Consultation on the Draft Scottish Climate Change Adaption Programme: Analysis of Responses

5 Climate Ready Natural Environment

5.1 This chapter presents an analysis of respondents' views on the objectives, policies and proposals set out under the heading of a Climate Ready Natural Environment (the N theme). The N theme included three objectives:

• N1 - Understand the effects resulting from climate change and their impacts on the natural environment
• N2 - Support a healthy and diverse natural environment with the capacity to adapt
• N3 - Sustain and enhance the benefits, goods and services that the natural environment provides

5.2 The consultation asked five questions in relation to this theme:

Question 2a: Do objectives N1, N2 and N3 collectively set an appropriate long term direction to ensure that Scotland's natural environment is able to adapt to our changing climate?

Question 2b: To what extent will the policies and proposals listed under objective N1 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Question 2c: To what extent will the policies and proposals listed under objective N2 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Question 2d: To what extent will the policies and proposals listed under objective N3 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Question 2e: Taken together, do the policies and proposals listed under objectives N1, N2 and N3 address the current and predicted impacts to the natural environment in Scotland identified in the UK Climate Change Risk Assessment?

5.3 This chapter includes three sub-sections: the first will discuss respondents' comments to Question 2a; the second will present views about the policies and proposals under each objective (Questions 2b-2d); and the third will consider responses to Question 2e.

Do the objectives collectively set an appropriate long term direction (Q2a)

5.4 Forty-four (44) respondents answered Question 2a. Of these, 29 (66%) thought the objectives either "fully" or "mostly" set an appropriate long term direction for natural environment adaptation, while 15 (35%) thought they only "partially" or "poorly" did so. (Table 5.1.) The latter group included most of the non-governmental organisations (NGOs), six out of 20 local authorities and half of the education / research respondents.

Table 5.1: Question 2a - Do objectives N1, N2 and N3 collectively set an appropriate long term direction to ensure that Scotland's natural environment is able to adapt to our changing climate?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning					0
Education & research	1	1	2		4
Local authority & CPPs	4	10	5	1	20
NGOs		1	5		6
NHS or health-related	1	3			4
Other public bodies		4	1		5
Private sector		2			2
Transport	1				1
Individual respondents		1		1	2
Total	7	22	13	2	44
Total percentages	16%	50%	30%	5%	100%

* Percentages do not total 100% due to rounding.

5.5 Forty-one (41) respondents (61% of all respondents) provided further comment at Question 2a. Those who ticked "partially" or "poorly" in response to Question 2a generally made longer and more detailed comments than those who ticked "fully" or "mostly".

General comments

5.6 Those who endorsed the objectives described them as "suitable", "sensible" and "logical". The three objectives were seen to "provide a clear sense of direction" and the "multi-agency" approach taken in the N theme objectives was appreciated.

5.7 Those who were less supportive thought that the objectives failed to address some key issues entirely, or that they addressed them inadequately (as described below).

Perceived gaps and areas for development

5.8 The main issues, raised by a range of respondents, included:

• Need for action: Respondents expressed concern that the emphasis in the N objectives was more on "understanding impacts" and "raising awareness", and less on taking action. It was thought to be important to understand not only the impacts, but what drives them and what would help prevent them. There was concern that objective N1, in particular, could "be a recipe for inaction".
• Need for integration and a holistic approach: A range of respondents commented that they wanted to see better (or more explicit) integration between the N theme and the other two themes in the Programme. These respondents believed the natural environment can play a crucial role in helping Scotland's infrastructure and society to adapt to climate change impacts. Therefore, if action is taken to help the natural environment adapt, this will add value to other adaptation efforts.

Appropriateness of policies and proposals under each objective (Qs 2b-2d)

5.9 Questions 2b, 2c and 2d asked for respondents' views on the policies and proposals set out under objectives N1, N2 and N3 respectively. Tables 5.2, 5.3 and 5.4 on the following page show that around three-fifths of the 67 respondents answered each of these three questions:

• Of the 44 respondents who answered Question 2b, 27 (61%) thought that the policies and proposals under objective N1 either "fully" or "mostly" provided an appropriate lifetime focus for the Programme, while 17 (38%) thought they only "partially" or "poorly" did so.
• Of the 44 respondents who answered Question 2c, 32 (72%) thought that the policies and proposals under objective N2 were "fully" or "mostly" appropriate, while 12 (27%) thought they only "partially" or "poorly" did so.
• Of the 38 respondents who answered Question 2d, 26 (69%) thought that the policies and proposals under objective B3 were "fully" or "mostly appropriate, while 12 (31%) thought they only "partially" or "poorly" did so.

5.10 Across all three objectives, those who were less supportive included a majority of the NGO respondents and between a quarter and a third of the local authority respondents.

5.11 The number of respondents who made further comments at Questions 2b, 2c and 2d are shown below:

• 41 respondents (61% of the total 67) commented at Question 2b
• 43 respondents (64% of the total 67) commented at Question 2c
• 29 respondents (43% of the total 67) commented at Question 2d

General comments

5.12 Across all three objectives, respondents who endorsed the policies and proposals described them as "appropriate" and "comprehensive". The approach to understanding the potential impacts of climate change (in objective N1) was thought to provide a good foundation for future adaptation work. The policies and proposals under objective N2 were described as "holistic in their coverage" and well balanced between different aspects of the natural environment.

5.13 However, other respondents thought that some of the policies or proposals were "too vague". Respondents wanted to know how certain policies would assist adaptation. (The implementation of the Land Use Strategy (N2-8) and implementation of the EU reform of the Common Agricultural Policy (N3-1) were two examples.)

5.14 It was also suggested that the N theme could be strengthened by focusing more on positive measures to help adaptation, for example, by restoring and sustaining ecosystems and local habitat networks, rather than simply on understanding the risks or avoiding the impacts of climate change.

Table 5.2: Question 2b - To what extent will the policies and proposals listed under objective N1 provide an appropriate focus for the lifetime of the Programme?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research		1	3		4
Local authority & CPPs	1	12	5	1	19
NGOs		1	4		5
NHS or health-related		4			4
Other public bodies		4	1		5
Private sector		1	1		2
Transport		2			2
Individual respondents		1	1		2
Total	1	26	16	1	44
Total percentages	2%	59%	36%	2%	100%

* Percentages do not total 100% due to rounding.

Table 5.3: Question 2c - To what extent will the policies and proposals listed under objective N2 provide an appropriate focus for the lifetime of the Programme?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research		2	2		4
Local authority & CPPs	1	14	5		20
NGOs		1	4		5
NHS or health-related		4			4
Other public bodies		4			4
Private sector		2			2
Transport		2			2
Individual respondents		2			2
Total	1	31	12	0	44
Total percentages	2%	70%	27%	0%	100%

* Percentages do not total 100% due to rounding.

Table 5.4: Question 2d - To what extent will the policies and proposals listed under objective N3 provide an appropriate focus for the lifetime of the Programme

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning					0
Education & research		1	2		3
Local authority & CPPs	2	11	4	2	19
NGOs		1	3		4
NHS or health-related		4			4
Other public bodies		5			5
Private sector		1	1		2
Transport	1				1
Individual respondents					0
Total	3	23	10	2	38
Total percentages	8%	61%	26%	5%	100%

5.15 Respondents voiced support for the proposals listed under the three N objectives. Proposal N3-16 (Greater recognition of the role of integrated land management in tackling climate change), in particular, was welcomed by a range of respondents. Suggestions were made by different respondents about how the description of this proposal could be strengthened in the Programme:

• Make specific reference to the protection and restoration of peatlands given their importance in enhancing water quality and reducing flood risk.
• Require all new developments and regeneration schemes to make provision for allotments and growing spaces in proximity to housing.
• Provide further detail about the aims and expected outcomes of this proposal to distinguish it from the policy regarding the implementation of the Land Use Strategy (N2-8).
• Highlight the key role of farmers and land managers in delivering this work and make provision for building capacity within this group.

Perceived gaps and areas for development

5.16 Respondents identified a wide range of issues which they thought were missing from the Programme and which should be included. There were also suggestions for further development and requests for clarification in the Programme. Very detailed comments, including suggestions for changes to the wording of individual policies and proposals, were offered by different respondents. These comments cannot be adequately represented in this report but will be considered carefully by the Scottish Government in finalising the Programme.

5.17 The issues reported below were those that were identified by a range of different types of respondents.

5.18 Under objective N1 (understand the effects resulting from climate change and their impacts on the natural environment):

• Balance of policies: Several respondents thought that the policies under N1 appeared to place too much emphasis on marine and forestry environments, and not enough on other habitats. It was suggested that certain policies had (or should have) wider application to other types of habitats and ecosystems than what is described in the Programme. Respondents also advocated a more "rounded ecosystem-based approach" to understanding the impacts of climate change on the natural environment.
• Understanding the effects of climate change on coasts and peatlands: Respondents thought the risks of coastal erosion and the risk to peatlands were inadequately addressed in the policies and proposals under N1 (and indeed across the Programme). This was seen as a serious omission.
• Use of green space: Respondents wanted the Programme to incorporate research into the use of green space in supporting adaptation.
• Responsibility for delivery: Respondents made a wide range of suggestions for additional organisations and agencies that they thought should be involved in delivering particular policies. For example, Local Biodiversity Partnerships were often mentioned as key partners in the delivery of objective N1.
• Citizen Science: There was a general view that initiatives such as the policy to encourage citizen science and voluntary environmental monitoring (N1-9), should be acknowledged and supported. However, there were also some concerns raised about the range and quality of data that could be collected by volunteers, and that citizen science should not be seen as "a substitute for professional monitoring".
• Data issues: The issue of data quality was not only mentioned in relation to citizen science. It was emphasised that high-quality data was crucial to help in decision-making. For example, LiDAR (Light Detection And Ranging) was seen to be important for many aspects of data gathering along the coast and river corridors (in relation to N1-10), but funding constraints had prevented its widespread use.
• Other perceived gaps: Respondents identified further gaps in objective N1 in relation to freshwater ecosystems; drought and changing water demands; food security and organic farming; historic environment interests; and socio-economic consequences of climate change for businesses that use the natural environment.

5.19 Under objective N2 (support a healthy and diverse natural environment with the capacity to adapt), the following issues were raised by a range of respondents:

• Green networks: Respondents welcomed the reference to green networks in policy N2-2, but wanted greater emphasis on the role of green infrastructure in supporting a healthy and diverse natural environment. (This could include street trees, green roofs, allotments, wetlands and water features, etc.).
• Non-native invasive species: Respondents welcomed the policies on managing invasive non-native species (N2-7 and N2-16). However, it was pointed out that both these policies were now superseded by the "2020 Challenge for Scotland's Biodiversity".
• Land use planning: In addition to N2-8 (implement the Land Use Strategy), it was suggested that the Programme should refer to Strategic and Local Development Plans and development master-planning as key mechanisms for embedding adaptation into land use planning.
• Designated sites: Respondents thought that the focus in policies N2-3 and N2-4 on Natural Nature Reserves and designated sites respectively, was unnecessarily restrictive, and that adaptation measures should be applied wherever they are needed. In terms of policy N2-15 on marine designated areas, it was suggested that Marine Protected Areas (MPA) should be included.
• Habitat creation and protection: Respondents wanted to see more policies and / or proposals for habitat creation and protection, although it was also noted that an aim of the Scottish Biodiversity Strategy is to "restore and extend natural habitats". Some respondents suggested that the Scottish Government's existing policy on peatland restoration should be included in the Programme.

5.20 Under objective N3 (sustain and enhance the benefits, goods and services that the natural environment provides), the following issues were raised by a range of respondents:

• Balance of policies: A range of respondents commented that the policies under objective N3 were too narrowly focused on agriculture, forestry and fishing (described as "managed land"). Respondents wanted a more rounded approach to include urban green space, food growing, floodplains and upland moorland.
• Ecosystem approach / role of ecological services: Respondents emphasised that an ecosystem approach should be applied to guide adaptation for the natural environment. Respondents wanted to see policies that are aimed at protecting and restoring the natural environment so it is more resilient to climate change impacts and supports adaptation measures. Such measures could be linked to local authority planning and land-use policies (for example, by preventing development on floodplains; through infrastructure maintenance; and by using green space for carbon storage, heat reduction and water management).
• Common Agricultural Policy (CAP): Respondents commented that policy N3-1 (regarding implementation of the EU reform of the CAP) needed more development to identify which parts of the CAP would address the objective. It was suggested that this could draw out the measures which could promote organic farming, or improve resilience among farmers through co-operation on agri-environment schemes or water sharing arrangements.
• Fishing and aquaculture: A wide range of comments were made in relation to policies N3-11 to N3-15. There was a general view that policies for aquaculture should be separated from those for fishing, as these are different industries.

Extent to which the Programme addresses the risks identified in the UK CCRA (Q2e)

5.21 Forty-two (42) respondents answered Question 2e. Of these, 28 (66%) thought that the policies and proposals listed under the N theme either "fully" or "mostly" addressed the current and predicted future impacts to Scotland's natural environment identified in the UK CCRA, while 14 (33%) thought they only "partially" or "poorly" did so. (Table 5.5). The latter group included most of the non-governmental organisations (NGOs) and education / research organisations, and five out of 19 local authority respondents.

Table 5.5: Question 2e - Taken together, do the policies and proposals listed under objectives N1, N2 and N3 address the current and predicted impacts to the natural environment in Scotland identified in the UK Climate Change Risk Assessment?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research		1	3		4
Local authority & CPPs	1	13	4	1	19
NGOs		1	4		5
NHS or health-related		4			4
Other public bodies		5			5
Private sector		2			2
Transport		1			1
Individual respondents			1		1
Total	1	27	13	1	42
Total percentages	2%	64%	31%	2%	100%

* Percentages do not total 100% due to rounding.

5.22 Thirty-six (36) respondents (54% of all respondents) made comments in relation to Question 2e.

5.23 In general, respondents who commented at Question 2e referred back to, repeated or summarised comments they had made in response to one or more of Questions 2a-2d. Some identified additional gaps or areas for development in the N objectives, policies or proposals; however, only a few respondents explicitly linked their comments to the UK CCRA. Others appeared to use the space provided at Question 2e for more general comments or "any other comments" that they had not already mentioned in relation to Questions 2a-2d.

Perceived gaps or areas for development

5.24 In terms of perceived gaps between the Programme and the UK CCRA, respondents sometimes pointed out that there were certain issues that were not well covered in the CCRA, which they thought should nevertheless be included in the Programme. The three areas identified by a range of respondents were in relation to peatland conservation, coastal erosion and use of green infrastructure / green space.

5.25 Respondents identified a range of other risks to the natural environment which did not appear to them to be addressed in the Programme. Examples included:

• Risks to terrestrial systems other than forestry
• Biodiversity risks due to warmer rivers and lakes
• Changes in biodiversity reproductive habits
• Asynchrony between species breeding cycle and food supply
• Waterlogging
• Increase in prevalence of certain diseases
• Decline in marine water quality due to sewer outflows

5.26 However, it was not generally clear from the responses whether these were related to risks identified in the UK CCRA.