Scottish Biodiversity Strategy 2022 - consultation response:
The evidence of biodiversity loss
- Using your own knowledge and the evidence presented, to what extent do you agree that there is a nature crisis in Scotland?
Why do you think that?
Please insert answer here:
Yes, although species to species, and across the country the picture is different. The State of Nature Scotland 2019 report revealed that from 1994 to 2016, 49% of Scottish species have decreased and 28% have increased in abundance[1].
- What do you see as the key challenges and opportunities of tackling both the climate and biodiversity crises at the same time?
Please enter response here:
RTPI Scotland recognises that addressing the twin climate and biodiversity crisis will be one of the defining challenges of our time. As set out in the consultation the issues have remained largely similar since the first Biodiversity Strategy was published in 2004. As further set out, the lack of mechanisms to mainstream biodiversity in policy areas was a key contributing factor for our collective failure to meet the Strategy’s ambitions and reverse biodiversity decline. We note that economic policy was highlighted as an area with the greatest opportunity to mainstream biodiversity. RTPI Scotland believes the planning system to be one of the fundamental mechanisms for mainstreaming biodiversity into policy areas and especially economic policy areas.
The planning system can support the delivery of nature-based solutions, protect high-biodiversity value habitats and helping support biodiversity enhancements through policy frameworks and the subsequent planning application process. The opportunities of tackling the twin crises lie in unlocking delivery of a number of other desired societal outcomes simultaneously. Through quality placemaking running alongside interventions, we can, for example, also try to reduce health inequalities and stimulate inclusive economic growth. Acting as a regulatory catalyst, planning can help integrate a broad range of interventions, stakeholders and funding streams in a place-based manner to achieve this. If utilised effectively the planning system can maximize the value of public and private investment targeted at the biodiversity and climate crises to unlock wider social and economic benefit whilst also bringing in novel funding streams. The central role of planners and the planning system in addressing the twin crises has been recognised in the draft NPF4 with proposals for universal policies (that is, ones that should be applied to all decision-making) on the climate and biodiversity[2] and in the recently published draft guidance on developing with nature[3].
A significant factor omitted from this consultation for our failings to reverse biodiversity decline is the reduction in resources/skills available to local authorities over the past 15 years, and in particular resourcing cuts to planning departments. In order to achieve nature recovery in Scotland, we need to ensure planning authorities are effectively resourced to undertake their work. Research from RTPI Scotland[4] has revealed significant concerns around the resourcing of planning services with:
- Nearly a third of planning department staff have been cut since 2009
- Planning authorities’ budgets have diminished in real terms by 42% since 2009
- In 2020 local authorities only spent 0.38% of their total net revenue budgets
- Planning application fees only cover 66% of their processing costs
- There are 91 new and unfunded duties in the Planning (Scotland) Act, which could cost between £12.1m and £59.1m over 10 years
Research has also showed that planning has demographic and succession challenges with a limited pipeline. Only around 9% of staff in planning authorities are under 30 and there is an estimated replacement demand of around 500 planners over the next 15 years. Therefore, RTPI Scotland calls on Scottish Government to ensure that resource is also made available to increasing the pipeline of planners and to develop the necessary skills in our existing workforce to tackle the biodiversity and climate crises. An effective consenting process relies heavily on the collaboration between planning authorities and a range of statutory consultees. It is vital that they too have the necessary resources to support their work. RTPI Scotland is concerned with findings from the recently published report by CIEEM looking at LPA ecological expertise and capacity in Scotland. This work revealed significant cuts to local authority ecological provisions in recent years, with low to no capacity of ecological resource or expertise available to planning authorities alongside a lack of planning enforcement staff monitor compliance[5].
Our strategic vision – framing and context
- Is the draft vision clear enough?
- Yes
- No
Please enter comments here:
No comment.
- Is the draft vision ambitious enough?
- Yes
- No
Please enter comments here:
RTPI Scotland would advocate for the inclusion of wording that include ambitions to unlock wider economic and societal value, with specific reference made to the Place Principle or place-based approaches.
- Do you have any suggestions for a short strategic vision which would form the title for the strategy?
Please enter suggestions here:
No comment.
Scotland’s rural environment – farmland, woodlands and forestry, soils and uplands
- Do the 2045 outcome statements adequately capture the change we need to see?
- Yes
- No
Please enter response here:
An area in the 2045 outcomes that could be strengthened would be the inclusion of consideration of upland and forestry related development. The need to deliver the right development in the right place for nature can be seen with, for example, the significant impacts and implications of hill tracks, windfarms and reservoirs have in upland areas. Therefore, planning and development should not be seen as solely an urban issue and be integral to this section. Further to this the section ‘Towards a nature-rich landscape in the lowlands’ should be strengthened to include the role of Nature-Based Solutions. Whilst a new national park is expected in this parliamentary term, no mention has been made to it and how it could contribute to outcomes, be a milestone in itself or support the delivery plan.
- Are the 2030 milestones ambitious enough?
- Yes
- No
In the consultation and elsewhere, Scottish Ministers have set out commitments to maintaining or exceeding EU environmental standards. However, when comparing the 2030 milestones set out in this consultation to the key commitments of the EU Nature Restoration Plan in the EU Biodiversity Strategy for 2030[6] we are not clear that this will be achieved. This can be seen with, for example, a slower timeframe for legally binding nature restoration targets and less prescriptive and specific restoration targets set out. For example, should we be setting out clear set out clear for targets deer reduction?
Are we missing any key elements? Please enter response here:
RTPI Scotland would wish for better recognition in this section of the need to use economic policy to contribute to the ambitions set out. Should we, for example, provide a plan to help transition people out of jobs, activities and industries in upland areas that we know are detrimental to biodiversity enhancements and/or climate change impacts through providing training and green job opportunities? This would be a similar approach taken, for example, with the oil industry in Scotland.
- What are the key drivers of biodiversity loss in this outcome area?
Please enter response here:
RTPI Scotland believe the key drivers of biodiversity loss in this outcome area to be:
- High deer populations
- Upland land use management practices such as grouse moor management
- Lack of nature friendly farming
- What are the key opportunities for this outcome area?
Please enter response here:
RTPI Scotland believe the key opportunities in this outcome to be:
- Reintroduction of species such as beavers
- The establishment of Compulsory Land Use Management Plans as set out in the current Scottish Government land reform consultation
- Significant deer culls
- Economic transformation to change or enhance land-use management and activities
- What are the key challenges for this outcome area?
Please enter response here:
As set out in response to this section, we believe that planning and development should be seen as integral to Scotland’s rural environment and directly involved with farmland uses, woodlands and forestry, soils and uplands. Planning can manage the development and use of land in the long-term public interest, which includes delivering a nature-rich society. To do so, resource and skills issues set out in response Q2 need addressed.
Marine environment
- Do the 2045 outcome statements adequately capture the change we need to see?
- Yes
- No
Please enter response here:
Similarly to our response to the previous question, we would advocate for the inclusion of development considerations in the section in terms of context, issues and outcomes. This is especially important to consider given the large seabed auctions recently undertaken by Crown Estate Scotland for offshore wind. In particular, this section should be strengthened with reference the National Marine Plan and Regional Marine Plans.
- Are the 2030 milestones ambitious enough?
See response to Q7.
Are we missing any key elements? Please enter response here:
No comment.
- What are the key drivers of biodiversity loss in this outcome area?
Please enter response here:
No comment.
- What are the key opportunities for this outcome area?
Please enter response here:
RTPI Scotland believes marine planning and land use planning at the national level should be better aligned to allow for a coherent cross over between both disciplines which are so thoroughly interlinked and interdependent. As we have set out elsewhere previously, we believe the National Marine Plan should be refreshed and are also concerned over the lack of development of Regional Marine Plans. Whilst Marine Planning is a relatively new and developing field, its value should not underestimate, because as with on land, we can deliver the right development in the right place through coordinated, long-term, and strategic thinking to the benefit of both nature and people.
- What are the key challenges for this outcome area?
Please enter response here:
As with the response to the previous section, dedicated marine planning teams are very rare in Scotland and will be subject to the same resourcing issues faced throughout planning authorities as set out in response to Q2.
Freshwater environment: rivers lochs and wetlands
- Do the 2045 outcome statements adequately capture the change we need to see?
- Yes
- No
Please enter response here:
The role of planning and development and its impacts on the freshwater environment, has not been fully considered in this section. This is particularly pertinent given current difficulties being experienced in England and Wales around Nutrient Neutrality stopping developments already with planning permissions. A suggested outcomes to be included would be the widescale delivery of nature-based solutions to reduce the impact of development on freshwater systems.
- Are the 2030 milestones ambitious enough?
See response to Q7.
Are we missing any key elements? Please enter response here
See response to Q16.
- What are the key drivers of biodiversity loss in this outcome area?
Please enter response here:
RTPI Scotland believes that lack of natural riparian woodland and natural watercourses, land use management activities and inadequate wastewater infrastructure to be the biggest drivers in this area. Land use planning will also be a contributing factor.
- What are the key opportunities for this outcome area?
Please enter response here:
For planning, there is a significant opportunity to deliver nature-based solutions to protect waterbodies.
- What are the key challenges for this outcome area?
Given how interconnected water systems are to land and society, RTPI Scotland believes that the development of a systemic response is necessary. We believe that this can be achieved through place-based collaboration across a range of sectors.
Coastal environments
- Do the 2045 outcome statements adequately capture the change we need to see?
- Yes
- No
Please enter response here:
Agreement - no further comment.
- Are the 2030 milestones ambitious enough?
Are we missing any key elements? Please enter response here
No comment.
- What are the key drivers of biodiversity loss in this outcome area?
No comment.
- What are the key opportunities for this outcome area?
No comment.
- What are the key challenges for this outcome area?
The issues section could be strengthened with reference to challenges and opportunities from development, especially aquaculture and offshore wind power connections.
Urban environments – towns and cities
- Do the 2045 outcome statements adequately capture the change we need to see?
- Yes
- No
Please enter response here:
RTPI Scotland believes strongly that this section should be expanded and strengthened. Reference has been made to the draft NPF4 (with the new proposed universal policy relating to the nature crisis) but not the role of Local Development Plans, proposed and existing National Developments such as the Central Scotland Green Network and the Urban Sustainable, Blue and Green Drainage Solutions or Local Place Plans. As with our comments on the draft NPF4, clear definitions of phrases such as ‘nature positive’ and ‘nature networks’ would be welcomed to support decision makers. The role of Open Space Strategies, Forestry and Woodland Strategies and Local Biodiversity Action Plans should also be recognised in this section alongside Place Principle and place-based approaches.
- Are the 2030 milestones ambitious enough?
No. The retrofit milestone should be strengthened beyond simply identifying the opportunity by 2030. Please see also response to Q7.
Are we missing any key elements? Please enter response here:
Key to delivering biodiversity in towns and cities will be the planning system. Measuring the outcomes of planning is a complex area, as we have set out in previous work[7]. RTPI Scotland would welcome a joined-up approach between any nature targets set out and the draft NPF4 and its delivery plan. The importance of providing rich natural habits within cities and hinterlands should be made explicit in terms of the value of its accessibility from large population centres and the benefit derived form this.
- What are the key drivers of biodiversity loss in this outcome area?
Please enter response here:
Development, pollution and human activity.
- What are the key opportunities for this outcome area?
As set out in response to question 2, RTPI Scotland believes that harnessing the planning system is the key opportunity for creating nature-rich towns and cities.
- What are the key challenges for this outcome area?
Please enter response here:
As set out in response to Q2, RTPI Scotland believes resourcing the planning system to be a significant challenge for delivering nature-rich towns and cities.
Across our land and at sea – overall health, resilience and connectivity
- Do the 2045 outcome statements adequately capture the change we need to see?
- Yes
- No
Please enter response here:
RTPI Scotland would wish to see a commitment to bringing people closer to nature in this outcome statement.
- Are the 2030 milestones ambitious enough?
Are we missing any key elements? Please enter response here
As discussed in response to Q26, RTPI Scotland believes that the role of cities and towns in supporting biodiversity should be developed further throughout the Strategy and would be an important addition to this section which handles the overall health, resilience and connectivity of our country.
- What are the key drivers of biodiversity loss in this outcome area?
Please enter response here:
No comment.
- What are the key opportunities for this outcome area?
Please enter response here:
No comment.
- What are the key challenges for this outcome area?
Please enter response here:
No comment.
- To what extent will these outcomes deliver the Vision?
What might be missing? Please enter response here:
As set out in our response to Q2, without resources, especially a well-resourced planning system, and joined-up working across sectors the laudable content of the Strategy could again fail to materialise. The Vision fails to identify the critical role of people and communities in supporting biodiversity enhancements and the important role biodiversity plays in enriching people’s existence.
- What evidence and information should we use to assess whether we have delivered the Vision?
Please enter response here
As set out elsewhere in this response RTPI Scotland would advocate for a Strategy that works closely with the planning system to understand its performance and how it has, or has not, helped deliver the Vision. This will include close collaboration with the emerging role of the National Planning Improvement Coordinator.
The conditions for success
- Have we captured the key enabling factors which are essential in order for our strategy to be successful?
Yes - although this section could be strengthened with consideration of Community Wealth Building, the Place Principle and place-based approaches.
- Are there good examples of enabling conditions in other strategies we could learn from?
No comment.
- Can you set out how you think any of the proposals set out in the consultation might help to eliminate discrimination, advance equality of opportunity and foster good relations?
Can you provide any evidence which informed your conclusions?
No comment
[1] https://www.nature.scot/doc/state-nature-scotland-report-2019
[2] https://www.gov.scot/publications/scotland-2045-fourth-national-planning-framework-draft/
[3] https://www.nature.scot/doc/consultation-developing-nature-guidance
[4] RTPI Scotland (2021) Resourcing the Planning Service: Key Trends and Findings 2021. June. Available here: https://bit.ly/3s5h4Yc
[5] https://cieem.net/resource/a-summary-report-from-scottish-lpa-event-to-discuss-the-emerging-npf4-and-developing-with-nature-guidance/
[6] https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1590574123338&uri=CELEX:52020DC0380
[7] https://www.rtpi.org.uk/research/2020/november/measuring-what-matters-planning-outcomes-research/
