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.


5a) Does chapter 5 propose the right approach to reach the outcome that nature is flourishing and ecosystems are resilient as a result of sustainable land and water management practices, and this is increasingly helping rural businesses and the economy to prosper?

5b) What additional steps can you propose, including things that you, or your organisation, can do?

Nature is flourishing and ecosystems are resilient as a result of sustainable land and water management practices, and this is increasingly helping rural businesses and the economy to prosper.

Key steps
Support and encourage an approach to land management that fosters sustainable use of land and water resources and puts biodiversity at the heart of integrated planning and decision making ('an ecosystem approach').

Ensure that measures implemented under Common Agricultural Policy reform encourage land managers to develop and retain a diversity of wildlife habitats and landscape features across all land use systems.

Support 'High Nature Value' farming and forestry systems.

Achieve and maintain good ecological status for all surface water bodies in Scotland, and higher ecological status for certain nature conservation sites.

Ensure that biodiversity and ecosystem objectives are fully integrated into Flood Risk Management Plans, prioritising restoration of wetland habitats and woodland to provide sustainable flood management.

Restore and expand the coverage of habitats that lock carbon in soil and vegetation, helping to mitigate climate change.

The responses

6.1 Fifty eight respondents commented on question 5a, whilst question 5b was addressed by 48 respondents. Around half expressed broad support for the overall approach. However, most of these respondents had further suggestions or areas they felt required strengthening. It was unclear whether the remaining half of respondents supported the overall approach, as they did not indicate clear agreement or disagreement.

6.2 Third sector respondents were more likely not to have expressed a clear view on whether they supported the overall approach outlined in chapter five, where as the majority of local authorities indicated broad support. Only one respondent expressed outright disagreement with the approach.

Overarching comments

6.3 A number of respondents commented in general on the content of the chapter. A few respondents thought chapter five repeated the content of previous chapters. Several respondents commented that many of the chapter's key steps were already covered by other policies, guidelines and regulations. They felt it was important for the Strategy and key steps to outline what is going to be different in the future. Others highlighted that there needed to be a more explicit reference to the existing policy landscape, including the Land Use Strategy and RBMPs.

Specific objectives, actions and targets

6.4 Several third and public sector respondents welcomed this chapter as the first to cover specific actions with targets. Others felt that the chapter required a stronger focus on identifying clear objectives, the actions required to achieve those objectives, who would take them forward and by when. The need for monitoring was also raised.

6.5 Alternative key steps were proposed by several respondents; these mainly consisted of amendments to those proposed in the Strategy, however others suggested inclusion of additional key steps. These additions are highlighted in the relevant section below.

6.6 A few respondents were more specific in their comments, for example, suggesting the inclusion of minimum targets with values within catchment management plans and/or ecosystem approach zone plans. Another respondent highlighted that people required sound planning principles in order to take positive action on the ground and would benefit from advice on this.

Quality and influences on biodiversity

6.7 Several respondents highlighted a discrepancy between a statement in chapter one which noted that biodiversity is declining and paragraph 5.1.3 which notes that ecosystems are in good condition. They asked whether the wrong things are being measured. One respondent questioned why the strategy is focused so heavily on ecosystem delivery instead of biodiversity decline. Related to this, a few respondents noted that the focus on ecosystem services risks devaluing biodiversity which does not provide a service or is not considered of high cultural value.

Ecosystem approach to land management

6.8 A number of respondents commented on this aspect of the Strategy. Whilst several respondents explicitly welcomed the proposed adaptive management approach, a few respondents noted that it should be trialled and monitored in practice with lessons feeding into wider environmental policy. Another respondent asked how the Scottish Government will ensure adaptive management happens in practice, including within the SRDP and legislation. Only one respondent expressed concern with the overall ecosystem approach, noting that it has yet to demonstrate itself as a means of delivering biodiversity.

Urban issues

6.9 Urban issues were highlighted by a number of respondents who felt that the strategy did not adequately address issues within urban areas, nor the link between rural and urban areas. A few local authorities noted that further thinking was necessary to ensure that the ecosystem approach to land use management worked in an urban context. One respondent noted that there are designated sites within urban areas that are under greater pressure than rural sites.

Conflicts over land use

6.10 A number of respondents commented specifically on the issue of conflicts over land use. A few third sector respondents were concerned that the Strategy is not explicit in its recognition of conflicting priorities. They requested a clearer vision on how to achieve a balance between the demand for land for productive agricultural purposes (which may have relatively low biodiversity value), and that which is prioritised for biodiversity (and therefore may have a low productive value in the traditional economic sense).

6.11 In relation to this, several respondents noted that the Strategy should be stronger on explicit means of resolving conflicts, with one respondent noting that they had made the same comments in relation to Scotland's Land Use Strategy and a few respondents specifically mentioned planning mechanisms. One respondent suggested that the Scottish Government should give clear direction to planners, developers and conservation bodies in order to identify priorities and avoid unnecessary delays or difficulties in the assessment of development proposals in sensitive areas. Another respondent suggested that there should be more delineation of land use priorities and funding to support this.


6.12 A number of respondents commented on funding for biodiversity, including around half of local authorities who commented specifically on the SRDP. Two respondents from the third sector stated that Scotland is one of the worst funded countries in the EU with respect to agri-environment schemes. These respondents and several others cautioned against relying on agri-environment/SRDP funding alone and stated that there was a need for other funding sources. A few respondents highlighted payment for defined ecosystem services such as natural flood management from those who benefit downstream.

SRDP and Common Agricultural Policy (CAP) reform

6.13 Several respondents explicitly stated their agreement with the SRDP as the main source of funding for biodiversity and highlighted its importance. One respondent noted that the Common Agricultural Policy (CAP) should move away from subsidies which do not deliver multiple benefits (i.e. in addition to food production), whilst another respondent explicitly disagreed with the 'greening' of the CAP.

6.14 Several respondents noted that the SRDP would need to simplified and targeted much more effectively if it was to deliver as the main funding source. Improvements could be made by publishing information on the sites where SRDP and other scheme funding had been made available, and introducing robust mechanisms to ensure that: (a) CAP reform proposals achieve measured improvements in biodiversity, (b) the SRDP does not have negative effects (for example, on grasslands and peatlands). This is in order to help overcome the voluntary nature of undertaking the 'correct' environmental measures, which a few respondents felt resulted in doubts over the SRDP's effectiveness. A few respondents also suggested improving the advice, guidance and monitoring provided to land managers on regulatory requirements and how to implement beneficial biodiversity steps under SRDP schemes.

High nature value farming and forestry

6.15 A number of respondents commented on farming and forestry, including specifically on high nature value (HNV) farming and forestry. Several respondents noted that there was insufficient detail on how this would be achieved and that guidance was required. In a similar vein, a few other respondents noted that HNV farming has not been properly addressed in recent land management funding and policy. Whilst supporting HNV farming and forestry, one respondent expressed concerns about further designation of land and potential impact on economic viability of productive land use.

6.16 Other comments related to: the need for the SRDP to identify croft land as distinct from other farmland; the need to support farmed and cultivated biodiversity, possibly by recognising it under HNV farming; that the presence of semi-native habitat alone as a descriptor of HNV farming was insufficient; priority areas for woodland restoration and expansion had not been identified; and expansion of woodland should not be to the detriment of other habitats or to economic growth. More generally on farming, it was noted that sustainable farming will require stronger links with non-public agencies (for example, the NFU).

Surface water bodies

6.17 Several respondents commented on the proposal to achieve and maintain good ecological status for all surface water bodies in Scotland. A few respondents felt that this was unrealistic and would incur excessive financial cost and economic penalties.

6.18 These same respondents felt that the interpretation of the Water Framework Directive (WFD) in the Strategy was factually incorrect and that it does allow for departing from 'good ecological status'. Another respondent noted their understanding that for certain species water quality of higher than good ecological status may be aspired to, but the need should be clearly demonstrated through scientific evidence. They also noted that diffuse pollution prevention measures within the catchment of the water body should also be considered. In a similar vein, another respondent noted that the connectivity of water bodies is not always well integrated within the WFD and that there should be an awareness raising campaign on the benefits from sustainable land and water management (for example, reduced nitrates in drinking water).

6.19 Two respondents felt that the Strategy did not pay enough attention to wetlands, particularly transition wetlands, and the role these played in international migratory flyways for birds. It was felt that the Strategy should also aim for good or high ecological status for wetlands.

Sustainable flood management

6.20 A number of respondents commented on sustainable flood management. A few local authorities explicitly stated their agreement with this approach, but suggested specifying who will take the lead on this and asked where the funding will come from. One council noted a number of barriers based on their own experience, including problems from land ownership and tenancy models and the unpredictability of land lost to flooding in any given year.

6.21 A few respondents expressed concern about agricultural land being taken out of productive use and its impact on landowners. One respondent suggested further research was needed. Two third sector respondents noted that a key step on sustainable flood management is to identify and promote a variety of demonstration sites.

Mitigation of climate change

6.22 A number of respondents commented on the proposal to restore and expand the coverage of habitats that lock carbon in soil and vegetation. Whilst supporting the restoration of 100,000 hectares of peatland, several questioned where the 100,000 figure had come from. One respondent argued that the target may be optimistic given that many of these areas coincide with prime areas for onshore renewables and because techniques for restoring peatlands are still in their infancy. Another respondent stated that the role played by managed grassland in carbon storage should be recognised, whilst another noted that the majority of proposed woodland planting should use native trees.

6.23 Two third sector respondents noted an additional key step: 'Forestry practice guidance from Forestry Commission Scotland (FCS) and SNH will protect shallow peatland habitats and wet heath, and be properly applied by FCS as regulator.'

Other comments

6.24 Many respondents, from all respondent types but particularly the public and third sectors, 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: the development of spatial planning tools to help deliver ecosystem outputs; integrating offset schemes into flood protection schemes; and practical experience in riparian management and woodland expansion.
  • Examples of partnership working, including offers to help the Scottish Government with: knowledge of the international scene; to help analyse unused data and/or provide data; and with thinking to address the chapter's gap on urban areas.
  • Incorporating the Strategy's objectives into policy and management plans.

6.25 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.

  • Require that at least 10% of all land holdings are in Ecological Focus Areas under new SRDP roll out.
  • Create 500 kilometres of natural tree line.
  • Deliver measurable improvements in wildlife habitats and landscape features across all land use systems.
  • Ensure that steps are taken to facilitate sustainable land management in drinking water catchments, to enhance habitat for biodiversity in addition to improving raw water quality.

6.26 Other issues highlighted by a few respondents were:

  • The need to explicitly recognise the role of farmed and cultivated biodiversity and to raise public awareness of its role in providing a range of public benefits, including the support of rural businesses.
  • The widespread effects of high deer populations as a key challenge, and suggesting a committee set sensible deer densities in line with the capacity of the environment. A further respondent noted that the deer code was not statutory and that the SRDP may need to be extended to incentivise upland managers, whilst another noted that if sensible deer densities were not achieved voluntarily within eight years, legally binding deer management plans should be established.
  • The need for an improved understanding of geological processes and better engagement between the geodiversity community, landowners and managers through the SRDP.
  • A call to protect the diversity of soils, including assessing soil regulation, and to raise awareness of this issue in all sectors.


Email: Biodiversity Strategy Team

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