Monday, 24 August 2020

ACT and MaYA Foundation submit feedback for the re-evaluation of the National Rural Policy



ACT's and MaYA's have submitted a document outlining amendments and suggestions to the re-evaluated national rural policy. 

These suggestions were drawn up following a careful analysis of the policy document by the ACT (VO/1491) and the MaYA Foundation (VO/0823), and a public discussion organised by the two organisations that brought together stakeholders, individuals and representatives from other NGOs. 

The agricultural sector needs to be better enabled to grow sustainably. Agriculture is crucial towards our food security, the stewardship of our rural areas, and the rural character. Farmers ought to be able to make an adequate living. Their interests should be better represented by the policy, while at the same time, certain types of permitted development that are unnecessary and damaging to rural areas should be curtailed or removed. 

We acknowledge that the revision has made some important improvements on the preceding policy, however, some changes were perceived to be counterproductive to the progression and preservation of our rural landscapes. The policy does not adequately serve the needs of the modern farmer who, in a highly-competitive market, is under great pressure to update his/her machinery and to innovate his/her production and marketing methods. These necessitate improved land access and adequate storage space that caters for different kinds of machinery and different kinds of produce. In view of this, our suggestions below reflect the need for farmers to encountering fewer hindrances when applying for certain kinds of structures. This includes making it easier for genuine farmers to add value by developing on-farm retail facilities that showcase the processes involved in cultivating and processing fresh and artisanal produce. 

The policy as it does not favor facilities for small-scale farmers, despite existing examples of structures that have a small footprint and are sensitively designed to blend in effectively with the surrounding rural environment. Supporting the needs of small-scale farmers ensures a more resilient, populous, and diverse agricultural community, and more opportunities for resource sharing, capacity exchange, innovation, and the possibility for the creation of distinctive products and diversified streams of income for the agricultural sector. 

In order to avoid abuses, there is a crucial need in the policy for a criterion that identifies and enables genuine farmers. Other organisations have already pointed out that declared turnover (from agricultural related activities) is the best indicator of genuine agricultural engagement, and we support this demand. Apart from agricultural activities, there are activities that target ecology restoration which most of the time do not generate turnover; especially in the beginning. For such projects, it is recommended that the Environment and Resources Authority has a crucial role and possibly a veto in decision making as the competent authority for environmental protection.

It should be recognized that most forms of genuine farming entail spending most of one’s days not just to animals but also to crops. This is true not only for breeders with large herds but also for breeders with fewer animals and also for arable farmers. Thus, we suggest a more lenient policy with regards to farmer dwellings, alongside even tighter restrictions on non-farmer dwellings. Maximum building sizes are generally deemed excessive and smaller maximums are suggested. 

We propose that in Section A, a clause is included that provides a clear statement of how the relevant authorities are understanding the needs of the sector through research and communication with stakeholders. This would ensure that not only are relevant stakeholders accountable to the policy but that the policy and the authority are also accountable to the agricultural sector and other stakeholders. 

Finally, we understand that a policy must ultimately be implemented and its measures upheld both during applications and for existing buildings and projects. Towards this end, we demand the introduction of clauses in section A that specify the monitoring and assistance responsibilities of different entities, stating by whom, how, how often, and with what resources these are achieved. In doing so, a guarantee should be included stating that reports made on site-visits should not merely be communicated to stakeholders orally, but should be sent by email or by post. Guarantees must also be given that sufficient resources are being allocated in order to successfully implement the policy and that their allocation is solidly based on an assessment of the tasks required to do so.

These policy consultation processes are of great importance in devising a representative political direction that tailors for our communities' needs and aspirations. ACT and MaYA will remain pro-active in allowing for a healthy discussion with the main stakeholders and in generating constructive amendments and suggestions. 

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