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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.


10. STRATEGIC ENVIRONMENTAL ASSESSMENT

Four questions were asked on the Environmental Report. The questions and responses are reported below.

Question 11
Are you content that an accurate description of the current environmental baseline has been provided?

The responses

10.1 Question 11 was addressed by 23 respondents. Of these, most were supportive outright and a few in broad terms. Slightly fewer respondents provided comments but did not give a clear indication of whether they agreed or disagreed with the description of the current environmental baseline. Several respondents indicated disagreement with the description of the current environmental baseline.

Farmed and cultivated biodiversity

10.2 A few respondents noted the omission of farmed and cultivated biodiversity, including forestry, and highlighted its importance. Based on this omission, these respondents stated 'no', that they are not content that an accurate description of the current environmental baseline has been provided.

LBAPs

10.3 Several respondents noted the lack of reference to LBAPs, Supplementary Planning Guidance, Planning Advisory Handbooks and/or local development plans. A few respondents specifically noted this omission in '4: Environmental Context Policy Context for the Environmental Assessment'. Due to this omission, one of these respondents stated 'no', they were not content that an accurate description of the current environmental baseline had been provided.

Orchards

10.4 A few respondents noted that there is no mention of orchards in the Woodlands or other sections of 'Environmental Context - Landscape and Cultural Heritage'.

Other comments

10.5 Other issues highlighted by one or two respondents were:

  • The omission of the impact on ground nesting birds by foxes, otters, corvids and pine martens. It was suggested that exclusion zones should have been considered as a viable option for the protection of vulnerable species.
  • A suggestion of including predictions of confidence in the assessment findings (for example, inclusion of likelihood intervals).

The problem posed by large gaps in the environmental information available, making it difficult and/or impossible to comment on the Strategy's potential impact.

  • The problem posed by SSSI monitoring, described as an imprecise science as the Common Standards Monitoring is not really designed to monitor change.
  • A suggestion to include earthworm or at least a soil indicator organism in the baseline.
  • A suggestion to recognise those who contribute to biodiversity through sustainable land management outside of protected areas.
  • A suggestion to replace the text box 'UK BAP - co-ordinating' with 'UK Post-2010 BD Framework', as the structures of the UK BAP, including UK targets have been superseded since 2011 and that Habitat and Species Action Plans, if they still operate, do so only at a country, not UK, level.
  • Praise of the SEA as more scientifically-sound and biodiversity-oriented than the ecosystem services approach of the Strategy
  • Support for 'Strategic Scenario 2: Deep ecology' (page 18 of SEA) and support for aspects of the Provisioning Services section (page 41 of SEA)
  • Criticism that despite the report's ecosystem approach, there is also a tendency to treat the different service types as completely separate.
  • No mention of CAP or SRDP, which was cited as a serious omission.
  • Criticism that despite protected areas not existing in isolation, the baseline environment section is heavily focused on them, at the expense of wider countryside issues.
  • No mention of the Scottish hills and the retreat of livestock from them in agriculture section (4.3.22-23), which is exclusively focused on lowlands.
  • No mention of high nature value farming and forestry.

Question 12
Are you aware of any further environmental information that will help to inform the assessment findings?

The responses

10.6 Question 12 was addressed by 15 respondents. Just over half of these responded 'no', they were not aware of any further environmental information that would help to inform the assessment findings. Just under half the respondents provided comments and suggestions. These comments are summarised below.

References to work of others

10.7 A number of reports were suggested and/or provided, including: Policy drivers for Farm Animal Genetic Resources protection and conservation within the UK; Ecosystem services from Environmental Stewardship that benefit agricultural production, Natural England; The Status of Traditional Scottish Animal Breeds and Plant Varieties and the Implications for Biodiversity, the Scottish Executive, 2002. Other made more general references to work by the United Nations Food and Agricultural Organisation and work on the UK Species Dictionary and a new list of Native Breeds at Risk in the UK.

Other comments

10.8 Other issues highlighted by one or two respondents were:

  • A suggestion that SNH work closely with research institutes, universities and NGOs for best and most efficient data use.
  • A suggestion to include Scottish Government statistics on the extent and broad distribution of High Value Nature Value farming and forestry systems in Scotland.
  • A suggestion that partner organisations and effective networking would help to inform the assessment findings.
  • Offers of their own data (a third sector organisation and a public sector organisation) which could contribute to the assessment findings.
  • A suggestion to include information regarding status of the New Zealand flatworm in Scotland.

Question 13
Do you agree with the conclusions on the environmental effects of the Strategy?

The responses

10.9 Question 13 was addressed by 24 respondents, most of whom provided comments but did not give 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 them.

Marine

10.10 Several respondents commented on the marine environment in relation to the environmental conclusions. This was the most commonly agreed point made by respondents to question 13, all of whom stated that the SEA makes very little reference to the marine and coastal environment despite the Strategy itself devoting a whole chapter to it. A few of these respondents also noted that the SEA's definition of water focuses on fresh water, despite paragraph 4.3.8 acknowledging that over half of Scotland's administrative territory is marine. They argued that this is an oversight and should be re-balanced.

Reasons for disagreement

10.11 A few respondents disagreed with the conclusions on the environmental effects of the Strategy because they do not recognise farmed and cultivated biodiversity, including forestry. Another of these respondents disagreed with the conclusions because they felt the report's emphasis on ecological network development may be impractical and in conflict with economic aspirations (for example, farming, forestry, renewables). This respondent suggested that instead of relying on 'metapopulation linkage', more analysis and prominence should be given to local breeding and reproductive management.

Scenarios

10.12 A few respondents commented on the scenarios. One respondent stated that the four scenarios are extremes and do not represent a likely way forward. It was suggested instead that the focus should be on striking a balance among them and in turn, also a balance among conservation, ecosystem services and natural capital. Another respondent stated a preference for the second delivery scenario. One other respondent thought there was a lack of clarity whether the scenarios have been developed by taking account of the current Biodiversity Strategy.

Other comments

10.13 Other issues highlighted by one or two respondents were:

  • The intrinsic importance of biodiversity in its own right (as opposed to its relation to economic growth).
  • No mention of CAP or SRDP, which was cited as a serious omission.
  • Although the generalised environmental effects of ecosystem services may be realised, the consequences for biodiversity remain highly uncertain.
  • Although the SEA is cohesive in itself, there is a disconnect between it and the Strategy, in that the prominent utilitarian approach of the Strategy is dismissed in the SEA.
  • Concern regarding potential additional legislation other than those already imposed through EU Habitats Directive, based on statements made in paragraph 1.1.64
  • The landscape topic is subjective.

Question 14
Are you aware of other 'reasonable alternatives' to the Strategy that should be considered as part of the SEA process?

The responses

10.14 Question 14 was addressed by 15 respondents. Just over half of these respondents answered 'no', they were not aware of other reasonable alternatives to the Strategy that should be considered as part of the SEA process. Just under half of these respondents provided comments, most of which addressed the question directly by suggesting specific alternatives, although others offered more general feedback.

Farmed and cultivated biodiversity

10.15 A few respondents suggested that farmed and cultivated biodiversity should be developed as an alternative. One of these respondents suggested that there should also be full assessments of a 'Strategic Scenario' and a 'Delivery Scenario' that comprehensively integrate all components of agricultural and forestry biodiversity/genetic diversity.

More detail

10.16 A few respondents answered 'no' to question 14 but also suggested that more detail is needed. One of these respondents thought the SEA had dominated the Strategy, resulting in a vague document, but this was understandable given that the impetus was economic development. Another respondent argued that the Strategy should include more details regarding the who's, how's and when's.

Other alternatives highlighted

10.17 One respondent stated that the SEA's scenarios are good and suggested a combination of the Deep Ecology and Delivery Scenario 2.

10.18 Regarding INNS, one respondent suggested as complementary and not as alternatives, the existing UK Strategy, the EU Directive and the Marine Strategy Framework Directive.

Contact

Email: Biodiversity Strategy Team

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