From September to December 2008, the Scottish Government ran a consultation exercise entitled, "The Less Favoured Area Support Scheme in Scotland, 2010-2013". This aimed to gather views on the future role of the Less Favoured Area Support Scheme ( LFASS) in Scotland, in preparation for the expiry of the first interim scheme (2007-09), and in the light of anticipated regulatory changes in Europe. The consultation document sought responses to ten open questions, and 77 responses were received. The key findings of the analysis of these responses are summarised below.
Main Findings
- Responses were received from a wide range of stakeholders including most of the bodies whose comments had been expected, and a substantial number of grazing committees and individuals.
- The proposed new designations for demarcation of the LFA enjoyed very strong support, largely due to a perception that they might increase payments to more disadvantaged areas. A proposed payment calculation based on the agricultural capability of the land received more support than an alternative linked to current stocking density, but the largest share of respondents to this question expressed no preference.
- The rationale and objectives of the second interim scheme were strongly supported, but there was strong disagreement with the suggestion that it should simply be a continuation of the current scheme. This was because of fears that it would fail to prevent the further decline in livestock numbers, and because of its use of historic rather than current livestock data. Views were mixed as to whether the scheme should continue but with some redistribution of funds to more disadvantaged areas.
- There was very strong agreement with proposals for closer links between payment and livestock-related activity, and for inclusion into the scheme of previously ineligible new entrants to farming. However, there was criticism of the proposal to continue using historic livestock data as a basis for these changes, rather than current data updated annually.
- In response to the request for suggestions as to how the delivery of the environmental benefits of farming could be improved, the most common view was that no adjustments to the scheme were necessary. Of the respondents suggesting the introduction of additional environmental measures, views were divided as to whether these should be mandatory or optional.
- A proposal for reallocating LFASS funds to other measures in the Scotland Rural Development Programme ( SRDP) was strongly rejected, either on principle or because of the current economic climate.
Policy background
Support to farmers in Less Favoured Areas ( LFAs) within the European Union ( EU) is a long-standing measure of the Common Agricultural Policy ( CAP). Since 1975 it has provided a fairly broad mechanism for maintaining farming activity in areas facing disadvantages for agricultural production. Within Scotland, the LFASS is a significant component of the SRDP of 2007-13. The LFASS is designed to sustain active farming and crofting in these areas, and it aims to improve the environment and the countryside. It is also important for the vitality of local communities and for food production, with Scotland's livestock finishing and processing industry depending heavily on animals from the LFA.
Land management in Scotland's LFA faces particularly difficult physical and climatic conditions and, to compensate for these natural challenges, the LFASS provides around £61 million each year to over 12,500 farmers and crofters. Expected changes to the European regulations on LFA schemes could have significant implications for the classification of Scotland's LFA and for the basis of LFASS payments.
The consultation
From September to December 2008, the Scottish Government ran a consultation exercise entitled, "The Less Favoured Area Support Scheme in Scotland, 2010-2013". This aimed to gather views on the future role of the LFASS in Scotland, in preparation for the expiry of the first interim scheme (2007-09), and in the light of anticipated regulatory changes in Europe.
The consultation document was widely distributed and promoted, to encourage broad participation. Responses were sought to ten open questions. Seventy-seven responses were received and, for purposes of analysis, respondents were grouped into categories that aimed to reflect the main stakeholder interests, to differentiate between public sector and industry bodies, and to acknowledge the strong environmental and crofting interests in the LFA. The responses have been analysed using a structured approach to help identify concepts and ranges of views and to ensure complete and consistent treatment of each response.
Issues addressed
The issues addressed by the consultation fell into six broad subject areas:
- EU changes to the demarcation of the LFA, and to the calculation of payments (questions 1 and 2);
- the nature of the second interim scheme, including its objectives and whether or not it should differ significantly from the current scheme (questions 3-5);
- proposals for closer links between payment and livestock-related activity (questions 6 and 7);
- the environmental benefits of farming (question 8);
- a proposal for reallocating LFASS funds to other measures in the SRDP (question 9); and
- a request for any other suggestions (question 10).
Aims and objectives
The purpose of the consultation paper was to seek views on the part that the LFASS can play in helping to sustain farming and crofting in Scotland's LFA. The findings from the consultation will feed into decisions as to what will replace the current interim scheme, entailing notification to the EU and a new Scottish Statutory Instrument.
The aim of this report is to present the findings of a transparent, rigorous and systematic analysis of the written responses to the consultation document.
Findings
Question 1 asked for respondents' views on the use of a 'mountain area' designation and a 'specific handicap' designation for islands. The proposal to use these designations anticipates changes that are likely to be made by the EU to the criteria by which LFAs are demarcated.
The possible use of the designations enjoyed very strong support. Of the 69 responses to this question, 87% were in full or qualified agreement with the proposal. The main reason given for supporting the new approach was a perception that this could increase payments to more disadvantaged areas. Respondents who expressed qualified agreement preferred the status quo unless change were to be driven by the EU.
Question 2 outlined possible modifications to the calculation of LFASS payments. Option A links support to current levels of production by basing payments on current stocking density ( i.e. livestock units per hectare), and Option B is based on the agricultural capability of the land. Both options would be subject to a 'hectare adjustment' to avoid over-payment to land with low levels of livestock activity. Respondents were also asked whether they had alternative suggestions.
In the 73 responses received, there was more support for Option B (36%) than for Option A (14%). Supporters of Option B cited an objective system, the use of existing information, better targeting of disadvantaged areas, and a better fit with EU/ WTO rules regarding coupled payments. Those supporting Option A noted its emphasis on active land management, agricultural activity or production volume. Although Option B attracted more than twice as much support as Option A, the largest share of respondents (41%) expressed no preference, and 10% supported neither Option A nor B. Alternative suggestions were made by 53% of respondents to this question: the most common alternative proposed was to increase payments to remote or peripheral areas. 19% of respondents to this question were critical of the hectare adjustment.
Question 3 sought respondents' views on a rationale for LFASS based on the inter-dependence between support payments, land management and rural development, and on objectives of delivering social, economic and environmental benefits.
The rationale and objectives received strong support, with 86% of the 69 responses giving full or qualified agreement. Agreement was qualified by respondents who wished to add their own emphases or supplementary aims, the most common of which was a perceived need for more effective targeting of support on the more disadvantaged areas. Other respondents called for clearer definition of the scheme's aims, or proposed alternative aims.
Question 4 asked whether respondents would be in favour of continuing the current interim scheme, with no significant changes, during the period 2010-2013.
There were 74 responses to this question, but it received little support: 83% of respondents were in disagreement with the proposal. The most common reason for disagreement was the fear that failure to change would result in further decline in livestock numbers. Another common reason was an objection to the continued use of historic data as a basis for payment, which currently excludes new entrants from LFASS whilst continuing to make reduced payment to farmers who have significantly reduced their stocks.
Question 5 asked whether respondents would be in favour of continuing the current interim scheme, but with some redistribution of payments to more disadvantaged holdings. A consequence of this proposal is that payments would be decreased in other holdings to ensure budget neutrality. Respondents were also asked whether they had alternative suggestions.
There were 67 responses to this question, with slightly more against this proposal (55%) than for it (45%). Respondents agreed if they wished to see more funds directed to the more disadvantaged areas, and disagreed if they felt that the priority should be more fundamental change, more emphasis on environmental protection, or avoidance of the payment cuts that would be necessary to balance out the increases. The most common alternative suggestion was concerned with increasing the value of the minimum payment that is made to all LFASS recipients.
Question 6/ 7i asked for respondents' views on reinstating a closer link with livestock-related activity. At present, LFASS payments are related to the livestock declared in 2004. This meets EU requirements for the decoupling of payments from production, but has meant that farmers and crofters could have reduced their stocking levels whilst continuing to receive payments. The proposal is an update from 2004 to 2008 data.
There were 69 responses, of which all but three agreed with this proposal. This very strong agreement was driven by concerns including the support of active farming, the maintenance of stock or production volumes, and the environmental benefits of grazing. Some respondents suggested making LFASS payment conditional on stock density, but others tempered their agreement with concerns including the method of measuring stock density, the need to avoid administrative complexity, and the continued use of historic (although updated) livestock data.
Question 7ii asked for respondents' views on helping new entrants to farming since 2006, who are ineligible for LFASS payments. The proposal was to update the 2004 livestock data that is currently used, to data updated for 2008, which would make those who entered farming between 2006 and 2008 eligible.
This proposal enjoyed support from all 64 respondents to this question, because new entrants were seen as critical to a sector whose workforce and production are in decline. However, 34% of these respondents disagreed with the proposed use of livestock data from 2008 instead of 2004, on the grounds that this would not solve the issue in the future. Many respondents suggested the use of annually updated data instead.
Question 7iii proposed the reintroduction of a supplementary payment related to the ratio of cattle to sheep, which was terminated in 2008 to comply with EU requirements to decouple payments from current production.
There were 53 responses to this question, of which 89% gave full or qualified agreement to the proposal. Those who agreed had common aims of promoting the environmental benefits of mixed grazing, or of maintaining stock numbers, or both. The few who disagreed indicated dissatisfaction with the current scheme and with the proposed changes that still retain a link to production.
Question 8 asked respondents to suggest ways of maximising the potentially beneficial environmental effect of livestock farming, and of offering a greater incentive for environmentally-beneficial farming practices.
The most common view expressed in the 65 responses (46%) was that no adjustments to the scheme were necessary, because environmental benefits are intrinsic to good farming practice. The other respondents suggested additional environmental measures, but their views differed between those feeling that such measures should be mandatory, and those preferring that they should be optional.
Question 9 sought respondents' views on reallocating a proportion of LFASS funding to other measures in the SRDP.
There was very little support for this proposal. 92% of the 62 respondents disagreed, either with the proposal in principle, or with its introduction in the current economic climate. Common reasons given included a lack of confidence in the SRDP, and a fear of reduced support payments. Even where respondents agreed, opinion was split regarding whether the destination measures within the SRDP should be of an environmental nature or not.
Question 10 asked whether respondents had any other suggestions for the scheme to 2013.
Thirty-eight respondents made suggestions, the most common of which (made by 21% of the respondents) was a complete reform of LFASS in lieu of a second interim scheme. Next most common was a suggestion made by 11% of respondents, for increasing LFASS payments to holdings in remote areas.
Conclusion
The responses reflect a very wide range of views, from across the many sectors represented by the respondent categorisation. It should be noted, however, that the following categories were particularly strongly represented with a high number of responses: Local Authorities, Economic Development and National Parks; Individuals; Crofters' Commission and Common Grazings; and Land-based or regionally-defined associations. Furthermore, the responses from the Crofters' Commission and Common Grazings and Individuals often expressed similar views, reinforcing the strength of opinion in relation to these views.
This document, "Analysis of Responses to the Public Consultation on the Less Favoured Area Support Scheme in Scotland (2010-2013)" along with the full research report of the project, and further information about social and policy research commissioned and published on behalf of the Scottish Government, can be viewed on the Internet at: http://www.scotland.gov.uk/socialresearch . If you have any further queries about social research, please contact us at socialresearch@scotland.gsi.gov.uk or on 0131-244 7560.