Land Reform (Scotland) Bill: business and regulatory impact assessment

Annex A

Measures applicable to large-scale landholdings

The Bill introduces four measures which would apply to large-scale landholdings. Our current working assumption is that large-scale landholdings will be defined as landholdings of more than 3000 hectares or land that accounts for more than 25% of a permanently inhabited island, with a minimum area of 1000 hectares, as set out in the public consultation, These measures are:

New duties on owners to support compliance with the principles of the Land Rights and Responsibilities Statement (LRRS);

The introduction of compulsory land management plans;

The introduction of a test at the point of transfer of a landholding to determine if the landholding should have conditions placed on that transfer; and

Requirements for community bodies to receive prior notification of impending sales or transfers.

Where all or a portion of the landholding is subject to a tenancy agreement meaning that the landowner does not have control over land management decisions for that land, this would be taken into account in terms of the duties and requirements on the landowner.

We need to strike a balance between the land rights and responsibilities of landowners, communities and the wider public. We do not wish to place an undue administrative burden on small businesses which would disadvantage them relative to larger landholdings with more staff and capacity.

Given that the Bill is still under development, the matter of administering authority is still to be finalised. At this stage, it is probable that the functions in relation to the LRRS duties, management plans, and investigation as part of the transfer test will fall to the Scottish Land Commission, with administrative responsibilities and decisions in relation to pre-notification and the transfer test being determined by Scottish Ministers in line with current arrangements in place for the existing statutory community rights to buy. Resourcing decisions are yet to be determined.

LRRS Duties

Proposal

Landowners would need to comply with specific duties based on LRRS principles, focused on engagement and land management plans.

Breaches of the duties could be reported to the administering authority, who if satisfied that a duty was not being complied with, would in the first instance prioritise advice and support to support the landowner to remedy the breach.

Where a breach is proven and not remedied there could be financial penalties.

Questions

• Do you have current and/or past experience of community engagement activities?
• What were the impacts of undertaking engagement?
• What were the impacts of undertaking engagement?
  • For example, how did it affect your timescales, did members of the community engage, did it lead to changes, were there subsequent delays to certain activities/tasks – if so what was the impact on the business?
  • Are you able to share cost and/or resource implications of engaging with local communities, e.g. meetings, workshops, etc.?
• Do you/the landholding have experience with leasing areas of land to local communities or local businesses?
  • If so, can you provide more detail about the scale and length of those leases, and was it for a specific agreed purpose?
  • Are you aware of any positive or negative impacts of leasing land in this way, such as financial or social impacts?
  • If you have direct experience of impacts, are you able to quantify these?

Land Management Plans

Proposal

Requirement to consult on, publish and update a land management plan. A plan may require information such as:

• A long-term vision and objectives for the landholding
• High level management proposals over a long period
• Details of the land owned, including a map.
• Information about land that may be available for lease or sale over the life of the plan
• How the management contributes to carbon emission reduction and/or nature restoration
• Note that details are only an example, looking to understand impact of providing a range of information.

It’s proposed that local communities should be engaged on the development of land management plans. Guidance would set out what the expectations for this engagement would be, so that parties were clear on what steps would need to be taken to meet the requirements. Plans would be required to be updated periodically, e.g. every 5 years.

Breaches of requirements for producing a plan could be reported to the administering authority, who if satisfied that requirements were not being met, would in the first instance prioritise advice and support to the landowner to allow them to remedy the breach (i.e. through updates to their plan). Where a breach is proven and not remedied there could be financial penalties.

Questions

• Beyond what is set out above, is there additional information which you think should be included in a land management plan?
• Do you already identify or set out any of the information that could be included in a plan, for example including it on your website?
  • Can you quantify the impact (e.g. costs, time, resource, contracting of workers etc.) of collecting, collating and presenting that information?
  • How do you publish that information or otherwise make it accessible to the public and/or local communities?
• What would you expect the impact, including any cost and resource implications, to be of preparing a land management plan that contained such information?
  • Do you have a sense of which requirements would have the most costs associated with them?
  • Would you be able, based on experience, to quantify the costs you would expect to be associated with the different requirements proposed for land management plans?
  • Would you expect cost and/or resource implications to be less when updating a plan, compared to producing the first plan?
    • If so, where do you see the costs being less, and do you have a sense as to how much less they might be?
• Would this work be likely to be carried out in-house, or would some of the work be likely to be carried out by a third party?
  • If work was likely to be carried out by a third party, what work would this be likely to be?
• If you needed to consult the local community on a draft plan and allow them time to comment, do you have an idea of what the impact of doing so might be for the organisation, particularly based on your current or past experiences of community engagement as discussed earlier? The requirements for engagement on plans would be set out, and could include requirements for communities to be able to submit written comments within a defined timeframe, e.g. 12 weeks. Landowners may then be required to set out how they considered these responses and why any changes were or weren’t made following the consultation.

Pre-Notification

Proposal

Landowners would be required to notify the administering authority should they intend to transfer all or part of their landholding (where it met the definition of a large-scale landholding), to allow for registered community bodies in the area to be notified.

Community bodies would have a period of protected time where the landowner would be prevented from taking further steps to transfer the land to a) express an interest, and should they pass an initial screening, b) produce a formal application under either Part 2 Community Right to Buy (private landholding) or Community Asset transfer (public landholding). The criteria for decision making would follow what is currently set out for those routes.

Should a formal application be accepted, the community body would have a registered right to buy over the relevant land and would follow the process to complete purchase set out in existing Part 2 community right to buy or community asset transfer routes.

Questions

• What impact do you think the pre-notification process would have, given the potential impact on timescales and plans to transfer land?
  • If, for example, the community group had 30 days to note interest and a further 40 days (if passed screening) to submit an application? Could the additional time be planned for? What would the cost and/or wider business implications be of the transfer being delayed for this process?
  • What if this was extended to 30 days note of interest and 60 days to prepare application? Does this change the impact?

Transfer Test

Proposal

Where a landholding was in scope for pre-notification, the administering authority would conduct a screening to determine whether the landholding should be subject to a transfer test, considering whether there were risks of concentration of power held over communities.

Should the landholding screen into the transfer test, a further investigation would be carried out and a report produced for ministers. This process could take place concurrently to the pre-notification process, to limit impact on transfer timescales.

Scottish Ministers would determine on the basis of this report whether they were satisfied that a) there was concentration of power over communities in the landholding, and b) that this concentration of power had, or was highly likely to lead to harm to these communities. Where satisfied of both of these, Scottish Ministers would determine whether lotting of the landholding would be appropriate. If lotting was determined to be appropriate, this could be of the whole landholding or a certain part (e.g. only land near to a given community), and would be subject to expert advice.

Questions

• If a landholding did screen in for a transfer test, what impact do you think the subsequent investigation process and any delay to transfer proceedings while that was taking place would have for the business?
• If the landholding was then required to be lotted, what might the impact of this decision be from the business’s/landholding’s standpoint?
  • What would the impact on costs, timeframe etc. associated with the transfer process likely be, if the land had to be lotted?
• Based on past experience, are you able to quantify any costs in relation to these points?

Land Use Tenancy Questions

The new land use tenancy will complement existing types of land tenure leases, rather than replace them. In particular, it will not have an adverse effect on farm leases under agricultural holdings legislation. Officials will be continuing to work with stakeholders to consider whether further measures are needed during the course of the Bill.

This proposal places a new duty on Scottish Ministers to publish a land use tenancy template, and to consult with key stakeholders about the template.

This duty seeks to ensure that the land use tenancy template is developed in a way that enables individuals to undertake a range of land use activities that supports:

• Climate change mitigation and adaption;
• Nature restoration and enhancement;
• Other diverse land use opportunities; and
• Food producers.

The letting template will be published on the Scottish Government’s website. It may also be recorded in the Books of Council and Session to give parties confidence that they can rely on the terms of the lease when entering into an agreement.

Stakeholders have confirmed that they are currently not utilising a commercial lease mechanism for hybrid land use due to the legal costs associated with the changing of the terms of the standard commercial lease template. They also lack confidence in the commercial lease process.

It is intended that the Tenant Farming Commissioner will produce guidance on how to enter into a Land Use Tenancy.

Questions

• What financial impact could the land use tenancy have for you as:

an individual starting a business; an established business; a charity/organisation; and/or a perspective landlord?

• How much do you think it would cost to get legal advice when preparing a land use tenancy agreement? Do you this would cost less or more than the legal advice required to enter into a commercial lease?

Agricultural Holdings Proposals – Questions

Diversification (undertaking non-agricultural activities)

The diversification proposals will enable a tenant farmer to set out the environmental benefit/s which will be delivered as part of a proposed diversification on part of their agricultural holding.

Their landlord will be required to consider impact of the tenant farmer’s proposal across the whole of the tenant farmer’s holding, rather than only the part of the holding where the diversified activity will take place. The range of grounds where a landlord can object to the diversification will be altered to reflect this change.

The landlord will be required to provide more detailed information and reasons if they object to the proposal. This will enable their tenant farmer to consider if they want to amend their proposal so their landlord can reconsider and potentially change their mind. As part of the process a tenant farmer will also be able to serve a “suspension notice” which would pause the approval process for thirty days. These changes will give both parties the ability to have the opportunity to negotiate and consider revising the diversification proposals.

The proposed changes will also allow the Land Court to take into account any environmental benefit/s of a proposed diversification when they are asked to consider whether a landlord’s objection to a proposed diversification is reasonable.

Questions:

• How much do you think it would cost to receive advice from a relevant consultant to assess the environmental benefit of a proposed diversification?
• What impact would this proposal have for your business?

Agricultural improvements to Schedule 5

Schedule 5 of the 1991 Act currently enables a tenant farmer to undertake a specific range of activities which are supplementary to the agricultural activity on the tenant farm and support the use of the holding. The Schedule is split into three Parts:

Part 1 which lists the range of tenant farmer’s improvements that need the landlord’s prior consent.

Part 2 which lists the range of tenant farmer’s improvements that need the tenant farmer to give advance notice to their landlord before they do the improvement.

Part 3 which lists the range of tenant farmer’s improvements that do not need the landlord’s consent or tenant farmer to serve a notice in advance.

The tenant farmer may be entitled to compensation for the improvement at the end of their tenancy.

Currently if an activity is not on one of the three lists it is not an improvement. The lists have been created in the past and are no longer flexible enough to support modern farming activity and the practices needed in the future to enable a tenant farmer to do their part to tackle the twin climate and biodiversity crises.

The proposal is to modernise and update the existing lists using a principles-based approach with example activities. As follows:

Part 1 – Improvements which the tenant farmer will need the landlord’s prior consent to do the activity. Where the activity is a change of the agricultural use of the holding that will generate direct income for the holding.

Part 2 – Improvements that relate to infrastructure or land management which can be altered without major impact to the land management of the holding. Where the tenant farmer will require to serve a notice to their landlord in advance of undertaking the activity.

Part 3 –Will be a list of specific tenant improvements that do not need the landlord’s consent in advance or for the tenant farmer to serve a notice in advance before they do the activity.

Part 4 – Improvements which will benefit the holding by being sustainable and regenerative agriculture and the tenant farmer will need the consent of their landlord before they do the activity.

Parts 1, 2 and 4 will all contain examples of the activities that fall under the principles and can be undertaken in those Parts. Part 3 will retain a specific list of activities which can be undertaken without the landlord’s permission. All activities currently listed in Schedule 5 will be kept and will be moved into a relevant Part. You can see the proposed approach in the attached Schedule 5 list.

Questions:

• If improvements or activities are carried out do you expect these to have an economic value to an incoming tenant farmer of the holding? What are those?
• As a landlord do you think the proposed changes will provide longer term economic benefit to your estate? Why do you think they would or would not provide longer term economic benefit?
• What impact will these changes have for your business?

Good Husbandry and Estate Management Rules

The proposal will shift the current approach to the rules of good estate management and good husbandry from ‘efficient production’ to placing a greater emphasis on sustainable and regenerative agricultural activities meeting the aims of the Scottish Government’s Vision for Agriculture. This will enable tenant farmers to undertake activities such as leaving uncropped field margins as part of their agricultural activities within the Rules.

The Rules of Good Husbandry applying to tenant farmers, and the Rules of Good Estate Management applying to landlords, were defined in the Agricultural Holdings (Scotland) Act 1948. As a result, they focus on how agriculture worked post World War II. The Rules will be redefined so that a tenant farmer will be expected to farm in a way to achieve both efficient production and sustainable and regenerative production.

A landlord will have fulfilled the rules of good estate management if they manage the estate in such a way to enable the tenant to achieve efficient production and sustainable and regenerative production.

Questions

• What impact will these Rules changes have to your business?
• Do you think allowing a tenant farmer to undertake sustainable and regenerative agricultural activities along with their obligation to maintain efficient production, would enable those businesses to be more profitable, less profitable, or not have any impact?

Waygo

The proposal aims to provide a clear timescale around the ‘waygo’ process for waygo to better enable tenants and landlords to settle waygo claims timeously and move forward with the next stage of their life. Currently waygo claims are not subject to uniform timescale. In the majority of cases the waygo claim can come months after the date of termination of the lease, and there is often significant delay between the date of lease termination and the date when the claimant will receive any compensation due.

The proposal is to insert a timeframe for parties to adhere to, following a notice being served to end the tenancy. They also require that a valuer should be appointed nine months prior to the termination of the tenancy. In the event that parties cannot agree the appointment of a valuer, then they can approach the Tenant Farming Commissioner to appoint one.

The valuer will produce an interim valuation report providing a valuation of the heads of claim being sought by either party. The interim valuation report will be provided six months prior to the termination of the tenancy.

Three months prior to the termination of the tenancy an updated valuation report will be provided, taking into account any changes in the circumstances in the tenancy and providing a valuation for any new claims arising.

The valuation report is not the final word on the amount which the claimant is entitled to claim against the other party, but it should be used as the basis for the respective claims for compensation submitted by the claimant against the other party. Parties will intimate their claim for compensation against the other party two months prior to the termination of the tenancy. Should any new claims arise less than two months prior to the end of the tenancy, where parties dispute the valuation, then either party can apply to the Land Tribunal.

Questions

• Will this proposal enable you to receive the compensation due to you at Waygo quicker? If not why not?
• Do you think this proposal could provide cost savings when reaching the final settlement, and why? If you think it would, what would these be?
• How else will these changes impact your business?

A new rent review system

It is proposed to reform the rent review system introduced by the 2016 Act, as elements of the provisions which were identified as being difficult to translate into robust practical procedures. The proposed approach will draw on the work of the Tenant Farming Commissioner and engagement with the Tenant Farming Advisory Forum. This creates a flexible system of rent review which enables both parties to provide evidence from a number of different sources and places an increased emphasis on negotiation.

The new rent review system will be based around a non-exhaustive and non-hierarchical list of factors, which should be taken into account when calculating rent. This will mean that parties will require to consider:

• Comparable rental information
• The productive capacity of the holding; and
• The prevailing economic conditions and factors reasonably foreseeable over a 3 year period.

Where parties are unable to reach agreement on the rent payable, they will be able to access Tenant Farming Commissioner (TFC) mediation which will be supported by TFC guidance. Failure by parties to agree rent, will result in either party being able to apply to the Land Court to have the rent fixed using the revised method.

Agricultural Holdings (Scotland) Act 2003 agricultural tenancies will follow a similar approach.

Questions

• If you already use a different approach to calculating your rent what is this based on?
• Would having a TFC code of practice on the new rent method enable both parties to come to agreement quicker? If you think it would, would this new method help you save money?
• Would you access TFC mediation if you fail to agree rent given the average cost for mediation is estimated around £3,000?
• How will this proposal impact your business? Will it result in you receiving/paying more or less rent?

Resumption

Resumption is the term used when a landlord takes land back out of an agricultural tenancy for specific purposes. The aim of the resumption provision is to promote a thriving tenant farming sector, and to enable tenant farmers to plan with business certainty. This proposal aims to allow this to happen.

Currently, a landlord has the right to resume if there is a written lease which contains a resumption clause and the clause sets out the purposes when land can be resumed. We are not changing that.

The 1991 Act confirms that when a landlord resumes land for non-agricultural activity, they must give their tenant farmer notice of the intended resumption at least 12 months before it is due to take place, otherwise it is invalid. The planned resumption must not constitute a fraud on the lease. However, when the resumption is for agricultural use by the landlord then their tenant farmer can treat this as a notice to quit and the tenant farmer can serve a counter notice.

The proposals aim to make these procedures consistent and aim to modernise the compensation due to the tenant farmer to ensure that they are provided with fair compensation for their loss. The provisions will allow the tenant farmer to claim compensation on a reduction in rent, a disturbance payment, and an additional reorganisation payment.

Questions

• Do you think a landlord with a tenant farmer with a secure 1991 Act tenancy, would have to pay more compensation to resume land? Would this be more than the compensation paid using the current valuation process using multiples of rent?
• What affect would this proposal have on your business?

Compensation for game damage

The proposals aim to modernise the compensation for game damage provisions to clarify the process and enable tenant farmers to claim compensation for losses other than damage to crops. This will amend section 52 of the Agricultural Holdings (Scotland) Act 1991.

Game is defined as deer, pheasant, partridge, grouse and black game (that is, black grouse) within section 52. The proposals will remove black game from the definition of game, due to their declining population.

Currently the tenant farmer is only entitled to compensation where there is crop damage and the payment rates are outdated with the tenant farmer only currently able to receive compensation if crop damage exceeds 12 pence per hectare. The proposals will enable tenant farmers to claim compensation for damage to their crops, fodder, grass for livestock grazing, disease impact on livestock, damage to trees for the purposes of short-rotation cropping, damage to trees which are planted for sustainable and regenerative agriculture, damage to trees planted for non-agricultural purposes, and damage to fixed equipment.

Questions

• Would you need specific training to assess game damage or would you pay a consultant to do this for you? If you would like specific training who should pay for that? As a landlord do you anticipate being able to recover part of this cost if you have a sporting tenant?
• How would these changes impact your business? How would you fund any costs arising to you from these changes?

Small Landholdings Measures- Questions

The Scottish Government committed in the Programme for Government to “modernise small landholding legislation” and the Bute House Agreement committed to “explore providing small landholders with the same pre-emptive right to buy as crofters and Agricultural Holdings (Scotland) Act 1991 tenant farmers, and the treatment of the land under their houses”.

To meet these commitments, the Small Landholdings Modernisation consultation included proposals to modernise small landholdings legislation relating to:

• Right to Buy;
• Diversification;
• Succession and Assignation; and
• An Umbrella Body.

The Scottish Government Agricultural Census results (June 2021) shows that there are approximately 59 small landholders who have identified themselves in Scotland and with 5,360 acres (2,168 hectares).

Right to Buy

It is proposed that the pre-emptive right to buy proposal for small landholders will generally mirror the pre-emptive right to buy approach that tenant farmers with secure 1991 Act agricultural tenancies have With the aim of removing barriers to sustainable agricultural activity and rural development by providing small landholders with greater certain over their smallholding and encouraging them to invest in their agricultural business.

It is intended that the small landholder will initiate the process by providing a written notice to their landlord confirming their intention to exercise their pre-emptive right to buy. This notice will include a plan and map together with a detailed description of the land which the small landholder considers forms their smallholding. Once the landlord receives the written notice they must respond to their small landholder within 30 days confirming whether they agree to the information contained within the notice. This process will encourage dialogue between the small landholder and their landlord and enable them to clarify and agree the area of the small landholding.

There will be an option for the small landholder and their landlord to go to mediation at this point and the Tenant Farming Commissioner will provide guidance on the pre-emptive right to buy process and mediation.

The small landholder will have the option to go to the Land Court if there is a dispute with their landlord about the area of the small landholding or the lease.

Once the notice is served by the small landholder a pre-emptive right to buy will be triggered in two situations:

• Where the owner of a small landholding or creditor gives the small landholder notice of a proposal to transfer the land covering the small landholding; or
• Where the owner or creditor of a small landholdings takes some of action with a view to transferring the land covering the small landholding or any part of it. ‘Takes action’ means that the land is advertised or exposed for sale, negotiations are entered into, or any proceedings are further taken with the proposed transfer of the land.

After the landlord or creditor ‘takes action’ then the small landholder can make an offer and agree the price of the smallholding with the landlord or creditor in a standard security.

Where the small landholder or the landlord/creditor fail to agree the value of the small landholding then a valuer can be appointed by agreement. Where both parties fail to agree the appointment of a valuer then one can be appointed by the Land Court.

The valuer will be required to take into account value that is likely to be agreed between a reasonable seller and buyer. They also need to consider any factors that may lead a person wanting to buy the land at a price higher due to the characteristics of the land; and the date when the small landholding may be returned to the landlord ( the vacant possession date) and the individual terms or conditions of the lease and any moveable property.

As part of this process, the small landholder, landlord or other persons who have an interest in the estate can make written representations to the valuer. The expenses of the valuer will be met by the small landholder or shared equally between the small landholders (where more than one small landholder is exercising their right to buy in relation to the seller’s land eg if part or all of an estate was being sold).

Within 6 weeks of being appointed, the valuer must send seller and small landholder the price. Where parties do not agree with the valuer’s price assessment then the seller or small landholder can appeal the valuation to the Lands Tribunal within 21 days of receiving the valuer’s notice. At the end of the process the small landholder will be able to purchase the whole of their small landholding.

Questions

• What financial impact will the pre-emptive right to buy proposal have on your business?
• As part of agreeing the boundaries of the small landholding lease, would you wish to undertake mediation prior to going to the Land Court? (average cost for mediation is estimated around £3,000)
• As a small landholder would you be able to pay the potential valuation cost of owning your small landholding?

Diversification

Currently small landholdings may only be used for cultivated purposes. Cultivation is defined as being used for “horticulture or for any purpose of husbandry, inclusive of the keeping or breeding of livestock, poultry, or bees, and the growth of fruit, vegetables, and the like” or other occupations that the Scottish Land Court find reasonable, so long as the occupation is not inconsistent with the small landholding’s cultivation.

This proposal will enable a small landholder to use the small landholding for a purpose other than for ‘cultivation’. This will align with agricultural holdings diversification provisions set out in Part 3 of the Agricultural Holdings (Scotland) Act 2003.

When assessing the small landholder’s proposal, the landlord is required to consider it in the context of the impact it will have across the whole of the small landholder’s holding, not just the effect it will have on the part of the holding where the diversified activity will take place. The grounds upon which a landlord can object to the diversification will be changed.

A landlord will be required to provide detailed reasons if they object to the proposed diversification. This will enable the small landholder to consider if the proposal can be modified to remove any concern, so both parties can agree to the proposal. A small landholder will be entitled to serve a “suspension notice” to pause the approval process for 30 days to enable negotiation between the landlord and small landholder, creating an opportunity for a modified proposal to be agreed.

The Land Court will, if asked to consider whether an objection to the proposed activity is reasonable, be able to take account of any environmental benefit.

Questions

• Would you hire a consultant to assist in assessing the environmental benefit of a proposed diversification? How much do you think this could cost?
• Would you expect that any diversified income would be reflected in the rent for the holding?
• Do you expect that diversification could devalue the holding and result in the landlord claiming compensation from the small landholder at waygo?
• How else will these changes impact your business?

Succession and Assignation

The proposal aims to enable small landholders to assign their tenancy to the same classes of people as tenant farmers with secure 1991 Act agricultural tenancies can through the Land Reform (Scotland) Act 2016. It aims to encourage investment and growth; enabling wider family members to take over, provide older small landholders greater ability to retire at an earlier stage, while opening up opportunities for new entrants and future generations of young farmers.

The provisions modernise the range of family members who can succeed a small landholding by amending the legislation for testate succession in the Crofters Holdings (Scotland) Act 1886 (which significantly limits the range of eligible individuals, compared to modern family arrangements).

Question

• As a small landholder, will being able to pass on your tenancy more easily, encourage you to invest in your small landholding?
• As a landlord, how do you think this proposal will affect your long-term business plan for the estate?
• What impact will this change make to your business?

Umbrella body

The proposal aims to allow landlords and small landholders to have access to the Tenant Farming Commissioner (TFC) and intends for the Tenant Farming Commissioner to have similar functions for small landholdings as those currently set out for agricultural holdings in Chapter 3 of the Land Reform (Scotland) Act 2016.

The Tenant Farming Commissioner would promote and encourage good relations between small landholders and their landlords, publishing guidance and codes of practice.

The Tenant Farming Commissioner would also be given the power to investigate alleged breaches of codes of practice. This proposal would help to reduce confusion and tension while making small landholdings legislation more accessible.

The Tenant Farming Commissioner would be able to produce small landholding guidance on - negotiating rent; diversification; negotiating the fulfilment of the obligations of landlords and small landholders; the right to buy process; the process of succession and assignation; guide for landlords on the creation of small landholdings; conversion to crofting; and determining compensation at removal.

Questions

• Do you think that being able to access TFC guidance and codes of practice reduce your costs? Please explain why.
• Would this change help you resolve disputes without having to go to the Land Court? (Average cost for mediation is estimated around £3000)
• How will this proposal impact your business?