Piloting an Outcomes Based Approach in Scotland (POBAS) project, Phase 1 report
Published: September 2020
Summary of Phase 1: April 2019-March 2020
Piloting an Outcome Based Approach in Scotland is an NatureScot-led project working with 40 farmers and crofters in four clusters across Scotland (Skye, Argyll, Strathspey and East Lothian) to test innovative approaches to delivering environmental outcomes on farms and crofts in Scotland. The project also worked closely with two partner projects in Shetland (with the RSPB) and in the Outer Hebrides (with the European Forum for Nature Conservation and Pastoralism).
This report summarises the outcomes and lessons learned from the Phase 1 activities and focusses on the four pilot areas led by NatureScot.
The overall aims of the project are to;
1. Demonstrate how a results based approach to agri-environment schemes can work in different regions across different farm types.
2. Understand implementation issues associated with a results based approach including practical barriers, issues and opportunities, and farmer behaviour.
3. Test the range of outcomes that can be delivered through this approach and how these are translated to management measures and indicators at the field, farm and landscape levels.
4. Identify solutions and recommendations to inform delivering an agri-environment scheme using this approach as part of future farming support architecture beyond 2024.
Phase 1 ran between April 2019 and March 2020. Phase 2 runs from June 2020 to March 2021. It will build on the experience and input received from farmers and crofters who took part in Phase 1 and will involve further preparatory work to enable implementation of a potential full pilot scheme from the start of 2021/22, with a view to operating that for 2 years until March 2023.
What did we set out to do in Phase 1?
Phase 1 set out to:
- establish four groups of farmers and crofters willing to participate in a trial and who represent a range of farm types and geographical range across Scotland;
- identify a range of environmental outcomes that could be delivered by a payment-by results approach across the different farm types and in different regions;
- identify result indicators through the development of a range of scorecards that can be used to measure how well outcomes are achieved and as a basis on which to set potential payments.
- explore the basis for calculating a range of payments that would reward the outcomes achieved.
What did we achieve?
Expert environmental consultants were employed to select and work with up to 10-20 farmers and crofters in each of the four areas. Areas were selected due to their geographical range, a good representation of the farm type and history of collaborating on environmental outcomes. The project embraced other initiatives aiming to test the approach including an RSPB Scotland and Shetland Amenity Trust led initiative to explore agri-environment outcomes in Shetland crofting conditions and a LEADER funded project in the Outer Hebrides led by the European Forum for Nature Conservation and Pastoralism focussed on common grazings.
The consultants ran three workshops in each of the four pilot areas involving a mix of indoor and outdoor sessions usually on one of the participating farms nearby, and generally covered the following:
Workshop 1: Introduced the payment-by-results approach and ‘public goods’ with help of visiting practitioners from pilot schemes operating in Ireland and the Yorkshire Dales. All pilots focussed on an introduction to results-based payments and scoped outcomes that were relevant to their farming system. Due to time constraints we had to narrow in and focus on just one or two of the identified outcomes.
Outcomes investigated in each location:
- Strathspey: Habitat management for waders.
- East Lothian: Hedges and field margins.
- Argyll: Grassland and habitat mosaics on the marginal land beyond the in-bye, together with the hill land.
- Skye: Maintaining whole croft diversity based on mixed livestock management of semi natural grassland.
- Shetland: Peatland quality
- Outer Hebrides: Approach suitable for whole range of conditions encountered on common grazings
Workshop 2: Introduced scorecards and trialled their application to locally identified habitat targets.
Workshop 3: Introduced payment rate calculation assumptions and methodologies.
Covid-19 restrictions in March 2020 meant that the third workshop could not take place in East Lothian, and restricted further testing of scorecards on the ground across all pilot areas.
However, more work is required in Phase 2 to finalise the scorecards, guidance and payment rates necessary to run a pilot scheme that would put the methodology into practice.
What were the common issues and lessons learned?
Farmer and crofter attitudes
- Participants easily understood the results-based concept but this was very much helped by the guest speakers from the Yorkshire Dales, Hen Harrier project and the Burren Programme sharing their experience.
- Participants welcomed the prospect of a simple application process and a move away from a prescriptive basis of management towards being given a choice as to how to implement management on their farms and crofts.
- However there was also feedback from participants that they do not want schemes to be unnecessarily complex. The outcomes need to be simple to understand and applicable to the circumstances of their croft or farm business.
- There was a willingness to contribute and provide practical comments about the draft scorecards and payment rationale. Participants appreciated being given the opportunity to input at each stage and changes were made based on their feedback.
- Farmer and crofter attitudes to results-based schemes were generally good with most signing up to take part in Phase 2. In phase 2 we intend to implement attitudinal surveys to properly gauge what opinions are throughout the pilot.
- Generally participant’s interest in an outcome based approach extended beyond the results-based scope explored in Phase 1. Had time and resources allowed, farmers and crofters in each pilot would have liked to explore how environmental outcomes could be supported across their whole farm or croft. Whilst a payment-by-results approach works best when the primary purpose of management is to achieve the environmental outcome, in other circumstances where the management purpose is shared more equally with business purposes, participants were interested in how the public benefits might be recognised by other farm support schemes. For example, the East Lothian participants were interested in the climate and biodiversity benefits that can be generated by in-field (as opposed to field margin) crop and soil management alongside crop production. Meanwhile participants in the other clusters wished to explore how the high nature value of relatively less intensive management across the whole farm or croft can be recognised in all farm support schemes.
- This pilot focussed on a limited number of environmental outcomes to test the concept, but participating land managers were keen to test more outcomes if the opportunity arises.
- Not all outcomes require a results-based approach; for example some capital items or in-field climate measures such as cover crops. These are usually one-off, or annual, actions where strict implementation is more likely to lead or contribute to delivering the desired outcomes without the need for assessment of how they have been implemented, or where there would be a long lag in the response of the scoring criteria to an otherwise desirable change of management. They are more suited to payment based on evidence of installation or implementation.
- Most pilots focussed on one or two specific outcomes that could be delivered on part of the farm. However, the Skye group wished to explore the sustainability of the ‘whole croft’ because the limitations of holding size makes it difficult (and undesirable) for crofters to respond on a field-by-field basis.
- Prioritising outcomes and assessing the scale at which they should be delivered requires further testing. Farmers were wary about how such an approach would work in practice beyond the limitations of this pilot and whether all support would be framed around outcomes. Issues identified included how to prioritise outcomes when management for one is less optimal for another, and at which scale outcomes should
- Farmers across all pilots were keen to pursue soil health because of its benefits to business, the climate and biodiversity.
- Balancing simplicity of approach with more specific requirements which would achieve better outcomes is an ongoing issue that will need further exploration.
- Scorecards are a critical element of any results-based scheme. They describe ideal management to achieve the outcomes and are used as a tool to measure success. The scorecard concept was easily grasped by participants. It proved relatively easy to prepare a first draft of each of the score cards tested with the groups. It proved particularly helpful to have examples of scorecards trialled by other countries (e.g. Ireland and England) to work from. However, the cards needed to be thoroughly tested in the field to tease out the potential implications and unintended consequences of some of the attribute parameters and scores in each pilot area.
- Each pilot focussed on outcomes that were particularly relevant to that region e.g. Strathspey waders, Argyll hill mosaic. However there were generic outcomes which were explored such as hedge quality or grassland species diversity that could apply more widely across Scotland.
- Scorecards require further development and testing particularly for some pilots given their scale of complexity and stage of development e.g. How to apply different scorecards to multiple habitats and species outcomes in the Argyll hill situation.
- The annual scorecard assessment could be carried out by advisors (as in Ireland) or by the farmers themselves (as in England). This is an area we anticipate exploring in Phase 2 by testing both approaches and gauging the farmers’ and advisors’ ability and confidence.
- Farmers were concerned about the potential for inconsistency, their lack of expertise and the time required. There would be a need for verification of results if farmers are scoring their own areas.
- The management and capture of data generated by using the scorecards will need further exploration in Phase 2. Results-based schemes require annual monitoring using scorecards and so we will need to develop systems that allow us to store the data in a way that would enable a scheme to operate efficiently. The Irish Hen Harrier
project developed an app for handheld devices so that scoring could be recorded electronically. We are developing a CivTech proposal to look at opportunities around this.
- Phase 1 involved preparatory work and not management on the ground, so no payments were made in this phase.
- Most pilot areas were able to develop proposals for a potential basis of calculation for payments, apart from East Lothian, where effort was focussed on scorecard development.
- Further work and consultation will be required in Phase 2, taking into account developments and research work from other countries to build on our payment rationale.
- Further scoping of pilot farms will be required to consider potential for double funding during the pilot, where there are existing agri-environment scheme contracts, another option is to trial on farms without agri-environment contracts and invite the other farmers in the group to discuss the results.
- It has been difficult to consider appropriate basis of payment given the uncertainty about where such payments would sit within future rural support architecture, particularly in Argyll and Skye where the approach could have implications for the whole farm or croft.
Further detailed reports on each workshop
The consultants prepared detailed reports on each workshop within each pilot area and these are summarised below. An additional document containing the full reports and additional work received from contractors following each workshop is available by contacting the Project Manager: [email protected].
Expert environmental consultants
The following consultants were contracted by NatureScot to facilitate the pilots:
|Strathspey||Paul Chapman and Gillian McKnight, SAC Consulting|
|Argyll||Helen Bibby, SAC Consulting, and Gwyn Jones, European Forum for
Nature Conservation and Pastoralism (EFNCP).
|Skye||Janette Sutherland, SAC Consulting and Gwyn Jones, EFNCP|
|East Lothian||Tony Seymour, The Farm Environment Limited|
Kay Prichard (SRO) and Kirsten Brewster (Project Manager)
30 August 2019 – Grantown on Spey – 17 farmers attended
This workshop introduced outcomes, public goods and how results-based schemes have worked in other countries.
Farmers identified the following environmental outcomes which benefit from farming in Strathspey: waders, species-rich grasslands, native woodlands (especially grazed woodland), water quality/flooding, maintaining and improving soil health, promoting retention of organic matter with potential benefits for carbon capture. Farmland waders was identified as the most obvious priority given the importance of Strathspey for these species and the suitability of assessing grassland management for waders for trialling a results-based approach. Key issues identified for wader management included the need for predator control, and the impacts of protected predators, such as badgers, and the competing priority of native woodland expansion.
A common theme throughout was that a holistic, whole farm approach, rather than a piecemeal, land parcel-based scheme, is preferable. Farmers were also keen to emphasise that farms need to be financially sustainable in order to be able to produce the biodiversity outcomes discussed, a decline in the profitability of producing food over time was specifically mentioned.
15 November 2019 – Nethy Bridge – 15 farmers attended
This workshop introduced, and tested, the scoring criteria using a representative of similar pilot in Yorkshire Dales from which participants could learn.
Guest speaker - Hannah Fawcett - Yorkshire Dales experience
Hannah shared her personal experience of an outcome-based agri-environment scheme for waders in the Yorkshire Dales National Park as a farmer, as well as reflections on the project
from the National Park where she is employed. This got Strathspey farmers interested in the idea of outcome-based agri-environment schemes. There was particular enthusiasm for the
simple application process, the lack of prescription-based rules and the ability to set the level of outcome that best suited each farm.
The draft scorecard was tested on one of the participant’s farms and this revealed some practical considerations to inform further development of the scoring criteria. The difference between the simplicity of the approach to wader conservation in the Yorkshire Dales and the more complex situation in Strathspey became evident when discussing the draft scorecard. Key issues that participants picked up on were: Predation was not given as much
prominence as habitat structure and it was felt that improved grass and arable fields were not valued sufficiently in the scoring. The importance of the whole farm context as against assessing individual fields in isolation was discussed, recognising the benefits to waders of a mix of cropping and habitats and proximity to wet features. Farmers were keen to include an element of assessment of soil health.
There was discussion about the possibility of including wader counts as part of the scoring system, as a direct measure of the outcome. There was some support for this as it will reward those delivering the actual outcome desired. However, there were also reservations about putting too much weight on wader numbers due to annual fluctuations in numbers on some farms that were beyond the control of farmers, perhaps weather related.
4 March 2020 – Nethy Bridge – 13 farmers attended
This workshop allowed the group to discuss payment rate rationale, use the updated scorecard to score habitat in the field and discuss what ‘good’ looks like.
Following concerns about some aspects of the scorecard at the second meeting, considerable work had been carried out to revise the scorecard criteria, and the revised scorecard was circulated to attendees prior to the meeting. The general approach to
measuring vegetation structure and extent/quality of wet features seemed to be broadly accepted with few negative comments compared with the previous meeting, although the need for detailed guidance on scoring was highlighted, to avoid inconsistency. The optimum time to carry out scoring was discussed, with April-June likely to be best, as that is the key
period during which waders will be breeding.
Paul had prepared a potential basis of payment prior to the meeting and the workshop enabled a useful testing of the payment assumptions. Farmers provided comments on the potential financial implications of ideal management for waders, and noted that the current AECS rates were considered to be barely worth the additional restrictions that are required.
A site visit enabled the scorecard to be tested on the ground and there was a good level of agreement. It did show however that it might be difficult to assess vegetation structure in a large parcel and this example emphasises the need for further testing.
Expert advisors have prepared the following:
- Breeding Wader habitat scorecard
Contributions from the SWWI (Strathspey Wetlands and Wader Initiative) have been very helpful in developing the scorecard.
- Predator control is an issue. Whilst many seem to have sufficient predator control already taking place, often by landlords on tenanted farms, badgers are a major issue which farmers would like recognised through e.g. monitoring and evidence collection. A lack of predator control in adjacent RSPB woodland was also noted as a
- Most farmers already have AECS contracts over the majority of their farms and so double funding will have to be avoided when paying for management under POBAS.
- There are different opinions as to appropriate grazing levels during the breeding season, and the degree to which there should be minimum prescriptive requirements.
East Lothian workshops
30 October 2019 – Tyninghame – 10 farmers attended
This workshop introduced outcomes, public goods and how results-based schemes have worked in other countries.
Farmers identified a wide range and number of public goods provided by farming in East Lothian but the key outcomes can be summarised as:
- Enhancing Biodiversity (e.g. pollinators, wildlife corridors, grey partridge, barn owls)
- Addressing Climate change (carbon sequestration)
- Managing Soil and Water resources (water quality and flood management)
Some farmers thought that we should have several measures under each of these outcomes for farmers to choose from. However, it was emphasised that for the pilot to be manageable,
we would need to focus on just two or three measures to test under a results based approach. Farmers are looking for win-win scenarios i.e. where biodiversity/carbon outcomes also benefit business.
A site visit took place at Kirklandhill to view some agri-environment options on the farm and explore how we would measure the success of these. This teased out some practical points such as the type of land makes spring cropping options difficult; the benefits of habitat networks in-farm and at a landscape scale for the likes of barn owl; the desire for support for cover crops/green manures, and concerns over weed control, particularly in the longer term.
4 December 2019 – Haddington – 8 farmers attended
This workshop went over the principles again as it was a slightly different group of farmers, and explored the potential for two measures to take forward under this pilot.
Tony presented tables which showed matrices of measures against services, both in terms of ecological outcomes (habitats and species) and broader environmental outcomes (soil,
carbon, water). Whilst some farmers found this an overly complex approach, the analysis provided a mechanism to identify potential measures which would provide the most benefits.
Farmers were tasked with considering:
- in-field measures e.g. green manure, arable reversion to grassland and legume crops. They considered aspects such as mixes, management issues and what would influence soil condition and yield.
- field boundary and field margin measures e.g. hedgerows, grass margins, pollen and nectar mixes, conservation headlands; and identified what would influence success. Longer-term measures were cited as being preferred over short-term measures which required annual inputs.
A site visit took place at Colstoun to view examples of these measures to consider practicalities of implementation and scoring success. It was decided that a results based approach may not be appropriate for in-field/whole field measures and that it better suited field margin and boundary features.
Farmers emphasised that they do not want to be subject to complex scoring systems for the sake of it, and that where applicable they would prefer a simpler “Land Management
Options” style of capital payment for action. However there have been views portrayed elsewhere that past Agri-Environment Schemes have demonstrated that some simple “broad and shallow” measures on their own do not deliver significant ecological outcomes, can be poorly targeted, and therefore do not necessarily represent good value for money.
Workshop 3 was due to run in March 2020 but was cancelled due to Covid-19 concerns. It was decided that the time available would be better spent on the development of the scorecards and as a consequence, there has been limited development of potential payment rates.
Tony has spent a significant amount of time developing scorecards and guidance for the following two measures:
- Field margins
These are significantly more complex than those developed for the other pilots but are more visual and descriptive. They reflect the range of potential components of these features and the range of potential interventions. These have not yet been tested on any of the farms as the Covid-19 restrictions were placed after the scorecards were completed.
- Maintaining interest of farmers after focussing on field margins given their interest in soil improvement measures.
- Finding a balance between simplicity of approach and minimum bureaucracy against a mechanism which would encourage and reward more beneficial management
- Scorecards will require more significant testing than the other pilots given their scale of complexity and stage of development.
- Fitting liaison and workshops in with the arable farming calendar.
11 September 2019 – Dalmally – 12 farmers
This workshop introduced outcomes and public goods as well as how results-based schemes have worked in other countries.
Guest speaker – Michael Davoren – The Burren programme
Michael described his farm and his role in the development of a results-based approach on the Burren with fellow farmers. Whilst the type of land and farming systems were not directly comparable, Michael emphasised that the principles can apply anywhere and that the participants can “take ownership”, help shape and influence future direction, and have pride in what they are doing.
The participants came up with a possible list of biodiversity habitats and species which benefited from farming in Argyll and Lochaber hill ground;
Black Grouse, Hen Harrier, Blanket Bog/lowland raised bog, Montane Grasslands, Eagles, Marsh Fritillary, Grazed Glades, Habitat Mosaic, Species Rich Grasslands and wetlands,
We decided to focus on grassland and woodland habitat mosaics on the marginal land beyond the in-bye, together with the hill land, as these areas are not well catered for under AECS yet provide benefits for multiple habitats and species as well as other outcomes such as landscape and water quality. Some farmers were keen however that any “scheme” should have a “totemic” species as an attractive headline.
8 November 2019 – Appin – 6 farmers
This workshop included an introduction to designing scorecards as well as a talk on a results-based project in Ireland followed by trying scorecards in the field.
The indoor session consisted of a short introduction to some factors to be considered when designing scorecards, including the need at times to use surrogate criteria i.e. to measure habitat condition as a means of considering suitability for success of a bird species.
Guest speaker – Ryan Wilson-Parr – Hen Harrier Project, Ireland
This focussed particularly on the rationale of the scorecards and their close relationship to the needs of the target habitat or species, in this case the breeding and foraging habitat of the hen harrier.
This was followed by an introduction to some example scorecards, explaining and discussing the criteria one by one. The group then went out on Achnacone Farm, Appin to field test the scorecards. This raised some issues such as applicability to the different
habitats and how scrub was dealt with, and the scorecards were subsequently adapted by the expert advisors to try to resolve these.
27 February 2020 – Taynuilt – 9 farmers
This workshop allowed the group to score habitat in the field and discuss what ‘good’ looks like as well as discussing stocking densities and payment rate rationale.
The first stop was an area looking across a mosaic of habitats including woodland, scrub, wetland and improved grassland. The group discussed the updated scorecard for Mosaic habitats and the scores arising. The second stop, was on an area of heath looking onto scrub, wetland, bracken and wet heath dominated habitats where discussion continued on grazing and stocking density. These visits were extremely useful in considering the various elements of the scorecards; whether they were all appropriate; and whether the weighting of maximum scores allocated to each element reflected the importance of the various
Gwyn had prepared a note on possible payment rationales prior to the meeting and he outlined the principles and issues at the meeting. We discussed the difficulties arising in formulating a rationale for payment based on current default systems and stocking rates due to the strong policy signal (in BPS) towards 0.05 LU/ha and the overwhelming dominance of the support payments in the economics of the farming system at that stocking density, combined with weak or absent general signals suggesting that some other stocking level (one which should have opportunity costs relative to 0.05) is more desirable.
Expert advisors have prepared the following:
- Bog & Heath Assessment Scorecard (for use on peat soils)
- Rough Grazings Habitat Mosaic Assessment Scorecard (for use on all soil types except peat)
- Designing scorecards which fit the wide range of habitats or species that may be present in the Argyll hill ground is a significant challenge.
- Balancing the desire to reward tree and scrub regeneration, and desire to avoid poaching, with the need for suitable grazing levels, with cattle, to maintain the open habitats. Encouraging more woodland could have issues for tenancies.
- Applying the different scorecards within large areas with multiple different habitats.
- Considering appropriate payment rate basis is difficult. Need to consider appropriate labour rate to reward good management. Keeping cattle is borderline in an economic sense and is directly linked to broader subsidies. We will need to ensure any payment ensures this remains a viable option given the biodiversity benefits of cattle grazing.
12 September 2019 – Edinbane Hall – 15 crofters attended
This workshop introduced outcomes and public goods as well as how results-based schemes have worked in other countries.
Potential outcomes identified by the group included; water quality, public access, biodiversity (plants and wildlife- hen harrier), carbon sequestration and storage, landscape, healthy soils and grazing management.
After discussion, the group decided that a whole-croft approach scoring semi-natural grasslands would be the most useful for a Skye context in this study.
The meeting provided a strong basis to build on as participants were open and receptive to this new methodology. They were also aware of some potential issues but were very engaged in discussions for solutions.
9 November 2019 - Edinbane Hall – 9 crofters attended
This workshop included an introduction to designing scorecards as well as a talk on a results based project in Ireland followed by trying scorecards in the field.
The indoor session consisted of some factors to be considered when designing scorecards, including the need at times to use surrogate criteria.
Guest speaker – Ryan Wilson-Parr – Hen Harrier project, Ireland
This included a short video and a presentation of the Hen Harrier Project focussed particularly on the rationale of the scorecards and their close relationship to the needs of the target, in this case the breeding and foraging habitat of the hen harrier.
The group had an introduction to some example scorecards, explaining and discussing the scoring criteria one by one. The group then went out on croft using Irish scorecards based on species rich grassland (Leitrim and Hen harrier) to try scoring field parcels on a nearby participant’s croft. Initial crofter and agent individual scoring proved to be very similar indicating the ease at which those new to the concept of scoring habitats in this way could master the technique. Potential edits to the cards to fit the conditions on Skye were discussed. Crofters were encouraged to take home the scorecards to score their own fields prior to the next workshop.
24 February 2020 – Edinbane Hall – 8 crofters attended
This workshop focussed on discussing payment rate rationale.
The meeting started off with explaining the background to how agri-environment payments work within World Trade Organisation (WTO) rules. Using the example of a project in Leitrim, Ireland, we examined how the two options of income forgone and additional costs which must underlie agri-environment payment calculations could be interpreted in the context of the three threats faced by biodiversity in that area, namely Intensification, Abandonment and Alternative land uses.
In a results based scheme, payments increase with higher scores and the demands of cross-compliance might mean that very low scores receive no payment. Crofting units, herds and flocks are often smaller than average hill farm equivalent systems. The concept of ‘degression’ i.e. paying more for the first hectares or livestock units was discussed; situations where this is justifiable and situations where it is not e.g. as a means of incentivising the smallest units or flocks.
Full cost of management was discussed as a potential methodology because crofting businesses are loss making. Crofters were assured that any payments discussed were only
illustrations and no commitments can be made for future budgets.
The meeting ended on a positive note that it was important crofting systems were considered at an early stage when any new payments are being developed.
- Incentivising practices which are not profitable – top up payment towards cattle for their biodiversity benefits.
- Irish species rich grassland card may not be appropriate for use on all parcels.
- Skye focussed habitat scorecards will need to be developed in Phase 2.
- Diverging from the current basis of farm/croft support in our assumptions to address the economy of scales found in crofting systems and High Nature Farming outcomes that can be achieved by supporting whole croft management rather than on specific habitat or species outcomes.
- How to use this approach to prevent croft abandonment and consequent additional costs of re-establishing land management activity, particularly involving reestablishment of cattle grazing.
Additional partner projects
SNH commissioned a short piece of work by the RSPB in Shetland through POBAS to work with farmers/ crofters to develop a peatland scoring system. The opportunity to develop the
scorecard with farming stakeholders was cut short because of Covid-19 but there is potential to pick up this work in the future and to test the scoring system in consultation with land managers and subsequently discuss payment rationale.
RSPB have also recently been granted a KTIF application to look at rewarding wader habitat in an outcomes/ results based manner in Shetland which although unconnected to POBAS will be complementary.
SNH are contributing towards a LEADER project in the Outer Hebrides being run by the European Forum for Nature Conservation and Pastoralism, through which a project officer is
employed to develop results-based scorecards tailored to relevant habitats/ public goods. To date there are a number of draft scorecards including for machair wet heath and blanket bog. Although the intended stakeholder consultation has been delayed by Covid-19, it is hoped that targeted individuals e.g. grazing clerks and SNH Area Officers will test the cards. As a result the end date of this project has been extended from September 2020 to December 2020.
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