EX-ANTE EVALUATION OF THE WALES RURAL DEVELOPMENT PLAN

Transcription

1 EX-ANTE EVALUATION OF THE WALES RURAL DEVELOPMENT PLAN Final Report for National Assembly for Wales Submitted by Agra CEAS Consulting in association with Collingwood Environmental Planning Telephone: *44 (0) Fax: *44 (0) Job No2239/BDB/September 2006

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3 Contents S1. EXECUTIVE SUMMARY...III 1. INTRODUCTION REPORT PURPOSE REPORT STRUCTURE SOURCES OF EVIDENCE TASKS CARRIED OUT Drafting an interim report Commenting on the National Strategy Plan Advising on the need for alternatives to the schemes proposed Commenting on the SWOT analysis and the RDP Interviews with key Assembly Government staff Informal feedback POLICY BACKGROUND ORGANISATIONAL BACKGROUND WHAT PROBLEM IS THE DRAFT PROGRAMME EXPECTED TO TACKLE? SWOT ANALYSIS OF THE PROGRAMME AREA Assessment of the completeness of the SWOT analysis Causes of disparities shown in the SWOT Specifying problems facing rural development in the programme area PROBLEMS WHICH CAN BE ADDRESSED THROUGH THE RDP PROBLEMS WHICH CANNOT BE ADDRESSED THROUGH THE RDP TARGET GROUPS AND THEIR NEEDS COHERENCE OF THE RURAL DEVELOPMENT PLAN THE CONSULTATION PROCESS NATIONAL STRATEGY PLAN CONSULTATION STRATEGIC ENVIRONMENTAL ASSESSMENT SCOPING REPORT CONSULTATION RURAL DEVELOPMENT PLAN CONSULTATION ENVIRONMENTAL REPORT FOR THE STRATEGIC ENVIRONMENTAL ASSESSMENT (SEA) CONSULTATION ASSESSMENT OF CONSULTATION PROCESS WHAT ARE THE OBJECTIVES THAT THE DRAFT PROGRAMME IS EXPECTED TO ACHIEVE? OVERALL POLICY OBJECTIVES COHERENCE WITH THE NATIONAL STRATEGY PLAN LOWER LEVEL OBJECTIVES MEASURE OBJECTIVES AND EXPECTED RESULTS WHAT ARE THE MEASURES PROPOSED? LESSONS LEARNED AND EVIDENCE DRAWN ON ALTERNATIVE SCHEMES, INSTRUMENTS AND DELIVERY MECHANISMS Alternative schemes and instruments Alternative delivery mechanisms MEASURES TO BE USED BALANCE BETWEEN AXES i

4 6. WHAT POSITIVE AND NEGATIVE IMPACTS ARE EXPECTED FROM THE MEASURES TO BE APPLIED? ADDED VALUE OF COMMUNITY INVOLVEMENT SUBSIDIARITY AND PROPORTIONALITY Subsidiarity Proportionality CONSIDERATION OF OTHER COMMUNITY OBJECTIVES INTERACTION WITH OTHER INTERVENTIONS Demarcation Complementarity Synergy Degree of additional ( marginal ) effects that can be attributed to the draft programme HELPING TO ACHIEVE COST-EFFECTIVENESS ASSUMPTIONS BEHIND EXPENDITURE PLANS FINANCIAL AND HUMAN RESOURCE COSTS ASSESSMENT OF THE ECONOMY OF THE RDP IMPLEMENTATION, MONITORING AND EVALUATION IMPLEMENTING ARRANGEMENTS RISK IN RELATION TO IMPLEMENTATION ARRANGEMENTS DESCRIPTION OF THE MONITORING AND EVALUATION SYSTEM ASSESSMENT OF THE PROVISIONS FOR MANAGING, MONITORING AND EVALUATING THE PROGRAMME INDICATORS THE RESULTS OF THE STRATEGIC ENVIRONMENTAL ASSESSMENT ENVIRONMENTAL CONSIDERATIONS MAIN RESULTS OF THE ENVIRONMENTAL ASSESSMENT Potential conflicts between the RDP objectives and the SEA objectives Assessment of alternative options Key impacts of the draft RDP and proposed mitigation measures Monitoring proposals INTEGRATION OF ENVIRONMENTAL CONSIDERATIONS INTO THE RDP The Rural Development Plan for Wales document and scheme design The Common Monitoring and Evaluation Framework for the RDP REFERENCES EU EVALUATION RELATED EU RDR RELATED WALES GENERAL STRATEGY WALES RURAL DEVELOPMENT RELATED WAG INTERNAL DOCUMENTS WAG CONSULTATIONS APPENDIX 1: EX-ANTE EVALUATION QUESTIONS ii

5 S1. Executive summary This report comprises an ex-ante evaluation of the Wales Rural Development Plan (RDP) and an associated Strategic Environmental Assessment (SEA). The evaluation took place between October, 2005 and September, 2006 and was conducted by Agra CEAS Consulting Ltd.. The SEA was undertaken by Collingwood Environmental Planning over the same period. S1.1. Purpose of the ex-ante evaluation Article 85 of the Rural Development Regulation ( ) 1698/2005 specifies that implementing authorities undertake an ex-ante evaluation of their proposed Rural Development Plan (RDP). Guidelines on ex-ante evaluation (European Commission, 2005) use the DG Budget definition of exante evaluation which is as follows: Ex-ante evaluation supports the preparation of proposals for new or renewed community actions. Its purpose is to gather information and carry out analyses which help to ensure that the delivery of policy objectives will be successful, that the measures used are cost-effective and that reliable evaluation will be subsequently possible. European Commission (2004). The objectives of the Strategic Environmental Assessment (SEA) are to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans with a view to promoting sustainable development. S1.2. Tasks carried out The ex-ante evaluation required the completion of a number of tasks, the timing of which was established by agreement between the consultants and the Assembly. These included: Drafting an interim report, comprising a thorough analysis of relevant literature (including previous evaluation exercises), description of the policy background and the development of a set of questions that this ex-ante evaluation report is required to answer. Interviews with key Assembly Government staff to facilitate answers to these questions, including lessons learned from implementing the RDP. Commenting on drafts of the Rural Development National Strategy Plan (NSP) for Wales and the subsequent more detailed RDP, including the SWOT 1 analysis it contains. Drafting these documents was an iterative process, with comments from the consultants being incorporated as revised versions were developed. The SEA was also an interactive exercise, with feedback from the consultants informing the RDP. Thus to a significant extent the output of the ex-ante evaluation has been built into the NSP and RDP as they have moved to published form. 1 Strengths, Weaknesses, Opportunities, Threats. iii

6 Providing formal advice on aspects of the RDP, including the need for alternatives to the schemes proposed (which had to be considered by the Assembly). Informal feedback throughout the contract. S1.3. The problems the RDP is expected to tackle medium and long-term needs The SWOT analysis is judged by this evaluation team to be highly consistent with the literature on the problems of rural Wales. Generally, the strengths, weaknesses, opportunities and threats identified in the SWOT summary table are derived from the analysis of evidence (contained in Part II of the RDP document). Attention was drawn to some inconsistencies in early drafts between the SWOT and the evidence base present, and suitable action was taken. The SWOT does not articulate the basic economic explanation for why environmental/landscape problems arise when adjustments made by the agricultural sector in response to pressure threaten the supply of environmental (and social) non-market services. That said, on the basis of the literature, consultations with stakeholders, and discussions with senior Assembly staff, it is the view of this exante evaluation team that the SWOT analysis is complete in its coverage of medium and long-term needs in the context of the preparation of the Welsh RDP for the period It is also our view that the SWOT summary provides a secure link between the analysis of needs for policy intervention and the measures that are proposed in the RDP. Some of the problems which can be addressed by the RDP are central to its remit and as a result are addressed directly by its measures. For example, through vocational training the RDP can be used to improve the skills of the workforce. Others are less central and are likely to be addressed more indirectly. For example, the RDP is not able to impact directly on the pattern of inward investment, though there may be an indirect influence It is the view of the ex-ante evaluators that the drafting team has successfully identified appropriate target groups and has considered the extent to which these different groups have different needs. There is clear recognition in the RDP that the approaches required to address these needs will differ from group to group. S1.4. Consultation The RDP involved four separate public consultations as follows: 1. National Strategy Plan (77 respondents); 2. Strategic Environmental Assessment scoping report (80 respondents); 3. Rural Development Plan (18 respondents); and, 4. Environmental Report for the Strategic Environmental Assessment (8 respondents). Some 201 organisations were asked to take part in these consultations. These organisations cover a broad range of areas including those with environmental, enterprise, forestry and tourism remits, academic institutions and organisations representing farmers and sub-groups such as women, young people and ethnic minorities. In addition to those invited to comment, the consultation documents iv

7 were made available online for any other individual/organisation to contribute their thoughts. This demonstrates that the consultation exercise was widespread, covered a range of organisations active in the economic, environmental and social domains and that a reasonable number of comments were received. Where appropriate these were taken into account in subsequent drafts of the documents consulted on and in relation to the financial balance between Axes in the RDP. S1.5. Objectives the RDP is expected to achieve The overall policy objectives are not explicitly set out in the RDP, nor in the NSP. This reflects the fact that the RDP is set within the Welsh Assembly s national strategic agenda, as set out in Wales: A Better Country and a range of other Welsh policy documents that give greater detail, dealing inter alia with agriculture, skills and employment, sustainable development, environmental strategy and economic vibrancy. A case can be made that the RDP is capable of contributing to all the objectives contained in Wales: A Better Country. The RDP (para 3.2.3) explicitly states that the measures to be implemented are in line with the strategic priorities of the Wales Annex of the UK National Strategic Plan, which are not restated in the RDP (as might have been expected to emphasise the carry-over). This coherence may be largely the case, though instances can be found in which leads given in the NSP are not taken up directly in the RDP, and where measures are proposed in the RDP that do not have an obvious antecedent in the NSP. Nevertheless, if disjunctions exist, these are only minor. Thus it is the view of this ex-ante evaluation that the Wales RDP is coherent with the contents of the Wales Annex of the UK NSP. S1.6. Consideration of alternatives Alternative approaches to the policy mechanisms that are already in place for the current programming period have been considered at regular intervals. These alternatives have either been instigated or set aside for various reasons or because circumstances/situations have progressed beyond the point where these schemes were useful. Lessons learned to date have also been used to amend the implementation of measures when necessary; the Assembly has conducted a formal lessons learned exercise to capture this experience. The ex-ante evaluators can therefore conclude that alternative schemes and instruments have been considered, although this has not been a main feature of the drafting process, largely as a result of the choice constraints under which the RDP has been constructed. Changes in delivery mechanisms have also been made, most notably the incorporation of the Welsh Development Agency (responsible for delivery of some schemes during the programming period) and the Tir Gofal agri-environment scheme into the Assembly. This latter change has been made for a number of reasons unrelated to RDP performance, but administrative savings are expected as a result. To the extent that greater efficiency of administration was an element contributing to these changes, the ex-ante evaluators are satisfied that consideration has been given to alternative delivery mechanisms. v

8 S1.7. Balance between Axes The current (September, 2006) estimate of total funding available for the RDP is billion. This figure has been derived following a number of assumptions, including the size of the UK allocation from the EAFRD, and the subsequent Welsh share of that; the anticipated receipts made available to Wales from the proceeds of Compulsory Modulation, along with the associated Match Funding; and, the amounts expected to be available to the Assembly from its own resources over the period of the Plan. In addition to this there is likely to be a contribution from the use of Voluntary Modulation, though this has not yet been factored into the Plan. The balance set out is clearly supply driven, in that the allocation is dominated by minimum spends per Axis, set by the legislative framework of the RDR, and existing commitments (for example, under ten-year agri-environmental management agreements) that have to be carried forward to the next programming period. Consequently there is relatively little ability to reflect demand as shown by the analysis of needs in the SWOT (only 17% of total EU funding is not already taken up by existing commitments). S1.8. Positive and negative impacts expected from the measures to be applied Although it is clear that positive impacts are expected from the measures to be applied, these cannot be quantified in this ex-ante evaluation because a final budget settlement has yet to be reached. This also limits the ability to provide an analysis of any potential negative impacts as these are likely to be dependent, at least to some extent, on the allocation of resources to different measures (impacts under Axis 2 are complicated by the review scheduled for 2007/08). That said, negative impacts are expected to be few as lessons learned from the current programming period and previous policy interventions have been used in the design of the Plan. S1.9. Added value of Community involvement The view of the evaluators is that subsidiarity has been respected in the Wales RDP, whichever interpretation of this term is adopted. The issue of proportionality is reflected in the allocation of resources between Axes and among measures within Axes. Discussions with Assembly Government staff show that they are aware of the problems of achieving an appropriate allocation, but also that their choices are constrained by a number of legal factors and political priorities. The evaluators are satisfied that other Community objectives have been taken into account when drawing up the RDP and that the Plan is consistent with them, particularly those relating to economic growth in the context of sustainable development. The Wales RDP also operates within the existing strategic framework of Wales (and the wider UK), strategies that themselves are coherent with EU priorities. The issue of demarcation has been discussed between staff responsible for policy design in the Assembly (responsible for the RDP) and in the Welsh European Funding Office (responsible for convergence funding), both in person and through the exchange of papers on the subject. Proposed vi

9 national legislation and scheme details have achieved what appear to be satisfactory solutions to the problems that demarcation relates to. The Wales NSP (paras 14 to 17) and discussion with senior Assembly Government staff demonstrate that complementarity with other activities under the Structural Funds has been adequately considered. Our assessment is that the Assembly Government is aware of the possibility of achieving synergy within the RDP and its measures. However, little explicit evidence has been offered of synergy between RDP measures and the measures of other policies. That said, the awareness of the drafting team of complementary relationships between them implies a sensitivity to synergies where they may be found. The impression of the ex-ante evaluators is that the designers of the Wales RDP have considered the issues of Community added value and that the proposals (taken together with the NSP) reflect this. S1.10. Cost effectiveness As ex-ante evaluators we are satisfied that the Assembly will operate the RDP in an efficient manner, drawing on the experience gained from the implementation period. This, coupled with the adjustments to payments under Axis 2 (which accounts for the vast majority of overall funding) and the fact that incentive payments are not made, should ensure that the RDP is delivered economically. S1.11. Implementing arrangements The approach taken by the Assembly to implementing the RDP appears to be considerably better organised than applied to the RDP. This is partly the result of having more time to prepare the Plan, but it is also clear that experience gained from the RDP has been taken into account. Again, attention can be drawn to the formal lessons learned exercise that the Assembly conducted. However the main change in implementation has been the centralisation of delivery, resulting from a review Making the Connections: Delivering Better Services for Wales; this led to the delivery of Tir Gofal being passed from the Countryside Council for Wales to the Assembly and the incorporation of the Welsh Development Agency within the Assembly. S1.12. Risks in relation to delivery The centralisation of the delivery mechanism holds the potential for greater control, integration and synergy of the various schemes that constitute the RDP. Centralising delivery will certainly have positive implications for access to scheme data for monitoring and evaluation purposes (a recommendation from the mid-term evaluation of the RDP) and is also likely to result in some administrative cost savings, thus improving delivery efficiency. Risk is likely to be reduced compared to the previous programming period. vii

10 S1.13. Assessment of the provisions for managing, monitoring and evaluating the programme The mid-term evaluation (MTE) of the RDP raised concerns about the disaggregated nature of monitoring data collection and pointed to the difficulties that this posed for effective evaluation. It is clear that the recommendations made at the time for improvements have been incorporated in the planning of monitoring and evaluation for the programming period. This is best exemplified by the creation of the monitoring and evaluation sub-team (who have had input to the drafting of the RDP from an early stage) and the use of, as far as possible, a single payment agency. The sub-team will bring together all monitoring information and report to the Programme Monitoring Committee. It is well aware of the need to be able to measure outputs. That said, there remains some uncertainty over the ability to assess outcomes. Nonetheless, this new structure amounts to a big step forward from the implementation period. S1.14. Indicators The process of setting indicators and targets is not complete at the time of writing (September, 2006), largely as a result of the delays in agreeing the budget for rural development at the EU level. The indicators specified in the RDP are therefore those set out in Regulation 1698/2005. Targets are likely to be agreed in October or November, 2006 once resource allocation is known. It is therefore not possible to thoroughly assess the indicators at this time. However, given the fact that in most cases the measures put forward are similar to those under the current programming period, it is considered that the mechanisms to be used to collect information to service the indicators will be sufficient. The fact that DG Agri has recently reassessed the common evaluation framework, including the use of indicators, inspires confidence that the indicators put forward by the Commission for the programming period are relevant, sufficiently easy to use, credible, widely accepted, robust and generally cost efficient. S1.15. Results of the Strategic Environmental Assessment SEA objectives were developed under a number of themes in order to provide an appropriate means of focusing on the environmental baseline information that is most relevant to the nature and scale of the plan. The Environmental Report (ER) provides a detailed description of the current baseline, key issues and environmental problems, reflecting the themes selected for the SEA objectives. Key environmental issues for Wales include, inter alia: halting the loss of biodiversity; pollution discharges from all sources to water courses; climate change; air quality; and, landscape change. The RDP offers an opportunity to address many of these issues. A total of six areas of possible conflicts were identified relating to two of the RDP objectives under Axis 2 and one under Axis 3. Three alternative options (the draft Plan, a do-minimum option and a continuation of existing measures option) were assessed against the broad headline SEA objectives, taking into account the viii

11 relevant sub-objectives. The outcome of the assessment of alternatives shows that the draft Plan as proposed is the best of the three options with respect to environmental effects. Although many aspects of the RDP are generally very positive as a result of its strong environmental focus and overall objectives, particularly relating to the agri-environment schemes, there are some key areas where there is considerable uncertainty and where there is potential for negative effects. The SEA identified measures across all Axes where further specification will be necessary to ensure that suitable environmental conditions are in place to mitigate the potential for damaging effects. As a result the Assembly has examined ways of addressing the areas highlighted in the report, in particular the proposed mitigation measures. Whilst no changes will be made to the text of the Plan itself, the findings of the SEA report will be a key consideration when developing the schemes to be implemented through the RDP. In particular the proposed mitigation measures will be considered as part of the eligibility criteria for schemes and the conditions put in place for receiving payment. The SEA emphasises the importance of SEA monitoring being integrated, as far as possible, into the monitoring of the implementation of the RDP. The Assembly fully supports this observation and through the development of the monitoring framework will ensure that this is taken forward. ix

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13 1. Introduction The National Assembly for Wales selected Agra CEAS Consulting Ltd. to carry out this ex-ante evaluation in association with Collingwood Environmental Planning who took responsibility for the Strategic Environmental Assessment (SEA) of the Wales plan Report purpose Article 85 of the Rural Development Regulation ( ) 1698/2005 specifies that implementing authorities undertake an ex-ante evaluation of their proposed Rural Development Plan (RDP). Guidelines on ex-ante evaluation (European Commission, 2005) use the DG Budget definition of exante evaluation which is as follows: Ex-ante evaluation supports the preparation of proposals for new or renewed community actions. Its purpose is to gather information and carry out analyses which help to ensure that the delivery of policy objectives will be successful, that the measures used are cost-effective and that reliable evaluation will be subsequently possible. European Commission (2004). The objectives of the Strategic Environmental Assessment (SEA) are to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans with a view to promoting sustainable development Report structure This report follows the structure for ex-ante evaluations first set out the Common Monitoring and Evaluation Framework Draft Guidelines for ex-ante evaluation issued by the European Commission in November 2005 and subsequently redrafted in February This structure is as follows: 1. Introduction This Chapter sets out the purpose of the report and the structure followed. The main sources of evidence and information on which it is based are set out. The tasks under taken in this ex-ante evaluation are described, as are the policy and organisational backgrounds. 2. What problem is the draft programme expected to tackle? This Chapter provides an assessment of the SWOT analysis. This includes consideration of the completeness of the SWOT, the causes for disparities highlighted, the issues which can be addressed through the RDP and those that cannot be addressed, target groups and their needs and the coherence of the Plan. 3. The consultation process This process is set out and assessed with regard to the four 2 Throughout this report the 2006 version is referenced. 1

14 4. What are the objectives that the draft programme is expected to achieve? 5. What are the measures proposed? 6. What positive and negative impacts are expected from the measures to be applied? 7. Added value of community involvement 8. Helping to achieve costeffectiveness 9. Implementation, monitoring and evaluation 10. The results of the Strategic Environmental Assessment consultations carried out. The overall policy objectives are discussed. The coherence of the RDP with the National Strategy Plan (NSP) is assessed, the lower level objectives are set out, as are the measure objectives and their expected results to the extent possible at this stage. The lessons learned and evidence taken into account in designing the RDP are described. This is followed by an assessment of the extent to which alternative schemes, instruments and delivery mechanisms were considered. The measures to be used are presented and finally, the balance between the measures in the context of the overall Plan objectives is set out and its derivation discussed. The potential positive and negative impacts expected from the measures are discussed to the extent possible at the time of writing. The way in which subsidiarity and proportionality are taken into account in the proposed Plan is discussed and the extent to which the Plan takes into account other Community objectives is considered. Complementarity and synergy with other interventions are commented on and the magnitude of additional ( marginal ) effects that may be attributed to the Plan are noted. This Chapter also includes an assessment of the approach to the demarcation of funds. The assumptions on which the proposed expenditure programme is based are set out. The financial and human resource costs of the proposed Plan are elaborated and consideration of whether the expected results could be achieved at a lower cost is provided. This Chapter is concerned with implementation and the monitoring and evaluation system to be used. This includes a consideration of risk in relation to the implementation arrangements and an assessment of the provisions for managing, monitoring and evaluating the programme. This summary of the full Strategic Environmental Assessment covers the environmental considerations that have been taken into account, the main results of the environmental assessment and describes the measures proposed to ensure the integration of environmental considerations into the preparation of the Plan. Appendix 1 contains the set of ex-ante questions used in this evaluation. The full Strategic Environmental Assessment is presented as a separately bound Annex. 2

15 1.3. Sources of evidence This report is based on information drawn from several sources. Inevitably, in order to address many of the questions set out in the ex-ante evaluation guidelines (European Commission, 2006), a primary source of information was discussions with senior staff within the Assembly Government who have responsibility for drafting both the National Strategy Plan (NSP) and, subsequently, the Rural Development Plan (RDP). The information gleaned from these discussions was supplemented by a range of documentation from drafts of the NSP and the RDP, internal audit/evaluation reports, internal working papers and statistical bulletins, published evaluations/research relating to previous programming periods, published national strategy documents and documents published by the European Commission through various departments. A full list of the documents consulted is presented in Section Tasks carried out The ex-ante evaluation required the completion of a number of tasks, not all of which are fully reflected in this document. The timing of these tasks was established by agreement between the consultants and the Assembly. These tasks included: Drafting an interim report This report established the methodology to be followed in carrying out the ex-ante evaluation. A major task undertaken at this point in the evaluation was a literature review of all relevant documentation. This review (see Section 11 for a full reference list) covered European Commission documents relating to evaluation and documents relating to rural development, including the base legislation. Welsh general strategy documents and those relating specifically to rural Wales (including external policy evaluations carried out on behalf of the Assembly) were reviewed to provide the Assembly with a digest of material of relevance to the National Strategy Plan and the RDP itself. Internal Assembly documents of relevance, including assessments/evaluations of rural policy measures currently in place, were summarised to provide a set of lessons learned to be incorporated in the RDP. Finally, consultation documents were reviewed to highlight issues of relevance to the programming period. The second major task reported on in the interim report was to develop a set of ex-ante questions. These were drawn from guides to ex-ante evaluation available at the time from DG Agriculture and more widely within the Commission. Interviews were then carried out with senior members of the Assembly Government with responsibility for drafting the NSP and RDP in order both to provide preliminary answers to these questions and to make the drafting team aware of the issues that the ex-ante evaluation is required to report on. The objectives and processes of the ex-ante evaluation were thus made explicit to the Assembly Government. The initial set of questions used was derived from DG Budget s ex-ante evaluation guidelines (European Commission, 2001). Subsequently further guidelines were issued by DG Agriculture. Our set of questions was revised in accordance with this later guide, although in practice the DG Budget 3

16 questions were more comprehensive and many were retained. The purpose of some questions was to prompt discussion with the drafting team, with their answers expected to be reflected in either the National Strategy Plan or the Rural Development Plan. Answers to some others were required explicitly for this ex-ante evaluation. The questions used (drawn from Article 85 of Regulation 1698/2005 and from DG Budget s general methodological recommendations (European Commission, 2001)), are set out in Appendix Commenting on the National Strategy Plan A draft of the NSP was made available to the consultants on 17 November, 2005 and comments on this draft were included in our interim report. This draft had been written before the Commission s guidance document (Establishing the National Strategy Plan: Guidance Template (VI/197/396/05)) was received by the Assembly and as a result it was not surprising that its formulation departed considerably from that required by the Commission. At this time it was also unclear whether the Wales NSP would form part of a UK submission or whether it would be submitted to the Commission in its own right. The comments made on this document were incorporated into the next draft by the Assembly. This next draft of the NSP was provided to the consultants on 09 December This was returned with comments on 14 December, This version followed the Commission s guidance template, although improvements were considered necessary to the rationale for providing public support, especially in relation to Axis 1. It was pointed out by the consultants that the information on co-ordination with other EU funding streams and policies could be strengthened. These comments (along with more detailed drafting points) were taken into account by the Assembly and incorporated into the next draft. A further draft of the NSP was made available to the consultants on January 11, 2006, at the same time as the document was put out to consultation. Comments were returned to the Assembly on 20 February, 2006 noting that the NSP tended to consider the causes of anticipated change rather than the problems of adjustment that might result. The logic for intervention was, as a result, not as clear as it could have been. A recommendation was made that the intervention logic should be clarified and that this should be taken forward and developed in the RDP itself in relation to the particular measures proposed. These comments were taken into account by the Assembly alongside comments arising from the consultation process Advising on the need for alternatives to the schemes proposed Following interviews with key staff in the Assembly Government and reviews of various drafting documents, a concern was raised by the consultants in relation to the need for the Assembly to have considered alternatives to the schemes and delivery mechanisms that would ultimately form part of the RDP. The consultants pointed out to the Assembly in a letter dated 19 January, The questions within the guidelines subsequently released by DG Agri did not contain questions beyond the scope of these earlier documents. 4

17 that it is a requirement of both the ex-ante evaluation and the Strategic Environmental Assessment that alternative ways in which the overall objectives of the RDP might be met are appraised and that consideration be given to the differing environmental, economic and social impacts that might arise. This issue had previously been raised in interviews with senior staff within the Assembly Government in November, Agra CEAS therefore strongly recommended that a number of alternatives be considered and that these alternatives and the results of their consideration be made available, including the criteria against which options were selected or rejected. Explanations for the choice of schemes adopted and the delivery mechanisms employed were subsequently provided in both further interviews with senior Assembly staff and, to a more limited extent, within the RDP itself Commenting on the SWOT analysis and the RDP A draft SWOT analysis was made available to the consultants on 24 March, 2006 and a draft of the RDP (minus material covering Axis 2) on 31 March, Comments on these documents were returned to the Assembly on 13 April, The main suggestion was that the logic flow from the background descriptions of the sectors to the SWOT table and then to the measures themselves needed to be improved. It was also noted that the document would benefit from some streamlining to make clear that the SWOT table came out of the general discussion and then that the priorities and measures come out of the SWOT table. It was pointed out that some issues/problems mentioned in the measures did not appear in the SWOT table and were not discussed in the background material. Finally, the focus of the document needed to be more on causes of problems rather than their symptoms and the Assembly were referred back to similar comments made in respect of the NSP dated 20 February (see Section 1.4.2). More detailed comments were submitted on a paragraph by paragraph basis and handwritten drafting comments were also returned, noting where improvements to the flow of the text could be made. These comments were taken into account by the Assembly in subsequent drafts Interviews with key Assembly Government staff As alluded to above, a number of interviews were carried out with senior staff members within the Assembly Government. The ex-ante questions mentioned in sub-section were used as the basis for discussion. These interviews took place in three sessions, the first between 09 and 16 November, 2005, the second on 06 March, 2006 and the third between 04 and 06 April, The first set of interviews were carried out in order to obtain preliminary answers to the evaluation questions. The material gathered was presented in out interim report (see Section 1.4.1). These interviews covered staff members with responsibility for: overall drafting of the NSP and RDP; individual axes within the RDP; provision of statistics to facilitate monitoring and evaluation; 5

18 convergence areas and their relationship with the RDP; and, the ex-ante evaluation. The purpose of the second interview/discussion was to set out revised timelines given delays in the drafting process (partly caused by the decision to submit to the Commission a UK NSP with country annexes rather than individual country NSPs); to consider the consultation process for the NSP and the Strategic Environmental Assessment scoping report, and how these should be taken forward; and to discuss the comments submitted by the consultants relating to the consideration of alternatives (see Section 1.4.3) and the clearer identification of problems within the NSP (see Section 1.4.2). The purpose of the third round of interviews was to address outstanding issues that must be examined by an ex-ante evaluation. This process was compromised to some extent by the fact that the consultants were only in receipt of the RDP itself two days before the meetings took place. Interviews were carried out with individuals/teams with responsibility for: overall drafting of the RDP; drafting material in respect of each of the axes; monitoring and evaluation of the RDP; financial governance and control; demarcation between the RDP and convergence funding; and, the Welsh Rural Observatory. All these interviews provided material which has been fed into this ex-ante evaluation report and also provided feedback to the Assembly which has been considered in the drafting of the NSP and the RDP Informal feedback In addition to the more formal inputs into the construction of the RDP and this ex-ante evaluation, a number of informal telephone calls, s and conversations took place in which comments were provided on a wide range of issues. These fed directly into the drafting process. It should be highlighted that throughout this process the Assembly Government staff responded positively and in a timely manner to our requests, despite their heavy workload, of which preparing the RDP and associated documents formed only a part Policy background The Rural Development Regulation (RDR) set out in Regulation 1698/2005 operates over the period and follows on from Regulation 1257/99, operational from 2000 to This 1999 Regulation brought together 9 different pieces of legislation which in some instances were initiated in the 1970s. Regulation 1698/2005 is based on a proposal presented by the European Commission on 15 July In line with the recommendations made at the Second European Conference on Rural 6

19 Development in Salzburg (12-14 November, 2003), the Regulation aims to reinforce rural development policy and simplify its implementation by: Introducing a single funding and programming instrument for rural development, the European Agriculture Fund for Rural Development (EAFRD). Strengthening the bottom-up approach - Member States, regions and local action groups will have more say in attuning programmes to local needs. Introducing a new strategic approach for rural development with clear focus on EU priorities such as the Lisbon and Göteborg goals, and targeting the wider rural population, i.e. going beyond the agricultural sector. Reinforcing control, evaluation and reporting and dividing responsibilities more clearly between Member States and the Commission. With the introduction of the EAFRD, a new structure for CAP funding was established with a single fund for each pillar (pillar 1 will continue to be funded from the European Agricultural Guarantee Fund). Under the new strategic approach, rural development policy is to be focused on the following three core objectives: 1. Increasing the competitiveness of the agricultural and forestry sector through support for restructuring. 2. Enhancing the environment and countryside through support for land management. 3. Enhancing the quality of life in rural areas and promoting the diversification of economic activities through measures targeting the farm sector and other rural actors. For each core objective, key actions are suggested across four Operational Axes which are: Axis 1: Axis 2: Axis 3: Axis 4: Improving competitiveness of farming and forestry Environment and countryside Improving quality of life and diversification of the rural economy the LEADER approach In the new approach, Rural Development Programmes in all Member States should pursue all three objectives. To ensure a balanced strategy with at least a minimum level of funding for these three core objectives, a minimum of 10% of the national envelope has to be spent on Axis 1, 25% on Axis 2 and again 10% on Axis 3. This leaves Member States or regions substantial flexibility to meet their specific situation and needs. The EU co-financing rate is a maximum 50% (75% in convergence regions) for Axis 1 and 3 and 55% (80% in convergence regions) for Axis 2. For afforestation, the co-funding rate is 80% in LFAs and 70% in other areas, i.e. 20% higher than in the period. 7

20 Each programme must have a LEADER element (Axis 4) for the implementation of bottom-up local development strategies of local action groups. EU-15 Member States have to reserve a minimum of 5% of national programme funding for LEADER. This element should contribute to the priorities of the three main areas described above, but also plays an important role in terms of improving governance and mobilising the endogenous development potential of rural areas. In particular, the building of local partnership capacity, the promotion of private-public partnerships, the promotion of co-operation and innovation and the improvement of local governance are sought. This reorganisation of rural development policy also involves changes to the implementation of Objective 1. The rural development aspects of this programme, funded through EAGGF Guidance in the programming period, will henceforth be financed through the new EAFRD under the RDR. At the same time, Wales has lost its Objective 1 status but has been granted convergence status for the programming period. This effectively results in additional funding in the former Objective 1 region over and above that which would have been made available under the RDR. The options available to the Assembly Government when drawing up the RDP are fairly constrained. There is no facility to start from the beginning with a genuine assessment of rural needs and the construction of a policy to address these. It should also be noted that agreements entered into during the current programming period retain ongoing financial commitments into the period and that this further reduces the ability to design the policy ab initio Organisational background Regulation 1698/2005 sets out the organisational background for the programming period in the following way. First, Member States must provide a National Strategy Plan (NSP) which describes the overall problems and objectives for rural development. The requirement is therefore for a UK NSP which includes annexes for each of the constituent countries. It should be noted that this was not the original understanding from the Commission and that this change in requirements caused a degree of confusion. Although the Commission released guidelines on the construction of the NSP 4, this document was only made available on 16 November, sometime after the Assembly had completed a draft. Regulation 1698/2005 stated that the Rural Development Plan (RDP) should be an elaboration of the NSP, although this time at the regional level where appropriate, as in the case for Wales. Annex II of the draft Implementing Regulation, dated 27 October, 2005 (European Commission, 2005), prescribes the structure and contents of an RDP in detail. The guidelines for establishing the NSP allude to a stakeholder consultation on the NSP, although it is unclear whether this is mandatory. In any case, public consultation is widely undertaken within the Assembly and the NSP was duly put out to consultation over an 8 week period (from January 11, 4 Establishing the National Strategy Plan: Guidance Template (VI/197/396/05). 8

21 2006) in accordance with this general practice. During this time, drafting commenced on the RDP. Whilst this was necessary in order to ultimately meet the Commission s deadline for submission of the RDP at the beginning of June, 2006, this was obviously not an ideal situation as the draft RDP was unable to benefit from adaptations made to the NSP, from which it ought to have been developed. A similar consultation was undertaken with respect to the draft RDP. Hard copies of the consultation document were sent to some 300 stakeholders across Wales on May 24, 2006 with an 8 week response period. Although there was ultimately no requirement to carry out a Strategic Environmental Assessment (SEA) in respect of the RDP, the Commission had suggested that this would be a requirement when the contract to carry out the ex-ante evaluation was drawn up by the Assembly Government. In order to ensure that the Welsh Plan could meet this requirement, should it be necessary, a SEA was commissioned as part of the ex-ante evaluation. The SEA has been carried out in parallel with this ex-ante evaluation and the drafting of the RDP. However, because of constricted timelines resulting from the delay in release of Commission drafting guidelines and in the absence of an extension to the date by which the RDP must be submitted to the Commission (and the absence of a financial settlement), the extent to which the SEA was able to feed into the RDP itself was severely compromised. This problem was addressed by feeding information from the SEA into the draft documents at the same time as the consultation results. Two elements of the SEA were put out to consultation. First the SEA scoping report which sets out the environmental issues that the SEA should take into account, and second, the SEA itself. In addition to these public consultations, a meeting was held in December 2005 to which a number of stakeholders both within and outside the Assembly Government were invited. The purpose of this meeting was to assist in identifying the issues for the scoping report and also to ensure that those drafting the RDP were aware of the environmental issues which should be taken into account The logic of the approach set out by the Commission to the drafting of the RDP is to be commended. To recap, a national strategy should first be put in place setting out national issues and objectives. A detailed SWOT analysis should then be carried out at the implementation level to help inform the focus of the RDP which should itself be an elaboration of the NSP. However, there are two factors which considerably reduced the effectiveness of this approach. First, as noted above, the Rural Development Regulation is specified at the EU level and follows on from previous legislation, some of which dates from the 1970s. This reduced considerably the scope to target measures on current rural problems at the local level. This was exacerbated by the scale of on-going commitments as a proportion of the available budget (see sub-section 5.4). Second, the timetable, already fairly tight, was made worse by delays in the publication of guidance material, Implementing Regulations and the agreement of the budget. This meant that it became impossible to derive the RDP, taking account of the SEA, from the NSP in the manner intended. The late release of key 9

22 documents from the Commission was raised as a problem by the ex-ante evaluators of the England RDP for the period (contained within Defra, 1999) and it is disappointing that this situation has not improved. As a result, the drafting of the Wales RDP and consultations on the NSP had to proceed in parallel and the logic of the Commission s original design process has been compromised. Against this background the Assembly Government is considered to have carried out its task in consulting on and completing the NSP and the RDP exceptionally well. 10

23 2. What problem is the draft programme expected to tackle? The Guidelines for Ex-ante Evaluation issued by DG Agriculture make it clear that, from a procedural standpoint, the analysis of Strengths, Weaknesses, Opportunities and Threats (SWOT analysis), of the geographical area covered by the programme precedes ex-ante evaluation. The SWOT should represent the first step to define the strategy of the programme, and aims to bring out the needs of the rural areas concerned. It has to refer to the main structural components of the rural area and has to lead to an appropriate and coherent ranking of the disparities that need to be addressed. The ex-ante evaluation has to undertake a number of specific tasks, considered below, by which the SWOT analysis is assessed as a vehicle for identifying and appraising the medium and long term needs of the programme rural area. In practice the SWOT analysis for the Wales RDP , carried out by the Assembly Government, was not completed formally until after the National Strategy Plan had been drafted and put out to consultation. This did not necessarily handicap the development of an appropriate strategy because the basic structural characteristics remain closely similar to the situation described in the SWOT carried out in 1999 for the current programming period. Before embarking on an analysis of the SWOT it is necessary to comment on the definition of rural. There are a number of possible definitions and the SWOT analysis of the RDP comments at length on the derivation of the so-called Shepherd definition 5 which was delivered in 2004 by the Rural Evidence Research Centre at Birkbeck College (RERC). This was produced as a result of a joint project between the Welsh Assembly and a range of other UK government departments and agencies 6. This definition offers advantages over previously used definitions, mainly in the way in which the bias generally caused by urban centres within rural areas is mitigated. Having made the case for this definition, the SWOT analysis does not use it because data are not yet generally available in that format. The statistics that are available are drawn from a number of sources (including the 2001 census) none of which use the Shepherd approach SWOT analysis of the programme area The problems, risks and needs in the programme area are discussed in the SWOT element of the RDP, as are the driving forces, strengths and opportunities. These are summarised in a SWOT table which is not repeated here. The role of the ex-ante evaluation is to assess the completeness and validity of the SWOT analysis in terms of identifying the causes of disparities and specifying the problems facing rural areas. This assessment is carried out in the sub-sections below. 5 This is also referred to as the Birkbeck definition and the new rural definition. 6 The Commission for Rural Communities (CRC - formerly the Countryside Agency), the Department for Environment, Food and Rural Affairs (Defra), the Office for National Statistics (ONS) and the Office of the Deputy Prime Minister (ODPM). 11