CIEEM Response to A Biodiversity Metric for Scotland’s Planning System – Key Issues consultation. 

Here you will find our response to A Biodiversity Metric for Scotland’s Planning System – Key Issues consultation.

This response was developed by our Scotland Policy Group.


Key points:

  • Although the consultation focuses on the development of the metric itself, we highlighted other aspects that also require careful consideration and development in order that a metric be successfully implemented including approaches to offsetting, additionality, equivalency and integration with existing regimes such as Ecological/Environmental Impact Assessment.
  • When looking at identifying the habitat classification systems, need to consider the conservation status of habitats and the distinctive values for these. Consideration should be given to how well priority habitats (e.g. Annex 1) are identified through different classification systems and use this to inform which habitat system is taken forward.
  • With respect to irreplaceable habitats, it is agreed that these should be recognised within a Scottish metric. This will be of particular importance for blanket bog to ensure that restoration of blanket bog is appropriately considered, and the achieved benefits recognised.
  • CIEEM sees the lack of resources (primarily appropriately skilled biodiversity professionals in the sector and ecological capacity and expertise in local authorities) and lack of enforcement (legislation and capacity to do so) as the main barriers to successfully delivering this in Scotland. Ecological resource and capacity and lack of enforcement staff to ensure compliance were previously raised as concerns in a survey of Local Planning Authority staff.
  • Developing a metric for Scotland is a significant undertaking and will require significant resourcing within NatureScot.