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.


Q4a) Does chapter 4 propose the right approach to reach the outcome that the special value and international importance of Scotland's nature is assured, wildlife is flourishing, and we have a highly effective network of protected places?

Q4b) What additional steps can you propose, including things that you, or your organisation, can do?

The special value and international importance of Scotland's nature is assured, wildlife is flourishing, and we have a highly effective network of protected places.

Key steps
Ensure management of protected places provides diverse public benefits.

Align habitat restoration on protected areas with national goals for improving ecosystem health, with local priorities determined at the catchment or landscape scale.

Integrate protected areas policy with action for wider habitats to combat fragmentation and restore key habitats.

Develop a wildlife management framework to address the key priorities for sustainable management, conservation and conflict issues, including reintroductions and invasive non-native species.

Involve many more people in this work and in improving our understanding of the poorly known elements of nature and its role in sustaining life.

The responses

5.1 Sixty three respondents commented on question 4a, whilst 60 respondents commented on question 4b. The majority did not provide a clear indication of whether they agreed or disagreed with the approach. Around a third of respondents did express agreement in full or broad terms for the approach, but most of those did state qualifications to this or areas they felt required strengthening. A few respondents indicated an overall disagreement with the approach.

Action for habitats and protected places

Ecological networks versus individual habitat and species protection

5.2 Many respondents commented on issues related to the spectrum of connectivity - from ecological networks to individual habitat and species protection. Most of these respondents seemed to prefer an approach which aims to protect individual habitats and/or species within the wider context of an ecosystem approach.

5.3 A number of respondents stated that current thinking about protected designations is outdated insofar as it places boundaries around habitats and species, considering them in isolation from wider ecological networks. Several other respondents expressed concern that a focus on protected habitats and species may risk diverting attention from those which are not protected but are no less valuable. Several of these respondents expressed concern that the perceived value to humans of certain habitats or species may come at the expense of protecting others. For example, one of these respondents argued that not all places are suitable for the public benefits described in chapter four of the Strategy but this does not mean they are less important and indeed may need more protecting for this reason. Similarly, a few respondents mentioned that because people are often more familiar with some species than others, this may adversely affect those which are lesser known. Another respondent argued that an approach which focuses on designated sites loses sight of the wider (mostly cultivated) countryside.

5.4 On the other hand, several respondents cautioned that an integrated approach (however valuable) may come at the expense of individual habitats and species. One respondent was alarmed by the chapter's absence of a key step on species action, arguing that the Strategy needs to include a targeted species management programme.

Local Biodiversity Action Plans

5.5 Several respondents commented on existing local biodiversity work. A few respondents stated that in the identification of priority habitats and species, the Strategy ignores the work of LBAPs which have already done that. They and a few other respondents suggested these and other resources, information and expertise (for example, Local Records Centres, the National Biodiversity Network) be recognised and built upon. Another respondent asked, with the chapter's emphasis on national protected sites, where LBAPs should fit in. They also noted that catchment-scale and local priorities 'cannot be the same'.

Locally designated sites

5.6 Several respondents expressed disappointment or concern regarding the Strategy's lack of reference to the role of Local Nature Conservation Sites (for example, Sites of Importance for Nature Conservation, Community Wildlife Sites). A few of these local authority respondents noted that such sites are often overlooked by national and international designations despite having particular value locally.


5.7 Several respondents commented on and supported the chapter's references to geodiversity (paragraphs 4.3.7 and 4.3.9). Most of these however argued that the Strategy needed to go further in explaining how geodiversity will be better understood, considered in land management and integrated into thinking about biodiversity. A couple of the respondents who commented on geodiversity described it as the foundation of biodiversity and the baseline of an ecosystem. A few other respondents cited examples of their own efforts working on geodiversity.

Investment requirements

5.8 Several respondents commented on the assertion in paragraph 4.3.8 that 'With a core area of green infrastructure already in place, relatively little investment is needed to restore many natural systems back to full capacity.' One respondent stated they were not comfortable with this statement, another stated it is not clear and a few others disagreed with it. Of those who commented on paragraph 4.3.8, one respondent argued that it underestimates the conservation task at hand, while another respondent requested to see the evidence which supports paragraph 4.3.8.

Inconsistency of figures

5.9 Several respondents commented on the proposal in paragraph 4.3.9 to 'conserve at least 17 per cent of land and inland water'. Most of these respondents highlighted the inconsistency between the 17 per cent figure in paragraph 4.3.9 compared to that of paragraph 4.3.4 which states 'Nature conservation sites cover about 18 per cent of Scotland's land area.' A few of these respondents requested clarification on these figures, whilst a few others argued that the Strategy's aim should be to increase (and not decrease) conservation areas and that this goal should be more ambitious. One respondent cited Aichi Target 11 which states a figure of 17 per cent.

Action for wildlife

Intrinsic importance of nature

5.10 A number of respondents commented on the statement in paragraph 4.4.1 that 'there are also compelling reasons for maintaining and restoring the diversity of wildlife in its own right'. All of these respondents supported this statement and the principle of acknowledging the intrinsic value of nature. However, most of these respondents noted that this statement appears (too) late and only once in the Strategy. They recommended it be made a focal issue, with one respondent suggesting it should be one of the key statements at the end of the chapter. Another respondent argued that if the intrinsic importance of nature is not prioritised in this Strategy, other policy areas are unlikely to take this message onboard.

5.11 A few of the respondents who commented on 4.4.1 expressed worry that it represents the Strategy's 'best attempt' at defining the intrinsic value of biodiversity and that it encapsulates the Strategy's underlying focus on the benefits which can be derived from nature, rather than nature itself. Another respondent described the inclusion of paragraph 4.4.1 as especially important given the economic focus of the Strategy.

Scottish Biodiversity List

5.12 Many respondents commented on the Scottish Biodiversity List and around half of these supported the Strategy's proposal to shorten the list (paragraph 4.4.7). Most of these supported it outright, although a few did so with qualifications.

5.13 Of those who qualified their support, a few stated that a shortened list must ensure overall ecosystem benefits and that species need to be considered in a broad context. A few others meanwhile cautioned against the shortened list simply containing charismatic and relatively better known or understood species. Several respondents argued that the process of preparing this list needs to be flexible and ongoing in order to take into account new knowledge about ecosystems and previously unknown or less understood species. It should also be based on science rather than funding. One respondent thought a list of Scottish Priority Habitats should be developed in partnership with stakeholders, to aid the prioritization of resource allocation including SRDP funds.

5.14 Of all the respondents who commented on the Scottish Biodiversity List, several expressed concern or questioned the reasoning behind what they termed an a priori aim or supposition to shorten the list. A few of these respondents connected the shortening of the list with funding. They noted that although resource constraints may limit action, they should not dictate which species actually make the list, that being on the list helps to keep species in the spotlight and thus a reduced list may be interpreted as a reduced commitment to conservation. Another respondent argued that rather than propose to shorten the Scottish Biodiversity List, the Strategy should instead propose to make more funding available.

Wildlife Management Framework

5.15 Several respondents commented on the Wildlife Management Framework, around half of whom suggested the need for it to be developed or implemented with the engagement of different stakeholders. One respondent, for example, suggested it should be informed by the expertise of NGOs, volunteers and researchers, whilst another respondent noted it should not be a burden on land managers and another asked if there would be a consultation on the Wildlife Management Framework. A few others supported the framework outright.

5.16 In more general terms, a few third sector respondents felt that wildlife management was not adequately covered within the Strategy and that the use of the term 'Wildlife Management Framework' is limited to the control of species and does not cover all species groups. Furthermore, it does not include acting to ensure sustainable species populations, nor achieving sustainable ecosystem management for the future.

Species reintroductions

5.17 Several respondents offered diverse comments on the Strategy's proposed Code for Species reintroductions. One respondent agreed outright that such a code would be useful. A few respondents qualified their support by suggesting the development of such a code take into account the views of different stakeholders, including land managers. Of these, one respondent expressed significant concern that land managers had not been properly compensated for reintroductions and noted that further reintroductions are not supported. Another respondent suggested the need for a research agenda on species reintroductions.

Invasive Non-Native Species

5.18 A number of respondents provided diverse comments on the subject of Invasive Non-Native Species (INNS), several of whom expressed support of the Strategy's proposal to implement new INNS legislation and to develop a catchment-based approach to control INNS. A few of those who commented on INNS emphasised the importance of taking a prevention-based approach, while a few others noted that effectiveness will depend on adequate resources. One respondent strongly emphasised the need for early consultation on management of INNS in or near public water supply. Another respondent suggested consideration be given to the difficulty in transferring rural INNS approaches to urban settings with highly fragmented landownership, as well as to make clear the risk posed by each invasive species to native biodiversity.

Involving people


5.19 The subject of volunteers was mentioned by a number of respondents, all of whom agreed with the value of volunteer work and the importance of recognising it. Additional comments made by these respondents were diverse. One respondent believed there is a volunteer skills gap in the UK (for example, knowing how to monitor and gather data) and argued it is vital that the government address it with training and funding, including bursaries for underrepresented groups. Another pointed out the funding requirements of training volunteers. A concern that the Strategy's economic and utilitarian focus may result in volunteers feeling limited ownership of it, as it does not align with their motivation for volunteering, was another issue raised. Respondents suggested volunteer engagement as another reason for the Strategy to increase its emphasis on the intrinsic value of biodiversity. A few respondents did not think the Strategy goes far enough to recognise volunteering, with one respondent noting that despite a general recognition of volunteers, the Strategy does not actually make reference to their body of work.

Land Owners

5.20 A number of respondents commented on the importance of engaging with and taking into account the interests of land owners. These respondents mentioned different aspects of conservation programmes that should be developed with land ownership in mind, for example, funding schemes, designated sites, ecological networks, Wildlife Management Framework, species reintroduction and other government policies.

Other comments

5.21 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 and the approach outlined in this chapter including: geodiversity; engaging the public; 'Living Landscape projects'; data collection and recording; improving water quality, UNESCO biosphere status; a range of work on INNS.
  • Examples of partnership working, including offers to help the Scottish Government on: hosting modern apprenticeships; sharing existing spatial planning tools; research in a number of areas (protected areas, the role of local management in global processes such as climate change, quantification of biodiversity and land management scenarios).
  • Networks of volunteers and an interest in expanding these.
  • Incorporating the Strategy's objectives into their policy and management plans.

5.22 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.

  • Review the protected areas series for completeness and fitness for purpose, making amendments of designations as appropriate.
  • Achieve favourable condition of all protected sites that occur there.
  • Align habitat restoration outwith protected areas with national goals for improving ecosystem health, with local priorities determined at the catchment or landscape scale.
  • Develop a sustainable ecosystem stewardship framework that builds a future for Scotland's rare and threatened species.
  • Assess the success of the voluntary approach to sustainable deer management by 2020 and bring forward amended legislation if required.
  • Restore biodiversity in the intensively farmed and forested landscape, measured using an index of abundance of priority farmland species.
  • Ensure no net loss of important marine or terrestrial wildlife.
  • Maintain the biodiversity value of High Nature Value Farming and Forestry.
  • Eradicate rhododendron from Natura sites and prevent invasion by known damaging non-native invasive species into any uninvaded catchments.
  • Establish early warning and rapid response capacity for damaging invasive non-native species.
  • Address the drivers of change that are resulting in the loss of plant diversity in all habitats in Scotland, as measured in the UK Countryside Survey.

5.23 Other issues highlighted by a few respondents were:

  • Concern about possible implications of seeking diverse public benefits in protected areas, particularly in key and/or sensitive areas for biodiversity. Appropriateness should be assessed on a site by site basis.
  • The need for the chapter to explicitly recognise farmed and cultivated biodiversity and associated genetic diversity.
  • The belief that environmental designations lead to negative socio-economic impacts and thus disagreement with any additional designations.
  • The National Ecological Network (NEN) deserving more recognition and adequate resourcing.
  • The importance of training and development for professionals.


Email: Biodiversity Strategy Team

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