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
On 6 March, LINK held a Holyrood Parliamentary Reception, bringing people together around the Farm for Scotland’s Future campaign.
We started with two short videos from two very different farmers, both working with nature to the benefit of their businesses. First Johnnie Balfour, who farms in Fife, talks about doing more for nature and climate by working with nature, by, for example, reducing his inputs.
Then Padruig Morrison, in the Outer Hebrides, who is changing the way he is using the croft to manage for biodiversity and climate. He suggests how more crofters can be supported to use their land for food production and biodiversity and climate.
They both highlight problems with the current system of farm funding. You’ll see, just in the background, how different their farming environments are. Clearly they both need flexibility to do things at a time of year that suits their local area, but they also both talk about the size of farm units and how having a system that rewards farmers and crofters for results (or outcomes) will achieve more for nature and carbon.
These two short clips demonstrate the need for change in our current system of farm support in Scotland. Here we have a farmer and a crofter who are producing food but who also want to deliver for nature and climate. And it makes complete sense for them to do so.
If we care about food producers, and if we care about food security, then we need to care about our environment. We all rely on farming, and farming relies on nature. The food we grow depends on healthy soils; our crops need pollinators; and our farmers need a stable climate and resilience to extreme weather. Anybody who presents producing food and protecting our environment as competing aims is being extraordinarily short sighted.
LINK’s Chief Officer Deborah Long at the Farm for Scotland’s Future reception
But we do need to change how we farm in order to be more sustainable. As well as producing food, farmers and crofters manage three-quarters of Scotland’s land. However, many current agricultural practices cause pollution, severely harm our wildlife, and make the sector Scotland’s second-largest source of climate emissions. At the same time, Scotland spends more than £650 million a year supporting farmers. The opportunity in front of us right now is to use that money to support farmers and crofters to move towards nature-friendly and climate-friendly food production.
We deliberately started with those two clips to show that this approach is not just feasible, it is vital. The Farm for Scotland’s Future campaign is working with more than 40 organisations and farming groups who all want to see change so that farmers are able to build and maintain viable businesses in the future: ones that are resilient to climate change, ones that help put back species and habitats so our ecosystems are more resilient to ongoing change and ones that produce healthy food and products, that support rural communities and will form viable business legacies for future generations.
The campaign is looking at how agriculture support is distributed today, what it ‘buys’ today and what it could ’buy’ in the future. It is looking at what opportunities the current Agriculture and Rural Communities (Scotland) Bill is opening up for us, whether we are farmers or rural businesses, or members of Scottish society. We are all working together to call for a better farming support system that supports nature restoration and tackles climate change while supporting all farmers and crofters in the transition to sustainable agriculture.
You can find out more about the intricacies of the advocacy work we are doing in partnership with farmers and crofters to make the most of this opportunity we have in the Agriculture Bill here.
Meanwhile, in another short video, Vicki Swales, from RSPB Scotland, talks about the importance of nature in farming and the benefits it brings. And what the Scottish Government and we, as consumers, can do to support farmers to take action for nature and climate.
The Farm for Scotland’s Future campaign has 3 simple asks:
Replace the decades-old farm funding system with one that works for nature, climate and people.
Ensure at least three quarters of public spending on farming supports methods that restore nature and tackle climate change.
Support all farmers and crofters in the transition to sustainable farming.
Guests at the Farm for Scotland’s Future reception
For the current financial year 2023-24, only about five percent of the Scottish government’s £650 million farm support budget is being spent on dedicated support for farmers to deliver targeted environmental benefits like restoring habitats for priority species, improving water quality and mitigating climate change. In contrast, for the current financial year more than two thirds of the farming spend is being paid to farmers as ‘direct payments’ based on how much and what type of land they farm, with very few environmental conditions attached. These payments disproportionately benefit the largest landowners and do very little to support sustainable farming.
Is there a better way of doing this? Of course there is. By replacing the current old system, a new system could and should pay farmers, crofters and land managers to farm in ways that are sustainable.
In February, the First Minister has announced that, after the passage of the Agriculture Bill, at least 70% of funding will be paid across the bottom two tiers of the new system – effectively continuing the current approach where most money is spent on direct payments. In effect this means the new system is likely to direct only a little more of the farming budget to helping restore nature and tackle climate change – a small step forward, but not nearly far enough.
A business as usual approach will not put farming on the path to sustainability. It will leave those farmers and crofters who are working in ways that help nature and the climate without enough support, and it risks leaving our farming sector out of step with the growing consumer demand for environmentally friendly food.
As we heard from Padruig, smaller Scottish farms and crofts often support more biodiversity and rely less on chemical inputs than larger farms, yet they lose out under the current funding system. We’re calling for a higher rate of base level direct payments for the first hectares a farmer or crofter claims, making the system fairer and supporting nature-friendly methods.
We’re also calling on the government to set itself ambitious targets for increasing organic farming and helping farmers reduce the use of pesticides and synthetic fertilisers.
It’s important we keep talking about all this. With the rise in misinformation and the framing of environmental issues as elitist or exaggerated, the more we talk to colleagues, friends, neighbours about what is actually happening with nature, what is really happening with carbon and climate, the better. The possible futures in front of us that models are describing should both scare and re invigorate us. Now is the time to take on the false binary approaches of some on social media, illustrate what is happening but also what solutions of hope look like. Remember crofters like Padruig and farmers like Johnnie who are doing what they can but clearly want to do more and want to inspire others to accompany them on the journey. These are just two voices – there are many more out there. Just as there are many more people in Scotland, and the rest of the world, who want to see change. Sometimes we just don’t hear their voices loudly enough.
We can none of us do this alone. It is only through mature and far sighted conversations, embedded in mutually beneficial partnerships that we will see the swing towards the resilient and enjoyable future that we all need and that future generations, quite rightly, expect to have.
A more circular economy is really important. 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 first 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
This blog focusses on Reduce and Reuse and will comment on a few of the proposals included in the Route Map. These proposals arguably have the biggest impact, being at the top of the waste hierarchy. They are presented under three objectives:
Drive responsible consumption, production and re-use
Reduce food waste
Embed circular construction practices.
Drive responsible consumption, production and re-use.
At this point, my heart sinks. Not because Product Stewardship isn’t a suitable priority; but because it has been on the Government’s to do list since 2016, when Making Things Last included a laudable intention to “explore the concept of a single framework for producer responsibility, bringing together common elements into one flexible and transparent system, making it simpler for businesses who are involved in more than one product type and making it easier to add new products and materials to the producer responsibility regime in the future.”
This lack of progress reinforces the need for product stewardship measures in the Circular Economy Bill. LINK members propose that, building on existing examples of good practice, take-back obligations should be introduced. This would require retailers to take back products at the end of their life, acting as an incentive to design products that retain value. This can be phased in, with priority mainly based on the environmental impact of the product group. Take-back should also be a standard requirement in public procurement contracts.
Other actions under this objective in the Route Map include placing a charge on disposable cups and prioritising other problematic products to which to apply environmental charges. Here, my main concern is that the charge alone will have little impact on reducing consumption of single use cups. Parallel measures are needed. First, Scottish Government should ban all single use cups (and other single use crockery/cutlery) from closed settings, such as sit-in cafes, conference centres, work places, festivals. Second, a system is needed whereby people can borrow a reusable cup and then return it, often called ‘cup deposit schemes’. Such schemes are widespread in Germany and there have been trials in Scotland. They ideally operate over a large area, so that cups can be picked up from and returned to different locations – this can be achieved through a single scheme or neighbouring schemes working together.
Reduce food waste
There is a clear justification for tackling food waste with a number of reports highlighting it as key to addressing biodiversity loss and carbon emissions. The Route Map acknowledges that efforts to reduce food waste to date have been ineffective and suggests two priority measures. First, to deliver an intervention plan to guide long-term work on household food waste reduction behaviour change (by 2025). Second to develop with stakeholders the most effective way to implement mandatory reporting for food waste and surplus by businesses (by 2025/26).
Regarding the first, we need more than a plan, so this action must be clarified to make clear:
That it is to design (by 2025) and deliver (on an ongoing basis) a long-term intervention plan.
That this plan covers all mechanisms to support a reduction in household food waste, including behaviour change.
I would advocate for the second priority to be to strengthen data and evidence beyond business reporting, as this is needed to support the first priority. LINK members have proposed an addition to the Circular Economy Bill, mandating the reporting of volume of food loss and waste generated in Scotland, disaggregated by sector (primary production, manufacturing, retail, catering and in home); by type of waste, and by destination. It is hard to see how the thorny issue of food waste can be effectively tackled without such data.
Embed circular construction practices
Construction and demolition creates a huge tonnage of waste materials that could be better used. Commenting on this section is outside LINK’s expertise. However, even a cursory read of supporting papers throws up questions. The priority action in the Route Map is to support the development of regional Scottish hubs and networks for the reuse of construction materials and assets (from 2025).
However, in the report on improving the reuse of construction materials, published as a background paper to the Route Map; the main conclusion is ‘Acknowledging business and fiscal drivers, evidence presented in this report suggests that until legislative change is implemented to support circular practises as financially preferable, sectoral change may not escalate at the desired rate to meet reduced consumption by 2025 and beyond.’
The report (based on workshops for industry representatives) makes several specific recommendations for legislative changes and I would question why these are not included in the Circular Economy Bill? To consider such measures is included as another activity in the Route Map, but is more consideration what’s needed? We don’t have years and years to consider such options.
Conclusion
In general, the Reduce and Reuse section in the Route Map needs to be tighter and stronger and reflect more urgency. Specific actions are needed, linked to specific ‘reduce and reuse’ outcomes which will have a demonstrable impact on reducing material consumption and tackling materials that are particularly harmful to the environment.
Next week, LINK will publish a blog that looks at the Route Map sections on modernising recycling and decarbonising disposal.
By Phoebe Cochrane, Scottish Environment LINK’s Sustainable Economics Officer
We are delighted to welcome Countryside Jobs Service on board as as LINK supporter. To introduce themselves, here’s a blog from CJS Editor Kerryn Humphreys…
CJS – what’s that then?
Crazy Jumping Snails? Complete Juniper Solutions? In reality nothing quite so exotic; CJS stands for Countryside Jobs Service, which as a happy reader once memorably said “does what it says on the tin” – remember that wood preservative advert?
Countryside Jobs Service is the original countryside specialist, publishing countryside, conservation and wildlife sector information: jobs, volunteers, news and training. CJS is an ethical business working in harmony with environmental professionals to conserve the British countryside and natural world. Motivated by conservation success not profits. Although primarily known for our job service, CJS is much more than a recruitment site, we also publish a wide range of environmental, ecology and nature related content.
From small beginnings
In July 1994 small envelopes started landing on the doormats of countryside rangers, inside were a couple of sheets of closely typed A4 containing details of vacancies in the countryside management sector. Today, CJS has three newsletters which are all digital, no more stuffing envelopes late into the night on a Saturday; and, like many places, the pandemic brought a change in working practices with the CJS Team working from home on flexible hours, but that hasn’t affected our level of service and we’re delighted that CJS continues to grow.
More than just jobs
As well as the original jobs provision there’s now a full information service as an integral part of CJS. We are publishing several features each week looking at things countryside careers and land management related, including promoting the Rambling Ranger podcast from SCRA. The range of features is very wide from looking at how volunteering can support and enhance the wellbeing and resilience in landscapes, communities and people by Loch Lomond and the Trossachs Countryside Trust to an in depth look at the work being done to save one of our most iconic native animals the Scottish Wildcat, from Saving Wildcats. Articles come from a variety of sources, from a single farm, Spring Farm Alpacas who wrote about the use of alpaca as novel conservation grazers, to the large: we had an exclusive interview with RSPB Chief Executive Officer Beccy Speight for International Women’s Day, charting her progress from childhood caterpillar collecting to heading up one of the largest UK conservation charities.
Nationwide Coverage
Although based in North Yorkshire CJS covers the whole of the UK, working with all the main agencies and charities and many of the smaller ones too. Since the first edition CJS has supported and been endorsed by the Scottish Countryside Rangers Association and is the official job service for SCRA (and CMA south of the border too). 17% of all adverts published online in 2023 were based in Scotland.
Reasons to be proud
CJS is run along Social Enterprise principals and we’re proud that nearly 30 years on from that first edition we hold true to the principles of putting back as much into conserving the countryside as possible. We still offer Standard Free Linage in CJS Weekly: it’s possible to advertise virtually anything (anything relevant to the countryside that is) free of charge with CJS. 89% of all the work completed in 2023 was done so completely free. Many people wrote lovely things about CJS for our Silver Anniversary in 2019 including this from Peter Gilbert, Volunteer Development Officer at Scottish Wildlife Trust: “Back in the mid 1990’s there weren’t many options for environmental job seekers other than looking at individual newspapers and contacting individual organisations. CJS made the process a whole lot easier by collating these jobs and putting them in one place. Organisations then realised that CJS was the best place to advertise their jobs because it was the publication for environmental job seekers. Although there are now many more competitors, CJS is the original countryside jobs service. “
Scotland’s seas are renowned for their rich biodiversity. From fish to birds, marine mammals to invertebrates, they are home to thousands of fantastic species of plants and animals. They are loved by communities, are a key component of Scotland’s cultural heritage and identity, as well as a vital resource for those who rely on marine industries like fishing and wildlife tourism.
But scientific evidence makes it clear that Scotland’s marine environment has been in decline for some time. Most of our seabed is in poor condition, with some vital habitats, like seagrass and flame shell beds, covering just a tiny fraction of their former areas. Seabird species are also in steep decline. The overall abundance of 11 seabird species in Scotland went down by a significant average of 49% since 1986, putting Scotland’s seabird health now below the rest of the UK.
We all want our seas to thrive and be resilient in the face of the intertwined climate and nature crises. The livelihood and wellbeing of coastal communities depends on a healthy marine environment. Preserving Scotland’s marine ecosystems, helping them recover, and safeguarding them for future generations is therefore a crucial task. Maintaining and enhancing Scotland’s marine environment is also an obligation under both our international commitments and domestic law.[1]
Image: Fanny Royanez
What are marine protected areas, and why do they matter?
Marine Protected Areas (MPAs) are designated zones within the ocean set aside for long-term conservation objectives. They come in various forms worldwide, each offering different levels of protection and management strategies.
Scientific evidence from across the globe shows that MPAs are a proven tool to halt and reverse the decline of biodiversity, such as Fish Replenishment Areas in Hawai’i, as well as fighting climate change, such as measures detailed in the Great Barrier Reef Blueprint for Climate Resilience and Adaptation. When thoughtfully planned with marine communities, and effectively managed, MPAs become essential in addressing our impact on the marine environment. They can help marine species and habitats to recover, and safeguard established ecosystems from further degradation.
MPAs are a long-term investment. They work to ensure that the species and habitats that make up our complex marine ecosystems are adequately protected, so that future generations can continue to benefit from what our seas provide us with – commercial fish and shellfish, renewable sources of energy, climate regulation, natural coastal defence, and enjoyment, recreation and increased wellbeing across society.
However, designating a site as an MPA does not automatically mean it is protected[2]. Those responsible for MPAs must assess what changes to human activities might be needed within the site to reduce pressure on vulnerable species and habitats and give them the best possible chance to thrive. This might mean some activities have to be restricted or reduced in certain areas, at certain times of the year, or, in the case of higher risk activities, on a permanent basis. The Great Barrier Reef Zoning Plan is considered a successful example of where there is a mixed management approach that supports multiple human uses of the area. The success of a MPA in achieving its conservation goals is highly dependent on the management measures implemented to protect the site.
Scotland’s marine protected areas: management measures are eight years overdue
Image: Ben Andrew
The Marine (Scotland) Act 2010 sets out a duty for Scottish Ministers to protect and enhance the marine environment. Both the Marine and Coastal Access Act (2009) and the Marine (Scotland) Act 2010 provide the Scottish government with the power and duty to create a network of MPAs.
In 2014, 30 nature conservation MPAs were created with the objective of helping protect nationally important species and habitats – Priority Marine Features (PMFs). Designating the sites was only the first step, as management measures to restrict certain marine activities including commercial fishing were to be delivered by 2016.
Fisheries restrictions were adopted in a handful of inshore MPAs (within 12 nautical miles of the coast) in 2016, but the deadline to implement restrictions across the whole network by 2016 was missed. The measures that have been introduced in the most vulnerable inshore sites prohibit damaging fishing methods in less than 1% of the historically fished inshore area[3]. A subsequent deadline of 2020 was also missed. A commitment from the Scottish government in the 2021 Bute House Agreement to complete the MPA network and deliver the long-awaited management measures by 2024 has also not been met, leaving our MPAs without real protection from the most damaging forms of fishing. Repeatedly missing these deadlines put at risk the Scottish Government’s ambition to halt biodiversity loss by 2030.
It’s important to note here that these measures are not related to the proposals for ‘Highly Protected Marine Areas’ (HPMAs) that were mooted by the Scottish government in 2021 and consulted on in 2023. The appropriate management of our MPA network has been on the table for 10 years and has been subject to extensive discussion with stakeholders and local communities. HPMAs, as consulted in 2023, will not be progressed by the Scottish Government (although areas of consensus amongst stakeholders were identified during the consultation which will be helpful for future developments.
The Scottish government’s own data has repeatedly underscored the urgent need to implement management measures for the most damaging forms of fishing. Most recently, its Scottish Marine Assessment 2020 identified fishing activities that sweep across large sections of the seabed (‘bottom-towed mobile’ fishing) and ‘pelagic fishing’ (which refers to the water area between the surface and seabed) as the key pressures facing marine biodiversity, alongside climate change. Yet these forms of fishing are allowed to continue in all but a few of our MPAs.
In short, despite covering 37% of Scotland’s seas, the majority of the MPA network continues to exist in name only without real protection implemented. While fisheries restrictions are delayed, our marine ecosystems, especially seabed habitats, will continue to decline.
Image: NatureScot
Restrictions tailored to species and habitats
NatureScot provided advice to the Scottish government in 2014 on what types of fishing activities would need to be removed or limited in each MPA in order for the relevant species and habitats to be properly protected. The measures would vary for each site and be tailored based on risk to adequately protect the marine wildlife the sites contain. Depending on the MPA, the measures would mean restricting certain types of fishing, but allowing others that have little or no impact on the species and habitats identified.
The Scottish government ran a series of consultations and workshops with marine users and industries to consult on and deliver the management measures. Its proposals were confined to protecting small areas of priority species and habitats that remained in good condition despite decades of industrial activity. Scottish Environment LINK called for a more holistic approach to these management proposals, taking into account how the priority species and habitats are connected as part of the ecosystem, rather than just considering them on their own.
Today, the Scottish MPA network is composed of 233 sites designated for nature conservation purposes. But 10 years after their creation, only a minority of sites have fisheries management measures in place.
This cannot go on. The Scottish government must end the delays and act now to take this crucial step in helping our seas recover.
More is needed to help our seas recover
Delivering an effective network of MPAs is the bare minimum if Scotland wants to halt and reverse the decline of our marine biodiversity. Without these tailored management measures, MPAs cannot reach their conservation objectives.
However, the Scottish government’s approach through MPAs is confined to protecting the small areas of our seas that remain in good condition. If we are to help our seas recover, implementing MPA management measures is only the first step.
MPAs must be part of a broader ecosystem-based approach to tackle the ocean emergency effectively. Urgent action across policy areas is needed to facilitate species and habitat recovery and ensure that marine ecosystems can function. This means implementing a more holistic approach to the management of fisheries, establishing a new national marine plan centred on ocean recovery, and addressing cumulative impacts on the marine environment.
It is urgent we ensure our marine ecosystems can provide the life-sustaining benefits that our marine industries and coastal communities rely on, for generations to come.
By Fanny Royanez, Marine Policy and Engagement Officer
[1] Scotland is obligated to maintain and enhance its marine environment under international commitments such as the Convention on Biological Diversity (CBD), OSPAR Northeast Atlantic strategy, and delivering on the UN Sustainable Development Goals. It is also a legal requirement under national legislation such as the UK Marine Strategy Regulations, the Marine (Scotland) Act 2010, and the Nature Conservation (Scotland) Act 2004.
[2] Langton, R., Stirling, D.A., Boulcott, P. and Wright, P.J., 2020. Are MPAs effective in removing fishing pressure from benthic species and habitats?. Biological Conservation, 247, p.108511.
[3]Langton, R., Stirling, D.A., Boulcott, P. and Wright, P.J., 2020. Are MPAs effective in removing fishing pressure from benthic species and habitats?. Biological Conservation, 247, p.108511
Every year LINK’s annual Congress for our members tackles a key and current issue for the network. This year, we invited Community Land Scotland (CLS) and Coastal Communities Network (CCN) along to help us discuss how we, as communities of interest, can work with communities of place, to achieve our shared visions of healthy ecosystems with vibrant communities across all of Scotland. Our idea was to look at the way we work, learn from some of our members and from our colleagues in CLS and CCN.
This has been an informative year and we’ve had to learn a few lessons. Although 55% of those who responded to the consultation on Highly Protected Marine Areas (HPMAs) were supportive, what happened during the consultation was pretty devastating. This is because the science tells us that the protection of species and habitats is the cornerstone of future healthy ecosystems. The public support this, showing in a recent poll that 80% of those asked would support Scotland’s Marine Protected Areas being fully or highly protected. The Scottish Government and Ministers were putting forward a mechanism to help Scotland work towards the Global Biodiversity Framework target of 30% effective conservation areas at sea, and the Bute House Agreement included commitment to establish HPMAs in at least 10% of Scotland’s seas. But the consultation took us back to the drawing board.
Why did this happen? A fundamental element to this was that without a communication plan, supported by case studies of success, negative, frightening and false stories began to dominate. Another important element is that we are all suffering consultation overload, Government included, and as a result consultations are often rushed and not sufficiently thought through. A capacity crunch is affecting us all: Scottish Government, eNGOs and local communities. Witnessing this is what led us to our Congress theme: with the nature and climate emergencies, we cannot afford to let this happen again. We realised we need to revisit how we communicate hope, positive action and benefits for future generations.
In addressing the nature and climate crisis, there are a number of outcomes we urgently need to progress: effective measures at sea to protect and restore our remaining biodiversity, effective protection on land and halting perverse subsidies and actions that take us backwards on land and at sea. We need instead agricultural subsidies and forestry grant schemes that deliver for nature and climate and not against them, land reform, upland management and licensing that protects vulnerable upland ecosystems and increases their resilience to ongoing change.
But to reach these outcomes, we need a new approach that involves everyone to build irresistible change. We need to work with and support our own members who are already effectively engaging at local levels and we need to work with other networks, who are the communities on the ground and with whom we can pool resources in order to reach mutual goals on climate and nature action. Learning from those successes and finding new collaborations and activities will help us create a much bigger and more engaged public space where politicians and policy makers have no option but to listen to the science, the experts, the communities and young people who all want to see change.
Using the experience of 3 member bodies: John Muir Trust, Scottish Wildlife Trust and the Common Ground Forum initiative, which is supported by a number of LINK members, we heard examples of successful ways of engaging with local communities. The lessons they learnt and the successes they shared are all now forming part of our next steps.
There are some processes we can engage in together: What are called ‘place based’ responses: how can we help our communities see ourselves in the changes we need to see? And a Just Transition: how can we help build a socially just move to the necessary environmental transition?
In terms of how we do that, we came up with a few actions for us all to consider and deliver:
Public support for cross and inter networks’ priorities and projects
Building joint projects together
A whole of Scotland approach: there is a false narrative of urban vs rural emerging. We are in a strong position to prove that wrong with our network reach right across Scotland
Adopting the concept of Duthchas, where natural, cultural and community regeneration exist side by side.
There are some challenges in trying to do this. Environmental and social regeneration is suffering a lack of housing and inadequate transport. In tackling the climate and nature crisis, we have to tackle these too, which means we need to support those working in these areas. We need to meet the expectations of communities when communities of all sorts step up the challenge. We need to work out how to support them too at a time when public resources are extremely tight. There are also going to be more difficult conversations needed and in order to do that constructively we need to equip our staff so they are able to cope with stressful situations and difficult behaviours. And finally we need to recognise that in our communities, democratic decision making, which is the basis of all our work, will create tensions that we need to recognise and resolve.
LINK’s role in all this starts with our public positions on key issues around land and sea management, land reform and natural finance for example and around sharing and adopting best practice. We will be developing some joint projects including piloting and demonstrating the art of the possible in change at scale on land and on the coast. We are looking to build on the success of the Common Ground Forum to bring a new approach within our communities on the coast. We will manage our own priorities to ensure we have sufficient capacity and resource to take on this work and we will look at how we can lead the conversations around change at scale that benefits us all, wherever we live and whatever we do.
Communities togetherin action.
By Deborah Long, Chief Officer, Scottish Environment LINK
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