some aspects of forestry), enterprises (such as wild venison production), "soft infrastructure" (such as training, and schemes for new entrants) and ways of working (such as co-operatives and organic farming).
• Suggestions for additional elements include measures to support:
  • corncrakes (including incrementally-increasing payments for delaying mowing, increasing to 1st September)
  • corn bunting
  • black grouse
  • breeding waders
  • cattle retention
  • water quality
  • diffuse pollution
  • integrated moorland management
  • equestrian activities
  • geodiversity (geology and geomorphology)
  • quality livestock
  • local foods, flood management
  • postal service

6.3. Annex E (Proposed list of individual Tier 2 and Tier 3 measures for LMCs):

Respondents' comments include the following:

• it is complex;
• many areas are omitted such as;
  • pollution control and management (e.g. in relation to Buffer areas)
  • soil management (particularly restoring soil structure and fertility)
  • management of woodland and scrub (which therefore omits single trees, some being of historic importance)
  • tourism (proposals not recognising wider Scottish trends or Green Tourism options)
• skills, co-operative activity, and the production of ecological data need to be addressed.

6.4. Tier 2: Comments, improvements and additions proposed by respondents include the following:

• the outcomes of the Tier 2 measures will vary greatly;
• it is under-funded given its objectives;
• it is very weak on pollution control;
• measures which should be added to Tier 2 include
  • features of historic value
  • muirburn
  • woodlands
  • environmental outcomes
  • climate change
  • further support for farmers
  • animal welfare
  • training for health and safety.

6.5. Tier 3: Comments, improvements and additions proposed by respondents include the following:

• the proposed measures should be linked specifically to objectives and outputs;
• the Measures are criticised due to the apparent lack of realistic ways to address social issues;
• LMCs should learn from and be built upon the experience of the ESA and Rural Stewardship Schemes;
• new options should include:
  • deer management plans
  • predator control options
  • bracken control under moorland management options
  • improved options for wintering wildfowl, black grouse, raptors, and upland waders
• it is necessary to have environmental audits within the Tier;
• a wide range of specific measures are felt to be missing from Tier 3 including:
  • land-based business development
  • new entrants (not only young farmers)
  • the wider rural community
  • family support services
  • micro rural businesses
  • affordable housing
  • animal health
  • pollution control and resource management
  • water quality
  • archaeological surveys and management plans
  • vernacular buildings.

Q.7. Is there an appropriate balance between the proposed economic, social and environmental measures for LMCs?

7.1. Those who agree feel that the allocation of tasks and objectives to each Tier is well thought-through.

7.2. The majority of recorded responses from the textual data show that there is a widespread sentiment that an appropriate balance has not been achieved:

• The balance between the Tiers is not equal: the Single Farm Payment far outweighs other elements of the LMCs; conversely, others feel that the environmental elements outweigh the agricultural elements; and that LMCs as a "short-hand" for wider rural development measures is flawed as an approach.
• The balance is overly in the direction of the land-based sector: the Measures are not appropriate for wider rural community development objectives as espoused in the SRDP. Some respondents comment that there is insufficient emphasis on economics and businesses elements of the rural economy; others consider that there is insufficient emphasis on environmental objectives.

7.3. Respondents highlight specific themes, interests and concerns which are insufficiently addressed:

• community assets
• accessibility of funds across a wider range of applicants
• eligibility/competition for those "beyond the farm gate".

Q.8. Do the proposed measures encourage an integrated approach compatible with sustainable development?

8.1. Those who agree identify the LMC structure and content as leading to integration, through addressing the main elements of rural development (economic, environmental and social).

8.2. Those who disagree highlight key shortfalls and concerns, including that:

• there is too much variability at a time when, post CAP reform, stability is needed;
• the measures themselves cannot ensure integration or sustainability - it is the process for implementing them that is critical in this regard;
• they do not address more widely-accepted goals and objectives for sustainable development;
• there are additional components required for sustainability;
• more integration is necessary across economic, social and environmental objectives;
• there are concerns over how it will work in practice.

Q.9. Should there be a mechanism for ensuring that land managers adopt a spread of measures from Tier 2?

9.1. Those who agree state that:

• the menu system supports potential for balance - however this needs to be viewed in conjunction with the fact that all farms are different;
• there is a need to ensure an environmental emphasis, within a Whole Farm Plan approach;
• any farm planning should take into account regional priorities, as well as watershed/catchment areas;
• in order to achieve a balance, it is felt that there should be training and advice for farmers to support them in making informed decisions.

9.2. Those who disagree argue that:

• the monies available should be targeted rather than spread in a shallow manner across all measures;
• such an approach would require adaptation over time;
• farmers' own decisions should be respected.

Q.10. Do you agree with the list of capital items as proposed in Annex G?

10.1. Those who agree state that it is comprehensive, simple and easy to administer.

10.2. Those who disagree give a range of reasons:

• the standardised approach to payment rates does not recognise national variability in the costs of carrying out the work, or flexibility in how the work may be approached;
• the list omits a number of key elements, including measures relating to:
  • boundary features
  • rabbits
  • amenity tree planting
  • mapping/auditing
  • vernacular buildings
  • biosecurity
  • animal health and welfare
  • equestrian access
  • footpath development
  • drystane dyking
  • removal of waste
  • cycle paths and interpretation
  • riparian and instream habitat
  • cattle crossings
  • pollution control measures
  • renewable energy;
• costs related to wider community activities need to be included.

10.3. Recommendations from respondents include:

• the production of criteria for prioritising open-ground sites;
• risk assessments for deer fencing;
• more detailed specifications for mountain path construction;
• increased capital expenditure for conversion to organic farming;
• inbuilt flexibility rather than this being seen as a fixed list for the duration of the SRDP;
• more consistency in levels of detail relating to capital items;
• specific improvements to items;
• more innovation in the list, allowing for new technologies and systems.

LEADER

Q.11. Should the LEADER mechanism be used to deliver across all the Axes?

11.1. Respondents who agree highlight that LEADER:

• has a successful, innovative track record, and is a proven tool for engagement;
• allows for local issues to come forward;
• promotes partnership and integration;
• will fulfil the EURDR recommendations for the 2007-2013 programming period.

However, some concerns are raised about the lack of experience and knowledge of LAGs for some tasks, and a lack of experience in those areas of Scotland with no previous LEADER programmes.

11.2. Those who disagree highlight that:

• it is too cumbersome;
• it should not play a role in agricultural matters but keep its wider community remit;
• agricultural support will be diluted;
• LEADER is not always appropriate.

11.3. Recommendations from respondents include that:

• more detailed explanation of the "mechanics" of applying LEADER across all Axes is required;
• use should be made of experience and knowledge already gained;
• LEADER should not lose its emphasis on being innovative;
• reallocation of resources should take place such that LEADER receives a greater proportion of the overall SRDP budget.

Q.12. How can LMCs and LEADER be administered to deliver mutually supportive approaches to rural development?

12.1. Respondents outline key elements of a mutually supportive, and sustainable, approach to rural development:

• co-ordination and integration;
• strategic partnerships;
• building on what is already there;
• training/familiarisation;
• suitable make-up of the groups, allowing for knowledgeable decisions to be made;
• defining of local, regional and national priorities;
• avoidance of undue administrative and bureaucratic burdens;
• mechanisms to resolve conflicts of interest.

Rural Development Frameworks

Q.13. Do you agree with the proposed Rural Development Framework approach?

13.1. For respondents who agree:

• it is seen as a viable means of ensuring an integrated approach;
• RDFs allow for planning, and for a strategic timeframe to enter this planning stage, which are seen as important and positive;
• RDFs will lead to simplification of the rural development process.

13.2. However:

• there is confusion over the name RDF, since it is perceived as relating to land management rather than to rural development;
• there is concern that the RDFs do not appear to be linked with priorities at a regional level.

13.3. Respondents who disagree give two mains reasons, that:

• it is complicated and theoretical, particularly for local and voluntary groups;
• it comprises another layer of bureaucracy.

A regional perspective

Q.14. Do you think that the proposed RPAC approach would be an effective means of delivering regional and local priorities while meeting national objectives?

14.1. Those agreeing highlight the key positive features of the proposals as being:

• recognising regional differences;
• building on what is already there;
• allowing for regional collaboration;
• supporting decentralisation of decision-making.

14.2. Respondents also raise a number of concerns:

• Who is deciding the regional priorities which will underpin RPACs?
• Who will judge applications?
• How will objectivity be established and maintained?
• How will conflicts of interest be managed?
• How will working relationships within a regional boundary be managed, in order to balance the levels of expertise required for different decisions, the "vested interests" which may affect certain decisions, and the overlay of new RPACs with existing structures?
• Where are the physical boundaries for the RPACs to be set?

14.3. Those who disagree with the proposals state that RPACs:

• are too complex;
• introduce too much bureaucracy and administration;
• are wasteful;
• will drastically slow down procedures of applying for funds and carrying out activities;
• are unlikely to be representative of community groups and voluntary agencies, plus they are unlikely to be made up of local people.

14.4. Their concerns include those relating to:

• the importance of RPACs, while reflecting regional priorities, remaining actively within a national context;
• the make-up of RPACs, and the associated issues of multiple roles, governance and decision-making.

14.5. Some respondents propose alternative models, as follows:

• SEERAD should retain the role of decision-maker, supported by advice from Regional Advisory Committees;
• a multi-layered, hierarchical model should be established (in a similar way as for the English RDP), vesting programme management with SEERAD, priority-setting and monitoring with three regional committees and programme delivery with existing organisations;
• RPACs should be replaced by an integration of LAGs and CPPs (rather than creating a new structure).

Q.15. Would RPACs be an appropriate approach for applications under all of the Axes?

15.1. Respondents who agree see RPACs as joined-up and avoiding duplication. Their concerns focus primarily on:

• the make-up of the RPACs, including how 'representative' the members of the RPAC will be, and whether they should be similarly constituted for each Axis or whether there should be some variability and flexibility to reflect the different emphases of the Axes;,
• the expertise required for each RPAC, and whether this should reflect the particular ideas and projects/proposals being assessed - there is a minimum level of expertise required.

15.2. The main points of disagreement from respondents are that:

• the LEADER approach must be preserved (particularly in relation to Axis 3);
• different Axes require different approaches, since the range of schemes and objectives under the SRDP is too great for one committee in each region to be considering and assessing.

Q.16. Which interests do you think should be represented on the RPACs?

16.1. Respondents indicate that RPACs must have a broad representation of interests and:

• be as wide-ranging as possible and include;
  • Community Planning Partnerships
  • those with appropriate understanding
  • those with a practical understanding of land management issues
  • those with regional perspectives.

16.2. Types of bodies/organisations that should be represented on RPACs. Recommendations by respondents include the voluntary sector, Non-Governmental Organisations ( NGOs), those involved with land access and recreation, planning/local authorities, heritage, arts and culture interests, woodland/forestry, rural transport, business/economic development, and wild venison producers.

16.3. Recommendations from respondents include that :

• there will be a need for the RPACs to demonstrate genuine consultation processes and procedures and accountability;
• RPACs must reflect the National Standards for Community Engagement.

Respondents also made points, relating to publicity, resourcing, induction and training and audits.

Q.17. Do you agree with the proposed system of guidance on regional and local priorities to enable greater targeting in the SRDP?

17.1. For those respondents who agree, pertinent aspects include:

• the importance of establishing such priorities;
• the proposed guidance must be given well in advance in order to maximise how well it is understood;
• if the guidance leads to a synergy between national, regional and local priorities, this will allow for the targeting of funds;
• an inbuilt flexibility will need to underpin the guidance, allowing for the recognition of diversity both between and within regions;
• such guidance takes account of already-set regional priorities;
• this process will need to develop over time.

17.2. The caveats mentioned by those who agree with the guidance process comprise the need:

• to train advisors and support any required integration of advisory services;
• for an understanding of (potentially changed) advisory roles under the SRDP, both in recognition of the broad brief covering 3 Axes, and for supporting the functioning of a single gateway mechanism.

17.3. For those respondents who disagree, their main reasons relate to:

• complexity;
• the sense that this will lead to a compartmentalised approach;
• criteria underpinning such guidance do not cover economic aspects adequately.

Q.18a. Do you agree with the range of topics that the guidance will cover?

18.1. Respondents who agree state that:

• it appears comprehensive and integrated;
• they have concerns about how the guidance will integrate national and local needs and priorities, and how it will relate explicitly to the Axes and measures;
• the involvement of stakeholders in the further development of the guidance is recommended;
• the guidance should avoid duplication of existing (technical) guidance, and should be reviewed over time in order to develop its scope and content;
• the guidance should be more balanced, to incorporate social and economic elements, as well as business development specifically.

18.2. Areas where respondents feel that further guidance should be developed, include:

• cultural heritage;
• recreation;
• access;
• tourism;
• moorland management;
• sporting development;
• strengthening rural communities;
• organics;
• diversification;
• marketing;
• business development;
• climate change;
• migrant labour and minority issues.

18.3. Those who disagree highlight:

• an imbalance between a heavy emphasis on environmental aspects and insufficient weight on social and economic aspects;
• that such guidance is too generic, and will therefore be inappropriate and unworkable at a local level.

Q.18b. Should the guidance adopt the same approach across all three Axes?

18.4. Respondents agreeing state that:

• it will allow for continuity and consistency, and integration;
• there is a need for a degree of flexibility within a single framework, with subsets of guidance for more detailed components of Axes;
• there should be integration with existing guidance and between local, regional and national priorities;
• there must be elements and mechanisms for recognising diversity at local levels, and between measures and Axes.

18.5. For those who disagree, the main reasons are that:

• it would not recognise diversity;
• the Axes are inherently different in their focus and emphases.

Advisory network

Q.19. What mechanisms could be put in place to ensure that the advice provided is of a high standard that will help achieve the policy outcomes expected?

19.1. The overwhelming response to this question concerns the need for accreditation of advisors through:

• a modular system (which recognises and supports the range of measures being addressed by the SRDP);
• the use of existing and/or new accreditation schemes;
• the use of mechanisms for updating the knowledge and skills base of advisors.

19.2. Concerns relate to:

• the wide range of specialisms that will be required;
• the potential tension between new and existing advisory networks and sources.

19.3. Recommendations from respondents are that:

• SEERAD take a lead role in the training of advisors;
• quality of advice should in fact be the responsibility of the advisory organisations;
• appropriateness of advice (e.g. to specific measures) is a key component of quality;
• the use of specialist advisors can also ensure the maintenance of high standards;
• there is a need for advisors to train farmers to develop their own plans;
• advice and guidance needs to be co-developed with local land managers to maximise relevance;
• there need to be mechanisms for monitoring and accountability;
• there is a need to integrate any new advisory mechanisms and structures with those already existing - this is of increased importance when respondents consider the proposed "single gateway", since this will necessitate extensive networking and building of links to ensure a joined-up approach that works in practice;
• such a "one-stop shop" also needs to be supported by an online gateway for rural Scotland.

Co-ordination with other funding streams

Q.20. What areas of activity should the SRDP support in order to ensure that it complements activities supported through other funding streams?

20.1. The main priorities which should be supported by the SRDP include:

• addressing wider rural community development (the economic, environmental and social aspects of rural development in Scotland, if the SRDP is to engender the integrated approach);
• the need to complement both national and EU structural funds (to allow for synergies, and also exploit potential for leverage and complementarity between funding pots).

20.2. In addition, respondents describe specific areas which they feel require targeted support and measures/activities within the SRDP, including:

• rural infrastructure;
• supporting co-operation between land managers, rural education and training;
• Natura 2000 and National Scenic Areas;
• climate change;
• access;
• tourism;
• heritage;
• food connections;
• forestry and woodland;
• fisheries.

20.3. Finally, when considering how such measures can be funded, there is disagreement between respondents concerning voluntary modulation, with a split between those who do not favour any increase, and those who feel that an increase is of the utmost importance if the SRDP is to move towards achieving its objectives.

Equality and discrimination

Q.21. Do you have a view as to the potential impact of this programme on equality groups, such as those relating to gender, ethnicity, disability, sexual orientation, age and faith or belief?

21.1. There are a range of responses to this question, comprising:

• the SRDP has no links with equality issues;
• inclusion issues may arise, since, by its operation, the SRDP may indirectly and sometimes inadvertently have effects on inclusion/exclusion processes, and that awareness of these should be maintained and monitored;
• the SRDP is already exclusive in its language and in its target population;
• the SRDP should actively assist inclusion with SEERAD providing a degree of continuity and intervention, to ensure that inclusion issues are coherently and strategically addressed, rather than left to ad hoc optimism.

21.2. Respondents pointed to ways in which LEADER+ has consistently and directly applied inclusive approaches, and should therefore be used as a rigorous and tested model for the SRDP to incorporate.

21.3. Specific areas where the SRDP should improve its stance and generate specific measures and mechanisms to maximise inclusion include:

• public access
• migrant workers
• young people.

Responses to the General Comments section of the Consultation document

22.1. Respondents outline those issues which they feel comprise the backdrop to the SRDP, and as such, must be addressed directly and indirectly through the Programme. In its present form it is argued that the SRDP provides no recognition of such issues (see below), and will therefore be ill-equipped to address the diverse realities of living and working in rural Scotland. The main issues and trends highlighted include:

• the decline in the number of rural vets;
• changes in the labour force, and its implications for Health and Safety;
• rural young people;
• affordable rural housing;
• the tenanted farm sector;
• the ageing agricultural workforce and the importance therefore of attracting new entrants.

22.2. Respondents outline ways in which the SRDP should be oriented towards quality of life measures, and towards viewing rural communities, in their widest sense, as asset-based rather than deficit-based.

22.3. There are a number of issues which respondents highlight as having been addressed only partially, or even poorly, within the SRDP. They request that these imbalances are redressed, given their importance to the sustainability of rural Scotland. These are:

• climate change;
• forestry funding;
• the equine industry;
• native animal breeds;
• the specific societal benefits of organic farming;
• co-operative business and incentives for co-operation;
• moorland management;
• rural roads; and,
• tourism and eco-tourism.

22.4. Respondents, in earlier parts of the Consultation document, emphasise the absolute necessity for co-ordination of activity and purpose between the SRDP and other Scottish Executive initiatives and priorities. In this section, additional areas where such co-ordination of effort is required are outlined, in order to lead to an increased likelihood of meeting targets, through joining up of effort and activities. The priority areas include:

• outdoor recreation;
• the Scottish Diet Action Plan;
• the Scottish Executive's "Hungry for Success - A Whole School Approach to School Meals in Scotland;
• the Scottish Executive Sustainable Development Strategy;
• the Scottish Executive Consultation "Diffuse Pollution from Rural Land Use";
• geodiversity priorities;
• the remit of the Department of Trade and Industry;
• gender equality;
• Scotland's National Parks

22.5. Respondents outline two areas where they feel the SRDP Consultation document provides insufficient information:

• LEADER and governance;
• the overall, and operational, budgets of the SRDP.

22.6. There is disappointment from a number of respondents that, having commented on the Strategy document, their concerns and suggestions have not been visibly incorporated within the subsequent Programme Consultation document.

22.7. There is an associated concern that the "turn-around" time between receiving these Consultation responses and making policy decisions, is insufficient to allow for a genuine consideration of respondents' concerns and suggestions.

22.8. Finally, some respondents are disappointed that the Consultation document contained no questions relating to the monitoring and evaluation aspects of the 7-year SRDP, as the opportunity to make suggestions would have been welcomed. There is a concern over an apparent discontinuity with the Common Monitoring and Evaluation Framework ( CMEF) and the measures and activities outlined within the tiers of LMCs. An integral role for monitoring and evaluation of the SRDP is needed if the outcomes of measures are to be assessed.

Findings from SEERAD-sponsored public consultation meetings

23.1. Some participants in the consultation meeting were concerned about the timing of the introduction of the SRDP, and also whether there are plans in place should the timetable not be achievable.

23.2. Similar concerns about the future were raised in relation to the degree of certainty which could be expected from LFASS, particularly after 2010.

23.3. Respondents wished to clarify spending details, both as ongoing under the existing schemes, within the new SRDP, and specifically for administration.

23.4. In a number of meetings, dairy farmers expressed concern over their exclusion from LFASS.

23.5. Respondents were unsure as to whether farmers' co-operatives would be eligible for SRDP funds.

23.6. Specific examples of confusion associated with the SRDP include:

• biomass projects;
• (additional) planning permission for diversification;
• the need for an IACS number to ensure eligibility for SRDP funds;
• whether there will be a deadline for Tier 3 applications.

23.7. In relation to local-level delivery:

• there is interest in the On the Ground proposal;
• there are concerns over whether regionalising the SRDP is appropriate when local-level decision-making forums already exist and can be seen to be working;
• there is some concern over the capacity of the LEADER approach to deliver across all Axes across Scotland.

23.8. Respondents raise concerns over how achievements of the SRDP will be recognised and measured. Respondents also wish to be made aware of whether further opportunities for consultation exist within the SRDP.

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