We told the Department that we were concerned about the lack of baseline data, and asked what data it will use to measure environmental improvements.70 In its written evidence, the Green Alliance emphasised the importance of being able to measure outcomes in order to demonstrate value for money. It recommended that the Department should “develop standardised approaches for measuring outcomes and progress towards achieving overall objectives, and make sure they are adequately monitored to prevent potential environmental damage due to mistakes in execution.”71 We observed that in previous schemes payments were based on field sizes, which are easily measured, whereas in the new system it was difficult to tell what is going to be measured and what baseline it will be measured from, without accurate baseline data. The Department asserted that it had a very good understanding of the baseline data with respect to land. It explained that, for the soil standard, the first component of the scheme to be rolled out as part of SFI22, payments will be per hectare of land on which specified actions are carried out. The Department told us that this was because it believes it already had a detailed 67 C&AG’s report para 1.17 – 1.18 68 Q 3 69 Qq 43–44 70 Q 76 71 EMS0003 – Environmental Land Management Scheme, Green Alliance, 22 October 2021 20 Environmental Land Management Scheme understanding of the activity necessary to deliver the environmental benefits intended, and therefore a baseline was not necessary to assess whether a required outcome has been achieved. It explained that later scheme components, such as peatland restoration, will benefit from a more detailed assessment of the current condition of the land in order to measure progress and the impact of the scheme. The Department told us that it had a good understanding of the environmental quality of different areas of land, and that it planned to use this to identify actions that can be taken on specific farms through the L