Marine Protected Areas (MPAs) are designated spaces of the ocean and seas where human activities are regulated to protect natural resources and biodiversity. These areas are well-evidenced conservation tools to preserve marine species and habitats and enhance the resilience of marine ecosystems against threats such as climate change and overfishing. Scotland, like many countries, is committed to protecting at least 30% of its land and sea area by 2030, commonly shortened to “30 by 30”.
On 19th December 2024, the Scottish Government published its statutory report to parliament on Scotland’s inshore and offshore MPAs, which is required every 6 years. This report is a respective requirement of Section 103 of the Marine (Scotland) Act 2010 and section 124 of the Marine and Coastal Access Act 2009.
Progress welcomed
LINK members welcome the publication of the report to Parliament. The 2024 report considers the entire MPA network (including sites formerly designated under EU law, such as Special Areas of Conservation and Special Protection Areas), which builds on the 2018 edition.
Progress is welcome regarding the designation of sites. In 2018, Scotland had a network of 217 MPAs, but it now comprises a total of 233 sites.
In 2020 the Scottish Government designated four inshore MPAs for mobile species and 12 Special Protection Areas (SPA) for marine birds and seabirds. In 2022 theNorth Orkney and Scapa Flow SPAs were also designated. The same year, LINK members welcomed the permanent designation of the Red Rocks and Longay MPA to protect a newly discovered and extremely rare nursery ground for hundreds of flapper skate eggs,a critically endangered relative of sharks and rays.
Most importantly, the 2024 report to Parliament provides case studies showing localised positive effects on priority marine features (PMFs). In Loch Carron, designated as an “emergency” MPA in 2017 and made permanent in 2018, the flame shell beds that were damaged by scallop dredge activity are showing promising signs of recovery. This incident underscores the importance of proactively protecting vulnerable marine features before damage is done. The Loch Sunart to the Sound of Jura MPA for flapper skate exemplifies the benefits of restrictions on bottom-towed fishing. Monitoring of the site shows an increase in the abundance of flapper skates following the introduction of fishing restrictions in 2016. This case demonstrates the benefits of spatial management measures for mobile species, essential to safeguard populations of long-lived, slow-growing species such as flapper skate. LINK members particularly welcome the role of citizen science, such as recreational angling groups, and community engagement in the management and monitoring of the Loch Sunart to the Sound of Jura MPA.
New designations alone will not ensure the recovery of our seas.
In a report published in 2023, Professor James Harrison, an expert in marine environmental law from the University of Edinburgh, highlighted critical gaps in Scotland’s MPA network, both in terms of designations and the management measures that still need to be implemented.
Despite having a network of MPAs encompassing 38% of its seas, the majority of Scotland’s MPAs do not have restrictions in place for some of the most damaging or widespread pressures in the sea. The Scottish Government has committed to deliver a public consultation on fisheries management measures within MPAs and on the protection of Priority Marine Features (PMFs) outside MPAs. However, this commitment has repeatedly been delayed. A consultation on the fisheries management measures in offshore MPAs was published in 2024, 10 years after the designation of the first Scottish sites. Marine stakeholders and communities are still awaiting its counterpart on the remaining inshore MPA sites and the protection of vulnerable seabed habitat PMFs outside MPAs.
Since the start of the process to develop fisheries management measures for MPAs, they have been implemented in only a few inshore sites, covering less than 0.6% of the seabed that has beenhistorically subject to bottom-towed fishing activities. This underscores that current safeguards for our MPAs aren’t likely to make a big difference in reducing the amount of fishing activity that harms the seabed habitats and the species that depend upon them.
Professor Harrison’s report highlights the need for comprehensive revisions and enhancements to align with international best practices. A more detailed briefing on this report is available here.
Following the shelved proposals to designate Highly Protected Marine Areas in 10% of Scotland’s seas in 2023, LINK members welcomed theScottish Government’s commitment to build greater consensus and its stress on the need to deliver on ecological outcomes. However, clarity on how the Scottish Government intends to align with international commitments and benchmarks is still needed, such as the Global Biodiversity Framework target 2 (“Restore 30% of all Degraded Ecosystems”) and EU Nature Restoration Law. The current scientific evidence base, which must underpin conservation measures, is clear that the biggest threats to marine ecosystems are climate change and unsustainable fishing practices. Implementing the remaining fisheries management measures within MPAs is just one step towards better protection of our seas, focusing on specific species and habitats in specific places based on proposals that were developed 8 years ago. The ocean is all connected and we need to acknowledge that in the way it is managed. We want to see a change in the way fisheries are managed beyond MPAs, as part of a just transition to a fully documented, climate-smart and nature-friendly regime that enables ecosystem recovery and supports sustainable fishing opportunities and coastal communities.
Conclusion
LINK members welcome the progress highlighted in the report to Parliament. However,much more is needed to ensure healthy and resilient marine ecosystems. Simply designating an MPA without putting in place restrictions on damaging activities is meaningless.
Calum Duncan, Head of Policy and Advocacy at the Marine Conservation Society and Convenor of Scottish Environment LINK’s Marine Group said:
“We’re pleased the report shows that measures to protect the most vulnerable inshore sites in 2016 are showing localised signs of working with, for example, increases in flameshells and flapper skate numbers. However, despite welcome action to protect the most vulnerable inshore sites in 2016, most designated areas still lack robust management measures for damaging activities such as bottom towed fishing, and remain ‘paper parks’ until they are in place.
“Scotland’s seas are in a poor state, and we desperately need to safeguard important underwater sites needed to boost ocean health. Further delays will only make recovery harder and risk further damage to our seas. In 2025, the Scottish Government must act decisively to deliver long-awaited protections and live up to crucial legal, policy and international commitments before it is too late.”
By James Curran, Scottish Environment LINK Honorary Fellow
Is the COP process a busted flush? This year we had hopes and expectations raised, yet again, for the COP16 on global biodiversity and for the COP29 on global climate change. It’s fair to say, both were pretty disastrous. “Nobody should be OK with this” said Euronews about COP16. “Travesty of Justice” commented the Guardian on CoP29. In both cases, at least the arguments were more about funding of global action than about any remaining dissent on the science. Groucho Marx said “While money can’t buy you happiness, it certainly lets you choose your own form of misery”. That’s just about where we are now.
Biodiversity continues to decline, while greenhouse gas emissions are at their highest ever. In both cases the science is now totally conclusive. There is even widespread recognition that more than half the world’s GDP, amounting to $58 Tn pa, is dependent on nature. Meanwhile the World Economic Forum places extreme weather, Earth systems, biodiversity collapse, and resource shortages as the top four global risks over the next decade. “We are playing Russian roulette with our planet” says the UN Secretary General, “We need an exit ramp off the highway to climate hell”.
A necessary question is – do the COPs offer that exit ramp?
Reportedly, there were almost 1800 fossil fuel lobbyists attending COP29. Critics suggest the climate CoPs have been undermined, turning them into greenwashing trade shows.
As Henry Ford said “Don’t find fault. Find a remedy”. So what might be the remedy?
Well, climate COPs have to agree by consensus across 196 nations. From the outset the oil producing countries blocked any move to adopt a voting system. Biodiversity COPs can, as a last resort, utilise two-thirds majority voting. So, inevitably, there is a feeling that both COPs only deliver the lowest common denominator. Additionally, there are no sanctions for nations failing to deliver on their stated COP commitments. This is in contrast, say, to the World Trade Organisation (WTO) which can, if necessary, vote on resolutions and can also agree to international trade sanctions against defaulters.
Is it time to create a dual approach? Perhaps keep the existing COPs as a back-stop, but create something much more dynamic, focused robustly on delivery? Maybe a Community of Progressives (CoP), with their own annual CoP meetings, most certainly excluding lobbyists and with majority voting powers. This Community could bring together those nations who really seek a healthier and more sustainable planet and who have demonstrated either a track-record of correcting past mistakes, or a history of contributing very little to climate change, or are outstandingly vulnerable to climate impacts. So the Community could well include the likes of the EU, Philippines, India, Morocco, Chile, UK, Egypt, Brazil, Thailand, and Pakistan, as well as Dominica, Solomon Islands, and Samoa, amongst many others. It is probably time also to align the inter-connected global biodiversity and climate efforts into one Community. So, countries delivering determined biodiversity action should also join, including, for example, Congo, Tanzania, Zambia, Namibia, Venezuela, Bhutan, Japan, Brazil, and the EU.
Don’t such groupings already exist? Well, some do, but they’re disparate and fragmented. One was created alongside the Glasgow Climate Pact at COP26, formed of 137 countries committed to halting and reversing forest loss and land degradation while others, for example, the long-standing Environmental Integrity Group of nations even encompasses developed and developing nations and straddles both climate and biodiversity. The Accelerator Partnership was created at the Biodiversity COP15. As many as possible of these groups, if judged to be sufficiently dynamic and committed, should obviously join a new high-profile global Community of Progressives.
This Community of Progressives could, hopefully, agree new ambitious pathways, standards and targets to tackle the urgent problems of climate and biodiversity. The Community should also serve to illuminate the painfully slow pace of the traditional COPs, should demonstrate that much more can be done, and, thereby, drag other more recalcitrant nations along in its wake.
The new Community, like the WTO, should embrace a voting structure for decision-making but it also needs incentives and penalties for performance. How can nation states be sanctioned?
Well, the great majority of countries have been assigned sovereign credit ratings, predominantly by the three big US credit ratings agencies, Standard & Poor’s, Fitch, and Moody’s. Other agencies exist, including DBRS Morningstar and Scope Ratings. These agencies are all regulated, for example, by the Financial Conduct Authority in the UK which issues them with technical instructions. Currently, the credit ratings agencies pay little or no heed to government actions on climate change mitigation, climate change adaptation, or nature restoration. The regulators should address this gap. Surely a government that makes a commitment at a climate or biodiversity COP, and then fails to deliver, is a government not to be trusted? Such a government should be penalised by a significant reduction in credit rating – resulting in much higher interest rates and therefore repayments on international borrowing. However, successful delivery should improve ratings and lead to lower borrowing costs. This can be a very powerful tool – since resultant borrowing costs can easily double or halve (for comparison, UK Government borrowing costs are near 10% of total expenditure).
What about those countries not invited to the first-division Community of Progressives, like say Russia or the USA? They certainly wouldn’t escape the likely penalties from downgraded sovereign ratings, and might even be encouraged by the prospect of improved credit ratings if they step up.
The growing climate and nature emergencies demand new governance structures and new mechanisms that actually deliver. Perhaps leave the old discredited system in place – but it’s surely time to explore different models. Henry Ford again: “If you always do what you’ve always done, you’ll always get what you’ve always got”.
Tensions are certainly growing around the COP processes. It seems the USA may walk away again. A group of world leaders wrote an open letter condemning COP as not fit for purpose. Towards the close of COP29, the 44 nations represented by the Alliance of Small Island States and the 46 nations of the Least Developing Countries, stormed out, exasperated by slow and unambitious decision-making. “We are a force to be reckoned with” they said. Yes – together they could build a new highway to hope.
Responding to the draft Scottish budget, Deborah Long, Chief Officer at Scottish Environment LINK, said:
“The First Minister has committed to tackling the environmental crises as a priority for his government. This budget was a test of whether this commitment would be matched by appropriate funding.
“The increased investment in peatland restoration and for the Atlantic rainforest is very welcome. Restoring these vital habitats brings not just biodiversity benefits but is necessary to tackle climate change – and is an excellent use of the Scotwind resource.
“However these budget lines account for only a small proportion of environmental spend and we know there are significant pressures elsewhere.
“While it is positive to see an increase in the Forestry Grant Scheme, this increase only partially restores the significant cuts made last year – and it is important that this investment prioritises native woodland creation.
“Cuts to the budgets of environmental agencies are also very disappointing. While we accept there are pressures across the public sector, we must respond to the environmental crises with the seriousness required. Achieving our targets for nature restoration and the ambitions of the recently published Biodiversity Strategy will rely on people across society, but our environmental agencies have a crucial role to play.
“It does appear that we remain on track to hit the £65 million pledge for the Nature Restoration Fund over the lifetime of the parliament, which is very welcome.
“This is of course a draft Budget and the Scottish Government must find support across the chamber to pass it. We hope that MSPs in all parties will argue for investment in nature in line with the seriousness of the crisis we face and the work that needs to be done.”
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
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