Scottish Biodiversity Metric – Key Issues Consultation – Initial Overview of Responses

NatureScot has been commissioned by the Scottish Government to develop a biodiversity metric for Scotland’s planning system, suitable for use in supporting delivery of National Planning Framework 4 (NPF4) policy 3(b).

To inform the metric’s development, NatureScot consulted on its paper, A Biodiversity Metric for Scotland’s Planning System – Key issues, from 4^th April to 10^th May 2024 (late submissions were accepted up to 24^th May).  This was the first opportunity for stakeholders to provide comments on the range of issues initially identified and highlight if there were any additional issues that required consideration.  Stakeholders were alerted to the consultation via email (c.300 stakeholders identified, plus all recipients of NatureScot’s e-planning newsletter), the Scottish Government’s Planning, Architecture and Regeneration Division planning bulletin, and NatureScot social media channels.  The website consultation paper received over 4200 page views.

Response to Consultation

In total 92 submissions were received, 78 via the SmartSurvey link provided for the consultation, and 14 via email.

The 13 Local Authorities responding included Aberdeen, Aberdeenshire, City of Edinburgh, Falkirk, Fife, Glasgow City, Highland, North Ayrshire, Orkney Islands, Perth & Kinross, Scottish Borders, Shetland Islands and West Dunbartonshire.  In addition, responses were received from the Loch Lomond and The Trossachs National Park Authority and the Scottish Tree Officers Group.

Business and developer interests included the renewable energy and transmission sector (11 responses), housing developers (5 responses) and land management/investment interests (5 responses).

At least 23 responses expressed an interest in providing further assistance or involvement in the metric tool’s development. 

Overview of Key Themes Identified in Consultation Responses

The consultation asked a set of three common questions under nine issues, and a tenth question on priorities.  Although all feedback received through the consultation will be considered as part of the project, the following are some of the key themes and headline messages identified.

Q.1 Rules and Principles

• There was broad support for applying similar metric rules and principles to those used in the English metric, with a review to ensure these are appropriate for Scotland. Many detailed comments were submitted suggesting improvements or changes to the English rules and principles that should be considered when developing a Scottish biodiversity metric.
• Many responses highlighted a need to incorporate a flexible approach within the metric, provided any deviation from metric rules and principles can be supported with evidence.
• A range of views were submitted regarding the red line boundary issues identified in the consultation.  Some believed the metric baseline should only consider the area directly (and indirectly) impacted by a development, whilst others thought the metric baseline should consider the full area within the red line boundary.  Although primarily discussed in relation to the renewables industry, some indicated that red line boundary issues should also be considered for linear infrastructure (including land ownership concerns).
• When considering additionality, it was suggested that there is a need to clearly define what this refers to.  Some supported diversion from the English metric approach, to allow stacking/bundling with other ecosystem benefits/payments (e.g. carbon codes), though there was also support to maintain the need for an additional benefit requirement (e.g. beyond benefits provided through other paid for schemes or statutory/policy requirements).
• Several responses raised issues beyond the metric commission itself, including:
  • Desire for a small sites metric, or use of the metric to support NPF4 Policy 3c  
  • Clarity on the biodiversity uplift expected from developments (will there be a standardised, minimum uplift requirement?)
  • Interactions with other policies (and credits market)
  • Mechanisms to ensure delivery, implementation and enforcement of interventions that leave nature in a demonstrably better state
  • Use of the metric for carbon/water/natural capital projects beyond a planning context

Q.2 Habitat Classification

• Although there was broad support for a standardised habitat classification approach that is appropriate for Scotland, opinions differed sharply on which classification system(s) would be most suitable to underpin a Scottish biodiversity metric.  To facilitate upskilling, respondents agreed that early indication of the likely classification system(s) would be beneficial.
• Responses were equally split on whether to adopt the UK Habitat Classification system (UKHab) within the metric (as used in the English Metric), or whether to use Phase 1 and/or NVC classification systems that are currently more widely used in Scotland.  Those who have experience with UKHab appeared more optimistic about its potential suitability for a Scottish context and highlighted that upskilling was achieved relatively quickly in England.
• Shortcomings were noted for all potential classification systems that could be used. For example, several responses mentioned there is a skills shortage in Scotland of trained UKHab users and known issues surrounding UKHab upland/peatland classifications.  NVC was considered by some to be too complex for most sites, with a limited capacity of NVC surveyors in Scotland, whilst comments on Phase 1 suggested it is too simple to adequately capture site biodiversity.
• Some noted a general shortage of experienced botanists and habitat surveyors, which they feel needs to be addressed regardless of the classification system(s) chosen to underpin the metric.
• There was general agreement that translating between habitat classification systems presents challenges.  Views varied on the extent to which the metric should support translation between classifications, with concerns that correspondence tables could hinder uptake of the preferred classification system.  Some suggested an interim approach that phases out the use of correspondence tables once users are familiar with the preferred system. 
• Representatives from forestry and arboriculture expressed concerns with how the English metric classifies individual trees and urban trees.

Q.3 Irreplaceable Habitats

• There was general support for establishing a Scottish list of irreplaceable habitats, with a range of habitats proposed for inclusion (e.g. blanket bog, raised bog, mountain heaths, species rich/ancient grasslands, coastal cliffs).
• Although peatland was recognised as irreplaceable, some considered that its condition should be taken into account and/or these habitats should be treated ‘pragmatically’ (particularly relating to renewable developments).  Similar concerns were raised for woodland habitats.
• There was support for certain woodlands (e.g. Caledonian pinewood, Atlantic/temperate rainforest, ancient woodland, veteran/ancient trees) to be identified as irreplaceable, with detailed comments provided on the appropriate use of inventories/data sources to support this.
• Some confusion surrounded the English approach to treatment of irreplaceable habitats, with recognition that Scotland can develop a different/better approach. 

Q.4 Habitat Distinctiveness

• There was general agreement with the issues identified in the consultation paper and support to adapt the English metric approach to distinctiveness for a Scottish context.  This should include appropriate consideration of specific Scottish habitats that are not recognised in the English metric (e.g. Caledonian pinewood, machair).
• Some suggested a review of distinctiveness categories and weighting/scoring is required. This could include widening the gaps between scores applied to distinctiveness categories in the English metric, to better value highly distinct habitats. 
• Concerns were noted about how distinctiveness is considered within the metric trading rules, with the English metric perceived as favouring interventions to medium distinctiveness habitats and disincentivising more ambitious interventions. 
• It was suggested that there should be better incentives for large-scale habitat improvements (e.g. peatland restoration).  Some respondents noted that the high distinctiveness values assigned to many upland habitats created a challenge due to the resulting large-scale of habitat enhancement required to compensate for any losses. 
• It was agreed that it will be important to use Scottish spatial datasets when assigning distinctiveness values, with responses suggesting a number of datasets that would be useful to consider (e.g. Habitat Map of Scotland (HabMoS), Native Woodland Survey of Scotland (NWSS), SEPA's Water Classification Hub).  However, some commented that a review of available Scottish spatial data is required to identify any existing gaps/discrepancies in the data and where updates are needed.
• It was suggested that there should be consideration of how metric distinctiveness could interact with other Scottish Government objectives and ambitions (e.g. renewable energy targets, woodland creation, 30x30).

Q.5 Habitat Condition

• A review of condition assessment criteria and condition/scoring categories was supported, to ensure the biodiversity present on a site is adequately captured.
• There was a call for condition assessment sheets to be clear and easy to use, with supporting guidance to ensure consistency of survey methodologies (both for baseline and post-intervention condition).
• There was widespread support for species to be considered within the metric in some way, either as indicators of habitat condition or by allowing interventions that benefit species (e.g. incentivising targeted habitat interventions that aim to benefit certain species).  However, there was also recognition of the complexity this would involve and suggestions to consider species either through a separate process (e.g. a complimentary ‘wildlife metric’) or in later iterations of the metric.
• Opinions differed on whether to incorporate artificial interventions that benefit species (e.g. nest boxes) within the metric, with concerns that incorporating these within a site’s biodiversity unit score may deliver sub-standard compensation, reduce post-development green space or suggest that the natural habitats available do not meet species needs.
• If the Modular River Survey (MoRPh) is considered appropriate for assessing freshwater habitats in Scotland, it was recognised that widespread MoRPh training will be required.  Stakeholders familiar with MoRPh commented that there have been few issues with upskilling in England.  Alternative approaches (e.g. River Habitat Survey) were put forward if MoRPh adaptation for Scotland is not feasible.
• Some suggested considering how the metric condition criteria could be amended to incentivise woodland creation and improve support for positive ecological interventions on productive land (forestry and agriculture).

Q.6 Strategic Significance

• To adequately reflect strategic significance within the metric, a wide range of plans, policies and strategies were put forward for consideration, including:
  • Local Biodiversity Action Plans (LBAPs)
  • National Biodiversity Action Plans (NBAPS)
  • Scottish Biodiversity Strategy (SBS)
  • Climate Change Adaptation Programme
  • Land Use Strategies
  • Blue and Green Infrastructure Strategies
  • Nature Networks (NNs) 
  • Local Development Plans (LDPs) and Masterplan Consent Areas (MCAs)
• Concerns were raised regarding the fitness, consistency or age of some existing documents (e.g. LBAPs), noting a need for flexibility where ecologically significant sites, habitats or species are not captured by existing plans/policies/strategies.
• Many respondents highlighted the need to account for ecological connectivity/habitat fragmentation within the metric.  It was suggested that this could either be incorporated into the strategic significance multiplier (via inclusion of NNs) or addressed in a separate, standalone multiplier. 
• Some responses indicated a need for collaboration between land managers/developers to allow for adjacent schemes to be connected. 
• A range of views were submitted on how the metric will recognise local and community priorities against national or international priorities.
• Some questioned whether the strategic significance scores applied in the English metric adequately weight high strategic significance (suggesting an increase in score values to address this). 

Q.7 Difficulty Risk

• Almost all respondents agreed with the issues identified in the consultation, i.e. that risk multipliers may need some refinement to account for different ‘average’ conditions in Scotland, and that the ability to provide more flexibility and vary the multiplier in the Scottish metric, based on site-specific issues and professional advice, should be considered.
• It was suggested that clear guidance would be helpful to aid consistency when applying site-specific flexibility, and that professionals should provide robust justification if proposing to apply this kind of flexibility.
• Responses noted a range of factors that could potentially influence the site-specific ‘difficulty’ (or likely success) of measures.  These included topography, altitude, hydrology, grazing levels, existing habitat condition and target condition, the specific restoration techniques, the experience of those implementing measures, the applicant’s intended approach to monitoring and adaptive management, as well as the likelihood of enforcement action.
• A frequently raised issue was that the English metric multiplier values can act as a disincentive to creating or even enhancing some higher quality, longer-term habitats, particularly when the difficulty risk multiplier is combined with the temporal risk multiplier (higher quality habitats normally taking longer to establish). It was suggested that multipliers could potentially be set in a way that avoided disincentivising such ambition. Some respondents also suggested that this issue might be addressed through the principles and rules of the metric (and possibly rather than through use of multipliers at all). There was also a suggestion for exploring the use of an additive rather than multiplicative approach when combining risk values.
• Several respondents identified a particular sensitivity over risk multipliers (and high habitat distinctiveness ratings) as they affect expectations for large-scale peatland restoration, noting that this might affect delivery of projects. 
• It was suggested that further evidence gathering and review of the success rates of peatland restoration in Scotland would be helpful when considering risk values, whilst noting that difficulty risk might vary widely, depending on site-specific factors.

Q.8 Temporal Risk

• As for difficulty risk, most respondents agreed that the temporal risk multiplier values may need review to account for different ‘average’ conditions in Scotland, and that it would be good to consider more flexibility to vary the multiplier, based on site specific issues and professional advice.
• Again, it was suggested that clear guidance would help aid consistency when applying site-specific flexibility, and that proposed variations to the multipliers should be supported by good justification from an ecologist.
• A common theme was that it would be good to somehow more fully reward aspiration to deliver higher quality habitats that may take longer to achieve (e.g. woodland) rather than the metric incentivising easier and quicker-forming habitats of potentially lower ecological value.  One suggestion was to consider an additional multiplier drawn from the expected value of the end-result habitat.
• A concern was expressed that the English metric temporal risk multiplier did not adequately value interim or succession-stage habitats, and that this may contribute to disincentivising the ambition for higher value habitats.   
• It was noted that the current English metric approach may not adequately facilitate natural woodland succession/regeneration which may take more time than direct planting but can be preferable, for example in making use of existing seed sources adapted to the locale, being more resilient to climate change, and better protecting soils and carbon. 
• The concept of a ‘delayed action’ penalty reducing the number of biodiversity units was questioned on the basis that such delays are sometimes outside a developer’s control and that staging compensation/ enhancement works can potentially reduce wildlife disturbance and allow for a more considered approach and better outcome. 

Q.9 Spatial Risk

• Most respondents agreed with the key spatial risk issues identified in the consultation, i.e. recognising that as the Defra statutory biodiversity metric applies to an English framework, appropriate Scottish equivalents require identification. 
• Suggestions for possible options included:
  • Scottish Data Zones
  • Local authority boundaries
  • Landscape Character Types boundaries
  • A simple distance multiplier
• The challenges of using planning authority boundaries of varying sizes were discussed in some responses, with one suggestion being grouping of smaller authorities.
• The equitability (and benefits to people and species) of onsite or local delivery of habitat measures was recognised.  Although it was suggested that while local delivery might be prioritised, off-site or more distant measures should not be made overly restrictive or prohibitive, noting that sometimes better opportunities and more strategic outcomes are available elsewhere (e.g. at distance from human/operational disturbance). 
• It was noted that we need to bear in mind that the spatial risk is a blunt tool that does not necessarily reward well-connected nature. 
• It was suggested that the ability to discount the spatial risk multiplier should be considered, if clearly supported by good justification over better strategic outcomes.
• For island situations, it was suggested that if not on-site, the approach should first look towards delivery of biodiversity measures on the island, as this would be more palatable to affected communities. 

Q.10 Phased Approach and Priorities

• There was broad support for the overall metric project approach, as described in the consultation.
• Some concerns were raised that the timescale to deliver the metric tool is overly ambitious, while others emphasised the urgent need for a Scottish biodiversity metric.
• Several responses noted ecological connectivity and off-site offsetting/habitat banking as additional areas requiring consideration.
• There were a range of views on Scotland developing a distinctive tool versus ensuring compatibility/consistency with England’s metric.
• There was widespread recognition of the need for capacity building for all stakeholders, ensuring there is a lead-in time to allow for upskilling before the metric tool is available for use.
• There were some concerns that ensuring the metric works appropriately for peatland habitats could negatively ‘skew’ how it works in other situations, and that care will be required to ensure this does not happen.
• It was suggested that the differing character of island biodiversity (compared to the mainland) needs to be recognised and factored into the metric tool.

Summary and Next Steps

Responses provided to this consultation will be used to inform the development of the metric (and the issues to be examined) as we take this work forward.  Thank you to everyone who shared their views with us as part of this process.

Work will now progress to addressing some of the priority issues that have been identified and shaping the basic structure of the Scottish biodiversity metric.  This will require a review of the components that underpin how the metric works.  Early signalling of the proposed metric foundations will be communicated to stakeholders, to enable preparations for adopting the new Scottish biodiversity metric to begin.

As work progresses, we will be seeking more focussed discussions with key stakeholders, particularly with those who have experience of applying a metric approach in Scotland and those who have expressed an interest in contributing their expertise to the metric development.  However, there will also be further opportunities to contribute, including through established fora and open consultations published on the NatureScot website. 

If you have any queries, or further comments that could assist with the development of a Scottish biodiversity metric, please email [email protected].

NatureScot
August 2024