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.


Q1a) Does chapter 1 propose the right approach to reach the outcome that Scotland's ecosystems are restored to, and maintained in, healthy condition so that they deliver robust ecosystem services and build Scotland's natural capital?

Q1b) What additional steps can you propose, including things that you, or your organisation, can do?

Scotland's ecosystems are restored to, and maintained in, healthy condition so that they deliver robust ecosystem services and build Scotland's natural capital.

Key steps
Encourage and support ecosystem restoration and management, especially in catchments that have experienced the greatest historic degradation.

Using assessments of ecosystem health at a catchment level determines the priorities for building natural capital and identify where action is required.

Found plans and decisions about land use on an understanding of ecosystems, and take full account of land use impacts on the ecosystems services which underpin social, economic and environmental health.

The responses

2.1 Sixty five people commented on question 1a, whilst 64 respondents commented on question 1b. The majority of respondents 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. Another fairly large set of respondents provided comments but did not give clear indication of whether they agreed or disagreed with the approach. A small number of respondents indicated an overall disagreement with the approach.

Ecosystem approach

Conflicting political and administrative priorities

2.2 Many respondents pointed out the likely conflicts of interest that would result from an ecosystem approach, given the complexity of ecosystem and catchment scales operating across political, administrative and institutional boundaries. Several respondents pointed out the diversity of stakeholders inherent to an ecosystem approach, making collaboration and coordination all the more important but challenging (for example, across local-regional-national institutional and geographic scales, different sectors, government departments, local biodiversity partnerships and networks, etc).

Conflicting land use priorities

2.3 Several respondents pointed out the reality of different land use interests and that people own and manage land for different reasons. One respondent also noted that land managers generally manage estates, not catchments, which has consequences for the take up of the Strategy. Several respondents suggested that the Strategy needs to recognise the likelihood of varying human interests and/or conflicting priorities inherent to an ecosystem approach, and that the Strategy should provide mechanisms and practical guidance as to how such conflicts may be overcome in order to deliver the intentions of the Strategy.

Specialist knowledge

2.4 Several respondents highlighted areas of specialism and suggested that they be better recognised in the Strategy. The following areas of specialism were cited: land managed for shooting; productive forestry; National Park designations; game bird management; geodiversity; farmed and cultivated biodiversity; historic environment; business and industry.

Ecosystem health

2.5 Several respondents commented on ecosystem health. A few of these respondents noted the challenge of expressing, measuring and/or defining ecosystem health, arguing that more research is needed. A few respondents pointed out that the steps listed in paragraph 1.5.1 are not actually steps to improve ecosystem health, but rather, steps which must be taken before being able to improve ecosystem health. On ecosystem health, a few respondents pointed out the implications of conflicts of interests, asking what is meant by ecosystem health and who will deliver an assessment of ecosystem quality.

Concept of restoration

2.6 Several respondents commented on the chapter's reference to restoration, a few of whom argued that as a concept it is flawed because it does not recognise the dynamic state of nature. For example, referring to the future, a few respondents noted that new and different natural systems will emerge because that is simply how nature works, but even more so in the context of climate change. Similarly, referring to the past, a few respondents questioned the desirability or feasibility of restoring ecosystems, given the dynamic nature of ecosystems and changes in the overall economy. A few respondents argued that the Strategy does not adequately reflect these uncertainties and fluctuations when it refers to the notion of restoration and ecosystem health, which one respondent described as a 'moving target'. One respondent suggested that the Strategy should reference 'creation' rather than 'restoration' where there is no habitat remaining to restore.

Ecosystem services

Ecosystem services and biodiversity are not synonymous

2.7 A number of respondents commented on the relationship between ecosystem services and biodiversity. Several of these respondents thought that the Strategy infers a perfect association between ecosystem services and biodiversity - a point with which they all disagreed and suggested be clarified in the Strategy. A few other respondents meanwhile pointed out that ecosystem services can be achieved independently of large amounts of biodiversity and similarly, that more biodiversity does not necessarily equate to more or better ecosystem services. Illustrating this point, they highlighted man's management and control of biodiversity in agriculture (for example, pest and disease control).

Ecosystem services in conflict with biodiversity

2.8 It was noted that not only are ecosystem services and biodiversity not synonymous, they may be in conflict and therefore the Strategy should include mechanisms to manage those conflicts and establish priorities, including species protection. A few respondents noted that a focus on ecosystem services may come at a cost to biodiversity, insofar as it risks diminishing the value of habitats and species that do not appear to provide obvious or direct services to humans (for example, those which are more remote to humans). A few respondents suggested that the Strategy include mechanisms to conserve biodiversity in its own right, not just for the services it provides, and to explicitly state that biodiversity is a fundamental component to the ecosystem approach, including ecosystem health and ecosystem services. This suggestion - that more emphasis be placed on biodiversity's intrinsic value - was suggested by other respondents to this chapter, although not directly in the context of ecosystem services.


2.9 Several respondents provided diverse comments on the subject of valuation.
A few of these respondents suggested the need for accounts to distinguish between stocks and flows of natural capital and its services. One respondent argued that a consistent national approach to accounting is necessary, and as a model, recommended the United Nations Wealth Accounting and the Valuation of Ecosystem Services (WAVES). A few respondents disagreed with paragraph 1.1.2's assertion that the UK National Ecosystem Assessment (UKNEA) represents a full account of the value of the UK's ecosystem services, with one respondent noting that the Assessment itself acknowledges that many services cannot be valued monetarily or non-monetarily. This point - the difficulty or uncertainty of valuation - was mentioned by a few other respondents, one of whom cited cultural services and spiritual feelings as biodiversity values that are difficult or impossible to value or quantify. Another respondent cautioned against the Strategy skewing towards the socio-economic and away from the environmental, suggesting that the Strategy emphasise the intrinsic value of biodiversity from the outset in order to better direct the way in which it is valued and measured. A general suggestion was made for guidance on valuation.

Developing an ecosystem approach

Catchments and ecosystem types

2.10 A number of respondents commented on the catchment approach. Several of these respondents argued that the catchment approach and/or River Basin Management Plans (RBMPs) would not be appropriate for all areas, with a few noting their unsuitability for islands. A few respondents commented on catchments in relation to water, with one noting that the term 'catchment' only seems to reflect watercourses and not other ecosystems such as woodlands and grasslands. Another respondent suggested the Strategy clarify that RBMPs provide information on coastal and transitional waters and that freshwater in this context includes groundwater, rivers and lochs. Other issues highlighted included: making clear the special connections between river catchments, coastal and marine environments; the idea of a pilot-scheme to develop the 'catchment-by-catchment' proposal in paragraph 1.4.4; and a request for clarity and consistency regarding terminology, including the need to distinguish between the various operating scales mentioned in the Strategy, such as 'landscapes' versus 'catchments'.

Catchments and boundaries

2.11 Several respondents commented on the challenge of negotiating a catchment approach with political and administrative boundaries. Suggestions in response to this included: engaging stakeholders; the Strategy providing local guidance, developing sector specific initiatives and realigning local biodiversity areas.

2.12 Several respondents, half of whom were local authorities, suggested 'opportunity mapping' as a means to help identify area and funding priorities.

River Basin Management Plans (RBMPs)

2.13 Although a few respondents seemed supportive of a catchment approach, a few believed RBMPs will not deliver, or are in conflict with, an ecosystem approach. A few respondents described RBMPs as aspirational, having had limited impact and crossing local authority boundaries. Several respondents recommended that the Strategy specify how RBMPs will be improved and how they will deliver the outcomes of the Strategy.

Appraisal of development

2.14 Several respondents commented on paragraph 1.4.4 and disagreed with its statement regarding 'less demanding appraisal' of development.

Adaptive management

2.15 Several respondents commented on the topic of adaptive management, around half of whom supported its principles. Other respondents provided more detailed comments or suggestions but without a clear indication of support. For example, one respondent argued that the application of adaptive management for designated sites is challenging because of their existing procedures. Another suggested that the Strategy specify who it is referring to when it states 'we' in the context of adaptive management, whilst another suggested it should provide examples. How the government will ensure that adaptive management occurs in practice and is not prevented by, for example, agri-environment schemes within the SRDP, was raised by another respondent.

Existing local biodiversity work and national leadership

2.16 A number of respondents commented in relation to existing local work on biodiversity. Several respondents noted the chapter's lack of reference to the Scottish Local Biodiversity Action Plan (LBAP) Network, its Partnerships and Forums, which they argued should contribute to national priorities, in part because they are composed of both local government and non-governmental organisation (NGO) members. They argued that this work is vital and that it should be recognised as such in the Strategy. A few respondents suggested that existing local work should be built upon, for example, by focusing on projects and places already identified as priorities for action, or by using existing data.

2.17 The connection between local and national levels of biodiversity action was stressed by a number of respondents. All of these argued that the Strategy must provide guidance to ensure local work contributes to and is aligned with national priorities. For example, a few respondents suggested the need for the Strategy to clearly communicate local-level practical actions in the context of national priorities.

Scottish Biodiversity Duty

2.18 Several respondents commented on the Scottish Biodiversity Duty, one of whom asked if there is any evidence of its effectiveness, whilst another suggested it needs to go further in requiring public sectors bodies to report on their biodiversity actions. The other respondents suggested that the Strategy mention the Duty and what it requires of the public sector.

Central Scotland Green Network (CSGN)

2.19 Several respondents commented on and broadly expressed their support of the Central Scotland Green Network (CSGN). A few of these respondents believed this type of project should be extended, and another felt it was over-emphasised at the expense of other areas. Others commended the CSGN for achieving collaboration across boundaries and varying land interests.

National Ecological Network (NEN)

2.20 Several respondents commented on the National Ecological Network (NEN) and expressed support for its development. A few respondents asked if it will be extended, with one respondent suggesting it should no longer focus only on the Scottish central belt. Another respondent suggested the need to complete a habitat map of Scotland in order to inform the development of the NEN. One respondent noted that the Strategy does not explain what actually constitutes a NEN, while another suggested the importance of highlighting wetland networks (and not just 'green' networks).

Overarching comments


2.21 Several respondents commented on the Strategy's proposal for six to twelve broad indicators (paragraph 1.6.2). Issues raised included: such an approach could fail rare and threatened species which either may not be an economic priority, and/or which may need more detailed attention; the goal should not be a simple or arbitrary approach, but rather, an effective one; there should be a mechanism in place to establish the consequences of these indicators on biodiversity; and, broad indicators be broken down and made more precise and measurable.

Resources and Scotland Rural Development Programme (SRDP)

2.22 Many respondents commented on the issue of funding, with most of these commenting on the need for sufficient resources to be identified to deliver the Strategy. More detailed comments made by several respondents included: past failures stemming from issues with funding, including not enough funding or poor use; the need to better target resources; and a call for biodiversity partnerships to have dedicated funding so that valuable time is not taken away from delivery in chasing funding sources.

2.23 Many respondents, including local authorities, commented specifically on the Scotland Rural Development Programme (SRDP) and called for reform. Issues highlighted included: its complexity; that it cannot process large single bids at landscape scale from multiple landowners and therefore may compromise the ecosystem and landscape scale approaches; and the challenge of securing SRDP funding for small scale projects.

Learning from the past

2.24 Several respondents commented on the Strategy's failure to recognise and assess previous experiences, successes and failures on work to improve biodiversity. All of these respondents suggested the need for the Strategy to learn from past efforts, with a few adding that this was especially important given that the 2020 target is the same as the (unmet) 2010 target. A few respondents recommended such an assessment should be the starting point of the Strategy.

Level of detail

2.25 A number of respondents commented on the chapter's level of detail, all of whom agreed that it is insufficient and should be made more specific. Of these respondents, many described the chapter as vague or unclear in terms of how outcomes are to be achieved. Several respondents suggested the need for specific timescales and reporting structures, i.e. a more defined delivery plan. Several respondents also commented on the need to clearly state who is responsible for what, especially given the diversity of stakeholders involved and the need for their collaboration.


2.26 A number of respondents commented on the chapter's use of terminology, all of whom suggested a need for greater clarity, consistency and/or explicit definitions. A few of these respondents cited examples of inconsistency or confusing use of terminology, such as nature versus biodiversity; landscape versus catchment scale; and environmental capital versus natural capital.

Other comments

2.27 Many respondents, from all respondent types but particularly the public sector and the third sector, noted ways in which they could, or already were, supporting delivery of the Strategy. These included:

  • Highlighting examples of their own work which promotes biodiversity, for example, guidance for planners on how to apply the ecosystem approach to planning. This encompassed work which could provide and improve research data and evidence, for example, monitoring and surveillance of certain species.
  • Varied examples of existing partnership working, including communication with wider audiences, and offers to contribute to further partnership working.
  • Incorporating the Strategy's objectives into policy and management plans.

2.28 Alternative key steps were proposed by several respondents; some of these consisted of amendments to those proposed in the Strategy, however others suggested inclusion of additional key steps. Changes to the key steps were generally aimed at making them more specific and measurable. Three third sector respondents provided the same additional key steps, which are listed below. These bodies also stated that public lead bodies required to be identified for each habitat type and for each key step, alongside appropriate and adequate resources.

  • Meet requirements of the Water Framework Directive and Marine Strategy Framework Directive.
  • All land use decisions and plans result in no net loss of important wildlife and habitats, based on an understanding of ecosystems, and take full account of land use impacts on the ecosystems services.
  • Complete the "habitat map of Scotland" creating for the first time a map of habitats across Scotland to inform long term development of the National Ecological Network and identifying and defining areas of High Nature Value (HNV) farming and forestry.
  • Develop the National Ecological Network, (is this just terrestrial or also marine?), a long term project to restore health and connectivity to Scotland's ecosystems.

2.29 Other points highlighted by a few respondents were:

  • The Strategy's imbalance of focus on rural areas and the need to make reference to the unique circumstances of biodiversity in urban areas.
  • The suggestion that an ecosystem approach should not obscure the ongoing need to protect individual habitats and species.
  • The importance of monitoring the ecosystem approach.


Email: Biodiversity Strategy Team

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