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8 Part 3: Consultation Responses to the Implementation of the SRDP

8.1 Introduction

This section comprises findings which address the following SRDP issues:

• A regional perspective
• Advisory network
• Applications
• Finance
• Co-ordination with other funding streams
• Monitoring and evaluation
• Publicity
• Equality and discrimination

8.2 A regional perspective

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

Table 8.1. Summary of responses by respondent category

Commentary on response rates:

This question focusing on regional approaches, generated 153 responses, representing a 59% response rate. Twenty-seven responses from the 34 local authorities (including Community Planning Partnerships) were provided and regional/local development partnerships also had a high response rate with 26 of the 33 responding to this question. The lowest response rate was within the private individuals and businesses (including MSPs) category with 34 responses to this question from the 78 respondents to the Consultation.

Main themes from the Consultation responses

Respondents who agree that the RPAC approach would deliver regional and local priorities while meeting national objectives, highlight its key positive features as being: recognising regional differences; building on what is already there; allowing for regional collaboration; supporting decentralisation of decision-making.

RPACs allow regional differences to be recognised: It is felt that the RPACs reflect the "diversity in the rural environment and the variation facing rural communities and economies across Scotland" (203, Representative Organisation)

RPACs will build on what is already there: Respondents emphasise the wealth of existing partnerships which are already functioning in the management of land, and are already reflecting wider rural community interests. The fact that RPACs will build on these is seen as a positive attribute, since they will ensure continued local input:

"Although it is vital to have a local/regional partnership to ensure regional/local relevance and avoid top-down measures, we think existing partnerships should be built upon rather than introducing a completely new bureaucracy" (79, Professional or Academic Body)

"Some organisations have spent a great deal of time deliberating and consulting on how to split Scotland into regions for management and stakeholder engagement purposes, and this should not be ignored… We also support the idea of building on existing administrative structures and see this as key to maximising their effectiveness" (237, Regional/Local Development Partnership)

Respondents outline how such an approach allows for, and indeed must be integrated with, pre-existing activities in regional collaboration:

"The opportunity to submit collaborative applications will enhance the existing relationships between land managers to achieve improvements … over a wider area" (16, Voluntary Sector)

"There are already many regional focal points and bodies aiming to address rural, environmental and economic concerns, including: SEERAD regional offices; SNH areas; Forestry Commission conservancies; River Basin Districts; and Local Enterprise Companies. If RPACs are to be established, they have to be aligned and integrated sensibly with these other regional bodies and their objectives" (216, Voluntary Sector)

Those who support RPACs point to their potential as a mechanism for supporting the decentralisation of decision-making. It is felt that this will allow for local understanding of needs and priorities to be integrated in the making of decisions:

"We support the concept of RPAC in that they allow for some decentralisation of decision making and for regional and local priorities to be taken into account. We believe that there should be some representation on the Committees from the local authorities, to allow a link to be made with the land use planning system and also to allow for local democratic representation" (29, Local Authority [incl CPP])

A number of concerns are raised, however (whilst still supporting the proposed RPACs), the first of which relates to who is deciding the regional priorities which will underpin RPACs. Additionally, who will judge applications? How will objectivity be established and maintained? How will conflicts of interest be managed? The following quotes are illustrative:

"There is concern over how the RPACs will judge applications. We foresee issues with who will sit on the RPACs and how this will affect their decisions on competing applications. How will impartiality be maintained? Also, for example, how can a moorland management project be measured against erecting a new community building?" (64, Regional/Local Development Partnership)

"A wide range of stakeholders, and potentially different interests, in these Committees could lead to rather difficult negotiations and decision-making processes and potentially delay funding decisions. In order to avoid such complications, it would be crucial that the Committees have clear terms of references and maintain a balance with respect to the number of representatives, i.e. enough members to ensure necessary representation, but not too many which would make the Committees difficult to manage" (132, Professional or Academic Body)

A related, second concern is the management of working relationships within a regional boundary, in order to manage 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:

"The RPAC's relationship with LEADERLAGs needs careful tuning. The LAGs should be the vehicle for wider public and stakeholder engagement in creating action programmes that suit particular geographic areas. The role of local government and national park authorities in both the RPACs and the LAGs will be important and will require some thought about vested interest - the judge and jury issue" (32, Representative Organisation)

"There is the need to ensure that RPACs fit with existing regional structures. Our view would be that RPACs should be embedded in the Community Planning structure, which already provides the necessary link between delivery of national and local strategies. The establishment of mechanisms that allow decentralised decision making on a partnership and locally accountable basis would be appropriate" (35, Local Authority [incl CPP])

The third concern from respondents relates to where the physical boundaries for the RPACs are to be set, since it is recognised that individuals' ability and willingness to contribute will be directly shaped by such boundary-setting:

"The RPAC approach will only work if the boundaries for the RPACs make sense within a regional/local context and the balance between national, regional and local priorities is made clear from the outset" (83, Regional/Local Development Partnership)

"Of importance is the definition of regions. This must be a coherent area on a number of levels - geographically, administratively, and economically. It should not be too large and its relationship to LAGs also needs to be considered to ensure that local priorities are heeded and projects are truly locally developed" (106, Regional/Local Development Partnership)

"Provided that it is recognised that community needs can vary within artificial boundaries. The particular needs of local communities need to be recognised and understood and solutions arrived at applied with input from those communities" (90, Regional/Local Development Partnership)

Those who disagree with the role of RPACs in delivering local and regional priorities whilst also fulfilling national objectives, state that RPACs are too complex, they introduce too much bureaucracy and administration, are wasteful, and that they will drastically slow down procedures of applying for funds and carrying out activities:

"Sounds very complex with numerous competing interests" (5, Private Individual or Business [including MSP])

"We have concern that the RPACs appear very bureaucratic in operation and slightly redolent of a centralist planning system. Every effort should be made to offset these tendencies if the RPACs are established" (74, Representative Organisation)

"The centralised decision making process described in the consultation appears to be overly bureaucratic with the risks that decision making and project progress will be slowed, and that there will be limited engagement from local stakeholders" (87, Local Authority [incl CPP])

"We do not consider the proposed RPAC model to be progressive, nor does it demonstrate innovation. We believe that the creation of RPACs is duplicative of the roles of existing organisations and wasteful of staff resources from both the public and private sector" (129, Regional/Local Development Partnership)

"Rather than cutting bureaucracy, simplifying procedures, introducing greater clarity and shortening timescales for the application procedure, the consultation proposals appear to hold out the prospect of the opposite… the added layer of decision-making will necessarily extend the length of time take for applications to be adjudicated and extend uncertainty for applicants" (164, Representative Organisation)

Secondly, there is a concern that although RPACs may reflect regional priorities, these must remain actively within a national context:

"It is essential that the SRDP provides the Regional Project Assessment Committees ( RPACs) with a clear steer on national priorities. While we support regional decision making and targeting, this must be done on the basis of delivering clear national priorities. SEERAD should not simply pass responsibility for SRDP delivery to the Regions" (13, Voluntary Sector)

"A complication is that regional bodies, acting in isolation, would find difficulty dealing with cross-regional issues such as water pollution" (216, Voluntary Sector)

The third key concern focuses on the make-up of RPACs, and the associated issues of: multiple roles, governance and decision-making. The following quotes highlight some specific examples:

"Whilst we support the setting of regional and local priorities, and an ongoing advisory and monitoring role by stakeholder panels, we are unable to support the idea of RPACs' involvement in project assessment and the disbursement of public funding. Considerably more developmental thinking is required, should a system of RPACs be a feasible alternative to delivery of public funding though an accountable public body, which has inherent duties to adhere to in its actions… We would like to see SEERAD learn from the… Indicative Forest Strategies and … the Water Framework Directive" (39, Voluntary Sector)

"The RPACs: (1) it amounts to decision by committee which will inevitably lead to compromise decisions which stifle innovation (2) the cycle of reference to a national committee is very cumbersome and does not empower regional groups to select proposals which suit local conditions. (3) in practice it will be very difficult to balance environmental and economic interests in a committee (4) there is a very real danger that decisions become political" (118, Private Individual or Business [including MSP])

"Our concern is with the governance mechanisms. Here we asked ourselves whether these are truly devolved to local/regional levels; whether they involve a truly representative group of stakeholders in the locality or region; whether there is duplication of decision-making or multiple level decision making on the same projects; if there is real scope to 'join up' the different elements of the SRDP internally as well as with other regional and local policies; if there are planning duplication around priorities; whether there are contiguous boundaries for the implementation of different policies affecting the sustainable development of the locality and region. Broadly speaking, these conditions are regarded as more or less essential by the OECD for 'joined up' territorial rural development policy" (191, Private Individual or Business [including MSP])

Further, respondents who do not support the notion of RPACs highlight that it is unlikely that RPACs will be representative of community groups and voluntary agencies, plus they are unlikely to be made up of local people. These points are viewed with great concern:

"The membership structure of the RPACs as posited would be inimical to community sector development, social enterprises and would be dominated by the existing elites who were partially responsible for the situation as it is already. There is no evidence that community groups, voluntary agencies and many of the most important players in rural community development in Scotland will be represented on the RPAC and therefore, those important interests will not be represented" (40, Private Individual or Business [including MSP])

"But how would community interests be represented and funded to sit on such a committee?" (49, Private Individual or Business [including MSP])

"Membership of the RPACs would be weighted from people outwith the area who have no idea what it is like to live here" (8, Private Individual or Business [including MSP])

In addressing this question, some respondents outline alternative models which they see as more feasible than the RPACs. In the first alternative, SEERAD should have a key role as decision-maker; in the second, it should be multi-layered (in a similar way as for the English RDP); and in the third should comprise an integration of LAGs and CPPs (rather than creating a new structure).

Alternative one: SEERAD as decision-maker

This model would replace RPACs with Regional Advisory Committees, their key role being to advise, rather than make decisions - the latter being the responsibility of SEERAD. Such an approach recognises the local knowledge and input, but retains decision-making (and its associated bureaucratic demands) centrally with SEERAD:

"We would prefer to see a model of Regional Advisory Committees, where regional and local stakeholders would be involved in setting priorities, advising SEERAD, and monitoring regional LMC activity. This would overcome the issues of practicality and local capacity for involvement in RPACs, which could be excessively onerous in terms of input, and overly bureaucratic. LMC applications should not be assessed by committee, but rather by SEERAD, as the accountable body responsible for disbursing public money" (17, Voluntary Sector)

"We support the idea of bringing a measure of local representation to the scheme by establishing local or regional committees. They should not be concerned with project assessment, but rather they should advise on the local/regional objectives and priorities and take an active role in the development of the Rural Development Guidance. They would review demand across the range of measures as the scheme progresses and would be able to vary the priorities in response to their take-up. They could also perform some wider functions. For example … they could help to identify opportunities for integrated projects and initiatives - and provide a link with the LEADER component. They might also have a wider advisory role relating to the On the Ground initiative, which might be responsible for co-ordinating the efforts of various public bodies in various aspects of 'rural delivery'. They should have: clear terms of reference; a reasonable number of members to ensure a wide representation; a shared understanding among members; consistent and detailed consideration of the economic, social and environmental aspects of the scheme; close links with the project officers running the scheme" (97, Governmental Body)

"Instead of RPACs, local Community/Parish Councils and LEADER groups are used as a conduit by SEERAD area offices to establish the particular rural development needs of their area. These discussions can then form the basis of the decision making process when prioritising measures to be funded under Tier 3. The merits of an individual application should then be assessed by SEERAD staff" (98, Representative Organisation)

" RPACs will be another unnecessary and costly tier of bureaucracy. Decisions on applications should be made by SEERAD (in consultation with other government bodies). Ring fence budgets within local SEERAD regions and let the local LBAP groups decide on regional priorities for conservation" (22, Professional or Academic Body)

Alternative two: A multi-layered arrangement

This is a hierarchical arrangement, whereby each layer has a specific function or set of functions:

"In a similar way to that proposed for the English RDP, we see the following hierarchy as relevant to Scotland: SEERAD ensure programme management, implementation, monitoring and evaluation is in accordance with EU Regulatory requirements. A National and up to 3 Regional Monitoring Committees (based on existing structures) are given the role of setting regional priorities; monitoring progress and advising SEERAD on changes necessary to improve Programme efficiency and effectiveness. Existing organisations, best equipped to deal with such matters, deliver the assistance to the customer. For the three axes in question this would principally be through SEERAD, Scottish Natural Heritage, Forestry Commission Scotland and the Enterprise Networks who would also co-ordinate LEADER activity. Such a mechanism avoids duplication and customer confusion; does not add to clutter in the support landscape and still gives a crucial level of stakeholder engagement in the important strategic priority setting and performance monitoring" (247, Governmental Body)

Alternative three: Integrate with LEADERLAGs and/or CPPs

This approach would replace the proposed RPACs (viewed in this alternative as an additional, unnecessary layer of bureaucracy) with an integration of already-existing systems and structures, primarily CPPs and/or LEADERLAGs:

"We do not wish to see the Executive create a new tier of bureaucracy, preferring instead an integrated LEADER structure based on existing CPP structures within rural Scotland. Such an approach based on existing CPP structures would also have resonance with the likely co-financing delivery arrangements for the wider EU Structural Funds post 2006" (140, Local Authority [incl CPP])

"We have concerns that these will duplicate the work of CPPs and create another level of bureaucracy. In our opinion it would be best to use the CPPs (albeit these would need to be enhanced to engage non-public sector stakeholders), which already develop holistic plans and strategies for regions" (191, Private Individual or Business [including MSP])

" LEADER can deliver effectively across all the axes of the RDR. LAGs represent a wide range of stakeholders and many LAGs already contain a membership similar to that proposed for RPACs... We consider that a closer relationship between LEADER and LMCs would be most effective. Strategic priorities must be shared by both LMCs and LEADER partnerships through joint strategic planning and prioritisation. In seeking to achieve best value it is important that there is integration with Community Planning and we would encourage The Executive to develop this approach rather than create another structure which would inevitably lead to delay in implementation" (193, Regional/Local Development Partnership)

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

This question sought only textual responses, rather than offering the closed-type questions ("yes, no, don't know").

Table 8.2 Summary of responses by respondent category

Commentary on response rates:

This question attracted 105 responses which represents a low response rate of 41%. Local authorities (including Community Planning Partnerships), however, again recorded a high response rate with 25 of the potential 34 respondents in this category registering a response. Less than a third of the respondents within the professional or academic body, private individuals (including MSPs) and representative organisations categories responded to this question, with just 3 of the 14 professional or academic bodies providing a response.

Main themes from the Consultation responses

For those respondents who agree with RPACs being appropriate for all Axes, their main reason is that RPACs are joined-up and avoid duplication. However, respondents report a number of concerns, focusing primarily on: (i) the make-up of the RPACs, and (ii) the need for the required expertise to judge applications.

RPACs are joined-up and avoid duplication: They could be linked with farm plans, and should be applicable across all Axes if true integration - as espoused in the SRDP- is to be achieved:

"It would seem sensible to apply the RPAC approach to all 3 Axes. This should be linked to Whole Farm Audits and an outcome-based system that is best approached at a regional level. We believe that this approach should encourage collaborative approaches to meet regional targets" (37, Voluntary Sector)

"The only way to achieve integration is to ensure that there is compatibility across all Axes of the Programme. It is vital the wider community, environmental and business development grants are considered in the same context as individual Land Management Contracts. This then facilitates integration of agricultural businesses into the wider rural economy rather than exacerbating distinction, through an entirely separate decision making structure, as currently happens" (217, Regional/Local Development Partnership)

"True integrated development can only be achieved if all projects are considered in the same way and in relation to one another" (106, Regional/Local Development Partnership)

The make-up of the RPACs is critical: The main concern here focuses on 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:

"It depends how they are constituted. We feel very strongly that XXX represents only a narrow group of interests and that for groups such as ours there is no representation amongst the 'stakeholders' who have been contributing" (36, Representative Organisation)

Associated with this is 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, however, and it is felt that this needs to be explicitly addressed:

"Each RPAC should have a broad base of skills and expertise in its structure, enabling assessment of applications from all areas within the SRDP. Technical advice will be required for specific projects and each RPAC should have representatives with a range of expertise to provide the relevant guidance" (72, Local Authority [incl CPP])

"With the right balance of membership on the RPAC there is no reason why all applications could not be assessed at a local/regional level. For more technical applications a two-tier approach could be approved whereby the initial first assessment is done by the local RPAC and then re examined by the Scottish Executive. Interested parties representing the local community … should all be represented on a local area partnership focused on individual area needs and therefore invite additional representation from bodies key to their area as and when required" (126, Local Authority [incl CPP])

For those respondents who do not feel that the RPACs are appropriate across all three Axes, the main points of disagreement are that: (i) the LEADER approach must be preserved, and (ii) different Axes most definitely require different approaches.

The LEADER approach must be preserved: This is felt to be the case particularly in relation to Axis 3, and is also considered to require strengthening of links with CPPs:

"The LEADER bottom up approach must be preserved, with community groups and individuals approaching the LAG and being supported and awarded funding by the LAG, particularly in relation to Axis 3. The link to CPPs must also be more explicit and this could best be addressed at LAG level. It will be important to preserve the autonomy of the LAG within the RPAC / LAG structure" (30, Regional/Local Development Partnership)

"We support the principle of LEADER integration across all 3 Axes and, accordingly, would seriously question why RPACs should consider such applications" (140, Local Authority [incl CPP])

Different Axes require different approaches: Respondents highlight how the range of schemes and objectives under the SRDP is too great for one committee in each region to be considering and assessing. Further, while Axis 3 and Tier 3 might be appropriate for RPACs, Tiers 1 and 2 are not:

"If the RPACs are closely integrated with the LEADERLAGs and work largely within a LEADER framework, they can deliver across all three Axes. If they are designed to deliver LMC Tier 2 objectives, then they will not be suitable for delivering Axis 1 and 2" (117, Representative Organisation)

"If LMC applications are limited to Land Managers, then Leader is a more appropriate approach to delivering Axes 3 (wider rural development), and RPACs should focus on Axis 1 and particularly Axis 2 through LMCs" (86, Regional/Local Development Partnership)

"No. Business schemes are very different from environmental or water quality. Administrative centres/areas already exist and their policies vary" (46, Private Individual or Business [including MSP])

"Axes 1&2 should be more market-driven, land managers applying for LMCs which meet Axes 1&2 priorities will only be successful if their application predicts delivery of optimum benefits to their local area… Many schemes and measures which would be classified as an Axis 1 priority could involve sensitive commercial/business assessments which it would not be appropriate for an un-elected, unaccountable RPAC to be involved in" (98, Representative Organisation)

"Axis 3 lends itself more readily to regional consideration, whereas Axis 1 and some aspects of Axis 2 require a more national and strategic approach" (216, Voluntary Sector)

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

Table 8.3 Summary of responses by respondent category

Commentary on response rates:

Just under half (49%) of the 259 respondents to the Consultation provided a response to this question. The highest response rate within a category was from the local authorities (including Community Planning Partnerships), with 26 of the 34 respondents within this category providing a response. The lowest response rate within a category was from professional or academic bodies, with 4 responses to this question from the 14 respondents to the Consultation. Government bodies also recorded a low response rate with 7 of the 20 respondents in this category providing a response.

Main themes from the Consultation responses

Respondents indicate that, in order to address the priorities outlined within the SRDP, RPACs must have a broad representation of interests. Representations should: (i) be as wide-ranging as possible; (ii) include Community Planning Partnerships; (iii) include those with appropriate understanding; (iv) include those with a practical understanding of land management issues; and (v) those with regional perspectives.

As wide a range of interests as possible: Respondents outline the types of organisations and interests which need to be represented, in order for the RPACs to have credibility across the range of issues addressed under the SRDP:

"A broad range of interests including organisations representing land managers, environmental and socio-economic organisations, community planning groups, economic development agencies, local authorities, etc. There is a need to widen the group composition beyond existing administrative structures to ensure that the Executive's commitment to equality is fully realised" (148, Professional or Academic Body)

" RPACs require a range of expertise, experience and specialisation which will build a community focused, bottom-up approach and ensure parity of partnership between the local authorities, other public agencies, business and voluntary sectors to include agriculture, social/community development, forestry, other funding agencies" (63, Regional/Local Development Partnership)

"The 50/50 split between public agency and community/private sector that has worked so well under the Leader+ Programme should also be adopted for RPACs, and any other groups, such as Programme Monitoring Committees, that are set up under the aegis of the SRDP" (87, Local Authority [incl CPP])

" RPACs must represent ALL local rural stakeholders. The value of RPACs is that they include local community knowledge and expertise, including business knowledge and interests. Public agency and NGO representation should not exceed 50%" (111, Voluntary Sector)

Community Planning Partnerships: It is stated that these would allow an integrated approach to be taken forward, whilst still ensuring that local priorities are addressed:

"We believe that the local perspective would be best served by embedding RPACs within the Community Planning structure. It will be important to ensure that all interests covered by the proposed measures within the Rural Development Programme are effectively represented at both national and local decision making levels, including land managers, SEERAD, SNH, Forestry Commission Scotland conservancies, Local Authorities and other Community Planning partners along with providers of local rural development initiatives" (35, Local Authority [incl CPP])

"A sub-group of a CPP could be formed as the appropriate delivery vehicle to include a broad range of rural representatives ensuring the needs of the whole rural community are met. This sub group would include all previous members of Lag, RPACs and Rural Partnerships" (82, Local Authority [incl CPP])

Those with appropriate understanding: This is thought to be essential and should relate to the issues being considered under a particular application or set of applications. There are two "models" - either the RPAC has to comprise all areas of expertise and understanding, or specialists can be called upon to give advice and make recommendations on particular applications:

" RPACs should consist of those with the appropriate knowledge and understanding of the projects being considered for approval at the particular RPAC, e.g. those with knowledge of diversification projects should assess the agriculture projects. This might result in different members attending different meetings depending on the projects being considered for approval on the day. We would urge against all interests participating in all assessment committees to reduce the demands on resources both human and monetary" (48, Local Authority [incl CPP])

"It may be that a relatively small RPAC, which could call on relevant expertise to provide views on certain applications, would be a better and more efficient way of working" (83, Regional/Local Development Partnership)

" RPACS should be represented by those organisations appropriate to the geography of the regions defined" (134, Regional/Local Development Partnership)

Respondents also state that it is important for members of the RPACs to comprise those with a practical understanding of land management issues. This is viewed as critical in order that the most appropriate assessment of applications can be made:

"The RPAC needs to include active land managers - farmers, crofters, foresters. It is not good enough just to have government agencies, public bodies and charities who are the people who have the time to take part - but may not know the issues faced by land managers" (14, Voluntary Sector)

"…including those representing land management activities that also have a recreational and conservation value such as sporting shooting" (21, Representative Organisation)

" RPACs need to have strong reputations of private sector land management interests in order to be trusted" (43, Private Individual or Business [including MSP])

"If RPACs were to set regional and local priorities, there must be significant representation from private sector land management interests… It is the members of such organisations who will be making the applications and who would be responsible for delivering outcomes" (160, Representative Organisation)

Those with appropriate regional perspectives: Such a contribution to the RPACs is considered as important due to the need for having an awareness of local and regional plans, and for being able to relate that awareness to national objectives:

"There should be co-ordination for … regional land and water use issues, including River Basin Management Planning ( RBMP) Area Advisory Groups and Regional Forestry Forums… an inclusive approach, that ensures all relevant interests are represented, identified at regional level" (17, Voluntary Sector)

" RPACs need to be aligned with existing regional rural, environmental and economic bodies, and interests for the RPACs should be aligned with the remits of these other bodies" (216, Voluntary Sector)

Types of bodies/organisations that should be represented on RPACs: Respondents list the sectors and types of organisations which they feel must be represented on RPACs. These include: the voluntary sector, NGOs, those involved with land access, planning/local authorities, heritage interests, arts and culture, recreation, woodland/forestry, rural transport, business/economic development, wild venison producers. The following table summarises the reasons why respondents suggested such interests be represented:

Table 8.4. Respondents' suggestions for types of interests which should be represented on RPACs

In addition to outlining who should be represented on such RPACs, respondents emphasise that there will be a need for the RPACs to demonstrate genuine consultation processes and procedures, accountability, and reflect the National Standards for Community Engagement:

"More importantly than who sits on the RPAC is what role the RPAC will have. The role outlined in the consultation is bureaucratic and would entail substantial resource allocation for anyone willing to sit on an RPAC" (144, Governmental Body)

"Need clear terms of reference for RPACs to operate successfully" (86, Regional/Local Development Partnership)

"More important than representation is the contribution that individuals can make" (85, Local Authority [incl CPP])

"If RPACs are to be locally accountable then they should also be democratic, so either people should be elected onto them or elected representatives are co-opted onto them. Elected representative could include community council members" (134, Regional/Local Development Partnership)

"We are concerned at the principle of observer status suggested in the RPAC model. Through LEADER we have established procedures that deal effectively with conflicts of interest and consider that all participants should have an active remit rather than simply be seen as protecting member interests" (93, Regional/Local Development Partnership)

In addition to the above recommendations concerning who should be on RPACs and how they should operate, respondents also make three further points, relating to: publicity; resourcing/induction and training; and audits:

"There should be widespread advertising of the opportunities to be represented so that many interest groups can be represented" (36, Representative Organisation)

"The RPACs should be resourced sufficiently to allow for recompense for those who are giving their time on a voluntary basis, and for induction and training for members who may have great expertise and understanding in their areas, but be inexperienced in committee work of this kind" (117, Representative Organisation)

"Independent audits should be carried out from time to time to ensure effectiveness" (248, Governmental Body)

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

Table 8.5. Summary of responses by respondent category

Commentary on response rates:

Just under half, 124, of the 259 respondents gave an answer to this question of guidance representing a response rate of 48%. Local authorities, (including Community Planning Partnerships) recorded another high response rate with 27 of the 34 respondents in this category responding. Again, the lowest response rate was from within the professional or academic body category where just 3 of the 14 respondents in this category provided a response.

Main themes from the Consultation responses

For those respondents who agree with the proposed system of guidance, a number of aspects are viewed to be particularly pertinent, including: (i) the importance of establishing such priorities; (ii) that the proposed guidance must be given well in advance in order to maximise how well it is understood; (iii) that if the guidance leads to a synergy between national, regional and local priorities, this will allow for the targeting of funds; (iv) that an inbuilt flexibility will need to underpin the guidance, allowing for the recognition of diversity both between and within regions; (v) that such guidance takes account of already-set regional priorities; and that (vi) this process will need to develop over time.

The importance of establishing such priorities: Priorities will support decision-making during the implementation of the SRDP (for both the applicants and for those making funding decisions), particularly given the range of topics and measures being addressed:

"Knowledgeable guidance is vital with the application process and also to help the RPACs evaluate applications" (113, Representative Organisation)

"Well constructed guidance should remove the need for RPACs to refer applications to a national committee for guidance" (118, Private Individual or Business [including MSP])

"Yes, it is important that applicants have a simple and clear set of guidance notes to assist them in drawing up their proposals. The guidance should cover all topics" (131, Representative Organisation)

"Overall guidance on the Rural Development Regulation is essential for RPACs to understand what is required of them and to ensure they understand how best to approve projects and assess issues in their area although a flexible approach can help address regional and local issues at the lowest and most appropriate level. There is a huge range of communities, landscapes, access, towns and villages across Scotland and these needs to be considered when making decisions affecting local communities and economies" (126, Local Authority [incl CPP])

Advanced notice of guidance: In order for the buy-in and understanding of the SRDP to reach its maximum amongst the range of stakeholders involved, the guidance needs to be circulated well before agreements are being formulated and implemented:

"Guidance must be agreed in advance and in consultation with active land managers - and issued well in advance of the scheme being opened so that people know what they are applying for and whether they are likely to succeed. And the scheme must remain constant for at least 5 years so that people get used to it and can understand it" (14, Voluntary Sector)

Synergy between national, regional and local priorities: Respondents note that linkages and interconnections between priorities at different operating levels will allow for the targeting of funds to those activities and measures which are considered important from these three perspectives. Some respondents develop this point further, arguing that the priorities must come also from other Scottish Executive strategic documents (such as Smart Successful Scotland) if any measure of integrated rural development is to be achieved. The following quotes are illustrative of these arguments:

"The inclusion of regional and local priorities will allow scarce SRDP funds to be targeted more effectively... Regional and local priorities, which are not also national priorities, must be weighted lower than the national ones… The construction and ongoing review of regional guidance statements should be carried out in consultation with regional and local experts…" (17, Voluntary Sector)

"It should reflect national priorities as set out in documents such as Smart Successful Scotland and the Tourism Framework for Change, but should also reflect local priorities" (75, Local Authority [incl CPP])

"There must be a seamless transition between national priorities, clearly articulated, and locally important issues identified in regional guidance" (160, Representative Organisation)

Flexibility and adaptation of specifications to local conditions: In developing and articulating the guidance, respondents state that there must be an inbuilt flexibility to reflect the diversity of both the SRDP (the measures being covered by the programme) and Scotland's rural areas:

"We have long argued for regional and local flexibility in agri-environment prescriptions (for example in cutting dates), to reflect the different conditions found across the country. It is hoped that the regional and local priority setting process will also allow this" (17, Voluntary Sector)

"The building in of a flexible approach in establishing priorities for business development, diversification and other rural development measures is appreciated as it will allow RPACs to respond and adapt to local priorities and circumstances" (30, Regional/Local Development Partnership)

A specific aspect requiring additional sensitivity and flexibility is that of diversity within regions of rural Scotland, rather than implying a coherence within a region as a unit purely for implementation purposes:

"However, it is important to recognise that, for example, following the administrative standard regions does not create homogenous regions and the same set of priorities does not automatically apply for all areas within such a region… Any "regional" approach to guidance has to be flexible… The approach to the Environmental Stewardship ( ES) scheme that has been developed by DEFRA under the English Rural Development Plan… outlines the key characteristics of different parts of the English countryside through defining 150 Joint Character Areas. These Areas are based on the outputs of the Countryside Agency's 'Countryside Character Initiative'... For each Joint Character Area there is a 'Targeting Statement' that sets out the key opportunities, the key targets and the secondary targets, and the HLS points scoring system is based on how well an application addresses these targets…" (132, Professional or Academic Body)

"There are some examples where, for example, 'natural communities' may not map against ecological or economic region boundaries. Likewise, within those economic or ecological regions, different communities may have very different economic bases/social organisations/community capacity" (40, Private Individual or Business [including MSP])

Takes account of already-set regional priorities: Respondents state that some regions have been active over the years in establishing - through many iterations - their priorities, and that certain bodies have also drawn up regional priorities according to land use, sector, activity etc. Therefore, in establishing new SRDP priorities, there needs to be synergy and interconnectedness between differing sets of priorities. Thus, work needs to be carried out to ascertain these regional priorities already in existence:

"Benefit should be drawn from the wealth of local agenda-setting, local regeneration plans, regional priority-setting that has already taken place within rural Scotland, through various schemes (including Leader, Leader2, Leader+, Rural Voices, Community Planning Partnerships etc). Resources should be set aside specifically to access, collate and synthesise these reports and their findings, so that the years of experience and knowledge are not overlooked" (148, Professional or Academic Body)

"The Structure and Local Plan system is already in place, which reflects the priorities of local communities and has been developed in consultation with the public and stakeholder groups and is accountable to democratically elected councillors. It is important then, that the rural development guidance has to at least take account of these plans, and ideally the 'regions' should be based at a level which connects well with local authorities boundaries" (29, Local Authority [incl CPP])

"Existing strategies for rural matters including Forestry, Biodiversity and Access, could be embedded within a local programme document drawn from the Community Plan at the local level. Current Structure Plan and Local Plan provisions will also need to be taken into account" (35, Local Authority [incl CPP])

"It is relevant to note that VisitScotland (with partners) are bringing on-stream Area Tourism Partnership (and Action) Plans which would inform for example, the process of establishing priorities for business development and diversification" (154, Governmental Body)

A process over time: For such processes to be carried out thoroughly and appropriately, it is recognised that they will need to take time, and that guidance cannot (and indeed should not) be rushed and produced too quickly, particularly given that it is likely to be in place for the remaining programming period:

"We welcome the approach to develop guidance on regional and local priorities and we recognise that this is an evolving process requiring support from a number of partners and stakeholders. While it is important to develop these as quickly as possible, it is also important to produce achievable and appropriate priorities" (37, Voluntary Sector)

"It will take a considerable amount of time and effort to ensure that this guidance is appropriate and equitable across Scotland" (134, Regional/Local Development Partnership)

Respondents feel that, however, there should be the inbuilt opportunity and mechanism for reflection on how the guidance is being played out, and to respond with appropriate changes during the lifetime of the SRDP:

"There needs to be flexibility to allow guidance to change in a period when there will be significant change in the rural economy" (146, Local Authority [incl CPP])

The importance of setting appropriate regional boundaries: A key component of appropriate guidance is the way in which regional boundaries are set, and what these regional boundaries then imply. Concerns include: how the existing boundaries will be taken into consideration; and how other geographical, administrative and developmental boundaries will to be incorporated into the ' SRDP regions'. The following quotes illustrate the points made by respondents:

"An early priority, however, is to pin down the regions. Para 57 has the SEERAD regional office as the regional contact. Para 60 talks of ecological regions, and introduces river catchments or geographic areas as yet another layer. Para 60 also introduces "local" stakeholders in addition to regional stakeholders, implying another organisational layer" (91, Voluntary Sector)

"Various existing structures and geographical divisions could be taken as a reference for dividing Scotland for this purpose. We consider the most logical option would be to use existing administrative structures/boundaries as a starting point simply because people are familiar with them… dividing Scotland into around 12 units would seem to be about right... We would suggest that the Highland Council area is split into two, along the existing SEERAD boundaries separating Caithness & Sutherland from the rest of the Highland Council area, which would provide a framework that is familiar to farmers and a reasonable fit with other administrative boundaries. We feel Orkney, Shetland and the Western Isles each form discrete geographical units at an appropriate scale, and the logistics of linking these with other areas would be challenging. National Parks might also be separate units" (97, Governmental Body)

"In both policy and funding terms, it would make more sense to align such regional guidance according to the Scottish Executive's own Rural classification based on accessibility thereby acknowledging the outcome of the recent Parliamentary Inquiry into Rural Development" (140, Local Authority [incl CPP])

"Administrative divisions would be the simplest method, but should have a mandatory overview of appropriate geographical divisions (such as catchments, Nitrate Vulnerable Zones and Natural Heritage Zones)" (194, Professional or Academic Body)

Respondents state that the criteria and system for setting the regions must be clearly explained:

"Regional priorities must only be set based on sound assessment of local requirements, and the assessment system and priority setting process must be open and transparent" (98, Representative Organisation)

Regional funding to reflect regional priorities: Coupled with the definition of areas is the delineation of a regional budget, which is felt by respondents to be an important practical reflection of a regional orientation:

"We will need regional ring-fencing of funding to enable regional priorities to be funded. If this does not happen, regional priorities may be paid lip service, but eventually EU/Scottish priorities will prevail and regional priorities will be redundant, resulting in disillusionment with the process" (45, Private Individual or Business [including MSP])

The final caveats mentioned by those who agree with the guidance process comprise the need to train advisors and support any required integration of advisory services. The issue of accreditation is touched on elsewhere in the analysis, although it is also raised here by respondents. Further, there is a need for an understanding of (potentially changed) advisory roles under the SRDP, both in recognition of the broad brief covering three Axes, and for supporting the functioning of a single gateway mechanism.

"We would agree that advisory networks are critical to the process; however these advisors should be advisors who understand the sector and are accredited to a recognised standard such as the FBASS scheme" (218, Representative Organisation)

"There is already a well established network of advisors covering all of the sectors of interest under the proposed SRDP and we support the suggestion that it is integration of existing services rather than creation of new services that is required. However, the consultation is not clear on the approach that is proposed other than to refer to what appears to be a new structure, namely the establishment of a single gateway for advice. We would be interested to hear more specific proposals on what is actually proposed here but would point out at this stage that the Gateway offices in the Scottish Enterprise area and the Local Enterprise Companies … already offer a similar signposting function" (247, Governmental Body)

For those respondents who disagree with the concept and practice of regional guidance, their main reasons relate to: complexity, the sense that this will lead to a compartmentalised approach, and the criteria underpinning such guidance. The following quotes summarise these positions:

" RPACs may have a role in setting local and regional priorities but within a national framework. In our view it would add greatly to the complexity and compromise any national strategy to have different regions for different Axes and then adding another layer by working to locally determined regional guidance" (62, Governmental Body)

"The development of Regional Rural Development Guidance "to identify local priorities for environmental, social and economic objectives in the SRDP" would serve to offset any consistency which the national Rural Development Guidance aimed to introduce. Overall, we see the proposals as cumbersome, time-consuming, and costly to implement and maintain" (164, Representative Organisation)

"We are very cautious about this approach generally, but even more so if the guidance is based on the natural environment or river catchments as suggested in paragraph 60. This tends to suggest an over reliance on non-business criteria" (192, Representative Organisation)

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

Table 8.6. Summary of responses by respondent category

Commentary on response rates:

This question produced the second-lowest level of responses with just 103 responses representing a 39% response rate. The only question with a lower response rate was 18b. It could be that the question was felt to be extremely specific, and/or it could also be the case that a number of respondents felt that they had already addressed this point in previous questions. Local authorities (including Community Planning Partnerships), consistent with the high response rate provided throughout the Consultation, recorded the highest response rate within a category with 23 of the 34 responding to the question. The lowest levels of responses from within the categories were from the voluntary sector, professional or academic bodies, and representative organisations.

Main themes from the Consultation responses

The key points from respondents who agree with the range of topics covered, are that: (i) it appears comprehensive and integrated; (ii) there are areas where further guidance should be developed, including: cultural heritage, recreation, access, tourism, moorland management, sporting development, strengthening rural communities, organics, diversification rural development, marketing, business development, climate change, migrant labour and minority issues; (iii) 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; (iv) the involvement of stakeholders in the further development of the guidance is recommended; (v) the guidance should avoid duplication of existing (technical) guidance, and should be reviewed over time in order to develop its scope and content; and (vi) the guidance should be more balanced, to incorporate social and economic elements, as well as business development specifically:

"While the preparation of guidance notes is valuable, these should extend beyond ecological and land based elements. In particular partners such as the CPP and the Council will be equally interested in the social and economic elements of any programme" (84, Local Authority [incl CPP])

"It would appear from the suggested approach of paragraph 60 of the SRDP consultation that guidance might well be based solely on environmental parameters on a catchment basis. This does little to allay the concerns of the Association that there is insufficient consideration of business development issues within this 'package', underlining the thought that the gains from the SRDP 2007-2013 will not be sustained in the long term" (160, Representative Organisation)

This issue of balance is also raised by those respondents who do not agree with the proposed range of topics covered by the guidance:

"If guidance is based heavily on environmental parameters with insufficient acknowledgement of business development issues it will not be sustainable beyond 2013" (43, Private Individual or Business [including MSP])

"As outlined in the text the topic areas suggested for 'guidance' are 'heavy' on environmental considerations and 'light' on economic and social considerations. We believe that it would be helpful to seek a more balanced approach" (74, Representative Organisation)

A further criticism is that such guidance is overly generic, and will therefore be inappropriate and unworkable at local level:

"In the rural environment, even on a regional scale, it will be extremely difficult to produce a set of "one-size-fits-all" guidance note. Resources would be far better used to ensure that land managers and other stakeholders are aware of how and where they can obtain advice which can be tailored to their own specific situation" (98, Representative Organisation)

Finally, a number of respondents state that they are unable to address the question fully, since there is insufficient detail; they would welcome the opportunity for a wide range of stakeholders to comment on draft guidance.

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

Table 8.7. Summary of responses by respondent category

Commentary on response rates:

This question produced the lowest level of responses to the Consultation with just 88 responses, representing a response rate of 34%. As with Question 18a, it could be that the question was felt to be extremely specific, and/or it could be the case that a number of respondents felt that they had already addressed this point in previous questions. Typically, the local authorities (including Community Planning Partnerships) recorded the highest response rate (although significantly lower than for other questions) with 16 of the 34 choosing to respond to the question. As with Question 18a, the lowest levels of responses within categories were from the voluntary sector, professional or academic bodies, and representative organisations.

Main themes from the Consultation responses

Respondents agreeing with a single approach across all Axes state that it will allow for continuity and consistency, and integration. Coupled with this, they highlight the need for a degree of flexibility within a single framework, with subsets of guidance for more detailed components of Axes. Once again, the issue of integration (i) with existing guidance and (ii) between local, regional and national priorities, is raised.

Consistency, continuity and integration: This is felt to be a benefit for the applicants, as well as for those assessing proposals:

"Consistency will make it easier for the land manager to get to grips with" (14, Voluntary Sector)

"There should only be one guide covering all of the issue at hand, providing continuity. Would also prevent readers from unintentionally reading or referring to the wrong guide" (26, Private Individual or Business [including MSP])

"Consistent guidance will ensure consistent results and give clarity to SEERAD, SNH and Forestry Commission if they are the bodies determining applications" (118, Private Individual or Business [including MSP])

Flexibility: Whilst supporting a consistent approach, respondents also point to the need for building in elements and mechanisms for recognising diversity at local levels, and between measures and Axes:

"In general, the same approach should be applied, with guidance tailored to the requirements of the different axes. This flexibility is particularly important in terms of business development, diversification and tourism, which are market-led" (30, Local Authority [incl CPP])

"The common approach must include flexibility to enable an emphasis at local level to change in response to local situations. The approach must also ensure integration into local priorities" (80, Local Authority [incl CPP])

"We would agree that as far as possible locally-appropriate solutions should be found within a general set of principles that apply nationally" (132, Professional or Academic Body)

"Given the 3 legs of the sustainable development stool - environment, economy and society - it may be important to distinguish between the 3 and subsets of guidance appropriate for each. Clearly the current focus on environment and economy places community interests, at best, as a junior partner. Without sustainable communities, true economic and environmental sustainability is very difficult to create. Therefore, each Axis will need its own explicit objectives/priorities" (40, Private Individual or Business [including MSP])

Integration with existing guidance, and between local, regional and national priorities: As with previous comments, respondents highlight the need to integrate with guidance and priorities that pre-date the SRDP, in order to ensure continuity in direction and understanding:

"The Guidance must be compatible with strategies that are non- SEERAD e.g. Smart Successful Scotland, Tourism Strategy, Transport etc as well as regional and local strategies... The Guidance should also provide the framework for the LAG areas Business Plans" (83, Regional/Local Development Partnership)

"Yes, although the guidance for Axis 1 and Axis 3 should incorporate local knowledge from Economic Development Strategies, Tourism Strategies and Community Planning Partnerships" (87, Local Authority [incl CPP])

"The list of priorities for any given area is likely, similarly, to be made up of national priorities, which are priorities wherever they occur, and local priorities, which are priorities partly or entirely because the features they target or the outcomes they produce occur where they do. There may be a case in relation to business development to target measures less according to geographical divisions, and more on the basis of farm or business types, although the scope to do this may be constrained by the implementing regulations" (97, Governmental Body)

For those who disagree with a single approach across Axes, the main reasons are that it would not allow for recognition of diversity, and that the Axes are inherently different in their focus and emphases:

"Diversity to suit individual farmers and farms is likely to be the most beneficial" (11, Private Individual or Business [including MSP])

"No, the guidance for farm based measures needs to be different from those for rural development measures. No doubt farm based measures with their very specific rates of grant on very specific items will continue. This is not appropriate for LEADER/rural development measures" (79, Professional or Academic Body)

8.3 Advisory network

Qu.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?

Table 8.8 Summary of responses by respondent category

Commentary on response rates:

Of the 259 respondents to the Consultation, 119 provided a response to this question, representing a relatively low response rate of 46%. The highest response rate within a category was from local authorities (including Community Planning Partnerships) with 25 of the 34 respondents in this category providing a response to this question. Low response rates, of around or less than two fifths within the category, were recorded for professional or academic bodies, representative organisations and government bodies.

Main themes from the Consultation responses

The overwhelming response to this question comprises the accreditation of advisors, and this point is outlined in further detail below. Further points comprise: (i) training of advisors by SEERAD; (ii) that quality should in fact be the responsibility of the advisory organisations; (iii) that appropriateness of advice is a key component of quality; (iv) the use of specialist advisors can also ensure the maintenance of high standards. As with previous answers, respondents highlight the need to; (v) integrate any new advisory mechanisms and structures with those already existing. This is of increased importance when considering the proposed "single gateway", since; (vi) this will necessitate extensive networking and building of links to ensure a joined-up approach that works in practice; (vii) such a one-stop shop also needs to be supported by an online gateway for rural Scotland.

Accreditation of advisors: This point is emphasised and elaborated upon by the majority of respondents to the Consultation. Suggestions include a modular system (which recognises and supports the range of measures being addressed by the SRDP), use of existing and/or new accreditation schemes, and mechanisms for updating the knowledge and skills base of advisors. The following quotes illustrate these points:

" SEERAD should be developing a system of accredited advisory services. In particular … a modular system of advice should be developed for all advisory staff and this should include SEERAD and area staff working in allied fields such as SEPA, SNH and Historic Scotland, so that consistent and holistic advice is given" (37, Voluntary Sector)

"We anticipate that Advisers giving advice to land managers will themselves have properly accredited training in all aspects of environmental protection and management. Such environmental training must underpin all aspects of farm advisory services to comply with both national and European commitments and legal obligations. In some cases this will require specialist Advisers and in others a modular system of training to accredited standards will be necessary" (39, Voluntary Sector)

"Advisors should be accredited, either using existing accreditation schemes, or a new SEERAD one. Environmental advisors should have accreditation" (45, Private Individual or Business [including MSP])

"Ensure advisors pass certain assessments for competence/issues awareness. Ensure advisors engage in continuous professional development" (46, Private Individual or Business [including MSP])

Training of advisors by SEERAD: A number of respondents feel that SEERAD should play a key role in ensuring the competence of advisors through a coherent training programme:

"There should be Executive-funded training for outside agencies ... It is also considered important that parties involved in the delivery of LBAPs and River Basin Management planning have a knowledge and understanding of the programme, including its national and local priorities" (137, Local Authority [incl CPP])

"A wide range of professional advisory networks currently exists … these advisors need comprehensive briefing to understand the aims and objectives of the Executive. To achieve this, the Executive should offer training/briefing days for professional advisors" (131, Representative Organisation)

In contrast, there are those who believe that quality is the responsibility of advisory organisations:

"We believe that both in the public and private sectors responsibility for the quality and standard of advice is the responsibility of the individual organisation and should be part of that organisations operational planning and management framework" (74, Representative Organisation)

"It is up to the providers of advice to monitor their performance, irrespective of whether they are private or public organisations. I do not see the need for further mechanisms" (81, Private Individual or Business [including MSP])

Appropriate levels and types of guidance: This is viewed as a key component of "quality", since it is necessary to ensure that applicants are assisted in the process. Therefore, such applicants may require technical advice and support, and/or support in how to make their way through the funding options, checking eligibility etc:

"The guidance should be appropriate to each scheme run under the SRDP and be at the most appropriate level to assist the applicant e.g. there will be a different level of guidance required for a landowner applying for a non-competitive scheme than that required by a community group applying to the next LEADER programme" (48, Local Authority [incl CPP])

"There are two types of advice that applicants for rural development public funding require. Technical advice tends to be readily (if sometimes expensively) available from private consultants and agencies and semi-public bodies... More difficult to come by sometimes, is advice on accessing public funds in the first place. If rural development support is to be fully integrated … then such advice will have to be available. We suggest that each RPAC should have professional staff to assist communities, businesses and individuals with the process of applying for funds. This is particularly important where funds are bid for competitively, as in Tier 3" (99, Regional/Local Development Partnership)

Use of specialists: A number of respondents state that quality can be ensured through the targeted use of those advisors possessing knowledge of particular domains and issues, and that they should thus be brought in when appropriate:

"The use of specialists and co-option to RPACs for consideration of specific issues could ensure the quality of information" (21, Representative Organisation)

"Outreach consultants, similar to extension agents could be contracted to deliver advice to community and private sector projects" (40, Private Individual or Business [including MSP])

"We believe that a two-tier structure of advice is required, comprising general advisers providing a wide-range of farm advice and specialist advisers capable of providing in-depth knowledge on specific issues" (88, Voluntary Sector)

An example of a specific area requiring specialist advice is where farmers and land managers would need to co-ordinate their activity for benefits at catchment level:

"Additional resource is required for the provision of one to one advice to land managers on measures relating to water quality and achievement of the objectives of the WFD as well as to inform effective use of LMC funds... We have recommended that a programme involving catchment officers, similar to Defra's Catchment Sensitive Farming Initiative, be developed for Scotland… Catchment officers would be principally focused on the management of diffuse pollution but with the remit that measures should benefit biodiversity, landscape, flooding etc. In addition, we think it is important that advice is used to encourage collaborative applications" (248, Governmental Body)

Ensuring integration between advisors, and with pre-existing advice structures: In order not to lead to a further layer of administration which may indeed result in less clarity, respondents propose that there should be integration between different sectors, and integration of SRDP advisory structures with those advisory bodies which are currently providing advice across a range of issues and geographic areas:

"The most appropriate mechanism for delivering the right range of advice and expertise would be to ensure that agricultural, forestry, economic development and regeneration support is integrated in the same way as the decision making process. Utilising the existing local delivery mechanisms and co-ordinating these through the Community Planning process to ensure that focus on national, regional and local policy outcomes is maintained. We do not believe the current mechanism in operation through local SEERAD offices could offer the necessary levels of additional support to ensure a holistic development of integrated land management and wider rural development objectives" (35, Local Authority [incl CPP])

"It is important that any new advice arrangements do not cut across or replicate existing provision. For example, Business Gateway and VisitScotland's Quality Assurance schemes have clear roles and a market presence" (75, Local Authority [incl CPP])

"There is some confusion... On the one hand paragraph 62 states that there are a number of public and private sector bodies and individuals providing advice, and that the aim is to integrate existing sources of advice. However 63 omits the private sector (and non profit distributing advisory organisations such as Community Woodland Association, Farming & Wildlife Advisory Group and Scottish Native Woods). Non profit distributing organisations have a key role in delivering social and environmental advisory support, and this should be recognised and assisted by the Scottish Executive" (91, Voluntary Sector)

"Promotion of the advisory service provided by Safe and Healthy Working… provides an occupational health and safety service for small and medium sized enterprises in Scotland. Integration of this existing service within the Rural Development Programme would establish it as a service provider in the rural community (where uptake is known to have been low)" (114, Governmental Body)

Networking and co-operation building towards a single gateway: Respondents are well aware that such integration will not happen without concerted action, coupled with an understanding of, and commitment to, a rationale for collective and collaborative working. Thus, in order for a "single gateway" or "one stop shop" to become a workable reality, respondents highlight that there will be a requirement for much networking and communication "behind the scenes":

"Inter-agency co-operation "behind the scenes" is the key, to put in place clear lines of communication and structures that allow the customer to have a single point of contact that can either provide the advice directly or direct the enquiry with confidence to the appropriate person. An audit of the anticipated skills and knowledge required and map of where they lie that can be pulled together at a central point for the customer interface" (61, Private Individual or Business [including MSP])

"Liaison with relevant stakeholder organisations including the Rural Gateway, Rural Network, CPPs, Local Authorities, Business Gateway, SNH, Scottish Agricultural College ( SAC) etc" (71, Local Authority [incl CPP])

"There will be a need to link up connections in the enterprise network as farmers are used to using their own network of advisors and not all LECs are geared up to dealing with rural business development" (55, Private Individual or Business [including MSP])

"Advice needs to be coordinated at regional ( RPAC) and local (Leader) levels, through SEERAD staff and other rural development agencies such as Local Authorities and LECs, SNH, Farming and Wildlife Advisory Group ( FWAG), SAC. Support should be given to build capacity and facilitate cooperative working... In order to maximise the added value of the partnership approaches of RPACs and Leader LAGs both groupings should be involved in project development as well as in approving applications" (87, Local Authority [incl CPP])

"Networking with other areas also helps those involved with the decision making to have an overview of what is happening elsewhere in Scotland and adopt best practice wherever feasible" (126, Local Authority [incl CPP])

A number of respondents state that such a "single gateway" approach would be extremely useful, and may have the function of "signposting" individuals to specific sources, thus making the networking and inter-communication even more crucial:

"We suggest the need for "gateway advisers" who complete the majority of the plan (Rural Development Framework) but defer more detailed aspects to specialists... The "gateway adviser" would be the applicant's contact and would arrange for the specialists to provide advice and complete relevant parts of the plan, as appropriate. In this way the applicant liaises with one person who arranges completion of the whole application" (151, Local Authority [incl CPP])

"The adoption of a single information portal as described in the revised Forward Strategy for Scottish Agriculture could go a long way to help clear up the confusion as to who to turn to for advice. The major issue with this is often the land managers seeking advice are not familiar with the internet or do not have the facilities to access it therefore it would seem sensible for a single entity to provide a single entry point and guide to the support and services offered, with links to appropriate service providers" (195, Governmental Body)

An online gateway: It is felt that a one-stop shop approach "offline" could, and indeed should, be supported by its online version, such that farmers, land managers, and the wider rural community can access information, contact names, forms, and guidance, at times and locations which suit them, for example, outside office hours:

"The Rural Gateway site should be developed to ensure expertise and advice is freely available" (30, Private Individual or Business [including MSP])

"The "gateway" function to provide easy access to advice could be tied in with the proposed Rural Network and delivered as an extension of the existing Rural Gateway website" (117, Representative Organisation)

"We are currently delivering initiatives aimed at improving farmers' business skills… We would like to see this taken to another level by providing a single information portal to transfer knowledge from each initiative to an individual level, supplemented by a more detailed support tool to assist individual business decision making" (192, Representative Organisation)

Additional points raised by respondents include: the need for advisors to train farmers to develop their own plans; that the advice and guidance needs to be co-developed with local land managers to maximise relevance; and that there need to be mechanisms for monitoring and accountability.

Advisors to train farmers: As highlighted by respondents in connection with other Consultation questions, there is the view that farmers and land managers will have a greater understanding and therefore ownership of their farm plans, if they acquire the skills to be able to draw them up themselves, with advice and pointers en route. Experience appears to show that farmers then "buy in" to such plans and deliver more consistently over the agreed timeframe. They also understand better how such plans integrate with the operational and strategic aspects of their farm/estate business:

"We would like to see those farmers who may be capable of drawing up their own framework plans, however, given the opportunity to do so. We would strongly support a significant proportion of the 'advisory' effort associated with the scheme being used to train potential applicants to prepare their own plans" (97, Governmental Body)

Local input: This is felt to be crucial if SRDP beneficiaries are to maximise the appropriateness of the guidance to their situations:

"Lots of input at an early stage from local, active land managers - advice needs to be relevant. If the guidance needs someone to interpret it then it is badly written" (14, Voluntary Sector)

Mechanisms for monitoring and accountability: In addition to setting up accreditation schemes/frameworks, and/or applying those already in existence, such an approach needs to be monitored on a periodic basis, in order to ensure the maintenance of quality advice. There also need to be mechanisms in place for channelling feedback to locations where there are resources to respond and make necessary changes and improvements:

"Accountability mechanisms need to be put into place to assure that all aspects of sustainable development are equally respected" (40, Private Individual or Business [including MSP])

"Monitoring indicators help, together with monitoring of access provision: this should be in tandem with the L.A. access monitoring focus already in place" (41, Representative Organisation)

"Mechanisms will need to be in place for Quality Assurance ( QA), reviewing, and feedback on the quality and applicability of the advice and advisers for the wider rural community remit being proposed" (148, Professional or Academic Body)

Finally, respondents highlight a number of concerns, including the wide range of specialisms that will be required, and the potential tension between new and existing advisory networks and sources:

"We need less advisory bodies with more "rural" mentors. Advice can sometimes be compartmentalised, LMCs cannot and are not experts in rural development, community engagement / community development or wider business development. What would be their locus or motivation to become so?" (82, Local Authority [incl CPP])

"Annex H Code 115 of Common Output Indicators has "number of newly set up management, relief or advisory services" as an indicator. This might militate against the use of existing sources of advice" (91, Voluntary Sector)

8.4 Co-ordination with other funding streams

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

Table 8.9 Summary of responses by respondent category

Commentary on response rates:

This question yielded responses from 114 of the 259 respondents to the Consultation, representing a response rate of 44%. Local authorities (including Community Planning Partnerships) recorded the highest response rate within a category with 25 of 34 responding to this question. Again, the lowest response rate was recorded for the professional or academic body category with 4 of the 14 respondents in this category providing a response.

Main themes from the Consultation responses

Respondents outline the priorities and types of activity which should be supported by the SRDP, in the context of ensuring complementary with other funding streams. The main areas of commentary comprise: addressing wider rural community development; and the need to complement both national and EU structural funds.

Wider rural community development issues: As mentioned elsewhere in their commentary, respondents emphasise the need to address the economic, environmental and social aspects of rural development in Scotland, if the SRDP is to engender the integrated approach it espouses:

"If it is to mark "the start of a new era for rural development policy", the SRDP should fully reflect the current economic, environmental and social realities of life and work in rural Scotland. If it can be freed from its current over-emphasis on land management as the dominant tool for rural development, it can bring together and integrate a wide range of different funding and support for rural communities" (117, Representative Organisation)

"It is essential that the SRDP fully reflects economic, environmental and social aspects of rural Scotland. It should bring together and integrate a wide range of different funding and support for rural communities such as basic services, village renewal and capacity building" (90, Regional/Local Development Partnership)

"We would recommend that the SRDP should cover all aspects of rural development (such as heritage, language, culture, leisure/recreation and tourism) and not only land management" (129, Regional/Local Development Partnership)

"The SRDP should implement measures that foster sustainable rural communities - local health and social care services, affordable housing, affordable and accessible public transport, local schools, village halls" (133, Regional/Local Development Partnership)

"There is a world of opportunity in the rural area to link small scale land management initiatives to the fulfilment of social needs, providing work and volunteering opportunities for many people and this needs to be supported by land managers and public agencies. Specific support for village halls needs urgently to be restored; projects such as small town/village renewal programmes; capacity building for social enterprises and actions which help us to tackle deprivation which is dispersed need supported" (139, Representative Organisation)

Complement other national funds: Respondents point to the range and wealth of initiatives which are currently underway across Scotland, and outline the potential for synergies between programmes:

"Discussion with other funders is essential in determining similar community capacity building issues or rurality e.g. Big Lottery Fund. The launch of the Rural Development Small Award coincided with the launch of the Big Lottery Fund Investing in Ideas Programme, which feature considerable overlap and little apparent discussion between these funders, who both offer small grants" (71, Local Authority [incl CPP])

"It needs to have reference to initiatives funded currently under SE targets such as Closing the Opportunity Gap, but it also needs to integrate more closely with rural priorities which do not easily fit with current SE priorities which are based on an urban biased system of measurement of deprivation i.e. the SIMD" (139, Representative Organisation)

"Emphasis in the SRDP should be given to projects which conform to relevant Local Authority strategies on Crofting Policy, Outdoor Access Strategies, LBAPs, Economic Development Plans and Local Structure Plans" (146, Local Authority [incl CPP])

"We would suggest that our preferred delivery model would be one that was embedded in the Community Planning process in order that … maximising the benefit of each of the relevant funds can be achieved at the local level" (35, Local Authority [incl CPP])

Complement EU Structural Funds: Of equal importance (where appropriate to different regions of Scotland) respondents describe the ways in which the SRDP must complement structural funds, again to allow for synergies, and also exploit potential for leverage and complementarity between funding pots:

"Structural fund support has generally been targeted on large infrastructure projects while EAFRD funding particularly via LEADER has greater potential for supporting local community-based initiatives. The challenge here is to ensure that the interventions of the different funds are well co-ordinated avoiding the danger of a gap opening between SRDP and Structural Fund approaches to the detriment of rural businesses, particularly small non-agricultural SMEs" (140, Local Authority [incl CPP])

"The Executive commented in the Department of Trade and Industry (dti), Draft National Strategic Reference Framework for EU Structural Funds that there will be clear demarcation on eligibility criteria for different funds and that the structural funds are to support wider economic development and social development in areas dependent on agriculture and fisheries. This only adds to the confusion as to where demarcation with European Agriculture Fund for Rural Development ( EAFRD) will begin and end" (84, Local Authority [incl CPP])

"We know that Priority 3 from the Lowland & Upland ERDF programme and Priority 2 in the Highlands & Islands ERDF programme will have a sustainable rural development feature. There does not appear to be any evidence of complementarity here" (122, Regional/Local Development Partnership)

"The issue of match funding is particularly important… Match-funding arrangements give us the opportunity to increase the leverage of our grants budget for certain types of work and ensure that externally funded programmes contribute in an accountable way" (204, Governmental Body)

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, and fisheries.

Rural infrastructure: Respondents point out that this area of rural development often falls between funding streams, and is overlooked; however, it is essential (yet often invisible) in the move towards sustainable rural communities and the businesses that operating within them:

"One area of concern across many areas of rural Scotland is the gap in infrastructure funding, which is acting as an impediment to achieving local aims and priorities. Under-investment in water and sewerage, together with transport, is resulting in a severe brake on the capacity of many rural communities to fulfil their economic and social potential" (75, Local Authority [incl CPP])

"We would like to draw attention to the need for support for much needed infrastructure projects in the rural area, as this is an area that the structural funds and the utility companies appear to be withdrawing from in the future" (83, Regional/Local Development Partnership)

"Where appropriate the measures under the SRDP should link to other mechanisms for supporting the development of rural infrastructure. This would suggest that a role for the RPACs might be to liaise with (for example) the relevant LECs" (132, Professional or Academic Body)

Supporting co-operation between land managers: As respondents highlight elsewhere in the Consultation, the SRDP should be explicitly supporting and enhancing provision for co-operative activity, particularly in the light of its regional approach and integration priorities:

"The issue of cooperation between land mangers and their proposals appears to be an important area for SRDP to support to ensure delivery of wider benefits related to LBAPs, river catchment planning and sustainable flood management" (137, Local Authority [incl CPP])

Rural education and training: This is an area that is missing from the SRDP, in terms of the wider rural community (at the moment, the implication within the Consultation document is that the training and education that the SRDP is concerned with is within the land-based sector). It is felt to be crucial in enhancing the adaptability of Scotland's rural areas, and is contributory to reducing out-migration of younger people:

"Training is an example where local authorities and the enterprise agency would fund rural skills development" (146, Local Authority [incl CPP])

"We believe that the SRDP should also support: (i) Development of Human Capital; and (ii) Rural Micro Businesses e.g. rural tourism based businesses" (195, Governmental Body)

"If the thrust of the SRDP continues along the route of LMCs as the main delivery mechanism, there will be a danger that duplication occurs in a range of areas such as business diversification access, skills and training etc. It is extremely important that Skills development must not be restricted to land managers only, in order that rural areas benefit from funding to develop a flexible workforce" (217, Regional/Local Development Partnership)

Natura 2000, National Scenic Areas: The co-ordination and integration envisaged in the SRDP need to be reflected in the specific mechanisms adopted in relation to Natura 2000 and National Scenic Areas:

"We are specifically concerned about potential lack of co-ordination between the EAFRD and Structural Funds in meeting commitments to protect and enhance the Natura 2000 network of sites designated for their nature conservation importance… The SRDP must be clear and specific about how EAFRD funding will be used for Natura 2000 sites, and clarify which aspects of Natura 2000 funding will be covered by Structural Funds" (17, Voluntary Sector)

"We would like to see the management of National Scenic Areas, a national asset, supported through the programme" (58, Local Authority [incl CPP])

Climate change: As stated elsewhere in this report, respondents state that climate change is inadequately addressed in the current version of the SRDP, and that this should be redressed as a matter of urgency:

"The SRDP should fully support and complement climate change policies as implemented through other funding streams. With respect to its own climate change policies, paragraph 21 of the Strategic Plan notes that, "The Scottish Executive is committed to ensuring that agriculture and forestry play a key role in mitigating climate change and that 'food miles' are reduced through a greater proportion of Scottish products being processed and marketed locally". With respect to climate change policies under other funding streams, it would be beneficial if there were no rural development activities that cancel out the impact of activities under other funding streams" (248, Governmental Body)

Access: There are specific elements of public access to Scotland's countryside which should be addressed by the SRDP:

"It should support the implementation of the access part of the Land Reform Act, the delivery of the Physical Activity Task force and the requirements of the European Landscape Convention" (19, Voluntary Sector)

Tourism: The SRDP does not go far enough in its recognition of specific tourist growth areas, national tourism initiatives, or of the national trends for tourism in particular sectors and geographical areas:

"Tourism especially in relation to food production and processing, local food marketing" (36, Representative Organisation)

"The SRDP should also work towards achieving tourism's 50% growth by value agenda as set out in the Tourism Framework for Change" (75, Local Authority [incl CPP])

Heritage: Respondents emphasise the need for adequate resourcing within the SRDP for the management of historic sites within rural Scotland:

"It is important to note the existing shortage of accessible funds for the management of the rural Historic Environment, including archaeological sites, monuments and landscapes, rural and vernacular buildings and landscapes, and designed landscapes. The SRDP should support management of this area in particular" (180, Representative Organisation)

Vital food connections: A key element felt to be missing from the SRDP, and recommended for inclusion, is a coherent approach to facilities for primary producers, particularly those which directly underpin a shift towards low food miles which are of increasing interest to many consumers. This could, for example, be achieved through support for co-operatives, and manufacturing and processing facilities.

Forestry and woodlands: Due to schemes and agreements which pre-date the implementation of the SRDP in 2007, there is a need to address the current wave of activities to which funds have already been committed. In addition, clarity is required over differences in previous and future funding availability and its associated conditions:

"The fact that the SFGS is now closed means therefore, in the first year that the new scheme operates, there are likely to be at least 2 years worth of forestry schemes already in the pipeline. Tackling this should be a priority. It is also unclear if forestry schemes will be under Tier 3 and therefore competitive - this would be a significant change from precious practice where only WIAT schemes were competitive" (77, Local Authority [incl CPP])

Fisheries: There is a recommendation for showing the linkages between the fisheries programme and the SRDP, since many of Scotland's rural coastal communities will be affected differently (yet in an inter-related way) by both, and this issue is not highlighted within the current SRDP Consultation document:

"The fisheries programme ( EFF) is going to be at least as important to some of the Highland communities on the West Coast as the ERDF programme, so ideally the SRDP would be structured to integrate with it and aim to support small scale and artisan fisheries" (134, Regional/Local Development Partnership)

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. The reasons behind these two differing standpoints are presented:

No increase in voluntary modulation:

"With the reduction in SRDP funding we make a strong plea that funds are not diverted away from the agricultural sector, as there is little alternative funds available for this sector from other sources. Agriculture is intertwined with our rural development and if profitable productive farming is no longer an option then the populations, especially in the outer isles, will diminish leaving no one to use the rural facilities such as schools, shops, village halls, health service etc. Further modulation, without additional national funds, must also be guarded against as this reduces the funds which go direct to our rural communities" (48, Local Authority [incl CPP])

"We strongly disagree with the suggestion at paragraph 70 that voluntary modulation should be increased further. We have consistently said that rural development spending needs should be identified first rather than increasing modulation and then deciding what to spend the money on… We are also very concerned that the draft Council Regulation on voluntary modulation, issued in May, proposes that there can only be one modulation rate for the UK as the Member State. This completely undermines the principle of devolved government and the Scottish Executive and UK government must secure a change that allows Scotland to set its own, appropriate rate" (192, Representative Organisation)

Increase voluntary modulation:

"Voluntary modulation (the transfer of funding from direct farm support to wider rural development) should be increased to the maximum permissible to make up for the likely decrease in the Rural Development budget" (103, Representative Organisation)

"Given the severe limitations on funding, voluntary modulation should be increased to 20% as rapidly as possible" (117, Representative Organisation)

8.5 Equality and discrimination

Qu.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?

Table 8.10 Summary of responses by respondent category

Commentary on response rates:

This question attracted a relatively low number of responses, with 104 of the 259 respondents to the Consultation providing their views, representing a response rate of 40%. Consistent with the high response rate recorded throughout the Consultation, the highest response rate within a category was recorded by local authorities (including Community Planning Partnerships) with 23 of the 34 respondents in this category providing a response. The lowest response rate was within the professional or academic body category with 4 responses from the 14 respondents in this category.

Main themes from the Consultation responses

There are a range of responses to this question, comprising: (i) the SRDP has no links with equality issues; (ii) inclusion issues may arise; (iii) the SRDP is already exclusive in its language and in its target population; and that (iv) the SRDP should actively assist inclusion.

SRDP has no link with equality issues: A number of respondents feel that the SRDP really does not touch on equality issues, and thus the question has limited relevance:

"The programme has no bearing or bias as regards equality groups" (11, Private Individual or Business [including MSP])

"We cannot see how any of these matters can be issues that relate to the SRDP which will be administered on a menu / case by case base as appropriate" (21, Representative Organisation)

"The programme proposed here should have absolutely no bearing on anything related to equality. It smacks of unwarranted P.C. and is not required in this process. Everyone involved in Land Management has the opportunity to become involved" (26, Private Individual or Business [including MSP])

Inclusion issues may arise, for example, with hard-to-reach groups: Other respondents recognise that, 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 should be available to all and should not in theory create any equality or inclusion issues. However, given that the bidding process is still unclear with RPAC and LAG geographies yet to be established, there may be inclusion issues that arise" (30, Regional/Local Development Partnership)

"We would assume that efforts are made by the Executive to ensure that this consultation is reaching the traditionally hard to reach groups. We are aware in our area there is little awareness of the importance of this consultation for the whole rural community" (49, Regional/Local Development Partnership)

"Given the wide ranging set of measures outlined, the programme has potential to impact on the population as a whole. Unless there is prioritisation of specific target groups, it seems unlikely that there will be significant impacts on equality groups" (57, Governmental Body)

The SRDP is exclusive in language and/or in target population: In contrast with the first two sets of comments, there are those who argue that the SRDP does indeed lead already to exclusion of certain sectors and individuals, the following quotes being illustrative:

"Due to the complexity of the programme and the language I fear that it will discriminate in favour of middle class professionals (i.e. status quo) and against challenged groups" (50, Private Individual or Business [including MSP])

"We welcome the statement regarding equality between men and women and non discrimination, however the land based sector is weighted heavily towards the male gender and there must be consideration how to address this gender imbalance and encourage more women to enter the land based industries where they can play a valuable role" (218, Representative Organisation)

"The current programme seriously discriminates against females, ethnic minorities, disabled groups, sexual minorities, young people and non-Christians because it is mainly directed at farmers. Farmers are predominantly male, older, protestant, 'straight', and white" (79, Professional or Academic Body)

"This programme fails to properly address these issues and will make very little, if any, difference to ethnic minorities or the disabled. Even with simple things like access, only general public access is mentioned" (91, Voluntary Sector)

SEERAD/ SRDP to assist inclusion: Given these differing views, there is a need felt by some for SEERAD to provide a degree of continuity and intervention, to ensure that inclusion issues are coherently and strategically addressed, rather than left to ad hoc optimism. The following extensive range of quotes is illustrative of the views expressed by respondents:

"We are disappointed that this point has been left until last, it reflects a lack of a clear social agenda, and we would suggest that it should really have been placed upfront... The social element is missing from much of the document and we believe needs to be given greater emphasis throughout the scheme" (175, Regional/Local Development Partnership)

"Focus on social enterprise, women's enterprise and programmes such as Closing the Opportunity Gap and the Carnegie Commission for Rural Community Development Rural Action Research Project, engender positive moves towards inclusion and the promotion of diversity" (71, Local Authority [incl CPP])

"It is difficult at this stage to see what is the potential impact on the six statutory equality groups. However, excluded groups such the elderly, the homeless, those with problems accessing transport and services must be included" (84, Local Authority [incl CPP])

"It is important that SEERAD adopts the Executive's National Standards for Community Engagement and uses these principals when designing local delivery systems" (88, Voluntary Sector)

"It is particularly important that SRDP engages with young people" (111, Voluntary Sector)

"Equality issues should not be an after-thought, which their position in this document suggests they may be. Given the changing demographics of rural Scotland and increasing diversification from the traditional land-based industries, it is important that equality issues are addressed throughout the processes put in place to implement the SRDP" (117, Representative Organisation)

"The following race equality elements relate to rural development: (i) the rising number of ethnic minorities in rural areas, particularly from Eastern European countries; (ii) the need for ethnic monitoring of grant funding so that positive action can be taken, and (iii) the need to update the Equality statement (p22) to reflect the race Relations Act (Amendment) 2000, and in particular the public duty element… the Consultation on Rural Development programme for Scotland 2007-2013 is of relevance to the promotion of race equality and we would therefore expect Scottish Ministers to have carried out a REIA" (241, Governmental Body)

In addition to the above, 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:

"The Leader+ programme, through targeting excluded groups, has previously supported some excellent examples of good practice across Europe. More focus on aspects of rural exclusion could provide a more proactive approach to such issues, e.g. Affordable Housing, rural transport, access to rural services etc" (35, Local Authority [incl CPP])

"The Leader+ Programme gave particular emphasis to young people and women but the new SRDP should positively promote the whole equal opportunities agenda in the same way that EU Structural Fund Programmes have done" (87, Local Authority [incl CPP])

"If the programme is delivered through a partnership approach using LEADER and Community Planning, issues of equality are addressed through due process in that partnership forum, as all partners work to an equality agenda" (134, Regional/Local Development Partnership)

Specific areas where it is felt that the SRDP should improve its stance and generate specific measures and mechanisms to maximise inclusion are outlined by respondents, and include: public access, migrant workers and young people:

Public access:

"The access elements in the scheme could contribute to improving facilities for people with disabilities as SFGS Schemes have done in the past. LMCs have been poor at this and the lack of clarity on what is acceptable as a path, and the lack of guidance on what is an appropriate access point (i.e. the inclusion of stiles in the scheme), mitigate against those with a disability who may seek access to the countryside. All measures should follow the general guidance that the provision should be suitable for all users unless there are good practical reasons that it is not, i.e. the slope is too steep for a reasonable path gradient" (77, Local Authority [incl CPP])

"We have noted that in both Tiers two and three concerning public access, there are no measures specifically aimed at disabled groups" (84, Local Authority [incl CPP])

"We would like to see the programme used to increase the opportunities available to disabled and disadvantaged people to enjoy the benefits of a well-managed countryside" (97, Governmental Body)

Migrant workers:

"We have particular concerns about the welfare of migrant workers in Scotland… we consider that an investigation of the housing, education and general welfare of this group is urgently required and should be considered under the Rural Development Programme" (138, Representative Organisation)

Young people:

"The SRDP is concerned with integration of people and environment and must therefore ensure that all sectors of society have access to that environment. There are particular concerns over the age profile in the land use sectors and farming in particular. The programme must encourage new entrants into farming and this should be adopted as a national priority" (142, Voluntary Sector)

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