9 "General comments" in response to the SRDP Consultation
9.1 Introduction
It is important to state that, in this Section, only those comments which raise issues which have not been covered in Questions 1 to 21, are described, in order to avoid repetition. However, it is necessary to note that respondents take the opportunity to re-emphasise points which they address earlier in response to the Consultation, particularly in relation to: (i) the balance of the SRDP being overly weighted towards the land-based sector through LMCs being the over-riding delivery mechanism; and conversely, (ii) the need for consistent recognition of a healthy business sector being the driver for all other elements of rural development. These issues are discussed in more depth in previous sections of the report.
Therefore, themes outlined below comprise those which are either not mentioned elsewhere in the document, or where a specific emphasis within a theme has not been described by respondents prior to this stage of the Consultation. An example of the latter is the need for integration of the SRDP with other strands of Scottish Executive policy, where specific strands are mentioned for the first time in this section.
9.2 Themes from the Consultation Responses
9.2.1 Contextual issues and trends which require recognition within the SRDP
Within this section of the Consultation, respondents outline those issues which they feel comprise the backdrop to the SRDP, and as such, they feel must also be addressed directly and indirectly through the programme. In its present form it is argued that the SRDP provides no recognition of such issues, and will therefore be ill-equipped to address the diverse realities of living and working in rural Scotland.
The main issues and trends which respondents highlight include: (i) the decline in the number of rural vets; (ii) the changes in the labour force, and its implications for Health and Safety; (iii) rural young people; (iv) affordable rural housing; (v) the tenanted farm sector; (vi) the ageing agricultural workforce and the importance therefore of attracting new entrants. The following quotes illustrate these points:
- Decline in number of rural vets:
"The veterinary profession in the rural areas of Scotland is in the decline and it is anticipated that there will be a reduction by at least 35% in the number of practices and even greater in terms of vets dealing with agricultural livestock in the next 10 years. It is now increasingly difficult to recruit young vets who see their long-term future in rural practice... The experienced core of veterinary practitioners who deal with cattle and sheep is rapidly diminishing and there are no tangible replacements... The introduction of the Land Management Contract Animal Health Initiatives have helped ensure some vets visit more farms annually than the usual and there needs to be greater promotion of this incentive to farmers and crofters" (27, Professional or Academic Body)
- Changes in labour force, and its implications:
"Already we have begun to see a decline in overall employment and a parallel decline in the number of larger farms. This has been accompanied by increases in the number of small, self-employed units, part-time and niche market farmers and in contracting-out. These trends are expected to accelerate markedly over the next ten years. There is also increased mobility for labour, livestock and foodstuffs, bringing increased threats, for instance, from disease and also increased 'casualisation' of labour. Management control is less evident and traditional regulatory intervention based around fixed establishments and employment law is less relevant. The UK Food chain … has some of the highest rates of injury, ill health and death at work of any industry sector...This trend of further fragmentation of the industry is likely to result in even more deaths and injuries for agriculture… A further major trend... is the increasing use of migrant and casual labour. The working conditions of many such workers is inconsistent with the aspirations of a civilised society" (114, Government Body)
"The labour market for young people in rural areas is characterised by low pay, limited choices for employment, seasonal work, a lack of quality employment and poor access to training. Accessing services can be particularly difficult … due to lack of transport infrastructure... Scarcity of services and lack of anonymity in rural communities make young people less able or likely to access information on drugs, alcohol, sexual and mental health. Rates of suicide amongst young males, aged between 16 and 24 are higher in rural areas than elsewhere. Young people who are caught up in the youth justice system are highly visible in rural areas and problems they may face on leaving prison are compounded by the lack of services that are available to them. In surveys undertaken with young people in rural areas the issues of transport, affordable housing and employment opportunities are key... It is disappointing that the SRDP does not appear to address any of these problems" (153, Voluntary Sector)
- Affordable rural housing:
"The supply of affordable rural housing is critical to the economic success and future prosperity of rural Scotland… it must be more explicit and firmly rooted within general rural policy" (160, Representative Organisation)
"It is estimated that about a third of Scotland's farms are tenanted and these units are more vulnerable than owner occupied ones to economic decline. Tenant farmers do not have the same flexibility and opportunity to diversify from agricultural activity as those who own their land ... The ability of tenant farmers to invest to promote and sustain rural development is compromised by their low asset base. Any rural development plan containing long term goals must surely make mention of tenant/landlord influences" (201, Representative Organisation)
- Ageing workforce and importance of attracting and retaining new entrants:
"In an industry that is characterised by an aging workforce the SRDP should recognise the need for, and encouragement of, new entrants and the improvement of skill levels among the existing and future workforce" (131, Representative Organisation)
"Provision should be made for new entrants to access the funding which is available of up to 55,000 Euro under Council Regulation ( EC) No 1698/2005 article 22. This funding will be competitive and based on a business plan. Funding should come from LMC funding in Tier 3… RDR Article 21 allows for support up to a maximum of 55,000 _ for the setting up young farmers. Scotland has not used the equivalent articles in previous regulations, but we believe that this is now justified, given the age structure of the Scottish agricultural industry. The regulation allows support to be granted to those "setting up for the first time on an agricultural holding as head of the holding", which therefore includes those who are taking charge of an existing business as well as those who are new entrants. We believe that this definition is crucial, as it is just as important to retain young people in the industry as it is to attract new entrants" (169, Representative Organisation)
"Farm businesses also need to manage succession and the associated financial planning… Succession has not been planned or managed in many businesses. The result is that some senior partners stay on within the business for longer than they should. Use of these RDR mechanisms would help the succession process in farm businesses" (169, Representative Organisation)
"There must be the opportunity for new entrants to develop their skills… Often young farmers have been late in years before taking control of the business and have not developed the business skills to cope with the change and challenges of a global market" (218, Representative Organisation)
9.2.2 Underlying approaches that need to be reflected in the SRDP
Respondents outline the ways in which the SRDP should be oriented towards quality of life measures, and towards viewing rural communities, in their widest sense, as asset-based, rather than deficit-based. These two elements are now elaborated.
- Quality of life measures:
"Many of the SRDP indicators and objectives could have more quality of life measures such as 'growth of volunteering' or 'greater participation in the social/cultural life of the rural community'. It is the strength of these bonds that keep people living and prospering in rural areas" (125, Representative Organisation)
- Assets as the basis for rural development:
"We welcome the aim to create a rural development policy that capitalises on the assets of rural Scotland - its people, its outstanding landscapes and natural heritage… The programme's ambitious place-based approach capitalises on local strengths" (58, Local Authority, incl CPP)
"Over the last few years some communities have benefited greatly from 'capacity building' where local people are taught basic methods of achieving their goals. These volunteers have, by and large, gone on to tackle projects that would have cost the public purse considerable sums of money. These methods of teaching people to recognise and use their many latent talents is most important for development in rural areas" (172, Local Authority, incl CPP)
"To maximise the development of Scotland's rural areas… emphasis should be on diversifying and growing the rural economy through focusing on growth and adding value to the primary assets… Capitalise on the natural asset base and contribution of rural areas to our national and regional priority industries… there remain opportunities to increase the rural contribution across our national priority industries, particularly in relation to tourism, food & drink and energy…" (195, Government Body)
"The success of the Axes1- 4 depend upon investment in human assets in the form of skills and workforce development… the strategy will not be realised unless the skills and competence are in place within the workforce... Skills and workforce development must encompass legislative, technical, business development and continued professional development ( CPD)" (218, Representative Organisation)
9.2.3 What the SRDP addresses insufficiently or partially at best
There are a number of issues which respondents highlight as having been addressed only partially, or even poorly, within the SRDP. They request that these imbalances are redressed, given their importance to the sustainability of rural Scotland. Such issues include: (i) climate change; (ii) forestry funding; (iii) the equine industry; (iv) native animal breeds; (v) the specific societal benefits of organic farming; (vi) co-operative business and incentives for co-operation; (vii) moorland management; (viii) rural roads; and (ix) tourism and eco-tourism. These are now presented.
"We do not believe the current proposals for the SRDP place enough emphasis on the role that the programme can and should play in helping the natural environment and rural areas mitigate the effects of, and adapt to, climate change. The SRDP must be regarded as one of the key ways in which a more robust and resilient countryside, able to cope with the quickening pace of environmental change, can be created… The SRDP needs to look to the future in terms of the challenges we face, rather than simply looking to the past in terms what SRDP has been used for" (13, Voluntary Sector)
"Climate change is the key environmental challenge. Land use and associated activities have a big potential impact on both mitigation and adaptation. Energy use, carbon management and greenhouse gas emission reduction must receive a very high profile in determining priorities for funding" (142, Voluntary Sector)
"Scotland's climate change programme (2006) states that "without a concerted global effort… climate change will cause devastation across the world… it is right for us to promote good governance and be among the first countries to reduce their emission"…. through promoting carbon sinks by conserving and enhancing peat bogs and woodlands, conserving soils, reducing energy use, using fertilisers efficiently, and developing energy crops... We recommend that Axis 1 and Axis 2 be used to fund climate change adaptation and mitigation measures, covered in the RDR measure 'restoring agricultural production potential damaged by natural disasters and introducing appropriate prevention actions'. This would strengthen the funding provision for climate change measures (paragraph 70)" (248, Government Body)
"Whilst we appreciate that the forestry grants have increased over the past few years, it is still the case that forestry is significantly under-funded in Scotland with grants this year totalling £26m in comparison to agricultural grants which total around £400m… We therefore would like to urge SEERAD to ensure there is adequate forestry funding for both the SRDP and the Scottish Forestry Strategy" (13, Voluntary Sector)
" SRDP remains a document firmly dominated by agricultural interest first and foremost, with only passing reference to the other major primary land use of forestry. The SRDP lacks clarity in recognising the first important principle of supporting sustainable, economically viable businesses in their primary roles of food and timber production. It is only through the success of such businesses that public benefits can be delivered" (197, Representative Organisation)
"In England & Wales the dynamic role played by equestrianism is reflected in the support DEFRA has given to the "Strategy for the Horse Industry in England & Wales". At this time SEERAD has proposed no equivalent strategy for Scotland, despite the industry's estimated contribution to the Scottish economy of some £300m. Official figures suggest there are around 22,000 'registered' horses in Scotland however it is widely accepted that the true figure is nearer 100,000… It is self-evident that through tourism, sport, leisure and recreation, equestrian businesses are a very significant player on the rural scene. The numerous ancillary and supply businesses which service the equine industry, together with the impact on local tourism and hospitality businesses, result in a significant multiplier effect… Recognition of the equine industry within the definition of an 'agricultural-type' activity would help to underline the value of the industry" (38, Professional or Academic Body)
"Some of our native breeds are omitted from LMCs proposals … Eriskay, Highland, Shetland ponies and Clydesdale… I know from DEFRA that they have included a measure for native ponies. The Grazing Animals Project in England has shown that ponies can create a structural diversity benefiting a wide range of species including invertebrates, small mammals and birds including birds of prey… here is an opportunity for people to contribute to sustaining our native equine breeds (who are part of natural heritage and biodiversity) and thus manage those habitats which present a challenge to other agricultural livestock" (68, Professional or Academic Body)
"It is important to appreciate that conversion to organic farming is a very significant fundamental change to a producer's farming operation. It isn't just a case of tweaking or modifying an area of the farm - it involves the entire farm. Significant support for organic farming is essential to allow this process to be completed effectively. It is also important that during this review process measures are considered to allow producers on short leases to access organic aid funds. The current system precludes their involvement unless they get written commitments from their landlords to take on liabilities if problems arise… That stifles the involvement of particularly the younger generation" (78, Representative Organisation)
"Organic farming and food can deliver across all three axes. Organic farming contributes substantially to rural economies by increasing farm based work opportunities. In the UK it provides 32% more jobs per farm than equivalent non-organic farms. This figure rises to 64% in Scotland. Organic farming is also attracting younger people into farming and those farming organically are more likely to be involved in on-farm processing, marketing and retailing" (142, Voluntary Sector)
- Co-operative business and co-operation:
"It is essential that the contribution and potential of co-operation to deliver significant improvement in the competitiveness of Scottish agriculture is recognised by the provision of support through the SRDP" (147, Professional or Academic Body)
"There is no clear indication of encouragement for groups of land managers to organise and cooperate together to put forward schemes that will deliver sustainable environmental management over broad areas… What funds are available should be primarily targeted to cooperative, collective group schemes which will enable funding to be used for environmental, economic and social benefits over a wide area" (171, Regional/Local Development Partnership)
"Provision for, and encouragement of, collaborative applications is essential… An initiative for catchment officers, similar to Defra's Catchment Sensitive Farming Initiative, should be developed for Scotland" (248, Government Body)
"The SRDP should emphasise positive moorland management practices, including: (i) Retention/reintroduction of hill livestock into areas where their use can enhance the moorland; (ii) Appropriate management of moorland through grazing; (iii) Improved quality and quantity of muirburn; (iv) Heather regeneration; (v) More sympathetic management of woodlands bordering moorland; (vi) Appropriate planting of native broadleaved trees to provide enhancement; (vii) Habitat management to prevent dominance by invasive species; (viii) Formation of Fire Protection Groups; (ix) Coordination of deer management; (x) Landowners collaborate to introduce management practices to reduce tick numbers; (xi) Development of moorland habitat networks; (xii) Removal of inappropriate woodland plantations from moorland areas, including priority habitats; (xiii) Greater emphasis on the production of integrated, long-term management plans; (xiv) Targeted incentives for key moorland species" (16, Voluntary Sector)
"Roads are taken for granted. That much is clear from your consultation document, which barely mentions them. But development inevitably impinges on roads… Should not the programme explain how necessary alterations to the network will be identified and the subsequent work funded?" (2, Private individual and/or business (incl MSPs))
- Tourism and eco-tourism as a rural employer:
"Having studied the consultation document on rural development, I am concerned that only farming, forestry and fishing seem to be worth consulting about regarding the rural economy… Tourism is our largest and still growing industry !!! Ecotourism has terrific potential" (6, Private individual and/or business (incl MSPs))
9.2.4 The need for co-ordination of the SRDP with other policy areas
Respondents, in earlier parts of the Consultation, emphasise the absolute necessity for co-ordination of activity and purpose between the SRDP and other Scottish Executive initiatives and priorities. In this section, additional areas are raised, where such co-ordination of effort is required in order to lead to an increased likelihood of meeting targets, through joining up of effort and activities. The priority areas include: (i) outdoor recreation; (ii) Scottish Diet Action Plan; (iii) the Scottish Executive's "Hungry for Success - A Whole School Approach to School Meals in Scotland (iv) the Scottish Executive's Sustainable Development Strategy; (v) the Scottish Executive's Consultation "Diffuse Pollution from Rural Land Use"; (vi) geodiversity priorities; (vii) the remit of the Department of Trade and Industry; (viii) gender equality; and (ix) Scotland's National Parks.
Outdoor recreation:
"We are pleased that the SE is making serious efforts to integrate outdoor recreation into its rural development work… There needs to be more coordination with other policy areas, notably with the SE's Physical Activity Strategy, the implementation of the access provisions of the Land Reform (Scotland) Act 2003 and the requirements of the European Landscape Convention" (19, Voluntary Sector)
Scottish Diet Action Plan ( SDAP):
"We note that the Scottish Diet Action Plan is now being reviewed, and anticipate the review to acknowledge the clear links between environmental and human health. The SRDP must be able to deliver the ambitions of the refreshed SDAP and must therefore retain some flexibility until these policies are made clear" (142, Voluntary Sector)
"Hungry for Success":
"We are currently developing a project to deliver local food to local schools and feel that this fits well with the aims of the SE's recent publication 'Hungry For Success - A Whole School Approach to School Meals in Scotland'... It is our ambition to take the objectives of Hungry for Success one step further and encourage the use of local producers in supplying food to local schools. This would also enable the SE to fulfil its aims outlined in the current consultation on the Schools Nutrition and Health Promotion Bill and in its Hungry for Success publication" (188, Voluntary Sector)
Aligning with other Strategies and Statements:
"The SRDP must be consistent with the SESustainable Development Strategy. However, the interpretation of sustainability outlined in paragraph 10 of the consultation is weak, in only seeking to "avoid net damage" to the environment. The SRDP must seek to go beyond this 'minimum standard' approach and present an integrated programme where measures benefit each of the three cross-cutting elements of sustainable development. The delivery of the SRDP must comply with the Nature Conservation (Scotland) Act 2004" (39, Voluntary Sector)
"There is a significant opportunity in this new SRDP to align strongly with Water Framework Directive ( WFD) priorities. No mention is made of the SE consultation 'Diffuse Pollution from Rural Land Use' in the Strategic Context section and yet this document specifically refers to the targeting of LMC measures to achieve the environmental objectives of the WFD" (248, Government Body)
Geodiversity:
"The recent DEFRAPlanning Policy Statement 9: Biodiversity and geological conservation and Local Sites: Guidance on their identification, Selection and Management is key to raising the support in England for Geodiversity... In Scotland, the recognition of geodiversity as of equal status to biodiversity stems from the Nature Conservation (Scotland) Bill and the recently published Guidance on Establishing and Managing Local Nature Conservation Site Systems in Scotland ( SNH 2006) in the current absence of a PAN equivalent to the new English PPS9. Indeed if the 2007-13 SRDP is subjected to SEA (Strategic Environmental Assessment Part 3 para 83) it is difficult to see how geodiversity can now be ignored as part of Rural Scotland's diverse natural environment (Part 2; para 18)" (155, Voluntary Sector)
Department of Trade and Industry:
"Whilst Rural Development in Scotland is the responsibility of SEERAD, the provision of postal services is not a devolved function and lies within the remit of the Department of Trade and Industry ( DTI). It is important that policy initiatives for the reinvention of the rural post office network currently under consideration by the DTI are fully consistent with SEERAD's Development Plan and that the two areas of government activity are mutually supportive… In the context of the uncertainty surrounding the DTI's intentions regarding the 'Social Network Payment' after 2008, we consider the SRDP as an alternative or complementary vehicle for recognising the social value of post offices, together with their economic value in sustaining the wider rural economy" (187, Government Body)
Gender equality duty:
"A key theme for the new programme will be to 'promote a more diverse rural economy and thriving rural communities' to do this effectively it will be essential to consider the different lives and experiences of men and women. The gender equality duty will have a direct impact on public services and policy marking. The duty will come into force in April 2007 and it will require public authorities to ensure that their policies and practices as employers, as service deliverers and in their other functions, including policy making, regulatory and enforcement activities, address the different needs of women and men. Given that the duty will come into effect in the same year as the new SRDP we consider it essential that the new programme will take a vigorous and systematic approach to promoting gender equality and combating the disadvantage and discrimination faced by women and men in rural Scotland" (243, Government Body)
National Parks:
"The boundaries of the LAGs and RPACs in Scotland are important for the delivery of integrated sustainable development in the National Parks. We strongly support an approach where the National Park area is dealt with as a whole unit when drawing boundaries. We understand that the RPACS will be at a regional level but recommend that the whole National Park area must nestle within one RPAC area. We strongly recommend that SEERAD bases one of its LEADERLAG areas on the National Park boundary and that the LAG is hosted by the National Park Authority" (144, Government Body)
9.2.5 The SRDP requires more clarity in certain areas
Respondents outline two areas where they feel the SRDP Consultation document provides insufficient information: (i) LEADER and governance and (ii) the overall, and operational, budgets of the SRDP.
LEADER - governance issues:
Respondents describe the lack of clarity within the SRDP Consultation document, over how LEADER will work in practice. It is felt that issues of governance, responsibility, devolution of decision-making and budget, have not been fully addressed. This is considered a serious omission, since the SRDP also outlines specific expectations of the " LEADER approach". Those currently involved in delivering LEADER are aware of its complexity and thus of the need to specify the ways it will work and be appropriated within the different Axes. The following quotes from textual general comments illustrate these points:
"There is a lack of clarity on what SEERAD means by LEADER: process or programme. The document does not explain how LEADER is to be implemented, how and where it fits within the SRDP and what scale it will operate at" (134, Regional/Local Development Partnership)
"It is unclear if the LAG will be able to act as the final decision making body on projects funded under a LEADER 'type' programme. Local devolved decision making is a fundamental part of the LEADER process and should not be lost from a future programme. The 'bottom up, devolved local decision making' approach of the LEADER model must retained and applied across Axes 3 and 4" (134, Regional/Local Development Partnership)
"There is excessive detail on LMC eligible costs, but very little on LEADER. There is no guidance on its scope, how it could complement LMCs and LFASS, how it could integrate with Community Planning and RPACs, let alone eligible costs for LEADER projects. This is despite it being identified as a key delivery mechanism for the SRDP" (217, Regional/Local Development Partnership)
"It is not clear from the document how SEERAD propose to comply with RDR guidance relating to co-operative working and no mention is made of transnational or transregional working, which have been an important part of the LEADER+ programme and is identified in the RDR" (134, Regional/Local Development Partnership)
The overall, and operational, budget of SRDP:
Firstly, respondents are concerned that the SRDP has not clarified its operational budget, and indeed has not put it forward as part of the Consultation exercise. Secondly, many are aware of the EU funding structures and the potential for these to lead to a reduction in the funding pot of the SRDP. Respondents wish SEERAD to outline how they propose to address this, and more specifically, to outline the implications for the delivery of the SRDP. Thirdly, given the likely spend, and the proportion committed to LFASS and agri-environment, respondents are unsure that the objectives for wider rural development outlined in the SRDP will be feasible on such a budget. They seek greater clarity from SEERAD on these matters.
Operational budget:
"In order to ensure delivery mechanisms are fit for purpose it is essential that they be designed in consideration of an operational budget. The administration and management requirements for a small scheme can be disproportionate to the direct support being delivered. If some of the administration systems were to be centralised it would be essential that claim processing deadlines be put in place to prevent the financial burden of delayed payments falling on small community groups that are unlikely to have the financial systems in place to cope with delayed payments" (168, Regional/Local Development Partnership)
Declining EU spend:
"The consultation document makes clear the extent to which SRDP 2007-13 is likely to be affected by funding strictures. EU Funds are reducing (paras 65 and 66). SE funds will not make up the shortfall, because the tight Spending Review climate is likely to prevent additional SE funds from being allocated to SRDP. This is not a favourable background against which to bid for sufficient funds for the whole range of community initiatives" (186, Regional/Local Development Partnership)
The budget for wider rural development objectives of the SRDP:
"At the EU level, the budget allocation for the parent regulation ( EAFRD) is just under Euro 70bn for 7 years to 2013, representing about 20% of the total CAP spend. The annual agricultural spend in Scotland is about £500m, and assuming a pro-rata allocation… the SRDP might have around £100m per annum for the 2007-13 period, plus 5% modulation amounting to some £25m. If LFASS absorbs some 50% of this, and agri-environment nearly 20%, it leaves only 30% for other measures… Although there is some scope for using additional modulation funds to augment the budget for SRDP (perhaps another £25m?), the concern remains that the territorial rural development measures will be 'squeezed out'" (191, Private individual and/or business (incl MSPs))
"When will there be an indication on the budget? Our concerns centre on: (i) continuity of where financial support will be obtained from March 2007 with no 'black hole' between funding rounds; (ii) Current programme proposals raises concern that rural communities will be split between farming lobby and community development lobby. We are all part of a community and cannot be seen as at odds with each other" (206, Regional/Local Development Partnership)
9.2.6 Monitoring and Evaluation
The final themes within this section focus on: (i) SEERAD's evaluation of this Consultation; and (ii) the monitoring and evaluation of the SRDP. These are now outlined.
SEERAD's evaluation of this Consultation:
Firstly, there is disappointment from a number of respondents that, having commented on the Strategy document, their concerns and suggestions have not been visibly incorporated within the subsequent Programme document, for example:
"The programme does not seem to us to be consistently well aligned to delivering the Strategic Plan previously circulated for comment. For example the strategy document made clear reference to the promotion of local food, the need for small scale local slaughterhouses and meat processing and the need for a reduction in food miles (or an increase in food security), and reduction in timber miles but these appear to be missing from the programme document… The Strategy Document appeared to be taking a much broader and more integrated approach and we welcomed it. The Programme Document has not followed-through and we are therefore disappointed" (175, Regional/Local Development Partnership)
Further, there is an associated concern that the "turn-around" time between receiving these Consultation responses and making policy decisions, is insufficient to allow for a genuine consideration of respondents' concerns and suggestions, for example:
"The consultation period between the strategic and detailed considerations of the SRDP has been very short, and we are particularly concerned at the very short time proposed between the consultation period and the submission of the SRDP to Europe" (180, Representative Organisation)
Monitoring and evaluation of the SRDP:
Firstly, respondents are disappointed that the consultation document contained no questions relating to the monitoring and evaluation aspects of the seven-year SRDP, as the opportunity to make suggestions would have been welcomed:
"There are no questions within the consultation document on monitoring and evaluation. The monitoring and evaluation for the current SRDP has been unsatisfactory, and the delivery of public benefits through the programme difficult to identify. A clear system of monitoring indicators should be used, that allows the comparative assessment of activities carried out on designated sites with those on non-designated sites" (17, Voluntary Sector)
Secondly, there is concern over an apparent discontinuity with the Common Monitoring and Evaluation Framework ( CMEF) and the measures and activities outlined within the SRDP Tiers:
"There is a need for more integration of the CMEF (p.56) into the LMC Tier 2 and particularly Tier 3. (especially p.41). CMEF Output Indicators under Axis 3 (321, 322, 331 and 341) are not adequately supported under Tier 3 LMCs. In particular, 322 is not mentioned in the Consultation version of the SRDP" (148, Professional or Academic Body)
"The applicability of the 'common indicators' in Annex H is patchy, and not all of them are fully developed. With the new SRDP there is an opportunity to work on monitoring in a more collaborative manner, making use of the information already gathered by several public bodies and co-ordinating the monitoring of a range of programmes and initiatives" (204, Government Body)
Thirdly, the measures considered appropriate to the monitoring and evaluation of the SRDP need to be assessed:
"We agree that monitoring and evaluation is vital in achieving worthwhile results... The outcome-based prescription is a favoured option as this has the potential to deliver more benefits than using rules that contain fixed prescriptions... The identification of clear objectives rather than prescriptions at the outset will enable much of the evaluation process to be captured early on and will also facilitate improved planning for both farmers and advisers" (194, Professional or Academic Body)
"We believe that monitoring and evaluation of measures so as to assess effectiveness needs to be integral to delivery of the outcomes. Information on the targeting of measures and success, or otherwise, will require information on location and type of measure to be held in a database for mapping, using Geographic Information Systems ( GIS). The recent European Environment Agency Report 'Integration of environment into EU agriculture policy - the IRENA indicator-based assessment report' has many useful recommendations, both for monitoring and for schemes to be effective" (248, Government Body)