Response 684113271

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Contact details and publishing consent:

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Royal Scottish Forestry Society
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c/o Admiministrator,The Lilliebow, The Stell,
Kirkudbright,
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DG6 4SA
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Vision, Objectives and Principles

1a. Do you think that the Vision, Principles for Sustainable Land Use and three long term Objectives are still fit for purpose?

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Radio button: Ticked Yes
Radio button: Unticked No
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1b. Please provide your reasons for your answer.

1b
We believe there is scope to optimise sustainable land-use outputs .
We strongly support measures to help urban and rural communities to better understand land use issues.

Natural Resource Management

2a. Do you agree that continued use of an ecosystems approach is an effective way to manage Scotland's natural capital?

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Radio button: Ticked Yes
Radio button: Unticked No
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2b. Please provide reasons for your answer.

2b
We instinctively agree with an ecosystems approach.
But we think that the evidence that the monetization associated with an ES approach is an effective way of managing natural capital is open to discussion. It involves the creation of artificial markets and putting a price on things that are extremely difficult to value. We need more evidence that this is the most effective way to proceed.
Scotland's Natural Capital Asset Index is superficially interesting. But to be of any practical value it needs to be expressed on a regional, preferably catchment, basis. And the "direction of travel" of each element needs to be understood in order that the correct remedial measures can be applied in the right place.
We suggest that the language of "Natural Capital" and "Ecosystems Approach" is not understood by many in the land management community and elsewhere. This must be expressed in plain English and will take time to learn.
Not to do this potentially empowers a group of remote bureaucrats rather than local communities.
An ecosystems approach could be an effective way of managing Scotland’s ‘Natural Capital’, but with provisos that:-
• ecosystems are complex in their composition and structure, but especially in their functioning, and are influenced by many interacting factors.

• ecosystems are dynamic and change constantly in structure and function due to internal processes and external factors, even without input from humans.

• simple prediction of management outcomes is therefore impossible

• the ecosystem approach should therefore be used with caution.

Policy Alignment

3a. Is the relationship as set out in the draft Land Use Strategy 2016 - 2021 clear?

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3b. Do you have any comments on the relationship between the LUS and Scotland’s Economic Strategy 2015, National Planning Framework, National Marine Plan and other relevant policies?

3b
We believe that policies on forestry, agriculture, peatland and soils are vital, must inter-relate with each other and must each form a part of the land-use strategy. Thus they will help optimise the delivery of economic and other benefits from Scotland's land. We are not so clear that planners in local authorities do understand an ecosystem service approach.

Planning

4a. Do you think that the activities described above could be useful?

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Radio button: Ticked Yes
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4b. Do you have any suggestions on other kinds of information and activities that could be useful?

4b
A qualified Yes: This major LUS2 document should be sufficiently clear for planners and others to understand its relevance without further explanation. If insufficiently clear and explanatory, then perhaps the LUS2 is over-complex.
Raising awareness of an additional tool for the planning process might be perceived by users as potential overload of an already cumbersome system.
No other suggestions.

Forestry

5. How could the content of the current Scottish Forestry Strategy be updated to better reflect the Objectives and Principles of the Land Use Strategy and other key priorities?

5
If, as we believe, this Land Use Strategy has, as a central purpose, the facilitation of soundly-based land-use change, the Scottish Government (SG) should take the necessary steps to ensure that its own planting target is met. The Woodland Expansion Advisory Group (2013) made 24 good recommendations to SG. We question what progress has been made with their implementation. In any event we recommend that much of this work should be incorporated in the up-dated strategy.
We recognise that any decision to convert land to forestry will involve a trade-off of ecosystem services. We submit that, in view of the serious shortfall in meeting the SG planting target, there should be, for a sufficient period of time, a presumption in favour of planting in the absence of constraints.
The case for carefully situated new woodlands in upper catchments to aid flood amelioration should become an immediate priority across Scotland.

Land Reform

6a. Do you consider that there could be advantages in having a single policy statement about land which deals with ownership, use and management?

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Radio button: Ticked No
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6b. Do you have any comments on the relationship between current land related policies and how these would relate to a single policy statement?

6b
We consider there would be major disadvantages in this single policy statement. Throughout the pilot phase we were repeatedly assured by senior SG officials that the LUS and Land Reform processes were separate and in considering the LUS pilot we should not be considering LR. Now there is a question of reversing that.
We submit that there are here two policies which are regarded, rightly or wrongly, by many land-owners and managers as a threat to their interests. Compounded, they will meet with stiff resistance. Thus far, we believe there is wide-spread ignorance or mis-comprehension as to the purpose of the LUS. The first priority of SG should therefore be to explain this in simple English in order to encourage owners and managers to engage positively with the new strategy without the added fear of land reform.

Ecosystem Services Mapping and Tools

7a. Do you agree that models and GIS tools could help inform decision making about land use/management change?

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Radio button: Ticked Yes
Radio button: Unticked No
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7b. Please provide your reasons for your answer.

7b
The utility of these tools depends upon the quality of the assumptions that are built into the models. For example, we know that some forestry models are less than adequate for managing complex stands, so how certain are we that existing models of land-use reflect the complexities of, for example, afforesting upland catchments to constrain water flows?
A range of stakeholders will invariably be involved in land-use change decisions.
Therefore sensible decisions should always be based on a correct assessment of the present situation and the potential options for single or multiple benefit land use.
The point is to use the maps to identify opportunities.

7c. Do you think a baseline ecosystems services mapping tool could be useful?

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Radio button: Ticked Yes
Radio button: Unticked No
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7d. Do you have any comments on a mapping tool?

7d
Yes; but this depends upon the practicality of doing this. To take another example, mapping bird populations across Britain for the last census (2008-2011) involved hundreds of volunteers and several years of data processing. How easy is it going to be to develop a generic tool that can encompass a wide range of ecosystem services?
It could become perverse and counter-productive if granularity were to result in mis-appreciation of a local situation. Such a tool should never cancel out local knowledge and experience

Regional Land Use Partnerships

8a. Do you agree that regional land use partnerships could be a helpful way to support regional delivery of the Land Use Strategy?

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Radio button: Ticked Yes
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8b. Who do you think could be best placed to lead these initiatives?

8b
Tweed Forum would be a good example of such a partnership in action.

8c. Can you suggest any alternative means of supporting the delivery of the Land Use Strategy at regional level?

8c
There is an inherent level of complexity built into the system which is probably unavoidable. If you try to make it too simple it will become meaningless. Stakeholders will engage at a level they are comfortable with. It must be accepted that a significant proportion of the population will never engage with the LUS as they see little relevance in it to them. However, a strong environmental educational programme is urgently needed for both urban communities and rural land users.

8d. Do you have any other comments on this policy?

8d
A forum is a place where knowledge can be developed in a co-operative way and differing opinions can be resolved.
We would sound a cautionary note.
Objective 3 states:
"Urban and rural communities better connected to the land, with more people
enjoying the land and positively influencing land use"

Enjoying...and positively influencing are very different matters.
Involving local communities in land use decisions is admirable in principle and already works well in many places. But, to add value to decisions and be relevant, individuals must know what they are talking about and stick to that.

Regional Land Use Frameworks

9a. Do you think that regional land use frameworks could be useful to inform regional/local land use decision-making?

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Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know

9b. Which aspects of this approach do you think requires further development?

9b
We say yes, but with caution.
We think there is a risk that a framework may be seen as a rigid superstructure imposing yet more regulation. The proposal should be explained in simple terms in such a way as to encourage interest and offer very easy access to farmers and other land-users, many of whom do not have access to professional advice or the time to learn complex new procedures.

9c. Do you have any comments on this proposal?

9c
Terms such as ecosystems approach, natural capital, resilience and sustainabilty mean little or nothing to many people. Explanation is required which draws on practical local example rather than jargon.

Land Use Mediation and Facilitation

10a. Do you think that land use mediation or facilitation could be useful in a land use context?

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Radio button: Ticked Yes
Radio button: Unticked No
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10b. Please provide reasons for your answer.

10b
Reconciliation of different opinions re differing land-use options could become complicated and could be most readily resolved through an organisation such as Tweed Forum where it exists. We submit that this catchment-based a model is well worth replicating.
We repeat our point that using such a forum to resolve the tensions that will arise through the Land Reform agenda will risk losing much of the benefit generated in the Land-Use sphere.

Agriculture

11. Do you have any suggestions on other potential measures to encourage climate friendly farming and crofting?

11
This question assumes that much of farming is currently climate un-friendly and we do not adequately understand what this means.
Soil conservation is fundamental to all land-use. If that is ignored there is no sound basis for any other provision of ecosystem services. Maximisation of carbon stocks in soils and peatland should be a priority.
Reduction of greenhouse gas emissions and nutrient loss to water systems is also vital.
But we submit that these issues should be addressed through CAP cross-compliance.

Agri-Environment

12a. Do you agree that more localised map-based ecosystems assessments could be useful to assist in informing funding decisions?

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Radio button: Ticked Yes
Radio button: Unticked No
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12b. Please provide your reasons for your answer.

12b
Yes, but with caution. Local knowledge and land use history must be included as data sources for mapping or within attached reports.

Difficulties may arise if all regions of Scotland have not been covered by maps simultaneously because land owners, managers and local residents in areas without maps and forums or partnerships may feel that their locality is being assessed by different criteria.

Agri-Environment

13a. Do you agree that an assessment of ecosystems health and a spatial approach could be helpful to further inform targeting for the next SRDP?

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Radio button: Unticked Yes
Radio button: Unticked No
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13b. Please provide your reasons for your answer.

13b
We have reservations about how decisions will be made, and by whom, regarding the assessment of ecosystem health. This potentially a very complex issue open to differing interpretations.
We also submit that the old challenge fund approach to targeted delivery of support gave demonstrable best value and should be re-considered.

Urban Land Use

14a. Do you agree that an urban pilot project could be useful?

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Radio button: Ticked Yes
Radio button: Unticked No
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14b. Please provide your reasons for your answer.

14b
There is a huge resource of urban open space, some green, some less so. There will always be competition between differing land-uses which could best be resolved by an eco-systems approach.
Some cities (such as Birmingham) are working hard on improving their urban green spaces.
Edinburgh did a lot of excellent tree planting with the benefit of Millennium Forest for Scotland funding. We recommend an assessment of how well those woods have been managed since establishment and what eco-system services are being provided.

Upland Land Use

15a. Do you think that a strategic vision could be useful for the uplands?

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Radio button: Ticked Yes
Radio button: Unticked No
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15b. Do you have any comments on this proposal?

15b
We believe that Scotland's uplands represent a huge asset which is seriously undervalued and under-utilised. This is a complex issue about which there have been many studies but very little has changed.
Development of a mixed woodland and farming economy in the uplands could increase the productivity and profitability of hill farms without depleting rural communities or food security.
We believe there is here a huge opportunity to increase biodiversity and encourage wider recreational land use.
In particular we submit that carefully-situated and designed woodland planting in upper catchments should be addressed as an immediate priority.
The report of the Royal Society of Edinburgh on upland land use is relevant.

Monitoring Delivery of the Strategy - the Land Use Strategy Indicators

16a. Do you agree that the Land Use Strategy indicators are still fit for purpose?

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Radio button: Ticked Yes
Radio button: Unticked No
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16b. Do you have any comments on the future monitoring of the revised Land Use Strategy?

16b
No

General Questions

17. Are there any other activities that you think we should be undertaking to achieve better understanding and application of the Principles or delivery of the Strategy?

17
Notwithstanding the diligent work on the two pilots we believe that the land-owning and managing community is largely unaware of the LUS and its implications for them and their businesses. Of those that are, some regard it as yet another regulation / threat.
Many do not understand natural capital, ecosystem services etc and this consultation would leave them cold.
Most farmers are under severe financial pressure at present and timber returns are much reduced.
Farmers and foresters will not be amenable to what they may see as interference in their businesses by people who do not understand it. That would be totally different if they could see some improved return to themselves.
As soon as possible following this consultation SG should prepare briefing material in plain English, explaining how and when it will help them, not the many stakeholders who preside over them, to make better decisions about their own businesses and livelihoods.

18. Are there any other points you wish to make about any aspect of this draft Strategy?

18
• We feel that the strategy is rather complex and prescriptive. Ingenuity, individuality and ‘thinking outside the box’ are given little space in its scenario

• It must have clear and achievable goals. It will fail if it is too broad, too vague or too difficult for individuals to engage with.

• Incentivisation plays a major role in land use ie; agricultural subsidies, forestry subsidies & conservation subsidies. A land use opportunity mapping tool, coupled with publicly agreed priorities, linked to an appropriate incentive programme, could have a very beneficial effect on the land management planning process.
• Will Land Use Partnerships improve upon the current system of statutory consultees, public comment, and liaison between landowners or managers and local people?
• Will the two systems operate together (duplication) or will statutory authorities lose their present consultation and advisory role when Land Use Partnerships are set up? Will Land Use Partnerships be voluntary or paid?

Equalities

19. Do you have any comments on the policies and proposals in this draft Strategy in terms of how they may impact on any equalities group, i.e. with regard to age, gender, race, religion, disability or sexuality?

19
No

Questions on the Environmental Report

20a. Do you consider that the Environmental Report set out an accurate description of the current environmental issues/baseline?

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20b. Please give reasons for your answer.

20b
It is difficult to ascertain how the Environmental Report and Assessment differs from the Strategy: it seems to repeat the intentions and measures of the Strategy without providing data on which to base its conclusion that no negative effects could be foreseen.

21a. Do you consider that the predicted environmental effects as set out in the Environmental Report are accurate?

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Radio button: Unticked Agree
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21b. Please provide reasons for your answer including further information you feel should be considered in the assessment.

21b
The SEA should contain an analysis of the Strategy’s possible effects. However, for the Environment, it is not possible to predict what the effects of land use change will be, because of the many complex, dynamic factors which contribute to making-up and impinging upon an environment. If there is quantitative data as a basis, prediction might be possible, but only within given statistical limits or as broad generalisations.

22a. Do you consider that the recommendations and opportunities for mitigation and enhancement are accurate?

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22b. Please provide reasons for your answer.

22b
Linking potential environmental and land use change with existing Government strategies and measures is possible; however, if Local Partnerships are to provide the framework for the Strategy, then unofficial links between members and their constituencies would be far more effective than fixed rules to be followed

23. Are you aware of alternatives to the proposed policies that should be considered as part of the Strategic Environmental Assessment (SEA) process conducted for the draft Strategy?

23
No.
There are certain to be negative effects upon some people, some environments, some ecosystems and some species - because any change in land use will be positive for some people, some ecosystems and some species, but negative for others.
A change in land use will seldom be simply positive or negative: it is usually both.