Biodiversity - strategic framework: consultation analysis

Section Four: 30 by 30 Policy Framework

Summary

• There was a general positive sentiment from individuals regarding the policy framework, agreeing with the guiding principles with which to deliver the policy. Implementation was the main challenge raised by respondents. This included the desire for detail on funding, monitoring and accountability.
• One of the key principles of the 30 by 30 framework is adaptive, dynamic and responsive land management. Several respondents stated that many habitat types need to be managed on a long-term basis, and that adaptive, dynamic and responsive land management is not feasible in these cases.
• Industry organisations often emphasised sustainable or dual use of sites, whilst land ownership was raised by several respondents as being key to the success of the 30 by 30 goals.
• Some respondents supported promotion of the protection of specific qualities within targets over perceived arbitrary measures of areas, with others noting the contribution of linear features such as grass and arable margins, hedgerows, and riparian catchments.

This section relates to question 4a in the consultation document, which was an open-text response question (n=171).

Individuals and organisations provided a range of responses on the 30 by 30 Policy Framework. There was a general positive sentiment from individuals regarding the policy framework, agreeing with the guiding principles with which to deliver the policy. The alignment with the Global Biodiversity Framework (GBF) was also welcomed.

'Scotland's commitment to the GBF is a remarkably positive feature of policy. It provides the key 'anchor' for much of the work and it warrants much greater publicity.' (Individual response)

A few respondents supported promotion of the protection of specific qualities within targets over perceived arbitrary measures of areas, with others noting the contribution of linear features such as grass and arable margins, hedgerows, and riparian catchments.

Several respondents, including the Coastal Communities Network, Shetland Fishermen's Association, and the Sustainable Inshore Fisheries Trust, noted the omission of marine and intertidal/coastal habitats from the 30 by 30 framework, suggesting that they should be incorporated with a careful examination of which segments of the marine ecosystem are deemed to be suitable.

'Dedicated to actions for land management, but nothing explicitly related to management of the marine environment.' (Sustainable Inshore Fisheries Trust (SIFT))

'It is crucial to acknowledge the valuable ecosystem services offered by these key habitats, encompassing carbon sequestration, habitat provision, and facilitation of marine life.' (Organisational response – anonymous)

As with policy frameworks across the consultation, implementation was the main challenge raised by respondents. This included the desire for detail on funding, monitoring and accountability.

'Not only are budgets limited, but farmers and land managers are busy working to make a living on their land […]. Where is the joined-up thinking of how all these plans are going to work together to provide much needed action on the ground?' (Scottish Farming and Wildlife Advisers' Group)

'Designation alone will not be sufficient to ensure that these sites are effectively protected. Management of the sites is also required. How will 'effective' protection be assessed? What level of monitoring will be undertaken to ensure that Scotland is meeting its international commitments to the 30 by 30 ambition for effectively protected areas?' (UK Environmental Law Association)

Several respondents commented on site selection, including seeking clarity as to which site designations count as being protected under the scheme. A few commented on the omission of local nature conservation sites and expressed disappointment that there were no proposals for identifying new sites which meet the criteria for existing protections but are not yet designated.

A small number of responses referenced Scottish Environment LINK's report on 30 by 30, giving examples of positive points relating to site selection, including: that National Parks do not currently count in their entirety, as they do not meet Convention on Biological Diversity (CBD) Target 3; that national scenic areas do not count towards the 30 per cent; and that sites of local importance for biodiversity as well as land under restoration for nature should not automatically count.

'[Local nature conservation sites] are far more numerous and extensive than other designations, so provide a significant increase in coverage and connectivity across areas.' (Local authority)

'We agree that improvements could allow protected sites to deliver more for nature, but we do not agree that protected areas should de facto count towards the target. This is because some protected areas are in an unfavourable condition and, therefore, do not meet […] the GBF definition.' (Organisational response)

'Sites should be delivering for nature (i.e. good ecological condition/shown to be actively recovering to this condition) in order to be counted as part of 30 by 30.' (Butterfly Conservation)

One of the key principles of the 30 by 30 framework is adaptive, dynamic and responsive land management. Several respondents stated that many habitat types need to be managed on a long-term basis, and that adaptive, dynamic and responsive land management is not feasible in these cases. Equally, several organisations expressed a need for clarity as to the level of protection as well as potential exclusions within these areas of designation. Some expressed concern that the designation of 30 by 30 areas could mean a loss of support or funding for other areas.

Industry organisations often emphasised sustainable or dual use of sites, stressing the importance of food security, renewables infrastructure, and the overall economic impact of banning certain activities in protected areas.

'Recognition that other effective area-based conservation measures (OECMs) provide a key opportunity for a more bottom-up approach to site protection, allowing for inclusion of a much greater group of stakeholders to contribute towards the target.' (Scottish Wildlife Trust)

'The Scottish Government need to be clear about what restrictions on economic activity they are prepared to put in place to achieve these targets.' (Fish Legal)

'[Our] members call for more clarity on the intended approach to OECMs and the level of protection afforded to them. We understand they need to be effectively protected, but renewables should not be excluded entirely.' (Scottish Renewables)

Land ownership was raised by several respondents as being key to the success of the 30 by 30 goals, with responses highlighting the importance of coordination with public landowners as well as a need for strategies and incentives for engaging with private landowners.

'It's very welcome and shows commitment by the government. However, given that so much of this 30 per cent is in private hands, it's not clear how the private sector will be encouraged […] to take part.' (Individual response)

'We are supportive of the goals and themes set out for the 30 by 30 framework. It would appear that Scottish Water fits with Theme 4 action: "Land owning public bodies will manage their land to contribute towards 30 by 30" […] we would be keen to engage with Scottish Government and with NatureScot to explore how this will work in practice.' (Scottish Water)