Academic Advisory Panel - 6 November 2023 - Advisory Note

Items and actions

This advisory note has been prepared by the Academic Advisory Panel (AAP) in response to a request from officials, to provide feedback on development of the Biodiversity Audits as a new condition for farming support payments under the Whole Farm Plan (WFP). Biodiversity audits will be discussed at the next ARIOB meeting on 8 December and this note will be provided to help inform these discussions. The note is a summary of the discussion on biodiversity audits at the AAP meeting on the 6 November 2023, along with written communication. The panel, following presentation of work undertaken by Nature Scot, discussed general issues around the development of biodiversity audit tools and addressed specific policy questions.

Key Summary of the AAP’s Discussion

Panel members highlighted that it is not essential to conduct detailed biodiversity audits before setting biodiversity conditions for farms or crofts to meet. However, the selection of an appropriate Biodiversity Audit tool should include careful assessment of the many different tools under development to check delivery of robust results. Engagement of farmers and crofters in development and use of tools is critical and will help ensure future engagement with the process. How audit scores are interpreted, any associated consequences and follow up actions should be clearly communicated to those affected by audit requirements. Ideal tools should serve multiple purposes of providing assessment, collecting data, monitoring changes and providing recommendations. Remote sensing (e.g., Lidar) can provide independent checks on farmer-led audits.

General discussion:

• the purpose of the biodiversity audits should be made clear. Is the intention that this will form a monitoring baseline, or will it inform future and protection and management actions
• a range of biodiversity audit tools available should be assessed. The biodiversity audit result may vary between different tools due to lack of uniformity between datasets used as a reference point. The Government needs to be aware of strengths and weaknesses of alternative assessment tools to guarantee consistent outcome and ensure that results are comparable
• engagement with farmers and crofters is vital in selecting and developing an appropriate tool. Farmers and crofters rather than consultants should be involved in deploying and using the tools, for cost efficiency, avoiding human resource limits and improving engagement
• good understanding by farmers of audit scores and associated consequences is required. Farmers and crofters need to understand the reasons behind the audit score to maintain a good score or improve a bad one. Consequences associated with each score should be communicated and consideration should be given to incentivising good scores and mapping out steps for improvement for poor scores. Early messaging is important to allow farmers and crofters to prepare for upcoming change
• wherever possible prepopulated data and maps should be provided to farmers to reduce the amount of input required and encourage engagement. There are risks of poor quality and inaccurate data if done by farmers/crofters and general advisers. There were also concerns over expectations on large hill farms (getting comparatively very low levels of support) in having to map the condition of vast tracts of hill, peatland and uplands
• the ideal auditing tool should provide multiple benefits. To achieve the best outcome the auditing tool should be able to facilitate data capture to facilitate monitoring of changes, and to generate recommendations for the future with links to appropriate measures. Generated aggregated and anonymised data should be shared publicly considering public funding used for their collectionClear communication of future plans is required. The Whole Farm plan currently outlines four core audits, but the panel highlighted that an Integrated Pest Management (IPM) audit should also be included, and the panel were told this is currently being discussed with policy. IPM is a critical component of biodiversity action. The requirements of all audits included in a Whole Farm Plan must be clearly communicated
• careful consideration of proportionality of future payments in relation to undertaken actions is required. The design of the payments should aim to avoid extremes of aiming for a very low or very high score to secure higher payment. Payments should promote good engagement with actions benefiting the biodiversity and environment and be outcomes-based
• plans for monitoring and evaluation of changes are important to ensure effectiveness of the WFP. The plan should be used as an enabler to drive change, but follow-up actions are of greater importance and should be defined by incentives and clear policy demands.
• trusted source of baseline data is required. Development of biodiversity audit tools requires access to map based reliable data. Mapping will introduce discipline and help driving systemic change. Independent source of data such as LIDAR technology will enable independent checks of audits
• definition of ‘active farming’ should be updated. Definition should include activities associated with managing peatlands and biodiversity, and not be restricted to landowners growing crops and managing livestock, as this should encourage wider participation in the biodiversity audits
• concerns were raised about the compliance costs of biodiversity audits relative to support payments. We need to better understand the compliance cost of the audit / condition scoring, as well as the rest of the whole farm plan. Unless there are some lighter touches for small holders and crofters there is a risk of them withdrawing from the support structure

1. How often should the biodiversity audits be undertaken, and should this cycle vary depending on land type, geography or agricultural practice?

• the frequency of the need to undertake an audit may vary depending on the management goal. It is important to consider whether it is expected that the condition of biodiversity will be maintained or enhanced and how fast the condition of the habitat is likely to change depending on context and management practice
• to enable identification of trends audits should be carried out every 2-3 years. Shorter intervals may not register subtle changes whilst longer intervals pose a risk of not identifying adverse changes in time to take a corrective action
• capacity constraints may emerge due to the lack of suitably qualified people to undertake all audits in one go. Staggering audits across farm populations, careful management of detail expected from the audits and use of new technologies may help to alleviate some of the capacity pressures

2. How to ensure international comparators for standards used in biodiversity audits?

• UK wide engagements – alignment with approaches used in the rest of the UK and engagement with work carried out by DEFRA would be most beneficial for development of biodiversity audit framework. EU directives should be considered, if available
• consistency of the approach – rather than using international comparators it is more important that the same auditing method is used to produce farm biodiversity baselines and carry out follow-up monitoring. Using different tools may produce different results

3. How to encourage future participation?

• obligatory audit requirement – making the audit requirement mandatory would ensure wide participation. However, if the audit was to be mandatory, details of audits, training tools, and guidance must be available well in advance
• raising awareness – importance and multi-benefits of audits should be made clear and communicated to the target group. Creating an environment for bottom-up and top-down motivation would be preferable and more beneficial than perceived enforcement. The research evidence from the Farmer Intentions Survey (Scotland-wide) demonstrates that when farmers see the outcomes i.e., recognise the biodiversity produced on their farms, they are more likely to engage in environmental measures in the future. Farmers need to learn to be able to recognise how they are ‘producing’ biodiversity
• uniform engagement with quality assurance schemes - biodiversity action plans are included in the Scottish Quality Crops (SQC) assurance scheme but not in Quality Meat Scotland (QMS) so there is a likely imbalance between arable and animal farms in terms of planning and awareness. Alignment of requirements of the quality assurance schemes and requirements dictated by the WFP should be sought
• farmers and crofters engagement should be a priority at all stages of design and implementation process. Farmers should be engaged in the process of shaping the audits to encourage participation and change attitudes. The burden of audit requirements on small and part-time farmers and crofters and those less IT literate should be considered when designing the tools and audit requirements so people are not discouraged from engaging with the process. App fatigue and ‘form anxiety’ should also be considered when developing new tools.
• training – staggered peer-to-peer learning and hands-on training on farms which are already undertaking audits would be beneficial in engaging the wider farming community

4. What should be the focus when considering the minimum requirements for a biodiversity audit?

• main and important habitat - consideration should be given to how much of any main habitat, and certain important habitats (e.g., wetland), are present in the audited area, where it is, age of the habitat, and what condition it is in. All three aspects are necessary to provide meaningful assessment of the habitat ability to support biodiversity in the given area and decide on future management needs
• fauna and flora species – assessment should include presence of species of fauna and flora ‘at risk’ and on invasive non-native species (INNS), rather than on species counts

5. What approach should be taken in 2024 for wider testing of the audit, in terms of farmer/crofter representation and how to reach them?

• comprehensive testing – testing needs to be carried out across a full range of farm types, sizes and geographical locations. Aiming to recruit geographic clusters of farms which share habitats may be more useful than a formally stratified research sample
• careful selection of test participants - over-reliance on monitor farms should be avoided as feedback seems to suggest that the farmers involved are overloaded and becoming slow to effect changes. Ensure a broad demographic up-take by: promoting through Women in Agriculture events; Targeting young farmers and new entrants, through National Farmers of Scotland NFUS Next Generation, and Scottish Association or Young Farmers Clubs SAYFC.  The general findings of the National Test Programme survey completed as part of phase 1 of the test programme might be useful for planning the approach to test the audit across a wider range of farm types, sizes  and geographies