Biodiversity - meeting our '30 by 30' commitment on terrestrial and freshwater sites: consultation

Consultation paper seeking views on legislative proposals which will support the implementation of the '30 by 30' biodiversity commitment, and are potentially to be included within a natural environment Bill.

Section One: Creating flexibility for designated sites

Protected areas in Scotland work by identifying individual natural features (habitats, species populations or geology/geomorphology) to be protected on a site. Management of the site is then focused on maintaining those features in a favourable condition, which generally means keeping them as they were at the time of designation. This can cause problems where there are natural features on a site requiring different or conflicting management to reach or maintain favourable condition. This can sometimes mean that two or more such features cannot be in favourable condition at the same time, or if they can it can require very intensive management measures aimed at preventing any change. Not only can this sometimes be difficult to achieve, it can also be at the expense of delivering greater biodiversity benefits and resilience of ecosystems.

For example, in an upland context, areas of species rich grassland often form mosaics with dry heath habitats. Maintaining the species richness of the grassland requires a higher level of grazing than is needed to maintain the biodiversity in the heathland. As a result, a decision must be made to focus the management objectives for the site on maintaining either the grassland or the heath in favourable condition, at the expense of the other habitat.

The static nature of the designation also means that there is little or no flexibility to adapt management to changing circumstances over which we have no direct control, in particular climate and other environmental changes. This creates particular difficulties where changes in species ranges or species competition ‘within habitat’ mean that the feature for which a site is protected may be sparse or entirely absent, or that another species which might otherwise be protected has to be ‘managed’. Species range changes (e.g. geese populations) and within habitat species changes (e.g. oak becoming more prominent than Scots pine in lower-level mixed native woodland), both driven by climate change are already being seen.

In addition, focusing solely on individual ‘natural features’ represents a failure to recognise the importance of interactions across different habitat types and the species populations they support (the ecosystem). Ecosystems are dynamic, and will comprise different, changing habitats over time in response to changing conditions, and create particularly biodiversity rich areas. Transitional habitats also occur on the boundaries between different areas of habitat, and are an important element of a biodiversity-rich ecosystem. They allow space for the process of natural succession to progress. For example, as part of the natural regeneration of native woodland, there often develops an area of scrubby vegetation as a precursor to woodland expansion. These areas are favoured by black grouse.

There may be some instances where Scotland holds particular global responsibility for certain habitats (e.g. machair grassland) or species (e.g. Freshwater Pearl Mussel) where proactive, focused management will be particularly important to try and adapt to the environmental changes taking place with a view to perpetuating the species in that location. Nevertheless, a more flexible approach would enable recognition of the importance of the overall ecosystem, its functions and essential services, in addition to existing single features. Increasing options which provide additional flexibility would better focus management, whilst accommodating the requirements of rare or vulnerable species on the site. It is also hoped such changes would make it easier for land managers/owners to take a more holistic view in management for biodiversity in an area, which is better able to adapt to changing environmental conditions.


In order to ensure that protected areas can deliver the maximum for biodiversity, we propose that sites should be able to be designated on the basis of important ecosystems on land or interactions between habitats (which recognise the importance of transitional habitats in addition to individual features. This will allow for the holistic management of ecosystems, rather than component habitats and species populations within a landscape.

Guidance drafted by NatureScot, to supplement the existing SSSI Site Selection Guidance, would provide information relating to the designation of a site on the basis of ecosystem. This could include a variety of information aimed at assisting in the selection and designation of a site based on ecosystem. Such information could include, for example, issues and concepts surrounding designation, the broad operational approach and criteria for ecosystem evaluation and selection to assist in the designation.

Two example scenarios which describe how these provisions would allow greater flexibility to effectively protect biodiversity are set out below:

Scenario 1: A site is designated with the notified feature of a heath habitat. Following natural succession over time, part of the heath habitat has transitioned to scrub. Thus, part of the notified feature of the site is no longer present, although the scrub is an important transitional habitat which promotes biodiversity. Over time, under the same conditions, the scrub will become colonised by shrubs and trees, and develop to the next successional stage of naturally-regenerated woodland. Provision to continue to protect the transitional habitat would enable natural regeneration of woodland to take place.

Scenario 2: An undesignated site is identified as being important for biodiversity as it contains a naturally representative assemblage of habitats forming an important ecosystem. None of the habitats would constitute a ‘notified feature’ in their own right as they would not reach the standards set out in the SSSI Selection Guidelines.

These proposals aim to address the current inflexibility with protected areas provisions by providing the ability to include important ecosystems on protected areas citations (both existing and new sites). This would help create flexibility where appropriate and where it will deliver greater biodiversity benefits. We anticipate that NatureScot would develop supplementary guidance to set out what constitutes an important ecosystem.

Question 1: In Scotland, protected areas on land work by identifying individual natural features to be protected on a site (e.g. habitats, species populations or geology). Should the Scottish Government allow protected areas to also be designated on the basis of important ecosystems (including interactions between habitats, which recognise the importance of transitional habitats), in addition to individual natural features?

  • Agree
  • Somewhat agree
  • Neither agree nor disagree
  • Somewhat disagree
  • Disagree
  • Unsure



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