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.


Three general questions were asked about the Strategy. The questions and responses are reported below.

Question 8
Do you agree that the seven outcomes set out in the paper represent what we need to achieve for Scottish Biodiversity by 2020?

The responses

9.1 Of the 46 respondents who commented on question 8, a number did not comment directly on the outcomes but expressed a range of views on the strategy. The majority of the responses to question 8 were at least broadly supportive, however, many also suggested qualifications or areas they felt required strengthening. A small number of respondents provided comments but did not give a clear indication of whether they agreed or disagreed with the approach. A similar number expressed disagreement.

Deliverability of the outcomes

9.2 Many respondents commented on and expressed some degree of concern regarding the deliverability of the Strategy's outcomes. A few of these respondents described the outcomes as vague, whilst others specifically stated it is not clear how they will be achieved, with a few noting that a key barrier to progress has been that public bodies have not been compelled to act. The need to more clearly define the outcomes was suggested by a few respondents. A few other respondents described the outcomes as (too) long-term or ongoing, rather than intermediate for 2020.

9.3 A few respondents suggested alternative outcomes for the Strategy, although there was no clear pattern in the different alternatives suggested. One of these respondents argued that the key steps do not always correspond to their associated outcomes and specifically cited the second and third outcomes as more likely to be delivered by the key steps of chapters four, five and six than those of chapter two or three. Another respondent felt that there was overlap across the seven outcomes.

Level of ambition

9.4 Similar to the comments made regarding delivery, several respondents described the outcomes as highly aspirational or ambitious. On the other hand, one respondent described the outcomes as insufficiently ambitious.

Learning from the past

9.5 Several respondents commented on efforts to achieve previous biodiversity targets, such as the 2010 target. All of these respondents suggested the need for the Strategy to learn lessons from past actions on biodiversity.

Economic focus

9.6 A few respondents strongly commented on the economic focus of the Strategy. One respondent, for example, stated that their greatest concern with the Strategy is that it reads as a Strategy for economic development and social well-being, rather than biodiversity. Another respondent described the Strategy as 'unbalanced' with an underlying assumption that conservation has to be justified in a way that will be useful to economic growth. Another respondent expressed concern specifically regarding the monetary valuation of ecosystem services.


9.7 Several respondents made diverse comments relating to funding and resources. One of these respondents argued that the Strategy's outcomes will be especially challenging given the current financial climate, although noted that progress has already been made via LBAPs and the Scottish Biodiversity Duty. Another respondent believed the outcomes reflect funding pressures and a need to deliver projects with multiple benefits to justify the resource input. Another respondent asked for more detail regarding the cost of delivering the outcomes, while another suggested an alternative key aim for the Strategy which highlights the importance of funding by the Scottish Government and public bodies to halt the loss of biodiversity.


9.8 Several respondents commented on agricultural biodiversity. A few of these respondents highlighted the ecological and economic importance of farmed and cultivated genetic biodiversity, and argued that it is fundamental that the Strategy recognise it. Another respondent spoke of planting community orchards and their beneficial links to biodiversity, healthier eating and the contribution to the local economy. An individual respondent suggested that the Strategy take into account the benefits of lowland farming.

Local dimension

9.9 A few respondents commented on the importance of the local dimension of biodiversity efforts. One of these respondents suggested sharing and expanding across Scotland the work of LBAPs. Another respondent suggested the need for the Strategy to be flexible to local priorities and argued that local work has been underplayed in the Strategy despite it being critical to the delivery of its outcomes. Similarly, another respondent noted that the Strategy only refers to LBAPs and suggested it should reference the various strategies and mechanisms produced by local authorities and other organisations. This respondent also expressed concern that local authorities will be challenged to deliver biodiversity targets because other policy documents and legislation will not have caught up with the emphasis on ecosystems. They suggested guidance for local authorities as well as a more 'mixed approach' (i.e. not purely ecosystems) with an eye on the feasibility of local delivery.

International commitments

9.10 A few respondents commented on international biodiversity commitments and noted that the Strategy does not fully reflect them. For example, one respondent recommended that the Aichi Targets be included in an appendix to the Strategy, while another respondent suggested the Strategy incorporate some of the key objectives from international agreements such as Bern, Ramsar, Bonn, Europbats and the African Eurasian Waterbird Agreement.


9.11 A few respondents commented on the terminology used in the Strategy, stating that it could be clearer and suggesting a glossary. Another respondent pointed out confusion between the use of 'biodiversity' and 'nature'.

Conflicts of interest

9.12 A few respondents commented on conflicts of interest. They noted that the Strategy does not acknowledge potential conflicts of interest, that the outcomes hide these potential conflicts and that this risks damaging biodiversity.


9.13 A few respondents made comments in relation to scale. One respondent for example suggested the need for national and regional management of green corridors and integrated habitat networks, including to help coordinate urban-rural issues, such as the health of bees. Another respondent argued that over-emphasising the term and concept of catchment may prevent progress in those areas where catchments do not apply. Therefore, this respondent suggested 'rebalancing' the Strategy's emphasis to be more inclusive of and applicable to other situations, such as urban, wider wetland networks and rivers.

Other comments

9.14 Other issues highlighted by a few respondents were:

  • A need to engage with business, industry and local authorities on the installation of green roofs, walls, urban gardens and other local level initiatives.
  • A lack of correlation between the Strategy and 2020 Renewables Targets.
  • Despite assertions of the critical importance of peatlands, they continue to be disturbed by development.
  • The omission of a clear research agenda and research priorities
  • The suggestion that any resultant strategy or action plans be the subject of further consultation.

Question 9
Are there any equality issues that the Strategy needs to address (relating to race, gender, disability, age, sexual orientation, gender identity or religion/belief)? If so how could the strategy be improved to meet those needs?

The responses

9.15 Sixteen respondents commented on question nine, most of whom stated there were no equality issues that the Strategy needs to address. A few respondents stated they were not in a position to comment on this question.

9.16 A few respondents suggested that socially-disadvantaged areas were likely to experience the most impact from biodiversity, whether positively through healthy/restored areas, or negatively as a consequence of biodiversity loss. They suggested actively engaging with under-represented groups, for example by seeking minority groups' opinions on the Strategy and/or specifically targeting them with bursaries/funding.

9.17 One respondent suggested the need for an ecosystem approach mechanism that ensures all stakeholders are considered, noting that less direct/more remote stakeholders risk not being taken into account (for example, urban dwellers are affected by countryside issues even if they are not local to them).

Question 10
Are there any other points that you wish to make about any aspects of this draft Strategy paper?

9.18 Fifty one respondents commented on question ten. The majority of these 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.

Overarching aims and scope of the Strategy

9.19 The aims and general scope of the Strategy attracted a diversity of views. A number of respondents gave suggestions regarding the framing of the Strategy at the outset of the document. These included: making it clear why this strategy was produced (for example, in response to the Nagoya Summit and international developments, a trend towards the ecosystem approach); providing a clear statement of who the document is for; and outlining the current domestic and global situation.

9.20 Several respondents addressed the overarching aims stated in the Executive Summary. Some respondents felt these were insufficiently ambitious, and a few felt there was not a clear enough statement of the aims or stated that they did not fully understand what the Strategy aims to achieve.

9.21 Several respondents suggested amendments or alternatives to the stated aims. There were specific comments on the aim to 'increase the general level of biodiversity', which several third sector respondents felt was unclear, whilst others questioned whether it was consistent with Aichi Targets. Another respondent suggested qualifying this aim to take into account undesired increases in biodiversity from invasive non-native species. All of the suggested amendments to this aim were in favour of stating an explicit aim to 'halt biodiversity loss'.

9.22 The same respondents who expressed dissatisfaction with the first aim 'to increase the general level of biodiversity…' also raised concerns regarding the third aim 'to maximise the benefits for Scotland of a diverse natural environment and the services it provides, contributing to sustainable economic growth'. Suggestions included widening this to include wellbeing and not only economic growth, and replacing 'maximise the benefits' with 'carefully manage the benefits'.

9.23 A few respondents questioned what the Strategy adds over and above the Scottish Government's existing commitments to biodiversity. One respondent suggested clearing identifying in the text where the Strategy proposes new actions.

9.24 A few respondents also requested that the Aichi Targets be more prominent in the document, for example including the relevant targets in each chapter. Another respondent suggested that EU targets and Global Strategy for Plant Conservation 2020 Targets could also be included in Table 2 (chapter 7).

Ecosystem services

9.25 A number of respondents across sectors raised concerns about the Strategy's focus on ecosystem services. On the whole, these respondents felt that the Strategy overly focuses on the benefits to people and the economy at the expense of recognising and emphasising the intrinsic value of biodiversity. Several of these respondents thought the Strategy too strongly geared towards economic interests. On the other hand, a few respondents stated explicit support for the Strategy's recognition of the importance of biodiversity for society in general.

Specificity of the Strategy's actions and commitments

9.26 Many respondents raised concerns about the clarity and specificity of the key steps, actions and commitments, feeling that the Strategy does not provide adequate or concrete guidance on how these will be delivered. A number of respondents argued strongly in favour of clearer and more measurable key steps with greater commitment to action, including defined timescales. A few third sector organisations and public bodies called for an action plan to be put in place for implementing the Strategy. Two other respondents felt it was unclear as to whether the Strategy stands alone or if an action plan is to follow.

9.27 Related to the above concerns were issues raised regarding roles and responsibilities for delivery. A significant number of respondents, mainly local authorities, public bodies and third sector organisations, felt that it is unclear who will deliver the key steps and actions. Several of these (primarily third sector respondents) argued strongly that lead bodies should be identified for the key steps and actions. There were also several queries regarding how stakeholders such as landowners, LBAP Partnerships and other local and also national organisations fit in to the delivery of the Strategy.

Terminology and language

9.28 A number of respondents raised issues regarding the language and terminology used in the Strategy, with many of these emphasising the importance of clear definitions and consistency. A few respondents explicitly requested the inclusion of a glossary. Others highlighted terms which should be clearly defined in the text. These included: ecosystem approach, ecosystem health, natural capital/natural assets/natural capital assets, environmental health, and catchment. A few respondents warned against the use of general terms like 'nature' and 'natural environment' in place of 'biodiversity', as the former are subjective terms which carry implicit value judgements and different meanings for different audiences.

9.29 A small group of public sector respondents called for a single agreed hierarchical terminology to refer to the range of scales discussed, from National Ecological Network to local area. A few also felt that the use of ecosystem approach was conflated at times with other terms such as catchment management plans and river basin management planning and called for consistency in this respect.

9.30 Other comments mentioned the frequent use of words like 'should' and 'could', arguing that such language is weak and demonstrates lack of commitment. One respondent felt it was not always clear as to who is being referred to when the word 'we' is used - whether the Scottish Government, SEARS (Scotland's Environment and Rural Services), or a more generic 'we'.

9.31 Several respondents felt the text was repetitive, with one emphasising areas of overlap between the chapters. On the other hand, another respondent commented positively on the structure of the Strategy, feeling that the treatment of the main issues in separate chapters was appropriate.


9.32 A number of respondents voiced concerns over how delivery of the Strategy will be funded. These concerns were most common amongst local authorities and third sector organisations. A few of these respondents argued for a clear commitment to provide resources and funding. Others pointed out that difficult decisions will need to be made in targeting available resources, so priorities should be identified.

9.33 Several respondents, largely local authorities, expressed dissatisfaction with current funding mechanisms. Issues raised included the absence of allocated budgets to geographically defined areas, and ongoing difficulties in securing funding for the delivery of LBAPs.

The role of stakeholders

9.34 A number of respondents expressed disappointment in the lack of reference to local biodiversity partnerships and LBAPs within the Strategy and called for greater recognition of their work and potential role in delivery. A few respondents also highlighted the role of Local Records Centres and volunteer networks in data collection and requested greater recognition of these.

Stakeholder engagement and partnership working

9.35 A few respondents noted the importance of stakeholder engagement in delivering the Strategy outcomes. Some emphasised their interest in engaging, citing relevant biodiversity work, or highlighted structures in place for providing advice to policymakers. One respondent argued for a new approach to the Ecosystem Groups within the Scottish Biodiversity Working Groups; these were perceived to be ineffective and lacking consistency in the approaches of the different groups.

Learning from the Scottish Biodiversity Strategy

9.36 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. These respondents emphasised the importance of the current Strategy stating the lessons learned in order to build on the 2004 Strategy. A few third sector respondents raised concerns that previous commitments had not translated into results.

Scale and geography

9.37 Several respondents raised issues regarding the scale(s) at which actions will be delivered. Whilst some suggested that the scale for delivery should not be catchment/landscape level but coordinated across Scotland, another respondent queried how the scale will be defined and delivered and how landowners might collaborate to deliver landscape scale change. One respondent suggested considering how landscape scale delivery could be delivered through Habitat Management Plans (for example, for renewable energy development) and restoration of mineral extraction sites. Another felt that the treatment of scale in the Strategy is disjointed amongst the chapters (for example, jumping from ecosystems to landscape scale to public health).

9.38 A few public sector respondents suggested more flexible policy to meet the unique needs of agriculture in the Highlands and Islands. Most of these called for crofting specific land management options as opposed to generic farm options. One respondent highlighted sources of evidence on the unique aspects of crop agrobiodiversity in the West of Scotland and Scottish Islands.

Farmed species and genetic diversity

9.39 An argument that the Strategy gives insufficient consideration to farmed and other cultivated (plant and animal) biodiversity and associated genetic diversity was put forward by a few public sector organisations. Scotland's National and International commitments (including Aichi Targets) in this respect were emphasised within these comments. Suggestions to remedy this included: making a specific statement on the role of farm animal, crop and forest genetic diversity and their contribution towards ecosystem services; referencing the Scottish Government's (2002) study The Status of Traditional Scottish Animal Breeds and Plant Varieties and the Implications for Biodiversity and recent studies on crop agro-biodiversity; and mentioning the Scottish Landrace Protection Scheme.

Research agenda

9.40 A few respondents argued for setting out a research agenda to underpin the Strategy and promote its importance, with two respondents offering to work with the Scottish Government to develop this. One of these respondents argued that the appetite for tools such as the ecosystem approach, offsetting and natural capital valuation amongst policymakers is ahead of the scientific evidence, and therefore suggested a commitment to furthering research in these areas. One respondent expressed concern regarding the Strategy's lack of referencing to research and evidence, arguing that it is often very difficult to distinguish between the positions of the authors and those based on evidence.

Strengths of the Strategy

9.41 A number of respondents took the opportunity to highlight the strengths of the Strategy, in addition to suggestions for further attention. A diversity of points were raised in this respect including:

  • Comments welcoming the intentions, rationale and aspirations of the Strategy, including recognition that this is intended to be a high level strategic document as opposed to detailing each individual action required.
  • Appreciation of the aim to engage people with the natural world and support for recognition of the importance of the natural world for our health, wellbeing and prosperity.
  • Support for the emphasis on the ecosystem approach in the Strategy.
  • Support for the efforts to achieve the target of 95% of protected sites in favourable condition.
  • Welcoming the recognition of the importance of high quality biodiversity data.

Other comments

9.42 Other issues highlighted by a few respondents were:

  • The suggestion that the Strategy should make more explicit the links to other strategies and delivery mechanisms. On the other hand, one respondent praised the Strategy's alignment with other strategies.
  • A perception that the main focus of the document is outlining why we should be concerned about biodiversity rather than committing to action.
  • A view that the positive and idealistic tone of the document is disconnected from what land managers perceive as the real world, and an opposing view from another respondent welcoming the Strategy's realism.
  • A call for an assessment of the coverage and management of Scotland's network of protected sites.
  • Concern that the SBIF arose out of an outside agency petitioning the Scottish Parliament, rather than from the SBS in which it was identified as a priority action.
  • Lack of reference to the Caledonian Forest.
  • A recommendation for the establishment of a Centre of Biodiversity Expertise (in line with those for water and climate change).


Email: Biodiversity Strategy Team

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