Our response to the Scottish Land Use Strategy focuses on the following: 

More could be done in the Land-use Strategy to ensure nature is not lost against the other priorities and that we achieve these target by 2030. This includes highlighting the 22 other targets from the Global Biodiversity Framework, and subsequently the Scottish Biodiversity Strategy Delivery Plan, alongside the one target (target 3 - 30x30) which is currently captured in the Strategy.

We also flag the need for meaningful indicators for measuring and reporting on success - going beyond simply coverage of different land types to include whether these land types are in healthy condition. 

The consultation can be found here: https://www.gov.scot/publications/scotlands-fourth-land-use-strategy-consultation/

Our full response can be seen here:

Q1. Do you find Map Figure 1 to be a helpful representation of current land cover?

Yes

No

Q2. How can we most effectively represent housing and renewable energy alongside current land cover maps?

Q3. What sort of information about current land use would you find useful? (and how would you use it?)

Health of the ecosystems mapped

Whether there is sustainable/ unsustainable use of the current ecosystems

Q4. Do you agree that these are the key areas that need to be delivered by Scotland’s land?

Yes

No

Q5. Are there any important land uses that you feel are missing or underrepresented in this list?

Yes

There should be further clarity on the split of commercially productive forestry and native woodland, and the percentage of those commercial forests which are non-native species versus native species.

Under nature and biodiversity only one key target area is highlighted - the creation of Nature30 sites under the 30x30 target. While an important target, it is one of many land use related targets in the SBS Delivery Plan (derived from the Global Biodiversity Framework) that sit alongside 30x30 to ensure we meet our 2030 biodiversity commitments. These should also be considered within the Land Use Strategy and action plan, including (but not limited to);

• Landscape-scale restoration (of degraded ecosystems)

• Improving the effectiveness of current protected areas

• Strategic approach for Scotland's rainforest

• Invasive Non-Native Species plan

• Substantial reduction in deer densities

• Ensure grouse more management sustains healthy biodiversity

• Nature Networks

• Effective reintroduction and reinforcement programmes

It is only all these combined that will ensure we prevent further biodiversity loss and allow for our land to recover and aid in our resilience to future pressures.

The vision outlined in the draft environment strategy will also only be possible with changes to our land use and therefore should be considered here.

Q6. How do you think data and mapping can evolve to better support our understanding of future land use and national ambitions—including the impacts, benefits, opportunities and trade-offs of change?

Using forecast mapping of upcoming changes due to climate change

Scenario mapping of how different land use changes will affect future stressors

Q7. What tools, data, or approaches would help improve this understanding over time?

Q8. Do you think the description provided captures what is meant by 'integrated landscapes'?

Yes

No

Q9. Do you agree that integrated landscapes are the most effective approach to addressing Scotland’s land use ambitions ?

Yes

No

Please give reasons for your answer

Better include ‘multiple benefits’ 

Given the make-up of Scotland’s land use, we will only be able to achieve the multitude of targets and aspirations if land use delivers for multiple things. However, it must also reflect the long-term needs of Scotland, with an understanding that the benefits associated with nature and climate take time to manifest, and that short-term demands cannot always take precedence. 

Q10. Have we identified the right factors influencing land use integration?

Yes

No

Q11. Which of these factors do you feel are the most influential?

Financial incentives

Lack of regulation and enforcement

Q12. Are there any important factors we have misse d?

Lack of stewardship/guardianship for the public good

Q13. Would the inclusion of case studies help to illustrate the practical delivery of integrated land use?

Yes

No

Q14. Would the inclusion of information on ecosystem services and opportunities for increased benefits help to illustrate the wider value of integrated landscapes?

Yes

No

Q15. Do you agree that the role of LUS4 should be to influence policy makers and regulators in order to create an enabling environment that incentivises and/or supports land managers, communities and partnerships to further integrate land use/management ?

Yes

No

Q16. Are there other ways in which LUS4 could support alignment and integration?

Q17. Do you agree with the proposed approach to developing a new vision and integrated set of objectives for the Land Use Strategy?

Yes

No

Q18. Which approach would you prefer for LUS4?

• Removal of the land use principles

• Establishment of a refreshed set of principles (if this is your preference, please tell us what you think they should cover and how you envision their application)

A refreshed set of principles could be based on the need for integrated landscapes. While there have since been other principle based policies, the land use principles remain uniquely positioned to coordinate opportunities and highlight what is required for meaningful landscape integration, as well as demonstrate the ambition required to ensure Scotland survives and thrives over the coming years. As it stands, the LUS, does not adequately express the urgency and scale of change needed in current land management

Q19. To what extent do you agree that the draft indicators provide a strong basis for measuring progress toward improved outcomes under the Nature and Climate theme?

Strongly Agree

Agree

Disagree

Strongly Disagree

Unsure

If you selected "Disagree" or "Unsure", please tell us why

Coverage doesn’t tell us anything about effectiveness/quality. 

• Condition of woodland coverage

• condition/ level of effectiveness of the 30 by 30 suites (as well as just the coverage)

Q20. Are you aware of other data sources that could be used to monitor progress towards these outcomes?

Yes

No

If yes, please highlight them

Q21. To what extent do you agree that the draft indicators provide a strong basis for measuring progress toward improved outcomes under the Jobs, Skills and Economy theme?

Strongly Agree

Agree

Disagree

Strongly Disagree

Unsure

If you selected "Disagree" or "Unsure", please tell us why.

We’d want to see increased disaggregation of age as well as other characteristics beyond age and gender

Q22. Are you aware of other data sources that could be used to monitor progress towards these outcomes?

Yes

No

If yes, please highlight them.

Q23. To what extent do you agree that the draft indicators provide a strong basis for measuring progress toward improved outcomes under the Community, Places, People and Equity theme?

Strongly Agree

Agree

Disagree

Strongly Disagree

Unsure

If you selected "Disagree" or "Unsure", please tell us why.

Disaggregation by age and other characteristics

Q24. Are you aware of other data sources that could be used to monitor progress towards these outcomes?

Yes

No

If yes, please highlight them.

Q26. Are you aware of any potential costs and burdens that you think may arise as a result of the vision and objectives within this consultation? If so please give details

The failure to recognise the scale of change required in how we manage and connect with our land risks placing significant costs on current young people and future generations. Inaction today will result in far greater social, environmental, and economic burdens for those who come after us, a generational injustice that should not be overlooked

GYBN UK responded to the consultation with a focus on highlighting biodiversity and engagement commitments that the UK committed to through the Global Biodiversity Framework. Including;

• Target 3: 30x30

• Target 10: sustainable agriculture, forestry and aquaculture

• Target 22: meaningful participation of societal groups including young people, local communities, women, and those with disabilities

We think more could be done in the land use framework to ensure nature is not lost against these other priorities and that we achieve these target by 2030. 

Our response to the consultation can be found here:

1. To what extent do you agree or disagree with our assessment of the scale and type of land use change needed, as set out in this consultation and the Analytical Annex? Please explain your response, including your views on the potential scale of change and the type of change needed, including any specific types of change.

The scale of change proposed in the Land-use Framework does not appear to match the scale of risk posed to food security from climate breakdown and nature loss, and is unlikely to enable the UK Government to meet its targets under the KMGBF. Weather is becoming less predictable and extreme events more frequent. These risks to farmers are worsened by the decline of natural capital, which reduces climate resilience and the ability to mitigate impacts like soil erosion and water stress. 

In 2024, the UK government committed to Target 10 of the KMGBF, stating all agricultural land will be sustainably managed, with increased biodiversity-friendly practices. Therefore, we would expect most agricultural land (excluding category 3 and 4 areas) to at least fall into category 2 (e.g. river buffer strips, field margins). The UK also committed to Target 3. It's unclear which land categories in the framework qualify under the 30x30 target. With only 11% of land currently meeting DEFRA’s criteria, these proposals seem insufficient. The low percentage of land change on agricultural land presented in the framework would not meet KMGBF goals.

2. Do you agree or disagree with the land use principles proposed?

Please provide any reasons for your response including any changes you believe should be made.

Agree

Co-design - co-designing policy with people and community is incredibly important - and must be done in a meaningful way with adequate dedicated time and resources. It includes seldom-heard voices, including young people and other minority groups, in decision-making to ensure the representativeness of decision-makers reflects the diversity of opinions and voices of the communities the decisions are made for. Through the KMGBF, the UK is committed to Target 22.

Multifunctional - due to the mosaic nature of land use in England we fully support the notion of having multifunctional land. However, there is a rhetoric throughout this framework that we need to ‘make space for nature’. This perpetuates that we are separate from nature and it is something additional that we need to move other needs aside for - pitting nature against other land use types and therefore societal needs (such as food and housing). We already see this narrative in public discourse and using language that continues to separate us from nature does not help this. This often leads to the other functions of the land being put at a higher priority, eg in decision-making, in these so called ‘multifunctional land’ spaces.

3. Beyond Government departments in England, which other decision makers do you think would benefit from applying these principles?

• Combined and local authorities (including local planning authorities)

• Land owners and land managers (including environmental and heritage groups)

• Housing developers

• Large infrastructure developers (including energy)

4. What are the policies, incentives and other changes that are needed to support decision makers in the agricultural sector to deliver this scale of land use change, while considering the importance of food production?

Ecosystem services such as pollination, nutrient cycling, and erosion control are fundamental to food production; as nature diminishes, so too do these benefits. The following actions are needed to help ensure farmers can maintain food production in a changing climate:

Recognise that farmers are often penalised for taking voluntary action for nature (e.g. through losing eligibility for subsidies, carbon credits, or Biodiversity Net Gain credits), and incentivise farmers to be proactive.

Address the complexity of agri-environment schemes; no farmer should feel the application process is too complex.

Support the development of natural capital markets in a way which enables farmers to take advantage of these schemes without unnecessary conflicts with subsidies or food production.

Evaluate whether the requirement for tenant farmers to seek permission from the land owner under some circumstances is, in practice, a barrier to their entry into agri-environment schemes and/or natural capital contracts.

These incentives should be directly linked to national land use targets - such as target 3 (30x30) and 10 (sustainable use) in the KMGBF

As well as new incentives, current harmful incentives should be removed in line with KMGBF target 18.

5. How could Government support more land managers to implement multifunctional land uses that deliver a wider range of benefits, such as agroforestry systems with trees within pasture or arable fields?

Incentives linked to nature-based solutions and farming with nature must ensure a just transition in less productive landscapes. Farming communities should be supported with information, resources, funding, and peer networks to diversify land use and foster healthy environments. For example, agroforestry offers benefits for both landowners and biodiversity. While financial incentives are needed, awareness of these co-benefits must be more widely promoted, and any schemes must be ethical in their sourcing and distribution. 

This transition must be intergenerational, grounded in the principle of equity between generations. The average UK farmer is 59, with many over 65, yet younger farmers (under 40) are typically more willing to adopt sustainable practices such as regenerative agriculture, agroforestry, or reducing pesticide use. They also show greater recognition of climate risks and are more likely to engage in rewilding, biodiversity schemes, or environmental land management (ELM). These younger land managers often embrace innovation, making them key allies in scaling nature recovery and climate resilience.

 6. What should the Government consider in identifying suitable locations for spatially targeted incentives?

Rare and endangered species and habitats

Habitats that support ecological function 

Habitat connectivity for adaptation to change land use and climate

Natural capital and ecosystem services

Community need and support (supply and demand of ecosystem services)

Sustainability/longevity of initiatives (i.e. identifying locations with networks/communities who can support the long term delivery of initiatives, ensuring that incentives make the best use of resources)

7. What approach(es) could most effectively support land managers and the agricultural sector to steer land use changes to where they can deliver greater potential benefits and lower trade-offs?

Funding to support initial capital investment in technologies that enable a shift towards agricultural practices that co-benefit nature. 

Research and evidence of agricultural practices that have worked in similar/relevant localities and positive experiences spread by word of mouth/trusted individuals in communities to provide land managers with the confidence to adopt sustainable agricultural practices.

Safety nets - land managers want to be sure of continued income and maintained productivity of land. Practices that deliver greater benefits and lower trade-offs must also be low risk for land managers to adopt. What safety nets can be in place to reduce the risks?

Collaborative and partnership working - investing in relationships and facilitating more effective communication between neighbouring land managers could support them in steering land use changes at the scale needed. Notably these can also be encourage between different land use types and management types. 

8. In addition to promoting multifunctional land uses and spatially targeting land use change incentives, what more could be done by Government or others to reduce the risk that we displace more food production and environmental impacts abroad?

Please select all that apply and give details for your answer(s).

1.  Monitoring land use change or production on agricultural land

2.  Accounting for displaced food production impacts in project appraisals

3.  Protecting the best agricultural land from permanent land use changes

 Other (please specify)

Adopting agricultural practices that work with nature to protect and enhance ecosystem services is essential to safeguarding food production in the UK. This transition is necessary to avoid displacing environmental impacts abroad in the long term. Monitoring the production and consumption of agricultural and forestry products within the UK is important whilst we shift towards land use practices that enable improved and sustainable methods of production.

9. What should Government consider in increasing private investment towards appropriate land use changes?

To date, private investment has often come in the form of offsetting harmful activities by providing finance of improvements elsewhere. A “net” approach implies that it's acceptable to continue damaging nature, as long as it´s compensated elsewhere, and often later, by offsetting mechanisms.

It fails to account for the loss of, often incredibly complex, ecosystem functions and the benefits they provide to people and can assume one type of ecosystem or species can be compensated by others, ignoring the unique role of each in the area they are in. Time lags, uncertainty in the outcomes, and weak measurability limit the technical success of offsets. Several studies suggest that the total amount of planned offsets needed to respond to infrastructure and industry development is unrealistically high.

For example, private institutes contributing to the Nature Restoration Fund should not be used to avoid the mitigation hierarchy and for greenwashing purposes (ie. harmful actions allowed in exchange for contributions).

Government should consider how to facilitate funding reaching smaller, community based, projects to ensure a just distribution of wealth and reduce the risk of land grabbing.

10. What changes are needed to accelerate 30by30 delivery, including by enabling Protected Landscapes to contribute more?

Please use the text box to provide any specific suggestions for the following choices.

 Strengthened Protected Landscapes legislation (around governance and regulations or duties on key actors) with a greater focus on nature.

 Tools: such as greater alignment of existing Defra schemes with the 30by30 criteria (for 30by30 criteria and next steps see: https://www.gov.uk/government/publications/criteria-for-30by30-on-land-in-england/30by30-on-land-in-england-confirmed-criteria-and-next-steps)

 Resources: such as funding or guidance for those managing Protected Landscapes for nature

 Other (please specify)

Monitoring and regulation seen as a priority for government (to ensure land owners are meeting their responsibility and we see improvements in quality) 

Private and public finance is channelled towards 30x30 sites to assist landowners with management 

11. What approaches could cost-effectively support nature and food production in urban landscapes and on land managed for recreation?

The promotion and use of space (including vertical space) for allotments and food gardens in urban landscapes. New buildings and infrastructure should be required to include urban nature-based solutions such as green-roofs/walls, urban gardens and biodiversity spaces (meadows, habitat provision etc.). There should be designed with local communities, empowering meaningful participation and decision-making, with accessibility to green space in mind.

12. How can Government ensure that development and infrastructure spatial plans take advantage of potential co-benefits and manage trade-offs?

13. How can local authorities and Government better take account of land use opportunities in transport planning?

Transport routes have an opportunity to provide multi-benefits for people and nature. Large scale infrastructure can cause habitat fragmentation, and effort must be made to avoid this, however they can also provide opportunities for habitat corridors across a landscape. In more urban landscapes, in many countries, tram routes are embedded within grassy areas to reduce surface run-off and trees line the routes for biodiversity. Though public transport provides many benefits already, there are more opportunities for the UK to learn from European cities in their provision for biodiversity.

14. How can Government support closer coordination across plans and strategies for different sectors and outcomes at the local and regional level?

15. Would including additional major landowners and land managers in the Adaptation Reporting Power process (see above) support adaptation knowledge sharing? Please give any reasons or alternative suggestions in the text box below.

 Yes / No

16. Below is a list of activities the Government could implement to support landowners, land managers, and communities to understand and prepare for the impacts of climate change. Please select the activities you think should be prioritised and give any reasons for your answer, or specific approaches you would like to see.

• Providing better information on local climate impacts to inform local decision making and strategies (for example, translating UK Climate Projections into what these mean in terms of on-the-ground impacts on farming, buildings, communities and nature) (Met Office UK Climate Projections available at https://www.metoffice.gov.uk/research/approach/collaboration/ukcp)

• Providing improved tools and guidance for turning climate information into tangible actions (for example, how to produce an adaptation plan for different sectors) 

• Developing and sharing clearer objectives and resilience standards (for example, a clear picture and standards of good practice for each sector under a 2°C climate scenario: the climate changes we will experience if there is 2°C of global average temperature increase above pre-industrial baselines by 2100) 

• Supporting the right actions in the right places in a changing climate (for example, prioritising incentives for sustainable land uses where they will be most resilient to climate change) 

Other (please specify)

Improved narrative regarding the use of nature-based solutions to help land owners and managers mitigate and adapt to the impacts of climate changes, that ultimately will impact their land and business (eg. flooding, degraded soils, changes in growing seasons)

There is an established knowledge-action gap that means understanding of climate change impacts doesn’t necessarily lead to action - providing the information and tools may not be enough. Active support in developing adaptation plans; demonstrations of actions and follow-up support in delivering them is more likely to equip landowners, land managers and communities to prepare for the impacts of climate change.

17. What changes to how Government’s spatial data is presented or shared could increase its value in decision making and make it more accessible?

Please select all that apply and provide reasons for your answer(s). 

Other (Please specify)

 Again, all good but do the key stakeholders know that this information is available or where to access it? Targeted campaigns to increase the visibility of this data may be useful.

18. What improvements could be made to how spatial data is captured, managed, or used to support land use decisions in the following sectors?

Please give any reasons for your answer or specific suggestions.

 Development and planning: such as environmental survey data

 Farming: such as supply chain data and carbon or nature baseline measurements

 Environment and forestry: such as local and volunteer-collected environmental records

 Recreation and access: such as accessible land and route data

 Government-published land and agricultural statistics

19. What improvements are needed to the quality, availability and accessibility of ALC data to support effective land use decisions?

20. Which sources of spatial data should the Government consider making free or easier to access, including via open licensing, to increase their potential benefit?

21. What gaps in land management capacity or skills do you anticipate as part of the land use transition?

Peatland restoration

Grassland management (including in urban areas)

Collaboration and facilitation skills

Low production native woodland management

Please include any suggestions to address these gaps.

 Development and planning

 Farming

 Environment and forestry

 Recreation and access

 Other (please specify)

22. How could the sharing of best practice in innovative land use practices and management be improved?

23. Should a Land Use Framework for England be updated periodically, and if so, how frequently should this occur?

Yes, every 5 years 

 The science and understanding around land use, ecosystem services, and climate change, as well as technologies to address environmental issues, are so regularly being updated that frequent updating of the Land Use Framework is crucial for reflecting these findings.

However there must also be a balance between updating policies and ensuring action is actually implemented on the ground.

24. To what extent do you agree or disagree with the proposed areas above? Please include comments or suggestions with your answers.