Agricultural reform: environmental report - strategic environmental assessment

Chapter 5 Mitigation and enhancement

The 2005 Act states that ‘the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme’ are outlined within the Environmental Report. These measures are often referred to as mitigation measures. The following text summarises the mitigation measures identified from the assessment.

Significant negative environmental effects have been identified; in relation to continuation of existing environmental effects from the SBSSS and in relation to GHG emissions. A range of enhancement measures are described in relation to each Tier below.

Agriculture and Rural Communities (Scotland) Act Objectives and Agricultural Reform Outcomes

Opportunities for mitigation and enhancement

There is opportunity to strengthen the positive effects of the Agricultural Reform by providing more detail within the Agricultural Reform objectives, setting a clear direction of travel across all the SEA topics. This may include:

• Expand the of detail within objectives, ensuring key environmental issues (such water quality, water scarcity, flood risk, ammonia emissions, etc.) are identified at a high level as strategic priorities to be fed through future programme reforms.
• There is no mention of the historic environment in the strategic outcomes of the Agricultural Reform. Its inclusion in the strategic objectives of Agricultural Reform will help ensure it is identified as priority to be considered in individual Agricultural Reform actions. Farming and land management play an important role in the protection of heritage assets and can help deliver the positive management of historic features.
• In addition to supporting agricultural businesses and helping to deliver a just transition, there is an opportunity to acknowledge the role of agriculture in conserving and enhancing the countryside and promoting responsible public access, thereby delivering positive effects for communities, health and wellbeing.

Alongside the Agricultural Reform:

Ensure that the Code of Practice on Sustainable and Regenerative Agriculture is kept up to date and strengthened as a key mitigation and enhancement tool. It should provide clear detail on how to undertake the actions to achieve the most positive environmental benefits and make the best use of the land. This could include expanding sections on water quality, ammonia reduction, soil management, climate resilience, and cultural heritage. As a living document reviewed on a five-year cycle, it should reflect new science, industry feedback and monitoring evidence from Agricultural Reform delivery. Linking the Code more clearly to Whole Farm Plans, CPD modules and cross-compliance requirements would help embed best practice across all tiers of support.

Tier 1 (Base)

Whole Farm Plan

Requirements for the Whole Farm Plan were introduced in 2025 and have therefore been adopted. However, opportunities to enhance positive environmental effects include:

• Add water-management planning (usage, storage, drought planning).
• Bring the Nutrient Management Plan forward (not just “recommended” until 2028).
• Include requirement for a soil health plan.
• Introduce specific ammonia-reduction measures such as covered slurry stores, low-emission slurry spreading equipment (e.g. trailing shoe or injection), and timing applications to avoid high temperatures.
• Require farms to include basic waste and resource efficiency measures in their plan, such as recycling farm plastics, re-using materials where possible, and improving fuel, fertiliser and water use efficiency.
• Link Whole Farm Plan requirements to existing GAEC/cross-compliance rules by including a basic check for historic environment features before farm works. Farmers could be incentivised to record and protect heritage assets on their land, with this information feeding into the Whole Farm Plan.
• Use audits to signpost appropriate action in other Tiers of the Agricultural Reform.
• Collect farm audit data for monitoring of delivery against Agricultural Reform outcomes and reward/incentivise delivery of Agricultural Reform outcomes by monitoring WFP outcomes.

Phase in selected Tier 2 and 3 measures (such as habitat features or low-emission technologies) into Tier 1 from 2026 onwards, so that all farms begin to deliver more consistent and impactful environmental improvements in the short to medium term.

Scottish Suckler Beef Support Scheme

Requirements for the SBSSS were introduced in 2025 and have therefore been adopted. Through the assessment, a number of wider farm management improvements were noted. These are recognised as WFP recommendations, although originally emerged from the SSBSS assessment. Opportunities to enhance positive environmental effects include:

Require SSBSS claimants to include a basic herd fertility plan in their Whole Farm Plan, to ensure improved herd management.

Build on existing good practice in managing indoor calving areas by encouraging improved bedding, secure muck storage and runoff controls, as evidence [See reference 277] shows these measures reduce water pollution risks and improve animal welfare.

Plan for water supply in dry summers.

Promote good handling and calving area management (e.g. regular muck removal, well-drained surfaces, and sheltered calving pens where possible) to help reduce emissions and improve animal welfare.

Cross-compliance – new protections for peatlands and wetlands

New cross-compliance measures were introduced in 2025 and have therefore been adopted. However, opportunities to enhance positive environmental effects include:

• Strengthen grazing controls - including controls on stock, tracks and rutting on wet ground.
• Provide alternative watering points/mineral sites to protect peatland.
• Support small water storage outside peat areas (helps with drought).
• Require farms to have a basic wildfire plan and to check for historic environment features before carrying out peatland management or restoration on peatland.
• Provide a clear link to the Wildlife Management and Muirburn Bill when enacted to support cross compliance.

Scottish Upland Sheep Support Scheme

Through the assessment of SUSSS, a number of related farm management improvements were noted. Similar to the recommendations for SSBSS these are more closely recognised as WFP recommendations:

• Link payments under the WFP to basic grazing plans that set out herd/flock numbers, seasonal grazing patterns, and resting periods for sensitive pastures, helping to prevent overgrazing and protect soils, peat and biodiversity.
• Improve water supply and distribution on hills through WFP measures, so animals don’t impact springs in dry spells.
• Implement no-supplementary-feeding on peat requirement and wet-weather herding routes as part of WFP to protect peatland and soils.

Other

Incorporate a small unit support package into Tier 1, helping small units manage the challenges they face with meeting the requirements of the Agricultural Reform. Allowing small units, such as crofting communities, to comply with a simpler set out rules may offer positive environmental effects, as a disproportionate amount of valued natural capital is located on small units.

Tier 2 (Enhanced)

EFA changes

Provide guidance and advice to encourage farmers to choose EFA options with the greatest environmental benefits for their system (for example, field margins, fallow, low input grassland), while recognising that final choices remain with the farmer.

• Ensure clarity to farmers in fertiliser rules across different EFA types (fallow, margins, hedges, nitrogen-fixing crops, catch crops) to ensure consistent nutrient management and avoid unintended emissions.
• Consider adding EFA options that provide wider resilience benefits (e.g. riparian shade, small ponds), which support biodiversity and water quality, with potential co-benefits for drought resilience in line with Scotland’s National Water Scarcity Plan [See reference 278]
• Ban fertiliser/manure use on EFAs to help cut ammonia emissions.
• Make sure new features such as hedges, margins or ponds are designed and located so that they avoid harm to heritage assets or the character of historic environments.
• Support knowledge and information sharing with farmers on the historic environment to ensure that new EFA features (such as hedges, margins or ponds) are designed and located to avoid damaging designated heritage assets, while still delivering biodiversity and climate benefits.

Permanent grassland requirements

• Strengthen rules on stocking and poaching to protect soils and water.
• Promote the appropriate and effective planting of diverse grass and clover mixes, including native and deep-rooting species, to help enhance carbon sequestration, air quality and drought resilience.

Less Favoured Areas Support Scheme

• Tie support more clearly to basic grazing and nutrient plans to mitigate negative effects on local soils and water.

Encourage riparian buffers, peat protection and hill-slope planting to support climate, water and biodiversity.

Add light-touch nutrient requirements to address ammonia.

Tier 3 (Elective)

Increase budget weighting in favour of Tier 3 activities.

AECS, Future Farming Investment Scheme, other targeted capital support and Innovation pilot and landscape-scale collaboration pilot

• Opportunity to better integrate protection of the historic environment landscape into AECS, grant funding and future pilot schemes. For example, prioritising funding of proposals which have complementary benefits for the natural and historic environment (e.g. proposals addressing removal of scheduled monuments from ploughing, control of soil erosion over historic assets, etc.); and support for repair/re-use of traditional and historic buildings, repair and retention of traditional and historic routeways, field boundaries and landscape features.
• Opportunity to integrate management or enhancement of recreational access into AECS, grant funding and future pilot schemes. While not aligned with the outcomes/objectives of the Agricultural Reform, recreational access to the countryside is important in delivering benefits for local communities, health and wellbeing, access to nature, and enhancement of cultural heritage and landscape assets, and should be considered within the measures implemented within the Agricultural Reform.
• Similarly, future capital funding schemes should aim to align and take in all SEA criteria.

Forestry Grant Scheme

• Encourage riparian planting and shelterbelts.
• Prioritise woodland in riparian zones and flow pathways to provide shade, reduce run-off and support water retention in summer.
• Use tree belts/shelterbelts near livestock areas to help capture ammonia and particulates.
• Support measures to reduce deer impacts, helping to protect regenerating woodlands and biodiversity.
• Incentivise green technology and sustainable forestry supply chains to strengthen rural development benefits.
• Increase support for the sustainable management of existing forests, ensuring they deliver a wider range of climate, nature and community benefits.

Innovative and landscape-scale collaboration pilot

Ensure schemes are developed with the widest possible reach.

Tier 4 (Complementary)

Improved AKIS and integrated CPD system

The magnitude of positive effects in relation to Tier 4 will be dependent on the specific structure, content and requirements of the new AKIS and CPD system. While these are expected to align with the Agricultural Reform objectives, training, access to data and CPD should ensure they are focused on key issues across all of the SEA topics (for example, including positive management of heritage assets, water use efficiency, etc.)

• CPD system should be inclusive and accessible to all, reaching a wide audience. This should include targeted actions and support hard to reach crofters and farmers, varied levels of digital connectivity, IT access, learning styles and demographics.