Deborah Long, chief officer, Scottish Environment LINK
Nature is crucial for our survival. With six years left to meet the goals and targets of the Global Biodiversity Framework, urgent action is needed. UN Development Agency, UNDP. October 2024
The world’s governments are meeting in Colombia at the COP16 UN biodiversity summit this week to talk about biodiversity loss and how to stop it. Although the UK government is there, the Scottish government is not. As a nation world renowned for our landscapes and wildlife, this is a missed opportunity to contribute to and be inspired by the energy and momentum of these events. That momentum and commitment is not trivial: we will need to recreate that energy somehow back here in Scotland.
At the same time, Scotland is the current President of Regions4, the group of sub national and regional governments working together to halt the loss of biodiversity, halt climate change and meet the UN Sustainable Development goals. Regions4 is empowering regions to end biodiversity loss and bringing the regional voice and knowledge of regional and local initiatives into COP16. At home, Scotland is showing what is possible through its Nature Restoration Fund and its Peatland ACTION fund. So, Scotland’s absence from COP16 is baffling.
What is clear though is that Regions4 is a huge opportunity for Scotland and its partners to show the leadership humanity needs to see on biodiversity. In European terms Scotland’s biodiversity as measured though our biodiversity intactness index is in poor shape, languishing as we do near the bottom.
The scale of Scotland’s leadership will be revealed soon with the publication of the new Scottish Biodiversity Framework and its first delivery plan. This framework needs to be a step change in Scotland’s approach to biodiversity. Anything less will not be sufficient. A huge amount of work has gone into this, with Scottish Environment LINK members alone offering detailed comments in workshops and an 80 page consultation response . We don’t know what the strategy and plan will look like, but we know how they NEED to look for Scotland to meet the strategy’s objective of halting biodiversity loss by 2030 and reversing it through large scale restoration by 2045.
The key test for the framework and plans will be whether the actions outlined in them will together meet these objectives. This requires ambition, collaboration across society and working at scale. It is much more than a repackaging of actions that are already committed to: the State of Nature 2023 Scotland report shows nature continues to decline and we are not yet doing enough. Bending the curve on biodiversity by 2030 will take leadership and courage.
The Framework and plans need to:
Outline the ambition needed to reach nature positive by 2045: Nature targets set in legislation will help define the direction of travel and bring everyone on board. We don’t need to outline all the steps in this first delivery plan, but it needs to set a determination to progress.
Map out how we restore ecosystems on land and at sea: Ecological and systems thinking is needed to build ecological networks. This means thinking and acting at scale on the drivers of biodiversity loss. It includes tackling invasive non native species, deer management to achieve widespread natural woodland regeneration, and improved water and air quality. It also includes actions to meet the 30×30 commitments through maximising the benefits of national parks and protected areas and enabling communities, organisations and groups across Scotland to manage land and sea for nature, connecting up habitats and reconnecting with nature as they go.
Use public funding better: there is no place for perverse subsides in today’s environmental and economic conditions. Public funding must support the provision of public goods to society including carbon sequestration, thriving biodiversity and full access to healthy green and blue spaces.
Plan for biodiversity: local nature network plans are good but insufficient. Local Authorities alone cannot deliver ecologically coherent networks across Scotland. That requires planning at a national level, with guidance on what action is needed where to rebuild ecological connectivity. Ecosystems don’t stick to council boundaries.
Clear lines of responsibility for delivery and monitoring: without ownership and monitoring we won’t get where we need to be and we won’t know how we are doing.
Include Scotland’s people: Scotland’s nature requires us all to be involved. This means enabling people across Scotland to reconnect with nature, as a constituent part of every part of the plan. Integration and collaboration will be key to success.
Leadership and showing success: the proposed six landscape scale projects will help demonstrate leadership at scale and produce results at the geographical scale required over time. Ecological restoration is not quick but acting at scale, in collaboration with local communities and landowners and managers is the most effective approach to take to embed the conditions for change quickly and effectively.
Scotland’s nature needs action. COP16 should be the driver to inspire effective change. The new Framework and Delivery Plan must be the mechanism.
LINK is all about its members. Set up in 1987, LINK exists to be the voice of Scotland’s voluntary environment sector and, as the sector, the voice for Scotland’s environment. In the last 37 years, LINK has amplified the voice of our members and brought the environment into the Scottish Parliament.
Our new strategy to 2030 shows how we plan to continue to do that over the next 6 years. It deliberately takes us to 2030, when the intergovernmental panels for both biodiversity and climate have set targets, to halt biodiversity loss and to reach net zero respectively.
Against a background of ongoing nature loss and ecosystem decline, policy obfuscation and rapidly changing ecosystems, the network takes heart from the advances Scotland has made, particularly through the recent forward thinking Bute House Agreement. The commitments in there have helped Scotland make some steps forward, although not yet enough. We look forward to 2030, determined to continue to work with all political parties to build in the very necessary wins that the environment needs. These wins are not limited to policy change but must extend into delivery of those policies so that the people of Scotland see real and effective change on the ground and at sea.
The more than half a million people who support our members expect nothing less of the sector. Working together, our vision at LINK is:
Scotland’s environment is Connected | Restored | Resilient |
Our society has nature at its heart, benefiting people, communities and the planet.
To reach our vision, our new strategy doubles down on our mission:
LINK supports our members to work together on agreed priorities, in order to effect environmental policy change and delivery in Scotland. We build partnerships that create irresistible momentum towards change.
Our new strategy puts in place the structures to enable us to do this. We have identified 6 key transformations that are required to meet today’s nature and climate challenges: these transformations focus on delivery to meet policy rhetoric, leadership, approaches to land and sea use that are nature and climate friendly, with a major role for the National Planning Framework on land and the National Marine Plan at sea, all centred on a justice approach to ensure a just transition to a climate and nature friendly world.
Our new strategy identifies the activities we, as a network, will need to do over the next 6 years to achieve these transformations. The key mechanisms we will be using centre on partnership working, identifying and building common ground, a clear focus on key issues with outcomes and impacts measuring our success and prioritisation to ensure our limited resources have maximum impact. The driving engines for these transformations are our working groups, led by members, with annual work plans and priorities agreed by members. These groups work together to tackle the key issues and actions needed for progress on land, at sea and across society.
We will also be building on our successes to date: with the nature and climate crises impacting on everyday life, LINK, with our members, has designed and delivered effective campaigns, that are able to bring people’s voices directly into Parliament on a range of issues from marine conservation, to a circular economy and farming policy. Over the last 4 years, these campaigns have provided momentum as well as enabling people from right across Scotland to get involved and have their voice heard. A great example was the book of messages we gave to the Cabinet Secretary for Rural Affairs with quotes from people describing the change they wanted to see her make to farming support. You can read the messages here.
Our Nature Champions initiative was 10 years old in 2023 and we celebrated its success at Parliament with a public exhibition. We will continue to support this initiative, bring a new cohort of politicians into much closer contact and understanding of species and habitats in 2026 after the next election, bringing nature right into the centre of Parliament.
But finally, the key driver for the success of our new strategy is our commitment to work in partnership. As a network, we know that we can and will achieve much more by working together. Our new strategy helps us scale this up, working beyond our membership and with other supporters and other networks, helping others become a voice for the environment and ensuring that all voices for the environment are heard. Our commitment to being inclusive, more equal and diverse by welcoming everyone into the sector is fundamental to how we work. The groundwork laid between 2022 – 2025 through LINK’s Nature for All project, forms a strong foundation for equality, diversity and inclusivity to be a strong thread through our work into the future.
Working in the LINK network proves John Muir’s observation that: when we try to pick out anything by itself, we find it hitched to everything else in the universe.
The environment is too important and too interconnected to tackle one issue at a time – and the only way we can tackle all the issues that need our urgent attention now, is by working together, one network supporting the infinite ecosystems of the planet. It is an ambitious vision but one that is utterly necessary for everyone in Scotland today and everyone who will live in Scotland in the future.
The LINK Deer Group comprises all of the main eNGO landowning organisations in Scotland.
What are the Scottish government’s proposed Deer Management Nature Restoration Orders? Why does the LINK Deer Group agree that this measure is now necessary?
Recently the Scottish government announced its Programme for Government for 2024-5 and we can now expect a Natural Environment Bill (NE Bill) in this Parliamentary term. We expect this Bill to include welcome proposals to reform and modernise deer management in Scotland to help address the climate and nature emergency. The deer sections of the NE Bill should implement many of the legislative recommendations of the independent Deer Working Group Report (DWGR) published in December 2019, which were accepted and committed to by the Scottish Government in March 2021. The Deer Working Group Report was a response to the growing deer populations in Scotland, now estimated at 1 million animals and increasing. In the absence of natural predators, deer must be managed by people using humane techniques and to prevent damage to various public interests. The venison then provides a healthy meat product.
In its recent public stakeholder consultation of January 2024 the Scottish government additionally introduced the concept of Deer Management Nature Restoration Orders (DMNROs) described as follows:
“In developing our proposals to implement the recommendations made by the DWG, however, we also give consideration to what enhancement and restoration is required to improve biodiversity and about how we manage deer to help achieve this. Scotland is one of the most nature depleted countries in the world, and our country’s biodiversity has been altered by centuries of habitat loss and fragmentation, management changes, development and persecution. It has been that way for so long that simply maintaining the equilibrium is in effect maintaining already damaged land. The Deer Working Group report, while comprehensive, was commissioned in 2017 and presented to Ministers in 2019, and since then the Scottish Government has set out ambitious targets for tree planting and peatland restoration alongside our commitment to the global 30 by 30 targets. It is in the context of this work that we are proposing a set of new powers for NatureScot, set out in Theme 1 of this consultation. The proposals set out in this section are in addition to the recommendations made by the Deer Working Group but we believe they are essential to our deer management capabilities”.
“The proposed purpose of a DMNRO would be to enable all necessary deer management actions to secure restoration of nature across a specified area of land, covering one or more landholdings, to be prescribed by NatureScot under a single legally enforceable direction”.
Importantly, DMNROs focus on enhancement of habitats in contrast to existing NatureScot powers to intervene to reduce deer numbers which work from an existing ecological baseline and assessment of deer damage – which has already been shown over many years to be hard to prove in practice and costly to implement. In practice, a DMNRO could result in enforced reductions in deer numbers or densities; a requirement for deer fencing to be installed; or additional work to support deer management such as habitat assessments and cull plans and reporting.
Of course, any DMNRO would be subject to consultation with relevant affected parties, and public incentives are likely to be available to support land managers and encourage compliance. It is also likely that any measures would be signed off by the Minister so public checks and balances would be in place.
In September 2024 the Scottish government published the stakeholder feedback to its “Managing Deer for Climate and Nature” consultation. Those in favour of DMNROs comprised nearly all conservation and animal welfare organisations, three quarters of organisations in the “other organisations” category, and around two thirds of individual responses.
The analysis found that: “These respondents often said that deer overpopulation was the main obstacle to ecosystem recovery in certain areas of Scotland. They highlighted the benefits of improved deer management, including the regeneration of natural woodlands, reduced flooding, and greater carbon sequestration. In addition, this group pointed to the problems of deer causing damage to small farms and gardens in some parts of Scotland, the growing incidence of Lyme Disease, and the large numbers of road accidents involving collisions with deer. Some also suggested that better management of wild deer populations would have benefits in terms of animal welfare – particularly in areas where deer mortality is high due to insufficient food in the winter months. A recurring view among this group was that deer numbers need to be controlled as a matter of urgency.
Some respondents who supported DMNROs acknowledged that deer management groups have had success in reducing deer populations in parts of Scotland, but thought that, overall, deer numbers were still far too high. These respondents emphasised the need for ‘radical and new’ approaches. They supported a ‘landscape scale’ approach to sustainable deer management that was capable of achieving a long-term reduction in deer numbers without having to cull repeatedly. They also thought it was important that such efforts are not impeded by deer moving across land ownership boundaries, and there was a suggestion that the whole of Scotland should be the subject of a DMNRO, with locations being excluded only if there was a good justification for doing so. These respondents wanted the use of DMNROs to be linked to natural regeneration and improvements in ecological connectively, and to aim for full recovery and restoration of natural processes”.
So why are these new powers needed?
Since the introduction of the current Deer (Scotland) Act in 1996, Scottish Natural Heritage (now NatureScot) have had powers to intervene to reduce deer numbers either through voluntary control agreements under section 7, or compulsory control orders under section 8. We have seen a series of voluntary control orders over the past 20 years, mainly within the Highland red deer range. Most of these deer control sites are linked to designated upland and woodland wildlife sites, amongst our most important nature conservation sites in Scotland. Over a long period of time now they have demonstrably failed to meet their objectives when it comes to sustainable deer management. The first section 8 compulsory control order power has only been used this year, some twenty-eight years after the Deer Act was passed, and even that was subject to a lengthy legal challenge. The power has been largely considered unworkable due to concerns about establishing the facts around deer damage in the terms described by the Act to withstand legal challenge. If the years since 1996 have taught us anything, it is that we need unambiguous means of securing positive deer management to deliver nature restoration at scale.
The independent Deer Working Group Report highlighted that of eleven section 7 agreements administered by NatureScot, only one has achieved its objectives, namely Glenfeshie Estate (now part of the landscape scale ecosystem restoration project Cairngorms Connect), and where benign private landownership supported the measure. The most notorious section 7 agreement has been at Caenlochan in the Cairngorms National Park which has been in place since 2003 and has recently had to be re-instigated by NatureScot due to very high recorded deer densities and ongoing damage to one of the most important sites for arctic alpine plant communities in the UK. The Deer Working Group report estimated that section 7s had cost NatureScot – that is the Scottish taxpayer – £3 million between 2006-18, often with only continued declines in nature to show for it.
The LINK Deer Group wholeheartedly supports Scottish government’s leadership in trying to deliver sustainable deer management to address the climate and nature emergency, as well as to protect public investment in new native woodlands, peatlands and wildlife conservation programmes. DMNROs have been developed by the Strategic Deer Board comprising of Scotland’s main public bodies with an interest in deer management and these proposals have therefore been carefully considered. The clear failure of previous largely voluntary approaches to protect public interests over a long timeframe indicate that a new approach is now urgently required. We consider that DMNROs, if properly targeted, incentivised, and enforced by NatureScot, could offer a significant step forward and help improve Scotland’s largely degraded upland and native woodland ecosystems.
Duncan Orr-Ewing, Convener, LINK Deer Group
Hazel Forrest, Deputy Convener, LINK Deer Group
Supported by
RSPB Scotland, Trees for Life, Scottish Wildlife Trust, National Trust for Scotland, Woodland Trust Scotland, John Muir Trust, Nature Foundation
Earlier this summer I found myself repeatedly asking an uncomfortable question: where are all the bees?
It turned out I was not alone in being disturbed by the silence in my garden – which, the Bumblebee Conservation Trust explained, was caused by a longer than usual gap between the emergence of queen and worker bees. This gap appeared to be caused by a very wet spring, another reminder of how climate change is disrupting the rhythms of nature. By August, reassuringly, the bees were back – though, in contrast, the Big Butterfly Count found butterfly numbers at the lowest numbers in the scheme’s 14 years of operation.
Climate change and nature loss are global issues. But motivating action requires us to translate these into local stories. And there’s not much more local than the species you find in your garden.
One of the big challenges for conservation advocates is ‘shifting baseline syndrome’. When we appeal to historic levels of biodiversity, we are appealing to a natural world that is outside of living memory. For most people, the normal state of nature is probably what they remember as a child or a young adult – and it is changes against this baseline that they will notice.
This creates a negative feedback loop where falling numbers become seen as the new normal, and we collectively fail to understand the extent to which the species around us have collapsed.
This summer LINK commissioned Diffley Partnership to conduct polling which asked about the environment in a local context, as well as, in focus groups, presenting some of the evidence around longer-term trends.
We found that people really do understand that the environment is in trouble and are deeply concerned. 76% of respondents said that they worry about the natural environment often or occasionally.
And this concern comes from experience. The vast majority of people in Scotland have noticed environmental harm in their local area: with 82% noticing the impact of climate change, nature loss, or pollution.
But, despite this, when our focus groups were presented with evidence showing the longer-term trends, the reaction was much more mixed. While some participants acknowledged the scale of biodiversity loss in Scotland, others expressed surprise that Scotland ranks so poorly against other developed nations. One participant said: “You don’t hear a lot about Scottish species that are threatened with extinction… we can’t individually do anything about it or try and affect change if we don’t know anything about it.”
One insight from this research was that there is a generational gap in how people think about these issues: those aged over 65 were, predictably, most likely to say they had experienced nature loss, but in contrast those aged 16-34 were most likely to say they had experienced the impacts of climate change. To reach this younger audience, nature advocates may need to do more to draw out the links between species declines and climate change.
By Dan Paris, Advocacy Manager at Scottish Environment LINK
This piece first appeared in Scotland on Sunday on the 29th of September, 2024.
Who doesn’t love a sea view? Scotland has glorious ocean vistas by the bucketload. But looking out to the horizon, we rarely think about what’s beyond view, deep below the surface. Scotland’s deep seas are home to extraordinary creatures, from whales and sharks to bioluminescent anglerfish and clams that can live for over 500 years.
Our deep ocean environment is currently in the conservation spotlight, with a public consultation open on measures to restrict certain types of fishing in offshore marine protected areas. A separate consultation on inshore areas is long overdue.
Unique and vulnerable species thrive in in our offshore marine protected areas, including cold-water corals and sea sponges. The habitats they form play a critical role in ocean health, providing oases of food and shelter for a huge variety of other species, including commercial fish stocks.
The ecosystems found here are also key to helping tackle the climate crisis, providing important long-term carbon stores.
Most of Scotland’s offshore marine protected areas were designated in 2014, yet commercial fishing that threatens wildlife is still allowed to operate in most areas shallower than 800m depth. The proposals being consulted on include restrictions on trawling which sweeps across and damages large sections of vital seabed habitats.
Largely, the current proposals are not new. The Scottish government put forward plans for managing fishing in offshore marine protected areas in 2016 following extensive workshops with fishers, scientists and environmental organisations. Implementation of the plans was delayed by Brexit and by Covid-19.
However, a second, stronger protection option is now proposed for some sites, which would mean the tailored fishing restrictions would apply across the whole site, instead of just parts of it. This would help ocean ecosystems to start to recover, rather than just protecting some of what remains following decades of damage.
The current proposals are unrelated to Highly Protected Marine Areas (HPMAs), which were shelved last year following widespread concern from coastal communities. Introducing HPMAs would have meant banning all fishing and some other commercial activities (but not recreational access) in selected parts of Scotland’s seas. Locations for potential HPMAs had not been identified before they were shelved.
The current proposals are to restrict certain types of fishing in existing offshore marine protected areas. Some lower impact forms of fishing would be allowed to continue in many of these sites, while restrictions would apply to activities that pose the greatest risk to the species and habitats present. The boundaries of these defined and limited areas are very clear.
Globally, marine protected areas play a crucial role in safeguarding ecosystems, promoting sustainable fisheries, mitigating climate change and supporting coastal communities.
But in Scotland we’re seeing very few of those benefits, because failure to implement protections means that most of our marine protected areas, both offshore and inshore, are largely ineffective.
That’s why it’s so important that the current consultation leads to effective protections finally being introduced.
Marine protected areas are not the whole answer to the loss of biodiversity in Scotland’s seas. But implementing and enforcing the stronger protection option in our offshore marine protected areas is a crucial step to helping our seas recover. Scotland’s deep seas give us far more than we might imagine when looking out to sea, and now is the time to give them the protection they need.
Esther Brooker is marine policy officer at Scottish Environment LINK.
The deep sea is one of those mysterious parts of planet earth – or should that be planet ocean? It’s so far away and out of reach that most people only hear about it occasionally in the news or on wildlife documentaries. But did you know that deep sea ecosystems have a powerful influence on your everyday life and the environment around you? In this blog, we will take a dive into the importance of the deepest and most unexplored parts of our ocean, and look at what urgently needs to be done here in Scotland to protect the species and habitats that live in these hidden havens.
Stretching far beyond the familiar shorelines of Scotland’s coasts, beaches and cliffs, the offshore waters encompasses everything from the continental shelf to the deep sea abyssal plains, from 12 to 200 nautical miles. This vast and largely unexplored region is home to some of the most unique and fascinating species and habitats on Earth.
Along the continental shelf and within the dark, cold depths of Scotland’s seas, life thrives in extraordinary ways. Species such as the bizarre-looking deep-sea anglerfish (Lophius piscatorius), the majestic sperm whale (Physeter macrocephalus), and the elusive porbeagle shark (Lamna nasus) call these waters home. Habitats in Scotland’s offshore waters include cold-water coral reefs, which provide shelter and breeding grounds for numerous marine species. Seamounts and submarine canyons add to the complexity and diversity of these underwater landscapes.
These creatures have adapted to extreme conditions—immense pressure, frigid temperatures, and perpetual darkness. However, these conditions make for a much more stable environment than the busier and more dynamic inshore and coastal area. As a result, species and habitats tend to be slow-growing and long-lived. The orange roughy, a medium sized fish that lives at depths of up to 1,800m, can live up to 200 years! The ocean quahog, a species of clam found in Scottish waters, can live even longer, with the oldest recorded individual aged at 507 years old!
Image: Ocean quahog (credit: NatureScot on Flickr)
The continental shelf and deep sea environment plays a crucial role in global ecological health. It acts as a massive carbon sink, helping to regulate the Earth’s climate by storing vast amounts of carbon dioxide. The biodiversity of these environments contributes to the overall health of ocean ecosystems, supporting fisheries, helping to cycle nutrients to shallower waters and maintaining the balance of marine life. Deep-sea organisms are also a source of novel compounds with potential applications in medicine, biotechnology, and other fields. Recently, it was even discovered by Scottish scientists working at the Scottish Association of Marine Science, a pioneering institute on deep-sea research, that deep sea minerals produce oxygen! Until then, oxygen was only thought to be produced by plants and other living things that use photosynthesis and require sunlight.
Despite its remoteness, the offshore and deep-sea environment is not immune to threats. Human activities such as deep-sea fishing, mining, and oil and gas exploration pose significant risks. These activities can lead to habitat destruction, overfishing, and pollution, disrupting the delicate balance of fragile ecosystems. Climate change and ocean acidification further exacerbate these threats, altering the physical and chemical environment that deep-sea species rely on. Marine litter is also being increasingly found in deep-sea environments. A plastic bag has been discovered in the Marianas Trench – the deepest place on earth – at a mind-blowing 10.8 km deep, and deep sea creatures have been found entangled in or attached to plastic waste in multiple locations.
Most of these threats are already affecting Scotland’s offshore ecosystems, and some have done so for a long time. In the northwest area of Scotland’s offshore waters, a population decline of up to 90% has been estimated for orange roughy due to fishing activities. Strandings of deep-diving whales on Scottish beaches have been increasing over the last 60 years, including species such as Cuvier’s beaked whale (Ziphius cavirostris).
Protecting Scotland’s deep sea is not just about preserving the unknown—it’s about safeguarding the planet’s future. The health of our oceans is intricately linked to the health of our planet and human health and wellbeing. By conserving these environments, we ensure the continuation of critical ecological processes and the survival of unique species that could hold the key to scientific and medical breakthroughs. Whether we can see it or not, the deep sea is a vital part of our natural heritage.
In 2014, 13 new marine protected areas were created in Scotland’s offshore waters, adding to some of the MPAs already established under EU law (known as Special Areas of Conservation), such as the Anton Dohrn seamount and the Wyville Thompson Ridge. The West of Scotland deep sea marine reserve was also designated in 2020. However, as we have explained before, it’s not enough to just create the MPA without addressing the risks to the species and habitats that live there. During 2016, we participated in government meetings to discuss the fisheries management measures that should be established in the 13 offshore MPAs, plus 7 of the existing offshore Special Areas of Conservation. Those management measures still have not been adopted, apart from some voluntary protection currently being observed by fishers in the West Shetland Shelf MPA (long story involving cod and historic EU protections).
Delayed by Brexit and the Covid-19 pandemic amongst other things, the Scottish Government has now launched a public consultation seeking views on proposals for fisheries management in offshore MPAs. In the midst of a global ocean crisis, this consultation is a significant turning point for Scotland’s MPA network, the majority of which has remained open to seabed-contacting fishing activities that pose a direct risk to some of the delicate habitats and species these MPAs are designed to protect. Over the next six weeks, you have the power to make a difference. The current consultation on offshore MPA management is a crucial opportunity for us to protect our precious marine environments and ensure they thrive for future generations.
The consultation proposes two options in some of the MPAs: restricting fishing only in areas where the protected species or habitats are found, or restricting all towed seabed-contacting fishing across the whole MPA. The latter option will provide the greatest opportunity for the recovery of offshore ecosystems, from the continental shelf into the deep sea, and in the long-term will provide greater benefits to nature, people and sustainable businesses. By supporting proposals to restrict damaging fishing activities in these areas, we can help protect and restore the health of our vulnerable ecosystems. This isn’t just about preserving nature—it’s about safeguarding the resources and services we all depend on, from sustainable fisheries to climate regulation.
Proper protection for our offshore MPAs is already long overdue, and recovery of nature takes a long time in these environments – we need to give it the best chance possible before it’s too late. Your voice can help secure stronger protections for Scotland’s offshore MPAs. We urge you to participate in the consultation, support the proposed measures, and advocate for a future where both nature and people can prosper.
Nature restoration is a primary objective of many LINK members and we are pleased that in general the imperative of restoring Scotland’s biodiversity is increasingly recognised and that the Scottish government has committed to action. We are of course deeply concerned about the recent announcements regarding short term cuts to the local authority Nature Restoration Funds.
Scotland’s nature is in a poor and declining state. TheState of Nature report (2023) finds one in nine species at threat from extinction. Centuries of habitat loss, over-exploitation, intensification of farming, development, invasive species and persecution of wildlife means Scotland ranks 28th from bottom out of more than 240 countries/territories in terms of biodiversity.
Scotland has committed to theMontreal-Kunming Global Biodiversity Framework and Scotland’s (draft)Biodiversity Strategy sets out a clear ambition: for Scotland to be nature positive – to have halted and reversed nature decline by 2030, and to have restored and regenerated biodiversity across the country by 2045. A key target is ‘30 by 30’ – to protect 30% of our land, freshwater and sea by 2030.
These are exciting commitments and aspirations, but we are well aware that delivery is going to be thorny; not least the issue of how it is funded. In our paper,How to finance nature, we discuss this and set out a number of recommendations.
What is it going to cost? The nature finance gap (the gap between the cost of nature restoration and current levels of funding) was considered to be in the region of £20 billion over 10 years byThe Green Finance Institute in 2021. The inclusion of land purchase costs in the calculations has been questioned and smaller figures proposed as being more realistic. LINK members are keen not to get bogged down in discussing the exact size of this gap but, as described in our paperHow to finance nature, it is clear that costs considerably outweigh current funds. What’s more, and importantly, these costs will change over time with early action and complimentary policy reducing the long-term financial burden.
With costs vastly exceeding current levels of funding, alternative ways to pay for nature restoration are being considered. The cost of delivering global biodiversity goals was highlighted in the Global Biodiversity Framework which refers to the need to increase funding from all sources including the leverage of private finance; and a growing number of organisations and initiatives have been putting their minds to how this might work. Scottish government published itsInterim principles for responsible investment in natural capital and established theFIRNS programme which funds projects to ‘shape and grow the use of private investment and market-based mechanisms to finance the restoration of Scotland’s nature’.
There are several inherent characteristics of biodiversity that confound its suitability for investment seeking a return, principally it generally doesn’t generate an income and it takes many years to establish. Not all private finance is looking for a return and there are also options for private investment from organisations wanting to make up for their impact on biodiversity. For these organisations, measuring the amount of biodiversity enhancement is important – another thing that is difficult.
All in all, although LINK members believe there is an absolute need for additional funding including from the private sector, there is also a realisation that private sector investment at scale is likely to be a long time coming and its desirability is dependent on the development of a framework and supporting policies and standards to ensure the investment contributes to long-term ecological restoration, and benefits local communities.
We therefore need to think more widely about how to pay for nature restoration. Some general principles: landowners should be expected to look after land in the public interest, including by protecting and restoring nature. That said, where vital public policy objectives, like climate change mitigation and nature restoration, require concerted action for which it isn’t reasonable to expect landowners to pay, these are best pursued by public programmes and funding. Although this is preferable, the urgency and scale of the nature crisis means that a pragmatic approach needs to be taken and different financing mechanisms need to be pursued concurrently.
The Scottish government should continue to significantly increase the overall level of public investment in nature and, importantly, ensure that existing funding is used more effectively by ending subsidies for activities which degrade biodiversity. The most obvious, and probably most effective, intervention would be to reform agricultural subsidies; but all public budgets should be scrutinised to ensure they are compatible with nature restoration aims and this should extend to grants and loans.
Other fiscal measures like tax policy and charges can be used to both raise money and incentivise the necessary actions – see LINK’s new paper,Paying for nature: Options for fiscal reform.
Although, as mentioned, there are complications with private money (aside from philanthropic support), the possibility of investment in ‘biodiversity enhanced carbon units’ is probably one of the front-runners. The IUCN isdeveloping a procedure for biodiversity crediting alongside thePeatland Code andWoodland Carbon Code programmes, aiming for completion in March next year. Governments need to ensure that the operation of carbon offset credits in Scotland enhances biodiversity; and that they comply with strict additionality and integrity conditions.
An additional source of private finance is throughPlanning related biodiversity enhancement. The introduction of the requirement for development to deliver biodiversity enhancement, through NPF4 Policy 3, is potentially game-changing in ensuring that development contributes to leaving nature in a better state, rather than to its decline. With a robust system of enhancement design, targeting and enforcement, biodiversity enhancement could significantly bolster Scotland’s ability to meet its priority nature conservation objectives. See this RSPB paper.
The Scottish government is currently drafting a Biodiversity Investment Plan which should give due consideration to the advantages and disadvantages of different mechanisms to finance nature and the various roles that they might have.
This Investment Plan must set out a strategic approach to financing nature, making the best use of the various mechanisms available and matching them to ecological priorities. Such priorities should be laid out in a spatial plan of restoration needs and priorities. This plan of restoration needs and priorities and supporting data is a fundamental precursor to the Investment Plan.
LINK members look forward to working with Scottish government and others on ensuring that we make the best possible use of all options available to pay for nature protection and restoration. We emphasise that this needs to be led by a spatial plan of ecological needs and priorities and coordinated by Scottish government and regional bodies.
Blog by Phoebe Cochrane, Sustainable Economics Officer at Scottish Environment LINK
Scotland’s response to lockdown was to fall in love with nature. The more we were limited to our homes, the more we realised how much nature meant to us and how much it helped us feel better when the world felt bleak. Have we forgotten that?
The natural world is essential to our wellbeing and quality of life. Nature underpins our food production, supports our economy, and is our first line of defence against climate change.
As parliament comes back from summer recess, the imminent Programme for Government will be a key test of whether the environment is being treated with the seriousness it deserves.
The Scotland Loves Nature campaign, supported by over 40 environmental groups, is calling on the Scottish government to address this through a Natural Environment Bill in the upcoming Programme for Government, which would set legally binding targets for nature recovery, as well as putting more funding in place to restore nature and helping communities protect and restore their local environment.
The Scottish Government has accepted that nature is in crisis and has pledged to tackle it. But earlier this week we learned that investment has been cut from one of the flagship programmes, the Nature Restoration Fund.
The scientific evidence is clear that Scotland has suffered a decades long decline in biodiversity. Today, 1 in 9 species in Scotland is at risk of extinction. There are concerning declines in seabirds, in pollinators, in species rich grassland, in native woodland extent, and in peatland condition. The Nature Restoration Fund is a key tool we have to invest in reversing these declines, which although limited in scale, was starting to have some impacts.
Communities from right across Scotland are seeing these impacts even at this early stage: river restoration in Ross-shire, wetland restoration in Stirlingshire and Orkney, meadow restoration in the Borders, and seagrass restoration on the west coast. More than 140 projects have been supported by £40 million – a tiny amount of investment when measured against the scale of the challenge.
But it is investment not just in restoring nature, but in making Scotland more resilient to climate change, preventing flooding, and protecting pollinators of farmed crops. It is money well spent for today’s local community to enjoy and benefit and as a legacy for future generations to experience the delights of Scotland’s nature.
All this is why these cuts to nature spending is such bad news. At a time where every financial decision must be scrutinised for its impact today and tomorrow, cutting the small amount of funding available for nature restoration, which delivers services way beyond wildlife, is a backward step.
Scotland’s people know this too. A recent poll showed that 8 out of 10 people had noticed the impact of environmental harm in their local area. The same poll also showed us that people want to see more effort, not less, going into nature restoration.
Scotland’s environmental sector is calling on Scottish Ministers to urgently reconsider this cut and protect Scotland’s future. Even in difficult circumstances, failure to invest in Scotland’s environment will harm us all and will undermine Scotland’s ambitions to be an environmental leader. Investment in nature restoration is investment in our future – and it’s cheaper doing it today than tomorrow.
By Deborah Long, Chief Officer at Scottish Environment LINK
Marine protected areas (MPAs) are like nature reserves underwater. They are defined areas of the sea set aside to protect and restore important or vulnerable marine species, habitats or ecosystems (communities of living creatures). Usually certain activities are managed (restricted or changed) within MPAs to reduce or prevent damage and there can be different types of management depending on what the MPA is designed to protect.
Why do we need MPAs?
Our seas are in crisis. In 2019, Scotland declared a twin global climate and nature emergency. Climate change and human activities are causing widespread damage to marine life and habitats. Declines in species like cod, haddock, and seabirds are just some examples of the pressures our seas are facing. Scotland is one of the most nature-depleted countries in the world. Progress to tackle these crises and reverse the widespread decline in nature is slow.
MPAs are essential for protecting and restoring our marine environment. They provide safe havens for marine life to help prevent further decline in nature. Evidence from around the world shows that MPAs can help to rebuild fish stocks, protect biodiversity, and improve the overall health of our oceans.
Scotland’s MPA network already covers 37% of its seas – this is great, isn’t it?
While Scotland has a large MPA network on paper, these are simply lines on a map without effective management. To truly protect our seas, we need to restrict harmful activities within MPAs. Species and habitats for protection (Priority Marine Features – PMFs) have been identified based on the risks they face, so it’s crucial to put in place measures to prevent damage. The majority of Scotland’s MPAs don’t have restrictions in place for some of the most damaging or widespread pressures in the sea.
What activities need to be restricted within MPAs?
The main focus for MPA management is currently on fishing activities, particularly bottom-towed gears that can damage seabed habitats. Other activities like aquaculture and renewable energy are already managed through licensing processes (although the combined effect of all activities on MPAs and the features they protect is still not well understood and assessed).
Does MPA management pose a risk to small scale fishing businesses who may have more limited options for fishing grounds?
We understand the concerns of small-scale fishing businesses. While some changes may be necessary, the long-term aim is to enable sustainable, lower impact fishing practices, at levels where the environment can thrive. We believe sustainable fishing activities should be supported through any transition and should be able to benefit from improved opportunities provided by a healthier environment.
Are these management measures the same as Highly Protected Marine Areas (HPMAs)?
No. The current MPA management proposals have been developed through extensive consultation with stakeholders since 2014. The commitment to HPMAs was introduced more recently in 2021 though the Bute House Agreement, in keeping with EU and international targets to strictly protect 10% of land and sea, and proposals were largely developed by the Scottish Government.
While the idea of strictly protected areas has merit in principle for the recovery of nature, we believe it’s essential to first focus on completing and effectively managing our existing MPA network. This should be a priority and has been delayed for a decade.
Exploring any further actions that will be needed to enable nature recovery and align with global law/commitments should be done in collaboration with all stakeholders, including communities.
Who will benefit from well-managed MPAs?
Everyone stands to benefit from healthy seas. Well-managed MPAs can improve species, the habitats they live in, and ecosystem health, which in turn supports commercial fish stocks. Beyond economic benefits, healthier seas contribute to improved wellbeing, stronger coastal communities, and increased opportunities for tourism and employment.
If these MPA management measures are implemented, will Scotland’s seas become more healthy?
MPAs are one important tool for improving ocean health, but they are not a silver bullet to all the problems in the ocean. To fully restore our seas, we need a combined approach that includes MPAs, species conservation efforts, and wider measures such as effective marine planning and management of fishing beyond MPAs. By working together, we can create a thriving marine environment for future generations.
What needs to happen next to get the MPA management measures in place?
Urgent action is needed. The Scottish Government must prioritise and better resource the publication of outstanding fisheries management proposals for public consultation. Once these proposals are finalised, they must be implemented without delay.
Right now, the Scottish government is asking for people’s views on proposed restrictions for our ‘offshore’ marine protected areas – those between 12 and 200 nautical miles from the shore.
By Esther Brooker, Fanny Royanez (Scottish Environment LINK) and Rebecca Crawford (Scottish Wildlife Trust)
It has been 10 years since a suite of 30 new nature conservation marine protected areas (MPAs) were designated in Scotland’s seas under Scottish and UK law. These were in addition to the MPAs already designated under European law. The purpose of MPAs is to protect fragile species and habitats by restricting damaging activities, which allows marine ecosystems to recover and thrive.
At the time, it signalled a clear and ambitious intention to deliver real conservation outcomes, which would help to halt the decline of Scotland’s marine nature, enable more sustainable economic opportunities and contribute to thriving coastal communities. But 10 years on, has that actually happened? We reflect on the progress made and what urgently still needs to be done to safeguard our seas now and for future generations.
It is a truth universally acknowledged that Scotland’s marine biodiversity is not in good health.1 We are living through a global climate and biodiversity crisis, with the UK named as one of the most nature depleted countries in the world. There is a significant body of evidence that clearly shows current levels of human activities are not sustainable and that biodiversity will continue to decline if nothing changes. Only last week, news of a dramatic decline in breeding shag on the Isle of May nature reserve in the Firth of Forth hit the headlines, the latest in a seemingly endless conveyor belt of bad news stories about nature and climate.
A word cloud with responses to the question: “What three words would you use to describe the current health of Scotland’s seas?”, asked of delegates at the Sea Scotland conference, 2024.
Marine Protected Areas (MPAs) are a proven conservation measure that is widely used around the world, and the benefits both to nature (improving biodiversity) and people (better economic opportunities) are widely evidenced. The development of a “well-managed” network of MPAs has been an obligation for Scotland and the UK for decades. There have been a series of international and national deadlines over the years that have all been missed. For example, under the Oslo-Paris Convention (OSPAR), for which the UK is a contracting party and which covers the northeast Atlantic area, a recommendation set out in 2003 called for a well-managed network of MPAs to be established by 2010. The previous Scottish Government set a target of 2016 to ‘complete’ the network, which then slipped to 2020.
Following the designation of the 30 MPAs under Scottish law in 2014, the Scottish government set about working with stakeholders to develop management measures for high risk activities that are outside the licensing and consents system. In 2016 the first batch of fisheries management measures was adopted, following a public consultation and Parliamentary scrutiny. LINK campaigned to ensure these measures were sufficient for the purpose of protecting Priority Marine Features (PMFs), as many of the proposals were being suggested for areas where fishing activities were already low. In fact, the Scottish government’s own marine science unit recently published research showing that less than 1% of areas that have been historically fished by bottom-towed (seabed impacting) fishing activities are actually protected within MPAs. In the period since 2016, there has been some stakeholder engagement around additional proposed measures and development of assessments required by law (such as Socio-Economic Impact Assessment), but we are no closer to adopting measures for MPAs and PMFs beyond MPAs.
The Scottish government is now 10 years late in bringing forward the remaining majority of the fisheries management measures for the MPAs that we currently have. This means that activities that have been identified as posing a risk to many of the habitats and species the MPAs are designed to protect – primarily bottom towed fishing – continue to operate within these MPAs. Furthermore, monitoring and resources to understand the ongoing impact of the management measures not being in place is lacking, and environmental conditions have already changed significantly since the measures were first developed. Such is the imperative of the twin crises of climate change and biodiversity loss, that we should be progressing more ambitious measures to reverse these issues, never mind still waiting for basic protection measures that should have been in place years ago. These fisheries management measures are not an optional extra step – they are a fundamental requirement for MPAs, without which an MPA cannot even begin to achieve its conservation objectives. We can no longer afford to delay properly protecting our seas and allowing depleted species and habitats to recover.
LINK and some of its partners recently commissioned a report evaluating the effectiveness of Scotland’s MPAs network. The report, written by Professor James Harrison (an expert in marine and environmental law), underscores deficiencies in the MPA network including the lack of fisheries management measures in most of the inshore and all of the offshore sites. The report also highlights uncertainty around how it will contribute to Scotland and the UK’s global nature protection commitments and how it will meet current ecological and societal needs.
Infographic showing the steps needed to properly establish and protect Scotland’s network of marine protected areas, with annotations showing the progress made so far and where it has stalled.
In April 2024, the Scottish government announced the end of the power sharing agreement with the Scottish Green Party. The draft policy programme, published in 2021 and known as the Bute House Agreement, contained many essential policies for the marine environment. Critically, it again committed the Scottish government to finally implementing the long-awaited fisheries management measures, with a target of spring 2024 for those measures to be legally adopted. It’s now July 2024, and we are still waiting for the proposed measures to be published for public consultation. We’re concerned that the dissolution of the Bute House Agreement is just the latest thing to delay these consultations even further. Including the time for the consultation to run and the results to be analysed, we’re looking at a timescale of at least a year before any new measures may be adopted. This means if the consultations have not been published by around March 2025, there won’t be much chance of the fisheries measures being adopted within this parliamentary term (which ends in May 2026). This is a scenario we want to avoid – it’s not in anyone’s interest to delay this process any further.
Delayed management measures seems to be a chronic problem that is not unique to Scotland. For example, the Dogger Bank Special Area of Conservation in the English north sea was designated in 2011, but fisheries management measures weren’t adopted until 2022 when a complaint was brought to the European Commission against the UK government for not meeting the requirements of the law. Designating MPAs looks great, but they don’t do any good if damaging activities are not appropriately restricted, leading to ‘paper parks’. Not only does bottom-contacting fishing damage seabed habitats, there’s evidence to suggest that it contributes to climate change by disturbing carbon that is stored in the seabed. If it takes years to properly protect MPAs, could some of the ecological decline that has been evidenced in recent years be slowed or halted already if action had been taken sooner?
We’re calling on the Scottish government to progress management measures for inshore and offshore MPAs as soon as possible.
There is significant public appetite to see Scotland’s seas better protected2, and these MPA measures are a vital step towards this. Community involvement and transparency in policy making are extremely important to avoid situations like the backlash to Highly Protected Marine Areas (HMPAs) which caused a high level of anxiety and uncertainty within island and coastal communities. The proposed fisheries management measures for existing MPAs have already been subject to stakeholder discussion and the process has been supported by many marine interests, including the fishing industry who recognise the importance of protecting the resources on which they rely for their businesses. Protecting our environment and operating sustainable industries is mutually inclusive, and yet is often portrayed publicly as a false dichotomy that conservation measures come at the expense of economic opportunities. The reality is the opposite, if conservation measures are implemented within the principles of sustainable development – a global framework for improving the way environment, social, cultural and economic goals are achieved.
While it has been a tumultuous few months for Scottish and UK politics, we must not lose sight of the vital importance of environmental protection and the threats Scotland faces from climate change. As we move forward from the recent UK election under new national leadership toward the next Scottish election in 2026, our natural environment from which we derive so much must be the priority. Far from being only a Green Party issue, a healthy, productive, clean, safe environment is essential for our future and we must not lose sight of that. It is paramount that the Scottish government continue their commitment in responding to the climate and nature crises and creating a fairer, greener future.
What we need to progress MPA process and improve health of Scotland’s seas:
Management measures in MPAs to be progressed ASAP
Targets for nature recovery and for improving MPAs/marine protection in law
Clear leadership, including from industry and communities
Monitoring and resourcing as a priority (public and private finance) – healthy seas is in the public interest, huge influence on ecosystem service benefits that everyone needs
A more strategic approach to marine nature conservation – site protection alone is not enough ( species conservation and wider seas measures should also be considered, in line with Scotland’s Nature Conservation strategy)
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