IEMA responds to consultation on Scottish Biodiversity strategy

01/02/2024

In 2022, the Scottish government published a biodiversity strategy that aims for Scotland to be nature positive by 2030, and to restore and regenerate nature across Scotland by 2045. The document sets out the vision, outcomes and 33 priority actions to achieve this. The strategy is underpinned by a series of five-year delivery plans. In 2023, the Scottish government set out its proposed plans to deliver the strategy in a consultation document: ‘Tackling the Nature Emergency – consultation on Scotland’s strategic framework for biodiversity’. This is the first five-year delivery plan. IEMA brought together members and key stakeholders working in Scotland, to create a response. In its response, IEMA put forward several recommendations that it believes would accelerate restoration and regeneration, protect nature on land and sea beyond protected sites, support vulnerable species and habitats, unlock investment in nature, and support the development and delivery of statutory targets. The implementation of the Scottish Biodiversity Strategy offers an opportunity for government to work with businesses and landowners. Public and private organisations could be encouraged to share data that could be collated, managed and freely available through an online depository to facilitate its use and promote good biodiversity management. A platform to make it easier to create partnerships between business and those offering specific biodiversity expertise, such as NGOs, would make partnerships accessible to all sizes of business, again supporting biodiversity activities. Stakeholders, especially in farming, fisheries and forestry, but also in projects such as wind farms and infrastructure, should be included in developing actions that are practical and motivating. Collecting data is hugely important in mitigating nature loss. Ongoing public investment in monitoring and data collection in the long term will be essential to support the continued availability of up-to-date information into the future. A system for collecting data is needed, perhaps using ‘A Review of the Biological Recording Infrastructure in Scotland’ by the Scottish Biodiversity Information Forum as a guide. Baseline measurements are critical to the success of the biodiversity strategy and should either be set across the strategy as a whole or within individual parts of it. The nature investment market needs to be demonstrated (including what return on investment can look like) and structured transparently so that organisations can have confidence to invest in this market. The actions to drive investment must include a public-private investment component, and it should be easier for companies to invest and commit to providing biodiversity improvements, including a mechanism to link buyers, sellers and brokers, with information on how to find them, and who to trust. IEMA welcomed the commitment to publish a plan for marine and coastal ecosystem restoration, including prioritising habitat and locations by 2025. However, marine protected areas and highly protected marine areas cannot be left out of any implementation plan for the Scottish Biodiversity Strategy, as they currently are. Targets were not included in the consultation document. Statutory targets will drive actions but must also be underpinned by further requirements, including on delivery. It would be helpful to align targets broadly with those of other nations to make it easier for all organisations – from pension companies buying biodiversity credits to a business trying to be nature-positive – to implement nature-positive actions. Key to the strategy’s success will be clarity and consistency in the final document around what’s being asked for (targets and requirements), by when, of whom (who is responsible), and according to what standard of measurement (where applicable). Priority actions need to be identified and to be clear. The next steps will be for the Scottish government to collate and consider the responses, and other available evidence, and to then produce an analysis report. For the full IEMA response, visit here.