Response 1023087979

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Direct Payments (Pillar 1)

1. Do you agree with the stability approach described here? Please provide comments.

Do you agree with the stability approach described here? Please provide comments.
Scotland’s Rural College (SRUC) welcomes the chance to comment on the Scottish Government’s proposals for a rural funding period ‘Stability and Simplicity’. This response draws on expertise from across our Research, Education and SAC Consulting Divisions. SRUC’s vision is: “To be a unique, market-led and mission diverse 21st Century rural university”, and our mission is: “To drive the future needs of a dynamic, innovative and competitive rural sector in Scotland and to solve the biggest global agri-food challenges.” We welcome the Scottish Government’s recognition of the opportunity to simplify the delivery and regulation of agricultural support and fully agree that a period of stability is required during the most uncertain of times that Brexit has brought. Many of the challenges addressed in ‘Stability and Simplicity’ are not new, merely thrown into starker relief by Brexit. Nevertheless, we agree with the Agriculture Champions’ position of “no change is not an option” – and believe that this relates not only to most agricultural business across Scotland, but also for future agricultural support policy. Indeed our own new strategy has embraced such an ethos to drive SRUC forward with a bold vision that will put it at the forefront of innovation within the rural economy. Our Principal and Chief Executive, Wayne Powell, stating that “Simply tinkering with an SRUC with one foot in the last century would be a major error.” We believe that in order to unlock the true potential of Scotland’s agricultural sector in the long run the ‘path dependent’ nature of agricultural support (where minimum disruption has been the preferred option over devising support schemes that deliver defined outcomes) has to be broken. In order to deliver a more resilient and prosperous agricultural sector that protects and enhances the environment new and innovative approaches to agricultural support, regulation, monitoring and evaluation and upskilling that are fit for the 21st Century need devised. These novel approaches need to help deliver a more efficient, competitive and resilient sector delivering more transparent ‘public value for public money’ that helps justify why discretionary expenditure on agriculture (no longer ring-fenced) should be supported in the future, rather than spending it on other competing demands. The challenge in having a period of stability and general maintenance of the staus-quo for another six years means that the general public, and media, may continue to question the ‘public value’ derived from public expenditure in Scottish agriculture and press politicians to divert funds to other needs. We appreciate the logic in maintaining the staus-quo until there is some clarity over future support budgets, UK frameworks, trade deals (particularly with the EU), and the UK’s relationship with the WTO. Whilst there is a natural tendency to focus on the future trade deal between the UK and the EU-27 we also must consider how exposed to liberal world markets Scottish farmers may become in the longer term if fully outside the EU, and therefore what support mechanisms may be required under such scenarios. Clarity over our future trading situation may not be finalised for at least a couple of years, even under a worse case “no deal” exit scenario, meaning the position of stability is worthwhile pursuing until there is greater clarity on future agri-food trade deals. Further, the scope for the Scottish Government to set a post-Brexit farm, food and rural policy will be constrained by the policy framework agreed between the UK administrations and the associated future funding arrangement must be more fully understood before a future policy can be fixed. We suggest that urgent work is required in the coming months to decide upon the best policy mix to transit to should the preferred timescale of March 2024 be affected by a hard Brexit. We would encourage some contingency planning for a hard-Brexit that may necessitate more rapid changes to the support mix in reaction to needs linked with international trade barriers that such a scenario may bring. For instance, without tariff free access to the EU market, UK sheepmeat prices would probably collapse and without some form of emergency slaughter scheme, as occurred in the foot-and-mouth crises, an animal welfare problem would occur on Scottish sheep farms. Clearly, not only are contingency plans needed for a worse-case scenario, the cost of implementing such plans would almost certainly result in the need to change future Scottish rural policy faster than currently set out in the consultation document. We believe that it is critical for the Scottish Government to start thinking about the longer term future of farm, food and rural policy in Scotland to provide the sector with some clarity to help with business decision-making, whilst also ensuring Scotland is not left behind thinking and policy developments in England, Wales and Northern Ireland. The aims and objectives of Scottish agricultural policy post-Brexit need to be agreed (perhaps look to the EU’s own revised objectives) so that the mechanisms, that is policy mix, to achieve these can be derived. That is, a range of possible policy mixes should be whittled down to a short list, based on a priori knowledge, from which options are rigorously tested against a list of criteria such as the following: • Budgetary cost • Ease and cost of administration • WTO rules • Farm productivity and profitability • Environmental impact • Agri-food supply chains • Broader rural economy • Ease of transition Such analysis will then underpin a consultation process to arrive at a preferred policy mix that, based on the suggested timescale, would be implemented in 2024. Clearly, only when this end state policy mix is decided, can a real transition plan be started. We know that policy certainty has done little to drive innovation, improve competitiveness and deliver wider environmental outcomes across much of Scottish agriculture over the last 15 years. Therefore the transition period as the UK withdraws from the EU is unlikely to have significant impacts on the sector (unless there is a hard-Brexit and trade channels are blocked) as the proposals are to largely maintain the existing Common Agricultural Policy framework and mechanisms. The challenge for the industry will be how to transition to a new ambitious Scottish farm, food and rural policy in the longer term and SRUC are in a unique position to help that process from policy design, research and development, knowledge exchange, innovation adoptions and education and training perspectives, and we look forward to supporting the Scottish Government and the industry in this period of opportunity post-Brexit.

2. How might the annual application process for direct payments be adjusted to deliver with a lighter touch for those with little year-on-year change in their business?

How might the annual application process for direct payments be adjusted to deliver with a lighter touch for those with little year-on-year change in their business?
In terms of stability and simplicity, it would be an imperative that from applicant perspective nothing changes to make things more complicated, or more onerous. Whilst we applaud the Scottish Government’s ambition to deliver a lighter touch administration process for businesses there is a real danger here that by going for this approach “everyone says the same as last year”. Experience from within SAC Consulting (who complete around 40% of Scottish SAF forms annually) “same as last year” rarely occurs in the more productive areas of Scotland. Experienced consultants suggest that less than 20% of SAF forms would fall into this category, with mapping and field developments let alone cropping changes, meaning that this is almost never the case. Experience suggests that there is often little year on year change in less agriculturally productive areas, but even on such businesses things can and do move on, and it would be naïve to think that they would not (e.g. taking some land out of production for a new shed or stack of bales, giving up or taking on a seasonal field, taking a field out of an LFASS claim because of an ineligible activity, AECS and other designated schemes that still need to be recorded in some way). Should a lighter touch be applied there will be a requirement for clear and steadfast eligibility criteria along with a declaration of “no change” by applicants. There would also need to be increased tolerances built into the inspection regime, lest applicants fall foul of rules and penalties imposed that could lead to uplift in appeals (derived by confusion over the light touch application process). Common-sense and proportionality in the inspections/penalties system would be more useful and immediately beneficial to industry. The existing system is now relatively straightforward, and provided it stays stable is a good platform for applications. The initial issues that plagued the “Futures programme” seem, from an applicant’s perspective, to have been sorted. However, there is an awareness that more work needs to be done on the “Futures programme” but this cannot be to the detriment of client experience. There is a real concern that there is increased emphasis on mapping, and the need for adequate broadband capability to handle the data is a real issue for many on-farm/croft applications throughout the country. Mapping, and the changes associated with it, must not be allowed to become a complicating factor in the application process.

3. Are there operational changes in our delivery of Direct Payments that you would like the Government to consider during the transition period?

Are there operational changes in our delivery of Direct Payments that you would like the Government to consider during the transition period?
In terms of operational changes, there is one big change that would help many businesses that would involve an extension to the application window. If the window could be opened earlier, it would allow for a more orderly application operation (i.e. open in early February and run until 15th May). This would be especially helpful for the remoter areas where agriculture is either part-time or run in conjunction with other business. Such an extension would also help the less agriculturally productive areas, where the changes tend to be less numerous and where the current application window coincides with Spring lambing - probably the most stressful time possible for these businesses. For mainstream business there will, inevitably, be decisions that are driven by weather and ground conditions, although cropping plans and rotations are often fixed much earlier than generally accepted. For this reason, it is imperative that future greening rules need to be determined much earlier than at present, and that rules cannot subsequently change before the application and inspection period. This therefore puts pressure back on the Scottish Government to clarify any rule changes in the autumn preceding application year. The alternative is a completely simplified greening approach to perhaps something like 4m buffer round every field with arable crops in it. Operationally however, there is an absolute imperative that the hierarchy for changes is sorted out, such that where there has been a physical field inspection this takes precedent over desk based assessments. The desk based assessments are conducted using aerial photography that is sometimes out of date and current land use can be incorrectly interpreted. Where the desk-based assessor identifies a discrepancy in the stated land use this automatically leads to a penalty letter. We believe that this is inequitable and instead, where a discrepancy is seen by the desk based assessor, a verification letter should be sent to the claimant to provide them with an opportunity to verify or challenge the claim. We strongly suggest that where a physical inspection has occurred this should over-ride the desk top assessment - currently this is not the case. There is a need for more consistent and timely information dissemination from the Scottish Government, both to SGRPID offices and the wider applicant community. There are cases whereby similar queries are raised to SGRPID, but different local interpretations and responses are received from SGRPID regional offices that can lead to a lack of consistent message from the Scottish Government and confusion for those working across more than one SGRPID region (particularly agents). We believe that there needs to be greater proportionality in the penalty regime, with a more common-sense approach to inspections and penalties, particularly for unintentional errors. An example would be in NVZ regulations where an application of any amount of slurry, regardless how small, over a prescribed limit gives rise to an automatic minimum 3% penalty against all BPS, LFASS, AECS etc. which can run into many thousands of pounds.

4. Do you support the continuation of some or all CAP rules on inspections and compliance during the Transition period, bearing in mind that Scotland will still need to comply with the rules of the World Trade Organisation (WTO)?

Do you support the continuation of some or all CAP rules on inspections and compliance during the Transition period, bearing in mind that Scotland will still need to comply with the rules of the World Trade Organisation (WTO)?
Whilst Scotland is part of any EU CAP support scheme it would be prudent to continue the inspection regime as laid down in EU Articles. However, there likely remains scope to review the compliance and inspection process to identify opportunities for simplification and a less onerous regime. Whilst Scotland has not chosen to come out of the EU, post-Brexit may provide some relief from the EU audit process and its process-driven scrutiny of financial risks, and the ever-present threat of disallowance. We believe opportunities may exist with relation to livestock traceability and simplification of inspection regimes while being mindful of the current measures taken by third party countries to comply with EU regulations: Before exiting the EU it is paramount that the Scottish Government press ahead with plans for ScotEID to develop the separate Scottish livestock identification and movements system and separate Scottish Ear Tag Allocation System (ETAS) and that these are accredited with the EU at the earliest possible stage. The UK’s livestock traceability systems are currently not accredited by the EU meaning that unless a Brexit trade deal accounts for this fact there could be an unexpected non-tariff barrier to our livestock exports. Scotland is in a unique position to finalise its own traceability system that once verified by the EU could then be used to, as with specified cutting plants in Brazil, provide Scottish exporters access to the EU market even if the UK system is not recognised. The inability to readily access the UK’s ETAS for monitoring purposes is frustrating and it is important that this important element of traceability – that can be better used to assess actual traceability risk of individual farms/crofts – comes under the control of the Scottish Government. With regard to simplification we would suggest that Brian Pack’s Doing Better review (including the interim report) is reconsidered to assess if opportunities to simplify or reinterpret EU rules exist. The review highlights the complexities of the inspection regime and how the “risk” matrices are derived for different types of inspection. Whilst we believe that a risk based approach to inspections is beneficial to compliant businesses it is perhaps time to re-review the “risk” weightings and metrics used as we come out of the EU - – Brian Pack in his Doing Better Review highlighted that these risk matrices are driven by EU audit and are generally associated with financial risk to support claims rather than risks based on welfare or to the food chain. Other aspects referred to by Brian Pack relate to more flexibility from the Scottish Government regarding interpretation of EU rules. Specific examples relate to (a) the persistent approach to unannounced inspections in Scotland (and the stress that it causes farmers/crofters), where anecdotal evidence from other administrations suggest their farmers are afforded some notice period; and, (b) interpretation of the EU’s tagging rules and what determines an inspection failure; (c) mapping and inspection tolerances for land based inspections. Whilst it may be tempting to try and reduce the number of inspections carried out annually post-Brexit, there will be a longer term requirement for Food Standards Scotland, Audit Scotland, APHA, COSLA in particular to work with the Scottish Government in delineating appropriate inspection protocols and inspection rates to ensure food safety, financial accountability and animal welfare respectively. It will be essential to ensure that compliance with EU rules regarding regulatory compliance are not undermined as this could have detrimental effects on agri-food exports to the EU in the long-run. Therefore we recommend the Scottish Government urgently assess the compliance and inspection regimes to which third party countries must adhere with in order to trade with the EU. We are unaware of any WTO requirement for on-farm inspection, rather it is the type of support mechanism that is included and an assessment of any national production increases beyond 5% that would be considered trade distorting.

5. Do you have any suggestions for straightforward changes that would improve the environmental outcomes achieved through greening payments in Pillar 1?

Do you have any suggestions for straightforward changes that would improve the environmental outcomes achieved through greening payments in Pillar 1?
As the CAP Greening Group has recognised “The green payment in particular, which accounts for 30% of the Pillar I budget, has had limited environmental impact as it has been delivered with little flexibility to take account of the different geographies and agriculture type with Scotland as well as focussing too much on strict compliance to rules rather than allowing those rules to be flexed sensibly to give a better outcome in environmental and farming terms.” Improving environmental outcomes through greening would require a major redesign and overhaul of the approach. Such redesign is already being considered for the post-2024 period. In the interim, the choice is between maintaining the greening approach and payments through to 2024, or seeking to modify and/or scrap them once the UK and Scotland has left the EU. The first choice would have the advantage of keeping the need for ‘greening’ uppermost in farmers’ minds throughout the transition period, though no major environmental outcomes would be expected by doing so. Provided there is no decline in the need to meet associated environmental standards, scrapping the greening approach at the first available opportunity might serve Scotland’s farmers better with little or no unintended impact on the environment. The part of the budget formerly associated with the greening payments could then become available for use either in encouraging the greater uptake of innovation on farms, which needs to happen during the transition period and/or enhance the uptake of agri-environment schemes where the potential benefit for the environment is much clearer than through greening.

6. Considering how funding is currently distributed across CAP schemes, do you have initial views about how the balance between these schemes should change in future to maximise outcomes?

Considering how funding is currently distributed across CAP schemes, do you have initial views about how the balance between these schemes should change in future to maximise outcomes?
We are encouraged that the Scottish Government seeks to utilise funds, where available, to tackle issues such as environmental performance, climate change, innovation and efficiency and new entrants – issues that are largely under the auspices of Pillar II of the CAP and the SRDP 2014-2020. How decisions made by other administrations regarding future direct support impact on Scotland is yet unclear, particularly in relation the common framework and the desire to ensure there is no competitive advantage with in the UK. We remind all parties that internal market issues already exist within the UK, under the current CAP, through differences in how BPS is allocated, the use of coupled and LFA support in Scotland and how our Rural Development Programmes have significantly different priorities and mechanisms. Many consider area based direct income support such as the BPS (and LFA support to an extent) a blunt and ineffective instrument that has failed to deliver a widely innovative, efficient and resilient sector. We believe this has been largely true and it is refreshing that the Agricultural Champions, the Scottish Government, and majority of industry stakeholders now acknowledge this. It is, however, worth pointing out that there are many highly innovative, efficient producers who are striving to be industry leaders - they are often be prevalent in the historically un-supported or less-supported intensive production sectors and lessons can be learned from their sectoral developments – particularly integrated supply chains. The signals from other UK administrations is that there will be a move away from (or in Northern Ireland’s consultation a reduction in) direct income support through the BPS ,and we suggest that in the long-term Scotland will also have to follow a similar process if it is to achieve its ambitions for sustainable agricultural and rural industries across Scotland. The overall aim of any future farm, food and rural policy should be to develop more resilient businesses that are better placed to improve resource use efficiency, boost productivity while enhancing Scotland’s environmental credentials (thereby contributing to Ambition 2030 National Food and Drink Industry strategy). However, there are risks in cutting direct support to agricultural producers too quickly if this puts the UK significantly out of step with other large producers particularly our nearest competitors in the EU. Any heavy unilateral reduction in direct support, if not matched by reductions by our competitors would be significantly detrimental to many of our sectors, making them uncompetitive with EU imports. Much will depend on how open the UK market becomes to EU and third country imports. Within the EU market beef and dairy imports from subsidised farmers in Ireland would be particularly damaging to UK producers if a free-trade area is agreed with the EU and the UK pursues a sharp reduction in direct support. However many other sectors could be affected. Additionally, most sectors would be potentially threatened from any future wide free trade agreements, that include agri-food products, with non-EU countries such as Canada the US, Australia and New Zealand – meaning that competing on quality, provenance, welfare and environmental credentials may be necessary. Whatever mechanisms the Scottish Government choose to assess to deliver longer term farm, food and rural policy mix delivery we stress that they should be assessed against standardised criteria, such as those we establish in Q1. In the long term we believe future support arrangements are likely to need to combine an element of continued direct income funding with encouragement for productivity improvements alongside targeted agri-environment schemes and support for upskilling/ diversifying. In particular we believe: 1. There will likely be a need to maintain a reduced base level of direct support (BPS / Greening) that can be justified on terms of cross compliance requirements that deliver public value, whilst acting as an income support tool that farms can use to mitigate volatile markets and adverse weather. A degree of coupled support may be required to maintain activity in remote or biophysically challenging areas or to retain critical mass in key sectors (e.g. beef). The Scottish Government should perhaps reconsider the CAP redistributive model (e.g. higher payment rates for the first 60 Ha) to provide smallholders with a slightly higher payment rate per hectare. As part of future justification for receiving these support payments the Scottish Government may wish to introduce application criteria in the long-run: • Farm Environment Plan, including a nutrient plan • Animal health plan • Availability of key data from above plans for government policy planning/monitoring 2. With a reduced direct support budget we believe that there will needs to be a greater emphasis on transformative and agri-environment climate support. Continued support for effective knowledge exchange is vital over the long term to drive and support longer term change within the sector: In particular: a) Medium-term structural adjustment could be facilitated by a gradual reduction in income support funding, together with explicit support for productivity improvements, structural change and knowledge exchange. i. This could include, for example, investment grants/loans designed with training assistance to improve technological adoption, resource use efficiency and productivity. ii. There are opportunities to support more innovative ways to release land and buildings to new entrants or expansionist farmers looking to benefit from economies of scale (Ireland successfully achieved this through tax incentives). Rather than maintaining farming systems for nostalgic / cultural reasons future support (or fiscal measures) should prioritise encouraging: • Innovative approaches to business entry (joint ventures / equity sharing / improved rental opportunities) in commercially oriented / market driven farming systems (e.g. poultry, horticulture, mushrooms, pigs) • Diversifying businesses looking to capitalise on wider rural development opportunities b) Support for delivering environmental and social outcomes will likely need grater prioritisation in the future in order to maintain justification of budget expenditure on the sector. In particular there could be continuation of many of the existing agri-environment climate and forestry schemes in the short run, with an introduction of some support for broad and shallow elements (paid from reduced direct support) to help producing farm environment and animal health plans that could be a condition of longer-term direct support (with key data available to the Scottish Government for monitoring). In the longer term there is will be opportunities to introduce regionalised Payments for Results schemes and top-tier highly targeted Payments for Results schemes for priority species / habitats. c) There should be support for Continued Professional Development in the sector and some recognition of skills should enter any future inspection “risk” assessment.

7. Do you agree that changes to capping are a useful measure to enhance the positive social and environmental impact of agricultural policy?

Do you agree that changes to capping are a useful measure to enhance the positive social and environmental impact of agricultural policy?
Reducing the maximum amount of BPS any recipient can receive from the existing €600,000 appears to be worthwhile if budgetary savings have to be made to deliver trials or introduce new environmental or productivity support tools. However, it remains a challenge to fully endorse such an approach at this stage due to the lack of evidence to make a robust assessment, particularly around the levels of capping and the size of budget that the Scottish Government would like to generate from such an exercise. Given the assessment of the impact of Greening it is perhaps worthwhile post-Brexit to combine BPS and Greening payments for the purpose of capping analysis going forward. We recommend that the Scottish Government provide further details on the aggregated make-up of the businesses that would be affected by the different proposed capping levels put forward by the Agricultural Champions and the Scottish Government in this consultation. Equally, there should be some clarity of the schemes that this capping fund would support (e.g. how many new entrants may it support) to allow a full assessment of the potential net benefits derived from different capping levels. We suggest this approach to minimise unintended consequences of such actions – for example: • If the large BPS recipients under threat of the proposed capping measures are already highly efficient, productive businesses, major employers, or an integral part of the supply chain (e.g. a major cattle finisher) then capping may simply lead to economic displacement, or reduced net social (employment / economic multiplier) effects – particularly if the business has expanded and is operating on tight margins. In such a case there may be a desire by recipients to restructure their business as has been witnessed in previous CAP reforms to maximise support payments. • If the recipient is operating at minimal activity levels they may be providing limited socio-economic benefits, but may be indirectly be delivering environmental outcomes and there would unlikely be any business level changes with regard to economic activity as a result of capping. As the Agricultural Champions and the Consultation document suggest we agree that the net benefits of such capping proposals should be fully assessed. This should include an assessment of what the businesses are contributing in terms of employment, jobs, environment for their existing level of public support and what benefits the capping resource may bring. We also suggest that an assessment is made of the potential for avoidance behaviour by restructuring of businesses and ownership structures and any unintended consequences that may arise. If the scope for avoidance is large this would reduce the benefits to be gained from capping.

8. Do you have any specific views on how capping should work including what a maximum cap should be?

Do you have any specific views on how capping should work including what a maximum cap should be?
As indicated in Q7 it is challenging to comment on this without some further analysis. An alternative approach could be investigated using progressive (increasing) degressivity on BPS and Greening payments over a specified amount up to a newly defined cap. We illustrate this by the following example though it should be noted that the percentages applied do not constitute our proposal and such an approach would require rigorous modelling in order to arrive at an appropriate set of thresholds, for example. BPS & Greening £75K £100k £150k £200K £250K £300K £350 Degressivity level 5% 15% 25% 40% 55% 70% 100% In this arbitrary example the payment between £75k and £100k receives a 5% deduction, between £100k and £150k a 15% reduction, etc. The net effect would generate different results to overall capping and it may be worthwhile to investigate the amount of BPS and Greening that the SG could retain to fund under such a progressive degressivity model: BPS & Greening Payment Progressive Degressivity Recovered Payment Received £100,000 £1,250 £98,750 £150,000 £8,750 £141,250 £200,000 £21,250 £178,750 £250,000 £41,250 £208,750 £300,000 £68,750 £231,250 £350,000 £103,750 £246,250 £400,000 £153,750 £246,250

9. Should there be a maximum cap on the total funding a business receives from all schemes, or a scheme-by-scheme approach?

How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?
We firmly believe that there should not be an overall cap per business if they are delivering outcomes (woodlands, ecosystem services, diversified activities) as agreed with the Scottish Government. Such a cap may limit the Scottish Government’s ability to achieve agreed targets (e.g. peatland restoration, new woodland plantings, etc.). Whilst it may sit uncomfortably with some that larger businesses may continue to receive large sums of public support, it can be the most efficient way to deliver public outcomes. Land reform has gradually been changing the ownership profile of parts of rural Scotland (most notably the Western Isles) and it could be of detriment to these, sometimes largescale community owners (and therefore society) to impose a cap on their payments. There may be opportunities for the Scottish Government to introduce / revise schemes that encourage or actively support smaller farms and crofters to enter (e.g. enhanced payment rates for smaller businesses / fast track application process) that could help prioritise support expenditure on smaller businesses that can deliver positive outcomes (particularly if applying collectively).

10. How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?

How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?
Currently the SRDP 2014-202 state that the key purpose of LFASS is to: “Compensate farmers [and crofters] for income forgone and additional costs linked to the disadvantage of the constrained area. It is essential that the viability of these farms is maintained, to reduce the risk of land abandonment and maintain sustainable farming businesses in constrained areas. This then provides the basis for the delivery of secondary objectives – stability to allow farms to improve their economic performance and the delivery of environmental benefits, along with supporting rural communities.” It is certainly the case that support for activity in Scotland’s disadvantaged areas is absolutely vital if the Scottish Government wish to maintain agricultural activity in these areas and the associated social, economic and environmental outcomes that the support delivers. LFASS is often described as a “lifeline” payment, and it genuinely helps to maintain agricultural activity in hill and remote farms and crofts in Scotland’s fragile and very fragile areas – and to a lesser extent in marginal areas (lowland/upland) with greater production flexibility that means LFASS is a much smaller proposition of their overall income. It is indeed unlikely that farm and croft businesses in the most remote and biophysically disadvantaged areas could return profits without their LFASS support, and indeed for some businesses LFASS is equally important as BPS and Greening support. . We would suggest that LFASS is indeed helping support rural communities through population retention and economic activity. However, we are less certain if the secondary objective regarding environmental benefits are being delivered In their evaluation of LFASS / Development of Areas facing Natural Constraint Grieve, et al (2015) highlighted that the current LFASS incarnation “has perhaps endured far longer than could have been anticipated at the time of its creation.” This is due to the delays in the EU Commission undertaking the move to the requirement for a new delimitation of disadvantage (Areas facing Natural Constraint – ANC) due to the significant upheaval that the CAP 2014 reforms delivered across the EU, but also in devising an area-based scheme that was acceptable top stakeholders. Indeed during consideration of introducing an ANC in Scotland there was much debate on aspects of such a scheme – how to measure disadvantage; whether to include peripherality (increased transport costs); how the environment should be factored into support; whether historic stocking densities should be used; should payments be tiered toward greater disadvantage, where boundaries on maps be drawn, how WTO compliant evidence of income-forgone and additional cost elements can be derived, etc. It is likely the case that the current LFASS is outdated - we are still using LFA mapped areas from the 1970s and the move from the Hill and Livestock Compensatory Allowance system to LFASS was largely an exercise in minimising payment redistribution (maximising “winners” and minimising “losers”) rather than delivering specified outcomes for the scheme. Moreover, the LFASS grazing Category A is now embedded in the BPS and Greening direct payments in Scotland – having been used to delimit extensive grazing areas that receive the lowest level of support and acts as an eligibility criteria for the Scottish Upland Sheep Support Scheme. This means that there may be opportunity to evaluate if the BPS/Greening payments and LFASS payments could somehow be merged (with a review of relative payment rates) – with enhanced payments for achieving environmental outcomes that may be determined by livestock grazing mixes. We believe that in the medium term it is essential that the Scottish Government fully review how to provide a support package to our disadvantaged areas fit for a post-Brexit period that is not constrained by EU articles (or their interpretation of the WTO’s Agreement on Agriculture). This review needs to consider all possible support options in delimited areas, ranging from enhanced direct support payments, to uplift options for coupled support options such as the island uplift in the current Scottish Suckler Beef Support Scheme, through to a bespoke hill and uplands support scheme or specific support for High Natura Value farming. The review also needs to consider what the objectives of a future scheme are. For example: • If the principle objectives are agri-environmental then the scheme will be constrained by WTO rules on additional costs and income foregone. • If the principal objectives are income support to avoid land abandonment then support should be declared as such (similar to BPS) and it would be considered “green box” alongside BPS and Greening support provided it is paid on a per hectare basis. We would strongly urge the Scottish Government to consider how to factor in additional costs associated with farming and crofting in remote areas as part of any future support scheme. The rationale for this is supported by the evidence we were commissioned to provide the Scottish Government on the haulage costs faced by these remote businesses (e.g. £36 per tonne of fertiliser to Outer Islands, £28 per tonne to inner islands and £18 per tonne to remote mainland areas in 2016). Additionally, there may be scope for a future scheme to link payments to the uptake of new technologies and innovative practices which can serve to improve cost-effectiveness at the farm and croft level thereby improving business resilience. The Scottish Government rightly stress that there is an EU requirement to restrict the 2020 LFASS payments to 20% of the current value (parachute payments for LFA support falling out-with an ANC scheme), and this is of considerable concern to farmers and crofters in receipt of LFASS payments. We think that there may be an opportunity for the 2020 LFASS claim year to adjust the BPS and Greening payment rates (remembering 2019 is the last EU administered BPS claim year) for businesses in the LFA region as a means of mitigation. We think this should be seen as an emergency action and not a long term remedy for supporting disadvantaged areas without undertaking a full and thorough review of aims, objectives and support mechanisms for these areas.

11. Would you see value in directing future LFA support through other existing Direct Payment Schemes?

Would you see value in directing future LFA support through other existing Direct Payment Schemes?
As we indicated in Q10, SRUC is not adverse to such an approach providing it is fully assessed and additional support levels for disadvantaged areas remain thereby protecting against agricultural land abandonment and helping maintain marginally profitable enterprise that face peripherality or biophysical constraints. Assessing opportunities to streamline the number of support schemes should be encouraged – providing the underlying objectives of the schemes can be delivered. In Q10 we highlight how LFASS grazing Category A is now embedded in the BPS and Greening direct payments in Scotland – having been used to delimit extensive grazing areas that receive the lowest level of support (and acts as an eligibility criteria for the Scottish Upland Sheep Support Scheme). There may indeed be opportunity to evaluate if the BPS/Greening payments and LFASS payments could somehow be merged (with a review of relative payment rates) – with enhanced payments for achieving environmental outcomes that may be determined by livestock grazing mixes. We believe that in the medium term it is essential that the Scottish Government fully review how to provide a support package to our disadvantaged areas fit for a post-Brexit period that is not constrained by EU articles (or their interpretation of the WTO’s Agreement on Agriculture). This review needs to consider all possible support options in delimited areas, ranging from enhanced direct support payments, to uplift options for coupled support options - such as the island uplift in the current Scottish Suckler Beef Support Scheme, through to a bespoke hill and uplands support scheme or specific support for High Natura Value farming. However, we may caution that it may be challenging to factor in desirable new elements to any future support for disadvantaged areas post-Brexit, once the scheme constraint placed by EU articles are removed. For example SRUC strongly urge the Scottish Government to consider how to factor in additional costs associated with farming and crofting in remote areas as part of any future support scheme and investigate scope for a future scheme to link payments to the uptake of new technologies and innovative practices. We acknowledge that these additions may be challenging to factor into a combined scheme.

12. Do you think there are administrative and operational simplifications that would benefit current or future LFASS claimants?

Do you think there are administrative and operational simplifications that would benefit current or future LFASS claimants?
In response to Q10 and Q11 we suggest that the current LFASS is outdated and needs reviewed to deliver a truly supportive scheme based on peripherality and disadvantage needs. That is why we have suggested that in the medium term it is essential that the Scottish Government fully review how to provide a support package to our disadvantaged areas fit for a post-Brexit period that is not constrained by EU articles (or their interpretation of the WTO’s Agreement on Agriculture). As part of that review we believe that there should be scope to streamline the administration and simplify the complexity of the scheme. In the spirit of simplification it would be worth considering the retention of a minimum payment for any future LFASS-type schemes. During the review process there should be a full consideration given to the appropriate level of minimum payment to support active small units that recognises the lack of economies of scale in keeping stock on smallholdings.

13. Would you support a simplified approach to scheme use of map information or to the land mapping system and, if so, do you have views on where the main opportunities for doing so would lie?

Would you support a simplified approach to scheme use of map information or to the land mapping system and, if so, do you have views on where the main opportunities for doing so would lie?
Mapping is a major challenge and leads to significant administrative expenditure by both the Scottish Government and the industry. Currently it appears that there has been a move away from field to desk based inspections, presumably driven by risk and cost/benefit assumptions, and whilst the administrative efficiencies generated by an approach are welcome from a taxpayer’s perspective, we urge some consideration of the on-ground impacts. We support the retention of the basic mapping system but with a simplified approach to the use of the information. Currently many of the challenges relate to the process by which producers are notified of changes to their map, and that by which they can dispute these findings. • An example is where a new map is sent to a producer based on changes made following a Scottish Government review of aerial photography (for instance a boundary is either removed or added in error). The producer then needs to complete a Land Maintenance Form (which appears complex to complete) requesting that the error is removed. In accordance with recommendation 45 of Brian Pack’s Doing Better review the Scottish Government now (in agreement with the EU) utilise a reduction co-efficient for BPS rough grazing areas that provides a degree of tolerance between declared and eligible area. For example, producers were allocated only 80% of the Region 2 areas they claimed in 2015, giving a slightly larger payment rate instead. This means that for most producers there is little chance of over-claiming Region 2 land which permits reasonable leeway between claimed and eligible areas. We suggest that this approach could be adopted more widely such that a safety margin (perhaps 5%) is automatically factored into the declared area for Region 1 land for each producer. We believe that such an approach poses minimum risks to the taxpayer and could support a less intensive administrative approach to mapping reviews – in particular reducing the frequency by which each holding is reviewed and remapped leading to greater administrative efficiencies. It is worth noting that under the old CAP system “extensification” support had two possible stocking rate applications, i.e. “simplified” or “standard” for the farmer/crofter to declare. Under “simplified” the producer declared that they would stay under a set stocking rate every single day of the year, whereas under “standard” this would be the average for the whole year. This meant that inspections under “simplified” could be automated using BCMS data and the declared area (from SAF/IACS) and only a minimal amount of field inspections were required for verification purposes. • It is perhaps worth investigating whether a similar “simplified” or “standard” system could be introduced for SAF declared land area. Under a simplified scheme the producer would declare 80% of the area, get a marginally enhanced per-hectare rate on this area with them having to guarantee that they had this reduced area as a minimum on the farm. “Simplified” claimants could then attract significantly less inspection pressure, whilst “standard” applicants that declare every single hectare would attract a higher inspection rate due to higher “risk” of over declaration or ineligible features. This means that where there is genuinely less need for inspection businesses could have potentially less inspection pressure, and financial implications of penalties would be more proportionate. For "standard business" the existing system would still largely exist with a “risk” based inspection protocol. • We suggest that there also could be more emphasis put on the greening and other features for environmental benefit, such that the focus was about getting these right and less about the whole field situation. Both options would deliver resource savings for Government and potentially ease the burden especially for those farmers who opt for a simplified approach. We note that there is the same level of inspection pressure on extensive livestock farms and crofts on the remote Islands as there is in the most productive areas of Angus, where the “risks” between the two for inconsistency being totally different - as would any financial penalty implications resulting from inspection failure. We note that Brian Pack’s Doing Better Interim Report also highlighted this point that means potentially “higher risk” businesses were not inspected due to their location: “We noted that whilst the “risk” factors appeared, appropriate that the risk matrix was run at SGRPID regional office level rather than, for Scotland as a whole. This means that there is potential for lower risk businesses, being selected for inspection whilst businesses with higher risks are not selected by, virtue of geography due to the inspections having to fit SGRPID‟s rigid regional structure (e.g. if there was a region with generally higher “risk” businesses there would undoubtedly be under representation of these businesses in the “risk” selected businesses than if the selection process was run once for the whole of Scotland).” This recommendation was withdrawn in Brian Pack’s Final Report: “We note that in our discussions with Defra we were informed that the Rural Payments Agency have largely withdrawn from regionalised risk selections – a process that has required some difficult staffing logistics. The feedback that we received from SGRPID was that whilst they acknowledged the argument we put forward in the Interim Report there was an advantage to working at regional levels in Scotland. Firstly they explained the approach meant they had the ability to reduce or increase regional inspection levels as required (although it was not confirmed that this ever occurred). Secondly, and perhaps a more compelling argument for maintaining the status quo, was that if inspections were to be done nationally then due to the risk factors and weightings under the new CAP nearly all “Greening” inspections would have to be undertaken in the east coast arable regions, meaning there would be limited testing of compliance in other regions.” Whilst we acknowledge SGRPID’s rationale to Brian Pack for land based inspections due to “Greening” risks we believe that there should be a review of the regional approach to livestock inspections based on actual risk, with a minimum inspection level in SGRPID offices where risk is perhaps lower (if this is not already occurring). This review should be conducted alongside the “risk” factors as suggested in Q4.

14. Do you support the use of regional pilots to help tailor schemes to local circumstances?

Do you support the use of regional pilots to help tailor schemes to local circumstances?
We cannot find any reference within the Agricultural Champions recommendations that there should be regional pilots to help tailor inspections to local areas. However, SRUC support the regionalisation of support schemes particularly with regard to biodiversity and catchment level programmes on water quality, etc. All the pay by results approaches being trialled to date have primarily put a focus on a regional level and addressing targets and farmers at that scale. It seems clear that that approach actually works and hence in any pilot in Scotland there might not need to be a trial to see if regionalisation can be achieved – rather what ‘results’ should be prioritised. Within any such trial there will be a requirement to consider how to not only utilise farmers themselves in helping monitor and evaluate outcomes but also how inspections can assesses scheme progress and compliance with scheme rules. We suggest that this may need to be done by scheme specialists with onsite knowledge, rather than by general Scottish Government inspector specialist and conditions.

15. Do you have views on how the inspections regime could be made more efficient while retaining existing public benefits?

Do you have views on how the inspections regime could be made more efficient while retaining existing public benefits?
The Agriculture Champions correctly identified the rational for audit inspection, something that will remain post-Brexit with the role of EU auditors more than likely being undertaken by the National Audit office and Audit Scotland: “Where public money is being spent there will always be a need for audit and inspections.” However, removal of EU rules regarding inspection frequency, selection and focus post-Brexit means there is an opportunity to create a more efficient and sympathetic regulatory system that: (a) ensures the value for money from the public purse; (b) ensures scheme outcomes and rules are adhered to; (c) has penalties commensurate with the risks to human health, animal health and welfare or the environment from a breach, (d) provides a minimum notification period for inspection and; (e) provides a window of opportunity for rectification of minor breaches. One of the challenges identified in Brian Pack’s Doing Better Review was the timing of different inspections regimes – driven by EU timelines and the farming calendar. We acknowledge that there have been considerable improvements from the integrated inspection approach (joint visits, cross departmental inspections, reduced data burdens on claimants, etc.) and the co-location of services, initiated by SEARS in 2007. Whilst this has reduced the overall number of inspections of land managers, we still do not know how it has affected the overall regulatory burden on land managers (i.e. how has the total and average number of hours per inspection changed over time?). As we withdraw from EU governance of schemes it may be worthwhile reviewing application and inspection windows to assess if there are any efficiencies that could be gained. Additionally, Brian Pack’s Final Recommendation’s 24 and 46 relate to opportunities to minimise the administrative burden, and farmer stress and penalties associated with rectifiable minor breaches that may be avoided if farmers were afforded a limited period of prior notification of inspection (e.g. such as businesses are afforded by HMRC for CAT inspection purposes). We recommend that the Scottish Government revisit these recommendations as we withdraw from the EU as the rationale for rejecting these recommendations was on the basis of EU rules. The Scottish Government, in their response to Pack’s recommendations, agreed to try and engender a more flexible EU approach to these rules and since we are now withdrawing from EU influence there is an opportunity to revisit these (and other opportunities and recommendations where the Scottish Government identified EU barriers to adopting recommendations in part, or in full). There should be an ongoing review of how greater use of new technology, such as drones, can reduce physical inspection burdens and create staff efficiencies (whilst also capturing data). As highlighted in Q4 this, however, should not be at the expense of physical inspection and clarity should be sought from the recipient in any instances that such technology identifies apparent errors.

16. Do you have views on how the penalty regime – particularly around fairness, transparency, the maintenance of standards and compliance burden – could be improved in the short-term?

Do you have views on how the penalty regime – particularly around fairness, transparency, the maintenance of standards and compliance burden – could be improved in the short-term?
SRUC would welcome a future consultation on inspections and penalty regimes. It is important, as we come out of the EU, that a full review of the penalty regime is undertaken to make sure Brian Pack’s Doing Better recommendations about ensuring penalties are proportionate to errors are addressed when we no longer have EU oversight. In particular we may be able to reconsider the 1%, 3%,5% and 9% penalty defaults used by the EU Commission that may not appear to fit the risks associated with some of the errors (particularly as there is relatively low second offences within the 2017 cross compliance statistics for SMR7 and SMR8). • We believe that more consideration should be given to the scale of the breach and individual situations. o For example, although in GAEC 7 the severity of a breach is dependent on the actual physical length of the feature, proportionally that could be very small or large compared to the total length of the feature on the farm. This could therefore result in a disproportionate penalty. • We also believe that there should be a more common-sense approach, particularly for unintentional errors. o For example, under NVZ regulations where there has been an application of slurry over a prescribed limit (regardless how large or small the additional application is) it gives rise to an automatic minimum 3% penalty against all BPS, LFASS, AECS etc. This can run into many thousands of pounds for some businesses. We appreciate in doing this it may increase complexity for inspectors but would be fairer for farmers, as some penalties do not appear to match the extent of the breach. Although verifiable standards, inspection selection and penalty matrices are made available on the Rural Payments and Services website, they are complicated documents and unlikely to be read by farmers. In 2017, detailed inspection findings were published for the previous year which included details of the breach, intent, severity and the penalty applied, which has potentially helped to increase awareness and transparency. However, we would question how widely this information has been dispersed. More should be done to raise awareness of why breaches occur and the reason for the penalty rate applied in a clear and simple format. We believe that there may be greater opportunity for inspectors to play a greater educational and advisory role where breaches are identified that are perhaps an oversight (e.g. for missing tags on a small number of livestock, or delays in updating records due to valid excuses, etc.) that are easily rectifiable. The approaches adopted by SEPA and Local Authorities in their respective regulatory duties, where advice is an integral part of the inspection process, merits closer examination. This could perhaps be achieved in conjunction with the Farm Advisory Service. With regard to fairness, we recommend that (as expressed in Q15) that the Scottish Government re-assess the rationale for continuing with the EU default position of unannounced inspections as we withdraw from the EU. It would be more equitable to provide a minimum period of notification, especially as farmers and crofters are unable to rectify anything more than minor/ negligent breaches in any prior-notification period afforded. In Brain Pack’s Doing Better Interim Review it was highlighted that in Ireland the Department of Agriculture Food and Marine had developed a Farmer’s Charter of Rights in agreement with the farming organisations that aims to enhance the delivery of services and schemes to clients of the Department [https://www.agriculture.gov.ie/media/migration/customerservice/farmerscharter2015-2020/FarmersCharterFINALTEXT160715.pdf]. In the name of equity, transparency and shared understanding , we also recommend that SGRPID considers developing such a Charter in Scotland, being mindful that post-Brexit there will be greater flexibility and scope for SGRPID to work with the industry to reduce the regulatory burden, minimise disruption and manage expectations of the farming sector.

17. Are there specific issues you think the SimplificationTask Force should prioritise for review?

Are there specific issues you think the SimplificationTask Force should prioritise for review?
SRUC endorse the Scottish Government’s intentions to establish Simplification Taskforce to consider improvements to the regulatory regime and to SGRPID customer experiences. We would like to offer our support to and assistance to the Task Force where possible. As we have mentioned in numerous answers to this consultation we believe that there a number of things that the Task Force should prioritise. Firstly, this is not a new topic and there have been considerable efforts in trying to simplify the regulatory burden on farmers in Scotland (Griggs in 2011 and Pack in 2014) and each of the other UK administrations, and indeed within the European Commission. We specifically recommend that the Task Force reviews the recent work by Defra (Farm Inspection and Regulation Review https://www.gov.uk/government/publications/farm-inspection-and-regulation-review). There is considerable latent knowledge from people engaged in these review processes, from the SGRPID staff and from farmers and agents on the ground at the sharp end of regulation. There is considerable insight into the regulatory systems, the problems arising from it and opportunities for simplification and the main initial task of the Task Force should be to collate and synthesis this knowledge. We specifically recommend that Simplification Task Force review the interim and final reports produced, alongside the evidence collected (including online ideas board) during Brian Pack’s Doing Better Initiative to Reduce Red Tape for Farmers and Rural Land Managers. This may provide a fast-track to understanding the regulatory framework and help identify areas for simplification of the administration and regulation of (a) agricultural support schemes, and (b) statutory requirements (e.g. animal welfare). This review should include the Scottish Governments actions in response to Pack’s recommendations and any subsequent developments of the RAFE board, etc. Particular emphasis should be placed on identifying opportunities to implement recommendations that were not fully developed due to EU rules or interpretation of Articles. We have already identified specific areas of regulation that need review with the potential for simplification the post Brexit goal. For example topics we have already referred to include: • Proportionality of penalties to risks associated with breaches (Q3, Q13 and Q16) • Regional inspection rates for schemes (Q13) • Risk matrices to identify businesses for inspection selection (Q4), • Mapping tolerance (Q13) • Remote sensing and protocols of its use for identifying breaches (Q3); • Opportunities to assess where EU rules generate disproportionate burdens on land managers without fear of EU Audit and national disallowance (Q4) In addition in Q16 we highlighted that in Brain Pack’s Doing Better Interim Review the Irish Farmer’s Charter of Rights was considered a useful approach to generating mutual understanding and trust of the regulatory regime between farmers and SGRPID. [https://www.agriculture.gov.ie/media/migration/customerservice/farmerscharter2015-2020/FarmersCharterFINALTEXT160715.pdf]. We believe the Simplification Task Force should review, with industry stakeholder the merit of such a Charter in Scotland, being mindful that post-Brexit there will be greater flexibility and scope for SGRPID to work the industry to reduce the regulatory burden, minimise disruption and develop greater trust between regulators and the farming sector. The final aspect that we believe needs to be prioritised is establishing the underlying factors behind the continued high failure rate in cattle and sheep identification inspections. It would appear that little progress has been made to addressing high failure rates across the industry since Brian Pack (2014) recommended (R56) that “a new initiative, with support from across the industry, is launched to identify best practice in complying with cattle identification regulations. The role of BCMS in cattle inspections needs to be understood by farmers, in particular, the need for farm records to agree with the BCMS database. There may be a role for Farm Assurance staff in developing this understanding.” There were positive responses by stakeholders and the Scottish Government at the time yet we are still faced with extremely high failure rates that has meant that the Scottish Government has had to increase the proportion of livestock businesses inspected annually. This appears to be a stubbornly persistent industry-wide failing, with perhaps a degree of cynical expectation by many farmers and crofters who routinely presume that any livestock inspection will lead to some element of failure. This must be seen as a failing of the system, the inspection process, or industry compliance (or likely a combination of these) and must be acted upon as an absolute priority of the Task Force [https://www.ruralpayments.org/publicsite/futures/topics/inspections/all-inspections/cross-compliance/inspection-outcomes/cross-compliance-inspection-statistics/].

18. Do you agree with the proposals to set a timescale of up to five years for transition? Please provide comments.

Do you agree with the proposals to set a timescale of up to five years for transition? Please provide comments.
As explained in Q1, the timescale proposed in this consultation is sensible assuming that the UK reaches agreement to leave the EU in an orderly manner after March 2019. However, should the UK leave the EU without a trade deal, any transition period would, by necessity, be shorter. Regardless of whether or not a trade deal is struck, we urge the Scottish Government to be proactive in thoroughly preparing for all eventualities. Waiting to see what is handed down by Brussels and London would be deeply unwise.

19. If new schemes seek to encourage collaboration, enhance skills development, help with capacity building, facilitate wider integration into the supply chain, promote carbon audits and monitoring of the soil health, how might pilot projects be best designed to help test and develop new approaches?

If new schemes seek to encourage collaboration, enhance skills development, help with capacity building, facilitate wider integration into the supply chain, promote carbon audits and monitoring of the soil health, how might pilot projects be best designed to help test and develop new approaches?
Pilots could be organised around "producer groups" - small groups of farmers working together to supply a specific product and market. Small groups of people who know and trust each other get things done, and a bottom-up approach to farmer led innovations should be encouraged in any pilot, such as the approach taken by the Rural Innovation Support Service (RISS) being led by the Soil Association. Groups are likely to be centred around supplying food such as beef, lamb, vegetables etc. but equally the product could be environmental services (catchment level pollution control, biodiversity), farm based tourism, renewable energy etc. Working more closely with processors, retailers and technology providers would help provide focus to integrate improvements. Training, competence certification and demonstrations by high technology providers and others could bring about significant improvements. Funding should be structured to encourage; greater collaboration; development of skills and adoption of new practices and technology. The potential to lever private investment in joint funding should be considered and projects demonstrating private leverage should maybe be prioritised to assess how local public/private funding initiatives can best work going forward.

20. Many of the measures described in this consultation will have co-benefits for both agricultural productivity and for reducing Scotland's Greenhouse Gas Emissions. Are there other practical and feasible measures that would have similar co-benefits that you feel should be considered?

Many of the measures described in this consultation will have co-benefits for both agricultural productivity and for reducing Scotland's Greenhouse Gas Emissions. Are there other practical and feasible measures that would have similar co-benefits that you feel should be considered?
Technologies will continue to develop particularly in relation to precision agriculture, low carbon, healthy soil farming methods. Therefore, having continued support for initiatives such as Farming for a Better Climate [https://www.farmingforabetterclimate.org], the Farm Advisory Service’s Soil and Nutrient Network farms [https://www.fas.scot/soil-nutrient/], Agri-tech initiatives (such as Agri-EPI satellite farm network [https://www.agri-epicentre.com/facilities/satellite-farms/], etc. can ensure that emerging practices, technologies and measure are promoted and practically demonstrated to networks of farmers. Suggestions of where co-benefits exist may include: • There may be benefit in introducing small capital grants or interest free loans to support farmers in adopting simple greenhouse gas reduction measures, for example for equipment that uses less fuel or electricity such as electric quad bikes, plate coolers, variable speed pumps and precision farming equipment. Small changes made to daily practices will lead to cumulative savings, both in terms of reducing farm fuel bills and reducing energy use. • Continued focus on better nutrient use; this could be in terms of slurry storage facilities, application equipment or nutrient budgeting. Again capital support may be useful to incentivise upgrading storage and/or application equipment to make best use of slurry and minimise losses. • Support could also be provided for capital and operational expenditure to reduce non-CO2 greenhouse gas emissions; acidifying slurry and adding nitrification inhibitors to slurry and fertiliser to reduce nitrous oxide emissions. Provision of covers for slurry stores would also reduce methane and nitrous oxide emissions and reduce the volume of slurry to be spread, saving further fuel and carbon emissions that way. • Support for farm soils. Routine soil testing is part of good agricultural practice, however land managers also need to be encouraged to take a look at wider soil health to maximise soil resilience in a changing climate. • Beef support payments could be tied to age at slaughter such that animals slaughtered younger attracted higher support payments. This may a) increase profitability per animal, and b) reduce methane emissions per unit product. Whilst, the majority of prime-beef could be covered by this process consideration would have to be given to those farming rare or slow growing breeds. • Post-Brexit there could be scope for incentivising behaviours such as; recording health events accurately (as part of good health planning practice anyway), ensuring staff are trained on how to recognise health/disease and how best to respond and ensuring a definitive diagnosis is reached and recorded when disease outbreaks occur. We believe there would be a very strong case to do this, and that it has the potential to deliver substantial animal health and welfare public good, including GHG emission reductions, in Scotland. • For the pig sector we think that incentives directed towards proactive disease elimination programmes would be of public benefits (including around GHG emissions) and support farmers who are unable to commit to the up-front costs of undertaking bold and innovative programmes on account of short-term cash-flow implications. Commercial experience has shown substantial benefits to pig health and welfare, and a sea-change in farming efficiency and economic success arising from such programmes on larger units farmed by industry leaders. Such initiatives would provide valuable community support and public good, particularly to the middle and lower tiers of the industry.

21. Do you agree to expanding the number and role of Monitor Farms or similar during the transition period? Do you have any ideas as to how Monitor Farms could be refined or adapted to better meet future needs?

Do you agree to expanding the number and role of Monitor Farms or similar during the transition period? Do you have any ideas as to how Monitor Farms could be refined or adapted to better meet future needs?
Yes, SRUC believe that there is a strong argument for Monitor Farms (MF’s) to be expanded as we approach a period of uncertainty, where the only certainty is that things will change. The MF concept has worked across different countries, because it addresses the main issues affecting farmers in each area in a practical way. Gaining in depth access to the performance of one farm, and pooling the resources of a Community Group to influence decisions and changes to policy is a winning formula that has seen large turnouts over a period of three years on most projects. We also acknowledge that there is an important role for the new Agri-EPI satellite farm network [https://www.agri-epicentre.com/facilities/satellite-farms/], Climate Change Focus Farms [https://www.farmingforabetterclimate.org/climate_change_focus_farms/] and the Soil and Nutrient Network farms [https://www.sruc.ac.uk/info/120605/soil_and_nutrients/1355/soil_and_nutrient_network/1] as demonstration networks to showcase and demonstrate innovations in precision agriculture, resource use efficiency and soil and nutrient management respectively. There remains an appetite for the traditional three year Monitor Farm where the group has an opportunity to see and evaluate the results of changes, which can take several years to come to fruition. The MF also acts as an opportunity to highlight the benefits of initiatives such as ILMP, carbon and resource efficiency audits, environmental audits and more on one commercial farm to a wide audience. Scotland’s Monitor Farm hub is a useful resource containing meeting and themed reports and adds to the mix of information available to Scottish farmers. A big shock to the system such at significantly reduced support payments or a collapse in produce prices will see farmers either give up or seek new solutions. Monitor Farms can be a major part of the solution given their local presence and potential for mass participation. • There is a strong argument to retain the standard Monitor Farm model of choosing a representative farm for a three year period in areas that have not previously had MF’s. • There is also an argument for a variant of the concept to be used to allow farmers to study specific aspects of enterprises on a smaller scale. For example a group could be set up to work out how best to boost suckler herd fertility and another look at soil improvement strategies, given the unique conditions of their area. This could be introduced as a series of smaller scale, lower cost groups set up across the country. • Alternatively a Monitor Farm project could be set up in an area, but instead of choosing one representative farm, multiple farms could be chosen to look at different aspects of production, and/or management of natural capital with annual visits to each to decide a course of action and review progress, and discuss the impact of the change. The network of Monitor Farms might work best with a mix of a number of traditional single farm, 3 year Monitor Farm projects, and, a number of focussed satellite MF projects, with knowledge being exchanged within the Programme network. This would address a current weakness whereby a chosen Monitor Farm might be open to changing some but not all aspects of their business. Satellite MF projects could form a useful legacy project for previous Monitor Farm groups. Legacy of Monitor Farm groups is an aspect that needs to be addressed. A lot of good work and momentum can be lost if activity ceases when the project ends. The Satellite Monitor Farm suggestion would address this, but there also needs to be more encouragement for the farmers involved to take the initiative and start up another project, through another funding avenue such as RISS (Rural Innovation Support Service). From a facilitator’s point of view, there may be a need to make Monitor Farms a bit simpler and less complex to manage, with as much consultant and specialist time being spent in front of farmers and crofters as possible. The current Monitor Farm model includes a core benchmarking group, who record physical and financial performance in detail, and meet regularly to discuss their figures and trends. The introduction of benchmarking groups was well intentioned, with the aim of farmers gaining a better understanding of the whole farm situation, but some facilitators have reported difficulty in obtaining the level of detail required from farm records and accounts and farmers have been less keen to participate when they saw the level of detail required. It may be easier to work with simpler, but meaningful, benchmarks that more farmers can engage with. QMS and AHDB manage the Scotland’s Monitor Farm Programme and it is overseen by the Monitor Farm Development Group of which SRUC staff are members. The MF Development Group, despite the name, also covers a range of Scottish KTIF funded initiatives including the NE Farm Profit Programme, Potato SPOT farms, KTIF projects, SNH initiatives, but there remains a lack of overall ownership and control by Scottish Government. Other initiatives like Climate Change Focus Farms are if not omitted rarely included in the conversation. Is the fact that these initiatives all have different websites a disadvantage, or could Scottish Government seek a way to bring all initiatives and links to individual websites together in one place to make them more easily accessible to farmers, and crofters? Likewise links to Agritech projects in Scotland could be added in. It is definitely not a job for ScotGov staff but it could be included within existing signposting web sites of which the Scottish Rural Network web site should be considered as a suitable candidate. There has also long been a need for a more co-ordinated events diary. SFAS has gone some way to helping with this. And people running initiatives need to be more aware of what others are doing and be open to bringing more ideas into their projects. In the ideal world the farmers would be reading things online and suggesting that these new ideas be incorporated into their project be this MF or whatever. RISS is a good example of a more open all inclusive approach being actively led by a Management Group with strong SG involvement (Alastair Prior) and a potential follow up to RISS, could be that the site is used to showcase future innovation projects when they attract funding. SRUC’s answer goes wider than just Monitor Farms, because they are just one of a number of initiatives. The Monitor Farm Development Group, should be renamed the Scottish Projects Development and Co-ordination Group (or words to this effect), and play a more active role in ensuring that the main representatives of each initiative are present, that discussion takes place on how KE messages from all initiatives can be made more available to farmers and the key learnings be incorporated in more projects. There needs to be an acceleration in the evaluation, commercialisation and adoption of new technology involving close links with Agritech Centre projects and if possible their satellite farms. The fact that Scotland is a small country and the main players in each initiative know each other, is to our advantage. More formalised regular contact between these key players could make a huge difference to the success of projects and the uptake of new ideas on farms.

22. Do you agree with the proposal to look at moving towards a more performance based approach to compliance, using key performance indicators and better information?

Do you agree with the proposal to look at moving towards a more performance based approach to compliance, using key performance indicators and better information?
In principle we agree with such an approach, but have some reservations as to how such an approach will be achieved in practice. SRUC firmly believe that good decision-making depends on good information. At all levels – the farm, catchment, supply chain and government – the collection and processing of data into information is central to benchmarking performance and evaluating options for improvement. It is a cliché, but “measuring to manage” works. However, placing more emphasis on Key Performance Indicators (KPI’s), especially if linked to payment, is not without difficulties. Establishing appropriate and agreed KPI’s is challenging. A good KPI should encourage actions that lead to the right outcomes but many don’t because there is no proven relationship between the KPI and outcome. This certainly applies in production agriculture where overzealous focus on technical KPI’s often doesn’t lift profitability. As for the environment, while some KPI’s are easy to define for some outcomes (e.g. water quality), KPI’s for other outcomes (e.g. soil health or biodiversity) remain unclear. It is important to consider how KPI’s will be measured accurately, in good time and at low cost. Experience suggests that typically this is much easier said than done, as has been the experience with the Beef Efficiency Scheme. In addition, linking some payments to production related KPI’s / outputs could breach WTO rules, so care will need to be taking in devising agreed indicators within the bound rules of the WTO support rules (i.e. the WTO boxes). Fortunately, we believe that the above problems are either surmountable or their adverse impact can be limited. Agreeing suitable (economic, environmental and social) KPI’s based on proven evidence and that are readily measurable is possible given due diligence and commitment. Allied to this are the rapid advances in digital technology (with its capacity to exploit the potential of big and open data), and in monitoring technology (e.g. satellite imagery, remote sensors, drones, etc.) in the measurement of outcomes and practices that best deliver them. Performance related payments require proportionality in the measures sought versus both the scale of payments being received by claimants and the primary benefit secured through this funding. The CAP currently supports a wide range of types of recipients and outputs, including both highly productive agriculture and cultural benefits (for instance in the hills and hard, remote parts of the country). A productive lowland/upland unit where the primary output is productive agriculture and the expectation that the business is run commercially is reasonable, could be expected to participate in carbon audits, soil testing, financial recording and KPIs etc. However for a crofting business in a remote area where the continuation of a culture and way of life is one of the key outputs of direct support, the imposition of an additional paperwork burden would be counter-productive.

23. Do you have views on the types of indicator that should be used or areas of priority action within the operation of current CAP schemes?

Do you have views on the types of indicator that should be used or areas of priority action within the operation of current CAP schemes?
To be relevant and informative, any indicator needs to be cost-effective to collect information on, repeatable on at least a two to three year basis so that trends can be established and bear as close a relationship as possible to the outcome it is designed to measure. Designing such indicators for environmental outcomes is no easy task. The areas of concern (e.g. water quality, carbon, soil health, biodiversity, greenhouse gas emissions, etc.) are not only many and varied, but differ markedly in our ability to assess quality or condition easily at a farm, landscape or regional level. We therefore believe that priority should be given within the transition period to considering what package of indicators and associated metrics could be best put in place to assess the overall public goods arising from management actions at the individual farm level. The Public Good Tool designed by Defra, and being tested by SRUC on a range of upland farms in Scotland and northern England during 2018-21, might prove a useful starting point for such discussions: [http://www.organicresearchcentre.com/?go=Research%20and%20development&page=Resource%20use%20and%20sustainability&i=projects.php&p_id=20] Such an approach might help to provide the justification needed post-Brexit that public funding is resulting in the provision of public goods at a farm level. Traditional prescriptive approaches to the design and implementation of agri-environment schemes, and the majority of measures across Europe, have also been shown to provide little in the way of biodiversity benefit. We think there would therefore be a lot of merit during the transition period in Scotland piloting a Payment-by-Results approach, given that this different mechanism is proving of interest and benefit elsewhere in the UK and Europe. The transition period would allow such a pilot to be tested in Scottish situations and thereby help inform post-2024 policy development. Note that such new approaches would be intended to supplement more traditional approaches rather than replace them, as it is well recognised that Payment-by-Results approaches are not applicable to all environmental concerns: [http://ec.europa.eu/environment/nature/rbaps/index_en.htm]

Scottish Rural Development Programme (Pillar 2)

24. Given the importance of continuity of support for the forestry sector and that the target for new woodland is to increase to 15,000 hectares by 2025, should the current the Forestry Grant Scheme continue broadly in its current form until 2024 or can you suggest other short-term changes that would better achieve these policy aims?

Given the importance of continuity of support for the forestry sector and that the target for new woodland is to increase to 15,000 hectares by 2025, should the current the Forestry Grant Scheme continue broadly in its current form until 2024 or can you suggest other short-term changes that would better achieve these policy aims?
The “What future for woodland and forestry chapter?” in SRUC’s Rural Scotland in Focus 2016 report [https://www.sruc.ac.uk/info/120428/rural_scotland_in_focus/1735/2016_rural_scotland_in_focus_report] highlighted a wide range of issues which had been hampering the creation of new woodland in Scotland or the replanting of harvested areas. There were recognised difficulties in establishing large blocks of new woodland associated with deer, bracken and local infrastructure. However, probably the greatest issues has been that incentive levels, outwith central Scotland, had not been high enough to stimulate much new woodland creation, or the restocking of many harvested woodlands. Increased bureaucracy associated with the current Forestry Grant Scheme had also been markedly increasing the time to process applications and acting as a disincentive to potential applicants. Subsequently it appears that the McKinnon report [https://www.gov.scot/Topics/farmingrural/Forestry/JimMackinnonreport] has gone some way to address many of these issues and applications are proceeding more quickly. In addition, an improvement in the economic balance between agriculture and forestry has occurred in the last couple of years. Steadily rising timber prices have greatly improved the investment returns for forestry whilst the outlook for farming has become increasingly uncertain due to Brexit. This is spurring more farmers to retire and making an increasing amount of land available for forestry. As a result in 2018/19 and again in 2019/20 Scotland is expected to exceed its forestry planting target of 10,000 ha. So far much of this land has been sold for investors to plant rather than for farmers to diversify into forestry. The risk here is that excessive afforestation will occur in specific areas, owned by individuals not resident in the area with potential detrimental landscape, biodiversity and social impacts. The current FGS favours large scale commercial conifer plantings by design. We therefore think that some rebalancing of the grant scheme may now be justified, perhaps by increasing payment rates for smaller schemes and more diversified / biodiverse plantings to drive the development of a more integrated forestry sector within the rural economy and landscape.

25. In considering the current Forestry Grant Scheme, are there opportunities to improve the administrative efficiency of the scheme?

In considering the current Forestry Grant Scheme, are there opportunities to improve the administrative efficiency of the scheme?
This has very recently been done and implemented via the McKinnon Report [https://www.gov.scot/Topics/farmingrural/Forestry/JimMackinnonreport], which was instigated by the Scottish Government. Much improved efficiencies were identified in the research for the report and addressed. The recent increase in the area of woodland creation grant applications being processed and approved now is evidence of the report's success. However, much emphasis has been placed on woodland creation, with the result that non-creation grants (e.g. for long term forest plans), and approvals for plans and felling licence applications, are too-often placed at the back of the queue and are taking too long to turn around. This is more a case of insufficient staff resource, rather than inefficiency.

26. Given the importance of continuity of support for environmental outcomes, should the current Agri-Environment Climate Scheme continue broadly in its current form until 2024 or are there short-term changes that could be introduced to i) simplify and streamline the scheme, ii) improve customer experience and/or iii) enhance the delivery of environment and climate change objectives?

Given the importance of continuity of support for environmental outcomes, should the current Agri-Environment Climate Scheme continue broadly in its current form until 2024 or are there short-term changes that could be introduced to i) simplify and streamline the scheme, ii) improve customer experience and/or iii) enhance the delivery of environment and climate change objectives?
Continuity is essential for land that has been under environmental management in order to maintain and continue environmental outcomes using public money, especially on high nature value sites such as designated sites, priority habitats and sites that support priority species. Continuity is also essential for farmers who have modified their farming systems to accommodate AECS management options. However the current scheme should be simplified and streamlined until a new more effective scheme is established . The application process for AECS is very complex, time-consuming, and expensive whilst the chances of success (given its competitive nature) are uncertain when time and funds are committed to application. The threat to a whole (expensive and time consuming) plan due to small clerical omissions is not a good use of tax payers money and reduces uptake to the scheme. Applicants are having to second-guess what SNH want to see happening on a particular site, often with relatively little guidance from SNH at the application stage, only to have the application rejected because the activity proposed is not what SNH want to see. It would be better if Scottish Government could identify those schemes and activities that it wishes to fund through a first-pass type approach (similar to SRDP statement of intent) and then provide support to applicants in order that the proposal submitted is clearly going to deliver the sought-after benefits and activities. Administrative simplifications and improvements should be made in the application process, management options and selection process. Improved liaison with case officers to work on scheme administration issues would enable applications to be improved rather than rejected. Grazing plans should be replaced by a simple exclusion period because some advisers and case officers do not have specialist knowledge to produce or assess effective plans . This is backed by research that suggests that there is more success for options that take agricultural land out of production than in-production options, but this is due to the lack of uptake and effective advice and implementation of in-production options. While targeting should be an effective tool , it is crude and doesn't replace specialist knowledge e.g. targeted options have proved successful for certain species such as corn bunting and corncrake due to simple management options, but there is no real evidence of the overall effectiveness of AECS in halting the decline of many other species at a national level. The payments based on income forgone should include an incentive for the farmers’ extra time, effort and hassle. Another missed opportunities is bespoke training for farmers in soil & functional ecological processes, species & habitat identification & management requirements so that farmers understand the objectives more clearly, their confidence in managing schemes is improved and they can take ownership of management. Effective monitoring is also essential to establish outcomes. A Land Managers Options (LMO) type scheme which would distribute AECS funding on wide-shallow basis would be popular with land managers, however at this stage the administrative costs may be prohibitive. An LMO type scheme could be tailored to specific regions in a similar way to AECS, so that the number of actions available in each area would vary depending on local needs.

27. Are there new emerging environment or climate change priorities that need particular focus under the Agri-Environment Climate Scheme in the next three - five years?

Are there new emerging environment or climate change priorities that need particular focus under the Agri-Environment Climate Scheme in the next three - five years?
SRUC consider that the scheme covers many important areas that should be maintained and expanded. Continued emphasis on peatland restoration, moorland management and good muir-burn practice as these have proved particularly effective measures with carbon and biodiversity benefits. SRUC also see the benefits of strengthening and supporting integrated crop and pest management in a more holistic and whole farm approach as this is where the greatest benefits arise rather than a piecemeal approach. SRUC also recommend that support be extended to several new areas and new methods of delivery. It would be beneficial to introduce relatively simple, accessible and well proven light touch LMO or similar type of options e.g. as for greening to address soils and carbon sequestration; pollinators, landscape linkages & water quality. There could also be measures to encourage farm plastic reduction and recycling. It would also be beneficial to provide further support to organic faming and other farm systems approaches such as biological farming; bio-agriculture, HNV farming by support for extensive farming systems and measures e.g. restricted LU/ha; using only natural fertilisers; restricted pest control /chemical use; self sufficiency in home produced feed and/or using locally sourced feed stuffs (i.e. not GM soya or soya from Brazil which is driving deforestation). Capital options and some of the targeted management options could be used to complement these farming systems. SRUC also consider that in order to promote a more integrated approach to sustainable agricultural production and consumption it is essential that new standards for certification or branding of products are developed for consumers to identify produce that is farmed within a sustainable farming system, or high nature value farming. These standards need to reflect common environmental, welfare and ethical standards that consumers can clearly understand and trust. There are currently many confusing certification and branding options that do not provide environmental reassurances other than organic. Scottish Government should review current certifications schemes and identify those of relevance to the delivery of programme objectives and consider bringing the most valid one(s) within the AECS requirement where appropriate.

28. Considering the current New Entrants Capital Grant Scheme, are there opportunities to improve the administrative efficiency of the scheme?

Considering the current New Entrants Capital Grant Scheme, are there opportunities to improve the administrative efficiency of the scheme?
Having consulted with numerous consultants within SRUC about the New Entrants Capital Grant Scheme there seems to be a very mixed opinion of the scheme. The perception is that eligibility of the scheme is not clear, it is complex and users would like to get to the point quicker. On the web site when you click on full guidance (https://www.ruralpayments.org/publicsite/futures/topics/all-schemes/small-farms-grant-scheme/small-farms-and-new-entrants-capital-grant-full-guidance/) it has details for both the small farms grant scheme and new entrants capital grant, which makes it tricky for people to differentiate between the eligibility of the two. SRUC recommend that each scheme is given a separate web page and the joint page is removed. The guidance also does not make it clear what level of detail is required at the time of application. Consequently there is a wide variation in the level of detail submitted with some consultants doing no financial projections, some doing partial budgets and others doing three years cash flow. It would be simpler if a template was made available to those applying for the scheme almost like the old FBDS application. New entrants have a severe lack of capital and getting a consultant to do these plans and financial projections can be expensive, so the simpler it is the better. In its current form the NECGS is a good example of a straightforward scheme and the simplest to apply for out of the three schemes that were available. The scheme is accessible to farmers, simple to apply for and even if professional help is sought an application is relatively inexpensive. Administrative efficiency is one of the best of an SRDP grant scheme with rolling applications and often quick decisions and quick payments (though this varies from SGRIPID office to office). It could be used as an administrative model for other schemes. Given the competitive nature of this scheme, and the potential for applicants to spend a lot of time and money yet be unsuccessful; a two stage screening process should be considered. The first stage would take a simple tick box approach to assess eligibility. Only the most likely candidates would then be permitted to enter the second more detailed second stage where further supporting information such as quotes, qualifications, supporting letters, etc would be required.

29. Considering the CAGS in its current form, are there opportunities to improve the administrative efficiency of the scheme?

Considering the CAGS in its current form, are there opportunities to improve the administrative efficiency of the scheme?
SRUC consider that CAGS has been of great benefit to crofting businesses across Scotland, allowing improvements in productivity, animal welfare and the environment. Whilst the application process is relatively easy, and turnaround relatively fast, we believe opportunities remain to increase uptake and relevance of the scheme, particularly given climate change and Brexit challenges faced by the crofting sector: • An online form would streamline applications for both crofter and SGRPID and if the application forms could be further simplified it would encourage crofters to apply and would reduce their reliance on agents. • The need for justification for simple operations such as fencing and drainage could be removed entirely or replaced with a tick-box menu of justifications. The need for more detailed justification is understandable for major improvements like sheds and handling facilities. • Provision of quotes can be problematic (as with any capital grant scheme), as many suppliers suspect they are merely being asked as a secondary quote and therefore do not provide realistic figures, or pay no heed to the necessary wording. Therefore a reduction in the number of quotes would help, as SGRPID officers understand what normal prices are within their locality (e.g. for fertilisers, or concrete delivery). However, a return to Standard Costs would be more helpful, with the option to obtain quotes for added cost in remote areas. • Consideration should be given to providing advanced (part) payment to suppliers to reduce their cash flow problems; or to help cash flow issues for the crofter applicant. For example 60% on application approval with 40% on submission of receipts and confirmation that all works have been completed and are ready for inspection. Whilst this carries financial risks regarding non-satisfactory completion of projects it may improve uptake and stimulate production gains, improve the resilience of crofting businesses and stimulate wider economic development in these remote economies. • We note that the time between submitting an application and receiving an approval is variable. Publication of turnaround times would allow applicants to plan ahead more effectively. Additionally, consideration should be made into defining a maximum length of time between claim submittal and SGRPID payment that would to allow crofters to improve cash flow planning. • We recommend that there should be a definitive guide as to what constitutes a “group” for the purposes of CAGS. To encourage co-operation, it should be possible for constituted groups to apply for CAGS, rather than limited to common grazing committees.

30. Should the scope of what can be funded be reviewed, for example in terms of adding in new elements and restricting total spend on some projects?

Should the scope of what can be funded be reviewed, for example in terms of adding in new elements and restricting total spend on some projects?
SRUC are of the opinion that no radical change is required; although, we recommend that the scope should be extended since crofting has changed over the years: • With new woodland crofts in existence, the scope of the scheme should be expanded to allow woodland management related works. • For environmental reasons, a ‘lime only’ or ‘phosphate only’ or ‘green manure’ option should be added, rather than associating with full reseeds. • There should be the ability to increase intervention rates to target uptake that delivers to Scottish Government priority objectives (e.g. if improving grassland productivity was deemed a priority there should be scope to provide an uplift in the intervention rate (say 10%) for CAGS rejuvenation applications). • Consideration should be given to extending the total amount of grant aid available beyond the current £25,000 ceiling. For larger projects, £25,000 grant can be insufficient and if a project is agriculturally justifiable, then it should be possible to get grant aid on the whole project. • It should be possible to provide a higher grant ceiling to young crofters eligible for the 80% grant so they could genuinely get more grant than those at 60%, rather than them having to stagger investments every 2 years. • Consideration should be given to the provision of grant aid for mobile items, such as creep feeders, machinery such as lime spreaders, without having to fix items in place. • Direct replacement/repair of old buildings with like for like would also help. Small businesses cannot generate the profit needed to reinvest to the scale required to fund a replacement shed. • We believe the labour rate, at 60% of £7.82/hr, is insufficient.

31. Do you have initial views on the proposal to close the Small Farms Grant Scheme?

Do you have initial views on the proposal to close the Small Farms Grant Scheme?
SRUC recommend that this scheme should not be closed. Although there has been a limited uptake to-date, it has provided valuable support to those small businesses that have applied. The scheme could be made more attractive by increasing the upper area limit for the holding and increasing the income threshold. It would also be worth considering eligibility of businesses above 30ha in size that lack in-bye land as this can reduce the productive capacity of their holding below that of smaller units on better land.

32. Would there be customer benefits if the CAGS, small farms capital grant scheme and the new entrants capital grant scheme were combined?

Would there be customer benefits if the CAGS, small farms capital grant scheme and the new entrants capital grant scheme were combined?
SRUC believe that it would perhaps be counter-productive to merge all schemes if the overall funding pot were to be reduced. However, we see benefits in such an approach if there could be movement of existing funds between schemes to allow full utilisation of available aid. It also considered that if schemes are combined then added complexity in the application form should be avoided – with separate schemes perhaps retaining simpler application processes. We recommend that the opportunity for a new entrant crofter to apply for funding from both the new entrant capital grant and CAGS should be retained.

33. Considering the current FPMC scheme, are there opportunities to improve the administrative efficiency of the scheme?

Considering the current FPMC scheme, are there opportunities to improve the administrative efficiency of the scheme?
Currently the grant entails significant cost to the applicant in terms of time and, if using a consultant to assist with the application, money. Getting three quotes and other supporting materials can also be surprisingly difficult, particularly if the supplier knows it is for a grant application. At the end of the process there is no guarantee of success for the applicant. We propose that a better solution might be to have an initial competitive round where the applicant effectively 'pitches' their project, which would not require the amount of detail and supporting material. Those projects selected at this stage would then need to provide full business and financial detail before being given a final go-ahead. If these were not satisfactory applications could still be rejected at this stage but in general this would be a more efficient use of applicant's time and effort. Additionally we suggest that ways need to be found to reduce the timescale between application and approval as many projects are time critical (e.g. responding to customer requirements) and especially for unsuccessful applicants who then need to find other sources of funding after a 3-4 month period of inactivity. The two-stage 'pitch' and application method would also help to overcome this problem.

34. Would you wish to see other aspects of this scheme changed in the short-term?

Would you wish to see other aspects of this scheme changed in the short-term?
SRUC believe that in the short term the FPMC should be more focussed on strategic industry sectors and targets. There could also be more of a focus on non-capital factors such as software for robotics, artificial intelligence etc. used to help increase efficiency and overcome issues such as skills shortages, while at the same time still encouraging start-ups and SMEs, as long as they have ambition and a strong business plan. The Scottish Government should perhaps consider conducting an audit of previous successful applicants after a reasonable period (3-5 years?) to understand the Return-on-Investment from the grant and identify any significant successful / unsuccessful factors.

35. Do you have views on priority issues to be considered by any pilots during the transition period?

Do you have views on priority issues to be considered by any pilots during the transition period?
Capital support schemes while popular with farmers have proved expensive for the tax-payer with uncertain results. The existence of these schemes can lead to price inflation from suppliers, over-expansion into specific sectors (laying hens, holiday accommodation) and a tendency to stifle innovation. However, we recognise that in the right circumstances capital investment can improve productivity and business viability meaning there may be an opportunity to support such investments (underpinned by a business plan) through a loan scheme, loan guarantee scheme (or indeed through tax relief). SRUC believe that capital funding can be effective at providing public goods and this should remain a priority. Capital funding should be therefore be focused on providing public goods such as pollution control (slurry stores, fencing of watercourses), to support younger farmers, technological adoption and innovative projects. Evidence of collaboration and benefits to the wider industry or supply chains particularly food and drink should be demonstrated. A further category of capital funding that could be considered to support farmers in climate change adaptation - protecting their businesses and soils from weather volatility (more forage storage, welfare friendly cattle slats).

36. Is the LEADER approach something that you could support?

Is the LEADER approach something that you could support?
The UK Government has suggested that the future of support through LEADER may come under the proposed Shared Prosperity Fund (SPF), which will consist of structural fund money that comes back to the UK following our withdrawal from the EU. However, there remains considerable uncertainty around how the SPF would operate, what level of funding would be available, how funding would be distributed across devolved nations, rural and urban areas, etc. A consultation on the SPF will be held in Autumn 2018. Rural stakeholder organisations have already expressed concerns to the UK Government that the majority of SPF money will be targeted at urban locations. The extent to which this is the case will depend on what logic is taken to allocate funding (e.g. if a traditional competitiveness logic is followed, based on agglomeration, then cities will predominate in terms of funding decisions) and how inequalities are defined and measured (e.g. in terms of social, geographical etc.). Discussions are required as to how far the SPF should incorporate ring-fenced funding for rural areas, have a designated rural stream, or should introduce minimum spending requirements at whichever level is appropriate (national, regional or local) for rural areas. These discussions need to progress in a complementary and open way with related discussions regarding proposals for future agricultural and environmental policies, including a future replacement for LFASS. LEADER as a programme and approach has been running since the early 1990s so there is a great deal of experience and learning that must be taken on board when shaping approaches to bottom-up, community-led, place-based development in future. It is also worth acknowledging the importance of continuity and the potential damage that can be caused when policies and structures change. Maintaining a LEADER approach into the post-Brexit future would demonstrate commitment to, and provide some critical continuity for, current LAGs, many of whom have highly knowledgeable and committed members who are keen to carry on doing good work at local level, with what have always been small amounts of funding (when compared to the amount of funding that goes to agriculture through other Pillar 1 or Pillar 2 schemes, for example). Following the bottom-up LEADER approach ensures that these small amounts of funding can be effectively focused on local needs and opportunities, thereby making a big difference. It may be worthwhile shaping a future LEADER scheme around the principles of social innovation, to encourage the private and third/community sectors to explore innovative ways of providing services, setting up community and social enterprises, in order to make the most of new opportunities (such as ageing, post-carbon and re-localised economies, digital technologies, etc.). The recent RESAS work on LEADER (to be published shortly), focusing on its economic, social, cultural and environmental impacts, exploring the challenges faced by applicants and providing some policy recommendations, will provide useful evidence to inform decisions on the future of a LEADER-type approach to rural community development. Evaluations of LFASS will be useful too in terms of seeing how it has supported some of Scotland’s most remote communities through support to farming businesses. It is also worth remembering other previous place-based rural development approaches from which lessons can be learned (such as the Initiative at the Edge). In relation to reducing inequalities between communities, it is also worth acknowledging the varying capacities between individuals, communities, LAGs, etc. across rural Scotland and the need to ensure that everyone has a voice in shaping future policies and programmes and, once they are delivered, that all those eligible are able to apply and to access appropriate support during the application phase. Alongside locally-led development through LEADER, there may be an argument for other programmes and spending at regional level (e.g. by local authorities, city region deals [which include rural areas] and other regional partnership arrangements [such as the Borderlands Growth Deal]) to tackle those issues that are best addressed at this larger geographic scale, such as infrastructure provision. It is critical, however, that the two levels i.e. communities and regional or local authorities, as well as other stakeholders, including funding bodies, etc. are well linked and work in partnership. It is also worth re-emphasising that alongside local and regional level initiatives, there is a continuing need for an over-arching cross-cutting rural vision and strategy to ensure that there is transparency and clarity over the direction of travel for rural Scotland and to provide a framework for local place-based initiatives. This strategy needs to have buy-in from all stakeholders, including all departments of Scottish Government, local authorities, NGOs, local communities etc. Having such a vision and strategy is a requirement for effective rural proofing as it sets out the direction of travel to which all stakeholders are aiming. The NCRA in its recent Discussion Document called for a new ambitious and positive Rural Economic Strategy. The debate is ongoing as to whether having a separate rural economic strategy is the right way forward. While it potentially runs the risk of rural issues being side-lined, more positively, a strategy would set out a vision for rural Scotland and the ways in which rural characteristics, challenges and opportunities are different to urban Scotland (which tends to be prioritised in policy) and therefore need to be approached differently. It could be argued that as we now have city region deals there is even more need for a clear strategic statement on the characteristics and potential of Scotland’s rural economies. The question also remains as to whether a separate Rural Communities Strategy is required. Having separate strategies runs the risk of artificially separating rural enterprises and rural communities, which are fundamentally intertwined. However, such a strategy would offer the opportunity for key issues such as service provision, housing, transport, community resilience and capacity etc. to be explored.

37. Considering LEADER in its current form, are there other opportunities to improve the administrative efficiency of the scheme?

Considering LEADER in its current form, are there other opportunities to improve the administrative efficiency of the scheme?
As mentioned in the consultation document, it will be important to have some over-arching guiding principles set by Scottish Government, but giving Local Action Groups (LAGs) the freedom to assess and decide on local priorities through their Local Development Strategies (LDSs) to deliver the most appropriate approach to rural development. Programmes and projects are locally tailored and locally managed and are focused on building up local assets and tackling local challenges. This approach can be described as place-based (rather than sector-based) policy and has been advocated by the OECD, the European Commission and the Scottish Government (the latter through the 2017-18 Programme for Government, for example, which states: “We will work… to attract further investment to rural Scotland by… exploring how place-based collective endowments could be used to revitalise local, and particularly remote, communities”. Feedback from current LAGs has emphasised that the administration associated with LEADER in the current programme is out of proportion to the funding, which is creating additional burdens for LAGs and discouraging applicants. This must be avoided in the next programme. While robust administrative requirements are needed to ensure that LAGs follow their LDSs and the ‘rules’ of the funding stream (whatever form it takes in future) this must not be too onerous so as to stifle creativity and discourage innovative projects from coming forward. The funding administrators need to have confidence in communities, businesses and individuals to use the funding efficiently, effectively and correctly to support the economic, social and environmental wellbeing of their communities. It is also important to consider the capacity of LAGs to take on the role that is envisaged through this approach. While many LAGs have existed for several years (and may include people who have been involved in LEADER since its inception in 1991) others are newer and may lack the experience, confidence and resources required to take on more delegated authority in future. This may lead to a more uneven landscape of socio-economic development across rural areas. Again, the recent RESAS work on LEADER (due to be published shortly), focusing on its economic, social, cultural and environmental impacts, the challenges faced by applicants and providing some policy recommendations, will provide useful evidence to inform decisions on the future of LEADER.

38. Do you have initial views on the proposal that SRDP broadband support would cease?

Do you have initial views on the proposal that SRDP broadband support would cease?
Digital connectivity – high-speed broadband and mobile coverage – are increasingly described and experienced as a core service, in the same way that provision of water, electricity – particularly since core administrative functions such as tax and many public services – are moving to a digital platform. There is a strong view that such infrastructural “architecture” should be provided by the Scottish Government, with strong co-ordination of broadband provision for the most remote communities. The recent Recharging Rural survey (http://www.princescountrysidefund.org.uk/research/recharging-rural) showed the centrality of digital provision for rural communities, and how – with such provision – a wealth of possibilities can be opened up for individuals, businesses and communities. There are two key points about this approach which are concerning: Firstly, the approach proposes withdrawal of a scheme due to low take-up, rather than investigating the causes of low take-up (it is attributed to R100 or The Reaching 100% Programme) but this is not necessarily the case. Therefore the causes once identified should be fully addressed to support increased take-up through an inclusive approach. Secondly, this proposed approach places the onus on individuals and communities to prove that there is a demand for broadband before broadband provision is made. This assumes that all communities have the capacity to (a) coordinate demand-assessment within their own communities and – as set out in the proposal – (b) work with other rural communities in a similar demand-assessment. Such complex and time-consuming work requires technical, business and community knowledge, resources and time, and is likely to only be possible for communities who are sufficiently resourced to take this approach. This leaves behind those without such a resource-base. It is concerning that the premise is one of ‘prove demand’ when so much evidence points to extensive demand already existing, with the need for high-speed broadband being a fundamental pre-requisite to rural economic and social development. This approach would also appear to work against the Scottish Government’s Purpose and Values of fairness, inclusion and social justice, since it is likely that those who can seize these opportunities will do so, leading to a greater digital divide, which is likely to remain “under the radar” with subtle implications for individuals and therefore more challenging to address, particularly for dispersed populations in rural settings.

39. Do you have any thoughts on the form, content and delivery methods for future advice?

Do you have any thoughts on the form, content and delivery methods for future advice?
Between April 2017 and March 2018, 3,192 people attended a Farm Advisory Service event. Of those who completed an evaluation form, 95 percent rated the event as "excellent" or "good" and 92 percent said they intended to make changes to farm or croft management as a result of the advice received. It is clear that there is demand and need for one-to-many advice to Scotland's farmers and crofters. Given the significant business, regulatory and environmental challenges and opportunities of the coming years - set against an expectation of declining post-Brexit support payments - there is arguably a need for more such advice. It is essential that the advice is relevant and accurate, available locally, and delivered professionally by individuals who are highly knowledgeable on the subject. Content should be informed by the challenges and opportunities faced overlaid with a strategic direction set by Government and its advisors / wider stakeholders. Whilst there will undeniably be a strong pressure and rationale for advice on delivery of public goods, it should be recognised that the most effective way to attract receptive and diverse audiences is by weaving such messages into others about the core operations of the farm or croft business. Improved integration with skills development programs, training and signposting to such initiatives will also strengthen the hand of advisors in the field and improve the relevance of any advisory programme. As more within the farming community become ever more comfortable with digital delivery of such information, the use of media such as webinars, apps and social media should increase. There remains, however, a need for face-to-face advice due to the greater effectiveness in spurring participants in to action and not least the wider social benefits for often isolated farmers and crofters. It is essential that one-to-many advice just like one-to-one, respects the views of farmers and crofters but is willing to challenge them to think differently about their business and to make necessary changes.

40. Do you have any views on the balance of advice delivered by one-to-one and one-to-many methods?

Do you have any views on the balance of advice delivered by one-to-one and one-to-many methods?
One-to-many advice is often where seeds are sown that then come to fruition thanks to detailed one-to-one advice. Both have their distinct functions and should be retained and expanded upon in order to help ensure Scotland's farms and crofts deliver their full potential. One-to-Many advice has benefits in that crofters and farmers learn from their peers and have the opportunity to see new ideas in practice. However, many farmers and crofters still struggle to attend events; geography, weather and cost all being factors. In remote areas in particular it can be challenging to reach all possible participants and accordingly there should be a review of how better to engage with remote communities through an improved balance of one-to-many and one-to-one advisory. The balance of spend on Farm Advisory Services is currently weighted in favour of one to many, but potentially should be the other way round in some areas of the country. One-to-one advice is invaluable. It can, and should, be held on farm or on croft or smallholding, or at local surgeries, where the issues can be seen and practical, workable, solutions found. The availability of funded ILMP’s is hugely beneficial, but not all need a whole plan – many need short, targeted advice throughout the year. A simple health check to steer an improved course is likely to be both popular and effective. For small, peripheral businesses, where there is little profit but an important social and environmental role within rural communities, one–to–one advice should be made available at significant discount, so that these businesses can reach their own and Scottish Government policy objectives. This would have the added benefit of reaching many more businesses and engaging people who may not be able to attend group meetings. The cost of time and travel to reach such communities must also be considered.

41. Do you have any views on how delivery of advice can be better linked to delivery of results?

Do you have any views on how delivery of advice can be better linked to delivery of results?
It may be possible, via a longitudinal survey of those receiving both one-to-many and one-to-one advice, to develop a more detailed picture of long-term impacts - albeit at the risk of observer effects - than is currently available via evaluation forms, telephone surveys and face-to-face interviews. It may also be possible, subject to data protection considerations, to benchmark the regulatory, environmental or business performance of those receiving advice and those not - albeit performance is likely affected by many factors. To link results directly attributed to advice received it may be necessary to improve the definition of what is trying to be achieved. A well defined set of annual Objectives would allow advisors to tailor the program to achieve these objectives. The temptation to improve everything at once should be resisted in favour of targeted continual incremental improvement in order to achieve sustainable changes in practice and culture.

42. Considering the Knowledge Transfer and Innovation Fund (KTIF) scheme in its current form, are there opportunities to improve the administrative efficiency of the scheme?

Considering the KTIF scheme in its current form, are there opportunities to improve the administrative efficiency of the scheme?
KTIF had two parts - Knowledge Transfer and Skills Development that was open to eligible bodies only (excluded SRUC) and Innovation - which has funded Monitor Farm Projects and some innovation projects. The uptake was relatively low and the budget for this 5 year scheme was recently reduced from its original £12m. The main aim of the Innovation part of the fund was to allow farmers and rural actors to set up Operational Groups to tackle common problems or add value introducing innovative approaches. The Innovation part of KTIF had a relatively low uptake, partly due to lack of publicity about the fund, lack of information on project submission deadlines (which often only appeared on the website close to the deadline). In addition, some potential applicants were put off by feedback received from rejected applications. It took a lot of work to draw up an Operational Group and submission of an application and subsequent rejection of the idea meant a lot of time and effort wasted. This problem has since been rectified by the introduction of RISS, the Rural Innovation Support Service, which has pump primed the crucial idea and project plan generation stage with funding leading to many potential projects moving forward. As a consequence of Brexit KTIF funding ceases to be available after 29th March 2019, and a replacement needs to be found otherwise many of these innovative projects might not happen. A replacement funding scheme is essential if the hard work done through RISS is to come to fruition. SRUC strongly believe that there needs to be a fund that encourages innovation that drives improvement and increased productivity from Scottish land based industries. SRUC experience has highlighted some areas where administrative improvements could be made. There should be better publicity of the scheme from Scottish Government with clear advance notification of PAC deadlines and better communication from the PAC. There should also be a clearly identified process for providing feedback on concepts or ideas and clear instructions as to what will happen regarding application deadlines before the withdrawal of the scheme at the end of March 2019. There was also an early impression formed that the PAC would only accept one KTIF project per agricultural sector. There should be no limit on the number of good ideas coming forward and each application should be judged on its own merits for level of innovation and likely impact. This impression, correct or otherwise, dissuaded some from submitting applications to the scheme.

43. Do you have any views on the effectiveness of KTIF and how the aims of the scheme could be promoted in the future?

Do you have any views on the effectiveness of KTIF and how the aims of the scheme could be promoted in the future?
KTIF Innovation projects have been a limited success to date and we suggest that more good ideas could have been funded with better publicity, clearer guidelines and a clearer approval process. We have observed that it tends to have encouraged larger funding bids of over £100k, when there is a need for a range of funding rates depending on the proposal. In particular, feedback from SAC Consulting suggests that farmers do not know much about KTIF unless they happen to be in one of the Operational Groups, but we are confident that this will change given the publicity generated through the Rural Innovation Support Service (RISS). We believe that the Knowledge Transfer part of any future KTIF type fund should be available to an increased list of eligible bodies. In KTIF this was restricted to organisations such as Levy Boards and Public Bodies. A knowledge transfer organisation such as SRUC was unable to apply. SRUC could have come up with a number of good ideas for knowledge transfer projects, but was ineligible, and had to tender for bids submitted by eligible bodies as mentioned above, which is not quite the same as gaining funding for your own or your client’s ideas. This part of KTIF was funded at a 75% rate, which caused the levy boards problems when making applications. Consideration should be made to offer knowledge transfer funding at a 100% rate, where the organisations applying don’t have the means to carry out projects without full funding. The success of a future KTIF is dependent on having a pump priming fund such as RISS to fully develop innovative ideas before they are put forward for funding. Conversely, RISS generated projects require a project funding mechanism, otherwise a lot of good ideas will not come to fruition. It is essential for Scottish agriculture and forestry that there is a fund that encourages groups to develop new initiatives for themselves and the benefit of others. The aims of the scheme are best promoted through the success of its projects, and more should be done to publicise some success stories in existing KTIF projects – example Live Lambs. It is not just up to project deliverers to do this, there needs to be a co-ordinated effort. The RISS project has funding for promotion and case studies and future KTIF funded projects could be publicised through this route.

44. Would you support a similar type of scheme going forward?

Would you support a similar type of scheme going forward?
SRUC believes that this scheme has the potential to unlock considerable environmental and economic benefit to Scotland’s largest agricultural sector and should be continued and extended in the future. The scheme has already established a base line to help farmers take step changes in terms of data informed management decisions. The scheme started from a base where there was no national level scheme for collating data so essential to drive population change and efficiency. If Scottish beef production and the industry itself is going to be competitive in an international market it is critical that farmers consider the efficiency of the whole system – within farm gates and across (inter) national supply chains. As the scheme was set up with a view to help farmers utilise genomics as part of the management options in the future there was a planned lag in the direct genomics results being available as the country moved from nothing to a meaningful population level genetic and performance database. Now with data having been collected and analysed we are at the stage where it is necessary to marry the technical potential of genetics with the advisory services messages and help farmer take forward and use tools that will become available. This will start with SRUC led Beef Efficiency Scheme training events being delivered over the coming autumn and winter. Scottish beef production needs to be on the leading edge of data driven efficiency improvements at a national scale to remain competitive and maintain price premium for their brand. Such a scheme provides a base line to help producers add that added value and create that unique and in high demand brand going forward. The tools will only help drive that continuously if farmers maintain the activity after the end of the scheme, be it with support or otherwise.

45. Would you support a future approach that aims to deliver similar increases in efficiency through the direct payment support mechanisms?

Would you support a future approach that aims to deliver similar
SRUC believes that yes, the scheme has the potential to have even more added value. On top of the maternal efficiency (limited to explore system wide economic benefits due to agri-environmental scheme) could be expanded for other key attributes of Scottish beef production. For example adding in data on disease/health planning could be used to add such traits to genetic improvement programmes but could also be used and mined for disease surveillance (e.g., EPIC). It could also be used to identify efficacy (or not) of alternative treatment approaches as well as helping farmers identify the key health/disease challenges and management options within their farm gates. Understanding the drivers of efficiency in different systems and at different lifecycles across the farm supply chain could be incorporated. At present there is a limit to how data from say a suckler farm that bred an animal is shared with a finisher of the animal – what has the animal eaten, when was it weaned, any potential perturbations to growth, breeding history of the sire and dam etc. Each of these attributes will impact on the potential efficiency and management decisions further down the chain within the finishing herd and could serve to optimise finishing system efficiency. All these data can also be analysed to identify different stressors within and across systems (for example – weather perturbations from recent times). Such consistency in the key animal, system attributes farmers are recording and benchmarking will help the industry develop the knowledge and tools to drive efficiency and make Scottish beef brand sustainable.

46. Do you see a continuing role for the Scottish Rural Network (SRN) and, if so, do you agree that its current aims and objectives should be maintained during the transition period?

Do you see a continuing role for the SRN and, if so, do you agree that its current aims and objectives should be maintained during the transition period?
SRUC believe there is a strong need for networking and knowledge exchange within the rural sector given the wide range of information sources and providers and the risk of a lack of a joined up approach. The need for rural communities and businesses to be fully informed about policy development and to have the opportunity to shape policy and seek advice and help, will continue to be essential. The SRN will potentially have an even more crucial role to play in supporting inclusion, and economic and social innovation, across rural Scotland so it is essential it provides a complete coverage of the resources and information available. However the current SRN web site does not currently provide a comprehensive sign posting role with omissions in several key areas and lack of visibility of other important initiatives. The Scottish KTIF scheme is highlighted however no mention or link to the main activities funded under this initiative are provided including; Scotland’s Monitor Farm Programme, the NE Farm Profit Programme, Potato SPOT farms, KTIF projects and several SNH initiatives. These projects are currently co-ordinated by the Monitor Farm Development Group but this group lack a common web site where all these initiatives can be reached. This hub capability could be a useful addition to the SRN web site. There also examples of where the SRN web site (https://www.ruralnetwork.scot/advice-support) does not currently give sufficient prominence to key initiatives for instance on the Advice page the links to the RISS network currently takes precedent over the FAS service despite the latter being an order of magnitude greater in the scale of funding and the services offered. Similar issues arise with the News section of the web site which contains no feeds from the FAS programme. Also with the development of more professional websites for various aspects of the SRDP such as FAS / Monitor Farms/ RISS etc there is a growing risk of duplicating effort. Instead the SRN sites activities should be re-focused to a signposting role and should not be attempting to provide detailed information where this is available elsewhere. As it stands currently the Scottish Rural Network provides useful signposting services and SRUC recommends that this role should be maintained and extended. There is a need for one web site to be the definitive signposting site for all publicly funded rural support and advice and this could be the SRN but improvements are recommended. The layout, structure and content would benefit from review to ensure the balance of coverage and the linkages reflects the scale and importance of delivery of the respective programmes for Scottish Government.

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Julian Bell

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