Respond to the Scottish Government's Nature Emergency Consultation

The Scottish Government is seeking views on a range of topics and proposals related to biodiversity and tackling the nature emergency in Scotland. We’ve told them we want to see Scotland declared a Rewilding Nation, with 30% of land and seas committed to rewilding by 2030.

How you can help

A consultation is open for views until 14th December 2023. Use the consultation to tell the Scottish Government you’re backing the dream of a Rewilding Nation.

To help you get started with submitting your answers online, we’ve created a guide response for you to use below.

The Scottish Rewilding Alliance is submitting a response to the consultation, and we’re encouraging you to do the same, with the support of our guidance below. 

Your consultation response

To help you get started with submitting your answers online here, we’ve created a guide response for you to use below – but adding your own thoughts will send a more powerful message to the Scottish Government. 

Respond to the consultation

Part A - Section One: Scottish Biodiversity Strategy

No questions.

Part A - Section Two: Scottish Biodiversity Delivery Plan - Chapter 1

No questions.

Part A - Section Two: Scottish Biodiversity Delivery Plan - Chapter 2

2a. Have we captured the key actions needed to deliver the objective: accelerate restoration and regeneration?

Suggested answer: No.

Suggested explanation:

I am calling on the Scottish Government to declare Scotland the world’s first Rewilding Nation, with 30% of land and seas rewilding.

We desperately need some areas where the balance shifts in favour of nature. We also need areas where people and nature coexist, with a mosaic of nature-friendly land and marine uses allowing nature to bounce back while communities thrive. When it comes to marine restoration, additional actions are needed, including active regeneration (seagrass planting, oyster reintroduction, etc).

Rewilding is a global movement that has inspired people across Scotland to take action to restore nature. Scotland has the experience, the space, the resources and the responsibility to rewild. Rewilding is the large-scale restoration of ecosystems to the point where nature can take care of itself. It can only be achieved by recognising that we must encourage a balance between people and nature so that we can thrive together. In Scotland, rewilding and repeopling go hand in hand. 

2b. Are the key actions, to support the objective: accelerate restoration and regeneration, sufficient to put Scotland on track to ending the loss of biodiversity by 2030?

Suggested answer: No.

Suggested explanation:

Ideas like rewilding, the large-scale restoration of nature to the point where it can take care of itself, could turbocharge efforts to restore and regenerate Scotland’s biodiversity. The actions proposed on marine restoration and regeneration need to be bolder and more urgent.

I call on the Scottish Government to consider rewilding interventions in support of its objective to accelerate restoration and regeneration in order to end biodiversity loss by 2030. 

2c. Which actions do you think will have most impact?

Suggested answer:

Actions that embrace scale, like creating landscape restoration partnerships and restoring precious habitats like Scotland’s rainforests and Caledonian pinewoods, will have the most impact. In our seas, only “delivering additional protection for spawning and congregation areas” will deliver any impact.

Part A - Section Two: Scottish Biodiversity Delivery Plan - Chapter 3

2d. Have we captured the key actions needed to deliver the objective: protect nature on land and at sea across and beyond protected areas?

Suggested answer: No.

Suggested explanation:

Despite decades of effort, Scottish wildlife continues to decline. Layers of legislation, intricate classification schemes and an army of volunteers have not halted, let alone reversed, biodiversity loss. Rewilding offers a new, complementary and affordable approach to traditional conservation and nature restoration methods. On land and at sea, we need to regenerate nature at sacle - not focus on protecting small site designations.

I call on the Scottish Government to support rewilding and embed its principles throughout its actions, frameworks and policies. 

2e. Are the key actions, to support the objective: protect nature on land and at sea across and beyond protected areas, sufficient to put Scotland on track to ending the loss of biodiversity by 2030?

Suggested answer: No.

Suggested explanation:

Protecting nature through traditional conservation alone puts nature in a holding pattern. Our existing landscape designations have not prevented nature loss. The lack of management measures for marine sites has held back the recovery of Scotland's seas. In order to stop the decline of nature, we have to think about not only protecting nature but also restoring the dynamic natural processes that make up a healthy ecosystem. In contrast to a species-focused, fine-tuning approach, rewilding takes a looser, systems-based approach. Rewilding focuses on the large-scale restoration of ecosystems. It aims to give nature the space and freedom to recover, grow and adapt on its own terms. Natural processes drive change, leading to more resilient ecosystems. 

That is how nature ‘protects’ itself. I call on the Scottish Government to lead nature lead.

2f. Which actions do you think will have most impact?

Suggested answer:

A refreshed approach to how we manage National Parks, National Nature Reserves and protected areas will have a great deal of impact on the space we leave for nature and our relationship with nature. 

Getting Nature Networks right could have a considerable impact on Scotland’s ambition to halt biodiversity loss. Nature Networks should be connected; at sufficient scale; and focused on the restoration of natural processes. Local authorities should be given the resources they need to make a success of Nature Networks. 32 Nature Networks consisting of connected sites managed for nature recovery, managed by skilled people, working along rewilding principles, could be transformative. 

Part A - Section Two: Scottish Biodiversity Delivery Plan - Chapter 4

2g. Have we captured the key actions needed to deliver the objective: embed nature positive farming, fishing and forestry?

Suggested answer: No.

Suggested explanation:

In order for human activities like agriculture, forestry and fishing to survive climate breakdown, we need drastic ecosystem restoration on a huge scale. Across these land uses, we need policy frameworks focused on the goal of nature recovery. Achieving a balance between nature and people will be all but impossible without drastic action to restore nature - now. I call on the Scottish Government to urgently support rewilding across 30% of land and seas.

2h. Are the key actions, to support the objective: embed nature positive farming, fishing and forestry, sufficient to put Scotland on track to ending the loss of biodiversity by 2030?

Suggested answer: No.

Suggested explanation:

There are many bold decisions that need to be made over the coming years. Between now and 2030, the steps we take will decide how ready we are as a nation to take on the challenges of an abruptly changing climate. Assuming that these actions are fully delivered, it might be possible for Scotland to slow the decline of biodiversity. In order to halt that decline - let alone reverse it - these actions must be part of a bolder vision for Scotland’s nature and people. I support the vision of a Rewilding Nation where 30% of land and seas are committed to rewilding.

2i. Which actions do you think will have most impact?

Suggested answer: 

The implementation of riparian buffers, fisheries management measures and encouraging the natural regeneration of woodlands are key actions that could help nature recover at scale.

Part A - Section Two: Scottish Biodiversity Delivery Plan - Chapter 5

2j. Have we captured the key actions needed to deliver the objective: protect and support the recovery of vulnerable and important species and habitats?

 Suggested answer: No.

Suggested explanation:

Ecosystems cannot function properly where certain ‘keystone’ species are missing. Failure to reintroduce key species will diminish our ability to end the decline of nature.  I call on the Scottish Government to embrace rewilding principles and look at what is missing from Scotland’s ecosystems. 

2k. Are the key actions, to support the objective: protect and support the recovery of vulnerable and important species and habitats, sufficient to put Scotland on track to ending the loss of biodiversity by 2030?

Suggested answer: No.

Suggested explanation:

Conservation is a vitally important activity and has preserved precious species in Scotland. It is incredible to see red squirrels, pine martens, water voles and other species flourishing. But it doesn’t always have to be down to humans. By targeting efforts at keystone species, we can turbocharge our efforts to halt biodiversity loss - and then reverse it. I call on the Scottish Government to embrace rewilding principles. 

2l. Which actions do you think will have most impact?

Suggested answer:

Actions focused on recovering, reintroducing and reinforcing key species will have the most impact. 

Part A - Section Two: Scottish Biodiversity Delivery Plan - Chapter 6

2m. Have we captured the key actions needed to deliver the objective: invest in nature?

Suggested answer: No.

Suggested explanation:

The government must establish a values-led, high-integrity market for responsible private investment in natural capital. Community benefits are a crucial element of this. The government also needs to ensure that rewilding is supported by public spending and investment, particularly for smaller projects or community-led groups who struggle to access funds.

2n. Are the key actions, to support the objective: invest in nature, sufficient to put Scotland on track to ending the loss of biodiversity by 2030?

Suggested answer: No.

Suggested explanation:

While I welcome the government’s planned actions on investing in nature, we believe that this needs to be ramped up again. Vital rewilding projects have achieved funding through the Nature Restoration Fund - more could be done. The government should also review how it supports rewilding projects through the rural subsidy framework. Funding for marine rewilding is also urgently needed.

2o. Which actions do you think will have most impact?

Suggested answer:

Investment in the rewilding workforce in general would significantly boost Scotland’s ability to meet its biodiversity targets. 

Part A - Section Two: Scottish Biodiversity Delivery Plan - Chapter 7

2p. Have we captured the key actions needed to deliver the objective: take action on the indirect drivers of biodiversity loss?

Suggested answer: No.

Suggested explanation:

Strengthening the connection between people and nature is key. The global rewilding movement inspires hope and catalyses change. It is a straightforward, popular message. 

Rewilding is supported across Scotland. In a poll conducted for the Scottish Rewilding Alliance in 2020 by an independent polling company, Survation, they found that 76 percent supported the idea, with only 7 percent outright opposed. 

By declaring Scotland to be a Rewilding Nation, with 30% of its land and sea committed to rewilding, the Scottish Government will be inviting everyone to be part of the effort to restore nature. 

2q. Are the key actions, to support the objective: take action on the indirect drivers of biodiversity loss, sufficient to put Scotland on track to ending the loss of biodiversity by 2030?

Suggested answer: No.

Suggested explanation:

The climate crisis has been mainstreamed across policy making in Scotland. When it comes to the nature crisis, we are still early on in that journey - and time is running out. 

In order to meet Scotland’s nature targets, we need to think bigger - and wilder. By tying all of the threads together into a cohesive vision - the world’s first Rewilding Nation - the government can inspire people to act. 

2r. Which actions do you think will have most impact?

Suggested answer: I welcome the proposed actions but call on the government to embrace rewilding as the thread that ties all the actions, policies, frameworks and systems together. 

Part A - Section Three: Nature Networks Policy Framework

3a. Do you have any comments on the Nature Networks Framework?

Suggested answer:

I welcome the establishment of Nature Networks. I encourage the government to work with councils to ensure that rewilding principles are embedded across these networks. With time to halt biodiversity loss running out, it’s imperative that we move from conserving nature to restoring and connecting nature.

Part A - Section Four: 30 by 30 Policy Framework

4a. Do you have any comments on the 30 by 30 Framework?

Suggested answer:

The selection and management of 30 by 30 sites should focus on nature recovery - and particularly on rewilding. 

Part A - Section Five: Impact Assessments

Skip section if needed.

Part B – Section Six: Statutory Targets for Nature Restoration

Suggested answer: Yes.

Suggested explanation:

I agree that statutory targets should provide clear focus, be ambitious and updateable. 

6b. The Targets Framework: Question: Do you agree with the criteria set out for the selection of targets?

Suggested answer: Yes.

Suggested explanation:

I agree with the criteria set out for the selection of targets. However, we would ask the government to prioritise ambition over alignment. Scotland could be a world leader in nature recovery. The targets set through this process should reflect that hope. 

6c. The Form of Targets: Do you agree statutory targets should include a combination of outcome targets and output targets?

Suggested answer: Yes.

6d. Examples of Potential Target Topics: Is the list of potential target topics sufficiently comprehensive in terms of the focus of proposed target areas and overall scope?

Suggested answer: No.

Suggested explanation:

In a nature emergency, we must use every tool in the box to address it. Rewilding is a potentially transformative land management tool that can be used to complement existing approaches. It is a growing global movement that inspires hope, catalyses change and provides significant opportunities for connecting people and nature. It should be a target topic.

6e. Do you have any other comments on the list of potential target topics?

Suggested answer: Yes.

Suggested explanation:

I would like to see these targets achieve real, lasting and widespread nature recovery in Scotland.

It is therefore our hope that in striving to achieve these targets, the government makes best use of every tool available to it. For example, in seeking to achieve targets around ecosystem integrity, it would be sensible to consider how the reintroduction of key missing species like lynx would help the government achieve that target. 

6f. Number of Targets Question: Do you agree with the proposal to have the smallest feasible number of targets which reflects the complexity of nature restoration?

Suggested answer: Yes.

Suggested explanation:

I agree that the number of targets should be as small as possible. It is therefore important to set targets that will have the maximum impact on a wide range of connected topics. 

Rewilding is a systems approach. It aims to give nature the space and freedom to recover, grow and adapt on its terms. The simplest possible target would be to ensure that 30% of Scotland is set on the path to rewilding. I call on the Scottish Government to declare Scotland a rewilding nation and set a target for 30% of land and sea to be committed to rewilding by 2030.

Part B - Section Seven: National Parks

7a. Purpose of National Park Authorities: Do you agree that the purpose of National Park authorities should be amended in order to emphasise the important leadership role that National Park authorities need to play in restoring nature and in mitigating and adapting to climate change?

Suggested answer: Agree.

Suggested explanation:

We need a fresh approach to national parks in Scotland that is fit to meet the challenges facing us. I believe that the overarching purpose of a national park should be the restoration of nature, in order to halt biodiversity loss and mitigate the effects of climate breakdown. 

7b. Aims of National Parks - First National Park aim: Do you agree with these suggested changes to the first National Park aim?

Suggested answer: Agree.

Suggested explanation:

I agree that it is appropriate to separate these aims and I support the mention of ecosystems within the first aim. 

7c. Second National Park aim: Do you agree with the suggested change to the second National Park aim?

Suggested answer: Agree.

Suggested explanation:

The Scottish Rewilding Alliance supports the rewording of the existing aims to better reflect other changes to the vision, mission and overarching purpose of our national parks.

7d. Third National Park aim: Do you agree with the suggested change to the third National Park aim?

Suggested answer: Agree.

Suggested explanation:

I support the rewording of the existing aims to better reflect other changes to the vision, mission and overarching purpose of our national parks.

7e. Fourth National Park aim: Do you agree with the suggested change to the fourth National Park aim?

Suggested answer: Agree.

Suggested explanation:

I support the rewording of the existing aims to better reflect other changes to the vision, mission and overarching purpose of our national parks.

7f. The National Park ‘principle’ Do you agree that the National Park ‘principle’ set out in section 9(6) of the 2000 Act should be retained? 

Suggested answer: Agree.

7g. Relevance of the National Park aims and the National Park principle to other public bodies operating within National Parks: Do you agree that public bodies operating within the National Park should have regard to the proposed National Park aims?

Suggested answer: Agree.

7h. Do you agree that public bodies operating within the National Park should have regard to the National Park principle?

Suggested answer: Agree.

I support the idea that other public bodies within a national park should have regard to the National Park principle. National park authorities need the support of other public bodies within the park area in order to solve the many challenges ahead of them. 

7i. Duty on public bodies to support implementation of National Park Plans

Suggested answer: Agree.

Suggested explanation:

I support the strengthening of the effect of the duty on other public bodies. National park authorities need the support of other public bodies within the park area in order to solve the many challenges ahead of them. 

7j. General powers of National Park Authorities: Do you agree with the proposal that National Park Authorities should be able to enforce byelaw breaches within National Parks by issuing fixed penalty notices rather than referring them to local Procurators Fiscal?

Suggested answer: Agree.

7k. Do you think that any other changes should be made to the general powers of National Park authorities?

Skip if needed.

7l. Governance of National Parks: Do you agree with the proposed changes to the governance of National Parks? 

Skip if needed.

7m. Do you have any other comments that you would like to make about the aims, powers and governance of National Parks?

Skip if needed.

Part B - Section Eight: Impact Assessments

Skip if needed.

Photo: scotlandbigpicture.com

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