Agriculture and Rural Communities (Scotland) Bill

Propagate is based across Scotland which organises, manages and delivers on a wide range of local, community and sustainable food projects. One of those projects is the (award winning) South West Scotland Regenerative Farming Network.

The RegenFarm Network is a farmer to farmer knowledge sharing group. There are over 200 subscribers to the network who are members of an email forum - this forum shares information weekly about regenerative, sustainable and agroecological food and farming systems.
We have a resource directory on our webpages.
We organise regular Farm Walks where we can see sustainable and regenerative farming in practice.
We host and hold networking meetings and webinars.
We have a Soil Health Group for farmers who want to take a more in depth step in their knowledge sharing. This group communicates daily via WhatsApp, discussing every aspect of sustainable and regenerative farming. They are the core group of the RegenFarm Network who regularly contribute to deciding which farms we visit, and what webinar topics we hear about.
Finally, we have a Policy Group, for farmers who want to be further engaged in co-designing policy responses, lobbying and campaigning. This group has co-written the following response.

Our RegenFarm Network recently won the Nature of Scotland Award: Food and Farming, for our work on knowledge sharing and supporting each other to adopt more sustainable and regenerative farming.

We cannot say if this is the right framework as more detail is needed regarding the Rural Support Plan, the Code of Practice for sustainable and regenerative agriculture, and other measures.
We would expect the Scottish Government to continue to engage with farming and rural communities to co-design these next stages.

As far it goes, there is some clarity, but due to the lack of detail we can’t be completely clear about the direction as yet.

The definitions of the objectives are not clearly set out. They look good as statements but can be read in different ways depending on the audience/reader. There is no clear definition of ‘High Quality Food Production’, we would like to see this.
We recognise that there is an intention to create a Code of Practice for Regenerative & Sustainable agriculture, but again we would like to see more detail at this point regarding the direction travel.
There should also be reference to a transitional process. We need to see measures that help reduce inputs such as fertiliser use, with the eventual outcome of true sustainable farming and food production.
We want to see these objectives strengthened. These objectives should be based on agroecology, and must include stepping back from intensive production. We want to see holistic thinking, not objectives and outcomes simply based on carbon footprints.

Broadly supportive – particularly if the intention is consult with the farming and rural communities. It’s long enough to plan ahead for rural businesses.
There may need to be changes in proportion of funding levels for different tiers – for example we would want to see flexibility to be able to direct future resources for ecological health.
We also would like to see reference and alignment here to the National Food Plan, as expected under the Good Food Nation Act.

This does not go far enough.
There should also be consideration of other relevant Scot Gov and wider strategies and plans, eg Biodiversity – natural environment bill, Land Reform Act, Good Food Nation, Community Empowerment.
The Rural Support Plan should also include dietary change and nutritional standards – as set by Scottish Government. Again we need to see a definition of High Quality Food Production that is based on high nutritional content foods and agroecological farming.
The RSP should also support farmers to transition to true sustainable farming, recognising this process can take years.

This does not go far enough.
We want to see the power to increase and adjust the budget applicable the Bill, particularly with regard to agroecological measures.
We want the Scottish Gov to be obliged to continue to engage with farming and rural communities. This should be a duty.
A significant power that is missing is redistribution, or front loading. We want to see a power retained to introduce more resources for smaller farms and holdings, in line with current EU CAP.

There are many omissions, and again this does not go far enough.
We welcome horticulture and fruit and vegetable production being added to this list. We must make sure that future vegetable production is based on regenerative methods, and avoids routine use of herbicides, pesticides and fertiliser.
We want to see support for smaller scale vegetable production and market gardening – for example a 2acre community supported agriculture project which provides nutritionally dense vegetables to local communities.
Pork, poultry and egg production are missing. Clearly the raising of pigs and poultry is food production, and especially where this is done in a regenerative system – such as woodland pastured pigs, and free range organic systems. These systems have clear benefits to ecosystems in addition to being high quality food production.
We would also like to inclusion of alternatives to soya based feed production, including for example Black Soldier Fly larvae and other insect farming.
Vertical farming could also be included here, and other new and innovative forms of food production.
Provisions should be made for value added products that enhance the rural economy.
We want to see stronger language on nature friendly farming throughout these purposes - enhancing ecological health.
We are concerned that some of these clauses would allow unsustainable forms of production to continue – must be continuous checks to ensure the Objectives are being delivered.
The purposes should be checked against the outcomes and objectives set out in part 1.

We must make sure that purposes and provisions are not dependent on ‘carbon footprints’ – outcomes should take an holistic and whole farm system approach based on soil health, ecological health, social and economic factors.
Dietary change should also be considered and alignment with nutritional standards in school and public food, and reducing HFSS foods.

Yes broadly. Knowledge sharing with current EU CAP iteration.

There is not enough detail given here.

The Scottish Government needs to recognition of the significance of feedback from the farming community. There are plenty of farmers who are already practising sustainable and regenerative agriculture and this code of practice should be based on their learning and experiences. Development of the Code of Practice should be grassroots up not top down. Involve farmers already engaged in this meaningfully, not just colleges, SRUC, consultants. Not just industry perspective.
In defining ‘Sustainable and Regenerative Agriculture’ our group propose the following:
Context is everything. Location, land capability, people capability and all of the variability therein make it really hard to come up with a definition that can be applied effectively to all contexts. There is no one size fits all.

Sustainable agriculture is not relying on unsustainable inputs for your fertility,but utilising healthy soils inherent function of generating fertility.
So: Not using industrially produced Nitrogen or slurry, as they both break down soil carbon in the process that allows plants to utilise them.
And: Not using mined sources of Potash and Phosphate for maintaining fertility,as these mined resources are diminishing, and are unsustainable .
To do this successfully nature must be thriving hence the focus on healthy living soils. Regenerative agriculture considers the system as a whole. In a regenerative system the life below ground is just as important as the life above ground. Management decisions are made for the long term benefit of the land and all of its occupants.

Sustainable and Regenerative Agriculture is based on a set of principles that put soil health first:
1. Minimise soil disturbance - Soil supports a complex network of worm-holes, fungal hyphae and a labyrinth of microscopic air pockets surrounded by aggregates of soil particles.
2. Keep soil covered – using cover crops, green manure, mulches and organic matter
3. Keep living roots in the soil. living roots in the soil are vital for feeding the creatures at the base of the soil food web; the bacteria and fungi that provide food for the protozoa, arthropods and higher creatures further up the chain.
4. Maximise diversity - Monocultures do not happen in nature and our soil creatures thrive on variety. Companion cropping (two crops are grown at once and separated after harvest) can be successful.
5. Incorporate livestock into arable rotations - allows arable farmers to rest their land for one, two or more years and then graze multispecies leys. These leys are great in themselves for feeding the soil and when you add the benefit of mob-grazed livestock, it supercharges the impact on the soil.

Some additional questions which we would like answered:
Will the Code of Practice be legally binding? Will the Code of Practice be enforceable? Will it involve Cross Compliance? When and what is the review period?
Monitoring and compliance: when you attach a standard/set of rules to RA you then have to audit against those rules.  People will invariably look to see it as a tick-box exercise and look for loopholes in achieving compliance rather than going for the outcomes.  (think Red Tractor farm assurance)
Outcome-based vs. input-based: the outcomes of RA are what are important for environmental gain but are hard to measure.  The inputs are easier to measure but may not be effective in achieving the outcomes.

See above. Ministers shouldn't have the power to do anything without asking the farming and rural communities this impacts on.

While we welcome this in principle, we have concerns that asking too much of already busy family farms is placing to heavy a burden on an already busy and overworked sector. Provisions around CPD should also include peer to peer, farmer to farmer knowledge sharing groups.
It’s also worth noting that there is a higher number of people with dyslexia in farming.

All the above discussed, and:
Specific inclusion of Holisitc management planning and whole farm systems approaches, for example using the Global Farm Metric framework.
Redistributive payments or front loading. Specific provisions for supporting smaller holdings – up to 150acres. Smaller farms are more likely to be implementing nature based solutions, diversification and enterprise stacking. Small holdings are subject to the same administrative burdens as larger counterparts and this must be reduced.

An option to consider that would assist with land justice and land reform could be capping of maximise size of holdings (as per Denmark) – with possible exemptions where there is clear social and community benefit.

We would like to see more re supply chain support, particularly for local supply chains and local food systems – including the capital infrastructure required to support sustainability and resilience of these systems.

Knowledge transfer is essential to the regenerative and agroecological transition. We want to see support for knowledge transfer projects strengthened.

We are concerned that Tier 3 – potentially where all the really interesting nature restoration and agroecological measures currently are – will be competitive, which indicates a restricted budget. This might be off-putting to smaller farmers and more accessible to larger holdings. We would like to see provisions for small farmers working together in cooperatives and collaborations. This could reduce the admin burden by sharing it across several holdings.

Land Justice and land reform should be a central feature of the new Bill. We want to see action to enable access to land for new entrants. We need a system that encourages smaller and more diverse farming systems.

We absolutely have to see a horticulture scheme as part of this Bill. Scotland is a net importer of vegetables. We are in no way resilient or food secure when we look at nutrition and health, rather than calories. This has to change, and the only way to support this is with a fruit and veg producers scheme that is accessible to smaller producers. A 2 acre market garden can easily provide fresh vegetables for 60+ households weekly, and provides an income to 1 or more people. This is in addition to the multiple co-benefits such as community resilience and health.

At time of writing this Bill is based on the 2015 CAP and not recent reforms. We need to see a more up to date and forward thinking approach with real CAP alignment. This is way out of step.
We have the ability to share learning with our European counterparts, who are more advanced than us in the agricultural reforms.

Yes.
All the Bills and Strategies mentioned above, and Just Transition.

The Bill would be further strengthened by controls on the market to create a better environment for a fairer deal for farmers. Farmers are often neglected in the value chain and receive a poor price for their product.

This could be alleviated through market controls, and a resource budget for marketing of local, sustainable and nature friendly products.