Deborah Long, Scottish Environment LINK Chief Officer retraces Sea Scotland 2024, which was held on 3rd and 4th June at Stirling Court Hotel.
Sea Scotland 2024 kicked off with our morning youth event, Making waves: Sea Scotland Youth Voices. An enthusiastic, knowledgeable and thoughtful group of 15 young people came together to find out more about how to make waves at conferences like this one. They are all starting their marine career, or anticipating one, and are keen to get involved. We were pleased that some of them were able to stay for the entire conference and practice their new knowledge and skills.
This year’s conference explored “Sharing our blue space”. Catherine Gemmell, Marine Conservation Society, started us off with her insightful and inspiring keynote assessment of what it means to share our blue space. We followed on with an expert panel discussion around marine policy. Speakers looked at where we are in marine policy, expressed all our frustration at the slow rate of progress but also stressed the absolute need to keep going. They outlined the challenges we face, and the actions needed, including public and private investment, using SMEEF as a current model for this. Audience questions explored how we can make more and speedier progress, and what the reality of change looks like and needs to achieve.
Later in the afternoon, delegates chose one of 3 sessions: an “Industry with Ambition” session looked at sustainability and the role of innovation in ecosystem restoration and supporting strong communities. The Marine Just Transition workshop underlined the fundamental need for a just transition and offered hope as well as wider scope for fair and just change. The nature restoration session looked at the challenges and opportunities in restoration and concluded that we need to do much more to meet our nature restoration goals.
Day 2 of the conference started with a message from the Cabinet Secretary. This helpfully reiterated her and the Government’s commitment to the nature and climate goals as well as outlining Government ambitions for Scotland’s blue space. The audience poll afterwards reflected the poor condition today of Scotland’s’ seas but also contained optimism for the future.
The morning expert panel session tackled marine planning. Speakers looked at Government plans for the National Marine Plan 2; the importance of coastal literacy and the potential of community-led partnership building with members of the public, schools and industry. The power of community-led action was illustrated through the community-led State of the Coast for Aberdeen and Aberdeenshire. Speakers also looked at what the future of marine planning could and should look like, especially related to offshore wind and how marine planning works for mobile species, like minke whales. Audience questions focussed on the speed of change already happening in Scotland’s marine environment and the need for policy to catch up with the speed of those changes. Comments underlined how we cannot afford to linger any longer. The audience was also interested in coherence and coordination for National Marine Plan 2, particularly the need to learn lessons from National Marine Plan 1, and to ensure it delivers community-informed decision-making.
The three afternoon workshops looked at managing diverse views and perceptions and how we can use our own feelings to help us understand others; using the community voice method in the Oceans of value project and using art for activism: how visualising the key issues in new ways engages more people, and builds creative new collaborations.
If I was to sum up the key points from our two days:
The need for speed: we’ve been talking about the need for protection and effective spatial planning for 20 years now. In that time, our marine environment has changed and deteriorated while becoming more pressured. While Scottish Government ambition remains high, delivery is far too slow. This is challenging but because ecological changes are already happening, we can’t afford to wait any longer to tackle it.
A Just Transition: one of our panellists said: Healthy, happy communities [should be] able to have a good life and protect their environment at the same time. Marine has long been an obvious gap in the Government’s Just Transition work, and it is very welcome to see the start of direct work on it. Some common themes of this year’s Sea Scotland echo themes in the visits the Just Transition Commission are making:
we need to learn the lessons of the past and avoid past mistakes that led to severe and ongoing injustices;
we need professionally facilitated conversations;
we need better communication and real engagement with local communities, to avoid the pervasive ‘consultation overload’;
we need to have the hard conversations about what has to change and who has to pay
and finally, we need to hear all voices.
There are 5 F’s that I took from the conference:
First F is for Food. It breaks the ice, brings people together and is the start of productive conversation
Second F is for Films: these inspire and communicate with a very wide audience
Third F is for Feelings: if we can be brave enough to harness the power of feelings, our own feelings help us understand our own perspectives as well as understand others and that mutual understanding builds better joint outcomes.
Fourth F is for Finding new ways; art is a great way to express complex and sometimes depressing environmental issues. But art visualises the issues we face in the marine environment in new and surprising ways, which helps us build understanding and support for action.
Scotland’s stunning coastline and rich marine biodiversity are celebrated worldwide. To better protect these fragile ecosystems, the Scottish Government has established a network of Marine Protected Areas (MPAs). However, a new research report has recently shed light on the pressing need for greater protection within this network. In this blog post, we’ll delve into this research and its implications for Scotland’s marine environment.
Scotland’s Marine Protected Areas
Scotland’s MPAs are designated areas where specific conservation objectives aim to safeguard the diverse range of species and habitats within their boundaries. These areas are designed to play a pivotal role in conserving and restoring marine biodiversity, offering havens for numerous species, from seals and seabirds to rare fish and invertebrates, and providing resilient habitats that can withstand the impacts of a changing climate.
Scotland has an extensive existing network of MPAs, with a new suite of MPAs for nature conservation created in 2014. However, most still allow damaging forms of fishing, as the Scottish Government process to put fishing restrictions in place is on-going.
The Research Findings
Recent scientific research, conducted by James Harrison, Professor of Environmental Law at the University of Edinburgh, has unveiled sobering findings regarding the effectiveness of Scotland’s MPA network, providing no less than 28 recommendations to improve the current approach. The research underscores that current protection measures in place are not adequately safeguarding these critical marine habitats and Scotland’s MPA network currently falls short of international targets and best practice.
The Convention on Biological Diversity – an international treaty to which the UK is a party – emphasises the importance of including a mixture of MPAs that are strictly protected and those that allow some human activities at sustainable levels to take place. However, a significant portion of MPAs lack effective protection from the most damaging activities. These were identified in Scotland’s Marine Assessment (2020) as the impacts of climate change and commercial bottom-towed fishing activities. Without the long-awaited restrictions for fishing activities within MPAs, habitat degradation will continue to harm the ecosystems within MPAs, emphasizing the need for more stringent protection and enforcement.
The report further highlights shortcomings in the monitoring and enforcement of Scotland’s MPA network and the need for a comprehensive marine conservation strategy for Scotland, of which the MPA network would be a key part.
Climate change is affecting Scotland’s marine environments, posing additional challenges to the resilience of MPAs and coastal communities. Rising sea temperatures and ocean acidification threaten the very ecosystems these areas were established to protect. Healthier ecosystems will be more resilient to the effects of climate change and will help to ensure resource availability for current and future generations. Empowering coastal communities by increasing their role in MPA management is crucial to ensure their long-term success.
What needs to happen next
These research findings emphasize the urgent need for action to enhance protection within Scotland’s MPA network. Policymakers must revise and fortify the legal framework governing MPAs, bringing Scotland in line with international best practice, and ensuring more robust enforcement mechanisms. Adequate funding and resources are paramount for effective MPA management, including enhanced monitoring, research, and community inclusion efforts. Against the backdrop of the UN Decade for Ecosystem Restoration, and targets to protect 30% of land and sea by 2030, this report underlines just how much needs to be done in the next few years. The highest priority is to get measures in place to manage the impact of fishing activities on Scottish MPAs – we’re currently running a petition calling on the Scottish Government to do this without further delay.
Conclusion
Scotland’s Marine Protected Areas are critical sanctuaries for marine life, fisheries, and climate resilience. However, the recent research underscores the pressing need to strengthen their protection. By revising legal frameworks, allocating more resources, addressing climate resilience, and involving local communities, we can ensure these precious marine ecosystems thrive and continue to benefit both Scotland’s natural heritage and its people. It’s time to act decisively to protect and preserve Scotland’s marine treasures for generations to come.
Over 2,500 people have signed our petition calling on the Scottish government to put tailored fisheries restrictions in place across Scotland’s marine protected areas by the end of 2025 – add your voice.
Image credit: Cath Bain, Whale and Dolphin Conservation
Scottish Environment LINK’s Chief Officer Deborah Long outlines seven actions Scotland can take now as a country to protect and restore nature, build our resilience to climate change and create a better place to live for current and future generations.
In 2023 average global temperatures rose above 1.5oc. Scotland’s biodiversity intactness is amongst the lowest in Europe. Without action, temperatures will continue to rise, nature will continue to decline. Now is not the time to be distracted.
These changes are impacting on Scotland’s people now. Storms last year rose in frequency, with more than twice as many named storms between September 2023 – January 2024 than the previous 6 months. Scotland loses an estimated 920,000 tonnes of soil per year, and soil erosion costs businesses £50 million annually. Flood damage to property is expected to increase by 20% by 2050 across the UK. Insurance premiums for homes that have flooded once are now almost twice as expensive as homes that haven’t flooded, up nearly 30% in cost from January 2023.
When climate change combines with biodiversity loss, the consequences are even wider reaching. Ocean warming is moving fish populations further north, while Scotland’s seabirds are affected by avian flu and having to travel further for food, resulting in lower chick survival rates. Scottish farmers are experiencing higher aphid populations, which are impacting on yield. Tick numbers are increasing, matched by a higher incidence of human infections and putting pressure on the NHS.
Against this background, while the political rhetoric has been strong, delivery on the ground has been weak. Just last month, NFU Scotland were calling for environmental regulations to be suspended because of the adverse impacts of a changing climate. Farming is the second highest emitting sector in Scotland but the sector with the highest potential to contribute to sustainable solutions.
The quickest and most logical and cost effective way out of this crisis is to work with nature, to repair nature so she can help us. Without functioning ecosystems, where river flood plains contain excessive rainwater, where forests and farmland can withstand storms, where predator populations can keep aphids in check, we have no long term solution. Our best chance is to build biodiversity and nature’s resilience to change and with that our own.
What should we be doing now?
1 Manage deer to sustainable levels
Deer numbers in Scotland are too high, having increased to about 1 million wild deer in 2024 from about half a million in 1990. This is beyond the capacity of Scotland’s ecosystems. By bringing down deer numbers, we will rebuild diverse and well adapted mountain plant communities that hold together upland soils and reduce erosion. We will also drive down tick infestations.
2 Create woodland along rivers
Creating woodland along rivers provides natural flood management by keeping river waters upstream for as long as possible. Trees along riverbanks create habitat and shade for salmon and insect populations and hold back mountain soils.
3 Reduce pesticide use and increase on-farm biodiversity
Reducing pesticides helps hoverflies, ladybirds and other insects survive in enough numbers to manage aphid infestations, for example. Increased plant biodiversity reduces soil wash out into rivers, reduces fertiliser demand and reduces river and loch eutrophication (when bodies of water become overwhelmed with algae, depleting oxygen levels).
4 Build nature networks
Creating nature networks helps strengthen the survival of rare species, builds genetic diversity by connecting individuals together, and increases habitat space so that local populations falls do not wipe out entire rare populations. They enable species to move when habitat becomes inhospitable.
5 Diversify forestry and woodland
Forests and woodlands with more species diversity are more resilient to disease and storms, limit species invasion onto adjacent habitats, support more biodiversity, create more interesting forests and support more livelihoods.
6 Involve local communities
When local communities are involved in decision making, they are more supportive of change, they have agency and choice via increased local economic opportunities and they bequeath a better legacy to future generations.
7 Set statutory nature targets
Having realistic but stretching targets to aim for drives ambition and enables us to measure progress. They help us prioritise and drive action on nature restoration, and all the points above.
These actions are all easy to implement. They need no new technology. They just need resource and application. As a crucial driver of some of these measures, the Agriculture and Rural Communities Bill currently before the Scottish Parliament could, and must, support farmers in maintaining healthy soils, building resilient crops through healthy insect populations and biodiverse flora, and retaining flood waters in upland areas.
By maintaining a clear-eyed focus on doing all we can to protect and restore our natural environment, we’ll allow nature to help us build a much better future: a low carbon, high nature world.
On 2 May, 21 organisations wrote to Mairi Gougeon, Cabinet Secretary for Rural Affairs, Land Reform and Islands, calling for a marked increase in the pace and scope of change in Scotland’s farm support system, to enable farming to meaningfully contribute to Scotland reaching Net Zero.
To: Mairi Gougeon MSP, Cabinet Secretary for Rural Affairs, Land Reform and Islands
Dear Cabinet Secretary,
The weakening of Scotland’s 2030 climate targets is deeply concerning. The impacts of the climate and nature crises are being felt worldwide, including by Scottish farmers and crofters, with many areas of the country having experienced their wettest April on record. We need to step up our efforts to tackle these deeply connected environmental challenges.
With agriculture our second biggest source of greenhouse gas emissions, it is clear that we cannot reach Net Zero without significant changes to the way we farm in Scotland. The Scottish Government must establish, without delay, a support system that enables farmers and crofters to make the transition to sustainable farming.
The recognition in last month’s climate policy statement of the importance of farming in addressing climate change is welcome. It is encouraging that nutrient management planning will be required as part of each farm’s Whole Farm Plan, and that methane suppressing feed additives will be piloted. However, the policies announced to date are not enough to bring about the transformative change we need to see in the agriculture sector. The interventions required to reduce agricultural emissions include:
An increase in the amount of land farmed organically
Increased funding for the integration of native trees and hedges on farms and crofts
Increased funding for the restoration of habitats including peatlands, wetlands and grasslands
Selective breeding for low methane livestock
A faster rollout than has been announced for carbon audit requirements
In particular, we need to see the majority of public funding for farming supporting methods that help restore nature and tackle climate change. Earlier this year the Scottish Government committed to distributing 70% of the farm support budget through the first two tiers of the new payment system. This risks a business as usual continuation of the current funding system, which the Scottish government’s own analysis has shown is unfair, and doesn’t help farmers and crofters who want to tackle climate change and protect nature.
Since Tier 2 funding will be focused on emissions reduction and nature restoration, and Tier 1 will largely replicate the current area-based ‘direct payments’ which have few environmental requirements attached,it is vital that Tier 2 is clearly prioritised in the announcement expected in June on the distribution of this 70%.
The Agriculture and Rural Communities Bill presents a once in a lifetime opportunity to make farming work for nature, climate and people. The Scottish Government must now demonstrate in detail how the changes proposed in this bill will enable Scottish farming to meaningfully contribute to Scotland reaching Net Zero. A marked increase in the pace and scope of change is required.
We urge you to ensure that the new farm support system established by the bill enables ALL farmers and crofters to produce food in ways that reduce emissions, restore nature, promote the highest standards of animal welfare, and revitalise our rural areas for the benefit of everyone. We hope the announcement expected in June on the distribution of funding demonstrates the Scottish Government’s ambition to transform Scottish farming.
Yours sincerely,
Lang Banks, Director, WWF Scotland
Josie Cohen, Head of Policy and Campaigns, PAN UK
Dr Rachael Cooper-Bohannon, Scotland Coordinator, Amphibian and Reptile Conservation
Shivali Fifield, Chief Officer, Environmental Rights Centre for Scotland
Angus Hardie, Director, Scottish Community Alliance
Kat Jones, Director, Action to Protect Rural Scotland (APRS)
Deborah Long, Chief Officer, Scottish Environment LINK
Robin McAlpine, Founder, Common Weal
Anne McCall, Director, RSPB Scotland
David McKay, Co-Director, Soil Association Scotland
The UK is now one of the most nature-depleted countries on Earth. The most recent State of Nature Report – the UK’s most comprehensive report on biodiversity – has clearly mapped the continued decline of our wildlife over the past decades, following on from the UK’s already extensive historical loss of nature prior to contemporary record-keeping. At present, one in six species is at risk of going extinct in Great Britain. As a signatory to the UN Convention on Biological Diversity, the UK legally must ensure that we respond to the scale and pace of the nature crisis.
Whilst many policy matters relating to nature are devolved to the Scottish Government, significant areas affecting Scotland’s natural environment are reserved to the UK Government.
Scottish Environment LINK calls upon all political parties to ensure that their manifestos for the upcoming UK General Election incorporate clear commitments to the protection and restoration of the UK’s natural environment. For Scotland’s benefit, these commitments should include the follow areas:
1. Agricultural Funding
Scottish Environment LINK supports the Nature 2030 campaign’s call for a pay rise for farmers. Farmers, crofters and land managers are central to meeting Scotland’s climate and nature ambitions, and they should be fairly compensated for their efforts. While the Scottish Government is responsible for agriculture policy, the overall budget is dependent on decisions made at a UK level.
Scottish MPs should push for higher funding for agriculture overall and ensure that Scotland continues to receive at least the current proportion of UK funding.
2. Reform of the Internal Market Act
The Internal Market Act poses a key risk to environmental policymaking in the devolved nations of the UK. The rules of the internal market may act as a ceiling to environmental ambitions, rather than a floor, and may dissuade the type of policy innovation which has to date been typical of devolution. There is a very real risk that the Internal Market Act, left unreformed, has a chilling effect on environmental policy.
There are also structural issues with the Act, with a lack of clarity on the mechanisms for devolved governments to request exemptions. There are clear opportunities to reform the operation of the Act in the interests of better policy making.
The Internal Market Act should be reformed and environmental measures made exempt from internal market rules.
3. Circular Economy
The next UK Government must commit to keep pace with Europe’s Circular Economy Action Plan on product policy, in particular eco-design standards and right to repair. Extended Producer Responsibility (EPR) schemes are needed that will incentivise reuse as well as fund collection and recycling, and we need the UK Government to deliver an all-inclusive deposit return system for drinks containers, including glass containers, by 2025.
The UK urgently needs a comprehensive UK Chemicals Strategy to outline its vision for protecting human health and the environment. UK REACH should at a minimum close the growing gap between the EU and UK in the regulation of harmful chemicals, such as PFAS, and remain aligned to EU REACH. Products should be incentivised to be safe by design and a national materials data hub should be developed to provide comprehensive data of raw and secondary materials including chemicals.
4. Peatlands
The UK Peatland Strategy (2018-2040) remains a valuable plan for all countries of the UK to coordinate peatland restoration and protection. The work of the UK’s IUCN Peatland Programme has been instrumental in supporting coordinated action between the countries of the UK.
However, continuing to allow the extraction and importation of peat for use in horticulture undermines the environmental gains made from restoring peat bogs and makes it more difficult for the UK to meet its net zero targets. The next UK Government should work with the devolved administrations to end the selling of peat for horticulture in all UK countries. It should also ban the importation of peat at the earliest opportunity.
5. UK [Good] Food Bill
The UK’s current food system is damaging our health and the environment, and the impacts of the global coronavirus pandemic have highlighted the need for resilient food supply chains. Following the recommendations of the Dimbleby Review, Scottish Environment LINK encourages a strong framework of legal targets to improve the UK’s food system.
Scottish Environment LINK supports the creation of a UK [Good] Food Bill, in line with Scotland’s Good Food Nation Act, which focuses on long-term measures to deliver a healthier, resilient, just and sustainable food system. A UK [Good] Food Bill would reinforce existing legislation in devolved nations through the ability to better engage with overlapping areas of food policy that are reserved to the UK Government, including trade and industry.
6. Lead Ammunition
Scottish Environment LINK supports banning the use and sale of lead ammunition for both live quarry shooting and outside use. The international scientific consensus is that lead ammunition poses risks to human health, wildlife and captive animals, including livestock and domestic animals. Partial bans on the use of lead ammunition have been ineffective or only partially effective and alternative ammunition types are both effective and widely available.
7. Climate and the UK General Election
Scottish Environment LINK supports and echoes Stop Climate Chaos Scotland’s (SCCS) calls for both the Scottish Government and the next UK Government to take bold action to tackle climate change. You can read more about the importance of addressing the climate crisis for both the Scottish and UK Governments, along with SCCS’ policy proposals for the next UK Government, here.
8. Global Leadership
The next government will represent the whole UK on the international stage. As such, it has a key role to play in driving ambitious global action for biodiversity, climate and environmental sustainability in this critical decade to 2030. This government must lead by example in its domestic agenda, including through its compliance with the Aarhus Convention, and support practical action around the world, demonstrating that the UK will play its part in securing a world where people and nature can thrive.
Nature underpins so much of our society – from the food we eat, the air we breathe, our medicines and more. The love of nature is shared across the political divide and there has never been greater need for clear political leadership to address both the nature and climate crises.
Tom Turnbull is Chair of the Association of Deer Management Groups, Duncan Orr-Ewing is Convenor of Scottish Environment LINK’s Deer Group and Richard Cooke is Chair of Scottish Venison. They are all members of the Common Ground Forum.
Scottish venison is bringing people from all sides of the deer debate together. Of all the qualities that deer management brings to Scotland, be it quality tourism or the skilled craft of our deer stalkers, Scottish venison is right up there as one of the most valuable products to come from our hills and forests. At a time when differences of opinion on deer management are coming to the surface once more, this seems a good moment to write jointly about an issue, and an opportunity, which we each passionately believe in.
Venison is a healthy meat, low in fat, high in flavour and has featured in Scottish cuisine, both lofty and humble, for centuries. Most of our venison comes from wild, rather than farmed, deer populations that have been part of our landscapes for millennia. While it may have a reputation for being expensive in some quarters, it sits in roughly the same price bracket as Scotch beef and lamb. In short, we have a great product that is distinctively Scottish and highly marketable.
The clear direction of government policy is that deer populations in Scotland need to be reduced to help enable nature’s recovery and mitigate climate change across more of our landscapes. A greater amount of work will be needed to implement this, with increased costs. Venison sales are often the only income to offset these costs, but current prices fall a long way short of reflecting the true value of this high-quality product. Research has indicated that it does not even cover the costs of hunting, letalone bringing venison to the market.
And it is here that we see a clear opportunity for Scotland. We have written jointly to the Cabinet Secretary for Rural Affairs and the Islands to ask her to consider allocating a small proportion of the public funding for land management to a venison subsidy. We argue that doing so will directly support the additional deer management needed to allow our woodlands and peatlands to regenerate, while helping at the same time to secure the basis of a sustainable venison market that Scotland can be proud of for years to come.
The investment required is estimated at £3-5 million per year, a comparatively minor part of Scotland’s annual ~£650 million land management budget. This will contribute to the costs of deer management in delivering a range of vital outcomes everyone will benefit from – for nature, climate change, jobs in deer management and allowing deer, one of our finest national assets, to shine. For all these reasons, we hope that the government will also see this as too good an opportunity to miss.
The discussions that us led to identifying this opportunity and to jointly write to the Cabinet Secretary took place under the Common Ground Forum, an initiative that brings together all those in the Scottish deer sector interested in a more collaborative approach to deer management, based on mutual respect and consensus building, can contribute to a vision of a greener, healthier and economically vibrant future.
By Phoebe Cochrane, Scottish Environment LINK’s Sustainable Economics Officer
Image: Friends of the Earth Scotland/Iain McLean
Moving towards a morecircular economy is important and urgent. Globally, about 90% of biodiversity loss can be attributed to resource extraction and processing and, in Scotland, about 80% of our carbon footprint is from emissions embedded in goods we use and consume.
A transition to a more circular economy, where we consume less raw materials, use products and materials again and again and prevent waste leaking into the environment, needs to replace our wasteful linear economy, one of using products for a short time before discarding them.
Scotland won’t meet its commitments on climate change or make a fair contribution to reversing global biodiversity loss until its economy becomes more circular. Although the need to transition to a circular economy is clear and it is popular across the political divide, the linear economy is firmly entrenched, and those that do adopt circular models are often at a competitive disadvantage, and many have remained niche. So, although there are many great pioneering initiatives, what we now need is wholesale change and that requires Government to take up the reins.
The Circular Economy Bill, currently going through Parliament, offers the opportunity to do just that. There are three stages to a Bill’s passage through Parliament. The Circular Economy Bill has just been voted through Stage 1 following scrutiny by the Net Zero, Energy and Transport Committee. The committeereport and Minister’s response are available.
LINK members were pleased to see unanimous recognition of the need to move to a more circular economy expressed by MSPs in the Stage 1 debate, and the calls for more ambition and clarity. We were also pleased to hear many of our ideas mentioned by MSPs.
The Bill has now moved on to Stage 2 where the Committee consider and then vote on amendments to the Bill.
LINK members are generally supportive of measures in the Bill (which include the introduction of charges for single use items, banning the destruction of unsold goods, improving local authority waste management services, reporting of surpluses and waste) but are proposing a number of amendments, which broadly fall into five areas.
A definition of circular economy and the waste hierarchy
Two fundamental omissions from the Bill are a definition of a circular economy and the waste hierarchy. Both could be included at the beginning of the bill in something called a ‘Purpose clause’. There are many different definitions of circular economy, which at its most simple must include that it is an economy in which the consumption of raw materials is reduced to sustainable levels. The Ellen MacArthur Foundation describe it as a ‘system where materials never become waste and nature is regenerated.’
Thewaste hierarchy holds that there is a hierarchy in the ways to deal with waste. As such, measures towards the bottom of the hierarchy (like landfill, incineration, and even recycling) should not be deployed until those higher up (reduction, reuse, refurbishment etc) are exhausted.
Strengthening the framework
The Bill is in part a framework bill – in other words, it sets out the framework for a strategic and comprehensive approach to a more circular economy in Scotland that will drive further regulatory and policy changes.
The Bill includes measures on setting statutory circular economy targets, publishing a circular economy strategy every 5 years, reporting requirements; and emphasises that targets and strategy should contribute to the reduction of consumption of materials. However, for the framework to be effective in driving and delivering change, it must be tighter and we are asking for specific amendments on the obligation to set targets; the nature of those targets, which must include a carbon footprint target; and the need for the strategy to detail how targets will be met.
Producer responsibility
LINK members would like to see the Bill include specific measures to make more businesses take back their products when they would otherwise be discarded. This would transfer the responsibility for management of this ‘waste’ to the producer and would incentivise them to sell products that are designed to ‘retain value’ at the end of their life – in other words, be made in such a way that they could be more cheaply and effectively reused, or parts of them could be reused or, if not, at a minimum the materials could be readily recycled.
The Bill should also obligate the use of reusable packaging, with targets for a proportion of all packaging to be reusable by a certain date, as is the case in other countries such asFrance and Germany.
Scottish Government’s circularity
LINK members would like to see public bodies obliged to consider use of materials in their procurement decisions, in the same way they already have to consider climate emissions. Similarly, circularity reporting should be part of the process for applying for public sector grants and loans. These measures would ensure that those in receipt of public money would need to be working towards making their products and operations more circular and reducing their consumption of raw materials and associated carbon emissions.
Just Transition and Due diligence
LINK members are proposing amendments on Just Transition and due diligence in the Bill. First, to require alignment with the Just Transition principles which include engagement with workers and a focus on sustainable jobs. Second, placing a duty on public bodies to prevent human rights and environmental harms as far as possible in their own operations and throughout their supply chain.
As you can see from the above, LINK members have quite a range of suggestions for improvements to this Bill.We will be working with the Scottish Government and MSPs on these amendments during the coming weeks. The Committee will be voting on amendments on the 30th April – this will be the end of Stage 2, and Stage 3 (back to the whole Parliament for the last chance to amend the Bill) will follow shortly after.
For more details on the amendments proposed please see the below or contact Phoebe@scotlink.org:
Duncan Orr-Ewing is Head of Species and Land Management at RSPB Scotland, and a member of the Scottish Leadership Team of RSPB Scotland. He has been involved in game and upland management policy issues since the early 2000s. He manages the RSPB’s UK Investigations Team which works with the Police and other enforcement agencies to prosecute and enforce wildlife protection laws. He is also Convener of the LINK Deer Group and Chair of the Central Scotland Raptor Study Group.
The Wildlife Management and Muirburn (WMM) Bill
The 21st March 2024, and the passing of the WMM Bill by the Scottish Parliament, will go down as a momentous day for all of us who have long campaigned for a better future for both nature and climate on land managed as grouse moors in Scotland. This legislation means that Scotland is the first part of the UK to have any form of regulated gamebird hunting. This situation was simply a historical construct, and we now fall into line with other similar European countries.
My own personal experience of the appalling levels of illegal killing of bird of prey in Scotland started when I was appointed to oversee the Red Kite reintroduction programme to the Black Isle, Highland in the early 1990s. Research at that time showed that of 103 Red Kites found dead 40% had been killed illegally, mainly by direct poisoning. When compared to the English equivalent Red Kite reintroduction project, the Black Isle population stood in 2006 at 40 breeding pairs whereas in the Chilterns in England the population was a startling 300 breeding pairs. All parameters were otherwise broadly the same between the two projects.
In 2000 the DETR Raptor Working Group Report was published and made a series of important recommendations for improving the conservation prospects for birds of prey. It was originally commissioned by the UK Government to look at “the raptor problem” in relation to grouse and pheasant shooting, as well as for racing pigeon breeders. How we have now come full circle, and rather than the licensed control of raptors, we now see licensed grouse shooting! Many of the recommendations of the DETR Working Group Report have now been implemented, and as a whole the populations of our raptor species have subsequently improved. However, the big exception has been on land managed for intensive grouse shooting, where there is good evidence to suggest that land management practices intended to produce very large grouse bags for clients to shoot have intensified since the late 1990s. These practices have pushed native raptors, especially the Hen Harrier, to the edge of extinction. In most recent years there have been less than 10 breeding pairs of Hen Harriers on Scottish grouse moors, despite very large areas of suitable habitat. The intensive land management practices on grouse moors have involved more rotational burning; more predator control; and the widespread use of medicated grit to prevent grouse diseases. Most recently not only has the illegal killing of birds of prey come to the fore, however also the impacts of intensive grouse moor management on peatlands – our vital carbon stores – important for helping Scotland to meet its Net Zero targets. In this context the Scottish Government has initiated a significant peatland restoration programme and with a large supporting budget administered through the Peatland Action Fund.
In 2017 the Scottish Government-commissioned report on the fate of satellite tagged golden eagles was published. This showed that a third of 131 satellite tagged golden eagles marked between 2004-16 had either been illegally killed or disappeared in suspicious circumstances. The publication of this report prompted the then Environment Minister Roseanna Cunningham MSP to commission the independent Grouse Moor Management Group chaired by Professor Alan Werritty. This report was finally published in 2019 and it recommended licensing of grouse shooting, and that all muirburn should be regulated, amongst other measures. Meanwhile the raptor persecution incidents on grouse moors continued unabated and as ever these crimes were hard to bring to justice.
The Wildlife Management and Muirburn Bill builds on the recommendations of the “Werritty Review”, and was introduced to the Scottish Parliament on the 21st March 2023, and now one year to the day on 21st March 2024, it has been approved with a substantial majority and with cross-party political support. In my view, it will change large parts of our upland landscapes for the better and certainly enhance the populations of our key moorland breeding raptor species.
The WMM Bill introduces the following legal requirements;
All grouse shooting will be licensed. The facility will be in place for NatureScot to remove the licence to shoot grouse if Police Scotland and NatureScot confirm wildlife crimes have taken place on a landholding. Licensing is based on a civil rather than criminal burden of proof. We believe that this process will provide a meaningful deterrent to wildlife crime.
The legislation that must be complied with includes the Wildlife and Countryside Act 1981, Badgers Act 1992 and Animal Health and Welfare (Scotland) Act 2006.
Two new statutory Codes of Practice will be produced to cover Grouse Moor Management and Muirburn.
There will be a requirement to monitor and report on the status of key moorland breeding birds of prey (Golden Eagle, Hen Harrier, Peregrine and Merlin) every 5 years to assess progress with improving their populations, and to update the Scottish Parliament. The whole Bill will be reviewed in 5 years with an opportunity to make further progress on peatland conservation in particular.
All muirburn in Scotland will be licensed and measures put in place to protect peatlands. Anybody who wishes to practice muirburn will need to be trained. Burning plans will need to be approved by NatureScot. The muirburn Spring season will end on 31st March (rather than the 15 April as now) to protect ground nesting birds.
All trap operators will need to be licensed, traps will need to be identifiable to the operator, and some inhumane traps such as snares and glue traps will be banned.
Enhanced powers will be given to Scottish SPCA to investigate and report wildlife crime cases working alongside Police Scotland.
The grouse moor licence will come into force on 12 August 2024 and the start of the grouse shooting season and the muirburn provisions will likely come into force from mid-September 2025.
In the late 1990s Scotland’s first First Minister Donald Dewar MSP described the scourge of illegal raptor persecution as a “national disgrace”. It has taken us some while to improve the legislation affording protection to Scotland’s moorland raptors, many of which have faced relentless persecution for decades – and even since all raptors were afforded full legal protection in 1954. This game-changing legislation will bring many important aspects of grouse moor management into the 21st century and allow for much greater public scrutiny. This substantial progress builds on the work of many organisations and individuals who have wanted to see a better future for large parts of upland landscapes and for our iconic raptor species. I highlight in particular the often difficult work of the Scottish Raptor Study Group and RSPB Scotland Investigations team. I pay tribute here to the massive collective efforts of all involved, and welcome the steps taken now by Scottish Government through the WMM Bill to address these concerns.
Moving towards a more circular economy is important and urgent. Globally, about 90% of biodiversity loss can be attributed to resource extraction and processing and, in Scotland, about 80% of our carbon footprint is from emissions embedded in goods we use and consume.
A transition to a more circular economy, where we use products and materials again and again and prevent waste leaking into the environment, needs to replace our linear economy, one of using products for a short time before discarding them.
The Scottish Government’s Circular Economy Bill is going through parliament, with the parliamentary committee report and Minister’s response now available. The Government also recently published its draft Circular Economy and Waste Route Map which describes all the activities (some of which need legislation and are in the Bill) the Government plans to undertake up to 2030.
The Route Map is divided into four ‘strategic aims’:
It is timely to focus on strengthening the circular economy. In Scotland we have many fantastic examples of businesses, social enterprises and innovative partnerships demonstrating how to deliver goods and services that reduce our consumption of raw materials and waste, for example tool libraries, repair cafes, the Remanufacturing Institute, Circular Glasgow . But arguably what has been missing has been the mechanisms and drive to bring the mainstream along – we need all businesses and organisations to be thinking about minimising their environmental and social impacts from materials in all aspects of their operations.
The Route Map proposes a number of actions to strengthen the circular economy.
Priority actions:
To develop a circular economy strategy every 5 years. Note – a statutory duty to do this is included in the Circular Economy Bill. LINK members welcome this as it is needed to guide a strategic approach to transitioning to a more circular economy and lay out how the new targets (see below) will be met. LINK members would like to see stronger commitments to some aspects of the Strategy such as how it links to the targets and the reporting requirements – you can read the detail in our evidence to the Net Zero, Energy and Transport committee.
To set new circular economy targets. Note – the powers to set such targets in legislation is included in the Circular Economy Bill. The current targets all relate to waste and recycling, are not in legislation and were set in 2016. We need new targets in legislation which will drive a reduction in our consumption of raw materials and, in particular, those materials that contribute most to our carbon footprint and impact on biodiversity. The Route Map indicates that Scottish Government is considering targets on reducing the use of materials, increasing reuse, increasing recycling and material specific targets. We welcome these, and would also like to see a carbon footprint target which would drive a reduction in carbon intensive materials and goods – those the production of which results in the biggest emissions. These emissions often occur overseas and so are not included in Scotland’s existing climate targets.
There are four ‘other actions’ which cover data, research, procurement and green skills. All are fundamental to strengthening the circular economy and, although LINK members would agree with the Government’s prioritisation, we would not see any of these other actions as optional. With out timely and relevant data, we can’t evidence policy design or monitor progress.
The background research on, amongst other things, behaviour change and fiscal incentives, is really important to inform the development of policy. Education and skills are also fundamental –Scotland’s children and young people need to learn about the importance of, and opportunities associated with, a different way of using our scarce materials; we need to redress the loss of repair skills in our society, and our future more circular economy needs scientists and innovators who take a different lens to their thinking.
Last, but not least, procurement and I will say a little more about this. Public procurement amounts to £14.5 billion of spending a year on goods, services and works. How this money is spent has a huge impact both directly through what is purchased, but also indirectly by stimulating market development and innovation.
LINK members would like Scottish Government to be more definite about changing public procurement procedures such that procurement departments have to demonstrate a move towards more circular suppliers. In fact, LINK members would like to see conditions put on all public bodies and the use of any public money such that government grants, subsidies, loans or other funding must further the transition towards a circular economy.
LINK members welcome the long overdue commitment to explore how legislation brought in 15 years ago (!) could be used to require public authorities to purchase certain goods with a given level of recycled content and/ or to be recyclable. It is time for the public sector to really lead from the front if the Government is serious about the circular economy.
Together these measures undoubtedly have the potential to strengthen Scotland’s circular economy. However, a number of measures are exploratory in nature, and so the follow up action is crucial as are the resources and budget needed for its delivery. This is why the statutory targets and strategy are so important – committing the Government to setting a direction and framework for action into the future.
Later this week, the Scottish Parliament will hold the Stage 1 debate of the Circular Economy Bill. Next week LINK will publish a blog focussing on the Bill – summing up Stage 1 and looking ahead to Stage 2.
By Phoebe Cochrane, Scottish Environment LINK’s Sustainable Economics Officer
Getting recycling right is an element of a more circular economy . Globally, about 90% of biodiversity loss can be attributed to resource extraction and processing and, in Scotland, about 80% of our carbon footprint is from emissions embedded in goods we use and consume.
A transition to a more circular economy, where we use products and materials again and again and prevent waste leaking into the environment, needs to replace our linear economy, one of using products for a short time before discarding them.
This is the second of three blogs which will discuss different sections of the Route Map and how they could be strengthened.
The Route Map is divided into four ‘strategic aims’:
Reduce and reuse
Modernise recycling
Decarbonise disposal
Strengthen the circular economy
Last week we published a blog on Reduce and Reuse. This blog will discuss some of the proposals in the Modernise recycling section.
The Route Map contains a number of actions to improve both household and commercial recycling.
There isn’t much data on commercial recycling. SEPA estimates that the commercial and industrial recycling rates are currently 53%, and waste has steadily reduced with a 21.6% decrease between 2011 and 2021. Actions proposed in the Route Map will gather additional information, reviewing compliance and undertaking a compositional study. Other actions include to co-design measures to improve commercial waste services, and to investigate the promotion of business to business reuse platforms. A firmer commitment to this last action would be welcome.
More data is available on household waste. Having more than doubled between 2004 and 2011, progress in household recycling rates has been less than impressive in recent years, remaining around 45% and standing at 43% in 2022. There is a huge variation in the rates achieved by different local authorities, varying from 21% to 58%. Analysis of residual waste, shows that over 50% of what householders throw away could be recycled and, at the same time, that recycling is often contaminated with products that aren’t recyclable.
Reduction and better management of household waste is also important for reducing carbon emissions. Analysis shows that household waste makes up approximately 21% of Scotland’s waste by weight, but 55% of the total waste carbon emissions, meaning we are throwing away carbon intensive products and materials, such as food, textiles and plastics. It is doubly important that such materials are, where possible, diverted from the waste stream and reused or recycled.
There is clearly a need to improve household recycling rates. This needs three components:
1. Recycling facilities that are clearly labelled and accessible to everyone. Actions in this Route Map should lead to accessible, clearly labelled and consistent recycling facilities and services and we would urge the Scottish Government to move ahead with the Codesign process for high quality, high performing household recycling and reuse services and then bring in the Statutory code of practice for household waste services as soon as possible and look at how Wales became one of the leaders in recycling.
2. Better labelling on packaging and products so people know whether it is suitable for their local recycling facilities. Too often it isn’t clear whether something is suitable for the people’s local recycling collection. The new extended producer responsibility scheme for packaging, being brought in across the UK from October 2025, will require much clearer labelling and incentivise recyclable packaging.
3. We also need a new public awareness campaign and to be more joined up.There needs to be a new and imaginative approach to communication so people know what they should do with their no-longer-required products and packaging. People generally want to do the right thing, they don’t like waste. People also need to see Government and local authorities leading the way. Too often it feels like recycling is only the premise of the local authorities’ waste management services; whereas a focus on the use, reuse and recycling of materials needs to be embedded across all departments, from education to leisure to planning.
I would like to make two additional points.
First, reuse and recycling have often been clumped together – for example the ‘recycling rates’ referred to are actually ‘reuse and recycling rates’ and yet the emphasis and investment in facilities and services has largely been on recycling. This needs to change – we know that it is preferable to reuse where possible, both for the environment and, if involving repair, creating more employment. The route map actions do include reuse (although generally coming after recycling in terms of delivery timescales), suggesting that this is being rectified, but we need to ensure that reuse services get the attention they require.
Another thing to keep an eye on is the total amount of waste, as well as the recycling (and reuse) rates. The total household waste (which includes the portion that goes for recycling) has slightly risen since 2017. This should be a cause for concern and bringing this down is important, as well as increasing the proportion of it that is diverted into reuse or recycling. We must always remember that ‘reduce’ is at the top of the waste hierarchy.
By Phoebe Cochrane, Scottish Environment LINK’s Sustainable Economics Officer
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