Biodiversity - strategic framework: consultation analysis

Section Three: Nature Networks Policy Framework

Summary

• Whilst the aspiration of the policy was commended, a considerable volume of responses provided comments related to its implementation.
• The resourcing of the delivery of the policy was widely considered to need further clarification, with several organisational and individual respondents raising concerns regarding the limited budgets of local authorities.
• Many responses provided perspectives relating to data collection and usage, with a few commenting on the role of local environmental records centres (LERC) as well as the reliance on volunteers for the collection of biodiversity data.
• Several responses sought guidance on how the policy aligns with other plans, networks and policy areas.

This section relates to question 3a in the consultation document, which was an open-text response question (n=184).

Respondents were positive about the principles and ambition of the draft Nature Networks Policy Framework and, in particular, referenced the collaborative approach taken to the development of the policy. Several responses highlighted the importance of connective habitats, including their role in enhancing biodiversity resilience and species survival.

'Very pleased to see this approach, which is clearly intended to alleviate some of the problems associated with 'disconnected' areas of nature conservation.' (Individual response)

'We believe that the recognition and protection of Nature Networks will contribute significantly to the long-term health and resilience of Scotland's biodiversity.' (Forth Rivers Trust)

Whilst the aspiration of the policy was commended, nearly half of responses provided comments related to its implementation (80 respondents or 45 per cent). The bottom-up approach was highlighted by several responses as being positive, with the focus on addressing local needs whilst empowering and equipping delivery partners and communities being well received.

Some individuals sought clarity as to who would have overall responsibility for the networks, whilst organisational responses were provided based on the recognition that they would ultimately be delivered and resourced by local authorities. One National Park Authority also requested to be responsible for delivering Nature Networks alongside local authorities.

Several responses also suggested a need for oversight at a national level with regard to how Nature Networks work together and whether they are delivered effectively, in recognition that there are considerable resources and coordination needed to facilitate this approach. A few responses also encouraged consideration of connectivity across local authority boundaries within this.

Responses from local authorities provided a range of perspectives, with comments focusing on the implementation and resourcing of the policy. They highlighted that building capacity in communities requires long-term engagement as well as dedicated staff to support stakeholder involvement, and sufficient notice of funding allocation to be able to implement the Nature Networks effectively. Several local authorities also highlighted the need for multi-year funding to enable good value for money as well as effective spending on seasonally dependent projects including wildflower meadows, tree planting, and INNS management.

'If local authorities are to be responsible for delivering Nature Networks, significant, ongoing funding will be required to ensure dedicated staff are employed on an ongoing basis to encourage involvement of all stakeholders, identify areas of connectivity, and implement through targeted grants.' (Aberdeen City Council)

'This obligation can only be carried out with appropriate staffing resource funded by central government and the tools centralised as much as possible so that local authorities are not reinventing tools and wasting resource.' (Perth and Kinross Council)

'The mapping of Nature Networks presents a challenge to all local authorities, but for an area the size and complexity of Highland, with a rich diversity of habitats and species, the challenge is significantly magnified.' (The Highland Council)

More generally, the resourcing of the delivery of the policy was widely considered to need further clarification, with several organisational and individual respondents raising concerns surrounding the limited budgets of local authorities. Both local authorities and other organisational responses highlighted the varying resource implications across local authorities, depending on their geography and population, and the need for a more strategic approach to land use planning and decision making. For example, NFU Scotland suggested that lessons could be learned from the development and implementation of the Regional Land Use Partnerships (RLUP), which they stated had been challenging due to inadequate funding, a lack of accountability, and limited strategic direction as to how they will operate.

Many responses provided perspectives relating to data collection and usage, with a few commenting on the role of local environmental records centres (LERC) as well as the reliance on volunteers for the collection of biodiversity data.

More generally, the role of volunteers as part of community groups was highlighted as being central to the success of the policy, with guidance needed as to how to best support them.

'It is vital that the Nature Networks Frameworks acknowledge the pressures facing community groups at present and that guidance to address these pressures is included in the proposed Nature Networks Toolbox.' (Volunteer Scotland)

A number of organisations, including the Scottish Crofting Federation, Scottish Land and Estates, NFU Scotland, and the Nature Friendly Farming Network, provided responses which emphasised the importance of farmers, crofters and land managers in delivering the policy. These responses made reference to both agricultural payments and incentives, advising that incentive arrangements will need to be stable and consistent to facilitate forward planning and ensure that funding options are accessible for crofters and common grazings. One council sought further clarification relating to rural land use issues.

'As an authority with a significant amount of rural land within its area, we are not clear to what extent there is an expectation that we engage on rural land use issues — farming and forestry, for example — in developing these networks.' (Aberdeenshire Council)

'We do miss explicit links to and coherence with the wider policy context, especially regarding agriculture, food, land reform, and human rights.' (Scottish Crofting Federation)

Several responses sought guidance on how the policy aligns with other plans, networks and policy areas. They included references to Regional Land Use Partnerships, forestry and woodland strategies, open space strategies, the Protected Areas Network, Local Development Plans, and wider placemaking initiatives such as Local Place Plans. In relation to the National Planning Framework 4 (NPF4), some responses wanted further details on how biodiversity enhancements are provided to developments in practice, particularly in areas with multiple landowners.

'[We] welcome the Nature Networks Framework and, in particular, opportunities for linear infrastructure developers to meet their compensation requirements for delivering ecological enhancement, recognising that developers like SSEN Distribution do not have ownership or control of the land beneath [their] networks.' (Scottish and Southern Electricity Networks (Distribution))

'We would welcome greater clarity on how Nature Networks and biodiversity enhancements within them will contribute to overall significant enhancement being delivered by developers.' (Scottish Power)