Draft Environment Strategy: consultation analysis

3. Tackling climate change and restoring the health of the natural environment

This chapter presents an analysis of responses to Q4, Q5 and Q6. These three questions explored respondents’ views on the first four outcomes in the draft Strategy, which describe the Scottish Government’s goals for tackling climate change and restoring the health of our natural environment, in Scotland and overseas:

• Scotland’s biodiversity is restored and regenerated
• We have ended Scotland’s contribution to climate change
• We minimise pollution and waste in our environment
• Scotland’s global environmental impact is sustainable.

Outcomes on biodiversity, climate change and pollution

Q4. The pathways for the outcomes on biodiversity, climate change and pollution signpost to existing policies – how can we best address potential synergies and trade-offs across these outcomes? For example, how can we reduce greenhouse gas emissions in a way that also helps to restore biodiversity and minimise pollution?

Comments were provided in response to Q4 by 100 respondents. The themes identified for addressing potential synergies and trade-offs included governance and regulation, monitoring and reporting, land management, nature-based solutions, investment and planning, among others.

Governance, regulation and cross-sector coordination

Governance was the most frequently raised theme, with many respondents consistently arguing that effective management of synergies and trade-offs depends on stronger, better coordinated systems of decision-making. Many felt that the draft Strategy relies too heavily on existing policies that have not consistently delivered their intended outcomes, and therefore requires a more explicit governance architecture to drive integrated implementation. Some of the attendees of the environment consultation workshop suggested that an analysis of where existing policies were not delivering and identifying gaps would be needed to deliver the vision.

Respondents suggested that cross-sector coordination is particularly important across planning, agriculture, energy, marine management, transport and environmental agencies, and that siloed policy development has historically resulted in contradictory decisions, for example, tree planting on peat soils, renewables infrastructure affecting sensitive habitats, and agricultural policies operating separately from water and biodiversity goals. Some of the attendees of the environment and economy consultation workshops highlighted the need to identify areas where trade-offs and synergies exist. For example, the potential tension between climate change and environmental policy goals was identified as a cross-cutting issue for biodiversity, pollution, transport, and Scotland’s global impact.

Several respondents recommended establishing mechanisms for integrated governance that bring together multiple departments and regulators. Suggestions included cross-government review processes to ensure policy alignment, creating one comprehensive impact assessment framework to replace multiple existing assessments, and integrating environmental principles and duties into all major policy decisions. A few noted the need for stronger scrutiny by Parliament and independent bodies, alongside clearer monitoring roles for regulators and public bodies such as SEPA, NatureScot and Scottish Water.

Some respondents highlighted the importance of transparency around trade-offs. They felt that the draft Strategy should not only signpost synergies but should also openly identify areas where outcomes may conflict, and provide structured processes for resolving these tensions. Some respondents argued that without clear principles and accountability, environmental ambitions risk being undermined by competing economic pressures or inconsistent interpretation across agencies.

Measuring, monitoring and reporting

Many respondents emphasised that synergies across biodiversity, climate change, and pollution cannot be achieved without robust monitoring frameworks, consistent data, and clear responsibilities for reporting. Several noted that existing indicators do not adequately capture ecological condition, soil biodiversity, species recovery or the cumulative impacts of development. Two respondents argued that the draft Strategy should align its monitoring framework with the Public Bodies Climate Change Duties and provide explicit guidance for public bodies on reporting against integrated environmental outcomes.

A few respondents highlighted concerns about current gaps in evidence. For example, some felt there is limited monitoring of biodiversity gains delivered through planning, insufficient evaluation of peatland restoration quality, or weak tracking of pollution impacts on rivers and marine ecosystems. Some respondents also felt that monitoring systems should evaluate whole-life and lifecycle impacts to avoid optimising for one metric at the expense of others. Some respondents called for independent scrutiny mechanisms with the power to intervene when targets are not met, while a few noted that national targets must be supported by localised monitoring to reflect variation in ecosystem condition and ensure representation of islands and uplands.

Land management

Land management was highlighted as an area where synergies and trade-offs frequently arise, particularly in relation to forestry, agriculture, peatlands, and renewable energy development. Many respondents stressed the need for integrated spatial planning to ensure that interventions are located appropriately, avoid unintended harm and deliver multiple benefits where possible. Many respondents expressed concern that current land-use policies permit practices that undermine biodiversity and climate goals. Examples included commercial conifer plantations on carbon-rich soils, insufficient controls on invasive non-native conifers, and woodland creation that prioritises carbon sequestration over ecological value.

A few respondents also raised concerns about the scale and siting of renewable energy infrastructure, such as hydropower, onshore wind and transmission lines. Several argued that the draft Strategy must address contradictions in existing policy, such as supporting peatland restoration while continuing to sell peat. There was strong support for regenerative and nature-friendly approaches, including agroecology, whole-farm planning and spatial prioritisation. Some attendees of the economy consultation workshop highlighted the importance of the Land Use Strategy and suggested that it should be more prominent in the draft Strategy.

Nature-based solutions

Many respondents identified nature-based solutions as effective means of achieving synergies across environmental outcomes. Examples frequently cited included peatland restoration, native woodland expansion, wetland creation, riparian planting and species-rich grassland restoration. Respondents noted that these interventions can enhance biodiversity, support carbon sequestration, improve air and water quality, reduce flood risk and increase climate resilience. However, they stressed that nature-based solutions must be implemented carefully and should not result in inappropriate land-use changes. Some warned against monoculture afforestation, tree planting on high-value open habitats or reliance on private carbon markets.

Planning and consenting

Several respondents highlighted the importance of embedding integrated environmental objectives in planning and consenting systems. Many argued that planning currently treats biodiversity, climate and pollution separately, and called for clearer requirements to assess cumulative and cross-sectoral impacts. Several supported embedding natural capital accounting, biodiversity net gain and whole-life carbon assessment within planning policy.

Investment, capacity and support

Several respondents highlighted the need for sustained investment and adequate organisational capacity to deliver synergies across outcomes. They emphasised that regulators, local authorities and environmental bodies require stable funding and specialist expertise. Some urged investment in multi-benefit projects, domestic reprocessing infrastructure, research and innovation and skills development.

Community-led approaches

Several respondents stressed the importance of involving communities in environmental decision-making. Several argued that meaningful community ownership of land and resources can enable integrated land management and strengthen nature stewardship. A few cautioned against top-down decisions, especially in relation to large-scale land purchases and carbon projects.

Circular economy and sustainable consumption

Several respondents viewed circular economy principles as a pathway to achieving multiple outcomes by reducing waste, lowering resource extraction and minimising pollution. They highlighted the need for stronger producer responsibility, improved reprocessing infrastructure and adaptation to rural and island contexts.

Education, behaviour change and skills

Some respondents noted that environmental literacy, behaviour change and skills development will be important in supporting integrated outcomes. They observed that the education sector faces capacity constraints that could limit its ability to contribute unless additional support is provided. Some attendees of the environment consultation workshop suggested that having positive examples of the delivery of multiple benefits would be helpful. An example was scaling up ‘no-mow-May’ and using subsequent grass cuttings to generate bioenergy.

Marine environment

Some respondents highlighted the need to align marine planning, biodiversity strategies and climate objectives. They emphasised the importance of source-to-sea approaches, addressing invasive species and ensuring that marine renewable energy development does not harm ecosystems.

Other issues

A few respondents emphasised the interconnectedness of greenhouse gas reduction, pollution prevention and biodiversity restoration, arguing that reducing emissions remains fundamental to achieving outcomes across all areas.

Scotland’s global environmental impact is sustainable

Q5. What are the top priorities the Scottish Government should focus on to improve the environmental impact of Scotland’s activities on other countries? – For example, this could include the impacts of producing the goods and services we import into Scotland, our exports of waste and our approach to international engagement.

Among the 41 respondents who answered Q5, the most prevalent theme evident in comments was the role of supply chains, followed by topics such as exporting waste and the circular economy. It should, however, be noted that the examples provided in Q5 may have led respondents to focus more on these topics; therefore, other less prevalent themes should also be considered to the same degree.

Supply Chains

Many respondents emphasised the importance of ensuring sustainability, traceability and accountability in Scotland’s global supply chains. They highlighted that many of Scotland’s environmental impacts occur overseas due to the importation of goods such as timber, livestock feed, and food, which can result in deforestation, biodiversity loss, pollution, and labour exploitation in other countries. Several respondents emphasised the need to integrate sustainability principles throughout supply chains to minimise Scotland’s overall environmental impact globally.

Given this, several respondents often cited reducing reliance on imported high-impact commodities as a priority, particularly soya and maize for livestock feed. A few respondents called for investment in domestic industries, which they felt could reduce dependence on imports linked to ecological harm, strengthen local production, and create green jobs. Similarly, some respondents highlighted the need to localise production and consumption. This included supporting local farmers and producers, developing domestic processing infrastructure, and promoting circular approaches that enable by-products and waste to be recovered and reused within Scotland.

A recurring recommendation was for the Scottish Government to strengthen trade, procurement, and due diligence policies to ensure imported goods meet robust environmental and ethical standards. Aligning public procurement with Fair Trade and certified sustainability principles was also supported, with a few respondents highlighting the potential for Scotland to lead by example and improve transparency through frameworks such as the Public Bodies Climate Change Duties (PBCCD) reporting requirements.

Exported waste

The second most prevalent theme was the need to reduce Scotland’s waste exports. Several respondents noted that while Scotland does not have the necessary domestic capacity to process its own waste, increasing capacity would allow the Scottish economy to retain the value of waste, reprocess materials and could be supported through green public procurement. To implement this, a few respondents suggested that investment was needed to provide infrastructure within Scotland to increase recycling capacity.

One respondent highlighted that reducing waste exports is essential not only for maintaining control over how the waste is managed but also for mitigating the health risks and pollution that could be placed on more vulnerable communities. Some respondents expressed the view that if waste is to be managed within Scotland, more effort could be put into attempts to reduce waste. For example, incentives or public awareness campaigns may be implemented to promote a more sustainable approach to consumption among both consumers and producers.

A thriving circular economy and reducing overconsumption

Several respondents also felt strongly that implementing a circular economy was an important factor when considering how to reduce Scotland’s environmental impacts. A successful circular economy was perceived as having the potential to reduce waste, address Scotland's import deficit, and contribute to economic growth and public sector savings. It was also felt that a circular economy could: reduce Scotland’s reliance on imported raw materials and energy-intensive supply chains, thereby minimising extraction pressures; support local economic and social opportunities; and allow Scotland to focus on a wellbeing economy rather than one centred on growth and GDP.

Similarly, overconsumption was identified as a key driver of Scotland’s impact overseas, with respondents agreeing with the draft Strategy’s focus on food, textiles, and transition minerals, citing these sectors as having a high impact on other nations. For example, to reduce the impact of Scotland’s food consumption on other nations, plant-based dietary changes or increasing domestic feed production were suggested. A few respondents also noted the impact of Scotland’s overseas carbon and biodiversity footprint caused by overconsumption. Some respondents highlighted the more indirect impacts abroad, such as diffuse pollution, including PFAS in water systems.

However, to reduce overconsumption and create a stronger circular economy, many respondents called for the necessary societal shifts, which they also noted will take time.

International Collaboration

Another prevalent theme was the value of international collaboration and strengthening international partnerships. Several respondents called for more support for nations that may lack the necessary resources to mitigate and adapt to climate change, particularly additional funding or financing for sustainable practices such as nature-based solutions. A few respondents suggested that Scotland use its international investments and trade deals to reflect its environmental priorities and support resilience in developing nations. In addition, the role of international partnerships in increasing education, research and global innovation was also noted.

A small number of respondents suggested that the impact of Scotland’s actions could be increased by aligning with EU sustainability initiatives. However, one respondent focused on what they felt is lacking in the draft Strategy, highlighting how international trade provides a pathway for Invasive Non-Native Species, and thus a biosecurity strategy must be considered when discussing international partnerships.

International Environmental Justice

Several respondents highlighted the importance of recognising the impact of Scotland’s activities in the Global South. These respondents felt that attention should be given to the fact that nations that suffer the most from climate change tend to have contributed the least to its causes. It was also suggested that Scotland has a historical responsibility due to its colonial past and its impacts on inequality and uneven global development. A small number of respondents also expressed the view that emissions and waste cannot be outsourced to developing nations, and that Scotland must not exceed its resource use beyond what it can regenerate.

Justice in relation to the energy transition was also raised. For example, a few respondents highlighted how Scotland’s energy transition will have a greater impact on other nations due to the need for critical minerals and the impact of mining on biodiversity loss and potential human rights abuses abroad. Some suggested developing a statutory framework to assess the overseas impact of imported goods needed for the energy transition.

Measures and targets

Some respondents emphasised the need to develop stronger and more transparent measures to monitor Scotland’s global environmental impact. Several respondents called for national environmental accounting to include external footprints from imports and exports, providing a fuller picture of Scotland’s global impact.

Developing a clear framework for measurement and reporting was viewed as vital. Several respondents suggested aligning with international standards such as the Taskforce on Nature-related Financial Disclosures, Taskforce on Climate-related Financial Disclosures, and Science Based Targets to ensure consistency and accountability across sectors. It was also suggested that businesses disclose their environmental and social impacts in line with the Global Biodiversity Framework. Maintaining an up-to-date evidence base and transparent decision-making on trade-offs were seen as crucial for delivering and assessing progress toward a globally responsible economy.

Resource demand and environmental literacy

Another theme was the need to reduce demand, with improved education and awareness seen as central to achieving this goal. Using fewer resources at the outset was viewed as key to minimising emissions and pressures along global supply chains. Many respondents emphasised the need to strengthen environmental literacy to improve understanding of how personal consumption choices affect the wider world. Education, supported by effective communication strategies, was noted as crucial to enabling informed choices and encouraging more sustainable behaviours in areas such as food, clothing, and transport.

Incentives and clearer labelling were also called for to help consumers make responsible choices. A few respondents noted that reducing energy demand should be prioritised alongside renewable energy generation, and that shared mobility schemes such as car clubs can offer practical ways to reduce car ownership and resource use, particularly in rural areas.

Land Management

Some respondents emphasised the importance of promoting sustainable and regenerative land use to reduce reliance on imported commodities and enhance biodiversity, soil health, and carbon sequestration. Suggestions included supporting farmers in adopting nature-friendly practices and integrating invasive species management into land-use planning.

Less common themes

A few respondents raised additional considerations. These included calls for clearer definitions of terms such as “sustainability” and “climate justice”, warning against their misuse to justify policies that may conflict with Scotland’s domestic resilience. A few emphasised policy coherence and a “local-first” approach, ensuring fair trade and international engagement do not disadvantage Scottish workers or industries. Additional suggestions included banning open-net salmon farming, prohibiting imports of goods treated with chemicals banned in the UK, and strengthening cross-government coordination on environmental policy.

Q6. Do you have any further views on how the pathway outlined in the draft Strategy can help achieve the outcome “Scotland’s global environmental impact is sustainable”? Please explain your answer in the text box below.

Comments were made by 49 respondents at Q6. However, many of the points raised reiterated themes that were raised in response to Q5 and are described above. In addition to these themes, governance was frequently mentioned in responses to Q6, with respondents highlighting the need for stronger policy delivery, robust monitoring and accountability, improved policy coherence and leadership, clearer legal and regulatory frameworks, and increased investment.

Governance

Respondents consistently emphasised the need to transition from policy ambition to effective implementation. They felt this requires a clear investment and mitigation plan, underpinned by regulatory stability and long-term policy consistency that extends beyond electoral cycles. Effective implementation was viewed as dependent on embedding lifecycle thinking across all sectors to ensure that the environmental impacts of products and services are fully accounted for.

Monitoring, reporting and accountability

Another prominent theme was the need for robust and transparent monitoring to ensure accountability. Some respondents called for regular public reporting on Scotland’s overseas ecological, carbon and water footprints, alongside a national materials footprint baseline with sector-specific reduction targets. Embedding global impact indicators, such as embodied carbon and biodiversity footprints, within the draft Strategy’s monitoring framework was also considered essential. Several respondents also proposed mandatory due diligence for key commodities, enhanced tracking systems for imported goods, and full implementation of community wealth-building principles to localise supply chains.

Policy coherence

A few respondents emphasised that domestic agricultural, food, and trade policies must align with Scotland’s global environmental responsibilities and climate justice commitments. It was felt that policy coherence should extend to guidance on natural capital markets, stable land-use policy, and trade practices that support fair and ethical production. Stronger government leadership was also called for, including the courage to make difficult decisions, avoiding reliance on contested technologies, and upholding Scotland’s integrity in global climate action. Some attendees of the economy consultation workshop suggested that more could be done in detailing synergies in areas such as environment and health, linking explicitly to an existing health policy and detailing how synergies should work.

Regulatory frameworks

To ensure delivery, a few respondents advocated embedding enforceable mechanisms within the Strategy. These included legally binding waste and import-related emissions targets, mandatory supply-chain due diligence, producer responsibility schemes, and regular overseas impact audits. Adequate resourcing of regulators was also highlighted as crucial to maintaining credibility and ensuring compliance. Some attendees at the environment consultation workshop suggested that there should be stronger requirements for due diligence for businesses to improve supply chain sustainability.

Investment

Several respondents called for targeted investment to support sustainable land stewardship, domestic processing capacity, and competitiveness within international markets. Collaboration was also recognised as key, both across the UK and internationally. Respondents also noted the need for greater coordination among regions and institutions, as well as enhanced global partnerships in research, innovation, and knowledge exchange. Scottish universities and island communities were highlighted as important contributors to international learning networks, with the potential to share best practices and support sustainable development globally.

Less common themes

Two respondents also highlighted the importance of education and research in achieving a sustainable global impact. Universities were recognised for their role in developing international frameworks, driving innovation in circular economy practices, and embedding sustainability in teaching and research. These respondents felt that stronger support for universities would reinforce Scotland’s role as a responsible global citizen through collaboration and knowledge exchange.

Wider behaviour change was discussed through increased awareness campaigns, engagement of Scottish businesses in sustainability certifications, and support for ethical exports.

A few respondents also highlighted community-led land management as a way to promote sustainable land use and reduce reliance on carbon-intensive imports. For island and coastal communities, stronger marine litter prevention through Extended Producer Responsibility schemes was recommended.

Some attendees at the economy consultation workshop suggested that the Scottish Government should explore opportunities to consult with representatives from the Global South about unintended consequences in the draft Strategy.