Submission on the Reform of Common Agricultural Policy Post 2013

by the

Irish Local Development Network

May 2010

Introduction

The Irish Local Development Network (ILDN) is making this submission on behalf of it's member companies who deliver the LEADER programme in Ireland. Thirty six of our fifty three member companies are based in rural areas and deliver the LEADER axis of the Rural Development Programme (RDP) 2007-2013. While LEADER is one of the four axes of the RDP, and is a required element of all national RDPs, in Ireland it was confined to Axes 3 & 4 with the minimum funding ceilings allocated to both.

In the context of making this submission on the reform of Common Agricultural Policy Post 2013, this submission will focus on the potential of enhancing LEADER but also maintaining the specific features of the LEADER programme in delivering more cohesive rural development in the next programme from 2014 onwards.

All member companies delivering LEADER, work within the framework of eight EC Council Regulations. They are EC Regulations, 1257/1999, 1698/2005, 1463/2006, 1944/2006, 2012/2006, 146/2008, 74/2009 and 473/2009. The Regulation No. 1698/2005 on support for rural development by the EAFRD, has been defined by the Commission as characterized by continuity and change. In reference to Regulation1975/2006 with respect to Axes 3 & 4 and for part of Axis 2, it indicates that "administrations and control rules need to be be adapted to [the axes] particular characteristic... special provisions therefore need to be established for these support schemes".

It is on the basis of continuity and change that we wish to make this submission, i.e. that Local Development Companies (LDC s), have a long history in delivering the LEADER programme. LAGs in Ireland have evolved to become Local Development Companies (LDCs) and this will be explained in the next section. Over almost two decades, LDCs have adapted to changing economic environments in rural areas and provided timely, appropriate strategies implemented through animation and financial supports to rural enterprises and communities.

Context:

 There are seven specific features of LEADER that are referenced below, Irish LDCs have cited these unique features which must all be present & honored in any LEADER Programme

 The Area Based Approach: Each company operates within a defined geographical region. Natural areas of Development of between 30 & 100,000 inhabitants typify LAG areas. However through the Irish Government’s Cohesion Process many LAGs are now coterminous with County structures except in the larger counties where sub-regions are in place but forming natural areas of Development. There are 36 LDCs (LAGs) that cover all the rural areas of Ireland. Some LDC’s cover urban centres and peri urban areas which are included as part of their area. While LEADER can only deal with the rural areas, the companies deliver a range of other programmes in addition to LEADER some of which cover both rural and in particular the urban parts of their areas.

 The Bottom up Approach: Each company has operated LEADER on the basis of responding to the needs of the community that they serve. The mid term evaluation of LEADER + by Fitzpatrick Associates noted that “ each group can provide extensive evidence of local experimentation with new ways of enhancing the natural and cultural heritage, reinforcing the economic environment so as to contribute to job creation, and improving organisational capability with rural communities”1 . The bottom up approach of local decisions being made within the framework of LEADER regulations is being challenged by the weight of the regulations of the current RDP being brought to bear. Examples include the current 20% cap on administration budgets and the challenges around the eligibility of the insurance bond for companies in the early part of the current programme.

 The Local Action Group The process of merging all LAGs and Area Based Partnership companies began in 2003, 13 LAGs had evolved to deliver LEADER and a range of other programmes since 1994. The aim of the Irish Government was to provide a more streamlined delivery of programmes and services. This cohesion process concluded in early 2009 and has resulted in the merger of a number of LAGS with Partnership Companies. The overall result has been to reduce the number of companies from 94 to 53, 17 are urban based and 36 of these companies deliver LEADER. These LAGS have been renamed Local Development Companies (LDCs) in order to reflect the broad range of programmes and services they deliver to their areas.

The Boards of the LDCs include representatives of all sectors in the region. Membership is gender balanced and represents a good geographic spread.

 Innovation: The development of LAGs into LDCs highlights the success of current methodologies applied regionally therefore eliminating the need for new regional programmes. Such is the success of the LAGs metamorphosis into LDCs Irish practitioners see this as a pilot of prototype for the rest of Europe. Innovation continues to remain the constant focus of LDCs primarily by means of strong involvement in inter territorial and transnational projects within LEADER.

On the Inter Territorial front the Irish experience has been very positive. There has been a very strong emphasis on networking. The capacity to use examples of projects from elsewhere and adapt them to local circumstances, and in some areas the methodology of developing clusters in regions to deliver programmes, has been applied.

 Integration: Achieving integration between sectors and agencies involved in rural development is a fundamental aim of the LEADER Programme. LDCs have been instrumental in ensuring more effective and efficient delivery of services to rural areas by providing such integration between a range of programmes which eliminates the risk of over-lap between funds and avoids the gaps that demarcation often created. . Promotion by LDCs of the multi sectoral approach involves all sectors contributing to the diversification, development and enhancement of social capital of the Rural economy.

 Inter-territorial and Trans National Cooperation: Irish LDCs place very high value on the contribution of networking, Inter-territorial and transnational co-operation in rural development. The main benefits of networking is the transfer of knowledge, information exchange, the promotion of best practice, sharing of know-how and innovative approaches and its contribution to reducing isolation of rural communities.

Inter-territorial co-operation has enabled Irish LAGs in the past and the new LDCs

to form clusters in order to achieve the economies of scale for certain actions.

Regional programmes can therefore be delivered through clusters of (LAGs) or

LDCs acting in an inter-territorial capacity. Examples include inter-reg in the Border

areas and Article 6 and ERDF programmes in other areas.

 Financial Measures; In the past LEADER was delivered through global grant on a multi-annual basis to each LEADER group. This funding enabled many rural groups and individuals to initiate and accelerate the development of local initiatives, facilities, businesses and Social Capital.

In the current round of LEADER funding, this is not the case. The Operating Rules that govern LEADERs delivery while allowing for multi-annual programming never the less have given the managing authority and Department Community Rural & Gaeltacht Affairs additional scope to micro manage and second guess the LDCs Board decisions.

LEADER in Ireland is hindered by reduced annualised budgets. The consequent negative impact on the 8% and 20%animation and administration allowed in the programme has meant that instead of front loading staff to get the programme off the ground early, after the 2 year delay in starting, LDCs had to let staff go in 2010 in order to meet the 10% over all cut in an already reduced admin/anim budget. The Financing Specific feature of LEADER needs to be re-informed in LEADER 2013-2020. This has a negative impact on the LDCs ability to deliver the programme locally and reach the targets on the development plan for their areas.

Expansion of the delivery of LEADER in Ireland: In 1992 there were 17 LAGs delivering LEADER in Ireland. This number was increased to 34 covering all rural areas in 1994. In the current programme, the number of companies has increased to 36.

The LDC encapsulates the participative institutional arrangements incorporating all the key stakeholders on their boards from the state to the community. Within the framework of the current RDP LDC’s are contracted to deliver the LEADER Axis and Axis 3, a programme of funding valued at over €425 million. While there are very real and pressing challenges in the delivery of the programme with new regulations and a changed economic environment, the innovative nature of LDC delivery must be maintained and LEADER has been a core part of the innovative delivery mechanisms.

The European Commissioner for Agriculture, Dacian Ciolo, in his announcement of this review in April, stressed the importance of ensuring that any changes to CAP must be entirely in keeping with the Commission's EU 2020 strategy. The 2020 strategy focuses on framing a cohesive response to the current economic climate through a series of headline measures that deal with sustainable and inclusive growth, including in the environmental context. . LDCs are in pole position to be a key local agent of the Commissions 2020 strategy. LDC’s will play a key role in the delivery of this required growth in a local, rural context post 2013, as they have done in previous RDP programmes.

Reform of CAP must take account of:-

  • The protection and enhancement of soil, ecosystems, landscape qualities and cultural heritage, by means such as cross-compliance and agri-environment payments (Ireland has suspended its agri environment scheme)
  • The skilled and resourceful management of soil and water resources, particularly in areas affected by flood, drought or draw-down of reservoirs.
  • The avoidance and control of pollution, and of runoff of agricultural chemicals
  • The observance of standards of hygiene, phyto-sanitary precaution and animal welfare
  • Management of soil, biomass and livestock in ways that ensure capture, sequestration and storage of carbon and minimizing of emissions of greenhouse gases, as contribution to mitigating climate change (in this field, there is need for urgent extension and dissemination of knowledge about practical methods for achieving these ends)
  • Generation of energy from renewable resources such as wood, other biomass, biogas, sun, wind and water
  • Sustaining of communities and local economies in areas affected by disadvantage through altitude, latitude, slope, poor soil, distance from cities and other factors.

In future regime, we urge that Member States be expected to pursue strong local development strategies, implemented through measures which may include:

  • Direct payments to small farmers
  • Agri-environment payments, recognizing the high quality of ecosystems , biodiversity and landscapes that have been created, and are maintained, by traditional farming systems; (public good)
  • Support to semi-subsistence farmers, focused on supporting their economic viability, rather than their competitiveness in an pan-European sense; (Ireland’s Rural Social Scheme is a good model)
  • Exceptions, where appropriate, from the application of EU hygiene and other standards for the production and processing of local products.
  • LEADER support for diversification of the Rural Economy improvement of the quality of life of rural inhabitants and the achievement of gender equality in rural areas.
  • Many of the above measures could be area based and delivered through LDC’s

What can LEADER & LDC's contribute in a reformed CAP model?

 As a long established infrastructure operating in a local context with national coverage, LDC's must remain central to the delivery of the LEADER and have an key role in broad, social, economic, rural and environmental development programmes. Bottom up, localized delivery of LEADER must remain a core principle. The specific features of LEADER must remain as core principles within the next programme.

 One of the key questions asked by Commissioner Ciolo is how can the EU stimulate the rural economy in terms of employment and sustaining the environment? There will always have to be a broad range of measures, but central to this will have to be LEADER. Through the programme, LDCs have provided financial and advisory support to promoters and supports employment and environmentally friendly projects that stimulate and sustain economic activity in rural Ireland.

 Clearly for all member states in the post programme 2014 period, the Commission will have to lay down control rules which are adapted to the particular characteristics of LEADER. The regulation under the current programme has been a challenge for all parties and is one of a number of factors impacting negatively on delivery. In the Post 2013 context, a clear focus has to be on developing proper accountability while at the same time ensuring flexible delivery on the ground so that the ‘LEADER’ Approach can flourish once again.

- The Global Grant, multi-annual nature of LEADER must be re-instated

 For LDCs, there must be greater authority given the LDC boards to draw up locally appropriate strategies and make their decisions within a flexible and accountable regulatory framework, at EU and National level.

 The opportunity to invest the LEADER Approach across Axis 1 and Axis 2 has not been realized to date in Ireland. ILDN would regard this as a loss to the overall RDP and would promote the appropriate use of the LEADER Approach across all Axes of the RDP.

 Taking the previous three points together ILDN are now proposing a third pillar, LEADER, which would ring-fence LEADER Type Activities of Axes 1, 2 and 3 of the second pillar. A distinctive and separate LEADER Regulatory Framework for Pillar 3 and actions designated to LDCs in Axis 1,2 and 3 of the second pillar could then be drawn up. This would result in a supportive yet substantive Regulatory Framework that can concurrently underpin the accountability of the investments and allow the ‘development’ nature of the LEADER Approach to expand.

 Innovativeness: This has been a hall mark of LEADER in Ireland. The challenge is how can we drive LEADER forward within the limitations of the current programme while placing companies in a position to grasp the opportunities of the next programme post 2013. The emergence of the Local Development Company as a concept and a reality delivering a suite of programmes including LEADER in an integrated way in a geographically based strategy is one of the innovative outcomes in recent years that could be replicated across Europe.

The issues raised in the reform of CAP are more complex and core than this summary paper reflects. ILDN would welcome dialogue with our key Departments and the Commission in the coming weeks to develop our ideas of the future of the LEADER approach within a reformed Common Agricultural Policy.

1 pg 47 Mid Term Evaluation of LEADER + Phase 2 Report Fitzpatrick Associates

ILDN 20101