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.


2a) Does chapter 2 propose the right approach to reach the outcome that natural resources contribute to stronger sustainable economic growth in Scotland, and we increase our Natural Capital to pass on to the next generation?

2b) What additional steps can you propose, including things that you, or your organisation, can do?

Natural resources contribute to stronger sustainable economic growth in Scotland, and we increase our Natural Capital to pass on to the next generation.

Key steps
Encourage wide acceptance and use of the Natural Capital Asset Index, including an index measure for the marine environment.

Inform decision-making and market-based approaches using established values for ecosystem services.

Begin a programme of peatland restoration and management, as recommended by the IUCN UK Commission of Inquiry on Peatlands.

Explore the potential for greater use of 'offsetting' to secure benefits for biodiversity whilst minimising costs to business.

The responses

3.1 Sixty two respondents commented on question 2a, whilst 49 commented on question 2b. 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 people who commented either way did however state qualifications to this or areas they felt required strengthening.

Economic focus

3.2 A number of respondents commented on the economic valuation of nature and on this being the focus of chapter two. Several of these respondents argued that it is a matter of emphasis - that either too much of the chapter's emphasis is placed on economic concerns, or that not enough it is placed on non-economic values, with some concern that a strong economic focus risks losing sight of biodiversity. One respondent pointed out that the EU biodiversity strategy explicitly recognised the intrinsic value of biodiversity, while another argued that it is critical for the Strategy to include mechanisms to protect the social, cultural, moral and aesthetic values of biodiversity. That such non-markets values are difficult or impossible to express in monetary or quantified terms was noted by a few respondents.

3.3 A few respondents suggested the use of the precautionary principle in order to help capture both market and non-market values of biodiversity, with one respondent suggesting the principle be defined in the Strategy.

Sustainable economic growth

3.4 Several respondents commented on the challenge of and conflict between simultaneously sustaining economic growth and environmental integrity, as well as economic growth and biodiversity. A few respondents suggested that the Strategy should address this fundamental conflict. For example, it was noted that for some, natural capital may be seen as getting in the way of economic development, whilst for others it may be difficult to accept the monetary valuation of nature. Another respondent suggested the Strategy should acknowledge that some activities which lead to economic growth do in fact exploit biodiversity. Similarly, a few respondents suggested recognising that natural capital is dependent on healthy ecosystems. Others pointed out that planning laws can override legislation designed to protect designated sites and asked if this contradiction had been considered.

3.5 In a similar vein, several respondents questioned or disagreed with the notion of sustainable economic growth (expressed in the chapter's outcome). One respondent argued that is not clear what sustainable economic growth actually looks like, pointing out the confusing contradiction of state owned forests being cleared for wind farms, and arguing that government must lead by example and show how it encourages/discourages (un)sustainable growth. Similarly, another respondent felt that the term 'sustainable economic growth' has lost much of its meaning and asked if is even possible in a world of finite resources, suggesting a more appropriate aim may be greater equity in sharing resources. Another alternative aim suggested was zero economic growth, given that growth cannot continue with finite resources.

3.6 On the other hand, several respondents supported the chapter's recognition of biodiversity's contribution to the economy. A few respondents stated that this recognition may increase awareness of biodiversity which one respondent noted, may in turn result in improved biodiversity itself.

Natural capital

Natural capital valuation

3.7 Several respondents commented on the relatively short-term focus of economic goals and natural capital valuation and how this conflicts with and may compromise biodiversity, which requires a long-term perspective. A few respondents noted that the valuation process itself will require time, whilst another respondent noted that Environmental Impact Assessment (paragraph 2.3.1) may not incorporate a long-term view and still permit the depletion of natural capital.

3.8 Several respondents argued that merely creating a valuation for natural resources does not equate to halting biodiversity loss, an increase in natural capital or sustainable economic growth, i.e. it is not a solution in itself, but rather a tool. Furthermore, one respondent noted that an increase in natural capital does not necessarily equate with an increase in biodiversity. In a similar vein, another respondent cautioned that the chapter's framework will result in certain ecosystem services being more highly valued than others just because they are perceived to have greater human (including economic) benefit.

3.9 Other issues raised in relation to natural capital valuation included: a question over how the exploitation of resources for short-term economic gains sits with 'resource efficiency' in paragraph 2.4; that considerable and coordinated research is needed; that valuation information be used as only one of many lines of evidence to inform policy; a suggestion to provide examples of natural capital valuation; and to explicitly recognise that natural capital includes farmed and cultivated biodiversity.


3.10 A number of respondents agreed with the Strategy's suggestion that the value of natural capital be incorporated into accounting practices and provided diverse comments. A few of these respondents noted the Strategy's lack of explanation as to how businesses could be convinced to start focusing on environmental accounting rather than Gross Domestic Product (GDP). A few respondents also stated that natural capital accounting will be useful for green networks. Other comments included: the need for research on the implementation of natural capital accounting; the change in culture and perception that will be required to make this transition and that few organisations have the knowledge to undertake this; and the challenge posed by an economist's need for tangible, compartmentalised and itemised units which are rare or do not exist ecologically.

Stocks versus flows

3.11 Several respondents highlighted the importance of differentiating between changes in natural capital stock versus its totality, and argued that the Strategy must make this distinction clear. A few respondents argued that what is needed is a focus on the pressures being exerted on natural assets and the responses to those (i.e. flows). Another respondent on the other hand argued that it is stocks of capital that need to be sustained, and not flows per se. One respondent pointed out that confusion on this matter has resulted in the over-exploitation of fish stocks.

Natural Capital Asset Index

3.12 A number of respondents provided diverse comments on the Natural Capital Asset (NCA) Index, several of whom supported it in full or in principle. However, a few others were concerned that it is being prematurely promoted given that it has not been peer-reviewed and does not seem to distinguish between stocks and flows. One respondent stated that the NCA Index relies heavily on expert judgement and personal opinion and has no assessment of confidence intervals around estimates, whilst another suggested it should be considered a work in progress in need of research. Additional comments on the NCA Index, each made by one or two respondents were:

  • To set the NCA Index's baseline at historic levels and not the current all time low.
  • Priority should be given to the establishment of an asset register and Natural Capital Index accounts.
  • A suggestion to note the quite different approaches of the UK National Ecosystem Assessment (UK NEA) and The Economics of Ecosystems and Biodiversity (TEEB) reports before implementing a NCA Index.
  • Connecting with similar efforts on a NCA Index in England.
  • It should include farmed and cultivated genetic diversity.


3.13 Several respondents commented in relation to subsidies and agreed with the proposal (paragraphs 2.9 and that subsidies will be reformed in order to support sustainable rather than unsustainable practices. One respondent added that an important part of this will be a re-orientation of values and a greening of the SRDP. Another suggested that these subsidies should not only support the building of natural capital (as stated in paragraph 2.9) but also its conservation. One respondent asked for reassurance against the subsidising of private or charity-based single focus organisations or groups who may restrict or prohibit access to traditional hunting areas.


3.14 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 and described a number of issues associated with offsetting.

3.15 Of those respondents who expressed some degree of support for offsetting, one respondent noted that it may help developers to better understand the adverse effects of their actions, or perhaps even to make them proud of the habitats they create.

3.16 However, a number of respondents argued that offsetting should only be seen as the last resort in the mitigation hierarchy, following avoidance, minimisation and onsite mitigation. Several of these respondents suggested that this point and the hierarchy itself be made clear in the Strategy, with a few respondents noting that it is currently lacking. A number of respondents also cautioned against offsetting because it could become a way for industries to avoid their responsibilities.

3.17 The varied issues highlighted by respondents in relation to offsetting are described below.

Offsetting and unique resources

3.18 A number of respondents commented on the impossibility of recreating habitats or offsetting substituting for the 'real thing'. A few respondents cited peatbogs and ancient woodlands and the historic environment more generally, as examples, and described them as irreplaceable. A few other respondents linked the irreplaceability of biodiversity with attempts to value it in monetary terms, with one respondent arguing that offsetting value is dependent on uniqueness, whilst another argued that nature is priceless and therefore should not be commoditised. Another respondent argued that no amount of mitigation or money will change loss to biodiversity. There was also a concern about the message offsetting may give regarding the importance of protecting valuable habitats.

Offsetting and the importance of time

3.19 A number of respondents highlighted the importance of time in relation to offsetting. Several of these respondents cited specific examples, such as peatbogs which have taken millennia to develop, or ancient woodlands being replaced (offset) with new planting. They argued that the age of different biodiversity has various implications, including its ecosystem and ecosystem services value. Similarly, a few respondents argued that offsetting must be considered on very long term timescales.

Offsetting and geographic scale

3.20 A number of respondents commented on offsetting in relation to appropriate geographic scale. Several of these respondents described the requirement of offsetting to specify a 'defined' area, whereas a few respondents stressed the importance of scale based on ecological networks and connectivity. A few other respondents noted that some places will simply be off-limits to offsetting and/or just not available when and where offsetting is being considered. Several respondents felt that offsetting should take place in a local area, with a few of them specifically stating that offsetting should deliver local benefits. One respondent asked whether offsetting funds are intended to remain local, while another felt that on-site solutions, such as green roofs or green walls, should be possible in most cases, and if not, that a site is being overdeveloped. Another respondent suggested that if used, offsetting benefits should focus on local or national priority habitats and species. This respondent also noted the difficulty of determining potential impacts at different scales, and that to do so would require considerable additional resources (for example, time, data) that may not exist.

Offsetting valuation

3.21 A number of respondents provided diverse comments in relation to offsetting valuation, although all of them expressed concern about this process. A few of them cited the limitations and uncertainties of valuation, including the potential for ineffective or counterproductive trading, for example, valuation of multiple benefits or high value biodiversity losses being traded for low value biodiversity gains. One respondent suggested the need for compensation arrangements to be flexible enough to enhance biodiversity rather than simply assume like-for-like trading (for example, replacing trees felled with new planting) would be the most beneficial. Several respondents stated that offsetting must result in a net positive benefit for biodiversity, rather than a reduced or net loss.

3.22 A few other respondents argued that financial pressures may skew valuations, with one of these respondents expressing concern that offsetting could be used inappropriately as a sort of development tax to compensate for the limited resources of local authorities. They described an increased tendency for developers to have to deliver biodiversity offsets significantly over and above the level of impact. Instead they suggested that offsets should equate to the loss of habitat and nothing more, and that any offsetting provider should have a credible track record (for example, the Wildlife Trust's Biodiversity Benchmark accreditation). A few other respondents expressed concern that nature could be perceived as just another commodity, which can be destroyed or traded for a nominal sum.

Offsetting and research

3.23 A number of respondents suggested the need for more research into biodiversity offsetting. A few respondents described this area as emerging and with insufficient scientific evidence, with one respondent arguing that the policy drive towards biodiversity offsetting and natural capital valuation is well ahead of research. Several respondents specifically suggested the need to commit funding for research into biodiversity offsetting, including pilot projects. A few other suggested lessons should be learnt from offsetting in other policy areas (for example, climate mitigation).

3.24 Several respondents noted that offsetting schemes are already in place outside of Scotland, and a review of these schemes was suggested by a few respondents. A few other respondents cited England's trial offsetting scheme.

Offsetting management and guidance

3.25 Several respondents provided diverse comments broadly related to the management of offsetting schemes, such as their monitoring, enforcement, transparency, accountability, legislation, partnerships and assessment of risk. One respondent suggested that biodiversity offsetting be regulated by Scottish Natural Heritage (SNH) and another argued that as a blanket policy, offsetting would be difficult to manage.

3.26 A number of respondents suggested the need for offsetting guidance, with several of them stating that this guidance should be standardised, national, strict, robust, and/or clear. One respondent mentioned the offsetting principles within The Lawton Review's 2010 Making Space for Nature: A Review of England's Wildlife Sites and Ecological Network.

Offsetting and wind farms

3.27 Several respondents referred to wind farms when expressing their concerns about biodiversity offsetting. For example, a few respondents expressed their concerns over offsetting valuation and the need for coordination and further research by pointing out that state owned forests and areas of peat are being compromised for wind farm development.

3.28 Other comments made by one or two respondents on offsetting included:

  • The suggestion that offsetting could be used to help increase connectivity of fragmented habitat (in response to paragraph 2.5.3).
  • The need for biodiversity offsetting to recognise the role of geodiversity.


3.29 A number of respondents commented on and expressed support for the Strategy's proposal to restore peatlands. However, a few respondents expressed concern about how such a programme would sit alongside others. For example, one respondent questioned the effects of peatland restoration on targets for woodland expansion, whilst another noted that peat areas are being damaged by wind-farms. A few respondents argued that the development of a peatlands programme will require working with landowners. Other comments included:

  • The Strategy should provide more details about how such a programme will work in terms of timescales and responsibilities.
  • That peat (and high carbon soils) be prioritised as significant assets and that awareness and understanding of them is improved, including the provision of guidance.
  • The Strategy should mention that there are other international and national priority habitats (for example, those in the UKBAP).
  • The suggestion to strengthen the peatlands programme by cross-referencing it with the Land Use Strategy and 2009 Climate Change Act.
  • Appropriate funding will be needed for any peatlands programme.
  • Peat Carbon and Woodland Carbon Codes (paragraph would not work to the same timescales.

Funding and delivery

3.30 Several respondents provided diverse comments on the topic of funding. A few of these agreed with the need to update the SRDP. A few others stated the need for funding more broadly, including one respondent who suggested increased resources for research into farmed and cultivated genetic resources.

3.31 Several respondents argued the need for a greater level of practical detail in terms of the chapter's implementation and that it should include time bound actions and responsibilities.

Other comments

3.32 A number of respondents 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 and the approach outlined in the chapter, including research and education with landowners; their own offsetting work in woodlands and the work of the Crichton Carbon Centre; work with SNH to explore taking an ecosystem approach to the Biosphere.
  • Examples of partnership working, including various offers to help the Scottish Government. This included: defining biodiversity targets and thinking by using amphibians and reptiles as a model; sharing expertise in offsetting; and mainstreaming biodiversity into the planning process.
  • Incorporating the Strategy's objectives into policy and management plans, including exploring the chapter's approaches in the Loch Lomond and the Trossachs National Park.

3.33 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 and alternative 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.

  • Restore 100,000 hectares of peatland to favourable condition, using carbon offsetting by public bodies as a funding mechanism where appropriate.
  • Restore 500 hectares of coastal dune and heath.
  • Restore 500 kilometres of natural tree line.
  • Restore 1,000 hectares of montane scrub.
  • If biodiversity offsetting is used, it should reflect the real value of existing and destroyed habitats so that offsetting can ensure real equivalents. Offsets should not be agreed on a numerical one to one basis.
  • Develop and monitor a programme of biodiversity outcomes funded through SRDP such that sustainable economic growth promotes biodiversity.
  • Ensure future SRDP spending achieves measured improvements in biodiversity.

3.34 Other comments made by a few respondents on the Strategy were:

  • It should recognise the long time work of land owners to provide services for the public at their own expense, and it should promote all forms of land management which deliver ecosystem services in a balanced manner, together with promoting conservation education to landowners.
  • A stronger message for planning authorities on the importance of natural resources should be included.
  • The importance of the natural capital value of their specialist area, for example, cycling's contribution to reducing carbon emissions, farmed and cultivated biodiversity.


Email: Biodiversity Strategy Team

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