By Malachy Clarke, Public Affairs Manager for Friends of the Earth Scotland and a member of LINK’s Planning Group.
Transport is Scotland’s biggest source of climate emission, accounting for over one-third of all emissions. It will be impossible for the Scottish Government to meet their proposed 75% reduction in emissions by 2030 without taking radical action to change our transport system. Encouraging walking, wheeling and cycling through an integrated transport system that encourages public transport and doesn’t give priority to cars will be key to achieving this goal.
The Scottish Government is beginning to accept this and has made some welcome changes, such as expanding free bus travel to under-22s. However, they have not gone far enough. Public transport should be free to all at the point of use, segregated cycle lanes are a necessity for ensuring people feel safe enough to use the roads. The Scottish Government must commit to increasing active travel infrastructure and bold ideas to reinvent our transport system and move people out of private cars and into public and active transport.
Already it has committed to reducing car km usage by 20% by 2030.This is a truly bold and ambitious target and one that Friends of the Earth Scotland welcomes. To meet these goals the Scottish Government will need to reverse a trend of increasing car usage that has gone on for almost 50 years. This will require radical change across our entire transport network.
The routemap for achieving 20% reduction makes it clear that new fourth National Planning Framework needs to play a big role in these changes. NPF4needs to reduce car journeys and make it easier to use sustainable transport. However, neither the plan for reducing car km, nor the current draft of NPF4, are clear on what actual tangible changes will be made to our planning system to achieve this.
There is a huge responsibility on this document but there are no significant details on how the Scottish Government or the NPF4 will meet these needs.
There are a number of measures that could be included to reduce car km usage and increase public transport. Such as:
Help councils bring buses back into public ownership
Requirements on density within urban areas
A robust ban on out-of-town retail parks and any developments that are entirely car dependent (for example, the drive-thru coffee shops we’re seeing pop up across Scotland have to become a thing of the past.)
A halt on new road building
Increased bus infrastructure
Redress the cost imbalance. Public transport costs have consistently risen across Scotland while the cost of motoring has dropped.
The Scottish Government could also make commitments on ending the construction of new trunk roads and diverting the funding into improving walking and cycling and helping councils start new publicly-owned public transport operators as a means of meeting their 20% car km reduction goals.
The Scottish Government is proud of their commitment to ’20 minute neighbourhoods’. However our politicians have yet to grapple with the reality of this commitment. Many communities have lost their only bank branch, and some areas of deprivation don’t even have an ATM. How can we help people use only local services, which they can walk or cycle to, when private companies have abandoned so many communities? The Scottish Government must take a holistic approach to supporting communities across Scotland by supporting high streets, community centres and local clubs to ensure local neighbourhoods are robust and thriving.
The Scottish Government can use the NPF4 to take radical action to tackle climate change and make our neighbourhoods safer, cleaner and more livable. Unfortunately the current draft of the NPF4 fails to do so in any meaningful way.
This blog was written by Malachy Clarke, Public Affairs Manager for Friends of the Earth Scotland and a member of LINK’s Planning Group.
The events in Ukraine are shocking and the ongoing acts of aggression against Ukraine and its people are truly terrible. The daily news images are clearly tragic. We all stand in solidarity and support for the people of Ukraine.
The impact on global food production is another pressure on our planet, heaped upon the existential impacts of climate change and nature loss. Those crises have not gone away. Scottish Environment LINK Food and Farming group members are deeply disappointed to see farming unions both in Scotland, and the UK, arguing for the lowering of environmental standards using the dubious pretext of food security.
These calls for the temporary suspension of greening rules, specifically around Ecological Focus Areas, so that more land can be made available for crop production are extremely troubling for three reasons:
Cutting into the tiny amounts of land currently put aside for nature will not make any difference to the level of food production possible in Scotland
Very little grain in Scotland goes directly into human food chains: most is used as animal feed or in the whisky industry. Wholescale change into different food crops would be required, not merely taking more land into current production.
There is so little land put aside and managed for nature that continuing to chip away at the little that remains, puts Scotland even further back in its long journey towards halting the loss of nature.
eNGOs across Europe are united in calling out this appropriation of land from green measures into production and what would amount to a rolling back on sustainable food policy objectives within the EU Farm to Fork and Biodiversity strategies. We stand with our colleagues in Birdlife International and their open letter, available here.
The arguments are flawed. Firstly, we know that almost 80% of our cereal harvest in Scotland is used for alcohol production or animal feed. Around two-thirds of the EU cereal harvest is used for animal feed or biofuel. Feeding grain to animals (even the most efficient ones) means converting 3 or 4 units of human edible calories or protein to 1 unit. We can ‘afford’ to do this because there is no shortage of cereals.
Secondly, we know that tackling the climate and nature emergency is the only way to ensure long-term food security. The poor harvest in North America last year was caused by drought, while this was counterbalanced by good harvests in India and Australia. As the climate becomes more chaotic, the risk of multiple harvest failures in different parts of the world increases.
Finally, this is all based on the false premise that farming and nature are a zero-sum game. Scotland is committed to becoming a world leader in sustainable and regenerative agriculture. The way forward – for Scotland, for Europe, and globally is farming with nature.
This means rewarding practices that deliver environmental benefit at very little or no cost to production. This would include buffer strips next to water courses for water quality for example, where fiddly pieces of ground with a negative gross margin have a disproportionate value for nature.
“The EFAs create safe corridors and essential food sources for iconic birds like barn owls and kestrels.” Denise Walton, Peelham Farm
“Lots of the EFA options like undersowing and catch crops can actually increase food production in the long run as well as improving the soil. Field margins also provide a home for the bugs which eat the bugs which eat the crops, so also help with sustainable food production.” Pete Ritchie, Nourish Scotland
The real lesson of this crisis is that we must look at the resilience of our food and farming systems. More than ever, we must shift towards environmentally friendly farming practices, such as agroecology, organic farming, and agroforestry, which provide the only path to ensure long-term food security, food sovereignty, and the overall sustainability of food systems.
Simply growing more grain and doubling down on unsustainable practices is not the answer. We need to think about the use and costs of nitrogen-based fertilisers and focus instead on the ways in which we can fix nitrogen naturally, and how we can use grass and food waste rather than wheat for animal feed.
We should maintain and improve Ecological Focus Areas, not drop them. We should be adopting a strategic approach to land use, and the current atrocities in Ukraine should not be used as an excuse to undermine efforts to tackle the twin climate and nature emergencies.
We agree. Now is not the time to add to the planet’s food insecurity and damage to ecosystem services that support us all. Now is the time to invest in resilient ecosystems able to produce food, and all the other services we depend on, thus increasing our own security and that of the planet.
By Helen Todd, Campaign and Policy Officer for Ramblers Scotland
Imagine there’s a disused railway line running through fields near where you live. It lies parallel to a busy road and connects two villages. It’s used by locals walking their dogs, but it would also make a great off-road route for walkers, cyclists, and horse-riders. Or even people pushing buggies or in wheelchairs. There’s potential for it to extend even further to the nearby town. Then someone gets planning permission to build a new house partway along the line. The far end of the plot includes the railway line. Soon they’ve fenced the whole area as part of their garden, severing the link. Now you’ve lost the dream of a safe path for your kids to cycle to school. Or for a longer distance route that visitors and residents alike will enjoy. If only someone in the planning department at the local council had thought ahead! They could have inserted a planning condition to force new owners to keep a strip of land for public access.
This is one example of how the planning system can protect and secure access rights for public benefits. But it’s not only an issue in rural areas. Planners can demand the creation of routes within new greenfield or brownfield developments. They can ensure rough ground or woodland remain accessible, for the benefit of nature and people. By setting conditions or securing agreements with developers, they can ensure those with deepest pockets pay for the work.
Scotland’s National Planning Framework Four (NPF4) is currently out for consultation. This document will incorporate every element of Scottish Planning Policy (SPP). It will also set out proposals for national developments such as electricity transmission lines. The current SPP says that you must consider Scottish access rights, under the Land Reform (Scotland) Act 2003, when planning or developing land. This makes access rights a material consideration in planning. Yet this specific reference doesn’t appear in NPF4. Without this explicit mention, will public access lack protection in future?
Despite this reservation, there is much to welcome in NPF4. It has plans to help people get outdoors and be more active. Well maintained and accessible natural places support our everyday health and wellbeing. They contribute to good placemaking. It’s particularly important that access to green places is spread around all communities. There are some very positive policies in NPF4. Those include making sure that local authorities support active travel and improve parks and natural areas.
NPF4 aims to create “20-minute neighbourhoods”, where you can reach everything you need on foot, bike or wheelchair. This is a good ambition, especially in urban areas. It has the potential to cut car journeys – currently over half of all trips are under five miles. Having pleasant, safe green networks to walk the dog or get to shops, school or work will improve quality of life. It will also reduce congestion and pollution. There’s also a commitment to a national walking, wheeling and cycling network of long-distance paths. This builds upon existing work in NPF3. While there is a need for more pace and ambition for the network, this is good news.
It’ll be difficult to deliver on these policies unless we ensure access rights are protected and planned for. Without clear references to access rights, NPF4 could result in the loss of greenspace and public access. For example, it could prompt expensive tussles to regain routes after householders have already planted daffodils over them!
Scotland’s planning system aims to manage development in the long-term public interest. Being able to get outdoors into nature and get around your local community is fundamental. That’s why LINK wants policy 12 – on ‘blue and green infrastructure, play and sport’ – to be placed within the wider context of statutory access rights.
By Helen Todd, Campaign and Policy Officer for Ramblers Scotland
By Nikki Sinclair, Green Belts Alliance Manager , APRS | The Association for the Protection of Rural Scotland
Scotland’s Green Belts
A Green Belt is the designated open land around, beside or within an urban area where there is a presumption against most types of development. Green Belts are designated by local authorities in their Local Development Plans (LDPs) to: help protect countryside by containing urban sprawl; preserve and enhance the landscape settings of towns and cities; give urban residents access to open areas; and direct any necessary growth into more appropriate locations within settlements. Scotland has 11 Green Belts designated by 21 Local Authorities – maps of all the Green Belts can be found on the APRS website.
Scottish Planning Policy
The purposes of Green Belts and the limited types of development allowed on them are currently set out in Scottish Planning Policy, 2014 (SPP 2014). As they are viewed by some developers as restrictive and inflexible there have been calls for reviews of Green Belt policy in order to weakening the protection against development they offer. Since 2014, Scotland’s Green Belts have been reduced by both planned land releases during LDP reviews and by significant speculative developments, mostly for housing. Many of the latter have been permitted on appeal despite being contrary to the LDP, via a loophole in SPP 2014 that allows contributions to housing land supply to be given more weight in planning decisions than other aspects of sustainable development.
The Scottish Government tried to address this loophole in 2020 with amendments to SPP. However, these changes were overturned at the Court of Session in July 2021 in a case brought by two developers who argued the manner in which the consultation had been undertaken was unfair. Part of the Government’s motivation to amend SPP urgently was that the loophole applies when more than 5 years have elapsed since an LDP was adopted. Covid has exacerbated the usual delays with LDP reviews, and on top of this, many planning authorities held off reviewing their plans until NPF4 and the proposed new guidance for LDPs were in place – both of which have been delayed themselves.
It is possible that 14 of the 21 local authorities which have Green Belts will have ‘out-of-date’ LDPs by the end of 2022, although hopefully a few of these will adopt replacement plans before then. Unfortunately, the introduction of an NPF4 which removes the current loophole will not come soon enough for some areas of Green Belt and other unallocated Greenfield sites that developers have their eye on.
Benefits of Green Belts
Throughout the NPF4 consultation stages APRS has promoted strengthening the presumption against development on Green Belt land and the upholding of a plan-led system. APRS has been making the case that designating and limiting development on Green Belts has multiple benefits in terms of climate, biodiversity, and landscape. In addition, as became even clearer during the pandemic lockdowns, they offer access to nearby countryside which can improve quality of life and wellbeing for the large proportion of the Scottish population that live in urban areas.
Green Belts contain significant areas of prime agricultural land, and semi-natural woodland. Even if much Green Belt is not considered important enough to be protected for nature conservation alone, by remaining as open land or ‘green infrastructure’ it can allow greater connectivity between key sites. They can also reduce urban air pollution and alleviate flooding. Green Belts have potential, through appropriate management, to do even more to tackle the climate emergency and nature crisis and to provide opportunities for home-grown food, outdoor education, improved active travel and recreation for local communities.
In terms of climate and meeting net-zero, Green Belts help direct development to more appropriate and sustainable brownfield sites, including vacant and derelict land, and encourage the re-use of existing buildings. In the recommendations from Scotland’s Climate Assembly (2021) there was 95% support for the call to “Strengthen planning restrictions immediately so that development on greenfield sites should not be permitted until all other development options, such as brownfield and existing building repurposing, have been considered and legitimately rejected”. There was even more support for “Create thriving town centres by focusing on the conversion of existing properties into high quality housing and community spaces rather than building more edge of town developments”. These recommendations perhaps recognise that the loss of open land near urban centres is regrettable in itself but also that more urban fringe developments are unlikely to enable future residents to have sustainable lifestyles, making net-zero targets ever harder to reach.
The Draft NPF4
Specific policy on Green Belt is contained in the section of the draft NPF4 titled “Urban edges and the green belt”. The clear statements of the multiple benefits of Green Belts to the environment and quality of life which are set out in the two paragraphs of preamble and in policy 29 a) are welcomed. The rest of Policy 29 is also supported although APRS will be making some suggestions for improved wording and the inclusion of the term Green Belt in the glossary. We welcome the removal of the above mentioned loophole from national planning policy and hope Scottish Government resist any calls to insert replacements for it in either the final NPF4 or the delivery programme. This would undermine the framework where policies such as reinvigorating town centres, planning 20-minute neighbourhoods, brownfield first and protecting Green Belts all support each other.
The six Universal Policies must apply to all planning decisions and their wording must be clear enough to ensure appropriate weight is given to the climate and nature emergencies in both LDPs and decisions.
“Perhaps the most important aspect of today’s Green Belt is that a legacy of open land has been passed down to us from previous generations. They did not squander it for short-term gain: neither should we. It is a precious resource that should be used responsibly and passed on to future generations.” From: Repurposing the Green Belt in the 21st Century (2020), Peter Bishop, Alona Martinez Perez, Rob Roggema and Lesley Williams, UCL Press, London
Further information on Scotland’s Green Belts and on the APRS Green Belts Alliance – a network of interested local groups and individuals – is available on the APRS website.
Nikki Sinclair
APRS | The Association for the Protection of Rural Scotland
By Clare Symonds, Convener of Scottish Environment LINK’s planning group.
“A new approach to planning could protect Scotland’s wildlife for future generations,” says Clare Symonds.
When you think of the Scottish nature we all know and love, what comes to mind? You might picture misty glens, coastal cliffs lined with seabirds, or open parkland near to home. The wide outdoors feels happily far removed from the technical documents, offices and debating chambers where the plans that shape how Scotland’s land is used are drafted and decided upon.
However, these planning decisions – and the policies that shape them – are crucial in determining the extent to which Scotland’s wildlife and natural habitats are protected and restored. Our planning system has a huge influence on how much space we can make for nature in our towns, cities and rural areas. Its impact can be as small scale as requiring new building developments to include areas of greenspace through to more innovative approaches like installing green roofs which provide vital pockets of nature in built up areas. It can be large scale changes too such as designating new national parks or strengthening protection of greenbelts.
This spring, politicians will be debating and voting upon a new ten-year strategy for Scotland’s planning system: the fourth National Planning Framework. Scotland’s people have until the end of March to submit their views on this framework which will set in train the direction of Scottish planning for the next decade.
As this is the same decade in which scientists tell us we must make major changes to reduce our contribution to climate change and reverse the global biodiversity declines, this new planning framework must put in place transformational policies that will guide Scotland’s planners and developers to make low-carbon and nature-positive choices.
There are many ways this transformation could be brought about, and Scottish Environment LINK, the network for Scotland’s leading environmental organisations, has set out some key changes the government must include in the new planning framework to ensure our wildlife and habitats are protected. A top priority is to establish a Scottish Nature Network which would link up vital habitats, making it easier for wildlife move from place to place as well as linking up with green spaces in our neighbourhoods. This must be taken forward at a national level in Scotland, just as the UK government has promised to do in England, rather than locally as current proposals suggest.
It’s also important that the framework strengthens key measures that protect our natural spaces, from greenbelts encircling towns to Wild Land Areas in some of the most remote parts of the country. Enabling new developments that can benefit nature, such as the creation of new National Parks, would show that the Scottish government is truly taking the nature crisis as seriously as the climate emergency.
At present, the draft proposals from the Scottish government do not go far enough. Though the document contains many statements signaling that, for example, “we must rebalance our planning system so that climate change and nature recovery are the primary guiding principles for all our plans and decisions,” too many of the policies it sets out for nature and climate are optional, things that “should” be done.
If we want to avoid ploughing ahead with a ‘business-as-usual’ approach to planning, simply put, the ‘shoulds’ need to become ‘musts’.
________________
Clare Symonds is convener of Scottish Environment LINK’s planning group.
This article was first published in The Scotsman on March 1st 2022
The Big Tree (Scotland) Winner of Woodland Trust Tree of the Year Contest 2017 (Mark Ferguson)
Scotland faces both climate and nature emergencies. Woods and trees are a huge asset on each front so protecting them is key, especially our irreplaceable ancient woodlands. The planning system has an essential role to play in ensuring that protection, so we can be climate ready as a nation while protecting and enhancing biodiversity. Scotland’s new Draft National Planning Framework (Draft NPF4) presents landmark policy changes that could halt further loss of ancient woodland and trees. We must seize this moment and ensure these policy changes are retained in the final version to become planning reality.
What it means to be ancient
Very often when people think about what defines ancient woodland, they will be thinking about old trees and woodlands which have existed since the 1750s (as categorised by Scotland’s Ancient Woodland Inventory). But some of these patches could have been continually wooded for many hundreds or even thousands of years more. They are relics in the landscape quite often holding clues to our cultural past, remnants of woodland industries and historical management.
Ancient and veteran trees are no less impressive and awe-inspiring than our ancient woodlands. Scotland’s oldest specimen, the Fortingall yew, is believed to be roughly 3,000 years old. But to be ancient or veteran, trees needn’t reach such extremes, so long as they are old for their species. While size can be a sign of their age, if an individual has faced tough conditions, as they often do in Scotland, an ancient tree may not be that big at all. Instead, they can be recognised by their gnarly bark, hollowed-out trunks, cavities or reduced crowns and the organisms they are usually bursting full of.
Kinclaven, Autumn October 2018 (Niall Benvie / WTML)
The Woodland Trust recently published ‘The State of the UK’s Woods and Trees 2021’, presenting key facts and trends focusing mostly on natives, including those that are ancient. The report highlighted the importance of these habitats and organisms for a happy and healthy society and for nature and climate. It presented data showing average amount of carbon stored per hectare in Scotland’s ancient woodland are 31% higher than the average for all woodland types, and there is enormous potential for carbon stored in ancient woodland to double over the next 100 years.
Yet the report’s key findings note that despite woodland cover gradually increasing, existing native woodlands are isolated and in poor condition. The last remaining 30,000 ha of Scotland’s rainforest on the west coast is one such example that is threatened with further loss if action is not taken now. There is also a reported widespread loss of ‘trees outside of woods’ including individual ancient and veteran specimens, to make way for inappropriate developments. Scotland’s ancient woodland has been reduced to cover just 1-2% of the land. It continues to be eaten away by inappropriate development, poor management, Invasive Non-Native Species (INNS)and grazing animals, particularly deer.
Development, Planning and Trees
Development does not only lead to the loss of ancient woodland and veteran trees it directly displaces. In many cases it can also harm adjacent woods, which may be spared the bulldozer and the saw, but nonetheless suffer a slow decline in ecological condition over time. This effect of development is often overlooked. Declines in ecological condition happens over extended periods of time and this is perhaps why people find it hard to understand. It’s not an immediately quantifiable loss and due to the long-life cycles of trees it’s not at once visible. Our baselines shift, and we forget how these woodlands once looked and felt, but gradually they decline and slowly quieten, until finally they disappear.
Figure 1. Edge effects: the impacts on ancient woodlands (cropped), The Woodland Trust – Planners’ Manual for Ancient Woodland and Veteran Trees – Scotland.
But well-devised planning can protect trees from inappropriate development. Whether that’s high-level protections outlined by Scottish government or developers integrating buffer strips and root protection zones into their development designs.
However, protections outlined to date by the government have been insufficient to protect ancient woodland and ancient and veteran trees. Whilst planning policy highlights the irreplaceable nature of these habitats, as of July 2020 the Woodland Trust was aware of 274 ancient woodlands threatened by development. The real figure is likely higher.
Ancient Woods and Trees in Scotland’s Fourth National Planning Framework
The Fourth National Planning Framework presents an incredible opportunity to strengthen the protections outlined for ancient woodlands and ancient and veteran trees in planning policy.
When the Draft NPF4 was published in November 2021 it marked a leap forward in ancient woodland protection policies saying, “Development proposals should not be supported where they would result in: any loss of ancient woodlands, ancient and veteran trees, or adverse impact on their ecological condition.”
This is a huge step forward for several reasons.
Current planning policy is more ambiguous and does not set the foundations for halting any further loss of ancient woodland or ancient and veteran trees. Whilst we have not yet seen the draft NPF4 policy in action, it provides more clarity and should hopefully eliminate development as a threat.
The draft NPF4 text also appears to place the same protection on ancient and veteran trees as it does ancient woodland and takes account of impacts on their ecological condition. Considering ecological condition is the kind of forwarding thinking that will be necessary for tackling the nature crisis and opens opportunities to think about the indirect impacts of development that can lead to declines in ecological condition and their eventual loss when considering planning applications.
There are still areas that need addressing. For example, the continued allowance of habitat fragmentation and the need to properly resource local authorities required to implement these policies. But the Draft NPF4 has reignited my hope that what remains of our precious ancient woodlands and ancient and veteran trees can be preserved. It is just a draft though, so we will keep on working and pushing government and MSPs for robust ancient woodland protections until they have become a reality.
Conclusion
Development is not the biggest threat to ancient woodland in Scotland. Pressure from deer is a much deeper-rooted issue. Results from the Native Woodland Survey for Scotland (NWSS) reported ancient woodland cover had reduced by ~21,044ha between the recording of the Ancient Woodland Inventory (AWI) and the recording of the NWSS. Roughly 90% of that loss was most likely due to herbivore pressures in combination with the poor regeneration capacity of older trees.
However, threats don’t work alone, they are piling up to decimate our woodlands. Development can fragment habitats changing the climatic conditions inside them, so altering the species suited to live there. A new housing development may lead to garden waste thrown over the fence into ancient woodland. That waste may contain INNS, those may spread through the site damaging its ecological condition.
The multitude of threats present is leading to the decline of woodlands across the country. We are facing the very real fact that 97% of native woodlands are in poor ecological condition and less than 2% of Scotland is now covered by ancient woodland.
NPF4 provides us with the opportunity to eliminate one of those threats. We must seize it.
The Woodland Trust is running a campaign to ensure proposed ancient woodland and ancient and veteran tree policy changes are retained in the NPF4. Stand with us and support the campaign here.
Suzie Saunders is the Public Affairs Officer for the Woodland Trust Scotland and a member of LINK’s Planning Group.
Scotland’s fourth National Planning Framework (NPF4) risks a ‘business-as-usual’ approach to the nature crisis rather than delivering the transformative change that has been promised.
Scotland hosts a variety of habitats and rare wildlife such as capercaillie and expanses of internationally important blanket bog in the Flow Country, to the nature we see every day around our towns, cities, gardens, allotments and community woodlands. It’s this amazing array of nature including the benefits it provides to society that we need to protect and restore. Through reforms to our planning system that are currently underway we can make great strides forward in supporting nature. The planning system affects nearly every aspect of our lives in some way, making decisions to put the infrastructure and amenities we need as a society in the right places, in the right way means that it can play a key role to combat the effects of climate change, halt biodiversity loss and restore nature.
Scotland’s fourth National Planning Framework (NPF4) is the Scottish Government’s long-term plan to guide where development and infrastructure in Scotland takes place. Unlike previous frameworks, NPF4 now includes national planning policies and is part of the statutory development plan. This means its policies apply to all areas of Scotland and it will sit alongside policies in local development plans to assess whether a planning application is approved or refused. It will play a critical role to guide all planning decisions in Scotland for the next decade and beyond.
Given its key role in determining planning applications, NPF4 must play its part to ensure a net-zero, nature-rich future. When nature-rich habitats and greenspaces are in a healthy state, they have multiple benefits for people and climate. However, Scotland’s nature is declining, and we cannot afford another decade of inaction.
In response to the global nature and climate crises, the Scottish Government has set out ambitious targets to protect 30% of land by 2030 and achieve net-zero by 2045. However, NPF4 does not yet go far enough to respond to the nature and climate emergency and meet these targets, nor will the current draft deliver the promised transformative change needed for Scotland’s planning system.
Whilst NPF4 recognises the dual nature and climate crises, the language and the rhetoric in NPF4 is neither radical nor transformative policy or measures that would address specifically the nature element. For example:
There is notable difference between the language used in Policy 2 on the climate emergency, which will be given significant weight when considering all development proposals, whereas wording in Policy 3 on the nature crisis merely states development plans and proposals should ‘facilitate’ and ‘contribute to biodiversity enhancement’.
There are references made throughout the draft to nature networks, however, how these will be delivered in practice is unclear. We are disappointed our suggestion for a Scottish Nature Network has not been included as a National Development, this is a missed opportunity.
Whilst setting out a need to secure positive effects for biodiversity, the draft NPF4 offers no concrete solutions nor clarity for decision makers on how to secure this in practice.
Despite our concerns, there is still time to make changes to strengthen NPF4 and avoid ‘business-as-usual’ and further destruction and loss of the natural environment; these changes include:
The language in NPF4 needs to be clearer and more precise to ensure developments actively protect and restore nature.
NPF4 offers a key opportunity for the planning system to coordinate and facilitate the delivery of a Scottish Nature Network in the long term. Embedding a Nature Network in NPF4 as a National Development will set the framework to provide multiple benefits for nature, climate and people, and ensure national ambitions are delivered locally to protect 30% of land for nature by 2030.
NPF4 should include policy that mandates the need for developments to secure positive effects for biodiversity to address the nature and climate crises with the urgency desperately needed. Biodiversity enhancement should not be a ‘nice to have’ in developments, but rather an essential requirement.
The planning system doesn’t hold all the answers to solving the biodiversity crisis, but it has the potential to play a significant role to deliver meaningful change to protect and enhance Scotland’s nature. NPF4 is a crucial opportunity to ensure Scotland’s planning system delivers transformative, meaningful action for people, climate and nature. NPF4 is a crucial opportunity to ensure Scotland’s planning system delivers transformative, meaningful action for people, climate and nature.
This guest blog was written by Niamh Coyne, from RSPB Scotland and a member of LINK’s Planning Group.
Today we celebrate World Wetlands Day! Scotland has many amazing wetlands that are not only sites of important biodiversity but also provide a unique home to a wide variety of wildlife. Wetlands provide many of the things which society relies upon such as clean water, flood protection, carbon storage, and are also great places for people to enjoy the outdoors.
World Wetlands Day marks the date of the adoption of the Convention of Wetlands, known as the Ramsar Convention, which was signed in 1971. The Convention’s mission is to conserve wetlands through local and national actions as a contribution towards achieving sustainable development and protecting biodiverse habitats.
We asked seven LINK members to tell us more about the importance of the wetland habitats and related species that they host as part of the Nature Champion initiative.
Hosted by National Trust for Scotland and Amphibian and Reptile Conservation
Scotland has a range of habitats, a mosaic of fantastic variety. Nestled within the grand and awe-inspiring mountain ranges, sweeping moors and tumbling waterfalls, are fragments of upland flushes, fens and swamps.
The upland flushes of our hills appear as long green lines of rushes or bright patches of mosses and liverworts. These green darts follow the springs, here you will find the heath spotted orchid, dwarf cudweed and butterwort. The flushes provide a home for a variety of invertebrate life, providing good hunting for common lizards and toads. These flushes are under threat from draining hillsides, ploughing for forestry or by cutting moor-grips.
Fens lack trees but these peaty wetlands are fed by a steady source of ground or surface water. They are home to a variety of plants and animals including the red jewelled sundews. Fen vegetation is variable but very distinctive and contains many species that are rare or scarce.
Swamps are largely undisturbed wildernesses, a tangle of woody species and shade tolerant plants. They add a sudden softness to the landscape in areas of moor and if they tempt in the unwary walker, their feet will get a soaking from the sodden ground.
Small Freshwater Bodies include ponds, ditches, springs and flushes. All of these provide huge ecological benefits, supporting a wide range of aquatic species and offset some of the negative impacts of many environmental issues facing us such as climate change, flooding and noise pollution.
Ponds support an extraordinary two thirds of all freshwater species and are central to the survival of many including frogs, toads, newts, a huge range of aquatic invertebrates and plants. Freshwater Bodies also provide mammals and birds with drinking water and some species such as grass snakes with important foraging areas.
One third of ponds are thought to have disappeared in the last fifty years or so and of those that remain more than 80% are in ‘poor’ or ‘very poor’ condition (Freshwater Trust Habitat research). This has had an enormous impact on aquatic wildlife.
Creating clean new ponds is one of the simplest and most effective ways to protect freshwater wildlife. Where it is not a viable option to create new ponds, restoring existing depleting ponds is greatly beneficial.
Kathy Wormald, Froglife
Emma Harper MSP is Nature Champion for Ponds and Small Lochs and Natterjack Toad. Ms Harper has previously contributed to a debate on World Wetlands Day in 2020. She underlined the importance of protecting wetlands both to support biodiversity and to provide a habitat for endangered species such as the natterjack toad to avoid extinction.
Hosted by Scottish Wildlife Trust and Woodland Trust Scotland.
The woodlands that follow the river and loch’s edge have always held an aura of magic in Scotland, considered by Celts to join our world to those more mystical. They continue to be places of natural connection and are vitally important for many reasons, both for people and wildlife. As with any woodland, riparian woodland is a carbon store and benefits biodiversity, acting as a wildlife corridor. More uniquely, the trees shading the river help keep the water cool, making habitat better suited for spawning fish, like Atlantic salmon, and freshwater pearl mussels. The trees present a barrier to run off pollution from farmland and roads, helping to keep the water clean and their roots stabilise the riverbank, reducing erosion. In high rainfall riparian woodland reduces the risk and severity of flooding, providing protection to people’s homes and businesses.
Historically riparian woodland would have run alongside most of Scotland’s rivers, but now many areas are devoid of trees due to human impacts. For the benefits of riparian woodland to be maximised we need to restore this habitat, allowing trees to grow by protecting them from browsing and grazing animals and encouraging landowners to plant native trees in these areas.
Rivers in Scotland are home to a great diversity of species, including plants, invertebrates, fish, birds and mammals. Rivers channels themselves provide a diversity of habitats that provide homes for an equally diverse array of species that are perfectly adapted to survive in the specific conditions provided by these unique habitat types. River habitat itself does not just include the channel itself but also the surrounding embankment flood plains and riparian habitats which are not only vital for different life stages of the species that inhabit our rivers but also act as a buffer against pollution and the impacts of climate change.
Each river in Scotland is home to some very special species. Every February Buglife launches its citizen science project the hunt for the Northern February Red stonefly. The Northern February red stonefly (Brachyptera putata) has its global stronghold in the Scottish Highlands and has only ever been recorded in two rivers outside Scotland – the River Usk in Wales and the River Wye in Hereford, where it is now thought to be extinct. During periods of winter sunshine through February and March these insects can often be found basking on fence posts that run alongside large rivers, from where the adults will have emerged to mate and disperse after spending their formative months as larvae growing under rocks in fast flowing water. The female has three dark bands across its wings, as well as dark wing tips, whilst the male is short-winged and unable to fly.
Lowland raised bogs are a peatland habitat created as raised domes of peat on wet impermeable substrate, such as clay. They are formed by Sphagnum mosses and are home to a host of specialist species and often rare biodiversity. Unfortunately, we have lost over 85% of our lowland raised bogs due to several factors such as peat extraction, afforestation and drainage. These special habitats are still found in the heart of the central belt in areas like the Slamannan Plateau in Falkirk. Raised bogs are important as they store massive amounts of carbon and water, providing a carbon sink and flood management when in a good condition.
Standing on a blanket bog in Scotland, looking out over the gently undulating moss hummocks and pools, you could be standing on peat more than 8 metres deep, that has formed over thousands of years and represents a globally rare habitat. Here in Scotland, blanket bogs cover around 1.8 million hectares, equating to 23% of our land area. Over 1.6 billion tonnes of carbon are stored in Scottish peatlands –a third of the carbon held in the Amazon rainforest which is 250 times larger in area! However, only around 20% of UK peatlands are in a natural, or semi-natural state due to human interventions and so are not only less effective in storing carbon, but actively release it.
Blanket bogs are also incredibly important for biodiversity and downstream flood management as they store vast amounts of water.
Large-scale restoration is underway, but it requires further investment and co-ordinated action at a regional and national scale. Peatland degradation must be halted by banning peat-based compost sales in Scotland, while promoting alternative composts and ensuring that peatlands are protected from inappropriately planned activities such as burning that does not follow the Muirburn Code, tree planting, wind farms and other developments.
Annie Robinson, CIEEM
As we can see, wetlands come in all shapes and sizes and there is a great variety throughout Scotland. Each support a wealth of wildlife which all have an important part to play in keeping our ecosystems healthy and balanced. At the start of this Decade for Ecosystem Restoration, now is the time for Nature’s voice in the Scottish Parliament to be strong, loud and well informed to protect important habitats like Scotland’s wetlands and the species that they support. Nearly 60 MSPs have signed up to be champions for a range of habitats and wildlife. Find out more information here.
By Deborah Long, chief officer, Scottish Environment LINK
Looking back on the rollercoaster of hope and despair that was COP26, there are many aspects of the Glasgow talks that give me cause for optimism as we enter 2022. One of the things that makes me hopeful is the enormous public profile of the Glasgow event. Pretty much everyone in Scotland knew about COP26 – and not just because the talks were hosted here. People are ever more aware of the urgency of the climate crisis.
Another thing that gives me hope for 2022 is the prominence of nature at COP26. In the negotiating rooms and out on the streets, nature inspired. We saw real recognition that halting biodiversity loss, in Scotland and around the world, is essential for the future of humanity. Nature has a crucial role to play in limiting and adapting to climate change. But it’s also clearer than ever that the solutions we put in place to tackle climate change must help restore the planet’s ecosystems. In short, we must address the nature and climate crises together.
So far, efforts to stop biodiversity loss and restore habitats and species are lagging far behind efforts to limit global temperature rises. This is true in Scotland as much as anywhere: Scotland has ambitious climate targets that are helping us reduce our greenhouse gas emissions, but despite one in nine species in Scotland being at risk of extinction, there are no equivalent targets in place for nature. Following a campaign by environment charities, the Scottish government has committed to introducing legally binding targets to restore nature in a Natural Environment Bill in 2023-4.
Despite the many failings of the annual UN climate talks – the COPs – these summits have undeniably helped galvanise countries to start taking action on climate change, albeit to a widely varying degree. For this reason, I want to see the UN biodiversity conference scheduled to take place in Kunming, China, in spring 2022 (but facing possible delays due to covid) get as much attention and fanfare as COP26.
The Kunming conference is the latest in a series of international UN biodiversity summits, equivalent to the climate COPs, aimed at conserving and ensuring the sustainable use of global biodiversity. Confusingly, these are also referred to as COPs (‘conference of the parties’), and since it is the fifteenth, the Kunming conference is COP15.
So what can the world hope to achieve at this other COP, the nature COP?
First, we need the nature COP to set ambitious global targets for halting biodiversity loss and restoring nature, to give countries, including Scotland, a clear framework for their own national targets. These would be the equivalent of 1.5oC for climate.
Second, we need financial commitments. Biodiversity is declining at a faster rate now than at any time in human history. Stopping the decline and helping species and habitats to recover will be a massive job, and it won’t come cheap. But it’s a job we have to take seriously if we want ecosystems to continue to function and provide for our needs.
Third, the rights of indigenous peoples and local communities must be protected. Biodiversity survives best where human pressure is less intense and where local communities work with nature, often using traditional techniques. Efforts to protect and restore biodiversity must work with local communities, rather than excluding or dispossessing them.
If it can make these things happen, and if it can help inspire the world to treat nature and climate with equal urgency, the nature COP might just be our next big chance to save the planet.
Plans for a National Strategy for Economic Transformation will have to be bold and radical if it is to protect people and the planet. So far, the signs aren’t encouraging.
How many people know that a National Strategy for Economic Transformation is being prepared for Scotland? Probably precious few, outside of policy wonk circles and the Holyrood in-crowd.
That does not seem right. This is to be a strategy for the whole nation to transform its economic outcomes, not just for government departments to follow, according to the Scottish Government. If so, a wide and deep process of consultation and debate is surely needed, to build popular support and buy-in from businesses, workers and citizens whose future it will affect, quite radically, if economic transformation is truly the goal.
Instead, a low-profile online consultation was launched in the summer with a 6 week deadline. There was little in the way of visible outreach promoting participation or efforts to ensure that the seldom-heard voices of those at the sharp end of the economic system were included.
If there has been outreach it must have been with business – it certainly was not with the environmental organisations which we represent, which is ironic because this was the only sector actively calling for a new economic strategy before the 2021 Holyrood elections .
Green groups had realised that vital objectives like zero emissions and protecting nature would only be achieved with the right economic policies; that existing economic management and fiscal policies had ignored these problems; and were often part of the problem, rather than the solution. Further, they had originated some of the few inspiring new ideas in the economic field in recent years – proposing a Scottish National Investment Bank; bringing the concept of Just Transition to the context in Scotland; being strong advocates of a circular economy and the prioritisation of wellbeing.
As the initially vague framing for the new National Strategy for Economic Transformation has been tightened up, it has been reassuring to see that the objectives of tackling climate change and protecting nature are in fact embedded in the remit of the new strategy. However, these purposes do not appear to be reflected in the discussions of the Advisory Council which was set up to advise on drafting the strategy in the six-month timetable which the Scottish Government had imposed on itself .
Who is speaking for nature and urgent action on climate change?
In the minutes of its meetings we have looked in vain for discussions of how to get our economy back within planetary boundaries or by what multiple do we need to increase investment in order to achieve a just transition. Nor do we see debates about the fundamental changes needed if soaring economic inequalities are to be abated and wellbeing for all is to replace GDP growth as the core objective of our economy.
The 18 pages of minutes from the first three meetings of this body do not feature a single mention of decarbonisation, nature or biodiversity, circular economy, climate change (there is one reference to the Climate Change Plan as a document). The only mention of just transition is a warning that “Care is needed on the language around just transition, recognising that this needs to be managed carefully to provide the confidence for businesses to invest …”.
We need to see a draft of the new strategy before reaching final conclusions, but it does seem that environmental organisations were justified in our concerns when we said in a letter to the Cabinet Secretart “there is no-one on the Advisory Council with a background in the environmental movement nor anyone who will speak from a climate change or biodiversity perspective with a track record of insisting that the priority for economic policy has to be to keep to (or get back within) planetary limits”.
Ten key points for transformation
In these circumstances, the Transform Our Economy group (Friends of the Earth Scotland, Wellbeing Economy Alliance and Scottish Environment LINK) has sought to fill the gap and propose how to tackle the urgent environmental and social challenges Scotland is facing. The new economic strategy needs to be bold in vision and broad in scope so we have set out Ten Key Points , criteria for what any truly transformative economic strategy would look like
In summary, these start from a proposition which might seem obvious but which is truly radical for economic policy – that the purpose of the economy is to achieve goals which are not framed in economic terms like GDP. We suggest these should be ‘wellbeing for all within environmental limits’. Secondly, that requires setting and achieving specific objectives like decarbonisation, social equality and reducing use of raw materials. These in turn require a whole-economy approach, drawing on all the powers of all parts of government, not just the bits labelled ‘environment’ – it needs to be fully embedded in economic strategy and policy.
To combat existing pressures locking us into the damaging status quo, Scotland needs a different relationship between public and private realms. Investment decisions need to be guided by democratically-determined goals that benefit collective wellbeing, rather than by market forces alone. Assessments of impacts on climate change, equity and nature need to be integrated into economic decision-making. A truly transformational strategy will need to listen to everyone’s voices and harness everyone’s enthusiasm so it will have to find specific ways of bringing benefit to all, including the most marginalised.
These are vitally important and difficult challenges. Scotland does have the potential to rise to them and there are some tools for doing that already being put in place such as Just Transition Plans for every sector of the economy, a Circular Economy Bill, and the Scottish National Investment Bank. But as we have seen too often, bold-sounding announcements from the Scottish Government can remain just that. Trying again, even trying harder, with a stale, business-as-usual approach won’t work.
Scotland needs a bold re-design of our economy to deliver collective wellbeing within planetary boundaries. Let’s open up the discussion of what transformation could look like, and how to get there, drawing on input from all our communities.
Please see here for our full statement on the National Strategy for Economic Transformation.
Matthew Crighton, for the Transform Our Economy Alliance (Friends of the Earth Scotland, Wellbeing Economy Alliance and Scottish Environment LINK)
By continuing to use the site, you agree to the use of cookies. more information
The cookie settings on this website are set to "allow cookies" to give you the best browsing experience possible. If you continue to use this website without changing your cookie settings or you click "Accept" below then you are consenting to this.
