A11 Views of interested organisations.pdf - Agra CEAS Consulting
A11 Views of interested organisations.pdf - Agra CEAS Consulting
A11 Views of interested organisations.pdf - Agra CEAS Consulting
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MID-TERM EVALUATION<br />
OF THE<br />
RURAL DEVELOPMENT PLAN<br />
FOR WALES<br />
Appendix 11 – <strong>Views</strong> <strong>of</strong> Interested Organisations<br />
Final report for<br />
Welsh European Funding Office<br />
Submitted by<br />
<strong>Agra</strong> <strong>CEAS</strong> <strong>Consulting</strong> Ltd.<br />
Telephone: *44 (0)1233 812181<br />
Fax: *44 (0)1233 813309<br />
E-mail: info@ceasc.com<br />
http://www.ceasc.com/<br />
2114/BDB/November 2003
MID-TERM EVALUATION OF THE RDP WALES<br />
Contents<br />
APPENDIX 11: VIEWS OF INTERESTED ORGANISATIONS.................................................................... 1<br />
<strong>A11</strong>.1. LIST OF ORGANISATIONS SUBMITTING RESPONSES................................................................................... 1<br />
<strong>A11</strong>.2. IMPACT OF THE RDP................................................................................................................................ 2<br />
<strong>A11</strong>.2.1. Farm businesses............................................................................................................................... 2<br />
<strong>A11</strong>.2.2. Welsh family farm ............................................................................................................................ 3<br />
<strong>A11</strong>.2.3. Farm amalgamation......................................................................................................................... 4<br />
<strong>A11</strong>.2.4. Non-agricultural businesses ............................................................................................................ 5<br />
<strong>A11</strong>.2.5. Environment..................................................................................................................................... 7<br />
<strong>A11</strong>.2.6. Wider rural economy ....................................................................................................................... 8<br />
<strong>A11</strong>.3. PERFORMANCE OF THE RDP.................................................................................................................... 9<br />
<strong>A11</strong>.3.1. Addressing the needs <strong>of</strong> rural Wales................................................................................................ 9<br />
<strong>A11</strong>.3.2. Operation <strong>of</strong> the RDP ...................................................................................................................... 9<br />
<strong>A11</strong>.3.3. Administration <strong>of</strong> the RDP............................................................................................................. 11<br />
<strong>A11</strong>.3.4. Financial balance .......................................................................................................................... 12<br />
<strong>A11</strong>.3.5. Gaps in the RDP ............................................................................................................................ 12<br />
<strong>A11</strong>.3.6. Interaction with other schemes/programmes ................................................................................. 13<br />
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MID-TERM EVALUATION OF THE RDP WALES<br />
Appendix 11: <strong>Views</strong> <strong>of</strong> <strong>interested</strong> <strong>organisations</strong><br />
A wide range <strong>of</strong> <strong>organisations</strong> expected to have an interest in the RDP Wales and its operation were<br />
canvassed for their views. This list was drawn up following a visit by members <strong>of</strong> the evaluation team<br />
to the Royal Welsh Show on the 23 July 2003 and supplemented by suggestions made by other<br />
interviewees during the course <strong>of</strong> the research.<br />
Representatives from <strong>organisations</strong> were either interviewed face-to-face by members <strong>of</strong> the<br />
evaluation team or sent a letter and response form asking for their written views. In some cases<br />
<strong>organisations</strong> submitted response forms and were also spoken to personally.<br />
This Appendix lists those <strong>organisations</strong> submitting a response and then summarises the responses by<br />
topic.<br />
<strong>A11</strong>.1. List <strong>of</strong> <strong>organisations</strong> submitting responses<br />
Responses were received from the following ten <strong>organisations</strong>.<br />
• Farming Union <strong>of</strong> Wales • NFU Cymru<br />
• Countryside Council for Wales • Environment Agency<br />
• The National Trust Wales • Country Land and Business Association<br />
• RSPB • PLANED<br />
• Dry Stone Walling Association • PTP Quality Training<br />
Interested <strong>organisations</strong> were requested to provide their views on the impact <strong>of</strong> the RDP on the<br />
following:<br />
• farm businesses;<br />
• the survival <strong>of</strong> the Welsh family farm;<br />
• farm amalgamation;<br />
• non-agricultural businesses;<br />
• the environment. and;<br />
• providing support to the wider rural economy.<br />
They were then asked to comment on performance aspects <strong>of</strong> the RDP as follows:<br />
• the way in which the RDP addresses the needs <strong>of</strong> rural Wales;<br />
• the operation <strong>of</strong> the RDP through a suite <strong>of</strong> different schemes and measures;<br />
• administration <strong>of</strong> the RDP and its schemes;<br />
• financial balance between schemes;<br />
• gaps in the coverage provided by the RDP. and,<br />
• co-ordination <strong>of</strong> the RDP with other schemes/programmes.<br />
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MID-TERM EVALUATION OF THE RDP WALES<br />
The views on each <strong>of</strong> the above topics are considered below.<br />
<strong>A11</strong>.2. Impact <strong>of</strong> the RDP<br />
<strong>A11</strong>.2.1. Farm businesses<br />
The impact <strong>of</strong> the RDP on farm businesses has been obfuscated by the impact <strong>of</strong> the foot and mouth<br />
disease (FMD) outbreak in 2001 during which Wales was especially hard hit. This obfuscation is tw<strong>of</strong>old,<br />
firstly the outbreak delayed the introduction <strong>of</strong> Farming Connect as farm visits were prevented.<br />
As a gateway to the Farm Improvement Grant and the Farm Enterprise Grant this delayed<br />
promotion <strong>of</strong> these schemes. Secondly, FMD had a significant negative impact on farm incomes 1 and<br />
this overshadows any other changes in farm income at this time that might have also been occurring.<br />
The result <strong>of</strong> the FMD outbreak is therefore to delay any impact <strong>of</strong> the RDP on farm businesses<br />
which makes it a little early to comment at this stage. It should, however, be possible to comment<br />
on the impact on farm businesses by the time <strong>of</strong> the ex-post evaluation.<br />
The Countryside Council for Wales (CCW) and the Country Land and Business Association (CLA)<br />
point out that the RDP is one <strong>of</strong> many initiatives in the agricultural sector and that its impact is<br />
therefore likely to be dwarfed by the Common Agricultural Policy. CCW adds that structural<br />
change in the wider UK economy adds to this background noise. That said, the Farming Union <strong>of</strong><br />
Wales (FUW) claims that there is anecdotal evidence to suggest that farmers in receipt <strong>of</strong> monies<br />
under Tir Mynydd, Tir G<strong>of</strong>al and the Organic Farming Scheme, but not directly affected by FMD (and<br />
thus compensated), were able to maintain some form <strong>of</strong> positive cash flow as a result <strong>of</strong> the RDP<br />
which may have helped them to remain viable over this difficult period. The Environment Agency<br />
(EA) adds that logically any funding channelled to farmers will assist the farm business to some<br />
degree, whether this can be detected or not, although it notes that the schemes are not universally<br />
available and impact will therefore be variable.<br />
NFU Cymru adds that diversification from a position <strong>of</strong> income weakness is not an ideal platform for<br />
development and the implication is therefore that the potential impact <strong>of</strong> the RDP may have been<br />
mitigated for this reason.<br />
The National Trust Wales and the CCW draw on evidence from the Tir Cymen pilot agrienvironmental<br />
scheme to suggest that agri-environment schemes do, in general, have a positive<br />
impact on farm businesses. On this basis, agri-environmental schemes under the RDP (specifically Tir<br />
G<strong>of</strong>al, but also the environmental enhancement element <strong>of</strong> Tir Mynydd) are likely to be beneficial for<br />
farm businesses. The extra income that can be generated by those in the farm household not fully<br />
employed on the farm through contracting work associated with agri-environment schemes, for<br />
example dry stone walling, also contributes to improved farm household income.<br />
1<br />
NFU Cymru informs that average farm income in Wales fell to £6,100 in 2000/01, although this had recovered to £10,100 by 2002/03.<br />
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MID-TERM EVALUATION OF THE RDP WALES<br />
PLANED explain that the impact <strong>of</strong> the RDP on farm businesses is potentially good, but that there<br />
are problems with red tape and bureaucracy which prevent many farmers, especially smaller scale<br />
family farmers, from accessing funding.<br />
While not a comment on the impact <strong>of</strong> the RDP on farm businesses per se it is interesting to note<br />
that PTP Quality Training have noticed a significant decrease in requests for Agricultural Skills<br />
Training in the past year. This does not suggest that farmers are being assisted towards taking<br />
training courses by schemes under the RDP. This may be the result <strong>of</strong> these options being in many<br />
cases introduced late. Alternatively, it could be a reflection on the health <strong>of</strong> farm businesses in that<br />
farmers do not feel able to sign up for training courses as a result <strong>of</strong> either a lack <strong>of</strong> funds or a lack <strong>of</strong><br />
time. In either case it does not suggest that the RDP is facilitating training. PTP Quality Training<br />
conclude that, coupled with a decrease in health and safety visits to farms over the last 18 months,<br />
disasters are waiting to happen as a result <strong>of</strong> a poor skill set.<br />
Tir Mynydd, covering over 80% <strong>of</strong> farmers in Wales, is the most important RDP funded scheme and<br />
as such is a major contributor to maintaining farm businesses. However, NFU Cymru explain that<br />
many farmers in LFAs are disgruntled about the re-deployment <strong>of</strong> resources under Tir Mynydd which<br />
has resulted in a significant adverse impact on many LFA farmers in Wales (especially the medium<br />
sized upland (but not mountain) farms, according to the National Trust Wales). In particular they<br />
are concerned about the decline in the ‘safety net’ mechanism which they feel has exacerbated the<br />
financial difficulties faced by farmers in Wales.<br />
The impact <strong>of</strong> modulation under the Agenda 2000 reforms to the CAP has had an impact on all<br />
farmers in Wales by removing 2.5% <strong>of</strong> subsidy in 2001/02, 3.5% in 2002/03 and which is scheduled to<br />
increase to 4.5% by 2005/06. NFU Cymru claim that the distributional impact <strong>of</strong> this, in that all farm<br />
payments are modulated, but not all farms are able to claim money back through the RDP, is a<br />
source <strong>of</strong> frustration to the industry. This distributional impact is compounded by the fact that<br />
money modulated in 2001 and 2002 is only now being returned to farmers.<br />
<strong>A11</strong>.2.2. Welsh family farm<br />
The notion <strong>of</strong> a Welsh family farm is widely held to be a political construct rather than a tangible<br />
entity. It was pointed out that the importance <strong>of</strong> the notion <strong>of</strong> the Welsh family farm is heavily<br />
linked to devolution and the fact that agriculture is one <strong>of</strong> the relatively few areas where the Welsh<br />
Assembly Government has significant devolved authority. The CLA does not have a definition <strong>of</strong><br />
Welsh family farm and believes that most farms in Wales could be classified in this manner.<br />
The NFU Cymru believes that economic pressure on the industry is reducing the number <strong>of</strong> viable<br />
family farms in Wales. In the opinion <strong>of</strong> this organisation, Tir Mynydd has worked against smaller<br />
family farms through the imposition <strong>of</strong> stocking density limits. They believe that these farms have<br />
historically had to stock at high densities to ensure viability and they do not have the economies <strong>of</strong><br />
scale to retain viability at lower stocking densities. It is not felt that Tir G<strong>of</strong>al <strong>of</strong>fers an opportunity<br />
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MID-TERM EVALUATION OF THE RDP WALES<br />
to these farms because the management restrictions would compromise production levels. This<br />
view is shared by RSPB Cymru.<br />
However, this situation may have been at least partially addressed by the change in Tir G<strong>of</strong>al<br />
selection criteria, a change made, at least in part, in order to allow entry to what the CCW believes<br />
to be family farms previously excluded for this reason (it was felt that small farms were able to access<br />
the scheme because their farming practices were <strong>of</strong>ten already compatible with scheme management<br />
prescriptions and large farms were able to access the scheme through making relatively small changes<br />
over relatively large areas). The CCW state that the current scoring system tends to favour farms in<br />
the 50 to 200 hectares range as a result <strong>of</strong> points being awarded for each farm enterprise. The<br />
award <strong>of</strong> extra points for young farmers is also felt to favour farms with a successor in place.<br />
The CCW also point out that the allocation <strong>of</strong> extra resources to young farmers under the Farm<br />
Investment chapter <strong>of</strong> the RDP (i.e. FIG and FEG) should also have a positive impact on the survival<br />
<strong>of</strong> the family farm. In the view <strong>of</strong> the CCW, however, the RDP lacks a coherent approach to this<br />
issue with the application <strong>of</strong> different minimum size criteria in Tir Mynydd and Tir G<strong>of</strong>al and the<br />
differential treatment <strong>of</strong> young farmers from scheme to scheme. It is felt that this results from the<br />
drafting <strong>of</strong> the RDP prior to the Farming for the Future document.<br />
Part <strong>of</strong> providing support to Welsh family farms is likely to involve supporting young farmers and the<br />
Farming Union <strong>of</strong> Wales is disappointed that the RDP did not incorporate explicit measures to this<br />
effect. The FUW believes that with the average age <strong>of</strong> farmers in Wales increasing there are fewer<br />
young farmers willing to enter the industry or take over the family business. They inform that<br />
representatives from the major banks present at the Royal Welsh Show suggested that up to 59% <strong>of</strong><br />
farms now had no successor as young people move away to pursue more lucrative careers in other<br />
sectors (a view also held by PTP Quality Training). This so-called ‘succession gap’ has apparently<br />
been widening in recent years and this evidence therefore suggests that the RDP has failed to have an<br />
impact on the long-term sustainability <strong>of</strong> the family farm. However, it should be noted that the<br />
‘succession gap’ may have widened less than it would have done in the absence <strong>of</strong> the RDP, but this is<br />
not a testable hypothesis.<br />
PLANED feel that the bureaucracy associated with the RDP schemes prevents many farms (and they<br />
emphasise particularly small family farms) from accessing funding. That said, the National Trust<br />
Wales view is that RDP schemes such as Tir Mynydd, Tir G<strong>of</strong>al and the Organic Farming Scheme<br />
have been and remain vital for the continuing survival <strong>of</strong> family farms.<br />
<strong>A11</strong>.2.3. Farm amalgamation<br />
Although the RDP has, in the opinion <strong>of</strong> the Farming Union <strong>of</strong> Wales, made a contribution to the<br />
viability <strong>of</strong> farms in Wales, the underlying economic position and the low market returns experienced<br />
over the last few years has resulted in the loss <strong>of</strong> farming families in Wales and the subsequent<br />
amalgamation <strong>of</strong> farms. Three and a half thousand IACS registered holdings have disappeared in<br />
Wales between 1997 and 2003 and this loss <strong>of</strong> farming families is likely to have impacts in the wider<br />
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MID-TERM EVALUATION OF THE RDP WALES<br />
rural economy in terms <strong>of</strong> spend and also in terms <strong>of</strong> the viability <strong>of</strong> schools, churches and the Welsh<br />
language and culture. It is not felt that the RDP has had a sufficient impact to make much difference<br />
to this general trend. PLANED refer to the impact <strong>of</strong> the RDP on farm amalgamation simply as<br />
marginal. The CCW note that the whilst they expect the RDP to slow down the trend in farm<br />
amalgamation, the scale <strong>of</strong> the programme is too small to have a major impact given the other forces<br />
involved, a view also subscribed to by the Environment Agency.<br />
The Environment Agency believe that farm amalgamation in the dairy sector is a particular problem.<br />
It claims that dairy farmers buy or lease additional quota and, for convenience, move more cows<br />
onto the home farm thus increasing environmental pressure at this site. At the same time, areas<br />
where the quota is leased from can then become under-grazed, which also has negative<br />
environmental implications.<br />
In contrast, NFU Cymru feel that farm amalgamation has helped some farming businesses to remain<br />
viable and to generate sufficient income to retain farming jobs that would otherwise have been lost.<br />
However, these gains must surely be at the expense <strong>of</strong> farms going out <strong>of</strong> business and it is difficult<br />
to see how the net effect on employment could be anything other than neutral at best. The NFU<br />
Cymru do add that farm amalgamation does reduce the opportunity for new entrants and<br />
undermines the fabric <strong>of</strong> rural communities. The impact <strong>of</strong> the RDP on farm amalgamation, however,<br />
is not stated.<br />
The National Trust Wales did not comment on the impact <strong>of</strong> the RDP on farm amalgamation, but<br />
they feel that amalgamation is not the way forward and that farms should diversify income streams<br />
rather than increasing scale and becoming solely reliant on food production. It is NTW policy to try<br />
to avoid farm amalgamations where possible. In contrast, PTP Quality Training believe that it is<br />
amalgamated farms which have the greater need to diversify as labour demand is increasingly met by<br />
machinery and not by family labour.<br />
<strong>A11</strong>.2.4. Non-agricultural businesses<br />
Any policy initiative similar to the RDP will inevitably create jobs related to the implementation <strong>of</strong><br />
the schemes themselves. These positions include, inter alia, scheme administrators and farm level<br />
consultants (although the National Trust Wales add that the latter are only <strong>of</strong> benefit to farmers if<br />
they are producing useful Farm Business Development Plans). Aside from this inevitable impact, the<br />
NFU Cymru claim that there is some evidence <strong>of</strong> additional jobs and income being generated in<br />
other industries linked to agriculture as a result <strong>of</strong> the RDP. However, the organisation questions<br />
the extent and permanency <strong>of</strong> the jobs created.<br />
The Farming Union <strong>of</strong> Wales states that agriculture is still the cornerstone <strong>of</strong> the rural economy,<br />
despite its relatively low contribution to GDP, and as such the multiplier effect <strong>of</strong> money paid out to<br />
rural businesses as a result <strong>of</strong> the RDP is substantial. Schemes within the RDP, such as Tir G<strong>of</strong>al,<br />
<strong>of</strong>fer opportunities for conservation contractors, although the impact <strong>of</strong> this through the RDP is<br />
5
MID-TERM EVALUATION OF THE RDP WALES<br />
more geographically dispersed than that recorded as a result <strong>of</strong> Tir Cymen 2 . All responding<br />
<strong>organisations</strong> agree that the RDP is likely to create employment opportunities for conservation<br />
contractors.<br />
The CCW expects Tir G<strong>of</strong>al to produce a similar impact to Tir Cymen in terms <strong>of</strong> impact on nonagricultural<br />
businesses, albeit watered down by the more dispersed nature <strong>of</strong> the scheme. The<br />
organisation adds that similar results would be expected from other schemes with a high capital<br />
expenditure element (i.e. FIG and FEG). Schemes with more emphasis on annual management<br />
payments, such as Tir Mynydd, are expected to have a less marked effect.<br />
The NFU Cymru also reports a positive impact on the tourist sector, though adds that tourism is not<br />
a panacea for a struggling sector. The Farming Union <strong>of</strong> Wales adds that some areas <strong>of</strong> Wales are<br />
now saturated as far as tourism is concerned and that this is having a depressing impact on the<br />
available revenue. It is also felt that the infrastructure in parts <strong>of</strong> Wales is not able to cope with<br />
increased levels <strong>of</strong> tourism. Finally, one <strong>of</strong> the main attractions <strong>of</strong> Wales as a tourist destination is<br />
the isolation and ‘wildness’ and this is not compatible with an ever increasing tourist burden.<br />
PTP Quality Training point out that whilst the RDP has created opportunities for rural businesses,<br />
whether these can be taken or not does depend on location. There are apparently issues relating to<br />
planning consent, especially in National Parks. The example <strong>of</strong> the Bluestone project is provided<br />
which, although it has gained the support <strong>of</strong> the County Council in Pembrokeshire, is being held up<br />
by the concerns <strong>of</strong> the National Park. If this project were to go ahead it would create 600 jobs.<br />
The Country Land and Business Association add that in their experience a lot <strong>of</strong> rural businesses<br />
have planning applications turned down, <strong>of</strong>ten because the Highways Agency claim that the local<br />
infrastructure is not adequate to deal with it. Also related to this issue, some applicants for planning<br />
permission are being told that they can only obtain permission for one cottage if they close their<br />
rural business. To this end it is possible that FEG has been hampered by the planning processing,<br />
although the CLA have not actually carried out research into this issue.<br />
The Dry Stone Wall Association comment that the implementation <strong>of</strong> Tir G<strong>of</strong>al could be hampered<br />
by low rates <strong>of</strong> grant as far as dry stone walling work is concerned. Grants for dry stone walling<br />
under Tir G<strong>of</strong>al are £18 per square metre, the same level as was available in the late 1980s under the<br />
Environmentally Sensitive Area scheme. This figure is actually lower than the £25 per square metre<br />
that is still available for the remaining Tir Cymen agreements. The Association also points out that<br />
the cubic bulk <strong>of</strong> a wall is not considered and therefore a wider wall requiring more work is eligible<br />
for the same grant as a narrower wall. Paying a flat rate also means that there is no link between the<br />
grant aid and the actual cost <strong>of</strong> the work. There is a suggestion that some recipients <strong>of</strong> grant aid for<br />
walling are carrying out the works themselves, in some cases to an inadequate standard, in order to<br />
save costs.<br />
2<br />
The CCW comment that expenditure <strong>of</strong> £5 million on Tir Cymen led to the creation <strong>of</strong> 200 full-time job equivalents, a substantial<br />
number <strong>of</strong> which were created <strong>of</strong>f-farm in the contracting and supply industries.<br />
6
MID-TERM EVALUATION OF THE RDP WALES<br />
<strong>A11</strong>.2.5. Environment<br />
The CCW explains that disaggregating the various policy influences on the environment is extremely<br />
complex. In this context it should be recalled that the RDP is dwarfed financially, and hence in terms<br />
<strong>of</strong> influence, by, amongst other policy initiatives, the CAP. The Farming Union <strong>of</strong> Wales state that<br />
the increasing raft <strong>of</strong> environmental legislation (EU and national) is likely to have a far greater impact<br />
on the environment than the RDP. However, the CCW consider it likely that the RDP has led to<br />
some positive environmental benefits, although whether these are always manifested will depend on<br />
the influence <strong>of</strong> other factors at particular locations.<br />
Assessing the environmental impact <strong>of</strong> the RDP is further hampered by the fact that a substantial<br />
number <strong>of</strong> the indicators listed within the Plan are, in the view <strong>of</strong> the CCW, output rather than<br />
outcome related. This is thought likely to result in a reduced emphasis on collecting the type <strong>of</strong><br />
information necessary for a full and systematic evaluation <strong>of</strong> the environmental impacts <strong>of</strong> policy.<br />
The National Trust Wales adds that the failure to carry out research into an environmental baseline<br />
makes it difficult to see how objective evidence <strong>of</strong> environmental improvement might be gathered.<br />
Results from Tir G<strong>of</strong>al environmental monitoring are not yet available, but the CCW believes that<br />
the scheme is having a noticeable impact on the reintroduction <strong>of</strong> arable cropping in parts <strong>of</strong> mid-<br />
Wales. RSPB Cymru also believes that Tir G<strong>of</strong>al has resulted in important environmental benefit,<br />
especially in terms <strong>of</strong> landscape improvement. The CCW feel that this impact is bolstered by the<br />
existence <strong>of</strong> other RDP schemes including Tir Mynydd, and the introduction <strong>of</strong> new technology such<br />
as ‘crimping’ <strong>of</strong> cereal silage. NFU Cymru also feel that Tir G<strong>of</strong>al is delivering environmental benefit,<br />
although they believe that a part-farm scheme would complement the whole-farm approach by<br />
allowing access to those farmers unable to commit the whole farm. However, RSPB Cymru strongly<br />
supports the whole farm approach.<br />
Research on the environmental impact <strong>of</strong> Tir Mynydd has been undertaken for the CCW and this<br />
suggests that in 15% <strong>of</strong> cases there was an intention to change from pure-bred to cross-bred ewes 3 .<br />
This change may have positive implications for the management <strong>of</strong> unimproved hill land because<br />
traditional breeds are generally better adapted to adverse weather conditions and poorer quality<br />
herbage.<br />
The CCW feels that the small average size <strong>of</strong> woodland under the Farm Woodland Premium Scheme<br />
may reduce the environmental potential <strong>of</strong> the woodlands created. It should be noted that the<br />
Forestry Commission have carried out a review <strong>of</strong> the FWPS and the Woodland Grant Scheme and<br />
in future these will be targeted more closely in line with the priorities set out in the Woodland for<br />
Wales document.<br />
3<br />
This was the result <strong>of</strong> a relaxation in the requirement to stock pure-bred flocks.<br />
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MID-TERM EVALUATION OF THE RDP WALES<br />
The Farming Union <strong>of</strong> Wales point out that environmental concerns may actually be hindering the<br />
RDP and hence the overall impact that it might have. They point to what they term overzealous<br />
environmental protection regulations, for example, restrictive planning policies, which might hamper<br />
schemes such as FEG.<br />
The Environment Agency stated that whilst there may be positive environmental impacts stemming<br />
from the RDP, the issue <strong>of</strong> water pollution has been virtually ignored. The point was made that the<br />
disparate nature <strong>of</strong> agreements under Tir G<strong>of</strong>al does not necessarily present an opportunity to<br />
improve water quality in a catchment area. This compares unfavourably with the geographically<br />
concentrated approach taken under Environmentally Sensitive Areas and Tir Cymen. However, it is<br />
recognised that the proposed Entry Level agri-environment scheme could prove to be a step in the<br />
right direction.<br />
The EA also point out that a greater degree <strong>of</strong> integration between the RDP and other initiatives in<br />
Wales such as the Water Framework Directive and the Spatial Plan Wales would be beneficial.<br />
Community strategies could also be more integrated and more account could be taken <strong>of</strong> the State<br />
<strong>of</strong> the Environment Report for Wales in terms <strong>of</strong> identifying environmental priorities to address.<br />
Finally, the EA add that there are particular issues with regard to individual RDP schemes. Most<br />
notably it is felt that the synthetic pyrethroid sheep dip used by organic farmers under the OFS is<br />
actually more environmentally damaging 4 than the organophosphate dip used by conventional<br />
farmers 5 .<br />
RSPB Cymru believe that whilst the OFS has inherent environmental benefits, more could be done to<br />
enhance opportunities for wildlife in terms <strong>of</strong> biodiversity and farmland birds. Further, the<br />
organisation states that without conservation standards, organic farming will become increasingly<br />
intensive with a potential risk that the environmental benefits <strong>of</strong> organic farming systems, and the<br />
organic sector’s environmentally friendly image, could be jeopardised. RSPB Cymru considers that<br />
maintenance payments for organic production should be awarded contingent on organic producers<br />
meeting high environmental standards.<br />
<strong>A11</strong>.2.6. Wider rural economy<br />
NFU Cymru explain that although the wider rural economy is heavily dependent on the viability <strong>of</strong><br />
the agricultural sector, the confluence <strong>of</strong> the RDP with the lingering after effects <strong>of</strong> BSE, FMD, the<br />
strength <strong>of</strong> Sterling against the Euro, etc. makes it difficult to assess the wider impact <strong>of</strong> the Plan.<br />
The Farming Union <strong>of</strong> Wales also concludes that the presence <strong>of</strong> so many confounding factors makes<br />
it impossible to assess the wider impact <strong>of</strong> the RDP with any accuracy.<br />
4<br />
Synthetic pyrethroid has between 100 and 1,000 times the toxicity to aquatic fauna than organophosphate dips, although the latter are<br />
themselves highly toxic.<br />
5<br />
Many conventional farmers have also switched to synthetic pyrethroid in response to human health concerns associated with<br />
organophosphates.<br />
8
MID-TERM EVALUATION OF THE RDP WALES<br />
The National Trust Wales believe that Tir G<strong>of</strong>al and Tir Mynydd have provided employment<br />
opportunities for local people (especially through conservation contracting) and that there has<br />
therefore been benefit to the wider rural economy. However, the degree to which the RDP<br />
stimulates inward investment is not clear.<br />
The CCW expects a significant impact on the wider rural economy based on the organisation’s<br />
experience and research into the knock-on effects <strong>of</strong> the Tir Cymen pilot scheme (see above,<br />
Section <strong>A11</strong>.2.4 in particular).<br />
PLANED state that in theory the impact <strong>of</strong> the RDP in supporting the wider rural economy is<br />
excellent, although the organisation claims that the failure to build on LEADER I and LEADER II<br />
represents a missed opportunity.<br />
<strong>A11</strong>.3. Performance <strong>of</strong> the RDP<br />
<strong>A11</strong>.3.1. Addressing the needs <strong>of</strong> rural Wales<br />
The Farming Union <strong>of</strong> Wales feels that the extensive consultation which preceded the drafting <strong>of</strong> the<br />
RDP has resulted in a policy which goes a long way towards addressing the needs <strong>of</strong> rural Wales,<br />
with the exception <strong>of</strong> young farmers who would have benefited from installation aids. However, it is<br />
felt that the UK’s historic low commitment to agri-environment schemes resulted in a low budget<br />
allocation from the EU. This has had a significant impact on the range and size <strong>of</strong> schemes run under<br />
the RDP Wales.<br />
In contrast, the CCW feels that the fact that the RDP pre-dates other important policy documents<br />
(Farming for the Future in particular) makes it potentially difficult for it to address the needs <strong>of</strong> rural<br />
Wales fully. It is not entirely clear, in the CCW’s view, to what extent the overarching priorities <strong>of</strong><br />
the RDP are reflected in budgetary allocation. A stocktaking exercise <strong>of</strong> all the RDP schemes would<br />
be useful in assessing this issue in more detail.<br />
The National Trust Wales believes that the RDP is helping larger farms to increase pr<strong>of</strong>itability, but<br />
that smaller farms (between 100 and 200 acres (47 to 95 hectares) are not seeing such benefits.<br />
From the point <strong>of</strong> view <strong>of</strong> the wider rural economy this is not ideal as it is the smaller farms which<br />
are more linked in with other rural businesses and the local community. The RDP is also seen as<br />
bringing benefits in terms <strong>of</strong> making subsidies to the agricultural sector more acceptable to urban<br />
dwellers through the greater emphasis on the delivery <strong>of</strong> public goods in return for support.<br />
<strong>A11</strong>.3.2. Operation <strong>of</strong> the RDP<br />
The CCW feels that Tir G<strong>of</strong>al is very well integrated with other RDP schemes (through its links with<br />
the delivery <strong>of</strong> the forestry measures, the training measure and the public access component <strong>of</strong><br />
Article 33 6 ). It is felt that this is the result <strong>of</strong> the extensive consultation process that was undertaken<br />
6<br />
The fact that organic farmers can gain extra points when applying to Tir G<strong>of</strong>al might also be added to this list.<br />
9
MID-TERM EVALUATION OF THE RDP WALES<br />
before the scheme was introduced. Other elements <strong>of</strong> the RDP were put together in a shorter<br />
period <strong>of</strong> time and as such did not benefit from this exercise to the same extent.<br />
The degree <strong>of</strong> overlap between elements <strong>of</strong> RDP schemes means that substantial cross-checks are<br />
required in order to make appropriate deductions to avoid dual funding. Aside from increasing the<br />
need for administrative resources, this is thought to deter farmers from taking up a second scheme,<br />
especially where the area involved (and hence the financial benefit) is small.<br />
The recent investigation into the pan-European application <strong>of</strong> the Rural Development Regulation<br />
(Europe’s Rural Futures: Rural Development in an Enlarging European Union) concluded that a key<br />
element in the delivery <strong>of</strong> a quality rural development programme was sufficient investment in<br />
capacity building and training. The CCW believes that this investment is not evident in Wales to the<br />
extent that it could be and that delivery suffers as a result.<br />
Many <strong>organisations</strong> believe that the operation <strong>of</strong> the RDP is more bureaucratic than it need be 7 .<br />
PLANED comment that this is the result <strong>of</strong> the top down delivery through mainstream <strong>organisations</strong>,<br />
whilst PTP Quality Training and the National Trust Wales believe that Farming Connect, as a gateway<br />
to some RDP schemes, is too unwieldy as an entity. The National Trust Wales state that in their<br />
opinion farmers have lost faith in Farming Connect because the Farm Business Development Plans<br />
drawn up by consultants are not specific enough to the farms they are concerned with. These do<br />
not <strong>of</strong>ten lead to a grant, which is the sole reason that many farmers apply to Farming Connect in<br />
the first place. PTP Quality Training believe that the PLANED Whole Farm Support Scheme (the<br />
pilot scheme from which Farming Connect was developed) was superior as a working tool for<br />
farmers.<br />
In the opinion <strong>of</strong> the CLA, this bureaucracy <strong>of</strong>ten leads to farmers wishing to carry out grant assisted<br />
work carrying it out themselves, unaided, in order to avoid the restrictions imposed upon accepting a<br />
grant. The CLA feel that this drives projects that farmers really believe will be worthwhile in the<br />
long-term to be carried out unassisted and projects where the farmer is less sure to be grant-aided.<br />
It should be mentioned that Farming Connect has been heavily criticised by many contacts<br />
throughout this research. Farmers feel that the Farm Business Development Plans are not providing<br />
enough value to their businesses because they are all too <strong>of</strong>ten generic. There have also been cases<br />
<strong>of</strong> misleading advice brought to our attention. There is a perception that Farming Connect provides<br />
more support for on-farm consultants than it does for the farmer, the intended beneficiary. This<br />
follows early criticism <strong>of</strong> Farming Connect for the delays between farmer requests and consultant<br />
visits, although we note that this problem was addressed when it came to light. The Farming Union<br />
<strong>of</strong> Wales feels that Farming Connect is now more appreciated in the farming community as a result.<br />
7<br />
The CLA explain that this bureaucracy leads consultants to carry out Farming Connect business only when they have nothing else more<br />
lucrative to do.<br />
10
MID-TERM EVALUATION OF THE RDP WALES<br />
The Farming Union <strong>of</strong> Wales expressed the opinion that whilst Tir G<strong>of</strong>al was popular amongst<br />
farmers, the scheme tends to be restricted through the application approvals process to certain farm<br />
types. Specifically, and this is a view shared by RSPB Cymru, it is felt that low numbers <strong>of</strong> dairy farms<br />
qualify and where they do qualify they receive a relatively low share <strong>of</strong> the budget 8 . The<br />
determination <strong>of</strong> support on the income forgone procedure was also criticised and the FUW believes<br />
that an element <strong>of</strong> pr<strong>of</strong>it ought to be included in payments in order to make the schemes more<br />
attractive to farmers. Despite the above, the FUW does believe that the RDP provides a range <strong>of</strong><br />
opportunities to farmers and their families and that this is due in part to the operation through a<br />
range <strong>of</strong> schemes.<br />
The NFU Cymru agrees that a range <strong>of</strong> schemes makes it more likely that farmers are able to find<br />
relevant opportunities. However, the organisation sees a danger in spreading limited resources too<br />
thinly.<br />
The CLA explains that in their view many contractors will submit expensive quotes for work if they<br />
realise that it is going to attract a grant. This has the effect <strong>of</strong> providing an incentive to farmers to<br />
carry out work themselves, which prevents the benefits <strong>of</strong> some schemes from reaching the wider<br />
rural economy.<br />
<strong>A11</strong>.3.3. Administration <strong>of</strong> the RDP<br />
Whilst the Farming Union <strong>of</strong> Wales believes there have been limited problems associated with most<br />
<strong>of</strong> the schemes run under the RDP, it believes that this was inevitable. The close partnership<br />
between farmer representatives, the Welsh Assembly Government, CCW, the Welsh Development<br />
Agency, Forestry Commission, etc. has meant that these problems have been addressed and changes<br />
made where necessary.<br />
The NFU Cymru also recognises the role played by the close partnership, although adds that the lack<br />
<strong>of</strong> clear boundaries <strong>of</strong> responsibility at the ‘grass roots level’ between the Welsh Assembly<br />
Government and the Welsh Development Agency has caused problems for Farming Connect and<br />
hence in the delivery <strong>of</strong> FIG and FEG.<br />
The National Trust Wales comments that late payments have led to some loss <strong>of</strong> faith in RDP<br />
schemes. It also adds that there is a perception that bureaucrats are safeguarding their own<br />
positions through the RDP.<br />
The general lack <strong>of</strong> comment on the administration <strong>of</strong> the RDP is likely to reflect general satisfaction<br />
amongst responding <strong>organisations</strong>.<br />
8<br />
Analysis <strong>of</strong> data provided to the Welsh Assembly Government Agriculture and Rural Development Committee on the 7th November<br />
2001, highlighted that during the third application round, ‘there was little discernible change in the type <strong>of</strong> eligible application with the vast<br />
majority made up <strong>of</strong> sheep and beef units (89%) whilst the percentage <strong>of</strong> dairy farms continued to remain low (2.4%)’. In the opinion <strong>of</strong><br />
RSPB Cymru it is imperative that a balance is kept in the farm types accepted into the scheme in order to build long-term support amongst<br />
the agricultural community.<br />
11
MID-TERM EVALUATION OF THE RDP WALES<br />
<strong>A11</strong>.3.4. Financial balance<br />
The NFU Cymru believe that allocation <strong>of</strong> resources should be demand-led, but should relate to the<br />
direct and indirect benefits that flow as a result. A greater degree <strong>of</strong> knowledge <strong>of</strong> the wider impact<br />
<strong>of</strong> the RDP is therefore required in order to consider the issue <strong>of</strong> resource allocation. This is a view<br />
shared by the CCW, although they add that the current allocation <strong>of</strong> resources is very much a<br />
reflection <strong>of</strong> the measures existing prior to the RDP.<br />
The Farming Union <strong>of</strong> Wales recognises that the financial weight <strong>of</strong> the RDP falls on the Tir Mynydd<br />
scheme and believes, as does RSPB Cymru, that this is a vital socio-economic payment. In this<br />
organisation’s view these payments retain farmers in the uplands and as a result ensure that the more<br />
isolated communities remain viable. Whilst they believe that the WAG should attempt to negotiate<br />
a greater share <strong>of</strong> funding for the RDP, the FUW is content with the allocation <strong>of</strong> resources within<br />
the Plan.<br />
Given the relative absence <strong>of</strong> comments on this point it is understood that the majority <strong>of</strong><br />
<strong>organisations</strong> are content with the current allocation <strong>of</strong> funds within the RDP, at least based on<br />
current knowledge concerning relative impact.<br />
<strong>A11</strong>.3.5. Gaps in the RDP<br />
A number <strong>of</strong> <strong>organisations</strong> identified what they perceived as gaps in the coverage provided by the<br />
RDP. These are summarised below:<br />
• The Farming Union <strong>of</strong> Wales believes that the RDP should incorporate measures to encourage<br />
young farmers to remain in (and enter) the industry. An early retirement scheme, coupled with<br />
young farmer installation aids would help to address the perceived imbalance in the age structure<br />
within the industry. The organisation adds that it is known that younger farmers are more likely<br />
to take advantage <strong>of</strong> RDP schemes and to embrace diversification and therefore encouraging<br />
these farmers would be beneficial to the overall success <strong>of</strong> the RDP.<br />
• The NFU Cymru believes that a gap in coverage exists in that all farmers are subject to<br />
modulation, but not all are able to recover these funds through RDP schemes. The proposed<br />
Entry Level agri-environment scheme may address this concern.<br />
• The CCW and the Environment Agency both recognise the need to take greater account <strong>of</strong><br />
diffuse pollution and to assist the effective implementation <strong>of</strong> the Water Framework Directive.<br />
To this end both <strong>organisations</strong> support a ‘broad and shallow’ Entry Level agri-environment<br />
scheme 9 , as does RSPB Cymru.<br />
• RSPB Cymru believes that some geographical targeting <strong>of</strong> Tir G<strong>of</strong>al should be introduced in<br />
order to achieve further gains in respect <strong>of</strong> species recovery, large scale habitat restoration,<br />
management <strong>of</strong> common land and flood management.<br />
9<br />
The CCW adds that this should not compromise the OFS or Tir G<strong>of</strong>al. RSPB Cymru believes that such a scheme would underpin Tir<br />
G<strong>of</strong>al and would provide impetus towards the WAG’s vision <strong>of</strong> an innovative agri-food industry that would also create a Welsh<br />
countryside rich in biodiversity and wildlife.<br />
12
MID-TERM EVALUATION OF THE RDP WALES<br />
• The CCW believes that the application <strong>of</strong> Article 16 could assist with the restoration <strong>of</strong><br />
vegetation on areas <strong>of</strong> upland previously modified by heavy grazing (although not over-grazed<br />
according to the implied definition under the existing beef and sheep subsidy rules). The first<br />
indent <strong>of</strong> Article 22 <strong>of</strong> the Rural Development Regulation could be used to support traditional<br />
breeds and crop varieties. It is recognised that the first modification <strong>of</strong> the RDP in 2001<br />
introduced support for Welsh Black cattle, but the CCW believes that there is scope to broaden<br />
this approach still further. Additional use could also be made <strong>of</strong> Article 33 where currently only<br />
5 <strong>of</strong> 13 sub-measures are used. The FMD outbreak demonstrated how reliant the recreation<br />
and tourist industry is upon agriculture and the RDP does not currently address the wider<br />
economy as well as it might.<br />
• The National Trust Wales feels that the biggest gap in coverage is the fact that medium-sized,<br />
family farms are less able to attract support then either the smallest or the largest holdings. This<br />
is an issue that also concerned the CCW and hence the change in application scoring for Tir<br />
G<strong>of</strong>al applications. It is unclear from key organisation comments to what extent this remains a<br />
problem with regard to Tir G<strong>of</strong>al, or to what extent this is a problem for participation in other<br />
RDP schemes.<br />
• RSPB Cymru suggests that all RDP schemes should deliver baseline environmental standards.<br />
The organisation also believes that the environmental enhancement element <strong>of</strong> Tir Mynydd<br />
should be developed further to provide greater incentives to promote mixed farming practices.<br />
<strong>A11</strong>.3.6. Interaction with other schemes/programmes<br />
The Environment Agency and the CCW made clear the need to have a greater degree <strong>of</strong> integration<br />
between the RDP and other policy initiatives, and this seems to be especially the case with regard to<br />
the protection <strong>of</strong> water quality. RSPB Cymru, whilst recognising the progress to date in delivery <strong>of</strong><br />
the aspirations <strong>of</strong> the Farming for the Future document through the RDP, called for unspecified<br />
improvements to increase effectiveness in meeting these aspirations. The CCW and NFU Cymru<br />
add that the current funding arrangements whereby the EAGGF Guarantee and Guidance funds are<br />
both used to fund rural development is an administrative problem. The EU Commission appear to<br />
share this view and it is likely that the funding <strong>of</strong> rural development will be streamlined in the future.<br />
The Farming Connect scheme (whilst not itself RDP funded) was cited by the National Trust Wales<br />
and the CCW as being problematic, although for operational rather than philosophical reasons. It<br />
should be added that comments provided to us direct from farmers are less certain <strong>of</strong> the benefit <strong>of</strong><br />
this approach, even assuming that it worked more effectively.<br />
13