The Royal Society of Edinburgh (RSE) is pleased
to respond to the Scottish Natural Heritage's (SNH) consultation on
the Natural Heritage Zones Programme. The RSE is Scotland’s premier
Learned Society, comprising Fellows elected on the basis of their distinction,
from the full range of academic disciplines, and from industry, commerce
and the professions. This response has been compiled by the General
Secretary with the assistance of a number of Fellows with substantial
experience of land use and the environment.
These SNH documents provide a quite comprehensive attempt to set out
a forward vision and series of ‘plans’ for the whole of
Scotland and provide an interesting basis for a stimulating discussion.
However, it is unclear how SNH will use the Programme to deliver the
actions listed under the different thematic programmes, nor is the connection
clear between the 6 themed national prospectuses and the 21 Natural
Heritage Zones.
In addition, it is unclear whether the stakeholders have been pre-consulted
about their envisaged roles or not. For example, the documents set out
tabulated summaries of the roles of the various stakeholders in the
process of sustainable development, but curiously do not list SNH, leaving
some uncertainty about SNH’s proposed role. If the publication
has been initiated ‘top down’ there is a risk that the spirit
of partnership that SNH wishes to promote across the range of agencies
and organisations that SNH has identified as stakeholders may not be
furthered by the documents. Partnership implies equals working together,
and most organisations are keen to engage in their own agenda setting.
Specific comments on the Overview and different National Prospectuses
are addressed below:
Overview
The Overview document ‘The Diversity of Scotland’s Natural
Heritage’ is a wide-ranging and aspirational paper on sustainable
development, encompassing the challenge of integrating local sustainability
with the wider global sustainability. The statement ‘We need better
stewardship of our own resources without imposing inequitable demands
on people and natural resources outside Scotland’ (para. 13) sets
a national standard that few developed countries aspire to - and even
fewer manage to achieve. The document, however, has very little detail
on the nature of and reasons for the 21 National Heritage Zones, and
there would have been merit in providing a summary of the salient characteristics
and scientific justification of the individual Zones.
In terms of some specific points:
- In paragraph 1, mention could be made of the high productivity
of Scottish waters, the fjordic ecosystems of the west coast that
introduce deep-water elements into nearshore waters, and the rich
and varied fish stocks that are so much under threat. It is this richness
and diversity that is the basis for the great importance of the seas
and coasts around Scotland.
- In paragraph 15, it should be emphasised that "Technological
Advances" include the ability to fish previously abundant stocks
to economic extinction. At the end of paragraph 15, reference is also
made to ‘decreasing soil fertility’. However, there is
little evidence that there has been any recent-timesloss of soil fertility
in Scotland which has not been caused by the economics of agriculture
and the associated reductions in fertiliser application (including
lime).
- Mention is also made (Box 1) of the paucity of marine data. While
much remains to be discovered, Scotland with its long-established
Marine Stations, Universities and Fisheries Laboratories has a long
history of marine research and observation and is far from lacking
in marine data.
Coasts and Seas
Summary
The summary (paragraph 3) could make reference to the human demands
of shipping, energy and other mineral resource exploitation, pipeline
and tele-communication usage, military requirements, and renewable energy
possibilities. It might also be mentioned that the key objectives and
issues identified in para 5 are not in order of priority, but all are
important.
Description of the Natural Heritage
With regard to the description of bird populations on high cliffs, if
the rare petrel colonies referred to involve Leach’s Petrel, it
should be noted that this bird is not rare internationally, with an
estimated world population of 7-9 million pairs. The paragraph also
gives the impression that the puffin is confined to the Isle of May
and Rum. However, the majority of breeding puffins are in Shetland.
In addition, raised beaches and their fragile marshland habitats should
get special mention as many continue to be damaged by drainage and poor
farm management.
Key Influences
The key issues affecting the coasts and seas of Scotland have been noted
and, in the main, addressed. Some specific comments include:
- In terms of the threat of alien species, no mention is made of mink,
which can destroy ground nesting seabird colonies such as those of
terns on a large scale in some areas of Scotland. Another (botanical)
example could be the spread of sea buckthorn in certain dune systems.
Some mention, here or later, should be made of the need to control
rat populations on islands and islets. These have had significant
effects on the breeding success of a number of sea-birds and are a
major conservation problem.
- In terms of coastal aquaculture, mention might be made of the conflicts
that arise as a result of predator control at fish and shellfish farms,
and of the harvesting of algae for food and for the alginate industry.
- On the topic of fisheries, paragraph 60 mentions that some seabird
populations have been ‘unbalanced’ by fisheries discards.
However, the evidence supporting the suggestion that discards have
played a role in the population increases of some species, is not
strong.
* With regard to estimates of the size of sustainable yields for the
exploitation of new species, a lot of research has been conducted
in this area and reference should be made to acting upon this existing
knowledge as well as to the need for new research.
- In terms of the oil and gas industries, mention could be made of
the continued deposition of oil residues in coastal habitats (in addition
to significant spills), and the impact of major on-shore developments
which have destroyed or modified important coastal habitats (e.g.
by pipe-line landfalls and crossings).
- With respect to alternative energy sources, it should be noted that
these technologies are not without their own environmental impact.
For example, off-shore wind generators could pose a threat to migratory
birds in certain areas. Tidal power is also dismissed a little too
readily as not all tidal power systems require the use of tidal barrages.
Vision
The proposed vision is sound, but in order to be achieved in 25 years
will require adequate funding and a lot of National and International
agreement.
Objectives
The objectives address the key issues and, for the most part, are appropriate.
The proposed actions are also relevant and will need to be taken up
quickly if the vision is to be achieved. In particular the RSE would
support further research and development on the ‘soft engineering’
approach to sea defence, and on the establishment of Integrated Coastal
Zone Management and marine protected areas.
In terms of specific comments, it is not clear how wildfowling on intertidal
mudflats (para. 99) can be expected to contribute to the 'physical integrity
and high biodiversity of these habitats'.
Key Stakeholders
Additional key stakeholders, could include the British Geological Survey
who are responsible for creating and maintaining the earth-science databases
for Scotland, both on- and off-shore. The data and staff resources available
in Murchison House, Edinburgh could be engaged with advantage in many
of the actions and associated research projects envisaged, especially
in the context of the physical and chemical properties of the sediments
and rocks on the coast and beneath the sea, with particular reference
to pollution, engineering and stability matters. Other potential stakeholders
include Oil Companies and Coastguards.
Forests and Woodland
Key Influences
With regard to climate change, the importance of tree cover in carbon
sequestration is recognised in the document but care must be taken that
this role does not subvert the need to maintain other habitats which
are important for biodiversity.
Vision
While accepting the main components of the Vision, it is over-optimistic
as a vision for 2025. This is inherent in the long time-scale for forest
re-growth, expansion and even for the creation of new 'native' woods
by planting.
Objectives
The list of objectives appears to list things which should already be
being undertaken, although inherent in much of this section is the need
for imaginative planning on a large scale, for example river catchment
planning. In terms of specific comments, mention could be made of the
interaction between forest and woodland expansion and archaeological
interests, and the use of some types of woodland for the cultivation
of edible fungi.
Key Stakeholders
Possible additional stakeholders include the Game Conservancy Trust
and the National Trust for Scotland.
Mountains and Moorland
Description
In the section on geology and geological history, more could be made
of Scotland's special alpine and sub alpine soils, and the section on
global position and climate should make mention of the effects of the
North Atlantic Drift.
In terms of the 'Upland Vegetation' section, mention could be made of
Montane Grasslands which are important, especially on the more base-rich
mountains, and in terms of bird fauna, special mention could be made
of the recolonisation of Scotland by the Osprey.
Key Influences
In terms of wider social change, the challenges of switching the mountain
and moorland areas of Scotland to a knowledge-based economy are substantial
and will be difficult to achieve within a generation. Reference could
also be made to the need for effective education programmes (for both
young people and adults) to increase awareness of the natural and cultural
heritage.
Vision
In general a sound approach and a good, realistic set of aims. The section
on climate change might mention the possible loss or contraction of
area, of some of the rare arctic-alpine plants as a result of climatic
warming (not just those associated with late snow beds).
Objectives
In general the Objectives seem comprehensive and appropriate, and the
Actions also acceptable. In terms of Objective 2, 'to secure improved
diversity, and good condition of Scotland's upland habitats (and their
fauna)…', the objective should refer to both flora and fauna.
Mention could also be made of the need to maintain and even improve
biodiversity in these important areas.
Key Stakeholders
Possible additional stakeholders include Aberdeen University and the
National Trust for Scotland.
Farmland
Summary
In the summary of this prospectus it is implied that that it is unacceptable
to have ‘polarised farming’. However, there is likely to
be support for the idea that high production systems (while sacrificing
some biodiversity) are kept in selected areas and simultaneously support
the smaller farms (which may or may not be more bio-diverse and may
or may not be less economic). This is the case in France, Germany, Spain
and other EU countries.
Key Influences
In terms of the key influences, specific comments include:
- Mention should be made of the need for a well-integrated transport
system (sea, inshore, road, rail and air) in order to facilitate rural
businesses such as agriculture and tourism.
- With reference to the overriding agricultural policies, it should
be recognised that agriculture is a mature industry in most of Europe,
and that the number of people employed in mature industries will decline
as economic efficiency increases. Therefore, the decline in the number
of people working in agriculture is a natural economic trend and should
be recognised as such. There should also have been associated growth
in the value-added activities further along the manufacturing and
retailing chain, but this has been the area in which Scotland’s
rural performance has been weak.
- In terms of Paragraph 45, the statement that contract ploughing,
planting and harvesting or taking advice from consultants ‘runs
counter to the inherited traditions of land management and the sense
of stewardship’ could be contested. Most of the ‘land
stewards’ of the last century were substantial landowners who
would never have been behind a plough or have driven a harvester.
- The paragraph on soil structure and composition gives the impression
that soil compaction and erosion are major problems in Scotland. There
is little evidence that this is the case.
- With reference to consumers, trends over the past few years show
that consumers are interested in value for money not price per se.
In addition, there is no evidence for a sustained consumer willingness
to place environmental standards high on their list of value for money
measures.
Vision
The vision suggested is somewhat vague. The idea of locally-based food-processing
is attractive but is unlikely to be achieved to a significant extent
and there is no mention of the economic environment that could ensure
its success. In terms of specific comments:
- In terms of public support for agriculture, there will be a progressive
move down the route of unsubsidised agricultural production, but it
will take fully the 25 years that this vision covers. However, the
consequences of that will be the two-tier type of farming that the
paper envisages. It is inevitable that those farmers who are going
to compete in an unsubsidised market will be big, highly efficient
and geared to providing competitive, high-quality, value for money
products. The remainder will be niche players, on a local basis, or
hobby farmers.
- With regard to wildlife habitat, the idea that farmers will receive
most of their financial support from the State for managing 15% of
their land is difficult to understand in economic terms, unless the
total amount of subsidy is very small. If the latter assumption is
the case it conflicts with the remainder of the vision of subsidy
for environmental farming.
- In terms of organic farming, it should be noted that organic farming
in the UK is not a sustainable development. Reductions in yield which
result from organic farming on any scale would increase the UK’s
environmental footprint elsewhere in the world, making demands on
other peoples’ land resources. In addition, the economic viability
of the approach is dependent on maintaining a market premium to offset
the higher costs of production and lower yields. If the scale of UK
organic farming was substantially increased, prices would fall, making
organic farms economically unsustainable.
- With regard to quality production, in all modern developed economies
the largest 20% of farms produce 80% of the agricultural product.
Likewise some 80% of the retailing is in the hands of a few major
supermarkets, which demand scale in produce supply. Thus the notion
that the group of small farmers envisaged in these paragraphs will
set the ‘backbone’ for quality food is unrealistic. With
luck they may be able to create a local market niche through farmers
markets or small local retailers, but their impact on the mass market
is likely to be limited. All UK market surveys show that the consumers’
perceptions of quality relate to cleanliness, convenience, range of
choice, value for money etc – the features that are associated
with the large multiple retailers.
Objectives
The objectives are comprehensive and address the key issues. The actions
suggested all look quite familiar and in general are promoted by the
Scottish Executive Rural Affairs Department, via the Scottish Agricultural
College and other organisations including SNH. Furthermore, they form
part of most courses in rural topics (including agriculture, rural resource
management etc) taught in the further education and higher education
sectors to Scottish farmers and employees of rural businesses both past
and present. Thus most farmers who have been to college or attended
advisory, open days in-service training courses will be familiar with
most of these.
What is lacking in the documents is any hard economic assessment of
the implication of these proposals for the taxpayer, the nation, and
farm and rural business incomes - specifically, the effect of reduced
yields, coupled with reduced inputs, on farm business incomes. There
appears to be a fundamental conflict in approach between the underlying
message of free market operation (‘no subsidies for production’)
and the regulated cross-compliance suggested here. Large efficient farmers
who are directing their efforts at the ‘real’ market may
well be prepared to do without subsidy for the freedom of action a free
market would offer. This would again lead to a two-tier agricultural
approach.
Fresh Waters
Key Influences
With regard to climate change, mention could be made of the backing-up
effects of higher sea levels on rivers and estuaries. The ever increasing
demands for recreation are also likely to be one of the most serious
factors affecting the freshwater environment.
Vision
The vision is again optimistic. As far as irrigation is concerned the
need will certainly increase but this is likely to be overshadowed by
the demand for water in new housing developments. The need to control
water use more effectively will be vitally important. Mention could
also be made of the possible future demand for water supply to England,
as changing weather patterns may well result in significant changes
in water needs and distribution in the U.K, as a whole.
Settlements
Key Influences
In terms of business development, there is no doubt that a knowledge-based
economy should make it possible and easier for companies to locate outwith
the main cities. However, it has also been shown that businesses tend
to cluster, setting up their offices in the cities, where there are
existing businesses.
Objectives
With regard to developing ‘self-contained’ sustainable settlements,
where work opportunities, production of goods and retailing are all
on a local basis are likely to be countered by ease of communication,
transport and travel, together with the globalisation of the economy.
For the kinds of settlements envisaged to develop would require a reversal
of the economic development trends of the last 300 years.
Key Stakeholders
A possible additional stakeholder would be the National Trust for Scotland.
Additional Information
In responding to this inquiry the Society would like to draw attention
to the following Royal Society of Edinburgh responses which are of relevance
to this subject:
Agriculture
- Towards a Development Strategy for Rural Scotland (March 1998)
Foresight for Agriculture, Horticulture & Forestry report on Forestry
and Wood Products (January 1999)
- Non-Food Crops (May 1999)
- A Forward Strategy for Scottish Agriculture (September 2000)Conservation
- National Parks for Scotland (November 1998)
- People and Nature: A new Approach to SSSI Designations in Scotland
(November 1998)
- National Scenic Areas Review (April 1999)
- EU policy on Biodiversity (May 1999)
- National Parks (Scotland) Bill (March 2000)
- A Proposal for a Loch Lomond & the Trossachs National Park
(February 2001)
- Proposal for a Cairngorms National Park (April 2001)
- The Nature of Scotland: A Policy Statement (May 2001)
- The Sixth Environmental Action Programme (May 2001)
Energy
- New and Renewable Energy (May 1999)
- House of Commons Select Committee on Science and Technology inquiry
into wave and tidal energy (February 2001)Economy
- Developing Scotland’s Clusters (June 1999)
- A Framework for Economic Development in Scotland (March 2000)Environmental
Planning
- Study of Environmental Planning (October 1999)
- Royal Commission Study of Environmental Planning (July 2000)Freshwater
- Conservation of Salmon and Sea Trout (August 2000)
- Protecting and Promoting Scotland's Freshwater Fish and Fisheries
(August 2000)Fisheries
- The Future of the Common Fisheries Policy (June 2001).
Economy
- Developing Scotland’s Clusters (June 1999)
- A Framework for Economic Development in Scotland (March 2000)
Environmental Planning
- Study of Environmental Planning (October 1999)
- Royal Commission Study of Environmental Planning (July 2000)
Freshwater
- Conservation of Salmon and Sea Trout (August 2000)
- Protecting and Promoting Scotland's Freshwater Fish and Fisheries
(August 2000)
Fisheries
- The Future of the Common Fisheries Policy (June 2001).
July 2001
Further information is available from the Research Officer, Dr
Marc Rands |