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.


6a) Does chapter six propose the right approach to reach the outcome that Scotland's marine and coastal environments are clean, healthy, safe, productive and biologically diverse, meeting the long term needs of people and nature?

6b) What additional steps can you propose, including things that you, or your organisation, can do?

Scotland's marine and coastal environments are clean, healthy, safe, productive and biologically diverse, meeting the long term needs of people and nature.

Key steps
Adopt a Scottish Marine Plan to aid balanced decision-making in the marine environment.

Establish a coherent network of Marine Protected Areas, promoting sustainable use and conservation.

Collate information on the location and sensitivity of Priority Marine Features, and make this information available to support their protection.

Achieve Good Environmental Status for Scottish seas.

Bring Common Fisheries Policy fish stocks to levels consistent with Maximum Sustainable Yield wherever possible, and take account of biodiversity in managing inshore fisheries.

Implement a rapid-response framework to prevent colonisation of invasive new species in Scotland's seas and islands.

Improve the monitoring of the marine environment to identify changes there and guide progress towards the above objectives.

Improve understanding of how coastal ecosystems are likely to adapt to climate change and develop appropriate strategies for coastal zone management.

The responses

7.1 Forty three respondents commented on question 6a, whilst 30 respondents addressed question 6b. The majority supported the overall approach proposed either in full or in broad terms, but many stated caveats to this or gave further suggestions. Few respondents indicated an overall disagreement with the approach, mainly local authorities. In the main, these respondents felt that the approach was not sufficient to achieve the stated outcome. A number of other respondents provided comments but did not give clear indication of whether they agreed or disagreed with the approach.

Marine biodiversity and terrestrial ecosystems

7.2 Several respondents welcomed chapter six's specific focus on marine biodiversity and saw this as a timely inclusion in the wider Strategy. A small number explicitly welcomed the Strategy's attempt to join up land and coastal policy. However, several public sector and third sector respondents questioned the separate treatment of marine issues, arguing for the importance of recognising the interdependence of marine and terrestrial ecosystems. It was noted that marine aspects could have been integrated into earlier chapters of the Strategy. Several suggested that the chapter give greater recognition to gaps between land and marine policy in regards to the downstream effects of river quality on coastal and estuarine biodiversity. Others felt the chapter was too heavily weighted towards marine issues to the detriment of coastal and island ecosystems.

Existing policy commitments

7.3 Several respondents from across the public and third sectors noted that many of the key steps relate to existing legislative requirements and policy commitments. Some questioned what the Strategy adds above and beyond these. Although a small number noted that many issues are already being addressed following the Marine (Scotland) Act, one respondent stated concerns that the chapter gives the impression 'all is already in hand'. It was noted that care should be taken to ensure consistency between the terms and commitments of this Strategy and existing policies such as the Marine Nature Conservation Strategy 2010.

Actions and targets

7.4 A number of respondents supported in principle the key steps proposed. However, some suggested options for strengthening the key steps. A small number of respondents explicitly stated the view that although the key steps will contribute towards the stated outcome for marine and coastal biodiversity, they are not sufficient in and of themselves. Some respondents proposed alternative and additional key steps (see paragraph 7.17).

7.5 Several third sector respondents called for clear actions with associated targets and defined roles and responsibilities. One third sector stakeholder suggested greater emphasis on Aichi Targets within the chapter. Some respondents, notably local authorities, emphasised the importance of setting SMART goals and called for greater specificity, particularly with regards to key step five. However another local authority also praised the key steps for fulfilling SMART principles.

Protecting marine and coastal biodiversity

Marine Protected Areas designation

7.6 A number of respondents stated their support for the existing Marine Nature Conservation Strategy, the adoption of the National Marine Plan and protection of Priority Marine Features (PMFs) through the designation of Marine Protected Areas (MPAs). The importance of basing the latter designations on robust ecological design criteria to ensure a true ecosystem approach was noted.

7.7 A few of the respondents noted that Scotland's islands do, however, require special attention, with one island local authority strongly opposing designation of MPAs in their area on economic grounds. One public sector body suggested the need for an analysis of the value of MPAs through an integrated socio-economic appraisal of the ecosystem services provided. A few respondents suggested the need for further action to protect the wider marine biodiversity outwith MPAs.

Marine renewable energy generation

7.8 A few respondents (primarily local authorities) stated the view that the Strategy does not give enough consideration to the impact of marine renewables on biodiversity. Two respondents requested more support from government and its agencies for planning authorities to ensure the protection of PMFs. One respondent suggested that greater recognition be placed on the links between marine geodiversity and biodiversity to help to inform marine spatial planning.

Invasive non-native species

7.9 Those respondents who commented on the issue of invasive species voiced support for development of a rapid-response framework to prevent colonisation of new invasive species in Scotland's seas and islands. One public sector body argued for more emphasis on quarantining and preventing the arrival of invasive species. Another respondent felt that the Strategy fails to recognise the impact of terrestrial invasive species on marine biodiversity.

Sustainable fishing

7.10 A number of respondents commented on the issue of sustainable fishing and marine biodiversity. A few considered that the Strategy does not emphasise strongly enough the need to achieve a sustainable fishing industry.

7.11 Many of the comments focused on the use of the Maximum Sustainable Yield (MSY) concept. A few respondents questioned the effectiveness of the MSY model and opposed its inclusion in the Strategy. These respondents suggested research into indicators of marine ecosystem health as an alternative. Some noted that the MSY principle relates only to commercial fish species and suggested that as it does not take into consideration the wider impact on other marine species, it is inappropriate for measuring good practice in relation to biodiversity. However, several third sector organisations supported the MSY model but argued that the MSY should be an 'absolute upper limit' and not a target.

Adapting to climate change

7.12 Several respondents commented on issues around coastal adaptation to climate change and the threat of rising sea levels, voicing a range of different views. A few respondents stated support for key step eight, with some emphasising the need to integrate coastal zone and flood-risk management strategies, and take account of biodiversity objectives within these. Others suggested greater utilisation of the existing knowledge and expertise on coastal processes or a greater emphasis on interdisciplinary working on this issue within the science community.

7.13 A few respondents noted that coastal change should not necessarily be seen as a threat. On the other hand, two local authorities, felt that the Strategy does not give enough recognition to sensitivities around coastal change and the potential conflicts from loss of local land. Others objected to what they viewed as local areas being held responsible for climate change adaptation, noting that sea level rise is not caused at a local level. A few queried the extent to which funding will be made available for adaptation work.

Research and monitoring of marine and coastal biodiversity

7.14 Across stakeholder groups, there was support for improving the monitoring of Scotland's marine environment. However one respondent felt that the Strategy does not adequately reflect the significant amount of monitoring and research already underway. Other comments included the suggestion that the Scottish Government should take greater advantage of the opportunity the Strategy presents to explicitly set out the research agenda, and that data-sharing amongst parties involved in monitoring should be explicitly encouraged. Others pointed out the significant resource requirements of monitoring and requested more detail on how improvements would be achieved.

Involving stakeholders

7.15 Those respondents who commented on the Strategy's commitment to stakeholder and public engagement supported an inclusive approach. One third sector respondent argued for the inclusion of an additional key step to deliver a programme of awareness raising and education through on-site interpretation and guidance.

Other comments

7.16 Many respondents, particularly local authorities and other public bodies, noted ways in which they could, or already were, supporting the delivery of the Strategy in their own work. These included:

  • Incorporating objectives into policy and management plans, for example Marine Spatial Plans, Marine Site Management Plans; Biodiversity Action Plans.
  • Assisting with delivery through partnership working and joint projects.
  • Continuing commitment to stakeholder engagement on marine and coastal policy.
  • Improving the evidence base through research programmes.
  • Promoting public engagement with marine biodiversity by working with schools, community groups and businesses, and by developing resources and projects to facilitate engagement and education.

7.17 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, noted 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.

  • Recognise the role of, and protect, marine habitats such as kelp forests and sea grass beds that act as carbon sinks to help mitigate climate change impacts.
  • Achieve good ecological status of all coastal waters through the integrated and sustainable management of Scotland's river catchments.

7.18 Other issues highlighted by a few respondents were:

  • The importance of terrestrial habitats such as dune systems, heathland, and woodlands in mitigating coastal change. One respondent suggested including a commitment to restore dune and heath habitats.
  • The need to recognise farmed aquatic biodiversity and associated issues of genetic diversity in the Strategy.
  • A feeling that the Strategy is oriented towards charismatic species, and the need for greater recognition of other species and taxa including marine lichens.
  • A desire for increased local accountability and control in the management of pressures on the marine environment
  • A need for consistency in the use of terminology, such as using 'marine biodiversity' throughout and omitting references to 'maritime biodiversity', as well as resolving inconsistent references to the 'National Marine Plan' and 'Scottish Marine Plan'.


Email: Biodiversity Strategy Team

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