Biodiversity - strategic framework: consultation analysis

Section Two: Scottish Biodiversity Delivery Plan

This section sets out the responses to the Scottish Biodiversity Delivery Plan, hereafter called 'the Delivery Plan'. Firstly, it outlines overarching comments relating to the Delivery Plan. Next, it sets out the quantitative analysis of closed-response questions associated with the six objectives in the Delivery Plan and then addresses responses to the actions and approach taken for each of the six objectives in turn.

Summary

• There was general support for the ambitious approach of the Delivery Plan mirroring the perceived ambition of the Biodiversity Strategy.
• Respondents were positive about the overall objectives of the Delivery Plan, particularly relating to the addition of the sixth objective of tackling the indirect drivers of biodiversity loss.
• Not all respondents were confident that the Delivery Plan captured the key actions needed to deliver the objectives, with many concerned that the actions were not sufficient to put Scotland on track to ending the loss of biodiversity by 2030. However, this was driven by several factors including the range of stakeholders with firmly held views on the prioritisation of land use, which meant that there was no consensus on whether the proposals are too ambitious or not ambitious enough.
• There was considerable feedback from organisations seeking clarity as to the implementation of the Delivery Plan, including with regard to action holders, timescales, monitoring approaches, resources, and the prioritisation of actions.

General Comments on the Delivery Plan

The Biodiversity Strategy will be underpinned by a series of five-year Delivery Plans. The plan contains over 100 actions which taken together represent a step change designed to accelerate the pace and scale of the Scottish Government's efforts to address the biodiversity crisis.

There was general support for the ambitious approach of the Delivery Plan mirroring the perceived ambition of the Biodiversity Strategy. Respondents were positive about the overall objectives of the Delivery Plan, particularly relating to the addition of the sixth objective of tackling the indirect drivers of biodiversity loss. Responses from individuals suggested that the Delivery Plan was symbolically important in demonstrating the Scottish Government's commitment to addressing the biodiversity crisis.

'The level of ambition set out in the Biodiversity Strategy is important, as it recognises not only the need for swift actions but also the need for those actions to occur at scale.' (Organisational response)

'All of the policies included in the framework are vital elements of Scotland's response to the nature crisis, and many are things that environmental NGOs have been calling for over many years — this is a significant moment that we really welcome.' (RSPB Scotland)

'On the whole, we feel that the proposed strategy is progressive, ensuring that Scotland's economy continues to grow, and nature continues to thrive.' (Organisational response)

Answers to closed-response questions suggested that not all respondents were confident that the Delivery Plan captured the key actions needed to deliver the objectives. The negative or uncertain sentiment was driven by several factors including: missing actions, existing actions needing stronger commitments or more specific wording, and a concern surrounding actions repurposed from existing action plans or policies. These included calls for more definitive or more timely action, and the need to strengthen wording such as 'review', 'revise' or 'consider'.

The sentiment that key actions had not been captured can also be attributed to the volume of respondents with firmly held views on the prioritisation of certain actions as well as a range of perspectives on land use. Across the six objectives, this meant that there was no consensus on whether the proposals were too ambitious or not ambitious enough.

The following subsections also include details on responses to specific actions related to each of the six objectives, including where actions are missing or could be strengthened or clarified.

Overall, closed-response questions suggested that respondents did not agree that the actions were sufficient to put Scotland on track to ending the loss of biodiversity by 2030. This negative sentiment was driven by concerns surrounding implementation and a lack of detail provided in the plan in relation to the resources, monitoring and accountability of each action, which meant that respondents could not be confident that the actions would be sufficient to meet biodiversity targets.

There was a considerable response from organisations that sought clarity as to the implementation of the Delivery Plan. This included details on the timescales for the delivery of certain actions, the relevant bodies responsible for delivering actions, the resources required, and details on data collection and monitoring. Several organisations called for the Delivery Plan to be strengthened by making all of the actions specific, measurable, achievable, relevant, and time-bound (SMART). A few organisations asked for clarity as to which actions were currently underway and which related to new schemes or funding.

'Whilst we recognise the need for urgent action on the nature emergency and welcome the Delivery Plan, the additional actions for local authorities should be clearly expressed and resourcing addressed.' (Aberdeenshire Council)

'Given the absence of delivery detail, the removal of suggested actions and lack of join-up to the existing marine nature conservation strategy and new commitments such as a blue carbon action plan, it is not possible for us to say that the proposed actions will reverse the decline of nature at sea.' (Marine Conservation Society)

'Without baselines it's difficult to know if the key actions will be deliverable. There are no connections between the outcomes and the monitoring framework further down the document to help to understand if the actions will be enough. Outcomes should be more quantified with a greater focus on indicators.' (Institute of Environmental Management and Assessment)

Many responses from organisations welcomed the cross-policy approach, and some also sought further details on the prioritisation of actions and how the actions linked together. Some respondents gave overall comments seeking reassurance that the Delivery Plan would create added value beyond the range of existing commitments and policies from the Scottish Government which are included in actions across the Delivery Plan.

Both individuals and organisations provided a range of perspectives on the timescale of the Delivery Plan and on specific actions.Across all questions, individuals asked that the actions happen more quickly, whilst others expressed caution towards delivering at pace without due regard for evidence of what works or the ability to take a strategic approach in collaboration with relevant stakeholders. A few conservation-based environmental non-governmental organisations (eNGO) noted that five years was not long in ecological terms, highlighting challenges associated with monitoring and evidencing change.

'Whilst we appreciate that the Delivery Plan is to be reviewed every five years and it is intended to be an agile and dynamic document, many of the actions would benefit from a more specific and definitive set of timescales and/or timetable for delivery.' (The Highland Council)

'We also warn against the popular belief that the government must 'act faster' or 'accelerate' its environmental actions where this may lead to policymaking that has not been carefully considered or evidenced-based.' (Shetland Fishermen's Association)

Quantitative Analysis of Responses

The actions in the Delivery Plan are set out under the six objectives of the Scottish Biodiversity Strategy. For each of the six objectives, respondents were asked whether the Scottish Government had captured the key actions needed to deliver the relevant objective. Overall, respondents did not agree that the key actions had been captured to deliver the objectives; respondents were most positive about the actions set out under Objective 6 on taking action on the indirect drivers of biodiversity loss. Figure 2.1 sets out the responses to the closed-response questions relating to the six objectives of the Delivery Plan.

Source: Strategic Framework for Biodiversity Consultation, Scottish Government (2023).

Please note that not all percentages will total 100 per cent due to rounding.

Across all six objectives, respondents were asked whether the actions were sufficient to put Scotland on track to ending the loss of biodiversity by 2030 (Figure 2.2). Again, not all respondents were confident that the actions would be sufficient. Analysis of the open-text responses to the specific questions asked under each objective is set out below.

Source: Strategic Framework for Biodiversity Consultation, Scottish Government (2023).

Please note that not all percentages will total 100 per cent due to rounding.

Objective 1: Accelerate Restoration and Regeneration

This section relates to questions 2a (closed response n=293 and open-text response n=271), 2b (closed response n=273 and open-text response n=257) and 2c (open-text response n=233).

Respondents offered a diverse range of views and perspectives on the actions relating to accelerating restoration and regeneration. Whilst analysis of closed-response questions suggests that the majority of respondents disagreed that the Delivery Plan captured the key actions needed to deliver this objective, this negative sentiment was driven by the lack of consensus on prioritisation as well as specific details relating to the action, which are addressed below.

Overall, there was hesitancy as to whether the actions were sufficient to put Scotland on track to ending the loss of biodiversity by 2030, due to challenges associated with implementation, the monitoring of outcomes, and the strength of wording (including in specific actions). A few respondents suggested that the actions under the first objective do not extend sufficiently beyond previous legislation or commitments.

'The actions are repackaged from other policies and plans, meaning the Scottish Biodiversity Strategy will offer little progress beyond what the Scottish Government has already committed to achieve.' (Individual response)

'There are several references to River Basin Management Planning throughout the Strategy and Delivery Plan. However, in most cases, these simply restate the status quo and lack the necessary ambition.' (Organisational response)

Several respondents suggested that the introduction of statutory nature restoration targets would be the most impactful action and would be a key driver or action within both government and public bodies (further perspectives relating to the introduction of statutory targets can be found in Section Six).

Many individual respondents gave general agreement on actions relating to ecosystem restoration, with many specific comments from organisational respondents relating to actions. These included supporting stronger wording on the action relating to banning the sale of peat in Scotland, and positivity in the urgency given to the restoration of Scotland's rainforest. One respondent noted the importance of working with existing partnerships, networks and groups such as Rural Land Use Partnerships when delivering the six proposed large-scale landscape restoration areas. A few respondents commented on the forthcoming Agriculture and Rural Communities Scotland Bill, noting that further reference to the Bill could be included in the plan, considering the impact that the Bill may have on the delivery of the Strategy.

A few of the respondents, both individuals and organisations, gave comments relating to the ecosystems listed in the consultation document, noting the absence of some habitat types including grasslands, heathland, and other lowland habitats, and the need for further details on actions relating to these ecosystems.

'The introductory text sets out a list of ecosystems which will be part of the programme of ecosystem restoration, as a footnote. This list must be developed into a series of actions for each ecosystem in the delivery table. In particular, we note that species-rich grasslands, whilst listed in the footnote in the introductory text, are not featured in the delivery table.' (Plantlife Scotland)

Respondents were positive about the focus on invasive non-native species (INNS) within the Delivery Plan, particularly the preventative approach advocated. However, several individual respondents noted that these actions could be strengthened. This would help to dedicate further resources for citizen scientists and volunteers, upon which the action relies, and more details on how actions relating to raising public awareness might work in practice.

Overall, there were mixed perspectives offered on actions relating to resilience in coastal and marine systems. Several organisations were concerned about the repetition of previous policies and actions, and missing actions in general. Missing actions included limited action on achieving Good Environmental Status (GES) in marine protected areas (MPA), action on bottom trawling, action on regeneration, and action on the importance of protecting 'blue carbon' habitats (as outlined in the Scottish Government's Programme for Government).

'The actions lack a plan for achieving Good Environmental Status (GES), which was a previous commitment to have been achieved by 2020.' (Sustainable Inshore Fisheries Trust (SIFT))

'Regarding marine issues, additional actions are needed to restore our marine ecosystems, including spatial management of bottom-towed fishing. Also, active regeneration is needed (i.e. seagrass planting and oyster reintroduction).' (Organisational response)

The actions relating to deer management were welcomed by many stakeholders, noting that these actions were examples of best practice for implementation and monitoring. This includes responses from conservation and deer management groups.

'We are very supportive of the need for robust deer management. The actions included under this priority action are a good example of how actions could be SMART, as they include specific and measurable figures for deer densities that are achievable, realistic and time-based. We would, however, like to see the same approach to the establishment of a national deer management programme.'(Scottish Wildlife Trust)

'[We] welcome a national deer management programme, as outside the deer management group area, little is known about deer numbers, cull levels, larder facilities, and the fundamentals of deer management planning.' (Association of Deer Management Groups)

Whilst the ambition of actions relating to water and air quality was welcomed, several organisational respondents suggested areas in which important actions were missing or could be further strengthened. These include river restoration and nature-based solutions.

'There is nothing in here about restoring natural flows in rivers and streams. We should have a programme of river restoration which includes the removal of redundant weirs and dams. There is nothing about restoring standing freshwater bodies, lakes, ponds, ditches, etc.' (Scottish Environment LINK)

'Water management, for example, should prioritise nature-based solutions which tackle water quality and/or extremes of water availability and which also enhance biodiversity — this is hinted at in the current wording but could be stronger.' (Hydro Nation Chair Research and Innovation Programme)

There were mixed responses to actions relating to grouse moor management, with respondents who agreed and some who disagreed with the proposed actions seeking clarity as to potential legislation and licensing approaches. The majority of organisational respondents who provided comments on grouse moor management were strongly in favour of these actions, suggesting that they would have a large impact on Scotland's ability to meet its biodiversity objectives, considering the scale of land that this would involve.

A few respondents provided specific comments relating to actions on the Muirburn Code, noting that the inclusion of the phrase 'by exception' could constitute a deviation from what will be prescribed in forthcoming primary legislation and that this wording should therefore be removed from the Delivery Plan.

Objective 2: Protect Nature on Land and at Sea across and beyond Protected Areas

This section relates to questions 2d (closed response n=259 and open-text response n=235), 2e (closed response n=242 and open-text response n=229) and 2f (open-text response n=205).

Respondents provided a range of comments on the priorities and actions set out under this objective, including reference to the 30 by 30 and Nature Networks Policy Frameworks elsewhere in the consultation document. This included comments that key actions outlined in the 30 by 30 framework, including finalising criteria, establishing governance, and incorporating provisions in the Natural Environment Bill, should be explicitly referenced under this objective for consistency.

Mixed perspectives relating to land use and policy were provided under this section, including the need for a holistic approach to land management and use, and the need for clear leadership in cases of potential conflicting uses. Actions related to protected area sites were noted to need further strengthening, including the introduction of buffer zones relevant to the size of the specific protected area.

'Protecting land and sea across and beyond protected areas requires a holistic approach sensitive to the broader context of just transition. This includes working towards a fairer distribution of land and the opportunities for environmental stewardship through biodiversity-friendly practices such as agroecology.' (Scottish Crofting Federation)

'Designation of additional protected sites [needs] to consider minimum area for effective conservation and how they link up across the landscape and with Nature Networks under a changing climate. The BES Protected Areas Report found that including buffer zones, habitat corridors, and OECMs [is] key to building ecological resilience and biodiversity.' (Chartered Institute of Ecology and Environmental Management)

Responses relating to monitoring sites were broadly welcomed by respondents over both land and sea; however, the monitoring of sites was noted to need further detail on 'adaptive management framework', with greater urgency needed on delivering this outcome before 2028.

'We welcome the actions regarding implementing a monitoring regime to ensure that protected area sites deliver their objectives, but this must be coupled with adaptive management to ensure that the management measures are adjusted should such monitoring show that objectives are not being met.' (Fisheries Management Scotland)

Respondents gave broad responses relating to planning and development measures, with comments requesting more details on the proposed guidance to support the National Planning Framework 4 (NPF4) biodiversity policy, as well as stronger wording than 'explore' within actions on biodiversity metrics.

'Land use change is one of the main drivers of biodiversity loss. The successful implementation of NPF4 will be critical to preventing future loss of biodiversity and enhancing biodiversity through land use change.' (John Muir Trust)

Whilst respondents were broadly positive about the proposed approach to improving biodiversity in green and blue spaces, a few respondents provided comments relating to the need for more tangible actions with clearer outcomes.

Several respondents referenced more detailed comments provided in other sections of the consultation document in relation to commitments relating to 30 by 30, Nature Networks, and National Parks, which are also addressed elsewhere in this report. In line with responses to these sections, several local authorities provided feedback relating to the need for clarity and resources for the delivery of several actions under this objective.

'Delivery of Nature Networks, application of NPF4 biodiversity policies, and use of a biodiversity metric will require significant staff resource and expertise in LAs. It will also require increased availability of trained ecological consultants.' (Falkirk Council)

Overall, respondents were unsure that the actions were sufficient to put Scotland on track to ending the loss of biodiversity by 2030, again due to the need for further details on implementation and outcomes.

Objective 3: Embed Nature-Positive Farming, Fishing and Forestry

This section relates to questions 2g (closed response n=251 and open-text response n=228), 2h (closed response n=230 and open-text response n=207) and 2i (open-text response n=190).

As with previous objectives, closed-response questions elicited a negative response to Objective 3, with the majority of respondents disagreeing or unsure that the Delivery Plan captured the key actions needed to deliver this objective. This was driven by a range of factors, specifically with regard to implementation, accountability, and balancing potentially competing land uses and priorities.

'The industries mentioned here are under financial pressures, and some operators, particularly small-scale ones, may find it difficult to make the required changes even if they wish to do so. Others are unlikely to make the changes required unless they are mandated to do so.' (Chartered Institute of Ecology and Environmental Management)

In relation to action on farming, several respondents agreed that the most impactful action would be related to new agricultural support payments and the incorporation of a biodiversity audit, which several respondents suggested would be a powerful lever with which to encourage nature-positive farming. A few responses emphasised the need to align the actions on agricultural support payments with the Agriculture Bill and demonstrate these links clearly in the Delivery Plan. A range of respondents expressed caution in ensuring that biodiversity audits would be simple and practical and not add a considerable burden on farmers.

Whilst a range of organisational respondents were positive about the support for farming methods, several offered perspectives related to farming systems. This included the encouragement of agroforestry systems as well as support for small-scale farming systems and crofters. Actions on soil health and measurement were well received across organisations, whilst some organisations noted that increased focus was needed in relation to water outcomes.

'The agricultural reform programme has huge potential for moving the needle on biodiversity. However, the budget must be decisively aligned with the need to change not just farming practices but also farming systems.' (Nourish Scotland)

'We would like to see more metrics and targets, for example, on reducing pesticide usage, on increasing the percentage share of land under organic management, or the area of land under agroforestry systems, to drive progress towards this 2030 target.' (Soil Association Scotland)

'We would wish to see more recognition of water outcomes beyond nutrient runoff and riparian buffers in the discussion of nature-positive approaches to forestry and farming.' (Hydro Nation Chair Research and Innovation Programme)

Many individuals and organisations noted the economic impact on farmers and communities, highlighting the importance of a focus on food security and the fact that food production must remain the central economic driver for farming businesses.

'The whole farm plan and associated audits should not result in prescriptive actions being undertaken. They should empower farmers and crofters to make their own decisions based on the results of the plan and give them flexibility in how they want to manage their land in an efficient and sustainable way going forward.' (NFU Scotland)

'There is extensive focus on new audits, checks and regulations, particularly a new biodiversity audit […]. We remain concerned that there are plans to introduce conditionality to funding models without clear benchmarking and impact assessments at a regional level.' (Scottish Red Meat Industry Resilience Group)

'For farming, there is a lot of testing, declarations, audits and planning — none of which will necessarily translate into actions that deliver for nature.' (Stockfree Farming)

Regarding actions on fishing, the most impactful actions were attributed to those related to protecting vulnerable ecosystems outside of marine protected areas (MPA), including bottom dredging, eliminating bycatch, and substituting low-impact fishing gears for high-impact ones. A few responses highlighted the importance of obligations under Section 25 of the Fishing Act 2020, while others stressed the importance of achieving Good Environmental Status (GES) for marine habitats.

Regarding sea fisheries management, some stakeholders cautioned against rushing to implement further management measures in MPAs and elsewhere before there has been time for the effects of existing management measures to become apparent.

'We are disappointed that the consultation focuses only on negative aspects of fishing […] and fails to acknowledge the many ways in which fishing is already 'nature-positive'. It also fails to recognise that the purpose of fishing is to produce food and that all forms of food production involve trade-offs — it is impossible to produce food without having effects on the environment.' (Shetland Fishermen's Association)

'The Bute House Agreement promised 'to consult as soon as is practicable on proposals to apply a cap to fishing activity in inshore waters' and 'set a ceiling from which activities that disrupt the seabed can be reduced in the light of evidence as it becomes available', but still this remains to be seen.' (Sustainable Inshore Fisheries Trust (SIFT))

In relation to Scotland's vision of sustainable aquaculture, a few respondents noted that the reference to the farmed fish health framework should be amended to encompass all fish, not merely those that have been farmed, with the action relating to escapes needing further ambition to address the underlying issue of genetic introgression of farmed genes into wild populations.

'We are broadly supportive of the actions set out in the plan, with the exception of the actions related to Scotland's vision for sustainable aquaculture. The actions included are a very small subset of the requirements for delivering the vision.' (Fisheries Management Scotland)

Regarding actions relating to the forestry sector, many responses welcomed the fact that large-scale action in forestry is required, including the need to improve biodiversity benefits from all woodlands as well as the facilitation of natural regeneration of woodlands. These included measures with which to restructure woodlands and diversify age and species mixes; some suggested that a specific reference to the Nature Networks Policy Framework in relation to connectivity was needed within the Delivery Plan.

'A programme to bring [ancient woodland] into favourable condition is welcome. We support this action and recognise that although starting with protected woodlands in unfavourable condition is sensible, many of the pressures acting on these woodlands (e.g. grazing, INNS) operate at the landscape scale and must be tackled at this scale.' (Woodland Trust Scotland)

A few local authority responses provided examples of key actions which were missing in relation to local area forestry and woodland strategies, which are required under the Planning (Scotland) Act 2019. It was suggested that these should require identification and protection of ancient woodlands for future restoration, ensuring that semi-natural urban woodlands of any age are under positive management. Some stakeholders noted the importance of trees and woodlands in urban areas for both biodiversity and climate adaptation through canopy cover, urban cooling, and floodwater alleviation.

Respondents highlighted the importance of land ownership, management and use in relation to forestry and woodlands, including community ownership and engagement. Many noted competing priorities between agriculture, commercial forestry, and woodland planted for the purposes of biodiversity and carbon benefits.

'The suggested objectives currently feel too diluted with clearer messaging needed, as the strategy does not seem to address how the conflict between different land uses will be balanced.' (Institute of Chartered Foresters)

'There is not sufficient emphasis on community engagement, including community ownership and management of land. Rebuilding the connection between people and environment so that people initiate, manage and sustain positive environmental works in all sectors of society is essential and largely missing throughout this consultation.' (The Community Woodland Association)

Objective 4: Protect and Support the Recovery of Vulnerable and Important Species and Habitats

This section relates to questions 2j (closed response n=200 and open-text response n=173), 2k (closed response n=179 and open-text response n=151) and 2l (open-text response n=144).

In general, respondents were positive about the overall ambition of this objective, with many respondents agreeing with the principle of the need to complement habitat restoration actions with actions targeted at specific species. The negative sentiment in response to this objective centred on the volume of respondents who advocated for an ecosystem approach, and concerns surrounding the progress of conservation status within marine habitats. Where respondents did not agree that the actions were sufficient to put Scotland on track to ending the loss of biodiversity by 2030, this was driven by a range of factors including feedback on the approach adopted, the timescales suggested, and a lack of focus on specific species.

Respondents were overwhelmingly positive about the proposed revision of the Scottish Biodiversity List and the reference to the Better Biodiversity Data project, with several organisational responses highlighting the need for multi-year funding for this project. There were suggestions to make the Scottish Biodiversity List user-friendly to promote effective usage across sectors. Respondents raised concerns regarding a delay in the provision of a revised list of priority marine features (PMF), with several respondents concerned about high-impact fishing methods of scallop dredging and bottom trawling as well as the timeline proposed for the action relating to PMFs. Several responses suggested that the review of species licensing has the potential to have the biggest impact.

'The more accessible the resource, the more readily it will be utilised by applicants, developers and determining planning officers.' (East Ayrshire Council)

Specific comments on the focus on priority species and species recovery included: that conservation action should not be based on species charisma or popularity or on endangered status, that greater focus should be placed on the maintenance of genetic diversity for species resilience, and that the Biodiversity List has above-ground and below-ground species with which to support soil health and carbon sequestration. A few organisational responses highlighted the need to broaden the focus on freshwater species beyond Atlantic salmon and ensure that other critical fish populations integral to Scotland's biodiversity are adequately acknowledged and protected.

Some organisational respondents demonstrated concern regarding the focus on reintroductions as a pathway to habitat restoration, whilst several responses gave the example of the introduction of beavers as 'ecosystem engineers'. The focus on species recovery and reintroduction was challenged by many responses, noting that the most effective approach to supporting species on land and sea was to adopt a whole-ecosystem approach, including achieving Good Environmental Status (GES) in the marine environment. However, a few organisational responses (including the RSPB and the Scottish Chough Forum) welcomed the action on species recovery and the collaborative approach in developing the prioritisation of species, including incorporating species vulnerability in Scotland.

'SRUC believes that there is a lack of ecosystem approaches in conservation efforts. While species of concern are protected, direct action supporting essential ecosystem functions, like pollination and decomposition, is insufficient.' (Scotland's Rural College)

'The most effective [measure] to protect and support these vulnerable species and build resilience to climate impacts in the medium to long term is to work at landscape scale, restoring the diversity and functionality of ecosystems at scale.' (Trees for Life)

The action deemed to be most impactful by most was the revision of the Scottish Biodiversity List, followed by a review of Nature Scot's licensing approach to species conservation and management. Moreover, reducing human pressures on species was considered to be highly impactful; however, several responses sought clarification as to how this would be achieved in practice.

Objective 5: Invest in Nature

This section relates to questions 2m (closed response n=197 and open-text response n=176), 2n (closed response n=170 and open-text response n=144) and 2o (open-text response n=132).

Many respondents welcomed the general aims and intention under this objective; however, a negative response to closed-response questions was driven by firmly held opposing views on the role of private finance as well as calls for additional funding in order to meet the 2030 targets.

Several responses suggested that the action which will have the most impact will be the development of a Biodiversity Investment Plan for Scotland to support the delivery of the Scottish Biodiversity Strategy, in recognition of the implementation and resourcing challenges across the Delivery Plan.

'If this is created and provides clarity on the resources and resource allocations required to implement the changes necessary, then it should provide a route map for delivery and addressing the decline in biodiversity. However, this should require additional resources to support its development and collation at a regional level to ensure parity and consistency across Scotland.' (Dumfries and Galloway Council)

'We also need a Biological Recording Fund to adequately resource the biological recording infrastructure in Scotland as per the SBIF [Scottish Biodiversity Information Forum] Review.' (Scottish Biodiversity Information Forum)

One of the key elements in resourcing the delivery of the Biodiversity Strategy is the timescale over which resources need to be made available. Long-term funding was particularly important for many specific nature restoration activities, for data collection, and to create and retain green jobs. Equally, the governance of funding mechanisms was noted to have a considerable impact on the types of organisations which could apply for and deliver work. For example, where the lead partner is expected to take on significant financial liability, this may present a barrier for farmers and community organisations in accessing grant funding, whilst a focus on large-scale or area-based outcomes may exclude crofters from funding opportunities.

'Controlling INNS takes 15–20 years, but resources are only available for 2–3. Consequently, the work is not undertaken and the cost of such work is rising almost exponentially.' (Organisational response)

'Many potential projects that the farming community would like to undertake are not being funded […] and there is no simple funding measures open to farmers to improve biodiversity on [farms] in a way that does not negatively impact the farming side of their business.' (NFU Scotland)

Actions on establishing a value-led, high-integrity market for responsible private investment in natural capital elicited mixed responses, with many respondents eager for funding from all sources in recognition of the positive outcomes that well-directed investments can achieve. Several individual responses highlighted concerns surrounding the potential for 'greenwashing', with organisations noting the need for strong and robust evidence to demonstrate that private finance delivers for the environment, climate, and rural communities.

A few responses referred to a report by The James Hutton Institute on the causes of biodiversity decline, highlighting the need for adequate safeguards against unintended outcomes caused by carbon markets, or any similar possible schemes for biodiversity. Equally, Net Zero Scotland emphasised the opportunity to reduce environmental impact through a focus on circular procurement practices as part of the delivery of both public funds and private investment.

'With the substantial sums required I think that there is not much option but to try and attract private investment to aid the government in achieving its nature targets.' (Individual response)

'We do not consider that the private investment market is mature enough to deliver at scale and pace, and consider that public financial support will still be required to ensure the development and delivery of large, landscape-scale projects in the short term.' (Organisational response)

'At present, investments and management for carbon will continue to dominate 'green' private sector investments. If this continues it may lead to unintended consequences that do not support holistic land management that balances multiple societal objectives.' (The James Hutton Institute)

Overall, a focus on increasing investment in coastal and marine environments was welcomed by respondents. Similar to broader restoration funds, funding mechanisms in this sector had the potential to overlook certain stakeholders including fishing communities for Scotland's Marine Environmental Enhancement Fund (SMEEF) as well as eNGOs for the Water Environment Fund.

'Unlike in terrestrial systems, much of the work that needs to be done to recover marine environments and biodiversity is actually through better managing and adapting to pressures. Current funding systems do not work well for this.' (Open Seas)

'We would caution against the implementation of a central levy on developers to deliver marine biodiversity benefit. As a regulated business, we are funded by [Great British] electricity bill payers and need to ensure that any cost to our business is accountable to consumers.' (Scottish & Southern Electricity Networks)

Both the trajectory and the investment in green skills were welcomed across several respondents, in recognition of the workforce investment needed to deliver the wider Delivery Plan. The barriers facing new entrants to the ecology and environmental sector were highlighted. These included both entry pathways and mid-career changes, as well as an overreliance on volunteers, and an unquantified capacity crisis in the sector.

'Lack of expertise and capacity is a real risk for delivery of the framework. Unless we have the right people in the right number, a lot of the objectives won't happen.' (Chartered Institute of Ecology and Environmental Management)

Objective 6: Take Action on the Indirect Drivers of Biodiversity Loss

This section relates to questions 2p (closed response n=188 and open-text response n=160), 2q (closed response n=169 and open-text response n=138) and 2r (open-text response n=137).

Overall, responses were mixed as to whether the delivery plan captured the key actions needed to deliver this objective. It should be noted that this is the only objective for which more people agreed that the key actions had been captured in the Delivery Plan, with one third of responses saying 'Yes' (35 per cent or 65 respondents), one third saying 'No' (32 per cent or 60 respondents), and one third 'Unsure' (34 per cent or 63 respondents).

Many respondents expressed a strong positive sentiment towards the addition of the sixth objective of tackling the indirect drivers of biodiversity loss, particularly the ambition of the proposed actions. However, respondents highlighted the challenges associated with behavioural change and the resources required to deliver this effectively and to make tangible progress.

'Whilst we support the ambition in this section, we do not consider that the identified actions will move the dial in a meaningful way.' (Fisheries Management Scotland)

The inclusion of actions with which to help connect people with nature was welcomed across both individual and organisational responses. Several responses highlighted that developing an effective communications and engagement programme appeared to be challenging, particularly within the proposed timescales.

'The most effective way to achieve long-term impact on addressing biodiversity loss is through empowering people, informing and helping them to understand how crucial our natural capital assets are to our future.' (South of Scotland Enterprise)

'While awareness raising is essential to engender behaviour change, it is unlikely to prove sufficient by itself. Communication campaigns should be accompanied by private sector action, if needed with the assistance of public sector partners.' (Scottish Borders Council)

Action relating to community ownership elicited mixed responses. Whilst many provided positive comments on the principle of community ownership, and increased engagement, there were several comments related to the capacity of community organisations to deliver these actions, the need for greater focus on community engagement throughout the Delivery Plan, but also the need for evidence that community ownership would be effective in delivering impacts for the community and the environment.

'Building community agency and consent into these projects — moving beyond the nebulous term of engagement. Without this, and in the absence of long-term commitments, this is where the longevity of nature-positive works [lies].' (Community Land Scotland)

There was widespread support for the intention to embed biodiversity and nature in curriculum development. Suggestions included extending this to tertiary education, pre-schooling provision, and support for youth groups. A few responses highlighted the value of outdoor learning as well as forest schools for young people, with a few noting the importance of universal provision to ensure access to nature for young people in urban areas and to address diversity in engagement with the outdoors.

'We must ensure that educational programmes increase children's understanding of environmental issues and strengthen their capacity to respond to environmental challenges.' (Children and Young People's Commissioner Scotland)

'This could go further with the creation of nature-based qualifications equipping young people with the academic and practical skills to contribute positively to the nature-based economy and support progression into careers in nature-based sectors.' (East Dunbartonshire Council)

Proposals to mainstream and integrate biodiversity policy across government were broadly welcomed. Many individual respondents noted the need for a coordinated approach to tackle the scale of the crises. A few sought clarity as to the term 'mainstream', whilst one local council sought further details on the implementation of this action in practice.

'Action would be welcomed to create pathways that would be able to facilitate collaboration between different policy areas and strategies. It should be recognised that the knowledge and skills gap within organisations plays a significant role in the lack of joint-up working in policy delivery.' (North Ayrshire Council)

Stakeholders offered positive perspectives on the recognition of addressing unsustainable supply and demand, including reference to the Circular Economy Bill. Net Zero Scotland gave further details on specific actions relating to microplastics, whilst others provided perspectives relating to the importance of action which facilitated corporate responsibility for addressing the indirect drivers of biodiversity loss.

'We believe this item to be extremely important in any successful engagement or implementation. The establishment of explicit mechanisms of measurement, monitoring, management, and reporting on their impact is essential. A mandatory mechanism (rather than a voluntary one) would ensure widespread adoption and adherence.' (Ecus Ltd)