IEMA responds to Scottish Government’s consultation on Strategic Framework for Biodiversity - December 2023

The Scottish Biodiversity Strategy consultation set out to obtain views on a range of topics and proposals related to biodiversity and tackling the nature emergency in Scotland. IEMA’s Biodiversity and Natural Capital Policy and Engagement Lead, Lesley Wilson, tells us about the consultation and IEMA’s response.

In December 2022 the Scottish Government published its Scottish Biodiversity Strategy. This set out a vision, outcomes, and 33 priority actions designed to halt and reverse biodiversity loss. In September this year, the Scottish Government produced its framework for delivering the Scottish Biodiversity Strategy and made it available for consultation.

The Scottish Biodiversity Strategy will be underpinned by a series of five-year delivery plans. The publication for consultation – ‘Tacking the Nature Emergency – Consultation on Scotland’s Strategic Framework for Biodiversity’ – is the first five-year delivery plan.

IEMA was delighted to host a workshop with members based in Scotland and/or working in Scotland to respond to this substantial consultation and to provide a strong set of recommendations.

The mention of baselines was very much lacking in the consultation document. Baselines are essential to the measurement and monitoring of the various aspects of implementing the Scottish Biodiversity Strategy. Baselines need to be agreed upon and defined, and a baseline date(s) needs to be set for either the whole strategy or for individual parts of the strategy.

It is important that Scottish Government have a clear view of how to prioritise the long list of actions in the consultation. Understanding priorities will support the creation of targets, metrics, and baselines by organisations and give them confidence to act. There will be a much smaller number of targets than the proposed list of actions in the document, but it’s important that the targets also have interim goals.

The availability of data was a key issue and we highlighted the need for more, shared data from public and private organisations and for that to be collated, managed, and available through a depositor to facilitate its use.

We also highlighted the key role of stakeholders in understanding, feeding into, and even co-designing actions, especially in farming, fisheries, and forestry, but also in projects such as windfarms and infrastructure. The direction of the framework suggests a cultural shift that needs to take people with it, and demonstrate the benefits to communities and businesses to them.

A significant omission was MPAs (Marine Protected Areas) and HPMAs (Highly Protected Marine Areas) yet these are in the Scottish Biodiversity Strategy. These should be playing a significant role in conserving and restoring marine biodiversity, not least because they make up 37% of Scottish seas.

As always, IEMA called for clarity and consistency around what’s being asked for (targets and requirements), by when, by whom (so who is responsible for delivery), and according to what (if any) standard of measurement.

The next steps are for responses to be collated and analysed and considered, along with other available evidence, by the Scottish Government and for a response to be made available. Meanwhile, the full IEMA response can be found here.

For IEMA members who wish to be involved in further consultation, especially in Scotland, or would like regular updates on biodiversity, you can join the IEMA Biodiversity and Natural Capital Network at: [email protected].