Environment, Food and Rural Affairs CommitteeWritten evidence submitted by the Agricultural Law Association (ALA)
ALA is the country’s largest inter-professional organisation focused on rural business with more than 1,000 members—lawyers, surveyors, accountants, farm business consultants and other professional advisers—across the UK. We are affiliated to the European Council for Rural Law which is composed of similar national associations in other Member States and elsewhere in Europe. For more information see www.ala.org.uk.
ALA is an apolitical association and our comments, therefore, concentrate on practical issues arising out of the proposals and questions raised in the inquiry.
This response has been compiled by an ALA Working Group consisting of the following:
Alex Carson-Taylor—rural business consultant, Alex Carson-Taylor Ltd., Shropshire;
Dr. Nerys Llewelyn Jones—solicitor and principal, AgriAdvisor, Pumsaint.
We focus our comments on the specific questions referred to on the Committee’s relevant webpage dated 3rd July 2012.
How effective has the RCPU been in engaging with rural communities?
The visibility of the RCPU has been significantly lower in rural communities than was the CRC. Experience shows a general lack of awareness of RCPU by end-users.
There has been a limited successful engagement. The feeling is of waiting for initiatives to “get off the ground”, eg Rural Business Finance Forum has potential but irregular/cancelled meetings are not delivering the engagement process.
Rural Hubs provide excellent communications on events/services available to local areas, but there is a distinct online bias.
There has been little on-the-ground promotion of the Rural and Farming Network other than launch. It is often incorporated into other organisations which leads to a blurring of identity/purpose.
Has the RCPU done enough to ensure the voices of the hardest to reach can be heard?
Predominantly e-based communication has limited access to RCPU work largely to online enabled and e-literate clients.
Use of sizeable attachments on e-communications emphasises requirement for suitable bandwidth connection to make use of online functions and disadvantages those without.
There is little printed coverage of RCPU work in traditional farming press that would be typically read by majority of prospective client base, which might be remedied by greater communication with those organs.
How effective has the RCPU been in engaging with other government departments, for example, providing challenge and ensuring policy is “rural proofed”?
The intentions are good and deserve credit. Cross-departmental vehicles—such as the RBFF cited above to address rural-specific finance issues—provide the vital rural viewpoint.
Another example is the good engagement with BIS—the Business Link website is a comprehensive source of farming business regulations, advice and links, although as noted the online concentration may exclude some potential users.
By contrast, any impression of a “silo mentality” within departments risks limiting the ability for rural proofing to have a significant impact on non-DEFRA policies. Evidence outside DEFRA is still of a lack of appreciation of basic specific rural modalities.
Should “rural proofing” be subject to external review? How might this work?
If the stakeholder engagement process is successful the RCPU should be able to formulate the correct “rural proofing” policies without the need for review which has the potential for adding another layer of administration and potentially creating a disconnect between stakeholders and policy formation.
Success of the above depends on proactive management of the RCPU with clear outcomes identified and implemented.
The RCPU is the Government’s “centre for rural expertise”
Is it sufficiently resourced to carry out this function?
It is difficult to comment meaningfully without sight of flexible staff resourcing requirements and the actual/expected workload.
The activity of the unit must be managed to ensure that its stated objectives are achieved. The DEFRA senior responsible owner for the RCPU must be supported at board and ministerial level to ensure that the RCPU has the cross-departmental access required to successfully deliver the Government’s rural policies.
Is the RCPU transparent and open?
It appears to be willing to be transparent and open, however lack of awareness of RCPU by end-user and low levels of engagement can give the impression of a “top-down” management approach rather than the underlying support at which it aims.
Independence and impartiality are equally important as transparency and openness in operational activity.
How should the effectiveness of the RCPU be measured?
It is important to identify and measure Quality/Cost/Delivery metrics to enable clear understanding of the outcomes delivered by the RCPU.
Clear and accountable management reporting structure key to help ensure that the unit remains focused on delivering its objectives.
Is there still a role for an independent Rural Advocate?
If the RCPU engages comprehensively with stakeholder groups and this is reflected in suggested policy outcomes then the role of an independent advocate is less crucial.
If it does not successfully engage with stakeholders, an independent advocate may be of use as single rallying point. However, if truly independent, it must be questioned whether this would result in any greater level of influence on policy than any other large sector organisations eg CLA, NFU?
Rural Grants and Funding
How effective will the measures announced in the Rural Economy Growth Review be in stimulating sustainable growth in the rural economy?
This is a potentially high-impact suite of measures which would benefit rural SMEs significantly. However, achieving the desired outcomes will be a function of delivery rather than of the measures themselves.
“Cherry picking” politically convenient or popular elements only will degrade the overall effectiveness of the proposals resulting in reputational risk to the strategy and limited impact when delivered.
Whilst there needs to be a uniform application and implementation of measures across England, flexibility is needed to adapt to local environmental and market conditions.
An active role needs to be taken (ie marketing and facilitation) in raising awareness of the measures available to ensure take up and utilisation of these opportunities.
What other measures might the Government have used?
Agri-food sector: in addition to stated aims, competiveness through operational efficiency is key to successfully operating in the world market. Although much advice is available online a face-to-face advisory service would significantly increase the potential for rural SMEs to increase their ability to compete with others in the UK and internationally by optimising the way businesses are run.
Whilst support for business start-up and in its early years is vital, there should also be emphasis on assistance for existing businesses to get to the next level in terms of targeting wider market/higher profits so that they can in turn employ more staff. Advisers need to have sector-specific experience; general business advisers are not necessarily well-equipped to deal with rural issues.
It is important to note that this is not the same as Business Link/UKTI advisers advocating innovation/export, but is a fundamental review of how a business can be run more efficiently. The Manufacturing Advisory Service already provides this function for the manufacturing sector.
We support the proposal to review planning policy and would encourage attention to be given to facilitating growth and business development in rural areas. Facilitators should assist businesses to understand and apply new policy.
How will uncertainty over the content and timetable for reform of Pillar II of CAP impact on the rural economy?
There is already a significant potential impact on land-based rural business as uncertainty influences a number of key business factors including:
Strategic land-use planning which will ultimately have an impact on UK production and price levels.
Ongoing capital investment programmes.
Business viability and structure and consideration of the need for change and development.
Unknown opportunities/challenges may arise from with Pillar 2 reforms.
Potential changes in the regulatory burden to access P2 funding.
Government Policy
The Government is preparing a Rural Policy Statement. What should be in it?
Reaffirmation that all elements of the REGR will be delivered and the key themes will form the backbone of ongoing policy formation.
Provision of an advisory service (which can be through one of the pre-existing delivery channels) to specifically address business efficiency in the rural/land-based sector, helping to enable UK-based business to compete within the global marketplace.
Commitment to fully engage with all stakeholder groups and to ensure a streamlined communication process.
Overall commitment to growing the rural economy with clear understanding of developing economic, social and environmental value throughout the agri-food chain.
Ministers’ stated rural priorities are housing, broadband, services, transport and fuel. Are these the correct priorities for the Government to focus on?
In the main, yes, since they represent key infrastructure items to improve access across the value chain. However, all elements, not just some of them, must be delivered to have the desired impact.
If not, what others should the Government prioritise?
Replication of business services seen elsewhere in the economy to improve business performance, innovation and competitiveness.
Do the measures announced in DEFRA’s Uplands Review do enough to support sustainable hill farming?
As per REGR, all elements of the review, and not just some of them, must be deployed to ensure that the desired outcomes are achieved. Partial implementation will result in compounding instability within the upland sector with the resultant negative consequences.
September 2012