CAIRNGORMS NATION­AL PARK AUTHORITY

Form­al Board Paper 3 9^th Septem­ber 2022

CAIRNGORMS NATION­AL PARK AUTHORITY

FOR DECISION

Title: SCOT­TISH BIOD­IVERSITY STRATEGY – CNPA CON­SULTA­TION RESPONSE

Pre­pared by: SARAH HEN­SHALL, HEAD OF CON­SER­VA­TION ANDY FORD, DIR­ECT­OR OF NATURE AND CLI­MATE CHANGE

Pur­pose To agree the response of the Cairngorms Nation­al Park Author­ity to the Scot­tish Biod­iversity Strategy consultation.

Recom­mend­a­tions The Board is asked to: a) Approve the pro­posed Cairngorms Nation­al Park Author­ity response (Annex I of this paper) to the Scot­tish Biod­iversity Strategy consultation.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Form­al Board Paper 3 9^th Septem­ber 2022

Stra­tegic Context

1. In Decem­ber 2020 Scot­tish Gov­ern­ment pub­lished a State­ment of Intent on biod­iversity, set­ting out their ambi­tion to take strong action to tackle biod­iversity loss. This included a com­mit­ment to pub­lish a new Scot­tish Biod­iversity Strategy (SBS) by end of 2022 to replace the exist­ing strategy pub­lished in 2013.

2. The SBS sits under the Envir­on­ment Strategy for Scot­land which cre­ates the over­arch­ing frame­work for Scotland’s strategies and plans on the envir­on­ment and cli­mate change. Its vis­ion and out­comes describe the long-term ambi­tions for Scotland’s envir­on­ment and the role in tack­ling the glob­al cli­mate and nature crises.

3. The SBS is the start­ing point in a pro­cess which will lead into the devel­op­ment of rolling deliv­ery plans and, through the intro­duc­tion of a Nat­ur­al Envir­on­ment Bill and stat­utory nature res­tor­a­tion targets.

4. Scot­tish Gov­ern­ment have launched a con­sulta­tion on the SBS Biod­iversity strategy: con­sulta­tion — gov.scot (www.gov.scot). Con­sulta­tion closes 12 Septem­ber 2022.

5. This con­sulta­tion forms part of an engage­ment pro­cess with a wide range of stake­hold­ers who have an interest in Scotland’s biod­iversity, includ­ing land man­agers, envir­on­ment­al organ­isa­tions, loc­al author­it­ies and oth­er part­ners. CNPA are rep­res­en­ted on the SBS gov­ernance frame­work on the Pro­gramme Board and in the stake­hold­er workshops.

The Evid­ence of Biod­iversity Loss

1. The Biod­iversity Intact­ness Index (BII) found only 56% of Scotland’s biod­iversity remains intact, pla­cing it in the bot­tom 25% of the 240 coun­tries and ter­rit­or­ies assessed by the BII. A head­line from the State of Nature Report revealed that there has been a 24% decline in aver­age abund­ance of 352 ter­restri­al and fresh­wa­ter spe­cies since the mid 1990’s. Peat­lands are in such poor con­di­tion that they are emit­ting, instead of stor­ing, car­bon and are respons­ible for 20% of Scotland’s total emissions.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Form­al Board Paper 3 Annex 1 9 Septem­ber 2022

Annex I — Cairngorms Nation­al Park Author­ity response to the Scot­tish Biod­iversity Strategy Consultation

Using your own know­ledge and the evid­ence presen­ted, to what extent do you agree that there is a nature crisis in Scotland?

1. The Park Author­ity agrees the evid­ence for biod­iversity loss glob­ally and in Scot­land is unequi­voc­al. This is dir­ectly rel­ev­ant to the Cairngorms Nation­al Park as we estim­ate there are around 90,000 ha of impacted peat­land and 57,000 ha of this has exper­i­enced some form of erosion. 20 % of all des­ig­nated fea­tures are in unfa­vour­able con­di­tion, with 29.4% of upland fea­tures in unfa­vour­able con­di­tion. Spe­cies decline is evid­ent too e.g. Scot­tish wild­cat, a once wide­spread spe­cies is now on the brink of extinc­tion with the wild pop­u­la­tion being clas­si­fied as func­tion­ally extinct. Cale­do­ni­an pine­wood spe­cial­ist twin flower has declined by 44% nationally.

2. The Cairngorms Nation­al Park is one of the key places to tackle the nature crisis and the recently approved Nation­al Park Part­ner­ship Plan has this as one of its core objectives.

What do you see as the key chal­lenges and oppor­tun­it­ies of tack­ling both the cli­mate and biod­iversity crises at the same time?

1. The Park Author­ity agrees the twin crises are inter­linked and reen­for­cing, build­ing the urgency and pro­file of the chal­lenges faced by all land man­age­ment in Scot­land. They also provide oppor­tun­ity to bring in new deliv­ery mech­an­isms and part­ners and poten­tially fin­ance to deliv­er on the scale required. How­ever, we need to ensure good inform­a­tion and evid­ence informs decisions and that address­ing one crisis does not take pre­ced­ence over the oth­er. For example, ensur­ing wood­land cre­ation hap­pens in the most suit­able loc­a­tion to max­im­ise bene­fits for biod­iversity in terms of con­nectiv­ity, hab­it­at het­ero­gen­eity and qual­ity along­side stor­ing and seques­ter­ing carbon.

2. The Park Author­ity wel­comes the dir­ec­tion in the SBS and high­lighted activ­it­ies to address issues that deliv­er for both car­bon stor­age and sequest­ra­tion and biod­iversity loss and nature recov­ery e.g. herb­i­vore impact on wood­land regen­er­a­tion and peat­land restoration.

3. The Park Author­ity recog­nises and sup­port the need for more evid­ence to inform rap­idly evolving under­stand­ings of the car­bon poten­tial of dif­fer­ent land use types, how­ever this needs to be con­sidered along­side the need to move at scale and speed.

4. There is clear oppor­tun­ity to pro­mote and sup­port nature based solu­tions, devel­op new rur­al pay­ment schemes that deliv­er for nature and build cli­mate resi­li­ence, demon­strate and pro­mote best prac­tice and provide sup­port for land own­ers and managers.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Form­al Board Paper 3 Annex 1 9 Septem­ber 2022

Vis­ion

Is the draft vis­ion clear enough? Is the draft vis­ion ambi­tious enough?

1. Over­all, the Park Author­ity wel­comes the vis­ion and level of ambi­tion of the SBS. There is clear align­ment with the new Nation­al Park Part­ner­ship Plan (NPPP) and the Cairngorms Nature Action Plan (CNAP). The Park Author­ity con­sider the NPPP and the CNAP to be the dir­ect deliv­ery mech­an­ism to deliv­er this SBS vision.

2. Restor­ing eco­sys­tem health and increas­ing spe­cies rich­ness, diversity and abund­ance is core to achiev­ing the 2045 vis­ion of restored and regen­er­ated biod­iversity. Work­ing on a land­scape scale achieves great­er out­comes for biod­iversity and max­im­ises oppor­tun­it­ies for res­tor­a­tion, regen­er­a­tion and build­ing of resi­li­ence. The park Author­ity has been work­ing at this scale for some time and con­tin­ue to do so in the new NPPP.

3. The Park Author­ity fully appre­ci­ates the import­ance and bene­fits of involving a wide range of land man­agers, com­munit­ies, vis­it­ors and organ­isa­tions in pro­tect­ing and restor­ing Scotland’s biod­iversity, fully integ­rat­ing nature recov­ery into the wider land­scape and soci­ety as a whole, and wel­come the dir­ect recog­ni­tion of this in the Vision.

4. The Park Author­ity wel­comes the ambi­tion set out in the vis­ion, acknow­ledging that more detail will be neces­sary in sub­sequent doc­u­ments to cla­ri­fy expect­a­tions. The infograph­ics provide a good visu­al rep­res­ent­a­tion of what the vis­ion looks like and we sug­gest great­er clar­ity is required in some instances, par­tic­u­larly where there is ref­er­ence to ​‘sub­stan­tially restored’ hab­it­ats and there may be a lack of com­mon under­stand­ing around what that means in practice.

Out­comes Framework

Do the 2045 out­comes adequately cap­ture the change we need to see? Are the 2030 mile­stones ambi­tious enough?

1. The detail con­tained with­in the forth­com­ing deliv­ery plans will be crit­ic­al to the suc­cess­ful deliv­ery of the SBS out­comes and mile­stones. We look for­ward to being involved in the devel­op­ment and imple­ment­a­tion of the SBS deliv­ery plans where meas­ur­able out­comes and actions will be required to ensure the 2045 out­comes and 2030 mile­stones are realised.

2. The object­ives and tar­gets in the recently approved Nation­al Park Part­ner­ship Plan strongly align with and echo the out­comes frame­work in the SBS and we are there­fore very sup­port­ive of the ambi­tion and dir­ec­tion; notably:

   a) SBS out­comes and mile­stones for farm­land prac­tices increas­ing biod­iversity, stor­ing car­bon and pro­tect­ing soils, while sus­tain­ing high qual­ity food pro­duc­tion are dir­ectly reflec­ted in the NPPP object­ive to ​‘Work with farms in the National

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Form­al Board Paper 3 Annex 1 9 Septem­ber 2022

Park to reduce their car­bon foot­print, con­serve soil car­bon, encour­age sus­tain­able pro­duc­tion and deliv­er increased biod­iversity on in-bye land’. The Park Author­ity wel­comes the recog­ni­tion that a reformed agri­cul­tur­al sub­sidy scheme is cent­ral to the deliv­ery of this outcome.

b)  SBS outcomes and milestones that enable natural regeneration of woodlands, greater diversity of woodland species and woodland age structure and increased woodland cover and connectivity are directly reflected in the NPPP objective to 'Increase the amount of woodland in the National Park to support larger, more natural woodlands, expanding in places up to a natural treeline, providing connections across river catchments and around the central core of the mountains'.

c)  The milestone to reduce the number of deer and their impacts alongside other herbivore impacts to enable peatland restoration, natural regeneration of woodlands and increased structural diversity in our uplands is directly reflected in the NPPP objective to ‘Reduce the negative impacts of red deer and other herbivores across the National Park to enable woodlands to expand, heather loss to be reversed, peatlands to recover and wider biodiversity and landscape enhancements to take place'.

d)  Proposed freshwater outcomes and milestones for restoring catchments, improving ecological status and increasing the extent, condition and connectivity of freshwater systems are delivered through the NPPP objective to ‘Restore and connect rivers to thriving wetlands and floodplains as part of a wider restoration of the National Park's freshwater systems, helping mitigate the impacts of climate change'.

e)  Proposed outcomes for delivering diverse nature networks, embedded in wider land use, that increase the health and resilience of ecosystems are directly reflected in the NPPP objective to ‘Connect habitats and ecosystems across all different types of land use in the National Park to create an ecological network, which will bring wider landscape, biodiversity and people benefits'.

Are there any key ele­ments missing?

1. We wel­come a land­scape scale res­tor­a­tion approach, how­ever the Park Author­ity feels there needs to be recog­ni­tion and mech­an­ism for tar­geted action for spe­cies. The Park Author­ity feels that whilst the recov­ery of hab­it­ats and eco­sys­tems at a land­scape scale is the long-term sus­tain­able solu­tion, there are some spe­cies that require tar­geted indi­vidu­al focus to get them back on a sus­tain­able foot­ing. We recom­mend that the Scot­tish Biod­iversity Strategy overtly recog­nises this need for spe­cies con­ser­va­tion in the short to medi­um term.

2. There should be more recog­ni­tion of pro­tec­ted sites, spe­cific­ally the role they can play as nodes in an eco­lo­gic­al net­work and the rela­tion­ship between des­ig­na­tions and eco­sys­tem res­tor­a­tion, resi­li­ence and adapt­ab­il­ity to cli­mate change impacts. This should not how­ever sub­sti­tute or detract from the import­ant role and recognised

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Form­al Board Paper 3 Annex 1 9 Septem­ber 2022

need for nature recov­ery to be fully integ­rated into wider land man­age­ment, rather it should high­light how pro­tec­ted sites can add value.

What evid­ence and inform­a­tion should we use to assess wheth­er we have delivered the Vision?

1. One of the chal­lenges will be to fur­ther define the end points of ​‘sub­stan­tially restore’ and/​or define the met­rics which would meas­ure pro­gress towards the kind of change we want to see. Cur­rent met­rics and data col­lec­tion may be focussed on pro­tect­ing exist­ing con­di­tion, hab­it­ats and spe­cies. The vis­ion is for the kind of change we need to see in light of the twin crises and new met­rics will be needed to assess pro­gress towards func­tion­ing hab­it­ats with assemblages that may not cur­rently exist. A focus on hab­it­at res­tor­a­tion and eco­sys­tem func­tion­al­ity may mean less of a focus on mon­it­or­ing indi­vidu­al species.

2. Exist­ing data sets and mon­it­or­ing frame­works (e.g. Water Frame­work Dir­ect­ive, WeBS, Wild­life Estates Scot­land) will be a good start­ing point to mon­it­or change from. We sup­port a crit­ic­al exam­in­a­tion of what the indic­at­ors might be for the land­scapes and assemblages we want to see in a sub­stan­tially restored, func­tion­ing and resi­li­ent eco­sys­tem, whilst recog­nising that it is import­ant that cur­rent hab­it­at and spe­cies data is mon­itored to fully under­stand how land man­age­ment change is affect­ing the dis­tri­bu­tion and abund­ance of some species.

3. The Cairngorms Nature Index is an excel­lent tool to provide evid­ence. The CNI has been developed closely with NatureScot input and we are keen for NatureScot and Scot­tish Gov­ern­ment to see the Nation­al Park as lead­ing the way in devis­ing a meth­od­o­logy to exam­ine eco­sys­tem health and func­tion­al­ity. The CNI will help define what ​‘restore and regen­er­ate’ looks like in the Nation­al Park, meas­ure pro­gress and provide evid­ence to show biod­iversity bene­fits. This will be hugely import­ant as there is a great­er shift towards fund­ing and oth­er inter­ven­tions being based on evid­ence of what works and on eco­sys­tem res­tor­a­tion outcomes.

Con­di­tions for success

Has the pro­pos­al cap­tured the key enabling factors which are essen­tial in order for the SBS strategy to be successful?

1. The Park Author­ity is very well placed, and a good example of how to cre­ate the right con­di­tions for suc­cess. There are already a num­ber of action plans and strategies, advis­ory groups, dis­cus­sion fora and lines of com­mu­nic­a­tion with stake­hold­ers that sup­port strong lead­er­ship, gov­ernance and inclus­ive engagement.

2. Object­ives in the NPPP demon­strate CNPA, and part­ners’ com­mit­ment to cre­at­ing the right con­di­tions for suc­cess that deliv­er mul­tiple eco­lo­gic­al and socio-eco­nom­ic bene­fits; not­ably object­ives to:

   a) Use private green invest­ment in the Nation­al Park to fund nature’s recov­ery and share the bene­fits between com­munit­ies, landown­ers, work­ers and wider society.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Form­al Board Paper 3 Annex 1 9 Septem­ber 2022

b)  Increase skills and training opportunities for people in the National Park to meet business needs and ensure opportunities created by the growth in green jobs can be filled by residents and under-represented groups.

c)  Improve the mental and physical health and wellbeing of the people of the National Park through greater connection with nature and the outdoors.

d)  Increase the number of volunteer days spent caring for the National Park, taking an inclusive approach to volunteering recruitment.

e)  Support and deliver opportunities for outdoor learning, linked to the special qualities of the National Park.

f)  Welcome visitors and provide a high-quality experience while managing their impacts through providing better infrastructure and high-quality ranger services

1. We par­tic­u­larly wel­come the recog­ni­tion of pub­lic engage­ment and com­mu­nic­a­tions as a pro­posed out­come, includ­ing the inclu­sion of a focus on young people and out­door learn­ing, cit­izen sci­ence, the engage­ment of loc­al com­munit­ies of place and interest, volun­teer­ing and beha­vi­our­al change. The Cairngorms Nature Action Plan includes ​‘Involving People’ as a stra­tegic object­ive and we have exper­i­ence to offer from our Her­it­age Hori­zons and Cairngorms Nature programmes.

Sarah Hen­shall 29 August 2022 sarahhenshall@​cairngorms.​co.​uk