CIEEM Response to SEPA’s Consultation on Safeguarding Scotland’s Water Environment (3 March 2026)

Here you will find our response to SEPA’s consultation on Safeguarding Scotland’s Water Environment (3rd March 2026).

This response was developed by the Scotland Policy Group.

Key points:

1. Invasive non‑native species (INNS)

  • INNS must be formally recognised as a Significant Water Management Issue (SWMI) in RBMP4, with a standalone section, clear objectives, measures, targets and monitoring.​

  • The assumption that 97% of water bodies are free from INNS is misleading because current Water Framework Directive (WFD) classifications only downgrade for certain species and do not reflect wider presence, abundance, or spread risk.​

  • Over 20% of Scotland’s transitional waters were previously identified as at risk of failing environmental objectives due to INNS, and there remain evidence gaps for lochs and coastal waters.​

  • RBMP4 should include specific INNS actions linked to the Scottish Biodiversity Strategy delivery plan, the forthcoming Scottish INNS Plan, and the revised National Marine Plan.​

  • SEPA should establish a Technical Advisory Group to develop a more robust INNS classification metric that accounts for abundance and lag phases to support early detection and control.​

2. Climate adaptation and nature‑based solutions

  • CIEEM supports aligning RBMP4 with the Scottish National Adaptation Plan (SNAP3) and integrating flood risk management with long‑term water resource planning.​

  • Nature‑based solutions should be central, including restoring natural flows, re‑meandering straightened rivers, reconnecting floodplains, riparian tree planting and peatland restoration to reduce flood peaks, improve storage and build resilience.​

3. Nature, biodiversity and policy alignment

  • RBMPs were not originally designed for biodiversity conservation, and monitoring has focused on water quality, flows and fish passage; RBMP4’s “Nature” theme must better incorporate macro‑invertebrates, macrophytes and algae/diatoms as ecological proxies for river health.​

  • RBMP4 should function as a key delivery mechanism for the Scottish Biodiversity Strategy and forthcoming statutory nature targets, including supporting ecological networks and Local Authority nature networks under NPF4.​

  • The plan should align with the forthcoming Scottish Biodiversity Metric and the new National Marine Plan (NMP2) to ensure consistency across terrestrial, freshwater and marine policy.​

4. Participation, innovation and delivery

  • Successful Scottish catchment initiatives (e.g. Tweed Invasives Project, Eddleston Water, Forth Rivers Trust, Dee Catchment Partnership, Spey Catchment Initiative) demonstrate the value of catchment‑scale, partnership‑led approaches for river restoration, INNS control and climate resilience.​

  • Common success factors include strong catchment identity, trusted local intermediaries (rivers trusts/boards), blended public–private funding, shared outcomes, transparent data and framing projects around multiple benefits for nature, flood risk, farming and community wellbeing.​

  • Environmental DNA (eDNA) offers a rapid, cost‑effective, scalable tool for monitoring, including early INNS detection and assessing impacts of interventions such as beaver reintroduction.​

  • CIEEM’s “rebuilding nature” project will provide best‑practice guidance for restoration across freshwater, coastal and marine habitats, with existing outputs on bogs, ecosystem services, large‑scale recovery and monitoring relevant to RBMP implementation.​

  • Adequate resourcing and partner commitment are essential; without this, RBMPs risk remaining “unused roadmaps” rather than effective drivers of change.