Academic Advisory Panel - Review of weightings applied to potential new arable EFA options: advisory note

The Academic Advisory Panel (AAP) prepared this advisory note and its recommendations in response to a request from Scottish Government officials to review the process of assinging weightings to four potential new Ecological Focus Area (EFA) options for arable land. This note summarises discussion held during the AAP meeting on 3 February 2025 and the consensus reached.

Introduction

Greening was introduced to improve the environmental sustainability of farming. The Greening payment for agricultural practices that benefit the climate and environment is paid in addition to the Basic Payment Scheme.

Recently, Scottish Government officials identified the need for changes to the existing Greening scheme to expand the number of EFA options available to farmers and crofters aiming to broaden the policy outcomes that Greening could achieve. The process of assigning weightings - alternative values used to calculate support payments - to four potential new EFA options for arable and permanent grassland was presented to the panel.

The key factors considered in assigning weightings included biodiversity impact, landscape features, length of management period, financial costs of implementation, and Greenhouse Gas (GHG) emissions. Table 1 lists the four potential new options for 2026, along with the recommended weightings, which were assigned by comparing all criteria against existing EFA options.

Proposed Ecological Focus Area (EFA) Options with Requirements, Weightings, and AAP Recommendations

1. Agri-Forestry Low Density Planting

   • Requirements: Trees planted at 20–50 per hectare, native species including fruit trees, protected with guards.
   • Proposed weighting: 2
   • AAP recommendation: 2

2. Unharvested Crop

   • Requirements: Must separate two crops, 6–12 m wide, no nitrogen fertiliser or spray, single species sown, remain unharvested until 31 December.
   • Proposed weighting: 1.5
   • AAP recommendation: 1

3. Legume and Herb Rich Pasture

   • Requirements: At least 3 herbs or legumes in seed mix, minimum 1 eligible legume.
   • Proposed weighting: 1
   • AAP recommendation: 1.5

4. Low Input Grassland

   • Requirements: No artificial fertiliser, no poaching.
   • Proposed weighting: 0.2
   • AAP recommendation: Do not take forward

The aim is to make this process repeatable for potential new options in future years. The panel was invited to provide feedback on the weighting methodology developed by government officials and the proposed weightings.

Key Summary

The AAP made the following recommendations:

Documenting the process - the panel commends policy officials for their efforts in designing the process of assigning weightings to potential new EFA options and for the progress made compared to the EU process. They emphasise the importance of documenting the process to ensure traceability and support future expansion.

Use caution with existing EFA weightings - The weightings of the existing EFA options should be treated with caution when used as a reference for establishing weightings for new options, as their applicability may not be directly transferable.

Incorporating uncertainty ranges – To account for the diversity in stakeholder feedback and variations in key assessment factors such as biodiversity outcome, length of management period, financial costs, income forgone, and GHG emissions the panel recommends incorporating uncertainty ranges into the final weightings to help guide future research and decision-making.

Allowing for flexibility in weightings - the AAP advises allowing flexibility in weighting values and developing a clear strategy for effectively communicating that weightings may change over time (to reflect uptake, prioritisation, normalisation of practices e.g. into compulsory GAEC, etc) and the policy implications of such flexibility.

Adjusting weightings – The panel recommends reviewing and adjusting the weightings (see Table 1):

• agro-forestry low density option - weighting should stay unchanged
• unharvested crop option - weighting should be lowered to 1
• legume and herb rich pasture option - weighting should be raised to 1.5
• low input grassland option – option should NOT be added to the list of EFA options

Key discussion points

• the panel commended policy officials for their efforts in designing the process of assigning weightings to potential new EFA options and for the progress made compared to the EU process. It is crucial that this process is documented to ensure traceability and to support future improvements and expansion

• the AAP advises treating the weightings of the existing Ecological Focus Area options with caution when used as a reference point for establishing weightings for the new options. Specifically:

• the Green Cover EFA option should have a different greenhouse gas emissions weighting than the Catch Crop option. Green Cover crops can be planted late and ploughed early, which does not align with GHG reduction goals. The weighting for Green Cover should be reassessed
• the scoring of the nitrogen-fixing crops option does not reflect their potential benefits in reducing synthetic fertiliser requirement and offsetting imported protein. Uptake will likely remain low if the scoring or guidance around spraying after the crop and the minimum two species requirement is not reviewed

• the AAP recommends acknowledging variations and uncertainties associated with key assessment factors and diversity in stakeholder scoring. Values applied to key factors considered in assigning weightings, (financial costs income forgone, additional cost of implementing new measures, GHG emissions, and biodiversity) will have a degree of variation due to natural variability or knowledge limitations. This variation has been particularly prominent in relation to potential biodiversity benefits from proposed options. This variation should be addressed by adding uncertainty ranges to the existing scoring system, which would help identify areas with potential research gaps and guide future research
• the AAP recommends that the system should be treated as dynamic, with flexibility in the weightings. Changes in weightings could signal a need for higher uptake rates. The AAP also emphasises the importance of communicating to farmers and crofters that weightings may change over time and the potential policy implications of such flexibility
• a key issue that needs more consideration in policy discussions is the recognition of ‘ineligible features’ on farms that are not currently recognized as habitats. To maximise benefits of Greening payments, these features need better recognition and management. For example, tree lines, water bodies, marshes, gorse, and tree thickets are not included in the current greening options, despite their role in biodiversity and land management. Reviewing and revising policies to incorporate these valuable features into future land management schemes presents a significant opportunity for improvement
• the AAP supports assigning a weighting value of 2 to the Agro forestry low-density planting option. This option has the potential to encourage tree planting, especially among farmers and crofters who need shelter for their livestock. Introducing tree planting at a small scale can act as a “gateway” for further planting. However, rows of trees on arable land may be seen as unattractive or impractical. Agroforestry should be considered in relation to temporary grassland or land that could be grazed. Additionally, this option should be considered for extending existing habitats and linear futures

To avoid confusion, definitions for both agroforestry and low-density planting should be provided. This will help farmers and crofters to determine which option to choose. Small farm woodland should be linked explicitly to the Scottish Forestry Grant Scheme.

The AAP recommends maintaining consistency in definitions between Scotland and England. The Forestry Commission has defined terms for very low, low, medium, and high density in-field agroforestry. Definition guidance can be assessed here: Funding and grants for agroforestry - GOV.UK

• the AAP recommends reducing the scoring for the Unharvested Crop EFA option to 1. This is because having an unharvested crop in the field will not remain stable over time. While it may provide soil nutrition benefits, its environmental benefits for biodiversity are likely to be lower than those of the EFA field margin (currently scored at 1.5). Additionally, the guidance associated with this option may make it less attractive to farmers. Restrictions on the application of fertilisers and plant protection products may be seen as high risk, particularly for those relying on contractors, as this increases likelihood of operator error, such as accidental spraying. The required width of 6-12 meters is also significant, making implementation more challenging. In some areas, this option may be further discouraged due to the potential for attracting geese in greater numbers, which could negatively impact other biodiversity, as well as human and animal health. In such regions, the existing margins EFA option is likely to be preferred. Consultants will play a key role in advising farmers and crofters on potential changes, and it would be beneficial to sense check this option with consultants to ensure feasibility of uptake. Scoring should also be reviewed in collaboration with other stakeholders, e.g. RSPB or NatureScot, who can provide additional context on the biodiversity benefits of these options
• the AAP recommends increasing the scoring for legume and herb-rich pasture on arable to 1.5. Legumes facilitate biological nitrogen fixation (BNF), reducing the need for artificial fertiliser and therefore driving a reduction in GHG emissions. This option is likely to offer long term benefits if temporary grassland becomes permanent after 5 years. However, it should be noted that establishing legume-rich pasture without plant protection products may be challenging in some circumstances. This option is also expected to offer more biodiversity and soil health benefits than fallow land (currently scored at 1). To encourage uptake, a higher weighting is necessary to recognise the additional work required compared to simply leaving the land fallow. Some practical challenges associated with guidance for this option that should be addressed include:
  • the requirement that the crop “must be clearly identifiable and distinguishable on the ground from 1 January to 31 December inclusive” means that, to qualify for that option in 2026 those establishing their grass in Spring would have to sow herb and legume rich pasture in spring 2025. To make this option feasible in the first year, a date adjustment (e.g., changing the period to 15 May – 31 December or another derogation may be necessary
  • this option may result in grassland being left fallow (ungrazed) after July for silage harvesting or over-fertilized with slurry or manure to meet year-round fertility requirements. Establishing temporary grass (TGRS) without weeds is challenging, making fallow a more practical choice despite its grazing restrictions. Additionally, the recommendation to use a hay tedder may not align with modern harvesting methods
  • farms with abundant TGRS but no designated TGRS1 or TGRS2 on the Single Application Form (SAF) may struggle to comply. They may have to rely on hedgerows, trees (unsuitable for Orkney), fallow land (unpopular due to grazing limits), or sowing new TGRS, which could introduce weed management challenges. The rules around TGRS rotation make compliance particularly challenging in the first year
  • weed control challenges in some areas could lead to a poor quality grazing or silage
  • restrictions on fertiliser application may reduce fodder availability, particularly for multiple silage cuts from high-quality grass (TGRS1). As a result, some farmers may opt to plough permanent grassland (PGRS) and establish permanent fallow to meet the grassland EFA requirements. This approach would allow fertilisers and spray use after 16 July enable silage production, though without spring grazing. In regions where hedgerows are common, farmers will likely incorporate them into their EFA strategy, though they provide limited environmental benefit compared to GAEC. Some may consider low-density planting, but in areas like Orkney, this may not be a viable option
  • consideration should be given to how failure to establish legumes and herbs will be addressed

The AAP recommends that the EFA low-input grassland option should not be added to the list of EFA options. This option is intended only for those who have permanent grassland (PGRS) and more than 15 ha of arable land. The low weighting of 0.2 for this option is justified due to limited environmental benefits. Its adoption could lead to unintended consequences, such as large areas being shifted into low-input grassland by arable farmers, which would reduce the environmental benefits of existing EFA arable options. This option may also present practical challenges, as for every 5 ha of permanent grassland required it would require 25 ha of actual low (no-input). More significant environmental benefits could be gained by focusing on temporary grassland or introducing alternative grassland measures.