Agricultural transition in Scotland - first steps towards our national policy: consultation analysis
Analysis of the responses received to the Agricultural Transition in Scotland consultation. The consultation was carried out between August 2021 and November 2021.
This chapter presents an analysis of responses to the first consultation questions, which cover baselining and ongoing data collection for measures such as carbon audits and biodiversity. Baselining was identified by the Farmer Led Groups as key to driving progress. The consultation questions examine whether support should be tied to baseline data collection, whether and what data should be collated, and how businesses can commit to incorporating baselining into their practice. An analysis of responses to Q9.3 is also included in this chapter, as its themes overlap with the baselining questions.
Q1.1: Should agricultural businesses receiving support be required to undertake a level of baseline data collection?
|Among all (314)||Yes||No||Don't know||No answer||No. of comments|
The vast majority of respondents (85%) agreed that agricultural businesses receiving support should be required to undertake baseline data collection; fewer than one in ten (8%) felt this should not be the case, and 7% were unsure or did not answer. Agreement was very high among both individual respondents (84%) and organisations (88%), but virtually all of those who disagreed were individuals.
Baseline needed to monitor progress
A view that a baseline is essential for a full and accurate understanding of the current status within the sector was the most common theme in responses, on the basis it can be used to monitor change and progress and assess the success of policy and support.
Using data for planning and business improvement
The use and value of baseline data was the second most prevalent theme. Comments typically highlighted one, or both, of two key benefits. Many described how the data could help farms identify areas for improvement, both in relation to environmental targets and business practices, and develop plans to address those areas. Several felt benchmarking against baseline data could help inform farmers when developing their own plans.
Respondents also highlighted the value of the data in planning more broadly. Government and decision makers could use it to develop policy and guidance, and to inform the direction and level of public funding and support. The potential for the data to be used by the industry more widely, to forecast future performance, was described. It could also be used to inform wider transitions such as the Just Transition and Scotland becoming a Good Food Nation.
"These baseline evaluations can feed into regional land use partnerships so that farms and agricultural businesses are not considered in isolation but a crucial component of overall regional land use strategies as well as measuring progress against national levels and targets." - CIEEM- Chartered Institute of Ecology and Environmental Management
Baseline data collection should be a condition of support
A third common strand of discussion across comments was agreement that support should be conditional on baseline data collection. Most made general statements that this should be a minimum requirement in exchange for continued support. Some felt this gives the taxpayer confidence that public funds are being used effectively.
"This is an absolutely basic 'public good', and if the principle embodied in any new support system is to be 'public funds for public goods' (as it should be), then to have an accurate picture of the baseline state of play is essential." - Individual
Straightforward data collection
Many respondents raised concerns over the potential cost and time implications of data collection. Though most of these respondents agreed with collecting data, there were concerns about the administrative burden, particularly for small farms and crofts. Several respondents called for the process to be as simple and inexpensive as possible with easy to complete forms. There were also calls for support to be available.
"However, data collection can be an administrative burden, especially for small farms that are more likely to already make significant contributions to biodiversity, climate change mitigation and social objectives, and proposals should provide for appropriate procedures and support." – Pasture for Life
Other data collection issues
Various points around data collection were made by many respondents. Most commonly, respondents outlined how the data collection process could be optimised and streamlined. There were calls for the metrics to be relevant, meaningful, well thought out, agreed upon and standardised. A small number expressed a view that the volume of data required should be proportionate to farm size. There were also calls to use standardised tools and calculators, and smart or automated tools, to ensure accuracy and consistency. Respondents expressed mixed views on how the data should be collected and by whom. A small number of individuals argued that farmers should be responsible; other organisations and individuals suggested independent or government assessors, or researchers, would provide better data. The Crofting Commission called for consideration to be given to the practicalities of data collection on shared common grazing land.
Some who argued the data needs to be accurate, validated and be collated and used effectively. A few expressed concerns about the robustness of current data collection. Two respondents specifically noted current tools do not consider grassland sequestration. A small number called factors outside a farmer's control to be considered e.g. weather, flooding, animal health outbreaks and activities being undertaken on neighbouring land.
Some suggested which data should be included in the baseline collection. These primarily focussed on carbon/emissions and biodiversity; a full list of is available in Appendix B.
Important to environmental protection
Several respondents emphasised the importance of baseline data collection in evidencing progress across a variety as environmental measures. These respondents felt the data could drive reduced emissions, improved biodiversity and better soil and water management, and help farmers understand how they can make improvements in such areas. A few felt regular data collection would keep a focus on environmental protection.
Increased transparency and accountability
Another theme, mentioned by some respondents, was the potential for data collection to improve transparency about the sector, and increase accountability. They felt a requirement to provide accurate data would encourage a greater sense of responsibility. A few noted the public could view agriculture more positively as a result.
Q1.2: Should collected data be submitted for national collation? Q1.3: What information should be collated nationally?
|Among all (314)||Yes||No||Don't know||No answer||No. of comments|
Over four fifths of respondents (83%) agreed that collected data should be submitted for national collation, with 6% disagreeing and 11% unsure or not answering. High agreement was recorded by both individuals (82%) and organisations (84%), but most of those who disagreed were individuals. While open comments were given by 250 respondents, not all addressed both parts of the question. This section presents analysis of themes around the benefits and challenges of national collation, followed by suggestions of what data should be collated.
Support for national collation to monitor progress
By far the most common theme in response to these questions was support for national collation of data and the resulting benefits. Many respondents argued it is vital to have a full, clear, national picture of the baseline to be able to monitor future progress and understand changes taking place. Some highlighted the value of national data in giving farmers wider context; the national data could provide a point of reference to benchmark their farm against. More generally, some noted their support and the importance of getting a comprehensive national picture, with a few reflecting that a national collation approach helps demonstrates everyone is working together.
"Scottish Government has set challenging targets to address biodiversity loss and climate change and data will need to be analysed at a national level to monitor progress and highlight areas where additional support is required." – South of Scotland Enterprise
A national dataset to drive action and policy development
The second most prevalent theme was how a national dataset could drive future action and policy development. Several respondents highlighted ways the data could be used. These included: identifying and prioritising areas where more attention, action or resource is needed; improving the targeting of existing support and funds, ensuring that public money is being used effectively; being used for research; informing the development of future schemes, support, funding and incentives; and shaping policy more widely including supporting the implementation of strategies such as Scotland's Third Land Use Strategy, the Scottish Biodiversity Strategy, and Scotland's Forestry strategy. A small number felt that national collation could help drive compliance with national standards and targets.
"In short, if resources are to be dedicated to baseline data collection, this data should be used to derive as much benefit as possible at individual business and whole industry level. National collation has the potential to facilitate both these objectives." – Scottish Tenant Farmers Association
Availability and ownership of data
There were mixed views among several respondents about who should own and access collated data. Some argued that, if collated, individual farm data should be anonymous, that farmers should own their data and that it should not be used for commercial purposes. Others argued that nationally collated data should be available to the public, public and regional bodies and researchers. This was seen as necessary to ensure transparency, ensure good use of public funds and encourage change. A specific point was made about the need to ensure that no publicly available data identifies sensitive wildlife habitats.
Potential negative consequences or impact
A recurring theme was concerns about collecting and using collated data. Several respondents – only a few of whom disagreed with national collation - raised a variety of issues which are addressed elsewhere in this chapter. These included the potential burden of data collection and the need for standardised metrics, simple data collection processes, and high quality data. Some identified other concerns including: a lack of enthusiasm from farmers; that the data could be biased by organisations trying to secure funds; and that the data could be used to assign blame to farms, sectors or areas of the country. A very small number felt that national data would have little or no impact.
Levels of data
Another theme, raised by some, was the challenge of reflecting the diversity of land use and agriculture in Scotland in national data. There were concerns that national data could lead to unfair comparisons and calls for national data to have sufficient context and reflect the variety of the sector. However, others noted that national data could help improve understanding of regional differences, and there were some calls for regional, local or farm type level data to be available. One suggested that using SEPA (Scottish Environmental Protection Agency) local offices might be an appropriate scale; another mentioned involving Regional Land Use Partnerships (RLUPs).
"There are differences between types of land, types of farm and location/weather. Therefore a national collation will mean very little." - Individual
Types of information to be collated nationally
Reflecting the focus of the consultation paper, the three types of data most commonly suggested by respondents related to carbon and greenhouse gas emissions, biodiversity and soil. These are described below. Various other suggestions were made, including sequestration, water quality, socio-economic measures, and animal welfare. These are detailed in Appendix B.
Carbon and Greenhouse Gas emissions
Collecting and collating data on carbon and greenhouse gas emissions was the most common suggestion. Most called for this in broad terms but where detail was given, respondents suggested pooling the results of carbon audits. Scottish Agronomy raised the global warming potential of Nitrous Oxide and the British Veterinary Association called for policies to reflect the different types of greenhouse gases.
Another prevalent theme was biodiversity. Scottish Wildlife Trust and a group of respondents who gave a similar response noted the Scottish Biodiversity Information Forum's review, which highlighted a need to improve the infrastructure for recording, managing, sharing and using wildlife data. They argued improved data would help capture the state of Scotland's species and habitats and actions farmers are already taking.
Soil health and management
A recurring theme was a variety of requests around collating information on soil. Some called for analysis of soil health in general through regular sampling. Others specified soil carbon, pH, nutrient status and management, and microbiology. Conversely, NFU Scotland noted that soil measures are more aligned to specific agricultural businesses, and so there is little value in national collation.
Q1.4: What are the next steps that can be taken to commit businesses to continuous improvement utilising the information presented by carbon, soil, biodiversity auditing?
Responses to Q1.4 were given by 284 respondents. There was significant overlap in the themes emerging from Q1.4 and Q1.5. This section focuses on themes which may increase commitment to continuous improvement, with the analysis under Q1.5 focussing on other steps which could encourage participation.
Financial incentives and a condition of future funding
The most common theme at Q1.4, and third most prevalent at Q1.5, was the role of financial support in ensuring commitment. A variety of approaches were described in comments, from the use of incentives and penalties, support in the form of grants and subsidies, and making continuous improvement a condition of future funding. Though most referenced incentives in financial terms, support such as training was also mentioned.
Many advocated for a system of rewards and incentives, using a 'carrot not a stick' approach. Suggestions included: incentivising farmers to collect data; using collected data to adjust payments according to performance; and additional funding or support for those who exceed expectations or undertake voluntary improvement. While penalties were less commonly mentioned, there were calls for fines or removal of funding for those who fail to comply or do not meet targets. Some respondents repeated their call to ensure whatever system is put in place does not penalise those who have already made positive progress.
Several respondents suggested using grants and subsidies, often as part of the reward system outlined above. These comments typically highlighted the financial costs to farm businesses – particularly small farms and crofts - of committing to improvements and the need to help cover those outlays. A small number noted that financial support helps increase farmers' confidence reducing the risk associated with changing practice. Plantlife Scotland made a specific call to ensure funds are delivered on time and paid consistently over the long-term, to address the high levels of financial uncertainty in the sector. A few respondents argued that any carbon producing activities should no longer be subsidised.
The third sub-theme was to make future funding conditional on showing improvement. Responses ranged from basing all payments on this, to having a tiered approach with a baseline payment for activities which meet criteria, supplemented by incentives as above.
A small number of respondents raised timescales, calling for schemes to have sufficient longevity to reflect the fact that much environmental change can take time. This would make farmers more confident they will benefit from taking action in the long-term.
"For agricultural businesses to commit to delivering continuous improvement on their carbon, soil and biodiversity indicators, it will be essential that the Scottish Government create a conducive environment, including ensuring that the businesses can continue to remain economically viable. As many have observed in the past, it's hard to be green when you're in the red. Agricultural businesses will need to be financially supported in enhancing their delivery of these public goods." - Royal Institution of Chartered Surveyors
"Put a huge emphasis on education and awareness within the farming community that they must now 'produce' environmental outputs (measured through these surveys) . Speak of it as a market in environmental goods. And then link it 100% to base subsidy payments. Farmers are very inventive at producing goods if the signals are clear, make the signals clear." - Individual
Continued monitoring and effective use of data
The second most common theme was how continued data collection, and effective use of data, could ensure commitment. Some respondents called for regular audits to verify progress against the baseline; a few felt this should be done annually. Related to this, some expressed concerns around continued data collection, raising the need for fair and accurate data and simple data collection process. As this was the second most common theme at Q1.5, these comments are included in that analysis below.
Several respondents highlighted the need for data to be used effectively to benefit the sector and individual farms. They described the importance of publishing the data widely and regularly, ensuring reports, guidance and recommendations for improvement are clear and accessible, and of providing farmers with training on how to use the data. Some called for experienced and independent stakeholders to monitor and report on change. A few said case studies could promote success and demonstrate best practice.
"Using the data collected to inform the likes of Climate Smart Farm Plans and Climate Smart Transformation activities would help drive businesses in the required direction." – NFU Scotland"
Education, training and advice
While this was the third most prevalent theme at Q1.4, it was the most common at Q1.5 and a full analysis is presented under Q1.5 below.
Whole farm plans
Preparing whole farm plans was a recurring theme at both Q1.4 and Q1.5, mainly in comments from two groups who left similar responses throughout the consultation. An example, provided by Scottish Environment LINK, is below. In addition to these consistent comments, a few others highlighted the value of whole farm plans.
"The information presented by carbon, soil and biodiversity auditing should be used to help prepare whole farm environment plans. These plans should identify: a) where urgent action is needed to reduce or minimise environmental impacts; b) activities/practices that should continue in order to maintain existing good practice; and c) opportunities for action to enhance and improve environmental performance. The preparation of plans should be supported by farm advisors. Plans could identify sources of government financial support and grant aid for the activities included." – Scottish Environment LINK (and others)
Communicating benefits to farmers and crofters
Several respondents at Q1.4 and some at Q1.5 highlighted the need to ensure farmers and crofters understand why the data is being collected, how the data can benefit their business both financially and environmentally, and the need for environmental improvement. A small number noted that this could be aided by ensuring that the data collected is relevant and useful. Equally, some called for clarity on how the data can be accessed and used by farmers, arguing it needs to freely available in easy to understand formats, with scope to view relevant data in the context of farm type. A few also highlighted the importance of providing a range of solutions for different farm types.
"An information and engagement campaign which makes clear what added value baseline data collection will bring and which demonstrates how to take samples and make measurements will be important." – Royal Society of Edinburgh
Q1.5: How can baselining activities be incorporated into common business practices across all farm types?
Over four fifths of respondents (259) answered Q1.5. Key themes evident in responses were the need for education, training and advice and a desire for a simple approach to data collection. In addition respondents reiterated comments which have already been addressed under the analysis of Q1.4; including linking future support to baseline activities, whole farm planning, and communicating benefits to farmers and crofters.
Education, training and advice
The most prevalent suggestion for incorporating baselining activities into common practice was to provide sufficient education, training, advice and guidance to the sector. This was also the third most common theme to increase commitment to improvement at Q1.4. Knowledge and skills in the sector are also the focus of Chapter 9.
Many of those calling for greater emphasis on education, training and Continuing Professional Development for farmers did not give more detail. Some identified a need for training on data collection and how to interpret and use data to benefit farm businesses. The importance of new technology skills training and how to use any new data collection software, and for training in agroecology and land management, was also raised. Scottish Wildlife Trust suggested creating a 'chartered farmer' qualification, and a very small number felt entry level qualifications should be a pre-requisite for applying for support.
Requests for advice and guidance took many forms. These included: provision of knowledge transfer initiatives, including peer-to-peer learning and sharing of good practice through forums such as farmer led groups; mentoring; funded advisory services; support from volunteer organisations; and suggested roles for the Farm Advisory Service (FAS) and SGRIPD (Scottish Governments Rural Payments And Inspections Directorate). A small number suggested a focus on younger farmers, or for on-farm visits to reach those who may not usually engage. Farmer-led approaches, using local farmer groups or clusters, were mentioned by a few respondents. Examples included Strathmore Wildlife Cluster, Lynbreck Smallholding in Cairngorms, and the network of LEAF Innovation Centres and Demonstration Farms.
"We need to ensure farmers and crofters have access to appropriate support and advice to develop knowledge and confidence in the role of healthy soils, healthy farm ecosystems and the role of nature in ensuring business resilience and profitability BEFORE we can take steps to commit businesses to continuous improvement this type of auditing will demand… Our current advice and education provision is lagging behind and not preparing current farmers and crofters or the next generation for the transition and adaptation they inevitably will have to face." - The Nature Friendly Farming Network
Simplify data collection
The need for simple data collection processes, which minimise additional work for farmers and crofters was the second most prevalent theme. In these comments were general calls for processes to be as simple as possible with a few key metrics on the basis that this would make them quick to complete and easy to incorporate into farming practices, thereby encouraging participation. A small number requested that farmers of all types are included in the design and regular review of baselining activities to ensure this is the case.
"Strip it down, make it easy to complete, no-nonsense and straightforward." – Individual
Some respondents called for a standardised approach with clarity on which measures are used, consistent procedures for information gathering, measures to avoid duplication, and standardised, user-friendly data collection templates.
Another theme was a call for baselining activities to be incorporated into existing data collection and auditing, or to use existing data for baselining. Specific proposals included: incorporating data into annual census returns, annual SAF (Single Application Form) return, or as part of EFA (Ecological Focus Areas) notation; for data collection to form part of departmental inspections; using a system similar to IACS (Integrated Administration and Control System); or through Scottish Environment Web or SGRPID reporting. Two respondents noted their dislike of the FAS Carbon Audits which was seen as too generic to provide meaningful recommendations.
Suggested approaches to data collection
A wide variety of suggestions and examples of approaches to data collection were put forward in responses. Some shared examples of specific tools, processes or frameworks to use or replicate; these are listed in Appendix B. Approaches which were suggested by very small numbers included online forms or apps, the use of independent advisors, assessment by professionals such as ecologists, and cooperation with environmental / wildlife groups who have experience of monitoring biodiversity. A few commented on timescales, advocating long-term monitoring and suggesting annual or bi-annual reporting and updated Land Management Plans. SOAS (Scottish Agricultural Organisation Society) outlined the potential for co-operatively owned data and the wider adoption of smart sensing technology.
Addressing the variety of farm businesses
Concerns about how to implement baselining activities across the diverse range of farms and crofts in Scotland was another response theme. Despite calls for simplicity and standardisation, some respondents felt a 'one size fits all' approach would not work and called for tailored activities or approaches depending on the type and size of farm.
"One or more models of best business practices should be developed, for each of the sectors (arable, beef etc) to make it easier for individual farmers/businesses to adopt them" – Individual
Q9.3: How can ongoing data capture and utilisation be enhanced on Scottish farms and crofts?
Seven in ten (219) answered Q9.3. Several reiterated general points about baselining which have been covered earlier in this chapter. The analysis in this section presents the themes which directly addressed the question.
Straightforward data collection
There was a recurrent call for data collection to be simple and straightforward, with two main themes within this strand of discussion. Several respondents highlighted concerns around the potential cost and time implications of data collection, and asked for it to be easy and with as little paperwork or bureaucracy as possible. The consensus was that this would encourage uptake and reduce resistance. A few asked for duplication be avoided.
Using simple digital platforms or apps for data collection was also mentioned by several respondents, whose suggestions included making websites more user-friendly and to allow for cross-platform data entry. Despite calls for digital processes to become the norm, a small number called for the continued use of paper forms, primarily due to concerns over digital literacy.
"Data capture and recording takes time and commitment, and is largely an office job. Farmers are good at multitasking but few have surplus time for office work so it's crucial that the move towards a new support structure is managed very carefully as the industry learns to record and use data effectively." - Individual
"There is a need for a common shared platform for data capture and data sharing, or minimisation of the number of platforms. There is a role for Scottish Government to help streamline the various initiatives, tools, and platforms that are currently available and ensure that user access is easy and at minimal cost to the land manager." - NatureScot
Other digital approaches and challenges
The second most common theme was the potential role of technology. A small number described new technology which could help data collection, including satellite data, remote sensing and monitoring, aerial drone surveys and Artificial Intelligence. Some respondents noted that poor broadband connectivity in rural areas limits the use of technology and called for this to be improved. A few respondents highlighted a perceived lack of digital skills in the sector, and suggested that advice and guidance should be available to support farmers in using any new technology.
"As a first step, ensuring that every business has access to reliable, fast broadband would enable digital solutions to be easily deployed and utilised universally. We still see many farm businesses put off utilising digital solutions because of a lack of connectivity." Quality Meat Scotland
Providing support and guidance
Another theme was the need to provide support and guidance to the sector. Many comments were general calls for advice and training in data collection approaches. Other specific suggestions included workshops with practical demonstrations and supporting local crofting associations through visits. A few called for training on how to analyse and make best use of any data collected and two suggested peer-to-peer learning.
Link to existing data collection
Some respondents asked for new data collection to be linked to or included in existing data collection requirements. Suggestions included making it part of, or replacing, the SAF, annual census information, or ScotEID.
Farmers should be able to use and own the data
The importance of ensuring learning from data analysis is communicated back to farmers in clear and accessible ways was highlighted by some respondents. Transparent, easy to access data, presented in regular reports, events and digestible formats, was felt to be needed to help farmers understand what improvements are required and to drive change. A few respondents felt it was important that the benefits of collecting data are communicated to farmers to encourage their participation. Related to this, a small number of respondents expressed a clear view that farmers should own the data they collect.
Ways to collect the data
Various comments were provided about how the data should be collected and by whom. Most called for farmers to collect the data themselves, with some suggesting they should be paid or incentivised to do so. A few respondents suggested collaboration with local communities, nature organisations, volunteer wildlife recorders, SEPA, and universities.
Collecting relevant data
Respondents highlighted the need to ensure that data collection is focussed on relevant data and metrics. Some noted that a large volume of data is already collected, but it needs to be analysed and used more effectively to help the sector develop.
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