Scottish Biodiversity Strategy 2022 – response to Scottish Government consultation

Over the summer months, the Scottish Government consulted on a draft Biodiversity Strategy, closing on 12th September1. At first sight, this seems unremarkable, since the previous strategies from 2004 and 2013 are due for an update. However, the timing doesn’t quite fit the wider context, since the previous publications were linked to biodiversity targets set for 2010 and 2020 respectively. The global targets are currently under revision, as part of the COP15 review of the UN Convention on Biological Diversity2. This is setting a ‘Post-2020 Global Biodiversity Framework‘ for the decade ahead, agreement on which has been delayed, mainly by the Covid pandemic. There’s a meeting set for Montreal in December which is intended to complete the process. So this draft biodiversity strategy from the Scottish Government will need to be reviewed in light of that outcome.

The draft strategy recognises “evidence……that Scotland is seeing dramatic declines in its biodiversity‘ (p7) – in other words that our wild plants and animals face a crisis of our own making. But I didn’t find its proposed response to this crisis at all compelling, since we failed to achieve most targets set for 2010 and 2020 and the new proposals do not feel like the promised ‘transformation needed in the way we use and manage natural resources‘ (p5). A revised draft strategy is awaited. In the meantime (for the record) here below are my responses to the questions raised.

  1. Using your own knowledge and the evidence presented, to what extent do you agree that there is a nature crisis in Scotland?

Evidence that we have a nature crisis in Scotland is summarised by Scotland’s poor showing in the global biodiversity intactness index – 28th from bottom of the global assessment of 240 countries and territories for land-based biodiversity. The UK as a whole is bottom of the G7 industrialised countries, setting a poor example to others. Furthermore, the accompanying detailed evidence for example the 2019 State of Nature report highlights two decades of failure since biodiversity strategies have been introduced. The vision set out in Scotland’s 2004 Biodiversity Strategy: “It’s 2030: Scotland is recognised as a world leader in biodiversity conservation” is failing. We must now construct a radical new approach.

2. What do you see as the key challenges and opportunities of tackling both the climate and biodiversity crises at the same time?

These crises cannot be tackled separately, because they are profoundly interlinked. Neither can successfully be overcome without the other. Our key challenge now is to tackle both successfully despite the mounting economic and social disruption of which they are, in part, a cause. Failure to do so will simply exacerbate economic and social turmoil into the future.

But this wider context of disruption also creates opportunities to pursue new directions, policies and measures for which there has been little prior support. Continuing with the status quo ante is not an option. A new biodiversity strategy must frame and expedite such policies and measures, providing a sense of co-ordination and shared purpose across the many relevant strategies and related policy documents.

3. Is the draft vision clear enough?

No – This draft vision represents an unacceptable retreat from the vision published nearly 20 years ago in 2004. In the first sentence, use of the word ‘substantially’ undermines clarity. Simply to slip the target date from 2030, in the previous strategy, to 2045 falls far short of the gravity of the crisis we face.

4. Is the draft vision ambitious enough?

No – This draft implies a sense that we can ‘kick the can down the road’, extending the 2030 ambitions of the current strategy to the longer term of 2045. Given our lack of progress towards 2030, our poor showing compared to other nations and the growing urgency of the task, this is far too complacent.

5. Do you have any suggestions for a short strategic vision which would form the title for the strategy?

‘Make more space for Nature in our lives’ – We must make more space in Scotland to live alongside the wild plants and animals which are being squeezed out here, in the United Kingdom and across the world. We must engage our fellow citizens, in all walks of life, in a joint enterprise of restoration and stewardship, without which the long-term prospects for our children and grandchildren are grim.

How will we know when we have succeeded? Topic 1 – Scotland’s rural environment – farmland, woodlands and forestry, soils and uplands

6. Do the 2045 outcome statements adequately capture the change we need to see?

No – The introduction rightly states that ‘transforming the way we use and manage land will be critical’ to delivery of the vision. But there’s little sign of transformation here. The 2045 outcome statements are aspirational, but show little indication of how delivery will be achieved any different from the failures of the last two decades.

Farming is our biggest single land use, but there’s an over emphasis here, for example the first bullet should be amended: “Farmland and forestry practices……while sustaining high quality food and timber production.”

The second bullet is overly focused on woodland, should include explicit reference to restoration of wetlands (a relatively quick win compared to woodlands) especially in lowland Scotland. The separate section on freshwater (below) leaves a risk that the impact of land management on wet habitats is overlooked.

7. Are the 2030 milestones ambitious enough?

No – Add drive to restore wetland habitats especially in lowland Scotland – across farmland there are too many areas where efforts to drain naturally damp ground continue despite limited success over many years. ‘Shifting baseline syndrome’ has erased our memory of the extent of wetland and the loss of wetland animals and plants.

8. What are the key drivers of biodiversity loss in this outcome area?

For decades, rural land management has been subsidised by the taxpayer to intensify production, reducing the space for nature despite often limited economic or social benefits. Redirection of this support is essential to achieve the transformation advocated in the introduction.

9. What are the key opportunities for this outcome area?

A new orientation of support for all aspects of rural land management to demonstrate better public value expressed in ecological, economic and social terms.

10. What are the key challenges for this outcome area?

Resistance to change and reluctance to replace or modify long-established funding channels is only to be expected, making it even more important to win widespread support for new ways of working. This is most especially true of the reframing of post-Brexit farm support which is currently under way, because the scale of this annual expenditure is the single most important policy influence on rural land management. The new approach must be evidence-led, including open discussion of the costs and benefits of different support measures.

Topic 2 – Marine environment

11. Do the 2045 outcome statements adequately capture the change we need to see?

No – These statements seem so far away from our current marine challenges as to question their value. Surely an outcome statement must begin by recognising our present poor position resulting from decades of overfishing (such that we don’t even recognise the richness of sea life we have lost since, say, the Eighteenth Century), pollution and climate impacts.

12. Are the 2030 milestones ambitious enough?

Again, these milestones seem from another world. Given the lack of progress since 2004, to adopt such statements for 2030 simply lacks credibility. How will we even establish a baseline from which recovery can begin?

13. What are the key drivers of biodiversity loss in this outcome area?

First, chronic overfishing since the mechanisation of fishing effort from the 1800s, second the cumulative impact of pollution (not only from industrial sources and shipping but many others, for example, the damage to the Firth of Forth resulting from reclamation of the Carse of Stirling) and third, increasingly, the impacts of climate change on weather patterns and ocean temperatures. Starting to correct these, by 2030, is a formidable challenge.

14. What are the key opportunities for this outcome area?

Create numerous sanctuary areas from which fishing boats are excluded, allowing marine species to recover. The resulting increase in stocks will, in time, benefit fishermen more generally as well as bolstering food supplies for seabirds, cetaceans and other wildlife.

15. What are the key challenges for this outcome area?

Marine fish farming is problematic, in terms of location, local impacts and sustainability of feed supplies. Recovery of, for example, wild salmonids depends on doing this better.

Topic 3 – Freshwater environment: rivers lochs and wetlands

16. Do the 2045 outcome statements adequately capture the change we need to see?

No -These outcome statements suffer from a lack of recognition that they depend, to a great extent, on changes to rural land management, especially farming.

17. Are the 2030 milestones ambitious enough?

The statements are fair as far as they go, but lack credibility in view of the failures to make progress since the 2004 Biodiversity Strategy.

18. What are the key drivers of biodiversity loss in this outcome area?

The context of centuries of efforts to drain farmland is overlooked. The space for wetland species, especially in lowland Scotland, has particularly been squeezed, so some rebalancing is long overdue.

19. What are the key opportunities for this outcome area?

As noted earlier, a new orientation of support for all aspects of rural land management to demonstrate better public value expressed in ecological, economic and social terms. Wetlands can especially benefit from such a change.

20. What are the key challenges for this outcome area?

As noted earlier, the new approach must be evidence-led, including open discussion of the costs and benefits of different support measures. This is especially important in understanding where effort is best directed to begin recovery of wetland habitats with minimum adverse economic and social impacts.

Topic 4 – Coastal environments

21. Do the 2045 outcome statements adequately capture the change we need to see?

No – These are very general statements, and it isn’t clear that ‘coastal environments’ are a distinct category not adequately covered by land management and marine. There’s an argument for the simplicity of focus on land and sea, understanding that there’s a coastal interface rather than a hard boundary between the two.

22. Are the 2030 milestones ambitious enough?

The focus on ‘coastal environments’ isn’t convincing (see answer to previous question).

23. What are the key drivers of biodiversity loss in this outcome area?

The drivers of biodiversity loss in coastal areas are not fundamentally different from those for land and sea respectively.

24. What are the key opportunities for this outcome area?

Focus on land, and sea, recognising the coastal interface between them.

25. What are the key challenges for this outcome area?

As above

Topic 5 – Urban environments – towns and cities

26. Do the 2045 outcome statements adequately capture the change we need to see?

No -The focus on urban landscapes is problematic because, while this is where most of the people are, it is directed towards the land rather than the people.

This strategy is missing a key dimension well captured in the 2004 vision “..everyone is involved; everyone benefits…”.

Take, for example, the second bullet: “Multi-functional urban Nature-based solutions provide the basis for healthy and resilient communities” – surely this outcome applies equally beyond urban centres?

27. Are the 2030 milestones ambitious enough?

The 2030 outcomes are very general, and should be rewritten in plain English. For most of us, ‘nature richness’, ecological coherence’ and ‘green/blue infrastructure’ are jargon. How would we know these when we see them?

28. What are the key drivers of biodiversity loss in this outcome area?

The focus on urban landscapes is flawed because urban drivers of biodiversity loss are widespread out and beyond the urban boundary. The engagement of people in all walks of life in tackling the biodiversity crisis requires a broader approach – although, since this is where most people live, conservation of urban biodiversity is essential to their personal experience and wellbeing.

29. What are the key opportunities for this outcome area?

Facilitate and harness community effort.

30. What are the key challenges for this outcome area?

Find ways in which people in all walks of life can constructively engage directly in meeting the biodiversity and climate challenges.

Topic 6 – Across our land and at sea – overall health, resilience and connectivity

31. Do the 2045 outcome statements adequately capture the change we need to see?

No – These draft outcomes imply a degree of central planning and top-down control which has proved difficult to achieve in practice.

32. Are the 2030 milestones ambitious enough?

These draft outcomes fail to capture the need to achieve active engagement of people and communities, without which past failures will continue.

33. What are the key drivers of biodiversity loss in this outcome area?

This standard question seems a poor fit with the topic, since the drivers are ubiquitous and equally affect rural, marine and urban environments.

34. What are the key opportunities for this outcome area?

This standard question seems a poor fit with the topic, since the opportunities equally affect rural, marine and urban environments.

35. What are the key challenges for this outcome area?

This standard question seems a poor fit with the topic, since the challenges equally affect rural, marine and urban environments.

36. To what extent will these outcomes deliver the Vision? What might be missing?

There’s a huge omission of outcomes to achieve constructive engagement of people and communities.

There’s also an increasing need to acknowledge and address conflict in delivering the vision, seeking to facilitate conciliation which will not happen spontaneously. Different contested accounts and perspectives need to be teased out and grounds for reconciliation cultivated.

37. What evidence and information should we use to assess whether we have delivered the Vision?

The existing monitoring effort, for example via citizen science supporting research and survey effort, needs to be properly resourced and maintained.

The conditions for success

38. Have we captured the key enabling factors which are essential in order for our strategy to be successful?

These proposed outcomes have an old-fashioned, top-down and rather tired feel to them. The jargon (delivery plans, buy-in, mainstreamed, line of sight, values-led and so on) is of a piece with an approach and style which has failed in practice over recent decades. The transformation sought in the opening sections of the draft will not be achieved simply be repeating previous practice.

There are some key points buried within this long list which suggest the possibility of trying new measures, but they aren’t adequately explained (for example ‘statutory targets’ do nothing to win people over) nor how they interface with the many other strategies and policy areas. Clarity of these relationships, how biodiversity fits into a wider picture, is lacking!

39. Are there good examples of enabling conditions in other strategies we could learn from?

Good examples are those which facilitate and empower people and their communities, providing evidence-based advice, flexible support and fostering a constructive approach to framing and overcoming diverse challenges. I’m not sure ‘strategies’ are the best place to find these examples, more likely in accounts of success and learning through practice.

40. Can you set out how you think any of the proposals set out in the consultation might help to eliminate discrimination, advance equality of opportunity and foster good relations?

These are all valid dimensions of the challenge; looking across recent debate around biodiversity, there’s a clear need to acknowledge and address conflict in contested accounts of issues and proposals, cultivating dialogue and grounds for conciliation.

  1. See: Scottish Biodiversity Strategy 2022 – Scottish Government – Citizen Space (consult.gov.scot)
  2. See: UN Biodiversity Conference (COP 15) (unep.org)

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