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.


Q3a) Does chapter 3 propose the right approach to reach the outcome of improved health and quality of life for the people of Scotland, through investment in the care of green space, nature and landscapes?

Q3b) What additional steps can you propose, including things that you, or your organisation, can do?

Improved health and quality of life for the people of Scotland, through investment in the care of green space, nature and landscapes.

Key steps
Provide opportunities for everyone to regularly experience and enjoy nature, with a particular focus on disadvantaged groups, school children, and young and older people.

Work with the National Health Service to develop initiatives that will improve health and well-being through physical activity connected with nature.

Support local authorities and communities to improve local environments, using green space and green networks, allowing nature to flourish and so enhancing the quality of life for people who live there.

Encourage public organisations and businesses to review their responsibilities and action for biodiversity, and recognise that increasing their positive contribution to nature and landscapes can help them to better meet their corporate priorities and performance.

The responses

4.1 Sixty one respondents commented on question 3a, whilst 57 respondents commented on question 3b. Just over half of the respondents supported the overall approach proposed either in principle or in broad terms. Most of those who voiced general support did however state qualifications to this or areas they felt required strengthening. Just under half of the respondents provided comments but did not give clear indication of whether they agreed or disagreed with the approach. A few respondents indicated a disagreement with the approach.

Biodiversity and health

4.2 A number of respondents commented on the overall emphasis of chapter three. These respondents felt that the chapter's emphasis on human health loses sight of the health of biodiversity. A few respondents remarked that the chapter makes either little or no direct reference to biodiversity itself. Several respondents described the chapter as misleading or confused because biodiversity is not considered on equal terms with social welfare, with a few describing it as a secondary consideration. Illustrating this point, one respondent commented on paragraph 3.6.1 suggesting that the NHS estate could also be used to enhance biodiversity (i.e. not just to enhance health). A few others thought that, although important, societal welfare objectives should flow from the strategy and be represented as value added, rather than being the motivating force of the chapter. One respondent added that the chapter (and the Strategy as a whole) pegs the value of biodiversity to benefits achieved in other sectors. A few respondents asked what the chapter's implications are for biodiversity.

4.3 In this context, a few respondents commented specifically on the key steps, noting that only the third key step directly addresses the intended outcome to improve health and quality of life as a result of investment in biodiversity. They suggested the key steps be reworded to focus on biodiversity and not people or health. A few respondents argued that the people-based focus of the key messages from the chapter (paragraph 3.9) ignores the work of organisations to conserve biodiversity in its own right.

Green spaces

4.4 Several respondents argued that green spaces and biodiversity are not synonymous, that biodiversity is what is important, not green space per se. These respondents argued that this distinction should be made clear in the Strategy. A few respondents pointed out that green spaces which are attractive to people (for example, mown lawns) are not necessarily the richest in biodiversity. To illustrate this point, one of these respondents quoted the distinction made on the SNH website between green networks (whose aim is to improve the environment for people) and habitat networks (whose aim is to improve biodiversity). Another respondent suggested the need to better understand what 'quality' green space means and offered to share their own research. This found that quality green spaces are more complex than simply 'green' and include opportunities to observe animals, water, different plants, etc.

Links between green space and health

4.5 A few respondents commented on the need to draw out and explain the implicit assumptions which connect green spaces and/or biodiversity to health. One respondent argued that although the chapter says a great deal about the potential health benefits resulting from green space and biodiversity, it does not explain how these health benefits can be achieved.

4.6 Within this context, several respondents commented on the management of green spaces and health. It was noted that although better management of these spaces is possible, this alone will not correspond with improved health. The latter will be more difficult to achieve as it requires behaviour change.

Green space management

4.7 A few other respondents commented more generally on the management of green spaces, stating the view that the Strategy needs to place more emphasis on the maintenance of green spaces. For example, one respondent noted the lack of detail regarding the responsibility of the public when accessing green spaces, as well as the steps authorities should take to minimise the impacts of irresponsible access (for example, dog fouling, wildlife disturbance). Similarly, a few respondents highlighted the importance of urban green spaces, with one respondent stating that a lack of their maintenance may result in rapid deterioration and unwelcoming, unsafe and anti-social areas.

Nature is for everyone

4.8 Several respondents expressed support of the notion that nature is for everyone. These respondents also noted the importance of developing such opportunities for disadvantaged groups, with one respondent noting that the Strategy does not mention how this will be done. This same respondent argued that by concentrating its attention on the hospitalised and on children (i.e. schools and the NHS), the Strategy does not address the wider population.

Education and biodiversity

Raising public awareness of biodiversity

4.9 Several respondents expressed support of the need to raise public awareness of biodiversity. These respondents specifically supported biodiversity education in schools, with a few suggesting that it be expanded or mainstreamed into formal education. One respondent stressed the importance of this process starting as early as possible with very young children. Another respondent noted that an additional benefit of connecting people with nature is an awareness of possible career paths or job types and the attraction of new entrants into the field.

Outdoor learning

4.10 Several respondents provided diverse comments on the topic of outdoor learning, although all of them agreed on its importance. A few respondents welcomed its recognition in the Strategy, whilst a few others felt it deserved more emphasis. Specific issues raised by individual respondents included: the Strategy does not provide any indication of how outdoor learning will be established in the new curriculum; the need to identify and address health and safety policies which may be restricting use of the outdoors for education; that the number of outdoor classes be monitored in order to establish a baseline and targets; and disagreement with the Strategy's statement that outdoor learning is a 'key aspect of school inspections' (paragraph 3.7.1), arguing that most schools would not be asked about their outdoor learning in an inspection.

4.11 A few respondents suggested the need for essential skills training on outdoor learning. One respondent added that such professional development should be available not just for teachers, but also for others working with children (for example, health visitors and midwives). Another respondent suggested the need for outdoor learning to be a part of obtaining qualified teaching status and for outdoor learning accreditation of other providers.

4.12 A few respondents recommended that the Strategy cite more examples of outdoor learning, including the Real World Learning Scotland Partnership and the Natural Childhood report by the National Trust. A few respondents specifically cited SNH's Teaching in Nature demonstration project, with one respondent cautioning against its primary reference in the Strategy, whilst another argued this project should be expanded.

4.13 The importance of school grounds, which for many children is the main outdoor space they have (regular) access to, was stressed by one respondent. It was argued that giving every child in Scotland access to nature in their school grounds is perhaps the most important thing that can be done to build appreciation of nature across Scotland. Although welcoming of the Strategy's recognition of school grounds, the respondent felt that the Strategy did not fully reflect their significance.

Joined-up thinking and collaboration

4.14 A number of respondents agreed with the importance of joined-up thinking across sectors, institutional scales and government departments. For example, one respondent welcomed the Strategy's intention to work with the NHS but suggested this be extended to include voluntary and community sector organisations. Another respondent suggested the need for the Strategy to be a shared agenda that is perceived as open to those outside of the traditional environmental arena.

4.15 Several respondents commented on the value of local work, with some noting the importance of collaboration across local and national scales, with one respondent describing much local work as very valuable but often patchy and therefore in need of integration in order to reap greater overall gains. Another respondent suggested that the Strategy give prominence to Community Planning Partnerships and the local initiatives of NGOs and Local Biodiversity Partnerships, which are vital to achieving the chapter's outcome. Another respondent suggested that the Strategy more strongly emphasise the important role of local authorities, while another argued that policies should work to encourage local authorities to conserve and enhance the 3,000 existing local biodiversity sites.

4.16 More specifically, several respondents highlighted the synergies between this chapter and other work happening at national and local government levels such as: the draft policy on architecture and place-making; Healthy Working Lives; Community Empowerment and Renewal Bill; Single Outcome Agreements; Community Planning and Health Partnerships; Joint Health Improvement Plans; Physical Activity Strategies; Designing Streets; School Estate Management Plans. Another respondent suggested that the Scottish Government's Biodiversity Team collaborate with the Built Environment Team, School Infrastructure Unit and Early Years Team.

Business and industry

4.17 A few respondents commented on the role of business and industry. One of these respondents suggested that one of the key steps should include ensuring the built environment sector recognises the importance of designing green spaces. Other respondents suggested that the Strategy should indicate how businesses will be encouraged to implement such initiatives as those proposed in paragraph 3.6.2 (projects focusing on physical activity and mental health issues).


4.18 A few respondents commented on the subject of volunteering. Issues highlighted included: opportunities for volunteering are limited by reduced funding; the significant training needs of volunteers, therefore volunteering should supplement, rather than substitute for, paid professional employees; and listing shooting/game management alongside environmental volunteering within the Strategy.

Funding and resources

4.19 A number of respondents commented on the importance of funding, several of whom spoke of limited or diminishing resources and the constraints they impose on delivery. Respondents noted that the chapter does not specify how funding may be increased or where it will come from, whilst a few others asked for more financial support, including one who suggested SRDP reform.

4.20 A few respondents noted the connection between use of resources and joined-up thinking (or lack thereof). For example, one respondent pointed out that although more connection with the natural environment may indeed reduce NHS costs, other costs, such as the development and maintenance of green space needs to be faced. A further issue raised was the disconnect between the Strategy's stated good intentions and the cutbacks made to Ranger Services, which one respondent described as key players in delivering chapter three's aims. Another respondent advocated investment in ongoing maintenance, as opposed to capital projects.

Biodiversity as prevention

4.21 Several respondents commented on the preventative value of biodiversity, either generally or in reference to paragraph 3.9 and the case for investing in nature close to where people live and work. For example, one respondent suggested that the NHS recognise biodiversity as preventative, as well as curative, and another that the NHS should acknowledge that NHS grounds are as important an asset to health as other forms of patient care, with a return on investment potential that is disproportionately high.

4.22 Several respondents commented specifically on paragraph 3.9's statement that 'There is a strong case for investing more in nature close to where people live and work as this can deliver a clear reduction in health spend'. One respondent agreed with this statement outright, while another was concerned about it and suggested research on the matter. The UK NEA was recommended by another respondent for demonstrating the link between proximity to nature and human health and property value. Another respondent argued that investing in such areas should not come at the expense of focusing on ecosystem health and landscape or catchment scales.

Demonstration projects

4.23 Several respondents commented on the topic of demonstration projects. A few of these respondents pointed out that although the chapter proposes demonstration projects, many such small scale projects are already delivering and could be expanded with enough resources. Teaching in Nature was one specific demonstration projects that was suggested, together with the NHS running demonstration projects supervised by a task force.

Overarching comments


4.24 A number of respondents felt that more detail is required in the chapter, mainly in terms of what is being proposed and how to deliver it. For example, several respondents described the chapter as vague or unclear and argued the need for an explicit statement or definition of the desired state. Several respondents also suggested a greater emphasis be placed on how delivery and action will be achieved. One respondent suggested that case studies would be helpful to explain how outcomes might be achieved in practice.

Urban and rural issues

4.25 Several respondents made comments in relation to areas being urban or rural. A few respondents felt that the chapter is more relevant to urban areas. One respondent noted a policy implication of recognising the connection between green spaces and human health - a major shift in environmental investment from remote and sparsely-populated areas to those of high population density - and that this is lacking from the Strategy. Another respondent meanwhile suggested that rural health inequalities must be taken into account, including access and provision to amenities.

Scottish Biodiversity Duty

4.26 The Scottish Biodiversity Duty was raised by a few respondents who pointed out that although the Strategy refers to it on numerous occasions, the duty is not actually enforced. It was therefore argued that using it as a means to deliver wider benefits seems risky. One of these respondents suggested there should be a requirement for public bodies to report on the implementation of their Biodiversity Duty.

Specialist knowledge

4.27 Several respondents cited their area of specialist knowledge and how it relates to chapter three. A few respondents noted that the Strategy should recognise that Scotland's green spaces and landscapes include farmed and cultivated genetic biodiversity. One of these respondents pointed out the link between agricultural biodiversity and the supply of healthy food. A few other respondents highlighted the ways in which their interests connect people with nature and/or help promote and protect green spaces. These included cycling, shooting and woodlands.

Other comments

4.28 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 this chapter, including offering education programmes and raising public awareness about biodiversity, enhancing green spaces and NHS sites, working in partnerships.
  • Enthusiasm to work in partnership with the Scottish Government or others, including by sharing knowledge on their area of expertise or requesting the knowledge/expertise of others in order to help advance initiatives. This included: expertise offered from a herpetological perspective; guidance sought for proposed work on grounds of schools and churches; interest in expanding an outdoor learning project from England and Wales to Scotland.
  • Incorporating the Strategy's objectives into policy and management plans.

4.29 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. Three third sector respondents provided the same additional and alternative key steps, which are listed below, retaining only a reworded version of the third key step from the Strategy. These respondents also stated that public lead bodies required to be identified for each habitat type and for each key step, alongside appropriate and adequate resources.

  • Focus investment in the stewardship and enjoyment of nature and landscapes.
  • Ensure everyone has access to green space local to where they live and work.
  • Ensure wild land and wild places are protected such that people can view and experience areas where natural processes prevail.
  • Provide opportunities for everyone to regularly experience and enjoy nature. Biodiversity is there for everyone and not just selected groups.
  • Ensure the NHS integrates knowledge and enjoyment of biodiversity into specific programmes with regard to health promotion, aiming to improve health and well-being through physical activity connected with nature.
  • Ensure biodiversity is included in the preventative spending agenda.
  • Build on Scotland's culture and the value it puts on our environment to ensure future generations continue to be inspired.

4.30 Other comments made by a few respondents included:

  • A suggestion to promote the often under-utilised 'right to countryside'.
  • A correction in paragraph 3.4.2, that the Central Scotland Green Network has already been established.


Email: Biodiversity Strategy Team

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