CIEEM Response to the Tackling the Nature Emergency Consultation on Scotland’s Strategic Framework for Biodiversity

Here you will find our response to the Tackling the Nature Emergency Consultation on Scotland’s Strategic Framework for Biodiversity.  This response was developed by our Scotland Policy Group.


CIEEM’s Comments:

Overall, we welcome the ambition of the Strategic Framework for Biodiversity.  This is the most comprehensive, challenging, and far-reaching Biodiversity Strategy ever published in Scotland, plus promised legislation with statutory targets in the Natural Environment Bill.   The intent to “mainstream and integrate biodiversity across government” is crucial.  Mainstreaming can only succeed if the relevant sectors/departments are mandated and directed to deliver on nature restoration.  The continued investment in nature restoration and management through Peatland Action Programme and Nature Restoration Fund and the commitment to six large scale landscape restoration areas is welcomed.

Key points:

  • The Biodiversity Framework will place some major and novel demands on NatureScot and we urge that support is made to reflect those – for example, designing and implementing a system and programme of Protected Areas monitoring, in the context of 30×30. Likewise, there are additional demands on Local Authorities, for example designation of nature networks, and we have published a survey and report on concerns over ecological capacity and expertise in Local Planning Authorities.
  • Few of the actions listed in the delivery plan are SMART. The recent State of Nature report clearly shows ongoing declines in terrestrial, freshwater and marine biodiversity despite previous strategies. We therefore need clearly defined SMART targets to engender and drive delivery.
  • For each action it needs to be clearly defined who has lead responsibility for delivery and the key delivery partners, strategies for implementation and timescales for delivery. A lack of clarity on who will do what, how they will be supported with funding, resources and expertise remain barriers to effective delivery.
  • We recommend that for each action it is clear how it will be independently monitored for progress in a scientific, evidence-based, transparent way. In addition, what sanctions if any are proposed for non-compliance or failure to meet targets.
  • In the Framework there could be greater differentiation between already existing policy and commitments and new actions designed to increase the delivery. This will help to ensure tangible clear actions, consistency, and accountability.
  • Scottish Government policy is to maintain or exceed EU standards as laid out in the Continuity Act so there is the requirement to align with the targets in the recent European Union legislation on ecosystem restoration.
  • Underpinning the Biodiversity Framework is the need to create and sustain Green Jobs for Nature. Society and the economy rely on a healthy natural environment and in turn it also provides lots of ‘green’ jobs and well-being.
  • There needs to be a National Nature Network to ensure that nature networks designated by local authorities link across boundaries and make ecological sense. A National Nature Network would join up sites for nature and link ecological processes across landscapes. Protected areas would form the core of Scotland’s Nature network and then by restoring and creating new habitats will connect these areas together. This requires spatial planning and co-ordinated action across the planning and land use sectors.
  • We propose that Environmental Standards Scotland takes on the role of reporting on the Government’s progress in meeting the statutory targets rather than the formation of an additional body. Environmental Standards Scotland already acts as an oversight/advisory body with a degree of statutory independence from the Scottish Government with growing in-house expertise on Scottish environmental law. Expanding the remit of Environmental Standards Scotland will involve increasing capacity and expertise.