Environment Strategy for Scotland: strategic environmental assessment (SEA) post adoption statement

How opinions expressed on the consultation have been taken into account

Overview

Section 47 of the UK Withdrawal from the EU (Continuity) (Scotland) Act 2021 requires Scottish Ministers to prepare, consult on and publish an environmental policy strategy. The responses to the consultation have been crucial to informing the development of the final Environment Strategy.

In the process of completing the consultation, we have sought to ensure that those with an interest in, or who will be affected by, the Environment Strategy had the opportunity to present their views on the consultation documentation.

Public consultation

A public consultation was held from 3 July 2025 to 29 September 2025 to obtain the

opinion of public individuals and organisations on the draft Environment Strategy and the possible impact of the Strategy. Responses were sought on the consultation through the completion of a questionnaire hosted on the Scottish Government’s Consultation Hub, Citizen Space. The consultation questionnaire included a question on the SEA and asked respondents whether they had any views on whether there are likely to be any positive or negative environmental impacts from the draft Environment Strategy that have not been identified in the SEA.

The consultation documentation also included the Environmental Report

along with online links to a Partial Business Regulatory Impact Assessment, and draft versions of the Islands Communities Impact Assessment, Fairer Scotland Duty, Equality Impact Assessment, Child Rights and Wellbeing Impact Assessment and the Consumer Duty Impact Assessment. There were 126 responses submitted to the consultation from individuals and a wide range of organisations. A number of public engagement sessions were also held with stakeholders to discuss the draft Environment Strategy. The full analysis of the consultation can be found here.

Consultation on the Environmental Report

Scoping report responses

Consultation responses to the scoping report were received from all 3 statutory consultees to determine the final scope of the Environmental Report and assessments. SEPA and Historic Environment Scotland (HES) were generally content with the approach and the scope that was proposed in the Scoping Report. NatureScot provided feedback on specific parts of the report.

SEPA: “We are content with the geographical and temporal scope of the SEA. We also agree that in this instance all environmental topics should be scoped into the assessment.”

HES: “On the basis of the information provided, we are content with this approach. We are satisfied with the scope and level of detail proposed for the assessment.

NatureScot: “note that the plan will have significant environmental effects and therefore will require a full Strategic Environmental Assessment.”

Public consultation responses from the statutory consultees

Feedback from the statutory consultees generally welcomed the introduction of an Environment Strategy, albeit with some caveats.

HES response suggested that the draft Environment Strategy could do more to reflect the importance of “the relationship between the natural and historic components of our surroundings.” On the SEA, HES were generally content with the findings of the assessment, but did expect greater reference to the historic environment policy “Our Past Our Future” and the links to the outcome on Scotland’s net zero, nature positive and circular economy thrives within the planet’s sustainable limits.

In response to the comments by HES, reducing and managing threats to the environment will help to preserve the cultural environmental alongside the natural environment. Strengthening the connections between environmental policy making and local communities will help to identify important cultural assets that should be taken account of in decision making. However, historical cultural assets are not covered in detail in the Strategy, which is driven by the definition of "environment" at section 45 of the Continuity Act.

SEPA generally welcomed the draft Environment Strategy and agreed with the vision and outcomes of the Strategy. However, SEPA did feel a “healthy environment” outcome could be added to avoid fragmented efforts and unintended environmental harm.

NatureScot supported the overall ambition and strategic direction of the draft Environment Strategy, but they did warn that it is dependent on the pace and scale of delivery of all the associated plans covered by the draft Strategy and how strong governance across successive governments is essential for the success of the Strategy. NatureScot also warned that the “slower approach” taken in the draft Strategy and the SEA on the grounds of a Just Transition and ‘bring people with us’ could “disproportionately affect other people or species/ nature.”

Public consultees responses

An analysis and response to the completed public consultation has been published by the Scottish Government. A summary of the analysis on the SEA question can be found below:

Among those answering Q13, half (50%) indicated they had views on whether there are likely to be any positive or negative environmental impacts from the draft Environment Strategy that have not been identified in the Strategic Environmental Assessment (SEA).

Additional comments in response to Q13 were provided by 49 respondents, highlighting the importance of strategy implementation and monitoring, ecosystems and biodiversity, and social impacts and engagement.

Strategy Implementation

The most common theme under this question was policy implementation, with respondents highlighting that positive and negative environmental impacts will depend on how this policy is delivered. Several respondents noted a general concern about the SEA's ability to properly identify and prepare for the negative environmental impacts of such a strategy.

Respondents highlighted specific, unidentified, or unforeseen environmental impacts that they felt could occur due to policy implementation, such as the impacts of solar and wind farms, resource-use impacts, landscape quality, vulnerable communities, and habitat disruption. Unidentified negative environmental impacts from the implementation of solar and wind farms were cited as a concern due to the carbon footprint associated with building these farms relative to their short lifespan, habitat disruption and release of stored carbon due to these large-scale infrastructure projects. Impacts of resource-use were also noted, with respondents suggesting negative environmental impacts that had not been considered, including the move to net zero could increase material extraction, leading to the overexploitation of natural resources locally and overseas, and potentially “unintended consequences for soil, water, cultural heritage and landscapes”.

Further unidentified issues that respondents felt could potentially arise from policy implementation included the unintentional introduction of non-native species through restoration projects, distributional inequities such as localised pollution, which may unintentionally burden local or vulnerable communities, and a reduction in landscape quality caused by large-scale infrastructure changes.

Monitoring

Several respondents noted that some impacts may develop over time and cannot be foreseen within the Environment Strategy or SEA, making robust and ongoing monitoring an important part of implementation. Some respondents also highlighted specific elements within the SEA where monitoring was perceived as underrepresented, such as surveillance of zoonotic diseases linked to climate change mitigation strategies, such as forestry, or waste-related crime related to changing waste policies.

Ecosystem services

The second most prevalent theme was delivery of multiple outcomes by ecosystems, with respondents highlighting several additional or underrepresented potential positive ecosystem delivery impacts from the Strategy. A few respondents suggested that the role of various ecosystems was underrepresented, highlighting grass-based sheep systems, suggesting they contribute to soil health, biodiversity and carbon sequestration. Another respondent highlighted the positive impacts of managed woodland for renewable fuel supply, promoting biodiversity, carbon capture and rural landscape resilience. Land management was also highlighted as contributing to biodiversity, such as woodland management creating new habitats, which some respondents felt were underrepresented.

Engagement

Engagement was the third most prevalent theme under this question, with one respondent noting that the strategy “feels very top down”. Several respondents highlighted that greater community participation could generate additional positive environmental impacts not fully recognised in the SEA. Respondents suggested public education combined with community-led conservation initiatives could empower local communities to engage in environmental stewardship and support behaviour change from connectedness to nature. Other respondents, conversely, highlighted the consequences of failing to engage with local communities, resulting in insufficient support for implementation at the local level. The issue of behaviour change was also highlighted; one respondent called for the SEA to detail research regarding behaviour change to achieve emission reductions, as “people as a whole are resistant to change”.

Land Reform

Several respondents suggested that the SEA fails to identify the environmental significance of land ownership, with one respondent noting that “The Land Reform Acts (Scotland) are not listed in Annex A” despite the pattern of land management being of “fundamental importance [in] restoring the relationship between humans and nature”. Additionally, farm support reform and resulting land use change were highlighted by one respondent as needing to be assessed in further detail in the SEA to ensure farming delivers “biodiversity gains, reduced pollution and healthy soils”.

Social Impacts

Positive social, community and health impacts were also noted, such as “sheep farming supporting open landscapes that enable responsible public access”. Several respondents highlighted the cumulative benefits of landscape-led planning, which integrates nature, climate, and social objectives. These included greater access to green spaces, improved air quality, warmer homes, and the promotion of healthier diets.

Negative impacts

A few respondents noted some potential negative impacts of the Strategy that could affect ecosystem delivery, such as the landscape impacts of changes in land use, such as wind farm developments. Several respondents suggested that landscape-scale delivery should be further assessed to ensure clearer delivery mechanisms for ecosystem services and promote biodiversity.

Responding to the consultation

The responses to the consultation were welcomed by the Scottish Government and have helped in finalising the final version of the Environment Strategy and this Post Adoption Statement. The consultation on the draft Environment Strategy received 126 responses with some of these also responding to the question on the SEA.

The majority of responses were generally in favour of the draft Environment Strategy, but some responses wanted the Environment Strategy to go further and faster. On the responses to the question on the SEA, most respondents highlighted the importance of delivering the positive environmental impacts of the draft Strategy, but also mitigating some of the potential unintended negative environmental impacts that could arise from the Environment Strategy. The importance of monitoring was highlighted as a way of managing the implementation of the Strategy, delivering the benefits of the Strategy and mitigating against some of the unintended consequences of the Strategy. The full analysis of the consultation can be found here.

Following the consultation, the Environment Strategy will generally be taken forward as outlined in the SEA and this Post Adoption Statement. However, we have outlined some of the changes from the draft Environment Strategy below:

• We are making the Strategy more focused by developing a shorter core Strategy with the outcome pathways presented as Annexes.
• We have introduced a new section setting out an integrated approach to achieving the vision of the Strategy.
• The Strategy will outline new policy approaches to support the integration of policies, through engagement with stakeholders. There is also a renewed focus on blue and green infrastructure, which supports local, place-based and community-led action, and an improved understanding of the environmental impacts of public spending decisions.
• The Strategy will set out how we will engage with businesses across sectors, their representative bodies and investors to better understand the opportunities and barriers in adopting net zero, nature positive, circular economy business practices..
• A clearer focus in the outcome pathways on the next steps that the Scottish Government will take to drive progress towards the outcomes.