30 by 30 biodiversity commitment consultation response

Mat­thew Bird Biod­iversity Team Lead­er Nat­ur­al Resources Divi­sion Scot­tish Gov­ern­ment [email protected]

Dear Mat­thew

Cairngorms Nation­al Park Author­ity 14 The Square Grant­own on Spey PH26 3HG

T: 01479 873 535

28 May 2024

Response to meet­ing our ​‘30 by 30’ biod­iversity com­mit­ment consultation.

Cre­at­ing flex­ib­il­ity for des­ig­nated sites

In our pre­vi­ous response to the Biod­iversity Frame­work con­sulta­tion on Nature Net­works and 30 x 30 (Decem­ber 2023), the Park Author­ity con­cluded that the vis­ion for ‘…evolving, flex­ible and resi­li­ent Nature Net­works allow­ing wild­life and nat­ur­al pro­cesses to adapt…’ was at odds with the cur­rent des­ig­na­tion sys­tem in the Cairngorms; and that the Park Author­ity would like to see a review of the des­ig­na­tion sys­tem to allow for a more mobile and adapt­ive approach to pro­tect­ing biod­iversity which allows the neces­sary change in the landscape.

As such we very much wel­come an approach that accounts for the func­tion­al­ity of land­scapes and eco­sys­tems as well as indi­vidu­al fea­tures. This is aligned with, and sup­ports deliv­ery of, the Nation­al Park Part­ner­ship Plan out­come for ​‘A car­bon neg­at­ive and biod­iversity rich Nation­al Park with bet­ter func­tion­ing, bet­ter con­nec­ted and more resi­li­ent eco­sys­tems’; and spe­cif­ic object­ives for cre­at­ing nature net­works and increas­ing the area of land man­aged prin­cip­ally for eco­sys­tem restoration.

In the Cairngorms Nation­al Park there sev­er­al instances where the cur­rent approach to des­ig­nated sites lim­its the abil­ity to deliv­er the Cairngorms Nation­al Park Part­ner­ship Plan and the Scot­tish Biod­iversity Strategy. For example, cur­rently there is a require­ment on some SSSIs or SACs to cut or burn nat­ur­ally gen­er­at­ing nat­ive trees when they grow on dry heath, and an inab­il­ity to restore moun­tain wood­land in SACs because some miss­ing, eco­lo­gic­ally sig­ni­fic­ant tree spe­cies are not con­sidered to be part of the qual­i­fy­ing fea­tures. In both these cases the

restric­tions on adapt­a­tion brought about by a fea­tures-based approach is restrict­ing the cre­ation of nature net­works and the res­tor­a­tion of func­tion­ing ecosystems.

An eco­sys­tems-based approach that accom­mod­ates planned pos­it­ive change and nat­ur­al suc­ces­sion, with the option to add fea­tures as well as trans­ition­al hab­it­ats, would remove some of these bar­ri­ers to eco­sys­tem res­tor­a­tion and the cre­ation of nature net­works in the Cairngorms.

Pro­act­ive man­age­ment of pro­tec­ted areas and oth­er import­ant areas for biodiversity

The Park Author­ity feels the legis­la­tion needs to reflect the urgent need to respond to chron­ic threats facing nature, includ­ing any his­tor­ic­al eco­lo­gic­al degrad­a­tion that occurred long before designation.

The Park Author­ity con­siders that cur­rent man­age­ment agree­ments and con­sent orders could be rein­forced with great­er powers. These would need to clearly demon­strate eco­sys­tem func­tion and nature-based solu­tions to cli­mate change. In the Cairngorms, these should use the Nation­al Park Part­ner­ship Plan as a guid­ing doc­u­ment to help identi­fy where they would have the most sig­ni­fic­ant bene­fits, with the Park Author­ity tak­ing an act­ive role in any process.

The Park Author­ity agrees there should be a defined and trans­par­ent pro­cess, with man­age­ment agree­ments and incent­ives to keep pos­it­ive hab­it­at man­age­ment going. We think there is a need to provide more secur­ity through long-term fin­an­cial sup­port, rather than just provid­ing advice on fin­an­cial sup­port. Spe­cif­ic time lim­its should con­sider times­cales of res­tor­a­tion and the poten­tial reversal of pos­it­ive out­comes, par­tic­u­larly where pub­lic money is inves­ted into deliv­er­ing long term pub­lic benefit.

We strongly feel that inter­ested parties must include com­munit­ies and the bene­fits from res­tor­a­tion man­age­ment include oppor­tun­it­ies for com­munity wealth-building.

Yours sin­cerely

Andy Ford Dir­ect­or of Nature & Cli­mate Change