The scale of the proposed public service reform in the Programme for Government has significant implications for the environment sector, which we are still considering. The Scottish Government has proposed merging NatureScot, SEPA, Zero Waste Scotland, and potentially Scottish Forestry into a single environmental agency. There is also a separate proposal, which appears less developed, to consolidate all public bodies involved in the management of public land.
Scottish Environment LINK members understand the significant fiscal challenges facing the Scottish Government and accept that Ministers are considering wide ranging reform to public services in this context. We accept that there are likely to be some rationalisations that could increase efficiency.
We also understand the wider context: that of a Scotland facing acute and worsening environmental pressures, and legal targets and duties on the Scottish Government relating to nature and climate. Any reorganisation of environmental agencies at this point comes precisely when those agencies need to redouble efforts to meet legal biodiversity targets, reduce climate emissions, and adapt to the impacts of climate change.
Very little detail has been shared on the rationale for these proposals or the implications for public services. We can only currently comment on the broad principles.
As things stand, we haven’t yet seen a strong case made to merge NatureScot into a single environmental agency. Such a significant reform will inevitably be disruptive and there has been no detail shared on the implications for resourcing, responsibilities, and organisational focus of the new organisation at this crucial time. We are also not convinced that this reform will be able to deliver significant cost savings without having a direct impact on frontline services.
It is unclear how the proposal to consolidate public bodies involved in the management of public land would interact with this merger, as NatureScot also own and lease land, mainly National Nature Reserves. It is also unclear how such an arrangement would balance the very different objectives of public landowners.
Earlier this year, in recognition of the scale of the nature crisis, the Scottish Parliament passed the Natural Environment Act. Over the next few years, we have significant policy challenges to meet: the introduction and delivery of nature targets; the expansion of the protected site network to meet 30 by 30 and the related need for improved monitoring and site management; the ramping up of efforts on peatland restoration, native woodland creation, and restoration of the marine environment; and dealing with the increasing impacts of climate change, including wildfires and extreme weather.
LINK members remain open-minded about the public service reform agenda and the potential for the consolidation of some functions or responsibilities of public bodies into an expanded environmental agency. However, it is our view based on the information currently available that the policy challenges facing us will be best tackled through a continued standalone nature agency, and that agency should continue to have a significant role in land management.
We will engage constructively with these proposals when further detail is provided. Any reform to public bodies must reflect the urgency of the environmental crises Scotland faces.
Our environmental agencies must:
- have strong statutory objectives and powers to deliver for nature and climate;
- be well resourced to do their jobs;
- have regulatory functions that are evidence-led, transparent, and determined independently of other functions.
Our ultimate judgement on proposals for reform will reflect on whether new structures will deliver against these principles.
Statement supported by:
Action to Protect Rural Scotland (APRS)
Bright Green Nature
Buglife Scotland
CIEEM (Chartered Institute of Ecology and Environmental Management)
Environmental Rights Centre for Scotland
The Froglife Trust
Marine Conservation Society
Nourish Scotland
Plantlife Scotland
RSPB Scotland
Scottish Wild Land Group
Scottish Wildlife Trust
Soil Association Scotland
WWF Scotland