NFU Scotland’s formal submission to the Scottish Government’s consultation on a new Agriculture Bill has now gone in but members have until Monday (5 December) to make their own submission writes Director of Policy Jonnie Hall.
Thank you to all those that provided both input and feedback to ensure our submission clearly sets out the needs of Scottish agriculture and the views of our members.
Our submission went public via a briefing for the press/media when we set out our key issues.
Below is the executive summary from our submission to help inform your own responses as you see fit – it is vital that as many of you as possible respond to this consultation (which now closes on Monday 5 December).
The executive summary from NFU Scotland’s response to scottish government consultation: ‘delivering our vision for scottish agriculture – proposals for a new agriculture bill’ reads:
The future of Scottish agriculture, and all it underpins, is under severe threat. While climate, nature and wider rural development issues remain, they cannot and will not be addressed by a disregard for the needs of Scottish agriculture.
It is more critical than ever that Scotland has a new agricultural policy to underpin sustainable and profitable agricultural businesses so that they can deliver agricultural production first and foremost – and not least because of a rapidly changing food security context.
Agricultural activity and production are the drivers of change – the means to meet the intended outcomes. It is critical, therefore, that the powers and policy intended to deliver key outcomes firstly align with the needs of Scottish agriculture and, secondly, do so in a way that enables farming and crofting to deliver what is increasingly expected of them.
Fostering sustainable and profitable agricultural businesses is the only route to delivering all the required outcomes.
Scotland’s farmers and crofters also need clear commitments on future funding – a dedicated and sufficient budget committed on a multi-annual basis and ringfenced, with the significant majority of that budget allocated to active farming and crofting to ensure the delivery of intended outcomes through a new support payments framework.
However, creating powers and committing resources is not sufficient – it is how they are used which matters most.
NFU Scotland welcomes and supports the intended shift to a new four-tier structure of future support – not least as it is effectively an adoption of the policy proposals initiated by the Union in the publication Steps to Change of March 2018.
However, the Scottish Government needs to be clearer and sooner as to how the new powers will be used. Critical questions remain as to how and to what degree ‘conditionality’ will be attached to the direct support elements of Tiers 1 and 2, through what different eligibility requirements will this direct support be distributed to help meet intended outcomes of support, and what shares of total funding will be allocated to these direct payments Tiers.
Equally, questions remain over the scope, function, and content of the indirect support of Tiers 3 and 4 – including their shares of the overall agricultural and rural development funding and their means to target support to best effect.
Right now, farming and crofting need a future support policy which drives agricultural activity and food production, to generate confidence and investment in the short and long term and deliver effectively on the Scottish Government’s targets for both climate and biodiversity.
In turn, that requires a significant focus on, and vast majority funding allocation to, the direct support elements of Tiers 1 and 2. Given the commitment to an equal split of direct support between the two, it is critical that the requirements of both attract and sustain commitment from all active farmers and crofters.
Tier 1 must provide continued financial stability for active farmers and crofters, subject to existing cross-compliance requirements. Tier 2 must foster productivity, efficiency, and resilience through accessible management options, whilst also recognising and rewarding good practice. Both Tiers 1 and 2 must combine to enhance agricultural management and agricultural business performance, whilst at the same time significantly contributing to desired outcomes relating to climate, nature, and wider rural development.
Farmers and crofters need a future support regime in Scotland that supports agricultural output together with practical measures to help cut emissions and enhance biodiversity. The new Agriculture Bill, and how its powers are used, must enable this.
However, some proposals for the new Agriculture Bill set out a route towards increasing layers of additional red tape and additional costs in the pursuit of goals that may add little or nothing to the bottom line of too many agricultural businesses already facing extreme financial pressures over and above other socio-economic issues.
The proposed powers, and how they are used, must have regard for the practicalities of managing a viable and profitable farm or croft. The proposed powers must not expose this generation of farmers and crofters to stark choices that might only result in agricultural land abandonment – and they must give opportunity to those who would have hoped to follow.
NFU Scotland echoes the Cabinet Secretary’s comments to the Scottish Parliament on 8 November in saying “There is no contradiction between high quality food production and producing it in a way that delivers for climate and nature” and “…sustainable food production…is an outcome that we know can only be reached by working with our producers”.
It is only with the buy-in of farmers and crofters across Scotland can new primary legislation turn policies into practices that deliver on high quality food production, climate mitigation and adaptation, nature restoration and wider rural development – simultaneously. It is the duty of the Scottish Government to help make that happen.
However, while this consultation may be about delivering the necessary powers via a new Agriculture Bill, it does not fill the alarming policy void that farmers and crofters currently face – which is simply compounding the severe volatility and extreme uncertainty already affecting so many producers in Scotland.
Via its response to this consultation, NFU Scotland is calling for a move from powers to policy, and then to practice, as a matter of urgency to enable sustainable and profitable agriculture to drive necessary change and attain the non-negotiable and necessary outcomes required.
A clear, unwavering commitment that future policy will underpin agricultural activity and food production is required immediately. If the pursuit of a misplaced vision is all that matters, then Scotland’s future ‘agricultural support’ policy will fail.
On 2 March 2022, the Scottish Government published its Vision for Agriculture. The Vision for Agriculture makes clear an intention to transform future support to make Scotland “a global leader in sustainable and regenerative agriculture.” To deliver the vision, a new Agriculture Bill is needed to provide the powers to enable the future agricultural policy for Scotland.
However, in the current context, NFU Scotland must question the current validity of the Scottish Government’s Vision for Agriculture. The context has changed dramatically, and such a vision has been overtaken by circumstances.
What is clear to NFU Scotland is that agricultural production must be front and centre of any vision for Scottish agriculture, or indeed any vision for land use in Scotland, and the policy intended to deliver that vision. Ensuring sustainable and profitable agricultural businesses is the only route to delivering all required outcomes.
However, the future of active agriculture is now under severe threat – largely driven by rapidly changing and unpredictable political, economic, and social circumstances, as well as environmental change to some degree. It is more critical than ever that Scotland has a new flexible agricultural policy to underpin sustainable and profitable agricultural businesses so that they can deliver agricultural production – first and foremost.
NFU Scotland has been very clear for a number of years that the way in which farmers and crofters are supported in Scotland must change. However, with a global food crisis beckoning and extreme volatility leading to extraordinary and unprecedented rises in input costs, as well as the needs of climate and biodiversity, changes in agricultural support cannot be at the expense of active farming and crofting businesses – because it is these businesses that are fundamental to the delivery of an array of necessary outcomes.
For NFU Scotland, it is also beyond question that sustainable and profitable agriculture is the key to delivering the host of economic, social, and environmental benefits that only active farming and crofting can deliver – if enabled to do so.
Active farming and crofting are the lynchpins. They provide the primary product for the food and drinks sector, which is vital to the current and future economic prosperity of Scotland, and the critical mass for the supply chain and investment in it. They are the mainstay of scores other rural and supply chain businesses, both upstream and downstream, and the thousands of jobs they provide. They are the bedrock of rural communities and the vitality of local economies. It is the shaper of landscapes and the provider of habitats for their wildlife.
NFU Scotland’s own stated Vision is “a sustainable and profitable future for Scottish agriculture.” While acknowledging that a new Agriculture Bill is needed to create the necessary powers, NFU Scotland is adamant that those powers must enable the necessary support, in various forms, to put agricultural activity and food production at the heart of the delivery of Scottish Government policy.
Within the proposals intended to deliver the Scottish Government’s Vision there is a clear intention to implement targeted measures for biodiversity gain and a drive towards low carbon approaches which improve resilience, efficiency, and profitability. NFU Scotland entirely supports that intention. Change is needed, but the scale of change and how it is managed are also critical to success if multiple outcomes are to be secured via a ‘just transition’.
Moreover, the Scottish Government proposals relating to primary legislation will set the high-level powers to then allow for more comprehensive secondary legislation to provide the required bespoke details, such as the specifics of schemes and measures around eligibility, options, payment rates, etc. In that sense, a new Agriculture Bill is essential in that it will create the powers that are required to deliver future support.
It is more critical than ever that the Scottish Government targets funding to active farmers and crofters through an accessible and effective new delivery mechanism. The new Agriculture Bill must provide a vehicle to do just that – and with a primary focus on agricultural activity and production.
Notwithstanding the clear commitment in the Cabinet Secretary’s statement on 8 November to move to greater conditionality under existing CAP measures sooner rather than later and by scheme year 2025, the current consultation and Agricultural Bill to follow are still a long way from the detail that so many farmers and crofters need if they are to plan for and implement change.
As a result, and in the disappointing absence of any specific policy options from the Scottish Government, NFU Scotland will use this consultation to set out its current and clear preferences as to how the future support framework can best be used to ensure sustainable and profitable farm business drive agricultural activity and production – thereby ensuring there will be no contradiction between high quality food production and producing it in a way that delivers for climate, nature and rural communities.
A copy of NFU Scotland's full 55-page submission is available on request from media@nfus.org.uk .