Publication - Research and analysis

Consultation Analysis: Getting the Best from Our Land – A Draft Land Use Strategy for Scotland 2016-2021

Published: 23 March 2016
ISBN: 9781786521729

This report analyses the written responses received to the consultation on the draft Land Use Strategy for Scotland 2016 to 2021.

Supporting documents

2. Analysis of Responses

Vision, Objectives and Principles

Q1a Do you think that the Vision, Principles for Sustainable Land Use and three long term Objectives are still fit for purpose?

	Yes		No		Don't know		Total answered*	Not answered
Individual	22	51%	13	30%	8	19%	43	11
Public sector (national or local government)	15	79%	3	16%	1	5%	19	5
Other public sector	8	100%	0	0%	0	0%	8	2
Third sector (woodland and environment)	19	86%	2	9%	1	5%	22	0
Third sector (other)	15	83%	3	17%	0	0%	18	1
Representative or professional body	6	75%	1	13%	1	13%	8	3
Private sector	7	88%	1	13%	0	0%	8	1
Academic or research body	4	80%	1	20%	0	0%	5	0
Other	3	38%	5	63%	0	0%	8	4
Total	99	71%	29	21%	11	8%	139	27

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.1 Most respondents (139) answered question 1a. Of these, the majority (71 per cent) felt that the Vision, Principles and Objectives were still fit for purpose. There were clear differences in opinion between respondent categories. While a high proportion of public sector, third sector, private sector and academic organisations agreed with the Vision, Principles and Objectives, there were higher levels of disagreement among individuals and those in the other respondent category.

2.2 Analysis by area of interest selected by respondents suggests that those with an interest in education or local communities were most likely to say that the Vision, Principles and Objectives were fit for purpose, while those with an interest in cultural heritage or farming were least likely to.

2.3 Respondents who were positive about the Vision, Principles and Objectives highlighted that they remained relevant and valid, and built on previous work. Some organisational respondents across categories (9) highlighted that the LUS was still in a relatively early stage of progress - through to 2050 - so the Vision, Principles and Objectives should not change. A few (3) highlighted that the Strategy recognised the importance and interdependence of economic growth, community wellbeing and environmental challenges. While two organisational respondents highlighted that the Strategy made appropriate links with health and wellbeing, another organisational respondent felt that the Strategy could say more about promoting healthy living and tackling inequality.

2.4 Many respondents indicated that they were broadly happy with the Vision, Principles and Objectives, but wished a small number of additional points to be considered.

Balancing economic growth, social and environmental objectives

2.5 One representative or professional body felt that the Objectives and strategic directions within the Strategy could be framed more in the context of sustainable economic growth, with viable and profitable land use (notably agricultural land use) at its core. It felt that if the economic drivers were right, then multiple benefits would follow.

2.6 However, many other respondents (15) raised concerns about the perceived focus on economic growth as top priority, beyond social and environmental considerations. This was raised by respondents in the third sector categories (across woodland, environment and other interests) and by individual respondents, as well as one representative or professional body. Many of these respondents felt conversely, that if the focus was on ecosystems, sustainability, resilience and productivity, the economic benefits would follow.

2.7 Many raised concerns that the Scottish Government's underpinning objective was about sustainable economic growth, and felt that this objective could conflict with environmental priorities. There was some concern that economic prosperity appeared to be a short term objective, while the long term interests of environmental sustainability received less priority.

2.8 Three respondents suggested that it was important to include an objective which was about the intrinsic value of the natural environment, while a further three respondents felt that sustainable development should be stated as an explicit objective. Another three respondents suggested that the order of the Objectives could be changed, so that the Objective relating to business and economic growth was not the first Objective - which they felt made it appear most important.

2.9 A public sector respondent stressed the need for clear guidance about priorities when making decisions about competing land use proposals. Five other respondents also felt that competing priorities needed to be more explicitly recognised within the Strategy. This included individual and third sector respondents. One third sector respondent suggested that it would be useful to adopt the 'Sandford Principle' that where there is a conflict between the environment and development, greater weight in decision making should be given to the environment.

Implementation of the Strategy

2.10 Some organisational respondents (10) commented on the implementation of the Strategy. Six of these respondents felt that for the Strategy to be successful, there needed to be a clear delivery plan - focusing on the next five years. These respondents came from across different respondent categories.

2.11 Four organisational respondents (largely from the private sector) felt that there was a need for greater clarity on the status of the Strategy in decision making at national and local level, with three emphasising that it was important that the Strategy did not become too intrusive. One representative or professional body respondent indicated that while land owners and managers could engage positively with the Strategy, bringing real benefits, there was also the potential that the Strategy was seen as interference in their day to day land management. It felt that there needed to be a demonstrable intent to engage openly and honestly with land owners and managers expressed within the Strategy.

Historic environment and landscapes

2.12 Six organisational respondents felt that the historic environment was not well referenced throughout the Strategy, and that the Strategy should not be limited to the consideration of natural resources alone. This included respondents from the public sector, third sector, representative bodies and others. One of these respondents highlighted that it was important that the objective around land based businesses recognised the value of historic environment related business.

2.13 Four respondents also felt that landscapes should be better recognised within the Strategy, perhaps with an additional objective around enjoying and enhancing landscapes and reference to Scotland's Landscape Charter. These issues were raised by third sector organisations with an interest in woodland and environment, by one representative organisation and by one individual.

Reflecting the changing policy landscape

2.14 There were mixed views in relation to how the Strategy reflected the changing policy landscape. Many respondents indicated that they were happy that the Vision, Principles and Objectives remained valid. However, four organisational respondents agreed broadly with the Vision, Principles and Objectives, but felt that there should be stronger links to issues around community empowerment, social justice and public interest - reflecting the significant shifts in the policy landscape around community empowerment and land reform since the last Strategy.

2.15 In addition, a third sector organisation indicated that it could not agree with the Vision, Principles and Objectives as the Strategy did not explicitly recognise land policy as a public interest matter, through which the government can deliver on greater fairness, social justice and realisation of human rights - including access to food and housing. Linked to this, one individual respondent also highlighted that the Strategy needed to include affordable housing as a priority, recognising that landed estates are a major provider of affordable rented housing in rural areas.

2.16 Finally, one organisational respondent stressed the need for the Strategy to discuss sustainable food growth.

Specific comments on the Vision

2.17 Five individual respondents specifically highlighted that they felt that the Vision was slightly dry, and should give more of an impression of what Scotland should look like in terms of biodiversity and natural heritage. Two respondents (one individual and one third sector organisation) felt that it was important that the Vision specifically mentioned water as well as land. A small number of respondents highlighted that they were happy that the Vision focused on wellbeing, and not just economic benefits.

Specific comments on land use and business Objective

2.18 Two respondents felt that it was important to build understanding of the value currently generated by land based businesses, and consider how (or whether) this could be increased. One academic or research body suggested that research demonstrated that many land managers believe they are already making as much of a contribution to Scotland's prosperity as they can.

2.19 Two respondents (one local authority and one third sector organisation) suggested that this Objective should emphasise the need to address issues around inequality of access to resources, and land ownership patterns.

2.20 Two respondents suggested specific changes to the wording of the Objective. One felt that 'nature' was a dated term, and should be replaced with a phrase to express that businesses work 'within the constraints of our environment'. Another was concerned about the term 'land based businesses', feeling that this did not recognise other important sectors such as those working in tourism, access and heritage.

Specific comments on land use and the environment Objective

2.21 Eight respondents provided specific comments on this Objective. Four organisational respondents from the other and local government categories stressed the need to include a reference to climate change, and one private sector organisation wished to see the role of renewables mentioned.

2.22 Two third sector respondents emphasised that it was important to highlight the need for conservation as well as responsible stewardship, which is actively restorative and regenerative.

Specific comments on land use and communities' Objective

2.23 Many respondents (12) provided specific comments on this Objective. Three (two individuals and one third sector organisation) indicated that there should be a stronger statement to reflect issues around land reform, proposed new rights and responsibilities in this area, and concerns about inequitable land ownership in Scotland and how we support more land into public and community ownership. One individual also stated that it was important to revisit how the Strategy connects communities with their land.

2.24 A few (5) organisational respondents suggested a number of small changes, including:

making clear links with the Fairer Scotland agenda and mentioning communities of interest as well as local communities;
emphasising the importance of access to land for livelihood and food production; and
mentioning the link with planning.

2.25 Finally, one private sector organisation had concerns about this Objective, suggesting that involvement requires people to be suitably informed, and creates the need for a forum for bringing together informed and competing interests. A third sector organisation with an interest in woodland and the environment also indicated it had concerns, stating that the focus should be on improving the quality of people's connection with land use, rather than simply increasing the number of people with influence.

Specific comments on the Principles

2.26 A small number of respondents provided comments on specific Principles:

Principle A - One local authority felt that this Principle should make clear that benefits should be social, economic and environmental.
Principle B - One third sector organisation felt that this should be reworded to 'promote' rather than 'protect' essential public interests to ensure they are sufficiently recognised.
Principle C - Two organisations (a research body and a representative or professional body) felt that it was important to recognise that land can have multiple benefits under this Principle, for example through encouraging farming and forestry to create a mixed economy. A respondent from the representative or professional body category highlighted that the planning system already takes primary land use into account. And one individual felt that it was important that the environmental value of 'wild land' was recognised, although this may not have an economic return.
Principle D - One representative body was unsure if this Principle was about decisions about the use or the management of land.
Principle E - A representative or professional body respondent wanted this Principle to have more emphasis. However, another representative body emphasised that there were already statutory regimes and guidance in place to ensure that landscape change managed positively and sympathetically.
Principle G - Two respondents (research and third sector organisations) felt that it was important to recognise that brownfield land can play a useful function through creating urban wildscapes, play opportunities and habitats. Another felt that the Principle should emphasise the need to encourage investment, and another felt that the Principle should recognise the role of the planning system.

2.27 Finally, two third sector respondents felt that more could be said about how these decisions will be made - for example about primary use of land. One felt that the Principles did not fully capture the relationship between land ownership and land use, and how land could be used in the public interest and for the common good. The other felt that more should be said about devolving land use decisions to a local level. In addition, one individual suggested that at some stage these Principles should be merged with a customised version of the Ecosystems Approach, which also contains twelve principles to produce a land use code for Scotland - and includes reference to local decision making.

2.28 A few organisational respondents indicated that they did not feel that the Vision, Principles and Objectives were still fit for purpose, and made varying points including:

there needed to be more reference to the urgency of change in relation to climate change, with one third sector organisation keen to see clear policies to deliver emissions reductions throughout the land use sector;
there needed to be a reference to the importance of renewable energy, including recognition of its role in employment and sustainable growth;
there needed to be a reference to investment in the land based work force;
there was a need to say more about urban sprawl and use of greenfield and brownfield land;
the Objectives should more fully reflect the Millennium Ecosystem Assessment (Supporting, Provisioning, Regulating and Cultural Services);
there was concerned that there were lots of references to the negative effects of agriculture on environment, but little about positive impacts;
there should be a reference to the potential Voluntary Guidance on the Responsible Governance of Tenure, Fisheries and Forests;
there should be reference to the Convention on Biological Diversity; and
there should be a reference to the UN Sustainable Development goals; the UN Framework Convention on Climate Change Conference of the Parties; and the 2020 Challenge for Scotland's Biodiversity.

Natural Resource Management

Q2a Do you agree that continued use of an ecosystems approach is an effective way to manage Scotland's natural capital?

	Yes		No		Don't know		Total answered*	Not answered
Individual	30	67%	9	20%	6	13%	45	9
Public sector (national or local government)	18	95%	1	5%	0	0%	19	5
Other public sector	8	100%	0	0%	0	0%	8	2
Third sector (woodland and environment)	16	80%	1	5%	3	15%	20	2
Third sector (other)	13	93%	1	7%	0	0%	14	5
Representative or professional body	7	100%	0	0%	0	0%	7	4
Private sector	7	100%	0	0%	0	0%	7	2
Academic or research body	3	75%	0	0%	1	25%	4	1
Other	8	89%	0	0%	1	11%	9	3
Total	110	83%	12	9%	11	8%	133	33

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.29 Most respondents (133) answered question 2a. Of these, the majority (83 per cent) agreed that the continued use of an ecosystems approach was an effective way to manage Scotland's natural capital. Just twelve respondents (nine per cent) said it was not, and eleven respondents (eight per cent) did not know. From the responses, it appears that the public sector respondent that ticked no when completing the survey may have done so mistakenly - as the comments were very positive. Individuals were the least supportive of an ecosystems approach, while public sector, private sector and representative or professional bodies were the most supportive.

2.30 Respondents with an interest in farming were least likely to agree that the continuted use of an ecosytems approach was an effective way to manage Scotland's natural capital.

2.31 Respondents who supported the ecosystems approach felt that it was essential and fundamental to the LUS. Respondents in support of the concept highlighted that maintaining or enhancing the quality of soil, water, air, habitats, species and communities was fundamental to the principles of sustainable land management, and that the ecosystems approach was the best way to understand the diversity of the environment, and the inter-relatedness of people and nature. A small number of respondents highlighted that the ecosystems approach was the only feasible way forward, and should be at the heart of the Strategy. A few respondents (4) specifically highlighted that the ecosystems approach allowed for the harmonious balance of interests (for example including forestry and farming) and showed connections between the various aspects of land use.

2.32 While largely in agreement, those who supported the approach made a number of additional suggestions, explored in detail below.

Simplifying the language

2.33 A large number of respondents (24) felt that work needed to be done to simplify the language used when talking about an ecosystems approach, and to explain the concept more clearly so that a wide range of people could understand it. This was raised by a large number of local authority respondents, as well as by third sector organisations, professional and representative bodies, individuals and othe organisations. The terms 'ecosystems approach' and 'natural capital' were highlighted as being particularly jargonistic, and unlikely to be widely understood.

2.34 Respondents were particularly concerned about the way the concept was explained as many felt that the current language may put off or disengage some of the primary audiences, who are central to making an ecosystems approach work. Many felt that the concept needed to be better explained, in clear language, making the benefits of the concept particularly apparent.

2.35 A few respondents made specific suggestions here including:

three organisations (from the research and third sectors) felt it was important to make reference to the Convention on Biological Diversity and the 12 Malawi principles;
one local authority respondent suggested using the term 'integrated land use' instead of an 'ecosystems approach';
one organisational respondent felt that the explanation should refer to the Millennium Ecosystem Assessment while another research or academic organisation stressed that it was important to be clear that an ecosystem assessment was not the same thing as an ecosystem approach;
one individual respondent felt that it was important to be clear what the level of 'ecosystem' was - for example at individual farm level, or much broader; and
one organisation felt that it was important to emphasise that the ecosystems approach does not preclude other management and conservation approaches.

Translating the approach into action

2.36 Some respondents who broadly supported the ecosystems approach raised challenges around translating the approach into action.

2.37 Seven respondents (largely from the third sector) felt that the way the consultation question was worded ('continue to use') indicated that the ecosystems approach may be more embedded in Scotland than it actually was. These respondents felt that it was important to recognise that the approach had not been used very much in Scotland, and that the pilots - while useful - did not fully provide working examples of the ecosystems approach in practice. In addition, one respondent involved in one of the pilot areas indicated that while the approach has significant potential, the process was highly challenging and it was difficult to pin point exactly when an ecosystems approach was being used.

2.38 Some respondents (6) highlighted the importance of the involvement of a wide range of national and local stakeholders in taking the approach forward. Some felt that while government agencies were now well aware of the ecosystems approach, land managers required support and incentives to make it work. Respondents stressed that this would require further development and research, with structures established for joint working and building understanding of how stakeholders could work together. Private sector respondents stressed that how the approach was applied, and the evidence used to support decisions in practice, would be key to determining the real benefit of this approach.

2.39 A few respondents felt that it was important to have more real life examples of genuine, full implementation of the ecosystems approach, and to say more about where, how and by whom the approach could or would be used in decision making. One local authority respondent suggested that it would welcome clear guidance and examples of good practice. One other public sector respondent felt that the EU Mapping and Assessment of Ecosystems and their Services (MAES) could deliver more clarity, accurate measurement and indicators.

2.40 Two respondents (one local authority and one third sector organisation) felt that some local authorities may lack the resources to support decisions based on an ecosystems approach. The third sector organisation highlighted the complexity of understanding and assessing social and environmental wellbeing benefits, and weighing these against direct financial considerations.

2.41 Finally, one research organisation felt that the Strategy should reference the formal commitments to the ecosystems approach made by delivery partners like the Scottish Environment Protection Agency (SEPA) and others.

Incentives for land managers

2.42 A number of respondents (4) who supported an ecosystems approach emphasised the need for greater progress to be made in developing Payments for Ecosystem Services. This was highlighted by a representative or professional body, one private sector organisation, and a local authority respondent. Respondents highlighted that this would recognise that land managers are managing natural capital while also running businesses, and that these payments would make engagement more attractive to land managers. One representative body (who supported the approach) felt that it was very important to recognise that the concept of productivity within the ecosystems approach - recognising that people make a living from the land - otherwise the approach risked being a concept rather than a reality.

2.43 Two local authorities highlighted the potential role of the Environmental Cooperation Action Fund in supporting collective action. However, one of these felt that there was a need for a review of Agri Environment Climate Scheme funding, to ensure the Environmental Cooperation Action Fund could be effectively used in assisting cooperative working to support the ecosystems approach.

Monetary value

2.44 Some third sector respondents (6) highlighted that they were pleased to see a move away from ecosystems services economic valuation as the only measurement for the ecosystems approach. These respondents were concerned about attaching a monetary value to the environment.

2.45 However, three respondents (two from the private sector and one other public sector organisation) stressed that the monetary aspect of the ecosystems approach could be made more explicit. The private sector respondents emphasised that it was vital that the ecosystems approach continued to try to take economic factors fully into account.

Wider and cultural context

2.46 Nine respondents (9) felt that it was important that the section on the ecosystems approach said more about cultural services, landscapes and the historic environment - including cultural diversity, spiritual and religious values, education values, inspiration, aesthetic values, social relations, cultural heritage values, sense of place, recreation and ecotourism. This was raised by local authorities, other public sector organisations, third sector organisations and others. Two of these respondents suggested that cultural contributions could be harder to map than others, but were important to include. In addition, two respondents also highlighted the need to explain that ecosystems were the product of humans and nature interacting together. And one third sector respondent felt that it needed to be clear that the ecosystems approach applies to urban contexts too.

2.47 One respondent highlighted that a strength of the approach was that it fitted well with the objectives of fairness, land reform and empowerment. However, one individual respondent was concerned that 'fairness' was a political concept which should not be connected to land use decisions.

Key reasons for not supporting an ecosystems approach

2.48 Many respondents (12) indicated that they did not support the use of an ecosystems approach. Half of these were individual respondents.

2.49 The main reason for individuals not supporting the approach was because they felt that this would result in preservation without recognising change. Four of the individuals felt that the approach did not recognise evolving ecosystems, and that the approach could result in stagnation rather than embracing change. One individual indicated that the approach could be expensive, and another felt that it was important to ask if it was the right tool for Scotland. One individual felt the ecosystems approach was complex and hard to implement, and that if it was to be pursued this would need to involve recognition that this would require taking a fundamentally different approach and taking hard decisions. And one felt that the approach was not properly explained and so disagreed with it.

2.50 Three organisations indicated that they disagreed with the ecosystems approach. (although one of them provided further comment which suggested it supported it). One third sector organisation felt that it could be difficult for land managers or communities to feel a sense of ownership through an ecosystems approach, and that many would find it difficult to manage the whole ecosystem rather than focusing on particular aspects. Another was concerned that an ecosystems approach did not say much about land use or management.

2.51 Those who indicated that they did not know whether they supported an ecosystems approach largely felt that they required more information about what an ecosystems approach was. Two individuals indicated that they were put off by the jargon used within the document.

Policy Alignment

Q3a Is the relationship as set out in the draft Land Use Strategy 2016-2021 clear?

	Yes		No		Don't know		Total answered*	Not answered
Individual	19	45%	9	21%	14	33%	42	12
Public sector (national or local government)	14	78%	3	17%	1	6%	18	6
Other public sector	6	86%	1	14%	0	0%	7	3
Third sector (woodland and environment)	9	50%	7	39%	2	11%	18	4
Third sector (other)	8	50%	7	44%	1	6%	16	3
Representative or professional body	5	56%	4	44%	0	0%	9	2
Private sector	3	43%	3	43%	1	14%	7	2
Academic or research body	2	67%	1	33%	0	0%	3	2
Other	2	22%	6	67%	1	11%	9	3
Total	68	53%	41	32%	20	16%	129	37

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question

2.52 A total of 129 respondents answered this question. Of these, just over half (53 per cent) said that the relationship was clear, and a third (32 per cent) said that it was not. The remainder indicated that they did not know. Public sector organisations were most likely to believe the relationship was clear, while individuals, private sector organisations and organisations from the other category were least likely to believe this.

2.53 Respondents with an interest in cultural heritage, education, community and 'other' interests were least likely to feel that the relationship was clear.

2.54 Respondents who said that the relationship was clear indicated that it was proportionate, and managed to show clear linkages in a summarised fashion across a very complex area. Local government respondents were most likely to feel that the description was proportionate and clear.

2.55 However, even those who felt that the relationship was clear often highlighted areas for development. There were three overarching themes, highlighted both by those who said the relationship was clear and those who said it was not:

the need for clarity on or development of the hierarchy and status of the policies and strategies;
creating real connections between the LUS and these policies and strategies; and
potential conflict between the policies and strategies.

A hierarchy of policies and strategies

2.56 Many respondents raised concerns about the hierarchy of policies and strategies used within the consultation document, and the status of the LUS in relation to other policies and strategies.

2.57 Some respondents (6) indicated that the overarching purpose and Economic Strategy were overly focused on sustainable economic growth, which should not be the over-riding priority for Scotland. These respondents - largely third sector organisations and individuals - indicated that environmental considerations should be in 'productive tension' with the economic strategy, rather than sitting underneath it. They felt that it was important that these tensions were recognised, and the hierarchy was reconsidered. However, another private sector respondent welcomed the supremacy of the economic strategy within the policy context.

2.58 In relation to the national plans, policies and strategies, respondents raised a number of questions. Some (8) indicated surprise that the LUS and the SRDP sat at the same level in the diagram. These respondents felt that the LUS should clearly sit above operational documents which could deliver Strategy Objectives - including the SRDP and the National Planning Framework. In addition, ten respondents (all third sector and individuals) suggested that the status of the LUS should be enhanced so that rather than sitting alongside other national plans, policies and strategies, it is the overarching Strategy under which all other policy and strategy relating to land are placed.

2.59 Six further respondents felt that the relationship between planning and the LUS needed to be made clearer. Some private sector, local government and other respondents felt that the LUS should have a clear status in terms of its relationship to planning, either as a statutory document or a material consideration. This would help to make clear which policies take precedence and how they align. One representative or professional body also made the point that while the LUS indicates that the planning system is a delivery mechanism for the Strategy, planners are largely not aware of this.

2.60 In addition:

one local government respondent questioned why the Historic Environment Strategy was presented as a 'national strategy' while the Scottish Forestry Strategy and Scottish Biodiversity Strategy are sectoral strategies;
one local government respondent wondered whether there could be scope for reducing the number of strategies and plans relating to land in the future, for example by rationalising the LUS and the National Planning Framework;
one third sector organisation suggested that a more detailed review of the policy environment was required, with accompanying guidance on how the policies relate to one another; and
one respondent felt that the climate change policy should have more of a priority above some of the other national plans, policies and strategies.

Q3b Do you have any comments on the relationship between the LUS and

Scotland's Economic Strategy 2015, National Planning Framework, National Marine Plan and other relevant policies?

Conflicts between policies and strategies

2.61 A range of respondents had concerns that while the connections looked sensible on paper, in practice, the policies and strategies could not be combined to make a coherent approach to land use in Scotland. Some respondents felt that while the diagram set out the policy context, the functional and working relationships between these was not clear. This included respondents from the public sector, private sector, third sector and research organisations. Six respondents were concerned that there was no practical evidence of the connections being made between the policies and strategies in practice, and questioned how this connection would be made. Some indicated that it would be helpful to have more information on the connections between the policies, which have a statutory duty to 'have regard' to one another, and how this is being done.

2.62 However, a large number (25) had comments about potential conflict between the range of existing policies, strategies and plans. Most (including respondents from local government and representative bodies) indicated that it was important to openly acknowledge the tensions which arise in land management, and the range of sectoral issues and geographical differences across Scotland. Local government respondents in particular felt that it was important to explain the sometimes competing relationships between for example agriculture, forestry, flood management and upland land use. In addition, one representative body indicated that the messages were mixed and contradictory, which made it very challenging to minimise conflict on the ground - unless a more 'bottom up' approach was taken to land management. Many respondents indicated that recognition of the conflicts was very important, because the LUS will only be successful if it is fairly implemented at local level.

2.63 A few respondents gave other suggestions:

some indicated that they would like to see policy documents better aligned to ensure that complexities are minimised, making clear how the LUS links with and is woven through other policies;
some felt that if there were conflicts, it was important to understand whether some policies over-ride others;
a very small number of respondents wondered whether the LUS added anything new, which was not already covered in other policies, strategies or plans; and
one individual respondent highlighted that the range of agencies, policies, strategies, laws, regulations and administrative practices makes it problematic to align and support a vision for Scotland.

Wider issues

2.64 Three respondents, highlighted the need to ensure clearer links with major policy objectives around affordable housing - and to reduce potential conflict in delivery of this objective. In addition, two respondents felt that the policy alignment did not reflect urban and regeneration priorities, and was primarily focused on rural areas.

2.65 Two respondents expressed concern about the timing of the LUS being developed - which may not fit well with the publication of the Independent Review of Planning System (later in 2016) and the setting of priorities for the Common Agricultural Policy and associated SRDP (which have already been set through to 2021).

2.66 A few individuals highlighted that the policy context was not clear because it used jargon and was over complicated.

Detailed points

2.67 Respondents suggested making connections to a range of policies including:

the Land Reform (Scotland) Bill (as it develops) and the Land Rights and Responsibilities Statement;
the Community Empowerment (Scotland) Act;
Local Development Plans;
River Basin Management Plans;
the Archaeology Strategy for Scotland - with further development of the link to the Historic Environment Strategy also suggested as helpful;
flood management policies;
the National Transport Strategy;
the Scottish Biodiversity Strategy
the Climate Change (Scotland) Act;
forthcoming Regional Marine Plans;
the One Million Acres by 2020 Strategy;
policy or strategy around renewables;
city region planning processes;
the European Landscape Convention and Scottish Landscape Charter;
the Map of Wild Places;
the Natural Capital Asset Index;
Good Food Nation;
European policies such as Common Agricultural Policy (CAP), FP and EU Environmental directives; and
all Scottish Government policies.

Planning

Q4a Do you think that the activities described above could be useful?

	Yes		No		Don't know		Total answered*	Not answered
Individual	32	82%	3	8%	4	10%	39	15
Public sector (national or local government)	19	100%	0	0%	0	0%	19	5
Other public sector	8	100%	0	0%	0	0%	8	2
Third sector (woodland and environment)	16	100%	0	0%	0	0%	16	6
Third sector (other)	12	75%	1	6%	3	19%	16	3
Representative or professional body	8	100%	0	0%	0	0%	8	3
Private sector	7	100%	0	0%	0	0%	7	2
Academic or research body	5	100%	0	0%	0	0%	5	0
Other	9	90%	0	0%	1	10%	10	2
Total	116	91%	4	3%	8	6%	128	38

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.68 This question explored responses to Policy 3, which set out a programme of information and awareness raising which would provide:

more detail and clarity on the relevance of the LUS to the planning system;
information about the added value the LUS can bring, particularly to development planning; and
information on the use of an ecosystems approach in Strategic Environmental Assessment, which in turn supports development planning.

2.69 A total of 128 respondents answered question 4a. Of these, almost all (91 per cent) felt that the activities could be useful. Only four respondents (three per cent) said that they would not - representing just three individuals and one third sector organisation. The remainder - eight respondents (six per cent) indicated that they did not know. This included third sector, individual and 'other' organisational respondents.

2.70 Most respondents felt that it was essential and crucial to undertake a programme of information and awareness raising, believing that there was lots of uncertainty about how the LUS related to the statutory planning system. Some felt that this programme would help with understanding the alignment between the LUS, the National Planning Framework and the Scottish Planning Policy. One local authority respondent felt that to date, the impact of the LUS on the planning system at local and regional level had been low, and another indicated that this approach would help make the relevance of the LUS clear to planners.

Reasons for disagreeing with the approach

2.71 One organisation and three individuals indicated that they disagreed with the approach of information provision and awareness raising. The one organisation which disagreed, from the third sector, felt that most planning decisions were now taken at national level (through appeals) and therefore awareness should be raised at national level rather than local. Another individual who disagreed felt the Scottish Government needed to consider the tensions between its policy priorities, and should instead raise awareness among Scottish Government decision makers of the impact of legislation on different policy areas, including housing.

Q4b Do you have any suggestions on other kinds of information and activities that could be useful?

Need for support and guidance

2.72 Most agreed with the approach. Many indicated that planners (and others) may need support, guidance and information to apply the ecosystems approach, in the real world. Respondents felt that this could include:

workshops, seminars and web based information;
examples of good practice;
clear links with local development plans, including a workshop at the next national development plans 'Forum' on how the LUS and Development Plans interact;
a Planning Advice Note outlining how the LUS could be translated into both strategic and local Development Plans; and
working with the Royal Town Planning Institute (RTPI) and the Improvement Service to deliver training.

2.73 Two individuals emphasised that the ecosystems approach should be explained in simple terms, echoing their responses to previous questions.

2.74 A few respondents from across respondent groups suggested that the learning from the Land Use Pilots could help, and one suggested other examples such as the Carse of Stirling project and the Scottish Natural Heritage LIFE project with Central Scotland Green Network could offer useful learning. One representative body suggested that Forest Plans could be recognised as a good example of the sort of integrated approach the LUS is seeking to encourage. Two respondents highlighted that there was evidence from Glenquey Quarry which illustrated the current problems experienced, which may also be useful. One third sector respondent suggested an urban pilot would also help to demonstrate the relevance of the LUS, while another emphasised that 'land use' may be seen as referring only to rural land use which can lead to disconnect between the LUS and planning.

2.75 Some felt that this was about a change of mindset, and required activity beyond information provision. A few respondents (11) suggested that awareness raising needed to extend beyond planners to include wider stakeholders, including communities, developers, experts and other organisations with an interest in planning developments. Three respondents, across a range of respondent categories, indicated that it was important to remember that it was not always planning authorities making decisions, and that individual land owner decisions were also very important. These respondents felt that the Scottish Government should engage with land managers to enable them to contribute to the Strategy aims to build shared ownership of the aims and priorities within it. One private sector respondent also highlighted that it was important to build links between the statutory planning regime and decisions made at a local level, for example at a catchment and landscape scale.

2.76 While many local authorities indicated that they would welcome further information and guidance, two rural local authority respondents made clear that an ecosystems approach was already well established and embraced in their area. In addition one representative body indicated that it was important that there was clarity on the relevance of the LUS to the planning system within the Strategy itself, rather than treating this as a separate piece of work.

Strength of requirements

2.77 A number of respondents questioned whether information provision and awareness raising would be sufficient to change working practices within planning. Many third sector, research, individuals and 'other' organisations (11) felt that the status of the LUS needed to be strengthened in relation to planning. These respondents felt that the Principles within the LUS needed to be translated into statutory guidance, national outcomes, regulations and / or mandatory requirements, otherwise the Strategy may not affect the outcomes of planning decisions. Some third sector respondents suggested that the Scottish Government needed to clearly state that the LUS is a material consideration in planning decisions, and that the National Planning Framework and Development Plans must have regard to it.

2.78 Two local government respondents felt that the Strategic Environmental Assessment provided a good route for more alignment and clarity, and that it was important to advocate a proportionate application of the ecosystems approach within these. However, another local government respondent indicated that it was important that the LUS was very clear about what aspects of planning it seeks to address. Another local government respondent indicated that the stronger the link to planning, the more likely it was that the LUS would be seen as a regulatory strategy.

2.79 One representative organisation highlighted that it was important to recognise that some land managers remain suspicious of a strong linkage between the LUS and planning at a local level, and are reluctant to see local authority planners having a greater role in land use policy. This was emphasised further by a private sector respondent.

2.80 Two respondents from the other category also emphasised the need for the link with planning to be made in a way that does not result in additional unacceptable obligations for developers, which might inhibit sustainable development. One of these organisations felt that there was a risk that the LUS might change the aims of the Scottish Planning Policy, particularly in relation to sustainable development and attracting global investment. Finally, one individual respondent stressed that the role of planning is to balance a range of policy directions, and that the LUS could be a key contributor to the National Planning Framework without being a competitor.

Wider issues

2.81 Three respondents (two organisations and one individual) indicated that it was important to recognise that taking an ecosystems approach takes time. This may have implications on the time taken to make planning decisions, due to the resources available, which may in turn make it difficult to contribute to the agenda of improving the speed of determining planning applications.

2.82 More widely, four respondents indicated that the information and awareness raising should specifically include:

linkages with greenspace and place making policies (2 respondents);
information on flood risk assessment (1); and
data about the nature of the shallow subsurface and its condition (1).

2.83 Within this question, two individuals also emphasised the need for a full database of land use and/ or land ownership.

Forestry

Q5 How could the content of the current Scottish Forestry Strategy be updated to better reflect the Objectives and Principles of the Land Use Strategy and other key priorities?

2.84 A total of 117 respondents commented on this question. Almost a third of individuals did not comment, rising to 70 per cent for other public sector organisations. Almost all (20 out of 22) third sector (woodland and environment) organisations responded to this question.

2.85 Many (14) indicated that the Scottish Forestry Strategy was still highly relevant, and largely fit for purpose. This included many private sector respondents, as well as some from other respondent categories. These respondents emphasised that forestry was a long term activity, requiring stability and clarity of objectives over the longer term. A small number, for example one individual and one private sector respondent, felt that little went on within forestry which does not involve consideration of everything that the LUS sought to achieve, and highlighted a positive track record of planning land use change through consensus rather than adversarial approaches.

2.86 However, most also felt that given the Strategy was published in 2006, it was in need of a light touch refresh. Many indicated their intention of responding in full to consultation on the revised Scottish Forestry Strategy. Some (such as one local authority and a representative body) indicated their interest in being considered as a key stakeholder in the process of reviewing the Strategy.

2.87 Some also indicated that while the content of the Scottish Forestry Strategy was good, there was a need to think more about how objectives will be delivered. For example, one private sector respondent indicated concern that targets within the Scottish Forestry Strategy had not been met. One organisational respondent from the other category felt that a complete review of the Scottish Forestry Strategy was urgently needed, to reflect the many changes that had taken place over the past ten years.

Ecosystems approach

2.88 Some respondents (10) indicated that it was important that the ecosystems approach outlined in the LUS was built in (further) to the Scottish Forestry Strategy. This included public sector, private sector and third sector organisations. Some respondents felt that there would be a need to assess some of the actions and indicators within the Scottish Forestry Strategy against the LUS Objectives, and to reprioritise. Some felt that the ecosystems approach could help with understanding the variety of services provided by woodlands, and how these can add to the social, environmental and economic value of the land, and be better integrated with other land uses.

Relationship between agriculture and woodland

2.89 Nine respondents commented on the relationship between agriculture and woodland, and the need for this to be explored in detail within the Scottish Forestry Strategy. This included respondents from the public, third, research and private sectors. Many of these respondents felt that there were clear conflicts between these sectors, with a need for recognition of these conflicts, prioritisation of conflicting objectives, and more work to support an integrated approach. There was particular concern that this had led to conflicts in the past over the use of prime agricultural land, and that the aims of the Scottish Forestry Strategy were impacting on the aims of the Future of Scottish Agriculture.

2.90 One representative body provided detailed commentary on this point. It considered that the Scottish Forestry Strategy should set out that only suitable farm woodlands of clear biodiversity, woodfuel or farm management benefit (and of mixed broadleaf and softwood species) should be allowed to be planted on farmland of class 3.1 or better. It felt that commercial forest expansion should be limited to areas where the agricultural production is not diminished. It also suggested that guidance and support mechanisms should be developed and refined so that agricultural businesses can make more of farming with trees. It also suggested a more fine grained approach to Indicative Forestry Strategies, so that a mix of enterprises are integrated.

2.91 In addition, a few respondents raised concerns about conflicting land use in upland areas. These respondents felt that these areas could be seen as conflicting and polarised land use areas where forestry and sheep grazing enterprises clash. However, one respondent (an 'other' organisation) indicated that neither was sustainable on their own - and there was more scope for multi-functional land use involving sheep, cattle, commercial woodlands, amenity woodlands, access, tourism, natural flood management, carbon storage and wildlife conservation.

Woodland expansion

2.92 Some respondents (6), from a range of categories, indicated strong support for continued woodland expansion in Scotland. Three suggested that the Scottish Forestry Strategy should make clear links with the Woodland Expansion Advisory Group, which they felt made good recommendations. One private sector respondent indicated that forestry should be seen as a long term crop, which land owners should be strongly assisted to plant. Two other respondents felt that there was a need to consider the tax, subsidy and direct support provided to land owners, as while the land owner may not see the benefit of forestry development, the community might. Another individual respondent specifically highlighted the need to prioritise reforestation of upland areas, to support degraded upland areas.

2.93 Five respondents also highlighted that since the last Forestry Strategy, there was significantly more evidence available about the positive economic benefits of forestry. These respondents felt that the Forestry Strategy could now better explain and highlight the benefits to Scotland in terms of jobs and prosperity, making the case for a focus on afforestation. A few respondents pointed particularly to the publication of 'The economic contribution of the forestry sector in Scotland' (2015) as providing valuable evidence, and indicated that they hoped the Scottish Forestry Strategy would recognise this. However, one local government respondent cautioned that it was important to also carefully consider the peripheral, challenging areas where commercial forestry is unrealistic but forestry can bring wider biodiversity and environmental benefits.

Environmental impacts

2.94 Many respondents (13) felt that the Scottish Forestry Strategy should note the clear role of forestry in reducing the impacts of climate change and alleviating flooding. This included private sector, local government, representative bodies and third sector organisations.

2.95 However, a number of respondents also highlighted potential negative impacts. One third sector organisation highlighted that it was important to understand that much forestry is not sympathetic to the ecosystem, particularly conifer plantation which can destroy diversity. Three individual respondents agreed, highlighting the potential costs of certain types of forestry - including albedo change, oxidative potential, loss of biodiversity and road damage. There were particularly varied views on forestry in upland areas, regarding whether this was desirable or not

2.96 One individual felt that commercial conifer forestry should not be termed as 'woodland', as this doesn't recognise the non-tree biodiversity of woodland - as supporting areas planted with trees to become woodland is a different thing from just planting trees on it.

2.97 A few (5) highlighted that it was important to test forestry expansion targets against other existing and potential land uses - including active peatland, moorland, bog, heathland and species rich grassland. Some of these respondents indicated that balance was critical, and it was vital not to lose environments or species to afforestation. Another third sector respondent indicated that it was important to think about carbon efficient and climate friendly forestry.

Woodland diversity

2.98 Some respondents suggested that current delivery of forestry in Scotland supported large scale investment forestry, rather than sensitive, locally appropriate and small scale woodland development.

2.99 One research organisation highlighted studies undertaken by the British Geological Survey in the Cairngorms and Eddleston catchment, which indicate that the Scottish Forestry Strategy should:

recognise that more mature woodland plays a greater role in reducing flooding; and
commit to preserving older mature forests given that these have increased capacity for rainfill infiltration and reduced runoff.

2.100 Five other third sector organisations and two individuals asked that there was more of a focus on protecting ancient and native woodlands, and prioritising natural regeneration - recognising the longer term approach required, but the longer term benefits generated. This may involve more varied woodland, trees growing at different rates, deciduous woodland, and smaller sites. One of these organisations highlighted the need for a strategic approach to deer population management to support this.

2.101 Four further respondents (three organisations and one individual) felt that there should be more emphasis on integration between different types of woodland (particularly broadleaved and coniferous woodland), to enhance habitat diversity and integrate non native species into the landscape. One of these respondents - an individual - was concerned that Scotland did not have the knowledge base to achieve broadleaf and native planting on a larger scale, due to a loss of capacity in forestry research and development, and disconnects between the research communities.

Relationship with renewable energy

2.102 Six local authority respondents, and one third sector organisation, suggested reviewing the removal of woodland to allow for renewable energy capacity. There was concern that there were competing demands for land use, and that there was a national target to install a certain level of energy capacity on the national forest estate - which would reduce woodland.

Community engagement and recreation

2.103 A few third sector and individual respondents (4) felt that the Scottish Forestry Strategy could better reflect the need for community engagement and participation in woodland planning and management. These respondents felt that more could be done to strengthen the connection between communities and land, through managing and owning local forests. One respondent suggested reviewing the National Forest Land Scheme in this regard.

2.104 Local authorities, third sector organisations and individuals (5) also emphasised the need to encourage the use of woodland for access, enjoyment and recreation - including hiking, mountain biking and leisure uses such as hutting. Two respondents emphasised the particular role that forestry could play in terms of vitality of rural communities through tourism, which could bring wider economic benefits.

Particular areas of focus

2.105 Respondents also made some distinct points, including highlighting the need for:

recognising the role of agroforestry, allotments, community gardens and orchards (3);
integrating the historic environment and mitigating the impact of expansion of forestry on archaeological sites (2);
investing in training and education around forestry (2);
recognising the importance of tree health (2)
recognising the links to the National Cycle Network, which sits partially within land owned and managed by the Forestry Commission (1);
recognising technological innovations since the last Strategy, particularly around GIS and digital mapping (1);
recognising that there can be inconsistencies in Forest and Woodland Strategies between local authority areas (1);
placing more focus on transitional habitats such as natural altitudinal treelines, montane scrub and wood pasture (1);
recognising the role of the Forestry Commission in delivering affordable housing, building on good examples such as Ardgael Kincraig developed by the Highlands Small Communities Housing Trust (1);
reviewing the transport infrastructure for timber haulage, including better integration into marine infrastructure planning (1);
placing greater emphasis of the importance of trees and woodland in the urban environment (1);
integrating landscape scale approaches into the Scottish Forestry Strategy (1); and
linking with the UK Forestry Standard and UK Woodland Assurance Standard (1).

Land Reform

Q6a Do you consider that there could be advantages in having a single policy statement about land which deals with ownership, use and management?

	Yes		No		Don't know		Total answered*	Not answered
Individual	28	58%	10	21%	10	21%	48	6
Public sector (national or local government)	8	53%	3	20%	4	27%	15	9
Other public sector	5	100%	0	0%	0	0%	5	5
Third sector (woodland and environment)	14	74%	1	5%	4	21%	19	3
Third sector (other)	13	76%	1	6%	3	18%	17	2
Representative or professional body	5	63%	2	25%	1	13%	8	3
Private sector	4	67%	1	17%	1	17%	6	3
Academic or research body	1	33%	0	0%	2	67%	3	2
Other	3	38%	2	25%	3	38%	8	4
Total	81	63%	20	16%	28	22%	129	37

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.106 Most respondents (129) chose to answer the question. Of those, the majority (63 per cent) agreed that there would be advantages in having a single policy statement covering ownership, use and management. Sixteen per cent of respondents disagreed with this, and 22 per cent said they did not know. Individuals and third sector organisations were most supportive of the proposal.

2.107 Respondents with an interest in cultural heritage an those with 'other' interests were most supportive of the proposal.

Q6b Do you have any comments on the relationship between current land related policies and how these would relate to a single policy statement?

2.108 Respondents from across all categories who were supportive of the proposal to have a single policy statement covering ownership, use and management felt that this would be useful and would provide clarity on the priorities for Scotland's land. A number of these noted that current policies were too sectoral and that a single policy statement would provide greater certainty about future land use and related policies, and help to identify any competing land uses. Two private sector organisations said that it would also make life easier on a practical level, as land owners and managers would be clearer on how they could assist in the implementation of the government's policy objectives.

Improved policy alignment

2.109 A large number of respondents from across all categories (15) felt that developing a single policy statement would help to improve the integration and alignment of the wide range of Scottish Government policies and strategies that were relevant to the ownership, use and management of land, including:

Land reform;
Community empowerment;
Marine environment;
Forestry and agriculture;
Climate change;
Biodiversity;
Affordable housing;
Water and quality;
Natural food management;
Food and drink; and
Access, sport and tourism.

2.110 Some (mainly third sector organisations) called for better alignment of the LUS and the proposed Land Rights and Responsibilities Statement. Some of these respondents suggested that the new Scottish Land Commission might have a role in overseeing the integration of policies and strategies relating to land rights, responsibilities and land use.

2.111 Two third sector organisations commented on the timing of the production of such a statement. These respondents felt that it would have been beneficial if the single policy statement had been produced prior to the Land Reform Bill, the revised LUS, the National Planning Framework 3 and the National Marine Plan, as they felt that having to retrofit a single policy statement to these policies and plans might not be very effective.

2.112 A few respondents (4) highlighted the importance of the statement setting out clear principles for sustainable land use that could guide future land use decision making. Two respondents also underlined the importance of links being made to planning, both at national and local level, to ensure that the best outcomes for land use in Scotland are achieved.

2.113 Finally, although supportive of the proposal, two respondents thought that it might be challenging to produce an overarching statement, particularly as this would involve bringing together different bits of legislation that may require to be changed.

Maximising public benefits

2.114 Some respondents (8) highlighted the importance of ensuring that the single policy statement was clear on Scottish Government's expectations from the use of land, and in particular the public benefits that could be delivered from this, to avoid confrontations and contradictory land use decisions. In particular, one third sector (woodland and environment) organisation highlighted that the main focus should be on how land is used and managed to maximise public benefit, for example, in relation to: biodiversity, carbon sequestration or improved water and air quality.

Focus on management and land use

2.115 Although agreeing that a single policy statement would be useful, some respondents (mainly third sector organisations) (7) felt that that it would be more important to focus on management and land use, and to exclude ownership. Some of these respondents felt that knowing who owned the land was of secondary importance, and this was likely to be problematic and could polarise discussions. One representative or professional body felt that this would allow a more balanced approach to be taken that focused on the current and future use of land. In addition, a few third sector organisations (3) suggested that the Scottish Government should consider developing a 'Code of Responsible Stewardship' to support the statement.

Challenges

2.116 A number of respondents (20) indicated that they were not supportive of the proposal to develop a single policy statement covering ownership, use and management. Half of these were individual respondents. Although stating that they 'did not know', some respondents made similar comments to those who said that they did not support the proposal.

2.117 The main reason for respondents (16) not supporting the proposal was that it would be too challenging to develop a single statement covering the complexity of the relationships between management, use and ownership, and that any statement was likely to be oversimplified, vague and generic. Some of these respondents also felt that it would be difficult to get buy-in from stakeholders to such an all-encompassing statement. In addition, some respondents (8) - particularly those that had been involved in the LUS pilots - felt strongly that ownership should not be covered in a statement about land use, and this should not be linked to the Land Reform agenda.

2.118 Finally, some of the respondents who indicated that they didn't know whether they supported the proposal felt that it was unclear what was being asked. Another respondent suggested that this should be a matter for the Scottish Land Commission to consider.

Informed decision-making

Ecosystem Services Mapping and Tools

Q7a Do you agree that models and GIS tools could help inform decision making about land use/management change?

	Yes		No		Don't know		Total answered*	Not answered
Individual	38	84%	4	9%	3	7%	45	9
Public sector (national or local government)	18	95%	0	0%	1	5%	19	5
Other public sector	8	100%	0	0%	0	0%	8	2
Third sector (woodland and environment)	17	89%	0	0%	2	11%	19	3
Third sector (other)	13	93%	0	0%	1	7%	14	5
Representative or professional body	7	88%	0	0%	1	13%	8	3
Private sector	7	100%	0	0%	0	0%	7	2
Academic or research body	4	80%	0	0%	1	20%	5	0
Other	7	88%	0	0%	1	13%	8	4
Total	119	89%	4	3%	10	8%	133	33

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.119 Most respondents (133) chose to answer the question. Of those, an overwhelming majority (89 per cent) agreed that models and GIS mapping tools could help inform decision making about land use and management change. Only four individual respondents (three per cent) disagreed with this, and ten (eight per cent) were unsure.

2.120 Respondents with an interest in cultural heritage, forestry, environment and general land management were most likely to agree with this proposal, while those with an interest in farming and deer and game management were least likely to agree.

2.121 Many respondents who were supportive of the use of models and GIS tools felt that the provision of spatial information was both useful and informative, and could help stakeholders - from a range of backgrounds - to visualise and understand complex information more easily. In addition, others noted that it would also assist in the strategic monitoring and review of land use and management change. In particular, one respondent from the other public sector category noted that the use of models and GIS tools provided a more holistic view of the effect of land use, and allowed planning and assessment across multiple ecosystems services.

2.122 Respondents outlined a number of benefits of using models and GIS tools, including:

providing an effective and powerful way to disseminate and communicate land use information that can be tailored to a range of audiences;
helping to stimulate dialogue between different interests and perspectives;
enabling a more collaborative approach to land use decision making;
introducing greater transparency to decision making processes; and
providing a baseline for monitoring performance against targets e.g. Local Biodiversity Action Plans.

Limitations of models and tools

2.123 Whilst supportive of the use of models and GIS tools, respondents also made a number of additional comments and suggestions.

2.124 One of the key issues identified by respondents from across respondent groups was the fact that the value of models and tools was very much dependent on the quality and reliability of the underlying data used to develop them.

2.125 Many respondents (12) mainly from the other and third sector categories also added that although helpful in informing decisions, information from models and tools needed to be supported by knowledge from local stakeholders about what was happening on the ground, to ensure quality control. In addition, one third sector respondent noted that consideration should also be given to other factors e.g. funding incentives and regulations. Some respondents (across a range of categories) noted that not all ecosystems and services could be mapped, and some areas did not have sufficient layers of data at the right scale to build models.

2.126 A small number of respondents (2) called for a standardised 'symbol/ legend' to be used in GIS mapping tools. Another individual respondent noted that baseline information was only useful if a standardised collection method had been used.

2.127 Although agreeing with the proposal, two third sector (woodland and environment) respondents cautioned against too much emphasis and resources being placed on developing models and tools, and suggested that more effort should be placed on developing incentives to secure landowner buy-in, and meaningful land use change.

Accessibility and availability of data

2.128 Many respondents welcomed the principle of wider access to data.

2.129 A number of respondents (mainly local government respondents) called for more support and training from Scottish Government in the use of models and GIS tools, noting that setting up and maintaining these types of models and tools was both resource intensive and costly. A public sector organisation also underlined the fact that given the implications in terms of costs and time, this might not be a priority for local authorities in times of financial constraint. In this context, another public sector organisation and a private sector respondent acknowledged the provision in the 2016-21 Strategic Research Programme to develop GIS based tools to inform this process, and also the Scottish Government's commitment to developing the web based portal (Scotland's Environment Web).

2.130 In addition, some respondents (10) across a range of categories underlined the importance of data being accessible and publically available, and in a format that was user friendly to community groups and 'lay people'.

2.131 A few respondents (4) noted that a number of models and GIS tools were already being used by different organisations e.g. related to farmland, forestry and designated sites, and that care would need to be taken not to 're-invent the wheel'. Others commented that it would be beneficial to be clear on the relationships with other data platforms and projects such as the National Biodiversity Network's Atlas of Living Scotland, Land Use Data Directory, Scotland's Environment Web and the Ecosystem Services Data Management project.

2.132 Finally, one research organisation suggested that it might be beneficial to channel resources to 'deliberative spaces', where stakeholders can access, debate and amend data. Another respondent from the private sector highlighted the importance of getting better collaboration and co-operation between stakeholders in relation to data sharing, for example, utilities companies.

Land Use Strategy pilots and other best practice examples

2.133 Some respondents (8) (particularly respondents from local government) commented positively on the findings from the LUS pilots in Aberdeenshire and the Scottish Borders, particularly in relation to the use of models and GIS tools. For example, two organisational respondents said that the land use pilot had demonstrated the value and usefulness of GIS mapping, helping to bring data together and present it in a usable and accessible format. Likewise, one individual respondent commented on the effectiveness of using GIS in the Borders pilot to examine trade-offs of different ecosystems services, for example, flood prevention versus food production.

2.134 A few respondents (4) highlighted the recent work being done in the Scottish historic environment sector to develop publically accessible GIS tools, stating that this was already proving successful for those involved in decision making at all levels. In particular, one representative or professional body suggested that it would be beneficial to refer to the Scottish Historic Environment's Data (SHED) Strategy.

2.135 Similarly, one other public sector respondent pointed to the Land Information Search Tool that had been developed in collaboration with Forestry Commission Scotland, Scottish Natural Heritage and Scottish Environment and Protection Agency. This tool facilitates the linkage and communication of a number of related datasets that can be used by key stakeholders to help inform decision making on the ground.

2.136 Another other public sector respondent also commented that it was already one of the pioneers in the use of GIS models for marine planning, and was currently leading the development of an integrated GIS platform/ data resource to support partners in the Tomintoul and Glenlivet Heritage Lottery Landscape Partnership project.

2.137 A third sector (woodland and environment) respondent also pointed to the models and tools being used by Scottish Natural Heritage in relation to Wild Land Areas, stating that it was essential that a spatial framework as used to embed the Principles of LUS.

Other comments

2.138 One individual respondent with an expertise in data management noted that although access to land information in Scotland had improved greatly in recent years, more needed to be done to develop a clear Land Information Strategy to support the initiatives proposed within the LUS. This respondent called for the development of a National Spatial Data Infrastructure that provided access to a holistic set of inert-operable land information.

2.139 One representative or professional body respondent noted that while accepting that models and tools could be useful, this would depend on how these were used, by whom, and for what purpose. It suggested that the use of such models and tools to inform decision making would need to be handled sensitively, as it might cut across decisions that were the responsibility of land managers.

Key reasons for not supporting the use of models and tools

2.140 A few individual respondents (4) indicated that they did not support the use of models and GIS tools. Some of these respondents felt that there was insufficient information in the consultation paper and on the consultation website about the proposals for models and tools, particularly for people who might not be familiar with the technical terms and language that had been used. Two respondents noted that land use decisions should not be based solely on information from models and tools.

2.141 Some of the respondents who indicated that they didn't know whether this approach was helpful provided additional comments. One representative or professional body supported the principle of transparency and sharing information on land. Another third sector organisation was of the view that GIS was a useful first stage in informing land use, but this needed to be backed up with more detailed ground based surveys making full use of Local Environmental Resource Centres.

Q7c Do you think that a baseline ecosystems services mapping tool could be useful?

2.142 A total of 118 respondents chose to answer the question. Of those, the majority (82 per cent) agreed that a baseline ecosystems services mapping tool would be useful. Only four respondents (three per cent) disagreed with this, and seventeen (14 per cent) said they did not know. Individuals were least supportive of the proposal.

Q7d Do you have any comments on a mapping tool?

2.143 Many respondents who were supportive of developing a baseline ecosystems services mapping tool said that this would be constructive and useful, and could lead to greater consistency in decision making. One research organisation also suggested that this would help to educate and raise awareness among stakeholders. However, a few respondents (2) reiterated the fact that this was still only a tool, and would need to be backed up by local knowledge, if it was to be used to inform decisions. Though supportive of the approach, one other public sector respondent said that caution would be required when interpreting and analysing data obtained from the baseline mapping tool, as the robustness of this would depend very much on the integrity of the data used to inform the mapping tool.

2.144 Respondents also made a number of suggestions in relation to the requirements for developing any mapping tool, including the need for:

clear assumptions underpinning the metadata associated with mapping tool;
basing the tool on standing boundaries, as held in the Register of Sasines for Scotland;
ensuring that data is open source, free and accessible to all stakeholders.
compatibility with other systems, and ease of use;
flexibility and regular updates to respond to new and changing ecosystems services;
capacity to accept data from a variety of sources;
using a common protocol to ensure data is comparable and GIS compatible; and
making the mapping tool available through Scotland's Environment Web.

Implementing an ecosystems services mapping tool

2.145 Although supportive of the proposal to develop a baseline ecosystems services mapping tool, respondents also made a number of additional comments and suggestions.

2.146 One local authority highlighted that one of the key lessons from its land use pilot, was that a standardised approach could be adopted across Scotland using national datasets that could be refined using local data. Another local government organisation suggested that to be effective, the tool should be hosted, operated and updated centrally, with datasets being uploaded by local authorities that had the resources to undertake baseline studies.

2.147 On the other hand, another local government organisation commented that the ecosystems services approach was not widely understood outwith academic and professional circles, and suggested that access to training and examples of best practice would be essential to support the implementation of this type of mapping tool across Scotland.

2.148 A small number of third sector respondents (3) made the point that some services could be more robustly quantified than others e.g. timber production compared to cultural services, and this could make the mapping of some services more complex. Related to this, a public sector respondent said that based on its experience of working with the land use pilots in Aberdeenshire and the Scottish Borders, any mapping tool relating to cultural services needed to go beyond simply identifying assets with an area. It suggested that consideration would also need to be given to non-material and intangible benefits from services, and this could be challenging to map.

2.149 On the other hand, a small number of third sector (woodland and environment) respondents highlighted the usefulness of the Borders pilot in investigating the interactions between different land uses and the delivery of multiple ecosystems services, and therefore recommended that this be rolled out further as a baseline. However, another individual respondent proposed that more research would be required to be certain that a given land use or vegetation pattern would provide a specific service.

Link to other GIS mapping frameworks

2.150 A few respondents (3) suggested that it would be useful to link this type of mapping tool to the other GIS mapping frameworks referred to in Q7a. In particular, two respondents said that linkages should be made to the mapping tool already developed by the Historic Environment Scotland, to map the historic dimension of land use (HLAmap.org.uk). Whereas a research organisation proposed that it would be useful to work towards integration with the Register of Land and Property in Scotland.

2.151 One representative or professional body respondent also highlighted that there might be potential for future connection to Scotland's Land Information System (ScotLIS). In the same way, a third sector (other) organisation proposed that the mapping tool should be linked to the development of a sustainable food atlas.

Greater co-ordination in regional land use planning

2.152 Two third sector respondents particularly welcomed the development of a baseline mapping tool for ecosystems services, stating that this would be an essential step in ensuring a systematic and co-ordinated approach to regional land use planning. These organisations also felt that this would help to reduce the burdens on local authorities.

Key reasons for not supporting the development of a baseline mapping tool

2.153 A few respondents (4) indicated that they did not support the proposal. One individual respondent raised concerns about the costs associated with such a proposal, whereas another individual felt the approach was overly complex.

2.154 Some of the respondents who indicated that they didn't know whether this approach was helpful provided additional comments. One public sector respondent felt that the language used in the consultation paper needed to be clearer, and this might help to foster a better understanding of the benefits of such a mapping tool. A small number of third sector respondents (2) stated that it would depend on what the tool was to be used for e.g. directing SRDP funding, and whether the right data was available to develop it.

2.155 Finally, two respondents who did not express a view either way, also made a few additional comments. One third sector organisation noted that more sophisticated approaches to the analysis of land use already existed, and was surprised that these had not been covered in the consultation paper. Another third sector respondent made the point that the most benefits would be delivered through stimulating dialogue between those stakeholders with differing interests and perspectives.

Regional Land Use Partnerships

Q8a Do you agree that regional land use partnerships could be a helpful way to support regional delivery of the Land Use Strategy?

	Yes		No		Don't know		Total answered*	Not answered
Individual	34	81%	3	7%	5	12%	42	12
Public sector (national or local government)	13	68%	3	16%	3	16%	19	5
Other public sector	7	100%	0	0%	0	0%	7	3
Third sector (woodland and environment)	15	79%	1	5%	3	16%	19	3
Third sector (other)	13	81%	2	13%	1	6%	16	3
Representative or professional body	4	50%	1	13%	3	38%	8	3
Private sector	4	57%	1	14%	2	29%	7	2
Academic or research body	4	100%	0	0%	0	0%	4	1
Other	6	86%	0	0%	1	14%	7	5
Total	100	78%	11	9%	18	14%	129	37

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.156 Most respondents (129) chose to answer the question. Of those, the majority (78 per cent) agreed that regional land use partnerships would be useful in delivering the LUS at a regional level. Just eleven respondents disagreed with this, and 18 did not know.

2.157 Respondents with an interest in farming were least likely to agree with this proposal.

Q8b Who do you think could be best placed to lead these initiatives?

2.158 Respondents who were supportive of the creation of regional land use partnerships felt that this would help to bring together all interested parties. However, some stressed it would be important to ensure that the regional distribution of these partnerships was appropriate, practical and based on meaningful geographic divisions. Others called for a flexible approach to be adopted, so that partnerships could be developed to respond to local circumstances. For example, one private sector organisation suggested that rather than being based on local authority boundaries, it might be better to define 'regions' by landscape/ water catchment level.

2.159 A number of respondents (from across respondent categories) felt that it made sense to build on existing structures, rather than to create additional structures and provided a range of suggestions, as detailed below:

Local authorities;
Community planning partnerships;
Coastal or river catchment partnerships;
Local biodiversity partnerships;
SEPA Area Advisory Groups;
Regional Forestry Forums; and
Local LEADER Advisory Groups.

2.160 Although supportive of the proposal, one other public sector respondent suggested that regional land use partnerships may not always be required, and would depend on the requirements of the different regions, whether there were existing groups, and who the key stakeholders were.

Bottom-up approach

2.161 Some respondents (mainly other and third sector organisations) recommended that structures should evolve from the 'bottom-up', rather than being imposed by national or local government. These respondents also suggested that the membership of these partnerships should ensure equal representation from across key stakeholders i.e. landowners, community groups (place and interest), community councils, planning and land experts, government agencies etc. Individual respondents underlined the importance of having local people, as well as experts, represented on regional partnerships. However, their views were mixed in relation to whether local elected representatives should be on the partnerships.

Leadership role

2.162 Respondents made a number of different suggestions as to who should play a leadership role, for example, local authorities, strategic development planning authorities, national park authorities, Highlands and Islands Enterprise, Scottish Natural Heritage, SEPA etc. Respondents (mainly public sector and representative organisations) felt that these bodies would ensure that transparency and accountability was built into decision making and governance arrangements. Others (mainly research organisations) felt that local authorities and national park authorities might have a useful role to play in supporting the development of these partnerships, but might not be best placed to lead them. Some respondents (mainly other and third sector organisations) suggested that community bodies and Community Development Trusts should be encouraged and given support to develop these initiatives in partnership with local land managers.

Funding and support

2.163 Respondents (from across respondent categories) highlighted that no matter how the regional partnerships were constituted, it would be important to ensure that they were properly funded and resourced. Some respondents (7 - mainly local government organisations) expressed concern that without adequate funding, the resourcing of these partnerships would be challenging given current funding pressures, and might deter some local authorities or others from establishing regional partnerships. A small number of third sector organisations (2) proposed that the LUS Action Plan should set out in more detail how the proposed regional partnerships would be resourced, facilitated and supported.

Clear remit

2.164 A few local government organisation respondents (4) noted that the draft LUS did not provide details of the proposed remit and powers of the proposed regional partnerships. These respondents felt that the role of the partnerships needed to be clearly set out to avoid overlaps with other competing activities related to land use. In addition, one local authority suggested that the relationship between regional land use strategies and other policies, plans and strategies e.g. strategic development plans, local development plans, Green Strategy Networks would also need to be made clear.

Good practice examples

2.165 A number of respondents (mainly third sector and research organisations) (7) highlighted the Tweed Forum - part of the Scottish Borders LUS pilot - and the Galloway and Southern Ayrshire Biosphere as examples of good practice (both of these examples are based on river catchment areas). Other examples of good practice were also highlighted e.g. the Shetland Islands Marine Spatial Plan, the Southern Uplands Partnership and the Tomintoul and Glenlivet Landscape Partnership.

Concerns

2.166 One local government organisation that disagreed with the proposal questioned whether regional land use partnerships were necessary, and how much they would add to the process. Similarly, a third sector organisation felt that the form, purpose and scope for the partnerships was unclear, and was likely to place even greater burdens on partners.

2.167 One representative or professional body respondent and another local government organisation suggested that the proposal to set up regional partnerships needed further consideration, particularly in relation to the links with strategic development planning authorities, community planning partnerships, strategic planning in the four city regions and the emerging community empowerment agenda.

Q8c Can you suggest any alternative means of supporting the delivery of the Land Use Strategy at regional level?

2.168 Respondents were invited to suggest alternative methods for delivering the LUS at the regional level. Their comments are summarised below:

Scottish Government should undertake a mapping exercise to look at which partnerships are already in place within regions, and to identify where the gaps are.
Build on what is already there and to use existing groups to deliver LUS at the regional level e.g. Tweed Forum, Woodland Forums, Local Access Forums, Regional Forestry Forum and SEPA Integrated Catchment Management Groups.
Strategic Development Planning partnerships could be resourced to deliver LUS at the regional level, particularly for the four city regions.
Community Planning Partnerships could play a key role.
All regional or local groups that use or influence the land should adopt Sustainable Land Use Principles.
People with local land use experience could be appointed to panels to provide advice and assistance in delivering LUS.
Land use champions should be embedded in other existing regional or local forums.
There should be dedicated resources to support local facilitation - this could make a significant difference to the delivery and success of land management partnerships.
Regional initiatives could be led by local professionals involved in land management - appointed on a voluntary basis and endorsed by a professional body like the Royal Institution of Chartered Surveyors (RICS).
Consideration should be given to regional partnerships having a role in targeting SRDP funding, consideration should be given to aligning funding incentives to regional land use.
River basin management planning and catchment management planning could provide a means of delivering the LUS at the regional level.
It would be beneficial to develop a toolkit to promote best practice and consistency in approach.

Q8d Do you have any other comments on this policy?

2.169 Respondents were invited to make any additional comments. Their responses are summarised below:

There is a need for clear guidance on the remit and scope of regional partnerships, as well as clarity on what is expected of these partnerships.
The resourcing and delivery of regional strategies should be spelled out in more detail in the revised LUS - without adequate resourcing, it is unlikely that the partnerships will deliver what the Scottish Government expects.
The learning and outcomes of the two LUS pilots should be circulated more widely - this could help to inform the development of new pilots or establishment of regional partnerships.
More work needs to be done to demonstrate how regional partnerships could contribute to decision making - so that they don't end up being 'talking shops'.
Regional partnerships will require clear mechanisms to ensure communities are involved and can exert an influence.
Regional partnerships will need to ensure consistency and co-ordination with existing regional level planning partnerships.
The community land sector is growing and could play a key role in LUS delivery.
If the set-up of regional partnerships is not to be funded by Scottish Government, there is no point in being prescriptive about the size and scale of partnerships. However, it would be beneficial to ensure a minimum size so that a landscape approach can be promoted.
More power and purpose should be given to community councils.
The idea of setting up regional partnerships is good, but it will be hard to ensure that it will be implemented properly.
It may be better to look at using incentives to achieve particular outcomes - if the incentives are right, the actions will follow.

Regional Land Use Frameworks

Q9a Do you think that regional land use frameworks could be useful to inform regional/local land use decision-making?

	Yes		No		Don't know		Total answered*	Not answered
Individual	22	59%	4	11%	11	30%	37	17
Public sector (national or local government)	14	74%	1	5%	4	21%	19	5
Other public sector	6	100%	0	0%	0	0%	6	4
Third sector (woodland and environment)	16	84%	0	0%	3	16%	19	3
Third sector (other)	10	67%	1	7%	4	27%	15	4
Representative or professional body	6	86%	1	14%	0	0%	7	4
Private sector	5	71%	1	14%	1	14%	7	2
Academic or research body	5	100%	0	0%	0	0%	5	0
Other	6	86%	0	0%	1	14%	7	5
Total	90	74%	8	7%	24	20%	122	44

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.170 Most respondents (122) chose to answer the question. Of those, the majority (74 per cent) agreed that regional land use frameworks could help to inform regional/ local decision making. Just eight respondents (seven per cent) disagreed with this, and twenty-four (20 per cent) said they did not know.

2.171 Respondents with an interest in farming were least likely to agree with this proposal.

General comments

2.172 Overall, respondents who were supportive of the proposal felt that regional land use frameworks would help to bring stakeholders together and build a better understanding of land use issues, competing interests and priorities, and also get communities involved in decision making about their local areas. A few local government organisations (4) noted that the frameworks would provide a clear strategy for land uses that were outwith the statutory the planning system, and would also enable a comprehensive approach to managing a range of land use priorities e.g. flood risk, biodiversity and energy development. One other public sector respondent added that regional frameworks had the potential to help stakeholders understand and evaluate the impacts of land management on ecosystems services, and the trade-offs involved in certain decisions.

2.173 Although supportive of the proposal for regional land use frameworks respondents raised some general concerns. A few respondents (3) noted that it would be important that the frameworks were set at the right scale, and that 'a one size fits all' approach would not work. These respondents called for clearer guidance on how 'regions' were to be defined. Three third sector organisations sought clarification on why the frameworks were only to be applied to rural areas, since land use in peri-urban and urban areas could be just as complex.

Q9b Which aspects of this approach do you think require further development?

2.174 Respondents also provided a number of suggestions and comments on areas where the regional framework approach required further development.

Effective community and stakeholder engagement

2.175 Many respondents from across respondent groups (11) highlighted the importance of having the right people on board including, land owners and managers, farmers, NGOs, and community groups. These respondents felt that this part of the consultation paper needed to be developed further to ensure that effective engagement processes could be developed and implemented. In particular, one local authority noted that from its experience of the LUS pilot, ensuring effective engagement was vital for securing wider participation in decision making processes. An other public sector respondent suggested that the guidance being developed to support part 4 of the Land Reform (Scotland) Bill relating to engaging communities in decisions, might be helpful in this context. In addition, a representative or professional body respondent noted that if regional frameworks were to be used to inform strategic and local development plans, then engagement would need to be carried in conjunction with planning authorities.

Alignment with existing policies, plans and strategies

2.176 Some respondents from across respondent categories (9) proposed that further work would be required to look at how the proposed regional frameworks could be aligned with existing plans and strategies, including:

Strategic and local development plans
Forestry and woodland, agriculture, biodiversity or flood risk strategies;
River basin management plans;
Regional marine plans; and
Energy renewal action plans.

2.177 One private sector respondent said that the regional frameworks must not add an additional layer of regulation and bureaucracy to what was already there. Whereas a local government organisation called for clarity on how the regional frameworks would relate to strategic and local development plans in particular, as this had the potential of creating confusion and duplication.

Access to data and mapping tools

2.178 Some respondents (mainly public sector and third sector organisations) (7) said that more consideration should be given to the types of information and data that would be required to support the development of regional frameworks, and that lessons should be learned from the experience of the LUS pilots. These respondents suggested that Scottish Government should lead on the development appropriate and improved GIS mapping tools, and also seek to improve access to robust baseline information.

Influencing funding decisions

2.179 A few respondents (5 - mainly third sector organisations and individuals) proposed that more consideration should be given to developing a mechanism that would allow regional frameworks to inform decisions about funding e.g. SRDP or LEADER programmes. One of these respondents felt that this was the only way that the regional frameworks would be taken seriously.

Learning from LUS pilots

2.180 A few respondents (5 - mainly third sector organisations) called for more to be done to disseminate the lessons and best practice that had emerged from the evaluation of the two LUS pilots. One of these respondents also suggested that Scottish Government needed to commit to a delivery phase beyond the initial pilot phase.

Guidance and support

2.181 A few respondents from across respondent categories (5) said that more consideration needed to be given to providing detailed guidance to support the development of regional frameworks. Some of these respondents felt that the language used in the consultation paper was not clear, and therefore more guidance would be needed on what the frameworks should cover, and how they should be developed. One research organisation suggested that it would be helpful to have a Land Use Pilot Toolkit.

Concerns

2.182 Eight respondents said that they did not support the proposals in relation to regional frameworks. The main concerns raised by these respondents were that it was not clear what the benefits might be, and it was felt that the regional frameworks would be resource intensive to produce, particularly in view of the number of stakeholders likely to be involved.

2.183 Some respondents who said they did not know whether they supported the proposal felt that there was not enough information in the consultation paper to be able to comment fully. Others suggested that further clarification would be required on a number of issues, including:

Leadership and purpose of regional frameworks;
Interface with strategic and local development plans;
Geographic coverage and scale of regions;
Status of regional frameworks;
Resourcing to support regional frameworks; and
Impact on local development.

Q9c Do you have any other comments on this proposal

2.184 Respondents were invited to make any additional comments. Their responses are summarised below:

Consideration needs to be given to the resources that will be required to develop regional frameworks - a particular issue given the current constraints on public finance.
Regional frameworks would only be of value if there is a distinct hierarchy flowing from national to regional to local.
Need to outline the value and benefits that could be derived from producing regional frameworks - both to justify resources likely to be involved, and to get buy-in from stakeholders.
Need for clarity on appropriate scales for regions and how best to align information available at different scales.
Regional frameworks will need to be flexible enough to adapt to the particular characteristics of each region.
Need for greater clarity on the land use changes that require to be considered as part of the regional framework.
Landscape Character Assessments and reports should be used to inform the development of regional frameworks.
Sensible to bring sometimes competing strategies together e.g. forestry, biodiversity and farming through a single LUS - but more clarity of purpose and vision required.
The overall profile of land use needs to be raised and a greater appreciation of the need and value of regional frameworks will need to be developed.
Strong leadership will be essential to ensure the most appropriate priorities are identified across a range of land uses.
More clarity required on which aspects of land use decision making are being referred to in the consultation paper i.e. does this relate to decisions currently made by planning authorities?
There is a need for guidance to support the implementation of the LUS on the ground.
Regional frameworks will only achieve their objectives if they have balanced input.
Insufficient evidence has been presented to justify the proposal for regional frameworks.
The language in the consultation needs to be simplified, there is too much jargon.

Land Use Mediation and Facilitation

Q10a Do you think that land use mediation or facilitation could be useful in a land use context?

	Yes		No		Don't know		Total answered*	Not answered
Individual	30	75%	4	10%	6	15%	40	14
Public sector (national or local government)	13	81%	0	0%	3	19%	16	8
Other public sector	5	83%	0	0%	1	17%	6	4
Third sector (woodland and environment)	17	94%	0	0%	1	6%	18	4
Third sector (other)	16	94%	0	0%	1	6%	17	2
Representative or professional body	8	100%	0	0%	0	0%	8	3
Private sector	6	86%	0	0%	1	14%	7	2
Academic or research body	3	100%	0	0%	0	0%	3	2
Other	5	83%	0	0%	1	17%	6	6
Total	103	85%	4	3%	14	12%	121	45

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.185 A total of 121 respondents answered this question. Of these the majority (85 per cent) said that they agreed that mediation or facilitation could be useful in a land use context, three per cent said they disagreed and twelve per cent said they did not know. The respondents who were most likely to agree were from academic or research bodies, representative or professional bodies and the third sector. Individuals were the only respondents to disagree.

2.186 Respondents with an interest in education or local communities were most likely to agree with this proposal.

2.187 The majority of respondents felt that mediation and facilitation were useful tools when there were competing interests and opposing views. Some respondents discussed mediation and facilitation together, others felt they were two separate processes and discussed just one, or discussed them separately.

2.188 Respondents across categories agreed that facilitation helps parties gain a better understanding of different views and helps to resolve differences. However, they noted that land use was a hotly debated topic with numerous deep-rooted tensions. A few respondents noted that the new Land Reform legislation may be the cause of future issues and that facilitation and mediation would be required.

Use of mediation and facilitation during disputes

2.189 Some respondents stated that they thought mediation was helpful during conflicts and felt that mediation was a useful tool for helping parties find common ground. Two respondents stated that mediation and facilitation would prevent projects from stalling and ensure timely progression.

2.190 Most respondents supported the idea of facilitation, particularly as a means to prevent conflict occurring or escalating. Five respondents felt that facilitation should be part of procedures from the beginning of a project, and that neutral independent facilitation could prevent the need for mediation due to conflicts later in the process.

2.191 One of the main reasons that respondents agreed with mediation and facilitation in a land use context was because they felt it would help parties to avoid turning to court proceedings in the event of disputes. Two respondents noted that legal action was often beyond the financial capacity of people involved, and so mediation was a welcome alternative. Respondents felt it would be faster, less expensive and more flexible to employ mediation than to litigate. Two respondents supported facilitation because they felt it would empower communities and organisations in land use dialogues.

2.192 Two respondents from third sector (other) category felt strongly that the focus should be on facilitation rather than mediation of disputes. And seven respondents, mostly from the third sector, stated that mediation should only be undertaken in exceptional circumstances or as a last resort.

2.193 However, seven respondents also noted that not all conflicts could be resolved through these methods. Respondents offered alternatives including subsidies, compensation and a publicly run land and property arbitration service. Four respondents specifically mentioned the Tweed Forum as a good practice example. One private sector organisation noted that although facilitation/mediation may not solve all issues, it might help ease the process towards final decisions. Four respondents noted that the use of facilitation/mediation would depend on the context of the project and the nature of any conflicts that might arise.

Lack of detail

2.194 Although respondents agreed on the whole, five respondents felt there was a lack of detail in the Strategy about how, when and through whom these processes would be utilised. Four respondents commented on the costs associated with facilitation and mediation and were unsure where these would come from.

2.195 Five respondents, from the public sector, third sector and individual categories questioned how the proposal would interact with other similar processes such as charrettes or the Place Standard. They felt that any facilitation/mediation would need to work with existing processes and services. And one respondent commented that any process would need to build on other models of good practice models from other fields (such as housing or social work).

2.196 Six respondents noted that they would be happy with the proposal provided that mediation and facilitation was balanced and provided by people that were experienced and knowledgeable in land use and management. Three individuals were keen to ensure that all views were given fair representation and that a facilitation process would help to rebalance the power.

2.197 A small number of respondents commented on who they felt should have the ultimate decision on land use. There were mixed views, with one respondent feeling strongly that land owners should have final say, another feeling that the government should and one feeling unsure.

Other comments

2.198 Five respondents spoke of the regional land use partnerships and felt that these partnerships should be used to implement this proposal and one respondent felt that facilitation and mediation should act as a back up to the partnerships.

2.199 Two respondents from the other category were hopeful that facilitation and mediation in the context of land use would help protect and sustain healthy ecosystems and biodiversity for the future.

2.200 One individual noted the use of language in the proposal that separates land owners and the community, and assumes that land owners will have conflict with the community they are part of. And one organisation felt that the definitions of all terms need to be clearly outlined.

2.201 Of those who disagreed with the proposal, one individual (a land manager) said they had not yet came across a time when this would be useful, as people with strong views were usually only moved by the law. Another individual felt that the LUS should preserve ecosystems and environment and that mediation and faciliation may not help to achieve the type of change required.

Applying the Principles

Agriculture

Q11 Do you have any suggestions on other potential measures to encourage climate friendly farming and crofting?

2.202 A total of 110 respondents answered this question. Of the 67 organisations that responded, all were supportive of the focus on climate friendly farming and crofting. And of the 43 individuals that responded, the majority offered suggestions for potential measures to encourage climate friendly farming and crofting.

Diversification of land use

2.203 The most common measure suggested was to encourage more climate friendly farming and crofting, was more mixed land use. A large number of respondents across all categories (27) stated that a shift away from mass production farming methods to more local scale production practices involving mixed land use, would have a positive impact on the environment. Respondents felt that farmers should be encouraged to make the best use of their land by combining food production with other land uses such as farm woodlands and flood management. Respondents said that mixed land use could also involve organic farming, more crop rotation, and smaller herds and flocks.

2.204 Many respondents (16) highlighted that tree planting on farmland was important to help mitigate climate change. While some respondents (10) felt that Agroforestry was a well evidenced method of carbon sequestration and the establishment of farm woodlands could help reduce the force of water flows, and give shelter to livestock and crops. One respondent highlighted a farmer-led project in Wales, involving the planting of woodland shelterbelts, which had significant benefits for livestock and reduced water run-off from fields.

2.205 Other ways to diversify land use were suggested. A few respondents (3) said that by supporting the promotion and protection of historic environment assets on farm and croft land, land owners could diversify land use. To achieve fully integrated land use, a few (2) respondents said that the role of biodiversity must be considered. Others (2) suggested that breaking up big farms and making more farm land available to individuals would help to diversify the farming sector and mitigate the effects of climate change.

Policy context

2.206 A large number of respondents (24) said that the policy framework surrounding climate friendly farming and crofting should be addressed more clearly in the LUS. Some (6) felt that there was a need for LUS measures to link more strongly to CAP measures, such as the CAP Pillar 1 greening requirements and cross compliance including Good Agricultural and Environmental Conditions. A few respondents (3) believed that CAP reform needed to be addressed within the LUS so that agricultural and environmental messages did not conflict and were not overly complex.

2.207 Some respondents (6) stated that work towards climate mitigation should be guided by the UK National Ecosystem Assessment. They felt that High Nature Value farming and ecosystems approaches to farming and forestry should be recognised and incorporated into the LUS. A few (2) respondents said that framing these approaches within the regional land use framework model would improve land use decision making.

2.208 The Scottish Government's Farming for a Better Climate (FFBC) initiative was felt to be useful by some (6). However a few respondents (2) felt that the voluntary approach to climate friendly farming advocated by FFBC was not enough and that the Scottish Government should consider the use of incentives and regulation to ensure the adoption of climate friendly practices. More generally, one respondent felt that that Scottish Government could be a much stronger driver of reform of climate mitigation agricultural policy and practice. For example, it could introduce an integrated food and farming strategy, in alignment with LUS Principles. Other respondents (2) agreed that the Scottish Government needed to show stronger leadership in this area. They felt that debates to date have been too broad and unfocused to effect real change.

2.209 Other potential policy measures mentioned by two respondents included policies to ensure regular soil testing and fertiliser management planning by all farmers, increased uptake of precision farming technologies and equipment facilitated through the provision of zero interest Government loans, and policies promoting recycling of nutrients to minimise waste and pollution.

Financial incentives and support

2.210 A large number of respondents (21) suggested that farmers and crofters should be financially incentivised or supported to adopt more climate friendly approaches. It was felt that to expect them to switch their practices at a cost would be unlikely, as agricultural margins are already tight. Therefore climate friendly agricultural policies should be accompanied by appropriate grant support or subsidies. A few respondents (4) said that only environmentally sustainable farming methods should be subsidised.

2.211 Some respondents (6) talked about the Payment for Ecosystems Services (PES) offered to farmers, crofters and land owners for managing their land using an ecosystems approach. They felt that this concept needed to be better developed. For example, annual payments could be made for controlling carbon and mitigating flooding by maintaining healthy peatlands and expanding farm woodlands; and encouraging pollination, agroforestry, biodiversity, tourism, good soil, water and air quality.

2.212 Five respondents said that the agricultural funding structure was key to influencing on-the-ground farming and crofting activity. A few (2) felt that the current grant system was a barrier to the uptake of environmentally friendly approaches. One said that SRDP can be unattractive due to restrictive funding processes. Another felt that clear codes of practice, delivering genuine climate friendly farming, should be implemented as the basis for famers receiving financial support through CAP and SRDP.

Advice provision and knowledge sharing

2.213 Some respondents (10) felt that a shift towards climate friendly farming and crofting required better awareness raising. A few (2) said that farmers, crofters and land owners needed to feel part of a cross-sectoral focus on climate mitigation, rather than singled out. Another said that while written materials were available, conversations were much more valuable to practical people like farmers. Several people (5) said that word of mouth among peers is very important in the agricultural sector, and suggested establishing a peer-to-peer farmer / crofter-led knowledge exchange network. Two people felt that knowledge transfer initiatives involving land managers and research institutes could have significant impact. Some (6) felt that the LUS could do more to shape an advice provision service to farmers, crofters and land owners.

2.214 Learning from existing approaches to climate friendly farming was mentioned by some respondents (8). Demonstration farm initiatives, including climate change Focus Farms, were thought to be useful in raising awareness of better environmental practices. A few respondents (2) felt that the LUS had omitted the important role of advice, extension and demonstration farms in addressing climate change mitigation. They said that farmers, crofters and land owners need to see farm-based evidence that reducing emissions and cutting waste will improve efficiency and profitability.

2.215 Some respondents (8) believed that to progress the climate friendly farming, there should be more investment in education. A few (5) felt that more relevant education and training was required to achieve a culture shift in farming and better appreciation of ecosystems. Two respondents suggested developing a national training programme in agroecology principles. Others (2) highlighted the success of Wildlife Estates Scotland (WES) accreditation, which has recently been recognised as being a deliverer of LUS Principles.

Food production

2.216 A commonly mentioned suggestion (12) for achieving more climate friendly farming was encouraging more sustainable methods of food production. A few (2) respondents felt that rural and urban, domestic and commercial food producers should be required to comply with environmentally sound practices. Another felt that rural Scotland could suffer as a result of excessive food consumption in urban areas. Some felt that smaller scale food production could help to achieve a culture shift in attitudes towards sustainable food production.

2.217 Reducing food miles as a way to contribute towards climate friendly farming was highlighted by a few (2) respondents. This would have to involve both exports and imports, and the possibility that food prices would rise in the future.

Partnership working

2.218 Some respondents (7) stated that partnership working in the agricultural sector was essential to progressing the climate change mitigation agenda. While some (5) highlighted Land Use Partnerships as the key driver of more integrated land use. They felt that farmers, crofters, land managers and foresters will need to work more closely together to resolve differences of approach, find common ground and agree on compromises. Other respondents (2) highlighted the needs for greater partnership working between the agricultural sector and organisations including Scottish Water, for example on issues such as peatland restoration.

Livestock management

2.219 Some respondents (7) set out the need for continued research and development into animal nutrition to better manage digestive gases in livestock. Some respondents (3) suggested that much of Scotland's agricultural land was best suited to livestock production, and a national strategy promoting practices to reduce methane emissions from animal production should be developed. A few people (2) stated that to aid climate mitigation, farmers should be producing less red meat, especially in areas where crops can be grown. At the same time, the public should be encouraged to consume much less farmed red meat.

2.220 The issue of intensive grazing was raised by a few (3) who said that a reduction in the level of sheep and deer (and to a lesser extent cattle) grazing would allow the vegetation of upland environments to re-establish, and increase its ability to capture and store carbon. Two people thought that over grazing could be addressed through a regulatory framework.

Peatland restoration and soil management

2.221 Some respondents (6) said that soil management and peatland restorations needed to be recognised more widely as potential carbon offsets. They suggested that there should be further investment into the restoration of wetlands and peat bogs, which retain stored carbon from the atmosphere. A few (4) highlighted that the crofting counties in Scotland are home to the country's largest natural carbon stores in peat, and felt that there is more work to be done to understand the optimal agricultural methods for maximising carbon storage in peatlands.

2.222 Other respondents talked about the importance of good soil management for climate friendly farming and crofting. Two people felt that the LUS should contain more information on oil management, and the benefits of a reduction in the use of industrial fertilisers. Another said that in order to protect soils, there should be more emphasis on crop rotation, which could mean accepting lower overall crop yields.

2.223 Linked to soil management, a few respondents (3) said that the LUS should have a greater focus on water quality, as a key resource to fully utilise other natural resources including soil. Three people highlighted that reforestation to create buffer zones would help to reduce soil erosion, decrease water acidification and improve conditions for fish in water bodies. One respondent wanted to see more new reservoirs being established to store excess winters rainfall and to ensure steady supplies during drier summers.

Carbon management and monitoring

2.224 Many respondents (12) reiterated that farms adopting good carbon management approaches, within wider environmental practices, should be supported and subsidised. A few (2) recommended the use of carbon foot printing tools, alongside the development of more ecosystems assessment tools (e.g. the Peatland Condition Tool). This would help rate the climate mitigation contributions of farms. Other respondents (2) suggested that all farms should be required to conduct a carbon audit.

2.225 Some respondents (5) talked about the current carbon scoring system. One felt that this was often detrimental for extensive livestock systems, in terms of carbon output per kilo of meat. They said that this must be set in the context of the wider climate change and agricultural benefits of these systems, as part of a truly integrated land use policy.

Other issues

2.226 Some respondents (8) made additional suggestions to further mitigate climate change. A few (2) felt that the LUS could give more consideration to wildlife friendly farming and crofting. Without this they did not believe that Scotland could become a world leader in greener farming. Again subsidies were suggested to encourage farmers to decrease the loss of biodiversity on their land. In relation to this, a few people (2) stated that the most harmful pesticides should be permanently banned, as they are harmful to bees and the wider ecosystem. They said that pesticide use should be reduced in general, despite potentially lower yields.

2.227 Two respondents mentioned the issue of tenant farmers, suggesting that presently tenant farmers are not rewarded for investing in their farms. They suggested that if tenant farmers were to be compensated for the value of improvements they make, including adopting climate friendly farming methods, this would benefit the sector overall.

2.228 One individual said that they would like to see a database of land ownership in Scotland by 2020. Another highlighted the dangers of heavy machinery use, including air pollution and soil damage.

Agri-Environment

Q12a Do you agree that more localised map-based ecosystems assessments could be useful to assist in informing funding decisions?

	Yes		No		Don't know		Total answered*	Not answered
Individual	26	63%	6	15%	9	22%	41	13
Public sector (national or local government)	11	73%	0	0%	4	27%	15	9
Other public sector	7	100%	0	0%	0	0%	7	3
Third sector (woodland and environment)	14	78%	0	0%	4	22%	18	4
Third sector (other)	9	90%	0	0%	1	10%	10	9
Representative or professional body	6	75%	0	0%	2	25%	8	3
Private sector	6	100%	0	0%	0	0%	6	3
Academic or research body	3	100%	0	0%	0	0%	3	2
Other	4	80%	0	0%	1	20%	5	7
Total	86	76%	6	5%	21	19%	113	53

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.229 In total, 113 (68 per cent) of respondents answered this question. Of these, the majority (76 per cent) agreed that more localised map-based ecosystems assessments could be useful to assist in informing funding decisions. Only 6 respondents - all individuals - disagreed with this question, and did not know.

2.230 Respondents with an interest in farming and deer and game management were least like to agree with this proposal.

Funding

2.231 Of those who agreed, the most talked about theme was the relationship between a map based ecosystems assessment and the agricultural funding process. A large number (around 30) respondents representing a range of organisational types discussed funding arrangements in some respect.

2.232 A large number of respondents from a range of respondent categories felt that more targeted funding facilitated by a map based ecosystems approach would be beneficial. Some respondents also pointed out that a localised map based ecosystems approach would be timely, considering the currently limited SRDP budget.

2.233 There was support for targeting funding toward measures which delivered the greatest impact. A few (3) local authorities as well as a mix of respondents said that more localised ecosystems mapping would help deliver good value for money and multiple benefits, including increasing buffer zones, increasing woodland cover and restoring wetlands. They felt that this could encourage smaller scale land owners and managers to apply for SRDP funding because reward would be linked to effectiveness rather than scale. One other public sector respondent felt that localised mapping information would be used to assist with targeting support payments, which would ensure that local, regional and national priorities informed decision making. A few respondents suggested that ecosystems mapping should be holistic, taking into account not only geography, but also farm type or system.

2.234 In one example, a respondent highlighted the LUS pilot in the Scottish Borders, which demonstrated that GIS maps have a fundamental role in helping to target SRDP funding.

2.235 One respondent from a third sector (woodland and environment organisation) stated that the previous SRDP was biased in favour of large land owners, but felt that implementing a more localised map based ecosystems assessment approach could help ensure that funding should go where it would be of ecological benefit. A local authority said that using GIS data to target funding could facilitate a more consistent approach for the assessment of funding applications. A respondent from a representative or professional body believed that it would provide a sound basis for justifying funding decisions through the SRDP, in a more transparent way.

2.236 A third sector (wooland and environment) respondent suggested that Scotland could move towards a system of Payment for Ecosystem Services to further ensure that agri-environmental schemes delivered the maximum benefits at landscape scale.

The map based system

2.237 Many respondents (19) from across respondent categories including both organisations and individuals, talked about the mapping system itself and what this should entail. Some discussed the level of detail that such a system should offer. A private sector respondent said that the map should be "zoomable to any level of planning need". They stated that there would be no need for individual local maps, rather all required detail should be available as a suite of overlay maps. A few respondents felt that the current system of PDF maps were difficult to use, and said that a new system should offer improved spatial resolution of data.

2.238 Some respondents (10) felt that the quality of the data that a map based ecosystems assessment was based on, was important. While these respondents agreed that such a system would be useful, they mostly felt that this depended on available data. One local authority said that the data used needed to be as accurate as possible, while other local authority and individual respondents felt that sufficient data for such a system did not currently exist or didn't scale down far enough. Others agreed that data accuracy was important, otherwise the system would be crude, and some sites which may be eligible for funding might fall outside targeted areas due to limited data sets. A few respondents from third sector (woodland and environment) organisations suggested that spatial targeting should be accompanied by rigorous sense checking.

2.239 One third sector (woodland and environment) respondent stated that there could be difficulties if some but not all regions in Scotland were mapped. If mapping was not carried out consistently across all areas, excluded areas could feel that they were being assessed differently in relation to funding.

2.240 One local authority respondent believed that while the system needed to be robust, it was important to progress with the approach now, with the best available information. Rather than waiting for perfect data sets and a finished model, this could evolve over time.

A combination of approaches

2.241 Some respondents (9), mainly from the third sector (woodland and environment) category and a few local authorities talked about the need to use a map based ecosystems approach as part of a wider range of tools. Some felt that a map based system should not replace advice and guidance that is currently available to land owners and managers.

2.242 Some third sector respondents said that spatial targeting was not suited to all objectives, and should be used alongside other tools. These respondents felt that human discretion and individual case reviews would still be required, especially where data was limited. For example, some sites could fall outside targeted areas due to lack of available or accurate data, and unless there was a system for review and exemption, some land owners and managers could suffer financially. One other category respondent said that site visits would still be necessary. And one third sector - woodland and environment respondent noted that maps were not a substitute for trained personnel, rather they could be used to inform assessors where to go to better assess outputs, impacts and issues

2.243 A few third sector (woodland and environment) respondents highlighted that spatial targeting was not appropriate for mapping data in relation to some species. Not all species were easily monitored, and numbers fluctuated due a number of factors including climate change. Maps would need frequent updates in these instances, and not all users would understand the margins of error.

2.244 A few respondents suggested other tools that could be used in conjunction with spatial targeting, and these included Whole Farm Plans, environmental maps, option eligibility criteria, framework and sectoral plans and strategies, local knowledge and professional advice and some forestry-specific tools (Ecological Site Classification Decision Support System and ForestGales).

2.245 A few organisations pointed out that historic environment assets could be integrated into the mapping system, to help identify sites of interest and incorporate them into a LUS. Respondents here felt that this would benefit the historic environment and also those economies depending on Scotland's unique cultural landscapes, and that it could further the enhancement and protection of the historic environment. Some commented that if land owners and managers did not know what assets they may have on their land, they could not contribute to the Historic Environment Strategy for Scotland.

Rolling out a map based ecosystems assessment approach

2.246 Four respondents from a local authority and representative or professional bodies talked about ways of engaging stakeholders in using a map based ecosystems assessment. One local authority respondent said that the system should be piloted with local communities to demonstrate its benefits and to gather feedback. Another local authority respondent felt that piloting the system specifically with crofting communities who have already mapped their land for the purposes of the Register of Crofts, would be useful. One person from a third sector (other) organisation suggested the development of a good practice guide or toolkit to help those who would use the system. Another representative or professional body respondent highlighted the need to market the tool to land owners and managers in such a way that they would understand that it was designed to help rather than hinder them. One local authority respondent believed that while the system could not provide a perfect model of land management (in terms of defining exactly what land management should take place on any given piece of land), it would be useful for engaging land owners and managers in the debate about regional priorities and the targeting of limited funds.

Accessible to all

2.247 A few respondents (4), including third sector organisations and one individual, talked about the need for a mapping system to be accessible to all. Organisations stressed that the system should be made available beyond the funders and decision makers; applicants and communities should also be able to see what the most appropriate funding options are and how communities would be impacted. These respondents called for the system to be transparent and open to all, and mentioned that people should be given opportunities to learn how to use it. It was felt that anyone with an interest in land use should be able to join the debate, and should be able to easily access the information needed to take part.

Challenges

2.248 Some respondents across all categories who agreed that a map based system would be useful, highlighted potential limitations and challenges of the system beyond data accuracy. One private sector respondent felt that the system could prove to be quite resource intensive, which would not make it attractive to land owners and managers. The system would need to be flexible according to a few (4) respondents, as there was concern that a rigid top-down approach could disadvantage some land owners and agricultural businesses.

2.249 Of those 26 respondents who answered that they did not know if a map based ecosystems assessment would be useful, the majority were unclear what the system would involve. Some local authorities said that they would not know if the system would be useful until they tried it. Some respondents, both organisations and individuals expressed concern over the cost of such a system, considering the limited agricultural funding available. One respondent from the other categorgy was not sure who would develop such a system and how its use would be supported.

2.250 Some respondents (6), all individuals, did not agree that a map based ecosystems assessment system would be useful. Two individuals felt that this was overly complicated and that using local knowledge and expertise would be a more effective way of delivering the same outcomes.

Agri-Environment

Q13a Do you agree that an assessment of ecosystems health and a spatial approach could be helpful to further inform targeting for the next SRDP?

	Yes		No		Don't know		Total answered*	Not answered
Individual	24	62%	6	15%	9	23%	39	15
Public sector (national or local government)	14	88%	0	0%	2	13%	16	8
Other public sector	6	100%	0	0%	0	0%	6	4
Third sector (woodland and environment)	11	61%	2	11%	5	28%	18	4
Third sector (other)	10	91%	0	0%	1	9%	11	8
Representative or professional body	6	75%	0	0%	2	25%	8	3
Private sector	5	83%	0	0%	1	17%	6	3
Academic or research body	2	67%	0	0%	1	33%	3	2
Other	5	100%	0	0%	0	0%	5	7
Total	83	74%	8	7%	21	19%	112	54

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.251 In total, 112 respondents answered this question. Of these, 74 per cent agreed that an assessment of ecosystems health and spatial approach to inform SRDP targeting would be helpful. Only seven per cent did not think it would be useful and 19 per cent were not sure about such an approach.

2.252 Respondents with an interest in farming or deer and game management were least likely to agree with this proposal, while those with an interest in general land manangement, environment and biodiversity were most likely to agree.

Support for targeted SRDP funding

2.253 The most common theme discussed in relation to this question was targeting SRDP funding. Respondents from across all categories commented on why they supported a change in the way that public money is spent in this area.

2.254 Most respondents indicated that an assessment of ecosystems health was central to understanding what the funding priorities of the next SRDP should be. These respondents felt that identifying and recording ecosystems health should be an important element of the LUS, and would help to target future funding. They thought that such an approach would target funding to areas which would produce the greatest public benefit, and provide the best value for money, and avoiding areas where positive outcomes from spending were unlikely. One representative or professional body respondent believed that a targeted approach would allow a focus on the highest priority ecosystems, before they were beyond restoration. A few respondents including one local authority, a private sector and an other public sector organisation, stated that this approach would make the best use of the limited public funding available.

Information available to support the decision making process

2.255 A few respondents (3) from the public sector (national or local government) said that such an approach had to be underpinned by the right information and environmental data. They felt that the decision making process regarding SRDP funding should be transparent and robust. They said it was important that information about accurate datasets was available to justify funding outcomes. One academic or research body believed that the integration of a wide range of data sources in targeting SRDP should improve its efficiency.

2.256 Many respondents (11) from across respondent categories (all except third sector (other) and private sector categories), who agreed with this question, detailed the types of information that would be required to support funding decision making. Two respondents, including an academic or research body and a third sector (woodland or environment) organisation, felt that there was data currently available to help the development of an ecosystems health and spatial approach. This included SEweb (Scotland's Environment Web), the Land Use Data Directory, and the Natural Assets Register. One third sector (woodland or environment) respondent said that existing spatial datasets such as the Native Woodland Survey of Scotland (NWSS) already informed forestry grants within the SRDP. A few representative bodies (3) for the historic environment agreed with this idea, and felt that information about historic environment assets should be incorporated into an ecosystems and spatial targeting approach. Currently they said that this did not happen, but that it should be considered for future SRDP schemes.

2.257 A few respondents (4) from other public sector, public sector (national or local government) and individual categories felt that an assessment of ecosystems health and a spatial approach was the right approach, but expressed some concern over the quality of the data available with which to achieve this. One other public sector organisation felt that ecosystems health involved a wide range of variables at a range of scales. They said that reliable qualitative data was not always available to assess this, and data could often be interpreted in different ways, which could affect targeting decisions.

2.258 Many respondents (11) from across categories incuding: academic or research bodies; other public sector; public sector national or local government; other third sector and third sector woodland and environment who agreed with this question talked about the ecosystems health measures and indicators required to underpin this approach. One academic or research body said that the development and implementation of an ecosystems health and spatial targeting approach was dependent upon a transparent and logical process of setting measurable ecosystems targets. It said that this would have to involve an acceptable definition of 'ecosystem health'.

2.259 A few respondents (5) from a mix of categories including other public sector, public sector (national and local government) and third sector (other) discussed how measures and indicators would be selected and agreed. One third sector (other) respondent said that for the approach to work, measurements and indicators or ecosystems health needed to be simple and accessible to all. They said that the right health indicators at the appropriate scale would need to be selected and agreed, to ensure that monitoring was accurate. Another third sector (other) respondent questioned how certain measures were to be decided upon, and by whom. All of these respondents agreed that measures and indicators needed to be appropriate and meaningful to ensure consistency.

Policy context

2.260 Some respondents (8) highlighted the policy context here. Four talked about CAP Pillar 1 and Pillar 2 funding. Two of these respondents (academic or research body and an individual) said that this approach should consider CAP Pillar 1 funding, including Areas for Natural Constraint and greening measures. A few of these respondents (academic or research body, representative or professional body, third sector - woodland or environment and an individual) also felt that the ecosystems health approach could help influence CAP reform, and increase funding streams into Pillar 2. One representative or professional body stated that the Pillar 2 package must work to address the adverse impact of area based payments under Pillar 1.

2.261 Other policy areas for consideration in relation to this approach, included Organisation for Economic Co-operation and Development. This was highlighted by one other public sector respondent who said that this could help the development of a more sustainable agri-environment policy where supply chains were shortened to stimulate local markets. One public sector (national or local government) respondent suggested that an ecosystems health and spatial targeting approach could also be informed by more local strategies, including a local authority level Woodland and Forestry Strategy, the Central Scotland Green Network and the local Agricultural Strategies. This respondent felt that these could help shape the development of agri-environment measures under the next SRDP.

2.262 One third sector - other respondent thought that the Environmental Co-operation Action Fund could be useful for informing this approach, while another respondent from the same category suggested the Incorporation of the Historic Environment Strategy for Scotland. An academic or research body also suggested some research which could be useful for developing this approach, under Scottish Government's Strategic Research Programme 2016-21. They explained that this research included work on natural assets, sustainable land management and food and communities.

Implementing the approach

2.263 Some respondents (7) had suggestions about how this approach could be effectively implemented. A small number of respondents (3), from the third sector (woodland and environment) and other categories, said that land use should be assessed at catchment scale, which would allow for recognition of wider issues such as diffuse pollution and help develop an understanding of how smaller sections of land could contribute to the healthy functioning of the wider ecosystems it sits in.

2.264 One respondent from the other category suggested that the approach be implemented in the context of other measures, including natural flood management measures, increased woodland cover and sustainable agricultural practices. Similarly, one local authority said that a spatial approach was only one tool to aid SRDP targeting. Other tools highlighted by another local authority which could be used in conjunction included local knowledge and expertise, whole farm plans and environmental maps.

2.265 One third sector (woodland and environment) respondent suggested that an advice service for farms would be useful in helping the implementation of the ecosystems health and spatial targeting approach.

Challenges and concerns

2.266 Many respondents (12) who agreed with this question also highlighted their concerns about the proposed approach. Some of these (5) came from private sector organisations. Concerns among these private sector respondents included:

one said that while the approach could be useful, ecosystems weren't stable and would be subject to much change in a very short space of time depending on a range of factors (such as crop values, land values and resource availability);
one felt that this approach could lead to an increase in the complexity and bureaucracy of the funding system, as a result of defining, assessing and mapping ecosystems health;
three respondents from the private sector agreed that care would have to be taken to avoid penalising those who had already instigated healthy ecosystems, and who may not therefore qualify for funding for further improvements. Further discussion would have to take place about the correct allocation of resources, either to protecting areas of high biodiversity and good health, or to areas where health or biodiversity could be restored; and
flexibility of the approach would have to be built in, for example in a situation where a project offered a beneficial solution which did not fit exactly with the parameters of the approach.

2.267 Some respondents from across most respondent categories were unsure if adopting an ecosystems health assessment and spatial targeting approach would be useful. Of those who commented in detail (mainly those from the third sector (woodland and environment category), some felt that it was unclear how accuracy of the assessment could be guaranteed.

2.268 One third sector (woodland and environment) organisation said that it had reservations about who would make the decision about whether or not a particular ecosystem was healthy. Another respondent from this category said that assessments could be overly reliant on data of variable quality. Another stated that other information would still have to be used, including farm management plans. One individual respondent stated that they were not convinced that the science behind defining and measuring ecosystem health was currently robust enough to underpin such an approach.

2.269 Some (8) from the third sector (woodland and environment) and individual respondent categories did not agree that the proposed approach would be useful. One third sector (woodland and environment) respondent said that the concept of ecosystems health was not sufficiently well developed or understood to form the basis of this approach. Two individuals agreed that ecosystems health was too vague a term to be used confidently. And two individuals felt that uncertainties over the UK's future within the EU might negatively affect such an approach.

Urban Land Use

Q14a Do you agree that an urban pilot project could be useful?

	Yes		No		Don't know		Total answered*	Not answered
Individual	27	71%	5	13%	6	16%	38	16
Public sector (national or local government)	15	83%	1	6%	2	11%	18	6
Other public sector	6	100%	0	0%	0	0%	6	4
Third sector (woodland and environment)	10	63%	4	25%	2	13%	16	6
Third sector (other)	11	85%	0	0%	2	15%	13	6
Representative or professional body	5	83%	0	0%	1	17%	6	5
Private sector	7	100%	0	0%	0	0%	7	2
Academic or research body	4	100%	0	0%	0	0%	4	1
Other	6	75%	1	13%	1	13%	8	4
Total	91	78%	11	9%	14	12%	116	50

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.270 A total of 116 respondents answered this question. Of these the majority (78 per cent) said that they agreed an urban pilot could be useful and nine per cent thought it would not. The remainder said they did not know. The respondents who most felt that an urban pilot would be useful were academic or research bodies, private sector respondents and 'other' public sector respondents. Individual respondents and third sector (woodland and environment) organisations were more likely to feel that it would not be useful.

2.271 Overall most respondents felt positively towards the idea of an urban pilot and welcomed the recognition that the LUS relates to all land, not just rural land. Many respondents stated that they felt a pilot would be essential to understanding the issues in an urban environment and gathering a baseline of information, to use and compare against rural environments.

2.272 Two organisations, one academic and one third sector organisation were also keen to be part of the pilot by sharing their knowledge and expertise or participating in the pilot.

Linking urban and rural

2.273 The top priority from respondents across the categories was the consideration of the urban-rural interface and peri-urban areas. Respondents felt the pilot would be useful as long as it acknowledged that urban areas could not be viewed in isolation - they are always connected to their rural hinterland, and vice versa.

2.274 One individual also mentioned that there were specific implications to be considered such as water/flood management that link urban and rural areas closely. And one other public sector respondent said that a pilot would be useful to understand the implications of changing urban land use on water quality and flooding.

2.275 Respondents hoped that the pilot would take into account and build on existing environmental schemes and strategies that are already occurring in urban areas - particularly local authority or third sector programmes on open space and green networks.

Relationship of LUS to existing planning and development regulations

2.276 Some respondents felt that the pilot should take into account the relationship of the LUS to existing development and planning strategies, feeling positive that a pilot would help to inform this relationship. These respondents were mostly public sector - national or local government (6) but also included private sector and third sector respondents.

2.277 Seven respondents felt that existing planning and development strategies already cover urban land use and take into account the LUS. They felt a pilot would be unnecessary and would duplicate what already exists. This view was mostly expressed by woodland and environmental third sector organisations.

2.278 A few respondents (3) from different categories stressed that the pilot must have clearly defined aims and outcomes.

Working towards future growth and development

2.279 Some respondents felt that a pilot would help plan future urban development and growth. Seven respondents felt that the pilot would help people understand how urban areas can better provide for the changing needs of urban populations, such as making better use of neglected, derelict and brownfield sites. Three respondents spoke specifically about the relevance of a pilot to improving housing plans through better use of urban land and ecosystems. And two respondents felt that the pilot might be useful given the increased interest in having green spaces and growing local produce.

2.280 Some third sector organisations and one 'other' organisational respondent felt that an urban pilot might provide the opportunity for more community involvement. One individual felt that it would be good if community groups could be involved but had concerns that local authorities may not be able to support them because of budget cuts.

2.281 One other public sector organisation and two individuals stated that a pilot might have a positive impact on health and wellbeing.

Differences between urban and rural

2.282 A mix of respondents addressed the need for a pilot to recognise that there are different challenges and issues to implementing an ecosystems approach in an urban environment than in rural environment. They felt that urban land was managed differently to rural areas and there were different influences. Three respondents also noted that there was variety even within the urban context and that this would need to be taken into account.

2.283 Two respondents agreed with a pilot but were not sure if an ecosystems approach would work well in a highly modified urban environment.

Location for the pilot

2.284 A few respondents gave suggestions for where the pilot could take place, including in an area where the urban environment has changed (e.g. loss of manufacturing industry) or on brownfield or derelict sites. One local authority volunteered itself and another thought that the authorities participating in the rural pilot would be best suited to taking on the urban land use pilot.

2.285 Other issues raised by respondents included:

One individual felt that the document focused on preserving rather than evolving ecosystems and disagreed that there should be a pilot.
One individual thought that land use depended on the future development of the area and disagreed that there should be a pilot.
One individual felt that an urban pilot would be fine as long as it did not take money away from the rural environment.
Two respondents stated that instead of an urban pilot, National Parks could be used as examples or case studies.
One individual agreed with a pilot as long as urban results were not applied to rural areas.
Two respondents wanted more radical land reform beyond the remit of a pilot project.
One individual felt that there have been enough pilots and that we should use the information already available.
One respondent felt that there were more important issues than an urban land use pilot that need to be addressed.
One respondent felt that the pilot should take into account the local food economy.

Upland Land Use

Q15a Do you think that a strategic vision could be useful for the uplands?

	Yes		No		Don't know		Total answered*	Not answered
Individual	38	88%	1	2%	4	9%	43	11
Public sector (national or local government)	17	85%	0	0%	3	15%	20	4
Other public sector	5	100%	0	0%	0	0%	5	5
Third sector (woodland and environment)	17	85%	0	0%	3	15%	20	2
Third sector (other)	9	69%	1	8%	3	23%	13	6
Representative or professional body	6	75%	0	0%	2	25%	8	3
Private sector	4	67%	1	17%	1	17%	6	3
Academic or research body	5	100%	0	0%	0	0%	5	0
Other	7	88%	0	0%	1	13%	8	4
Total	108	84%	3	2%	17	13%	128	38

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.286 A total of 128 respondents answered this question. Of these the majority (84 per cent) said that they agreed with the proposal of a strategic vision for the uplands. Just two per cent said they disagreed and thirteen per cent said they did not know.

2.287 The respondents who were most likely to agree were from academic or research bodies, other public sector and individuals.

2.288 The majority of respondents agreed that this was a welcome step to help offer direction and determine priorities for land use in the uplands with some feeling more strongly that it was vital and long overdue.

Q15b Do you have any comments on this proposal?

Definition of 'uplands'

2.289 Some respondents (7) from the academic and research, public sector local and national government, third sector (woodland and environment) categories along with one individual felt that the term uplands needed to be better defined as it can have different meanings and can refer to a range of areas and altitudes. However, one third sector respondent felt that a definition was not necessary in order to begin developing a strategy.

Why are the uplands important?

2.290 Respondents commented on the wide range of interests and uses of land in the uplands. These included environmental issues such as water and flood management, peatland restoration, carbon storage, wildlife conservation/ biodiversity, forestry and climate change. Two respondents from the public sector national and local government and a representative or professional categories also commented on the value of uplands towards employment, tourism, energy/renewable energy and communications. Overall, respondents felt that this wide range of interests, issues and multiple uses for the land needed to be accounted for in the Vision and Strategy. Most respondents noted that there is much regional and national value to the uplands and one organisation noted that the Scottish uplands have global value as well.

2.291 Some (5) organisations commented that all of these multiple uses must be understood and developed in order to positively tackle climate change. However, one individual noted that climate change priorities should be balanced to a national responsibility.

2.292 Eight respondents (including one third sector other, two individuals and five third sector woodland and environment) respondents were concerned about the levels of grazing and heath burning that they felt degrades the uplands.

2.293 In relation to upland use and management, flood, peatland and forest management were often commented on.

2.294 A few (5) respondents, commented on the value and implications of upland in terms of water and flood management. In addition, one other public sector respondent said that upland land use has an impact on the quality of drinking water (planting conifers upland can reduce water yield) and that the value of drinking water should be taken into account in the Strategy.

2.295 Some (9) respondents commented on the value of peatland management and restoration as a means of carbon capture, which would work towards positive climate change ambitions.

2.296 Some respondents (9) from the representative or professional, third sector and individual categories, commented on the value of forestry and afforestation in working towards government targets, mitigating flooding and tackling climate change. One organisation noted that there may be a less positive effect on moorland and farmland. And one local authority noted that any plans regarding afforestation and regeneration should fit into the forest and woodland framework.

2.297 Many respondents (14) from across categories commented that the upland ecosystem is fragile and that the way it has been managed is unsustainable, outdated and sometimes dangerous and damaging. Some respondents commented on the need to reduce degradation and enhance habitats and biodiversity. Some felt that this should be done through rewilding and reintroduction of native species, whilst two individuals felt that allowing the land to regenerate naturally over time was best. Ten respondents noted that there are competing interests in the uplands and conflicts over different land uses.

Policy

2.298 There was a mix of views on evidence towards a Vision and Strategy with a few (4) feeling that there is a need for better understanding and a smaller number (2) feeling that there is already a lot of evidence available.

2.299 Many respondents (14) felt that any new strategy should sit in the context of other related policies and frameworks such as those relating to moorlands, forestry, and wild lands. In particular, one local authority noted that it should link clearly to existing planning legislation with clear priorities. And one individual questioned how the most appropriate use of land would be decided. One individual and one public sector organisation felt that a strategy would be able to link to regional land use partnerships.

2.300 Some (5) organisations from the other, representative or professional and third sector categories were unsure of the benefit of having an upland strategy when Scotland's Moorland Forum has already been tasked with developing a Moorland vision and strategy by Scottish National Heritage's Science and Advisory Committee. One respondent from the other category said that the two should be combined or at least happen in close collaboration, to avoid confusion. This respondent also mentioned that the Scottish Gamekeepers Association published a Moorland Strategy in 2015, which should help inform development but is yet another document. Two organisations stated that they felt that the Moorland Forum should take on the role of developing this Strategy.

2.301 Some respondents (8) felt that an upland strategy should link to the Land Reform Bill, particularly in relation to ownership, sporting estate taxation and the 'Land Use Responsibilities' statement.

2.302 Two organisations from the private and other sectors, noted the need for improved infrastructure in the uplands, particularly relating to timber transport.

The strategic vision

2.303 Most repondents (over three quarters) discussed this proposal in terms of a 'vision', and nearly one fifth used the term 'strategy'. We have discussed all the views in terms of an upland vision as respondents did not distinguish between the two terms.

2.304 Seven respondents from across categories felt that an upland vision should be made of regional visions, in order to account for the different local environmental and socio-economic priorities. Nine respondents were in support of an upland vision being integrated and balanced to maximise the opportunities for multiple benefits for the public.

2.305 Some respondents (7) felt that a strategic vision should recognise and acknowledge the views of all stakeholders in the uplands, including land owners and local communities. Two respondents felt that those working in the uplands should be involved in developing the vision.

2.306 One representative body felt that there were many pertinent issues related to use of land in the uplands and how it provides a livelihood for farmers. It felt that policy should be integrated and should recognise uplands explicitly. It also felt that a strategic vision encompassing the range of issues and resources would work well provided that all voices are heard equally and no one issue is given priority over another.

2.307 A few (4) organisations with an interest in archaeology and history stated that an upland vision must include the historic environment.

2.308 Five organisations commented that the Scottish Government should lead in issues regarding upland use, and that it should fully commit to developing an upland vision.

2.309 Two local authorities hoped that the LUS would consider the impact of renewable energy on the uplands.

2.310 A few (4) respondents stated that they would like to be involved in the development of a strategic vision for the uplands.

Concerns

2.311 Several respondents from across categories (except the academic and other categories) did not agree with a strategic vision for the uplands. These respondents felt that there was no need for a separate upland strategy because the LUS takes an integrated approach covers all types of land. Two respondents thought that a single vision would not work because of the diversity within the uplands and two organisations were unsure about an upland strategy and they felt it would have to prove to add value to the LUS to be useful.

Monitoring Delivery of the Strategy - the Land Use Strategy Indicators

Q16a Do you agree that the Land Use Strategy indicators are still fit for purpose?

	Yes		No		Don't know		Total answered*	Not answered
Individual	10	24%	14	34%	17	41%	41	13
Public sector (national or local government)	15	83%	1	6%	2	11%	18	6
Other public sector	3	43%	3	43%	1	14%	7	3
Third sector (woodland and environment)	6	32%	4	21%	9	47%	19	3
Third sector (other)	5	38%	2	15%	6	46%	13	6
Representative or professional body	5	83%	1	17%	0	0%	6	5
Private sector	6	100%	0	0%	0	0%	6	3
Academic or research body	0	0%	1	33%	2	67%	3	2
Other	2	40%	1	20%	2	40%	5	7
Total	52	44%	27	23%	39	33%	118	48

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.312 A total of 118 respondents answered this question. Of these, less than half (44 per cent) agreed. Almost a quarter (23 per cent) disagreed and a third (33 per cent) did not know. Individuals, third sector organisations and research organisations were more likely than others to say they did not know. While local government, private sector and representative and professional bodies had high levels of agreement that the indicators were still fit for purpose, those in the other public sector category were much more likely to disagree.

Q16b Do you have any comments on the future monitoring of the revised Land Use Strategy?

2.313 Respondents who agreed that the indicators were still fit for purpose highlighted the importance of keeping indicators consistent, in order to track trends. This issue was raised by a number of local government respondents, as well as a small number of research and third sector organisations.

2.314 However, many who disagreed or indicated that they did not know highlighted concerns that the indicators required further assessment and consideration. Of particular concern was:

The indicators are very high level. Some (8) were concerned that there was little tangible connection between the LUS and any change in these indicators. There was some concern that the contribution of the LUS would not be detectable and clearly identifiable at this high level, beyond providing some background trend information. Two of these respondents (both individuals) suggested that it would be helpful to clearly show the linkages between the indicators and the intended outcomes of the LUS, including any key assumptions made. One of these respondents suggested this should be accompanied with a strategy to improve the quality of indicators over time.
The indicators may not provide useful information. A number of respondents indicated that they couldn't see how the LUS had impacted on any of the indicators so far. While some organisational respondents recognised the need to make the most of existing data, and the limitations this sets, some were concerned that the indicators would not help to gauge whether the Objectives of the LUS were being met. Two third sector organisations indicated that it was hard to know if the indicators were fit for purpose without some sort of assessment of how well they measured change secured by the first LUS. One of these organisations indicated that the Progress Statements on the LUS did not appear to use this information, and that there was limited analysis of the indicators and what they tell us.
The environmental outcomes may not be effectively measured. Some third sector and local government organisations felt that economic and social concerns were weighted more heavily than environmental concerns. There was recognition that some outcomes are easier to monitor than others, but some felt that the indicators missed essential aspects of what the LUS was aiming to achieve. One research organisation also highlighted that the indicators focus on outcomes, but that procedural aspects are also important to measure as part of the ecosystems approach.
The indicators are largely quantitative. A small number of respondents (3) indicated that indicators need to be qualitative as well as quantitative - not just measuring numbers, but experiences, behaviours and impacts. In addition, two respondents highlighted the need for SMART targets, setting out short, medium and long term goals specifically as a result of the LUS.
The relationships between the indicators. A number of respondents highlighted concerns about how progress against the indicators would be assessed and reported, given that they are indicators - and need explanation of the trade offs and balances between them, and the subtleties involved.

2.315 To help with these issues, respondents suggested:

periodic review of indicators, allowing them to evolve over time (5);
alignment with the National Performance Framework environmental indicators, which respondents suggested were under review (3);
monitoring at regional or local level (2);
development of an action plan setting out monitoring arrangements more clearly (2); and
an independent body with responsibility for monitoring (1).

2.316 Two organisational respondents felt that monitoring was particularly challenging in urban environments, and one other public sector organisation felt that monitoring was particularly challenging in terms of cultural service provision.

Suggested amendments to existing indicators

2.317 Respondents who were broadly happy with the indicators, and those who were not, suggested a range of potential amendments to the existing ten indicators:

Indicator 2 (Gross Value Added (GVA) in agriculture and forestry) - Some respondents (6) felt that this indicator (relating to GVA in agriculture and forestry) was crude and may be counter productive, or may conflict with other priorities within the LUS. Some felt it may drive production at a cost to the environment, and highlighted that monitoring needed to pick up on the subtleties of how the indicators relate to one another. Four (three third sector organisations and an individual) suggested considering whether GVA was really the best indicator for agriculture and forestry, as it did not fully reflect their role at the top of a cascade of jobs (in food, fencing, transport, veterinary services etc). In addition, one third sector organisation welcomed the inclusion of deer and game management within this indicator.
Indicator 3 (Scottish tourism visits) - One individual felt that it was important to measure the economic value of visitors, not simply the number of Scottish tourism visits. One third sector organisation hoped that shooting and stalking were considered in this indicator, as well as in indicators 8 and 9.
Indicator 4 (High nature value farming and forestry) - One third sector organisation felt that High Natural Value farming and forestry was not a reliable indicator as it was not a direct indication of the condition of the environment or ecosystems services. Another highlighted that this would change when some farming subsidies are based on Areas of Natural Constraint rather than the current Less Favoured Areas.
Indicator 7 (Terrestrial breeding birds) - Two third sector organisations and one individual were concerned that this indicator was only a partial measure of biodiversity. They indicated that it does not give a true picture of ecosystems health, and suggested linking to the new environmental indicators within the National Performance Framework here, around the base of ecosystems such as flowering plants, butterflies and bees.
Indicator 8 (Volunteering in nature) - Four organisations felt that it was important to widen this indicator to include volunteering in both the urban and rural landscape, recreational volunteering (such as walking groups), and young people volunteering (which are not currently included within the Scottish Household Survey question used as the source for this indicator). One private sector organisation also suggested more closely linking indicators 8 and 10.
Indicator 9 (Visits to the outdoors) - Two third sector organisations and one individual (all with very similar responses to this question) indicated that it was important to include something here about footpaths and access.
Indicator 10 (Community inclusion in land use decision making) - Three respondents (third sector and a representative body) felt that the source of measurement for this indicator was weak, since it relied on the Scottish Household Survey more general question about influencing decisions in the local area. One respondent suggested that the data to be gathered as Part 9 of the Community Empowerment (Scotland) Act (Allotments) may help with this.

Suggested new indicators

2.318 A number of respondents suggested particular areas of focus for new indicators, including relating to:

natural biodiversity indicators including habitat health, ecosystems health and EC priority habitats (5)
carbon (4) - as and when data is available
woodland creation or the loss of woodland areas (3)
raw source water supply quality (3)
the status of soils (2)
land ownership and occupation (2)
number of people employed in land based businesses (2)
greenhouse gas emissions from rural land use (1)
the Place Standard (1)
planning (1)
integration of the LUS into other policies/ strategies (1)
number of and type of land based businesses (1)
people's experience of the land and health and wellbeing benefits (1)
loss of green belt, and its consequences (1)
population retention or growth and housing (1)
peatlands - as these sequester a greater volume of greenhouse gases than forestry (1); and
landscape quality - although this is difficult to quantify (1).

General Questions

Q17 Are there any other activities that you think we should be undertaking to

achieve better understanding and application of the Principles or delivery of the Strategy?

2.319 A total of 71 respondents from across all categories provided a broad range of suggestions and comments on other activities that should be undertaken to achieve a better understanding and application of the Principles or delivery of the Strategy. There were two main themes.

Community engagement

2.320 Across all categories, respondents commented on the importance of engaging with a wide range of communities and community organisations. Many respondents believed that key to the progress of the Strategy, would be engaging and educating the public, and disseminating information. More specifically it was felt to be important to engage with land managers, land owners, farmers and foresters.

2.321 A representative or professional body respondent felt that engaging more land managers, would not only allow them to contribute more to the Strategy aims but would also encourage a greater sense of "shared ownership" of the Strategy.

2.322 In order to engage more practitioners in the development and delivery of the Strategy, one local government organisation felt that more community engagement was required and this could potentially be achieved through Policy 6 - the establishment of regional land use partnerships.

2.323 A public sector respondent recommended that the Strategy makes reference to the Place Standard and promotes its use as a tool to involve communities in land use decisions. Finally, one local authority noted it would be important to understand community capacity - to ensure that the emphasis on community involvement does not over-burden already active community members.

Building relationships

2.324 A number of respondents commented that the Strategy needed to build relationships, share knowledge and provide information and education. One public sector respondent felt that building strong relationships, sharing knowledge and research, and awareness raising would all be essential for the Strategy to seek to eliminate current levels of disagreement within key areas of the rural land use sector and would support more informed, joint decision making, whilst balancing private and public interests effectively.

2.325 A respondent from the 'other' category, suggested that a publicly funded environmental education programme was fundamental to ensuring that as many people as possible were able to understand the importance of land use and the complexities involved in managing it.

2.326 One private sector respondent and an individual suggested using 'modern ways of communicating' through social media and website updates, to get information about the Strategy into the public domain.

2.327 A third sector (woodland and environment) respondent felt it was important that the Scottish Government prepared materials explaining how the Strategy could help farmers and foresters to make better decisions about their businesses and livelihoods. And another respondent from the same category whilst commending the development of the Scottish Environment Web (SEWeb) portal, suggested that it should be improved in areas relating to influencing land use decisions, and education and knowledge transfer activities.

2.328 One private sector respondent cautioned that the Strategy should not become too complex - and that for it to be 'fit for purpose' it would have to be user-friendly and adaptable to local circumstances. Another respondent in the 'third sector - other' category acknowledged the complexities of presenting the connections between the National Planning Framework, the Planning System and the LUS. This respondent noted it would be a significant challenge to disseminate what the Strategy was trying to achieve.

Land Use Strategy links with policies

2.329 Respondents from the other public sector and the academic or research categories felt that the Strategy should be fully embedded into the key policies and strategies to which it relates. It was felt that this would require top legal and Cabinet level buy-in.

2.330 Two third sector (woodland and environment) respondents called for the Strategy to be better aligned with agricultural policy and the SRDP. And another respondent from the same category suggested working with the Land Commission when it is formed. This respondent also mentioned that land reform rights and responsibilities statement should be aligned with the ten Principles of the Strategy.

2.331 One third sector (woodland and environment) respondent made the point that sometimes coastal planning falls between land management and marine management policies. This respondent called for the Strategy to 'influence the coasts to optimise the multiple benefits of coastal land use and management' with the ultimate aim of reducing the impacts of climate change and rising sea levels.

2.332 An academic or research body respondent felt that the Strategy provides a unique opportunity for joint working and delivery between 'agencies, geographies and sectors'. This respondent also suggested that the Strategy requires an action plan and national stakeholder forum to oversee delivery.

2.333 'Partnership Learning Journeys' between local authority officers and local community organisations as a method of bringing people together to share ideas were suggested by a third sector (other) respondent.

2.334 A representative or professional body respondent believed that good relationships between Government, groups and people with an interest in land, were vital to progressing the Strategy. This respondent felt more effort should be put into developing better relationships in order to improve understanding from different perspectives.

Other comments

2.335 Respondents from across all categories made a number of other comments or suggestions and these are listed below:

Academic or research body - suggested a funding review of the land based further education sector.
Representative or professional body - commented on the importance of understanding from the past, how landscapes have changed to impact on the existing Scottish landscapes. Commenting that this understanding would ensure that land use and management will deliver positive landscape change in relation to challenges like climate change, flood management and food production.
An individual also commented that 'landscape' is a key omission from the Strategy - and only mentioned in passing. It is this individual's opinion that land use should be secondary to landscape and that a landscape approach would provide the necessary information on what type of landscapes we want to live in, in Scotland. This individual suggested that the Strategy should be the second tier, below a "Scottish Landscape Charter".
Another individual believed that the added value of ecosystems approaches should be communicated widely. This individual felt that the recent floods presented an immediate opportunity to illustrate the links between land use and wellbeing by showing the impact on people, properties and the economy.

2.336 Other individual respondents made comments in relation to:

the need for careful financial planning;
the importance of the supply of affordable housing to rural economies;
the inclusion of the creation of National Parks;
the introduction of a land valuation tax;
more research on factors affecting wellbeing of individuals and communities as part of an ecosystems approach;
a full GIS database of land ownership;
monitoring of selected declining species;
tax avoidance practices - endemic in the Scottish landowning profile;
linking urban areas to the countryside; and
community buy-outs, grant-aided community projects on disused land.

Q18 Are there any other points you wish to make about any aspect of this draft

2.337 A total of 68 respondents from all categories answered this question. A wide range of issues were raised:

Eight organisations noted the need for the LUS to link into and integrate with other existing policies and measures that relate to land use. These included: The Climate Change (Scotland) Act, Community Empowerment (Scotland) Act, Water Resources (Scotland) Act, Place Standard, Vision for Agriculture, Flood Risk Management Plans and Scottish Historic Environment Policy. Two third sector (woodland and environment) organisations noted the need for the Strategy to be aligned to the financial regime and fit into the wider economic context, and another third sector (woodland and environment) organisation felt that the Strategy should be backed by relevant Scottish Government directorates.
Seven respondents stated that the Strategy needed to be more specific; setting clear goals, responsibilities and impacts. One third sector (woodland and environment) organisation felt that the Strategy was not ambitious enough.
Six respondents felt that the Strategy should have more focus on empowerment, inclusion and integration to deliver a wide range of benefits.
Four respondents felt the Strategy should make more reference to the interactions between different issues relating to land uses, such as water, air, soil and people. One individual and one academic or research body wanted the Strategy to focus more on people and the 'human' element.
Four respondents commented on the use of incentives in the Strategy and how they should be used to encourage different types of land use.
Two organisations noted that the Strategy should address access and use of land for recreation.
Two academic and research bodies felt that the Strategy should recognise the need to support education and learning in relation to land use. And one individual commented on taxation and penalties for land owners in relation to land use.
Two third sector organisations (other, woodland and environment) felt that the Strategy should focus on a long term approach rather than short term outcomes.
Two respondents felt that the Strategy needed to further recognise the renewable energy industry in land use.
One public sector respondent wanted the Strategy to recognise the value of biological resources in land use.

2.338 Some (10) organisations reiterated the need for the Strategy to make reference to issues that are pertinent their work. Respondents wanted the Strategy to acknowledge the relevance and importance of the following in relation to land use:

aggregates
challenges for community land owners
coastal land use
food
forestry
historic environment
impact of industrialisation of rural areas
landscape
national parks
public safety
re-wilding and re-introduction of native species
role of national parks
sporting management
transport
urban and semi-urban land use.

2.339 Individuals made a number of comments on different areas of the Strategy. Individuals felt the Strategy should:

support greater transparency of land ownership;
include more information on how conflicts would be resolved;
take account of rising sea levels and flooding, especially regarding housing;
look at more radical local based governance; and
understand the motivations of land owners to adopt change and then decide priorities and how to achieve them.

2.340 One individual felt that there should be more public awareness of the Strategy and another felt that the language within the Strategy was not easy to understand. One individual felt that the public should be reassured that the Strategy would provide good value for money.

2.341 One (other public sector) organisation felt the Strategy should have specific commitments built into it. One (third sector other) organisations was concerned about the loss of land to development, when it may be needed in the future for growing food. One (other public sector) organisation said it would be happy to offer advice and one private sector organisation said it would be happy to be involved in further consultation as the policies are implemented. One individual and one academic or research body questioned how priorities for the Strategy would be decided.

Equalities

Q19 Do you have any comments on the policies and proposals in this draft Strategy in terms of how they may impact on any equalities group, i.e. with regard to age, gender, race, religion, disability or sexuality?

2.342 Respondents were asked to comment on the policies and proposals in the draft Strategy in terms of how they may impact on equalities groups (i.e. with regard to age, gender, race, religion, disability or sexuality). A total of 28 respondents provided comments.

Overall views

2.343 Eight respondents felt that the draft Strategy would not impact negatively on any equalities group. One organisation stated it was satisfied with the equality impact of the policies. A second organisation felt that the Strategy would benefit all the general public, including protected equalities groups, and a local authority explained that a pilot regional land use framework had been found to be consistent with their own equalities policies.

2.344 One individual said they did not see any particular danger to any group from the proposals, and a second individual respondent felt that the policies within the Strategy were equally accessible to everyone. Another individual made the point that the possibilities of the Strategy should be clear to any group of people without the need for "positive discrimination".

2.345 One individual, however, felt that the Strategy does not contain any proposals which will improve the involvement of under-represented groups. This respondent felt it would be a good idea to include a proactive proposal in order to address this issue.

Protected characteristics

2.346 Two individuals commented that it is important to consider the needs of older and disabled people. One of these respondents held the opinion that wheelchair regulations were not exacting enough, while the other individual highlighted the need for more woodland and farming areas with paths for older and less-able people to enjoy nature. This individual also expressed the view that allotments can be highly productive areas which can bring people of different races and faiths together.

2.347 Two academic organisations provided 'good practice' advice on accessibility. Suggestions included using suitable meeting locations so all sectors of society can attend and contribute to discussions, ensuring all media is available in a range of accessible formats, and making sure the tone of language does not exclude anyone. Both of these responses also made the point that the views of a community may contain a diverse range of perspectives and care must be taken not to give unequal weight to any side of a debate.

Rural inclusion

2.348 Three respondents included views on inclusivity and rural areas. One organisation suggested that the Strategy should be "rural-proofed" to ensure that rural community voices are heard and local resources capitalised upon to deliver equal growth across the country. A second organisation held the view that rural and urban areas in Scotland should be treated equally in the services that they use and require. This respondent also made the point that rural and urban communities depend on each other and there should be better support and awareness of such relationships.

2.349 One individual commented that discussion of 'human needs' was preferable to the needs of separate protected groups. This respondent also felt that the wellbeing of individuals and communities was important, and such wellbeing of rural locations can be dependent on land use decisions such as developing public transport links through forest areas.

Decision making

2.350 Two respondents commented on the importance of decisions being made by diverse committees. One organisation felt that Scotland's natural, cultural and historic landscape has been impacted upon by people of different ages, gender, religion, ability, etc. and such diversity should be reflected in today's decision making. Similarly, one individual stated that local groups involved in implementing regional policies should reflect a whole community and not just one sector of society.

Wider comments

2.351 Several respondents provided wider comments on the topic of equalities. One organisation highlighted the therapeutic benefits of natural landscapes and suggested that the Strategy should encourage diversification of farms and forests in order to serve the health of Scotland's communities. Two organisations stated that full impact assessments should be conducted before any changes be made to land management policy.

2.352 Six individuals also submitted wider comments. One respondent expressed the view that income and tenure are part of the equalities picture and they felt that land ownership needs to be "much fairer with more accountability and transparency". A second individual stated that land should be available to all people. Another individual commented that land use is a long term matter which will impact future generations more than current groups in society.

2.353 Three individuals did not feel that an equalities question was relevant to a land use consultation.

Questions on the Environmental Report

Q20a: Do you consider that the Environmental Report set out an accurate description of the current environmental issues/baseline?

	Agree		Disagree		Partially		Don't know		Total answered*	Not answered
Individual	8	23%	1	3%	13	37%	13	37%	35	19
Public sector (national or local government)	10	71%	0	0%	0	0%	4	29%	14	10
Other public sector	3	75%	0	0%	1	25%	0	0%	4	6
Third sector (woodland and environment)	1	13%	1	13%	1	13%	5	63%	8	14
Third sector (other)	4	80%	0	0%	1	20%	0	0%	5	14
Representative or professional body	2	40%	0	0%	0	0%	3	60%	5	6
Private sector	1	33%	1	33%	1	33%	0	0%	3	6
Academic or research body	1	50%	0	0%	1	50%	0	0%	2	3
Other	0	0%	1	33%	1	33%	1	33%	3	9
Total	30	38%	4	5%	19	24%	26	33%	79	87

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.354 Just under half (48 per cent) of respondents answered question 20a. The majority (62 per cent) of those who answered either agreed or partially agreed that the Environmental Report set out an accurate description of the current environmental issues/baseline. A very small minority (5 per cent) disagreed while one-third were unsure. Agreement was strongest from the public sector and third sector (other) respondent categories, while the third sector (woodland and environment) and representative or professional body categories were the least sure.

Fully agree

2.355 Many respondents agreed that it was an accurate description and provided comments which described it as "comprehensive", "accurate" and "balanced".

2.356 An other public sector organisation felt that the Environmental Report provided a coherent presentation of the issues and the respondent particularly praised the 'applying the principles' section. This organisation also supported the proposals under 'informed decision making' but felt that that the 'policy alignment' section would be strengthened by explicit references to the community empowerment and land reform agendas.

2.357 The baseline information on water was considered "appropriate" by a second other public sector organisation who welcomed the recognition of a healthy water ecosystem in relation to wellbeing and the economy. Another organisational respondent pointed out that the Environmental Report only briefly mentions the onshore windfarm technology that shall be required to meet the Scottish Government's greenhouse gas emissions target but agreed with the issues overall. A third sector (woodland and environment) organisation commented that the Environmental Report gave a very detailed account of the relevant policies but suggested that more clarity could be given to the statistical information.

Partially agree

2.358 Several respondents partially agreed with the description of the current environmental issues/baseline in the Environmental Report. One private sector organisation felt that the report was "probably the best we can do at this time" and cautioned that there is a long way to go in terms of understanding the long term effect of greenhouse gases and climate change.

2.359 A small number of individuals and organisational respondents who partially agreed with Environmental Report commented on what they considered to be omissions, including:

the production of quality timber and resulting carbon sequestration;
food security;
decline of lowland wildlife; and
upland ecosystems.

2.360 Two organisations made reference to the CAP and each response expressed the view that the Environmental Report should include a stronger link to the CAP. Specifically, both respondents feel that land use changes on Scottish farms are strongly influenced by the 'Pillar 1' component of the CAP, and so the report would benefit from including this aspect in addition to discussion on the Scottish Rural Development Programme.

2.361 Responses from an individual and an organisation both felt bias could be identified in the Environmental Report. The organisational respondent expressed concern that the report was weighted towards green issues without taking into account the potential effects they could have on people who live in and preserve the environment. Additionally, the individual respondent held the view that if the report is compiled from information which is partial or from only one source, then bias is to be expected.

2.362 An individual also commented that, while the issues stated in the Environmental Report were reasonable, there lacked a clear definition of what the 'baseline' actually is. A second individual who partially agreed with the Environmental Report said they did not support the ecosystems base as they felt this was an outcome not a starting point.

Suggestions

2.363 A small number of respondents disagreed with the Environmental Report and made suggestions. One organisation from the private sector felt there was not enough difference between the report and the Strategy. In contrast, two other organisations both felt that the Environmental Report contained important components which were not carried over into the Strategy. Specifically, they mentioned the historic environment and cultural landscapes as potential beneficiaries of the proposals and so felt these should be highlighted in the Strategy.

2.364 One individual held the view that the Environmental Report was too general and lacked practical value for a public consultation.

Unsure

2.365 A small number of respondents who were unsure of how well the Environmental Report set out an accurate description of the current environmental issues/baseline provided comments. Overall, these respondents felt they did not have enough background information or expertise to comment on the report, or they did not have enough time to fully examine the data.

Q21a: Do you consider that the predicted environmental effects as set out in the Environmental Report are accurate?

	Agree		Disagree		Partially		Don't know		Total answered*	Not answered
Individual	5	16%	2	6%	11	35%	13	42%	31	23
Public sector (national or local government)	9	64%	0	0%	0	0%	5	36%	14	10
Other public sector	2	67%	0	0%	1	33%	0	0%	3	7
Third sector (woodland and environment)	0	0%	1	17%	1	17%	4	67%	6	16
Third sector (other)	2	67%	0	0%	1	33%	0	0%	3	16
Representative or professional body	1	20%	0	0%	1	20%	3	60%	5	6
Private sector	0	0%	1	33%	1	33%	1	33%	3	6
Academic or research body	0	0%	0	0%	2	100%	0	0%	2	3
Other	0	0%	0	0%	1	50%	1	50%	2	10
Total	19	28%	4	6%	19	28%	27	39%	69	97

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.366 When asked if the predicted environmental effects as set out in the Environmental Report were accurate, a total of 69 (42 per cent) respondents answered. Of those responses, most (56 per cent) said they agreed or partially agreed while 39 per cent were unsure. A small number (six per cent) of respondents disagreed with the question. Public sector and third sector (other) organisations agreed the most strongly with the predicted environmental effects in the report while third sector (woodland and environment) and representative or professional bodies were least certain.

Q21b: Please provide reasons for your answer including further information you feel should be considered in the assessment.

Fully agree

2.367 Several respondents who agreed that the predicted environmental effects in the Environmental Report were accurate provided comments. One organisation felt that predicting environmental effects was difficult due to the complex relationships that exist in natural systems. One public sector (national or local government) organisation felt that it would be useful for the Environmental Report to indicate and assess the alternatives considered to the proposals in the Strategy. This respondent would also have liked to see any alterations made to the proposed policies in light of the environmental assessment.

Partially agree

2.368 Two organisations who partially agreed with the predicted environmental effects both felt that this section of the report could devote more attention to evidence, local knowledge and experience. Additionally, an other public sector respondent felt that, while the Environmental Report takes a pragmatic approach to its long term objectives, it would benefit from highlighting the importance of stakeholder participation within the process of delivering outcomes.

2.369 An organisation from the representative or professional body category stated it generally agreed with the assessment of environmental effects but warned there could be conflict between the Strategy and the greenhouse gas emissions targets set by the Scottish Government. Furthermore, this organisation held the opinion that there was the potential for adverse environmental effects in terms of landscape and visual amenity through the delivery of the Strategy, and highlighted the European Landscape Convention's framework for organisations to protect and enhance Scotland's landscapes.

2.370 A third sector (woodland and environment) respondent expressed the view that potential risks should be identified more explicitly with respect to land values being over or underestimated. This organisation provided an example of forestry being expanded into peatland in which the peatland, for various reasons, is actually more valuable than the forestry.

2.371 An individual who partially agreed with the environmental effects felt it was important to draw attention to the environmental effects of choosing broadleaved or conifer trees. This respondent listed carbon balance, soil damage, avalanche protection and water quality as factors which can be influenced by different species of tree.

Suggestions

2.372 A small number of respondents who disagreed with the predicted environmental effects provided comments. An organisation from the third sector (woodland and environment) category echoed previous comments regarding the difficulty in predicting the effects of land use change due to the many dynamic factors involved.

2.373 One individual cautioned that small changes in climate, government policy or the funding market can upset the balance of the environmental system and so policies should be based on the "more stable elements of the natural resource base".

2.374 A second individual who disagreed with the predicted environmental effects made the brief comment that a simpler report which highlighted the main issues would have been preferable.

Q22a: Do you consider that the recommendations and opportunities for mitigation and enhancement are accurate?

	Agree		Disagree		Partially		Don't know		Total answered*	Not answered
Individual	3	10%	1	3%	10	33%	16	53%	30	24
Public sector (national or local government)	10	71%	0	0%	0	0%	4	29%	14	10
Other public sector	2	67%	0	0%	1	33%	0	0%	3	7
Third sector (woodland and environment)	0	0%	1	17%	1	17%	4	67%	6	16
Third sector (other)	2	67%	0	0%	1	33%	0	0%	3	16
Representative or professional body	2	40%	0	0%	0	0%	3	60%	5	6
Private sector	1	50%	0	0%	1	50%	0	0%	2	7
Academic or research body	1	50%	0	0%	1	50%	0	0%	2	3
Other	0	0%	0	0%	1	50%	1	50%	2	10
Total	21	31%	2	3%	16	24%	28	42%	67	99

*Percentages of yes/ no/ don't know are calculated based on the total who answered this question.

2.375 A total of 67 respondents answered this question. Of those who answered, the majority (55 per cent) agreed or partially agreed that the recommendations were accurate, while 42 per cent were unsure. Only two respondents (3 per cent) felt the recommendations and opportunities for mitigation and enhancement definitely lacked accuracy.

Fully agree

2.376 Several respondents provided positive comments regarding the recommendations for mitigation and enhancement, and described this section of the Environmental Report as generally "comprehensive", "reasonable" and "accurate".

2.377 One organisation from the other public sector category not only viewed the recommendations as "reasonable and valid", but also particularly supported the recommendation regarding the ambitions of the Strategy in the urban environment and the multifunctional use of urban land. A second public sector (national or local government) organisation also expressed support for the recommendations and commended the ecosystems approach, the wider approach beyond the boundaries of local authorities to address climate change, and the encouragement of community engagement.

2.378 Two public sector organisations specifically felt the examples of how to mitigate certain effects in Appendix 3 were appropriate.

2.379 One representative or professional body organisation welcomed the implementation of mitigation and enhancement due to the potential benefits for landscape and visual amenity. A second representative or professional body stated that, by its nature, the Strategy presents opportunities for mitigation and enhancement through the identification of land-based practices which could mitigate the impacts of climate change.

Partially agree

2.380 Several respondents partially agreed with the recommendations. An organisational respondent who felt that the recommendations were comprehensive added that this was a broad area with "some recommendations and opportunities being more practical than others". This respondent highlighted an ever increasing population and a drive for ongoing economic growth as a strain on the ecosystems services which require attention.

2.381 A private sector organisation who partially agreed with the recommendations, expressed the view that current environmental issues require immediate attention and also added that it is important to create a balance between ideas and resources.

2.382 An organisation from the third sector (woodland and environment) category said that, while Environmental Report covers most of the major opportunities for mitigation and enhancement, the link between peatlands, wild land areas and reducing greenhouse gas emissions was missing.

2.383 One academic or research body stated that the recommendations and opportunities for mitigation and enhancement were accurate but could be improved with further evidence. A second organisation commented that some of the recommendations were accurate but "others appear flawed".

2.384 Comments from individuals who partially agreed with the recommendations were brief. One individual said the recommendations required a more in-depth look from a non-ecosystems approach while a second individual stated that there were different viewpoints to consider. Three individuals provided similar comments which highlighted the difficulty of understanding environmental effects due to many uncontrolled factors.

Suggestions

2.385 Only one organisation, from the third sector (woodland and environment) category, disagreed with the recommendations. This organisation felt that if local partnerships were to provide the framework of the Strategy, then "unofficial links between members and their constituencies would be more effective than fixed rules to be followed".

2.386 The only individual who disagreed with the recommendations stated that the report should be simple and focus on the main points. One individual respondent had mixed views, feeling information was too vague, while a second individual stated that they did not have enough expertise to answer with certainty. Two organisations said they did not have enough time to review this section.

Q23: Are you aware of alternatives to the proposed policies that should be considered as part of the Strategic Environmental Assessment (SEA) process conducted for the draft Strategy?

2.387 A total of 35 respondents answered this question. Of these, just six respondents said they knew of alternatives and the remainder said they did not. The suggestions made were:

One local authority felt that the Community Engagement (Scotland) Act and other relevant local authority strategies should be considered.
One local authority stated that the alternative options from the previous Strategy (2011-16) were still valid.
One third sector organisation was surprised that the assessment was so positive and felt that the SEA could have taken a wider view and been more critical.
One third sector organisation recognised that there would be positive and negative impacts from any change in land use.
One individual felt that the SEA lacked objectives that were not aligned to tourism or agriculture.
One individual felt that all alternatives should be considered.

Contact

Email: Sally Thomas

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