Freedom of Information Request - PeatlandACTION Ground-truthing
Date: 19 December 2025
Our ref: SIR182636/A5641051
Information Request – PeatlandACTION Ground-truthing
Your Request & Our Response
We have responded to each part of your request as follows:
1. Ground-truthing requirements for applicants
a. Any formal written requirements, standards, policies, or guidance documents held by NatureScot relating to ground-truthing of digitised peatland features (such as hags, gullies, or drains) submitted as part of peatland restoration plans?
Point 7 of the Peatland ACTION - Spatial data guidance states the following:
“Whatever the methodology used to map restoration works, ground truthing will be a necessary requirement to minimize the risk of variations on the original grant offer. Since it is not possible to ground truth all the elements that are mapped in the field, it is necessary to at least ground truth a representative random sample of features (hags, gullies and/or drains).”
The full spatial guidance note.
b. Any documents, checklists, guidance notes, training materials, or internal instructions provided to applicants or to NatureScot staff that describe how the level, extent, or adequacy of ground-truthing should be assessed?
The link indicated at point 1 a. above will provide this information.
2. Assessment and compliance by applicants
a. Records showing whether NatureScot systematically records or tracks the percentage or extent of peatland areas or digitised features that have been ground-truthed by applicants prior to submission?
PeatlandAction does not keep records of ground-truthed areas.
b. If such records exist, please provide the most recent available figures or summaries, including:
• The percentage of peatland restoration plans containing ground-truthing information.
• The recorded percentage of mapped features (e.g., gullies, drains, hags) that were ground-truthed by applicants.
Please see our response at 2 a.
3. Validation and auditing by NatureScot
a. Any documentation, protocols, or guidance describing how NatureScot staff verify the accuracy of mapped features in submitted plans?
We do not check each mapped peatland feature submitted in restoration plans. Instead, we run a software automation that identifies invalid topology in relation to mapped peatland features.
The spatial data for each application is checked against the checklist below:
Table 1 - spatial Data Checklist
| Checklist | Response |
|---|---|
| Template used | Yes/No |
| Layers deleted from template/attributes altered? | Yes/No |
| Restoration footprint (formerly subsite) boundary meets guidelines | Yes/No |
| Restoration footprint hectares | Value |
| Restoration footprint distance buffer in metres | 30m/50m |
| Geometries contain duplicates | Yes/No |
| Valid geometries? (ie: isolated lines smaller than 1 m or isolated polygons smaller than 1sqm? | Yes/No |
| Obvious errors in attributes | Yes/No |
| Do the map features overlay with aerial features? | Yes/No |
| Notice any clear cases of under mapping | Yes/No |
| Notice any clear cases of over-detailed mapping (example average segment lines <1m) | Yes/No |
| Number of subsites in [application form (Q39) / final report (Q8, Q9) / feasibility assessment report] and spatial data match | Yes/No |
| Restoration_footprint hectares match the [application form (Q39) / Final report (Q9) / feasibility assessment report] | Yes/No |
| [Application form (Q40) / Final report (Q10)] restoration techniques match those shown in spatial data | Yes/No |
| Spatial data restoration feature lengths and areas match the [application form (Q40) / Final report (Q10) / feasibility assessment report] | Yes/No |
| Are the haggs and/or gullies mapped as lines (metres) or polygons (hectares)? | Lines/Polygons |
| Overlap with previous projects? | Yes/No |
| Is there a PDS for the project? Either on the database or provided with the spatial data? | Yes/No |
| Meets SG, GHG inventory and SRUC requirements? | Yes/No |
b. Records or data showing what proportion (percentage or estimate) of mapped peatland features submitted in restoration plans have been independently checked, visited, or validated by NatureScot staff before or after funding approval?
We do not have data showing the proportion of mapped peatland features, submitted in restoration plans, that have been independently checked, visited, or validated by NatureScot staff before or after funding approval.
Please note the reference to ‘validation’ is a term used in the Peatland Code process administered by the IUCN.
4. Rejected or non-compliant submissions
a. The number of peatland restoration plans (for any year since the programme began) that have been:
• Rejected,
Evidence of ground truthing is not required as part of the assessment process and therefore no information is collated.
However, 38 projects were rejected between 2020-25 due to poor mapping (please note: this information was not collated prior to 2020).
• Returned to applicants for revision, or
Evidence of ground-truthing is not required as part of the assessment process and therefore no information is collated.
• Delayed for approval
Evidence of ground-truthing is not required as part of the assessment process and therefore no information is collated
due to inadequate, missing, or insufficient ground-truthing.
b. Any records of breaches or non-compliance identified by NatureScot relating specifically to inaccurate or unverified mapping of peatland degradation features (such as drains, gullies, hags, etc.).
Applications where mapping has been identified as inadequate/inaccurate are asked to submit revised spatial data prior to funding being awarded.
Projects where mapping issues are identified during the restoration process are addressed through our Variation to Offer (VtO) process
c. For any such cases, please provide summaries of:
• Actions taken by NatureScot,
As indicated above, action is taken thorough our VtO process. A record of VtOs from 2020 onwards, that were awarded/rejected specifically relating to “under-mapping” is attached separately to this response
• Corrective measures required from applicants, and
Where under-mapping is identified, the applicant is required to re-map the restoration
• Whether any funding was withheld, amended, or recovered as a result.
Projects where mapping issues are identified during the restoration process are addressed through our VtO (as indicated above).
On completion, the final restoration spatial data is verified by NatureScot in line with our Spatial Data Guidance
If you want to know more about the application process for PeatlandAction it can be found on our website, an application process “quick guide”.
How We Handled Your Request
We believe you have asked for environmental information as defined in the Environmental Information (Scotland Regulations 2004 (‘the EIRs’), so we are dealing with your request under those regulations. To be able to use the EIRs, we must apply an exemption under section 39(2) of the Freedom of Information (Scotland) Act 2002 (‘FOISA’). The Scottish Information Commissioner’s guidance recommends that public authorities apply this exemption to environmental information and handle request under the EIRs.
If you would like to find out more about the access to information legislation, there is a guidance booklet available on the Scottish Information Commissioner’s website.
Review and Appeal
I hope this information meets your requirements, but if you are dissatisfied with how we have responded to your information request, please write to us within 40 working days explaining your concerns. You can contact us at Battleby, Redgorton, Perth, PH1 3EW or email us at [email protected]. We will carry out a review of our response and contact you with our findings within 20 working days.
If you are not satisfied following this, you can make an appeal to the Scottish Information Commissioner within 6 months. The Scottish Information Commissioner can be contacted at:
Scottish Information Commissioner
Kinburn Castle
Doubledykes Road
St Andrews
Fife
KY16 9DS
Telephone: 01334 464610
Yours sincerely
FOI Officer,
NatureScot
