Here you will find our response to the NatureScot consultation on Scotland’s draft Peatland Standard (closed 28 August 2026).

This response was developed by the CIEEM members and the Scotland Policy Group.

In summary:

CIEEM supports the introduction of a Peatland Standard for Scotland and welcomes NatureScot’s work to consolidate Scotland’s fragmented legal and policy framework for peatlands into a single, well-referenced document. Our response, coordinated by the Scotland Policy Group, offers constructive recommendations to strengthen the draft before finalisation. Key points include:

• Clarify purpose and scope. The Standard should state explicitly why it is needed and what level of expectation it sets. As drafted, it reads more as collated guidance than a standard with a defined bar.
• Improve navigation. The pathway-based structure is difficult to use without prior expertise; a front-end decision tree, section summaries and diagrams would help non-specialist users.
• Adopt a single definition of peat. Depth thresholds vary across the document (30, 40 and 50cm). We recommend one clear definition early on and a precautionary approach extending protection to all peat deeper than 30cm.
• Make effective for all users. The pathway structure gives landowners little reason to choose restoration over protect-and-manage. Guidance on pathway selection, triggers for restoration and mixed-pathway sites is needed, with applicability to developers and planners made explicit.
• Tighten the Principles and wording. Several Principles use vague terms (“minimise”, “reduce”, “optimal”) without thresholds, and mandatory and advisory language is used inconsistently, risking uneven enforcement across sectors.
• Make monitoring practical. Many success indicators are costly or prohibitively difficult to measure; use of proxy indicators and the potential for existing and emerging technologies for monitoring should be acknowledged. Monitoring and evaluation should given greater prominence in the Standard.
• Draw from existing expertise. The Standard should acknowledge existing practitioner experience and make clear the circumstances in which it is necessary to consult ecological experts, for example, when taking a site-specific view on native tree establishment.
• Manage guidance separately. Operational material would be better held as stand-alone, easily updatable supplementary guidance, with a defined review cycle (e.g. every five years) for the Standard itself.