A Consultation on the 2020 Challenge for Scotland's Biodiversity: An Analysis of Consultation Responses

An analysis of responses to the Scottish Government's consultation on the 2020 Challenge for Scotland's Biodiversity.


This report presents the findings of an analysis of the consultation on the draft Strategy 2020 Challenge for Scotland's Biodiversity (hereafter referred to as 'the Strategy'), including the Environmental Report which accompanied it.

The Strategy builds on Scotland's Biodiversity Strategy of 2004 It's in Your Hands. It is Scotland's response to the European Union's Biodiversity Strategy for 2020 and to the Aichi Targets set by the United Nations Convention on Biological Diversity, which called for a step change in efforts to halt the loss of biodiversity and to restore the essential services that a healthy natural environment provides.

Consultation feedback will inform a strategy paper, which will constitute part of the Scottish Biodiversity Strategy, alongside its 2004 document.

The consultation took place between 6 July 2012 and 26 September 2012. In total, 76 consultation responses were received (30 from the third sector, 15 from local authorities, 19 from 'other' public sector, nine from individuals and three from the private sector).

In line with the aims of the consultation and the style of questions asked, responses were analysed using qualitative methods, with the aim of producing a report that represents the range of views submitted. It is therefore not appropriate to quantify the answers, although an indication is given of the balance of opinion and how often particular views were cited.

Main themes

A number of frequently recurring themes and points on the Strategy were evident within and across the responses to different chapter questions:

  • A need to better specify how the Strategy will be delivered, including defining roles and responsibilities and timescales for key steps and actions.
  • Concern about the intrinsic value of biodiversity compared to the Strategy's focus on economic valuation and benefits to the economy and people.
  • A call to better recognise the conflicts of interest inherent within the Strategy and its delivery, and to provide mechanisms and guidance on how to manage these conflicts to deliver biodiversity improvements.
  • The need for sufficient funding of the Strategy, including calls for reform of the Scotland Rural Development Programme (SRDP).
  • The benefit of including an assessment of past successes and failures in relation to the 2004 Strategy in order to learn lessons for this Strategy.
  • The need for greater recognition of existing work at local level and for the potential role of Local Biodiversity Partnerships in delivering the Strategy.
  • Respondents noted ways in which they could support the delivery of the Strategy in their own work, including through partnership working and stakeholder engagement.
  • A call for improved clarity and consistency of language and terminology.
  • The need to better consider the role of farmed and cultivated biodiversity.

Key points by chapter

Chapter 1 Healthy ecosystems and ecosystem services

  • Of the 65 respondents who commented on this chapter, the majority supported the overall approach proposed either in full or in broad terms. Most of those who voiced general support did however state qualifications to this or areas they felt required strengthening. A small number of respondents indicated a disagreement.
  • Many respondents pointed out the likely conflicts of interest that would result from an ecosystem approach, given the complexity of ecosystems in relation to institutional and administrative boundaries, theoretical versus practical considerations, and biodiversity versus economic interests.
  • Related to this, several respondents stated that the Strategy lacked mechanisms on how conflicts in delivery would be managed and improvements to biodiversity delivered.
  • A number of other concerns were raised in relation to the ecosystem and associated services approach:
    • The problematic notion of 'restoration' of ecosystems, including which historical state should ecosystems be restored to.
    • The difficulties of placing a value on ecosystem services and a suggestion that the Strategy provide guidance.
    • A risk of detracting from those species and habitats that require special attention and protection and/or which have less direct economic value.
  • Regarding the proposed catchment scale approach, a number of respondents pointed out difficulties between theoretical intentions and practical feasibility. This included: multiple stakeholders; complications arising from political and local development plan boundaries; the approach not recognising all ecosystems, including the limited value of the concept on islands; and that land managers are likely to base decisions on what is best for their estate rather than the catchment as a whole.
  • Of the several respondents that commented on an adaptive approach to environmental management, around half stated supported for it. Others asked how such an approach will be ensured in practice and suggested the Strategy provide more detail with examples.
  • Several respondents requested that the Strategy mention the Scottish Biodiversity Duty and what it requires of the public sector.
  • Many respondents commented on the issue of funding, with most of these noting the need for sufficient resources to be identified to deliver the Strategy. More detailed comments made by several respondents included: past failures stemming from funding issues, including insufficient or poor use of funding, and the need to better target resources in the future; a call for biodiversity partnerships to have dedicated funding so that valuable time is not taken away from delivery in chasing funding sources.
  • A number of respondents highlighted issues with the Scotland Rural Development Programme (SRDP), including its complexity, its inability to process large applications at landscape scale from multiple landowners, the challenge in securing funding for small scale projects, and called for reform.
  • A number of respondents expressed disappointment that the value of existing work, particularly by local biodiversity partnerships and forums, did not receive more recognition in the Strategy. Similarly, a number argued that the Strategy should provide guidance to ensure local work contributes to and is aligned with national priorities.

Chapter 2 Natural capital and resource use efficiency

  • Of the 62 people who commented on this chapter, over half of respondents did not give a clear indication of whether they agreed or disagreed with the approach. The remaining respondents supported the overall approach proposed either in full or in broad terms, with only one respondent indicating a clear disagreement. Most respondents stated qualifications or areas they felt required strengthening.
  • The most commonly cited concern, even by those who supported the chapter, centred on the economic valuation of biodiversity. They felt much more emphasis should be placed on the intrinsic value of biodiversity. Several respondents felt that the focus on economic valuation was short-sighted and risked compromising less economically valuable biodiversity.
  • Several respondents argued that the Strategy does not adequately acknowledge the fundamental challenge of sustaining both economic growth and environmental integrity. On the other hand, several respondents supported the chapter's recognition of the economic contribution of biodiversity, insofar as it should engage diverse stakeholders and raise awareness of ecosystem services.
  • Several respondents argued that creating a valuation system for natural resources does not equate to halting biodiversity loss, an increase in natural capital or sustainable economic growth, and that the Strategy must make clear such an approach is not a 'solution'.
  • Several respondents agreed that natural capital assets should be incorporated into traditional accounting practices, with a few requesting that the Strategy provide more guidance on this.
  • A number of respondents commented on the Natural Capital Asset (NCA) Index, several of whom supported it in principle or more fully. Others made a range of comments, including a few who thought its use premature given that it has not been peer reviewed and does not distinguish between stocks and flows.
  • A number of respondents expressed support for the chapter's proposal to restore and manage peatlands.
  • Many respondents to this chapter commented on biodiversity offsetting, with varying degrees of support: several respondents acknowledged its potential benefits, but few supported it outright. Most respondents suggested the Strategy err on the side of caution, highlighting the following issues:
    • If used, offsetting should be the last resort in the mitigation hierarchy.
    • The impossibility of recreating unique resource habitats and the issue of considering time in offsetting (for example, ancient woodlands, peatbogs).
    • Offsetting becoming a way for developers to avoid their responsibilities.
    • A number of issues and concerns with valuation.
    • The need for more knowledge/research about offsetting.
    • The need for offsetting guidance and good management.

Chapter 3 Biodiversity, health and quality of life

  • Of the 61 respondents who commented on chapter three, just over half of the respondents supported the approach proposed either in principle or in broad terms. Most of those who voiced general support did however state qualifications or areas they felt required strengthening. A few respondents indicated a disagreement with the approach.
  • A number of respondents felt that the chapter's emphasis on human health loses sight of the health of biodiversity.
  • Several respondents noted that green spaces and biodiversity are not synonymous, and suggested that the Strategy explain this distinction. A few respondents noted that green spaces that are well maintained and attractive to people are not necessarily the richest in biodiversity.
  • The notion that 'nature is for everyone' was supported by several respondents, who agreed that developing opportunities for disadvantaged groups is important.
  • Several respondents noted the importance of improved public awareness and education about biodiversity, including through formal outdoor learning. A few respondents suggested that the Strategy should go further in explaining the importance of outdoor learning, including how it will be implemented.
  • A number of respondents commented on funding, including the constraints imposed by limited or diminishing resources. A few respondents suggested the Strategy highlight the preventative benefits of investment in biodiversity.
  • Several respondents suggested that the Strategy should recognise the need for more joined up thinking and collaboration, including across government, between national and local organisations, and others outside of the conservation arena.
  • In a similar vein, several respondents highlighted the value of existing work, and suggested that with enough resources and better coordination, the value of those projects could be harnessed.

Chapter 4 Wildlife, habitats and protected places - connecting nature

  • Of the 63 respondents who commented on chapter four, the majority of these did not provide a clear indication of whether they agreed or disagreed with the approach. Around a third of respondents did express agreement in full or broad terms, but most of those did state qualifications to this or areas they felt required strengthening. A few respondents indicated overall disagreement.
  • A number of respondents supported recognition of the intrinsic value of nature (paragraph 4.4.1). However, most of these respondents noted that this statement appears (too) late and only once in the Strategy. They recommended that it be made a focal issue.
  • Many respondents commented on the Scottish Biodiversity List, around half of whom supported the Strategy's proposal to shorten the list. Several respondents meanwhile expressed concern or questioned the reasoning behind what they considered an a priori aim or supposition to shorten the list.
  • Many respondents commented on issues related to the spectrum of connectivity - from ecological networks to individual habitat and species protection. Most of these respondents seemed to prefer an approach which aims to protect individual habitats and/or species within the wider context of an ecosystem approach.
  • A number of respondents provided diverse comments on the subject of Invasive Non-Native Species (INNS), several of whom expressed support of the Strategy's proposal to implement new INNS legislation and to develop a catchment-based approach to control INNS.
  • Several respondents commented on resource issues, including the statement in paragraph 4.3.8 that '...relatively little investment is needed to restore many natural systems back to full capacity.' Some of these respondents expressed disagreement or discomfort with the statement.
  • A number of respondents commented on the importance of engaging with and taking into account the interests of land owners. These respondents mentioned different aspects of conservation programmes that should be developed with land ownership in mind.
  • Several respondents commented on the Wildlife Management Framework, some of whom suggested the need for it to be developed or implemented with the engagement of different stakeholders.
  • Several respondents expressed disappointment or concern regarding the Strategy's lack of reference to the role of Local Nature Conservation Sites (for example, Sites of Importance for Nature Conservation, Community Wildlife Sites).
  • The subject of volunteering was mentioned by a number of respondents, all of whom agreed with its value and the importance of recognising it.
  • Several respondents supported the chapter's references to geodiversity (paragraphs 4.3.7 and 4.3.9), with many stating that the Strategy needs to go further in explaining how geodiversity will be integrated into biodiversity thinking and land management.
  • A few respondents requested that the proposed Code for Species Reintroductions take into account the views of stakeholders, including land managers.

Chapter 5 Land and freshwater use and management

  • Of the 58 respondents who commented on chapter five, around half expressed broad support for the overall approach. However most of these respondents had further suggestions or areas that they felt required strengthening. Only one respondent disagreed outright.
  • Several respondents welcomed this chapter as the first to cover specific actions with targets. Others felt that the chapter would benefit from a stronger focus on identifying clear objectives, and actions, and who would take them forward and by when.
  • A number of respondents, including several local authorities, thought that the Strategy did not adequately address land management for biodiversity within an urban setting.
  • Several respondents noted that the Strategy requires a clearer vision and guidance on how to manage conflict in land use.
  • Whilst several respondents expressed their support for the SRDP as the main source of funding, some of these cautioned against sole reliance on the SRDP and noted that alternative funding sources should be identified. Others argued the SRDP would need to be simplified and targeted much more effectively if it was to deliver as the main funding source.
  • Several respondents thought that further guidance and detail was required on how high nature value farming and forestry would be achieved.
  • A few respondents felt that that the proposal to achieve and maintain good ecological status for all surface water bodies in Scotland is unrealistic and would incur excessive financial cost and economic penalties.
  • Whilst a number of respondents supported the 100,000 hectares peatland target, several questioned the rationale for the figure.

Chapter 6 Marine and Coastal

  • Of the 43 respondents who commented on chapter six, the majority of respondents supported the overall approach proposed either in full or in broad terms, but many stated caveats to this or gave further suggestions. A few respondents indicated an overall disagreement with the approach, largely because they felt the approach is not sufficient to achieve the stated outcome.
  • Several respondents questioned the separate treatment of marine issues within the Strategy, noting the importance of recognising the interdependence of marine and terrestrial ecosystems.
  • Several respondents noted that many of the key steps relate to existing legislative requirements and policy commitments, and some questioned what the strategy adds above and beyond these.
  • Several respondents called for clear actions with associated targets and defined roles and responsibilities.
  • A number of respondents commented on the proposed Marine Protected Areas designation. Of these, most voiced broad support for the designation in principle. However, a few suggested that there is a case for exceptions to be made for Scotland's islands.
  • A few respondents questioned the effectiveness of the Maximum Sustainable Yield (MSY) model and opposed its inclusion in the Strategy. However, several third sector organisations argued that the MSY level should represent an upper limit rather than a target.

Chapter 7 Measuring Progress

  • Of the 59 respondents who commented on chapter seven, many respondents agreed or broadly agreed with the approach. However, in around half of the responses it was not possible to determine whether respondents agreed or disagreed. In any event, most respondents suggested qualifications or suggestions for improvement. Only a few respondents disagreed outright.
  • In the main, disagreement or qualifications were based on a perceived need for greater specificity and detail, particularly on targets and indicators and roles and responsibilities for delivery of the Strategy, including monitoring activities.
  • Several respondents raised concerns about resource requirements and funding for the development of the indicator suite, and for monitoring and research of progress against the Aichi Targets.
  • A range of other comments were made on indicators, including:
    • The importance of regular reporting on progress and achievement of targets.
    • The suggestion of including additional indicators, primarily relating to social evidence, but also on cultivated biodiversity, geodiversity and soil biodiversity.
    • The need for local level data on the indicators to inform local policy and action.
    • Concern over the omission or insufficient recognition of other sources of data, including the role of Local Record Centres.
  • On the Scottish Biodiversity Information Forum (SBIF), a few respondents noted that it had already been established, so key step two should be altered accordingly. Several respondents made suggestions regarding the role of the SBIF, including a need for greater clarity and avoiding duplication of effort.
  • Several respondents explicitly welcomed the promotion of citizen science. However, questions were raised about how data quality would be assured, with some encouraging the use of data collected by stakeholder organisations and research institutions. A few others noted that volunteer recording only lends itself to monitoring particular taxonomic groups, such as birds.

General questions

Seven outcomes for Scottish Biodiversity by 2020

  • Of the 46 respondents who commented on question eight, a number did not respond directly on the outcomes but expressed a range of views on the strategy. The majority of the responses to question eight were broadly supportive, however, many also suggested qualifications or areas they felt required strengthening. A small number of respondents expressed disagreement.
  • Many respondents expressed a degree of concern regarding the deliverability of the Strategy's outcomes, suggesting that the outcomes should be more specific and questioning how they are to be achieved.
  • Several respondents argued that it is important for the Strategy to learn from past biodiversity successes/failures and for the outcomes to reflect lessons learnt.
  • A few respondents suggested the need for the Strategy to list/state in detail the Aichi and EU biodiversity targets for 2020.

Equality issues

  • Of the 16 respondents who commented on question nine, most of these stated 'no' when asked if there were any equality issues that the Strategy needs to address.
  • A few respondents suggested that socially disadvantaged areas are likely to experience the most impact from biodiversity, whether positively through healthy/restored areas, or negatively as a consequence of biodiversity loss. Active engagement with under-represented groups was suggested.

Any other points on the Strategy

  • Question 10 was addressed by 51 respondents. The majority were public sector respondents, who used this opportunity to comment on the Strategy as a whole, as well as to provide a wide range of suggestions to improve it.
  • Many respondents raised concerns about the clarity and specificity of the key steps, actions and commitments, questioning how these will be delivered and by whom. Concerns were voiced by a number of respondents on funding.
  • Several respondents commented on the overarching aims stated in the Executive Summary, with a number stating that the aim to 'increase the general level of biodiversity‚Ķ' lacked clarity, with some questioning whether it is consistent with Aichi Targets. All who commented on this aim felt it would be more appropriate to include an explicit aim to 'halt biodiversity loss'.
  • Arguments in favour of including an assessment of past successes and failures with regard to the 2004 Strategy were made by several public and third sector respondents.
  • There were calls from a number of respondents for greater recognition of the work and potential role of key stakeholders like Local Biodiversity Partnerships and Local Records Centres in the delivery of the Strategy.
  • A few respondents felt that there was insufficient consideration of farmed and cultivated (plant and animal) biodiversity and associated genetic diversity in the Strategy and suggested how this might be addressed.

Strategic Environmental Assessment (SEA)

Of the 24 respondents that responded to at least one of the questions in the SEA, most were supportive that the content provided an accurate description of the current environmental baseline. Several respondents provided suggestions to improve the environmental baseline.

Most of those who responded to the SEA did not provide a clear indication of whether they agreed or disagreed with the conclusions on the environmental effects of the Strategy. Several respondents expressed their outright support of the conclusions, and slightly fewer disagreed with the conclusions.

Only a small number of respondents noted that they were aware of 'other reasonable alternatives to the Strategy that should be considered as part of the SEA process'.


Email: Biodiversity Strategy Team

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