rights for tenants relative to landowners and the widening of eligible assignees and inheritors of tenancies. Additionally, tenants under the 1991 Agricultural Holdings (Scotland) Act are now presumed to have registered their right to buy. Since 2012 statistics for agricultural land occupation have been published on an annual basis for Scotland by the Central Association of Agricultural Valuers and the 2019 figures indicate low levels of letting activity and that much relet land is bare land without buildings or investment by the landlord. Criticism Criticism by landlords In August 2013, landowners including the Duke of Roxburghe expressed concerns about the work of the Land Reform Review Group and the focus on community ownership. The landowners stated that private ownership brought efficiency and greater protection for endangered species from development of land. Also, there were other social, economic, and environmental benefits to private ownership of Scottish land. The Duke of Roxburghe raised concerns specifically about the economic impacts, and the impact on the agricultural sector, saying: Many other landlords opposed the passage of the Land Reform (Scotland) Act 2016. Mark Coombs, the estate manager of the Queensberry Estate, owned by the 10th Duke of Buccleuch, stated that "there are also concerns if the purpose of changing the ownership is simply to allow another party … to carry out the same activity as is currently being undertaken by the existing owner as this strikes at the essence of ownership rights and suggests a clear move towards a more collectivist political view which is not representative of the body politic of Scotland." Thus hurting the property rights of the landowners since it strips them of control of their property. David Johnstone, chairman of Scottish Land and Estates, said the proposal could lead to land not being made available to let, and hurting the tenant farming sector. Johnstone said: "What you are doing is giving a tenant a stake in the capital value of the farm. If the landlord doesn’t have the ability to pay, then the farm never comes back... That has got to have a knock on effect in the confidence of anyone who might wish to come to let land or is letting land at the moment." Seafield and Strathspey Estates argued that land concentration is not a bad thing, as it may lead to more efficient management. Seafield and Strathspey Estates is a enterprise which includes salmon beats on the