Make a donation

Help fund our work to amplify nature-friendly farming’s benefits to farmers and policymakers across the UK

Policy & Views

Read a variety of articles, including topical blogs, comment pieces on policy developments and updates on key moments in farming.

Campaigns

Catch up with our latest campaigns and find out more about our work.

Farm Practices

Explore information on many aspects of nature-friendly farm practices.

What is the NFFN?

Discover our mission, our vision and the challenge we meet.

Meet The Team

Meet the farmers in our regional steering groups and the staff team at our core

FAQs

Got a question about nature-friendly farming? We've got it covered here

Supporters

We're proud to work with many organisations who support our mission.
Resources

NFFN Scotland: Response to the Agriculture Bill Consultation

Scotland
Policy & Views
policy

What is the consultation?

The Scottish Government’s consultation on the Agriculture Bill set out its vision for Scotland to become a global leader in sustainable and regenerative agriculture and outlined its determination to develop agriculture, climate, biodiversity and food policies that underpin sustained food security.

We’ve responded to this consultation in support of the Government’s proposal for committing to tackling the climate and biodiversity crises while ensuring we have a healthy environment and thriving rural communities for the long term.

Our members are currently working on their farms and crofts to bring back biodiversity, mitigate climate change and produce food across Scotland. We’re convinced by our own and the collective, cumulative experience of many others that agriculture can and should benefit from working with nature for viable food production and delivery of ecosystem services.

NFFN Scotland’s view

Farmers and crofters are critical to achieving the government’s ambitious climate and nature targets. We welcome the announcement by the Cabinet Secretary on 8 November 2022 that the future payment system will recognise and reward those taking action to pioneer best practices.

However, area-based payments will not achieve nature restoration or climate mitigation as part of a just transition. We remain concerned with the outlined pace for phasing out the existing BPS scheme and the impact this would have on reaching these targets. The Government’s design of the new payment framework must be rolled out at pace to reflect the urgency of the climate and nature emergency. The measures with future schemes should reflect ambitious action to mainstream sustainable farming systems that work in harmony with the environment.

If we’re to reverse the ecological and climate crisis, we need the majority, not the minority, of farmers and crofters to be farming in ways that recognise nature as central to food production. The future payment framework will be pivotal to this. We look forward to working with the Government on co-designing the framework as it’s developed.

Read NFFN Scotland's full consultation

Download here

Key points in our consultation response

  • We agree with the proposal that the new Agriculture Bill should include a mechanism to enable payments to be made under a 4-tier approach with the proviso that there will be a commitment to phase out area-based subsidies in the Bill within a managed transition period. All funding for Tier 1 Base Level Direct Payments to move into Tiers 2, 3, and 4 over the term of the next parliament 2026-30. Delivery of Enhanced Level Direct Payments under Tier 2 will be more effective in achieving what we need in the time we have.

  • We welcome the commitment to explore capping and/or tapering base-level payments to release additional funding to meet the goals of our agricultural vision, including the urgent actions required to reach net zero emissions. In the current Programme for Government 2022/23, we support adding ‘urgent actions to restore and enhance nature’ to this commitment. We urge the Scottish Government to start actioning capping and/or tapering now and to review the current three-region model as soon as possible. This investment is imperative as we will need significantly more of the roughly £600m agriculture budget to be put into targeted, tailored interventions for farmers and crofters to transition to agroecological and regenerative agriculture.

  • We would like to see targets set for getting more high-quality, nature-friendly Scottish food onto Scottish plates, and these should sit alongside targets for Zero Carbon and Biodiversity. We call on the Scottish Government, local authorities and health boards to lead by example in procurement and to give preference to local food produced by farmers and crofters who have established nature- and climate-friendly practices and are demonstrating excellent environmental land management.

  • Whole Farm Management is crucial in unlocking how farming’s profitability is linked to its partnership with nature. Whole Farm Plans mustn’t be seen as an arduous tick-box exercise. It needs to be a rewarding, valuable and accessible tool that effectively assesses what support is best for individual farms and crofts. This will need to be carefully designed and clearly defined, with the requirements as simple as possible.

  • While on-farm action is urgently needed to reach net zero, a reduction in farming emissions mustn’t be the only focus for climate mitigation, nor should it come at the expense of climate resilience. Biodiversity restoration and the carbon potential of well-managed habitats, including soils, grasslands and hedgerows, must be balanced carefully with land use strategies for decarbonising.

  • Scotland is in an enviable position, with 40% of our farmland classified as High Nature Value. This is a national asset, and this land and the farmers and crofters who manage it should be better prioritised in receiving support through the new proposed payment framework. HNV farmers and crofters currently get a low share of the c.£600 million CAP budget spent each year in Scotland. Support for Areas of Natural Constraint or LFASS, and coupled support for beef and sheep sectors are arguably closer to direct payments than ‘complimentary support’ as set out in the proposals.  Our upland grasslands hold huge opportunities for farmers and crofters of grazing animals and mustn’t be left to carbon profiteers and blanket afforestation. Done sensitively, grazing can be part of a biodiverse landscape – preserving valuable grasslands and enhancing soil fertility and biodiversity as part of a rotational system. Adopting these methods can also help farmers and crofters to gain higher margins, reduce input costs and tap into higher-value markets at home and abroad.

  • Currently, many small-scale farmers and market gardeners cannot access payments because they are below the 3ha threshold. We ask that the Scottish Government consider lowering the threshold to 1ha, abolishing it altogether or offering a Small Farms Scheme with a simplified process and a one-off flat rate payment, in line with the new CAP (which defines small farms as 10ha or below).

  • To achieve a significant transition to sustainable and regenerative farming, barriers for all farmers and crofters will have to be removed, including those for tenant farmers. We support the measures proposed in the consultation to modernise agricultural tenancies.

  • We must stop viewing forestry as non-agricultural land management and work towards integrating our agriculture and forestry sectors. We agree with Soil Association Scotland that agroforestry requires better non-competitive support within the proposed framework. Policy support should provide the best value for money if geared towards systemic change. Agroforestry will become more widely established if the productivity benefits are better understood, market development is supported, and schemes effectively facilitate private natural capital investment. Alongside this, we want to see similar non-competitive targeted support for hedgerow creation and restoration with national targets for agroforestry and hedgerow creation.

  • We welcome the focus on location-specific payments and access for co-operatives and groups. This holds the potential for supporting more ‘landscape approaches’ and ‘farmer/crofter clusters’ built on farmer-to-farmer and crofter-to-crofter support and collaboration. Support and funding for bottom-up farmer, crofter and land manager-led landscape localised groups will be fundamental to the success of the more top-down larger-scale initiatives of Regional Land Use Partnerships, Nature Networks and Local Biodiversity Partnerships.

  • In terms of a Just Transition, access to the appropriate skills, knowledge, and innovation must be available to all farmers and crofters in Scotland. There is an urgent need for research to catch up with the practices farmers and crofters are incorporating into their systems. There is currently no course for agroecology and no course in Scotland for agroforestry.  We call for a £200m ten-year co-designed, industry partner-led, funded programme of regenerative and agroecological learning, research and development and regional-based peer-to-peer farmer- and crofter-led knowledge exchange supported across Scotland (£20 million per annum.)

  • By its nature, a transition to agroecological and regenerative agriculture requires more people to build livelihoods from the land than less. We can see this in practice in Scotland within our crofting, High Nature Value and upland farming communities. The overarching aim for all of the above must be reversing Scotland’s rural depopulation. This will require careful consideration to ensure the proposals set out here and broader policy has a positive effect.

Read NFFN Scotland’s full consultation response

Download here

Cookie consent

We use cookies on this website to improve your experience, provide social media features, and analyse our traffic. By clicking Accept All, you agree to the use of cookies as outlined in our Cookie & Privacy Policy. You can manage your cookie preferences at any time by clicking Cookie Settings.