Agricultural reform: strategic environmental assessment - post-adoption statement

Consultation on the SEA

Screening and Scoping

Consultation was first undertaken with the statutory consultees (ScottishEnvironment Protection Agency (SEPA), NatureScot and Historic Environment Scotland), on the proposed scope of SEA for a 5-week consultation period between July 2025 and August 2025. Each statutory consultee was provided with the SEA Screening and Scoping Report issued by the Scottish Government and comments invited. Consultation responses were received from all three statutory consultees to determine the final scope of the Environmental Report and assessments. The comments received from statutory consultees on the SEA Screening and Scoping Report were included in an Appendix B to the Environmental Report, which also identifies how the comments were addressed for the SEA.

Environmental Report

The Environmental Report was published 12th November 2025 and open to responses until 4th February 2026

Statutory consultees

1. Scottish Environment Protection Agency (SEPA) Comment:

SEPA provided a response with no comments on the SEA.

2. NatureScot Comment:

Overall, the environmental assessment is through and comprehensive in the data included. We consider that the report adequately identifies the environmental issues/concerns, measures, and that the assessment of likely significant effects is satisfactory.

We are satisfied that the issues we raised in our response to the Scoping report (Response 8th August 2025) have been covered.

In addition to this high level comment they provided minor points in relation to Future Farming Investment Scheme (FFIS) suggesting the report should link it more clearly to the benefits for the environment and a suggestion for front loading SSBSS.

SG Response:

FFIS – The first round of FFIS applications had to demonstrate that the grant would deliver at least one of four objectives including to “protect, restore or enhance the environment. It has a wide range as it is dependent on what the grant is awarded for and the context it is used.

It is accepted that the report does not evidence the scheme as strongly as it could in relation to the link to environmental improvement

SSBSS – The introduction of a small herd derogation for SSBSS from 2026 meets similar policy outcomes to that of front loading. The small herd derogation balances the aims of the policy to recognise productive suckler beef production whilst recognising the challenges facing smaller scale beef producers.

3. Historic Environment Scotland (HES)

They make the following comments:

• Express concern that the historic environment is not part of the agricultural support being developed. The reform program is a once in a generation opportunity to promote truly sustainable farming, but that cannot happen without provision to protect and support this finite and irreplaceable resource.
• Accessibility of the consultation and the lack of a direct to the relevant plan (the Agricultural Reform Route Map), specifically that it was not published on Scottish Government Citizen Space hub.

SG Response:

We concur with HES that Scotland’s historic environment is a national asset and a vital and finite resource. The purpose of the agricultural reform is to deliver beyond the limits of cross compliance and GAEC 7 to Retain landscape features (including dykes, hedges and Scheduled Monuments) responsibility for safeguarding Scotland's historic environment and promoting its understanding and enjoyment lies with Historic Environment Scotland (HES).

Public consultees responses

There were no responses received from the public during the consultation phase.

Responding to the Consultation

There were no responses other than from the statutory consultees and Scottish Government will ensure they are provided with a copy of the post adoption statement. In addition to this they will be kept apprised, as appropriate, of future support development as part of the commitment for co-development of agricultural reform.

Reasons for choosing preferred options in light of reasonable alternatives

Strategic level budget splits

• Do Nothing - This option would have fallen short of the desired increased deliverables set out in the Vision for Agriculture which intends to push beyond the policy outcomes of the previous CAP.
• Options for the potential pace of budget allocation shift between Tiers within the support framework:

To give farmers and crofters an indication of how funding will be targeted, we have made three commitments:

• over time, at least half of all funding will be targeted towards nature restoration and climate mitigation and adaption
• 70% of funding will be allocated to Tiers 1 and 2
• we will apply a funding split of 70 / 30 between Tiers 1 and 2’.

This therefore presents a sliding scale of reasonable alternatives in the percentage of budget split, both between T1:T2 (currently 70:30) and between T1/T2 and T3/T4 (currently 70:30).

Tier 1 & 2 Reasonable alternatives

Three options for new protections for peatlands and wetlands:

• Peatland definition - Adoption of a definition for peatland related to peat-depth.
• Protective measures - Adoption of stocking density measures: In addition to the protective measures introduced, stocking density measures were considered.

However, a lack of data at business level and the complexity associated with validation of measures in a way that is consistent with a Just Transition, this option was not taken forward at the time.

For these reasons, this option was not considered reasonable and not assessed further within this assessment.

• Delivery options: Three options were considered for incorporating new protections into cross-compliance:

A) incorporate new protections into existing GAEC (preferred option),

B) create a new GAEC for protections

C) Option A or B plus additional Single Application Form.

Use of an alternative delivery mechanism is not expected to result in different environmental effects at a strategic level. Therefore, this alternative is not considered further in this assessment.

Using a lower threshold for defining peatland is expected to significantly strengthen positive effects across almost all SEA objectives, as a larger area of Scotland’s peatland would be protected, strengthening biodiversity, population and wellbeing, reducing greenhouse gas emissions and improving climate resilience, air, soil and water quality, and further protecting the integrity of heritage sites, waterlogged archaeology and landscapes.

Options for the Scottish Beef Suckler Support Scheme:

• Payment framework options:

Option A - single payment with added calving interval conditionality (preferred option)

Option B (reasonable alternative) - split payment between a base payment on all calves and a top-up payment on calves which meet the calving interval threshold.

Options to mitigate impacts of the new requirements on small herds:

Options for managing stakeholder concerns to mitigate the potential impact of calving interval condition on small herds i.e. front loading (reasonable alternative) vs. small-herd derogation

Options for Enhanced (Tier 2):

• Use of an alternative existing CAP scheme as the delivery mechanism for Enhanced (i.e. cross-compliance, Agricultural Environmental Climate Scheme (AECS) or Manage Application and Claims (MAC)) instead of Greening.

Tiers 3 and 4

Alternative options for the schemes within Tiers 3 and 4 were not identified by the Scottish Government. These Tiers remain at earlier stages of development.