Here you will find our response to the Scottish Government’s consultation on the Draft Environment Strategy (29 Sept 2025).

This response was developed by the Scotland Policy Group.

Key points:

Policy Integration and Accountability

• Recommend clarification in the Strategy about which elements stem from existing versus new policies, and transparent designation of responsible organizations for governance and delivery in order to avoid gaps or duplication.
• Suggest the Strategy should acknowledge and recommend analysis of underperforming existing strategies, using gap analysis to identify where new action is needed to meet targets.
• Stress adequate resourcing for agencies such as NatureScot and local authorities, along with enforceable targets, regulation, and defined governance roles.

Linking Biodiversity, Climate, and Pollution

• Urge clearer links to relevant frameworks (e.g., Forestry Strategy, River Basin Management Plan, Land Use Strategy, Biodiversity Framework), especially in achieving woodland creation and restoration targets.
• There should be explicit inclusion of climate adaptation as a distinct outcome, and detailed actions to address adaptation needs alongside mitigation.
• Call for a “source to sea” approach in water management, highlighting the absence of measures to address invasive non-natives in aquatic environments, which impacts the ability to achieve statutory ecological status.

Scotland’s Global Impact and Just Transition

• Note Scotland’s reliance on imported timber, highlighting sustainability and human rights concerns, and propose boosting domestic timber production through a balanced approach that also supports native woodland restoration.
• Strongly endorse the need for a just transition to a net-zero, nature-positive, circular economy, but finds a disconnect between headline policies and local delivery.

Societal Change and Equity

• Support strategies fostering societal and lifestyle change for environmental improvement, with a focus on implementation of evidence from reviews such as the Dasgupta Review on the economics of biodiversity.
• Call for more inclusive planning around “20-minute neighbourhoods” and better links between green space, health, and wellbeing, especially for disadvantaged and protected groups.

Implementation and Monitoring

• Recommend robust monitoring, fairer enforcement and regulation, and enhanced support for training, skills, and pathways into ecological careers—including diversity and inclusion measures.

Overall, CIEEM welcomes the Strategy’s ambitions but urges stronger delivery frameworks, integration with spatial planning, and a comprehensive approach to tackling interlinked crises of climate, biodiversity, pollution, and social inequality.