Agriculture Reform Implementation Oversight Board minutes: 4 May 2023

Minutes from the meeting of the group on 4 May 2023.

Attendees and apologies

  • Cabinet Secretary for Rural Affairs, Land Reform and Islands, Mairi Gougeon (Co-Chair)
  • Martin Kennedy ( Co-Chair)

Items and actions

Welcome (agenda item 1)

The Cabinet Secretary welcomed members to the nineteenth meeting of the ARIOB, offering apologies on behalf of Claire Simonetta and Marion MacCormick.

There were no substantive comments on the previous minutes from 3 February so, as standard procedure, a summarised version will be published to the Scottish Government website.

Before moving on to the substantive agenda item of the day, one member stated that the Biodiversity Audit update wasn’t particularly informative and asked that future iterations would provide more in the way of detail and an action point was taken.

Whole Farm Plans (agenda item 2)

The Cabinet Secretary made reference to an action from the last meeting to hold a session on the Framework, however, it was decided that the best use of members’ valuable time, in light of the strong feeling on the topic, would be to address the issue of Whole Farm Plans (WFPs).

She hoped for Board views on the proposed approach, which has been revised following their robust feedback in Dunfermline (July 2022) and invited officials to start a wider discussion on WFPs.

Officials cited the meeting paper, wishing to provide the Board with a simple overview which acknowledged previous discussions and feedback received in Dunfermline and might stimulate further discussion. The paper is intended to spell out the context and purpose of WFPs while being clear on what was consulted on as part of the Agri Bill consultation.

Officials are mindful of the push to deliver something cohesive which will allow farmers and crofters to make future claims, demonstrate the appropriate use of public funds and access the relevant support. A steering group is to be established to make further progress as part of the SG’s continued commitment to co-development and their initial focus will be on providing a productivity baseline. Officials opened the floor to ARIOB, citing some of the discussion points within the paper.

Comments from ARIOB members:

  • clarity is required over what is meant by a business plan – a concise single-page document or a whole dossier of farm information? Who are they serving? Will this require annual, 5, 10 year revisions?
  • officials sought to provide reassurance by stating that not decisions had yet been taken and that the service design approach would inform them
  • plans would be as detailed as businesses want them to be – there is no current expectation of a proscribed model, it is simply a tool to provide documented evidence against the use of public funds
  • continuing professional development was mentioned by a number of members, with uncertainty over plans, and that if it is to be a living document, sufficient guidance must be provided alongside
  • health and safety, air work and equalities duties cropped up more than once, with several members citing concerns over their respective inclusion(s) – primarily because these are all existing statutory management requirements so would result in a duplication of effort and unwanted, additional bureaucracy, offering no added value
  • officials added that they will make sure there is no duplication
  • other members were disappointed that WFPs, as presented, remain substantially different to proposals discussed by the Farmer-led Groups. Which examined productivity/technical aspects which are not reflective in the proposed baselines
  • there was some concern and scepticism over potential snowballing of RPID or Audit Scotland follow-up compliance/verification checks, particularly if Scotland re-joined the EU. Again, officials sought to allay fears that there would be future verification, reiterating that the aim of WFPs is to foster best practice and will be customer-led to support the intended outcomes within the Vision for Agriculture
  • one member was pleased to see that soil testing, Animal Health and Welfare and carbon and biodiversity audits were presented together to demonstrate the need for all to be include to increase efficiency and productivity
  • another pointed out that this could be expanded, that understanding the environmental asset base was a more strategic approach than simply biodiversity alone
  • there was some concern as to the relevance of some measures for smaller and/or crofting businesses, especially as many are covered by existing legislation. What’s the added value here in making all agri businesses comply with this? One size fits all is not the right approach
  • it was argued that the WFP as proposed is in stark contrast to Scottish Government’s wider approach to land management and may even encourage people to leave the industry altogether given the loss risk of making errors
  • in removing “unsuitable” principles from the WFP, it was hoped that these would not be left unaccounted for, but placed in Tier 4 and CPD is key to that
  • government must support the professionalisation of the sector by highlighting what CPD is available
  • in addition, engaging with peer support can provide indirect benefits such as great wellbeing and social cohesion. Officials agreed on the importance of this, particularly as not all sectors are in the same place on CPD
  • co-chair hoped that a pragmatic approach of corralling the required information into a SAF would be considered – it needn’t be complicated


At this juncture, officials acknowledged the desire from members to allow businesses to navigate some of these issues themselves, avoiding perceived government overreach. However, in an attempt to define a consensus position, officials asked the Board if it was a fair assessment that they agree with WFPs as how agricultural businesses seek to deliver on food production and climate and nature obligations while appropriately utilising the proposed tiers based on their individual businesses. However, plans should be simple, without red-tape and not an onerous bureaucratic exercise.

Further comments from ARIOB members:

  • one member said that outwith steps being taken on food, emissions reductions and nature, anything else is irrelevant for the purposes of a WFP
  • it should be solely a vehicle for demonstrating businesses use coherent policy mechanisms without the need for consultants
  • co-chair added that in terms of a public return for consumers, they are less interested in business planning and more on what steps are being taken, so that simpler approach chimes with that
  • another member pleaded for farmers and crofters to be treated as adults, keep it simple and focus on essentials but avoid the continual need to go to the lowest common denominator
  • there was further criticism that this conclusion could have been reached had officials “read the room” in Dunfermline as much of what was said then has been said today. Officials retorted that they have been listening and have removed some of the more controversial features from WFPs since then
  • the Cabinet Secretary acknowledged the need to reduce bureaucracy and that the steering group is intended to design something that will work for all

Steering Group

Co-chair reflected on the clear steer given by the Board and questioned the need for a steering group as a result. This can’t be allowed to drag on given the likely reaction within industry – it could be as simple as a declaration on the SAF but without Health and Safety and Fair Work principles as they are already monitored elsewhere.

The Cabinet Secretary appreciated the point made on the steer from within the Board and the need to get things moving but not having a sub-group would defeat the purpose of wider co-development.

Comments from ARIOB members:

  • officials were asked how they would create a representative group of farmers and crofters, highlighting the existing misunderstanding of overall policy direction
  • wfp's will be an important part of the process. Officials responded that service design colleagues have the expertise to take this forward and bring together a representative sample
  • a further question was asked on whether it was the Government’s intention to include baselining aspects, as presented to ARIOB, to the service design colleagues and steering group, however, members were reminded that it is not within the gift of officials to make such decisions, they provide advice to the Cabinet Secretary in the context of what is deliverable and based on feedback from groups such as ARIOB and consultation responses
  • a plea was made to allow the Policy Development Group (PDG) to be involved from the outset, having not been part of WFP development thus far
  • co-chair mentioned the lack of meaningful co-design so far and was keen to nail down potential members of the steering group, suggesting members of, PDG, select external participants and officials representing RPID
  • others agreed and asked for a clear timescale given the slow pace up until now, hoping that it could be established before the next Board meeting in June.
  • however, others suggested that genuine sector testing will take longer and June would be unrealistic
  • the Cabinet Secretary noted it is four weeks until the next meeting but would hopefully be possible for the steering group to meet before then and report back at least an initial summary of discussions. The Cabinet Secretary also agreed with the proposed make-up of the Group, including the PDG, without wanting to preclude others who wished to be involved and an action point was taken

AOB (agenda item 3)

Agriculture Bill

Asked about the outcome of the Agri Bill consultation, officials discussed engagement with the external analysis company but remain hopeful of publication this month (May 2023) and will share with the ARIOB as soon as possible. The Cabinet Secretary added that it would be tabled for discussion at the next meeting.


Co-chair opined that if there is to be a change in regionalisation, the Board needs more information and analysis and it must be talked about in June or the immediate meeting thereafter. Co-chair also raised the issues of a smallholders scheme and frontloading as really important, which are yet to be discussed and can’t be pushed further down the road. Others agreed on regionalisation and asked that it be placed on the next meeting agenda.

Based on that, the Cabinet Secretary offered to have a conversation during the June meeting about immediate agenda setting – what we can phase in and appropriate scheduling depending on importance. The next meeting will provisionally cover conditionality, the route map update and Agri Bill analysis.

The Cabinet Secretary closed the meeting and looked forward to seeing everyone in Dundee on Friday 2 June.

Summary of actions:

  • officials to provide a more detailed update on the Biodiversity Audit
  • officials to set-up a Whole Farm Plans (WFP) steering group to include the Policy Development Group (PDG), external participants and representatives of RPID with a view to meeting ahead of the next ARIOB meeting in June.

Additional Notes and Handling

Some speakers used PowerPoint presentations to illustrate their talks.

Where the author has given permission, these are available on request, using the contact address below. Please note, these remain the copyright of the authors and should not be used for any unauthorised purpose.



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