Draft Land Use Strategy for Scotland
For link to this Consultation visit: http://www.scotland.gov.uk/Publications/2010/09/23100015/0
For other responses to Consultations visit: http://www.jncc.gov.uk/page-3908
For further information about the Joint Nature Conservation Committee visit:
http://www.jncc.gov.uk/default.aspx?page=1729
Number of Consultation: 1061
ANNEX A: RESPONSE FORM
Getting the best from our land: A draft land use
strategy for Scotland
RESPONDENT INFORMATION FORM
Please note this form must be returned with your response to ensure that we handle your response
appropriately
1. Name/Organisation
Organisation Name
Joint Nature Conservation Committee (JNCC)
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Ms
Mrs
Miss
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Surname
Rose
Forename
Paul
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Monkstone House
City Road
Peterborough
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PE1 1JY
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[email protected]
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CONSULTATION QUESTIONS
PLEASE NOTE: Questions 1 to 10 relate to the Draft Land Use Strategy; questions 11 to 14
relate to the accompanying Environmental Report.
INTRODUCTION (Section 1 of the draft Strategy)
Vision – A prosperous and sustainable low-carbon economy, underpinned by successful
land-based businesses, flourishing natural environments and vibrant communities.
Question 1a: Do you have any comments on the vision that we have proposed?
The vision is suitably ambitious and inspirational but well beyond what can be achieved
through a land-use strategy alone. Recent studies, most notably TEEB, demonstrate how
important Ecosystem Services and Natural Capital are for prosperity, but it will be
challenging to make links between Ecosystem Services/Natural Capital and flourishing
natural environments sufficiently to sway decisions on land use away from the more
obviously economic activities. Accordingly, it will be difficult to maintain the correct balance
of land-use to treat all three objectives under the vision equitably.
Question 1b: Taken together, do the objectives and their accompanying strategic directions
support the vision?
The objectives support the vision well but, like the vision, go beyond what can be achieved
through a land-use strategy alone. Development, Natural Environment and People prove
very useful and intuitive headings for categorising the main considerations around land-use
throughout the remainder of the strategy.
The strategic direction supporting the natural environment objective should be
strengthened to say ‘mainstreaming the natural environment for the benefit of
Scotland’
PRINCIPLES FOR SUSTAINABLE LAND USE (as set out in text of section 1)
Question 2a: Is it useful to set out principles for sustainable land use?
Yes
Question 2b: Do you think that these are the correct principles? If not, how would you like
to see them changed?
All of the principles outlined are helpful but some additional concepts might usefully be
added.
Under principles for land-use decision making it might be useful to have a principle that
recognises the need to consider the European and international context, both in terms of
the obligations that arise from directives such as the Water Framework Directive and
Habitats Directive and also the wider footprint of the land use (both economic,
environmental and social) beyond Scotland. As the consultation document notes, Scotland's
land area is fixed and it suggests only a third of the raw material used for food and drinkin
Scotland is produced by Scottish agriculture / land use. In other words, a significant part of
Scotland's economy depends upon land use elsewhere in the world - if the aim is genuinely
to move to a low carbon economy then this cannot be limited to the impacts of land use in
Scotland alone.
SUCCESSFUL LAND-BASED BUSINESSES (section 3 of draft Strategy)
Objective – Successful land-based businesses contributing to Scotland’s prosperity and
wellbeing
Strategic direction – towards a low-carbon economy.
Question 3a: Do you agree with the objective and strategic direction for land-based
businesses?
No response from JNCC
Question 3b: Have we focussed on the right areas to achieve this objective and move us in
this strategic direction?
No response from JNCC
Question 3c: Are the actions identified the right ones to deliver the objective, and are there
other actions which would be more successful or effective?
JNCC has no response on the suggested actions but notes that additional actions will be
required if Scotland is to examine its footprint on land use beyond Scotland.
FLOURISHING NATURAL ENVIRONMENTS (section 4 of draft Strategy)
Objective – Flourishing natural environments delivering the widest range of benefits to
Scotland, and playing their part in mitigating global climate change.
Strategic direction – better consideration of the natural environment.
Question 4a: Do you agree with the objective and strategic direction for natural
environments?
In general, yes, but I think it would be better to aim for the optimal range of benefits rather
than the widest range of benefits. It will be a challenge to identify the optimal balance of
benefits across the three objectives (economy, environment and people), for each parcel of
land and then to further balance these decisions at different scales to ensure that Scotland
as a whole does not lose out.
Question 4b: Have we focussed on the right areas to achieve this objective and move us in
this strategic direction?
Taking an ecosystem approach and recognising that thriving ecosystems underpin delivery
of ecosystems services are both critically important for achieving this objective. Thriving
ecosystems comprise a variety or organisms (biodiversity), so conservation actions for
biodiversity need to continue and further action needs to be taken to reduce pressures on
biodiversity. In addition, more novel and integrated use of environmental evidence and
research is necessary to enable the benefits from thriving and functioning ecosystems to be
adequately quantified, placed in a local context and balanced against other types of
potential benefit that could be obtained from the land.
Question 4c: Are the actions identified the right ones to deliver the objective, and are there
other actions which would be more successful or effective?
The actions focus on the identification of land most appropriate for meeting climate change
targets, mitigation activities, such as tree planting, carbon storage and adaptation priorities.
Actions are also required to identify priorities for the maintenance of thriving resilient
ecosystems which in the long term will be essential for meeting climate change related goals
as well as for delivering all of the other ecosystem services and natural capital recognised in
sections 4.2.1 and 4.2.2. It will also be important to move beyond demonstrations and tools
before 2016 if imminent land-use decisions are expected to include the natural environment
impacts as well as those of businesses and communities.
VIBRANT COMMUNITIES (section 5 of draft Strategy)
Objective – Vibrant, sustainable communities in urban and rural areas, with people
connected to the land, enjoying it and taking an interest in its future.
Strategic direction – connecting people to the land.
Question 5a: Do you agree with the objective and strategic direction for vibrant
communities?
Yes
Question 5b: Have we focussed on the right areas to achieve this objective and move us in
this strategic direction?
Yes. Some of the thinking around making connections is particularly interesting. The focus
on where food, water and energy comes from is only one step away from increasing
awareness of environmental footprints locally and beyond, and the use of various schemes
of goods labelling and branding that could help stimulate market based support of some
land-uses that otherwise would need to be subsidised with public funds.
Question 5c: Are the actions identified the right ones to deliver the objective, and are there
other actions which would be more successful or effective?
The actions are restricted to developing community support aspects of the Climate Change
adaptation strategy and thinking about ways to involve communities in decisions and
debates. Much more is necessary along the lines suggested in the preceding sections of
Chapter 5. Active communication can be achieved through the goods people consume if
labelling and advertising are used imaginatively. This raises awareness and assists innovative
local decision taking processes that engage local people with a diverse spectrum of
interests. These types of idea are also fully in line with the principles of the Ecosystem
Approach.
DELIVERING SUSTAINABLE LAND USE (section 6 of draft Strategy)
Question 6a: What would be the best way of placing the national objectives of the Land
Use Strategy in a local context to assist land managers and local stakeholders?
Information and evidence flows that can be efficiently scaled up and down to create
overviews and provide local context are one means to achieve effective local engagement
but this is not an easy task and would need to be accompanied by supportive local decision
taking processes to fully justify the effort needed to produce evidence flows of this
nature.
Question 6b: Are there other actions which would assist local decision processes?
JNCC is not really placed to comment beyond improving some of the evidence flows.
Question 6c: Are there measures additional to those already in place which should be
considered to encourage the restoration of vacant or derelict land to economic, social or
environmentally productive use?
No response from JNCC.
GENERAL
Question 7a: Do you see any conflicts, either within this draft Strategy or between it and
other policies? If so what are they?
None
Question 7b: Do you see complementarities with other policy areas, which have not been
explored in the draft Strategy?
In line with JNCC’s specific role, it is important to consider this draft strategy within the
context of various international agreements, international targets and European Directives.
The recent framework of global targets agreed at the recent meeting of the Convention on
Biological Diversity in Nagoya, Japan very helpfully balances sustainable use, conservation
and the sharing of benefits in an attempt to try and halt biodiversity loss. These targets will
form the basis for development of a new EU biodiversity strategy and obviously have
similarities with the three objectives of this draft strategy.
The EU Habitats Directive, Birds Directive and Water Framework Directive also create
obligations relating to Land Use and need to be integrated into consideration of Land Use in
Scotland. Other emerging EU strategies are also likely to be very relevant to Land Use and
perhaps the Green Infrastructure strategy is one of the most relevant.
Finally, it is worth keeping abreast of other national natural environment strategies in the
UK for whilst these are not specifically land use strategies they are all likely to have impacts
on planning and land use more generally because of the integrated, locally implemented
ecosystem approach that appears as a common thread throughout the UK.
Question 8: Are there any equality issues that the Strategy needs to address (relating to
race, gender, disability, age, sexual orientation, gender identity or religion/belief)? If so,
how could the Strategy be improved to meet those needs in a better way?
No response from JNCC.
Question 9: Are there any other groups in society that may be adversely affected by
proposals in this Strategy? If so, how could the proposals be improved to meet their needs
in a better way?
No response from JNCC.
Question 10: Are there any other points you wish to make about any aspect of this draft
Strategy?
No response from JNCC.
QUESTIONS ON THE ENVIRONMENTAL REPORT
Question 11: Is there any other baseline or environmental information which could be used
to further inform the Strategic Environmental Assessment? Please provide details and
evidence to support your response.
No response from JNCC.
Question 12: Do you think that the Environmental Report has captured the significant
environmental effects of the Strategy? In your opinion has anything been overlooked?
Please provide details and evidence to support your response.
The draft strategy has rather overlooked the European and international dimensions of
many of the issues it is dealing with, including Scotlands ecological footprint beyond it's own
borders. Many of JNCC's previous answers reflect this gap and how it might be addressed.
Question 13: Do you agree with the measures for enhancement already adopted by the
Strategy and the additional enhancement and mitigation measures proposed for the final
Strategy? Please provide details and evidence to support your response.
No response from JNCC.
Question 14: Do you agree with the proposed arrangements for monitoring identified in
the Environmental Report? Please provide details and evidence to support your response.
No response from JNCC.