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International approach to land ownership holds lessons for Scotland

Scotland should look to international examples of land ownership, use, and management to provide new ideas and thinking in taking forward its land reform programme, the Scottish Land Commission said this week, following publication of its report on the subject.

The report, titled 'A Review of International Experience of Community, Communal and Municipal Ownership of Land,' has researched the way land is owned, used and managed across a number of countries. While clearly showing that in the international context there’s no such thing as ‘normal’ land ownership, it identifies three themes where Scotland’s approach currently differs, and where lessons could be learned from other countries’ experience. These are: governance/ownership structures; local democracy and control; and land use planning.

In particular the report studies four categories of community tenure, and analyses international examples of each category. They are:

  • Collective properties and commons, where land is owned and managed through cooperative business models, or where the rights of the title holders are restricted and other people hold beneficial use rights over land such as in England and Wales, Norway, Italy, Mexico
  • Municipal ownership and commonage, where local government authorities own and manage land in the public interest, and where land is co-owned by the state and community with varying degrees of community input as in Norway, France, South Africa and Germany
  • Third sector and Community Land Trusts, where local democratic and representative non-profit organisations own land with the primary aim of community benefit like the USA and England
  • Customary tenure and indigenous group, where land is owned/managed by indigenous people as happens in Kenya, Norway, Canada.

The report finds that the boundaries between private, public and community land ownership are often blended in different governance models much more than is usually the case in Scotland.

The report considers, for example, Community Land Trust models in England and the USA that help to deliver affordable housing through local partnerships. By working through an open democratic structure, the public sector and communities broaden their access to funding and other networks to deliver affordable local housing. These organisations are often supported at a regional level by ‘umbrella’ organisations who provide co-ordinated guidance and support, as well as a conduit into national policy development.

Highlighting the prevalence of collective private land ownership and use across Europe, usually in the form of cooperatives, the report demonstrates how cultural perceptions of land can be quite different in our nearest neighbours. These cooperative approaches – often supported by government – allow multiple small landowners to successfully work together to achieve economies of scale and landscape scale management.

Scottish Land Commission chief executive Hamish Trench said:

“There is no single blueprint for land ownership, but this report highlights the possibilities and opportunities for thinking differently about land ownership in Scotland. It poses questions that go beyond the usual debate on land reform and ask us to think beyond the sectoral divides we sometimes assume are fixed.

“We will be using this work to explore new governance models and I hope it will stimulate wider discussion and ideas. We should be drawing on this international experience to shape reform that works for Scotland, reform that is designed to enhance our collective wellbeing and prosperity.”