A d v ic e Pa p er (12 -09)

S E P T E M BE R 2 0 1 2

THE 2020 CHALLENGE FOR SCOTLANDS BIODIVERSITY:

a response to the Scottish Governments consultation

Summary
The strategy document is well aligned with the various strategies that have been developed in recent years pertaining to the land use, freshwater and marine sectors. It has attempted to demonstrate how a better integration of policy, implementation and administration of Government departments and partnership with NGOs and the public could deliver a more dynamic and cohesive approach to securing Scotlands biodiversity. However, the strategy document lacks any assessment of the state of Scotlands biodiversity despite the fact there is a great deal of information available. A review of the current position on species, habitats and ecosystems and the assessment of recent trends is needed to provide the focus for future action and the identification of priorities. While the strategy document contains many laudable aspirations, it is weak on strategic action, despite the fact that this will be essential to successful delivery of the desired biodiversity outcomes for 2020.The strategy should address how the implementation phase is to be approached and some of the most pressing problems that need to be resolved if action is to be effective.The development of an action plan will be essential to the achievement of the high level outcomes. The achievement of the outcomes for Scotlands biodiversity will require a clear demonstration of resourcing and commitment. The Scottish Government must ensure that adequate financial resources are put in place. Part of the problem of resourcing is the sources of funding that are available.The use of the Scottish Rural Development Programme (SRDP) as a vehicle for achieving objectives is important but its administration and the way that it can be used often mitigates against achieving cohesion across the various sectors, in particular agriculture, forestry and freshwater resources. A major failing of the strategy document is that it does not recognise the conflicts between nature and human activities.The result is that the strategy document fails to provide any explicit means of resolving conflicts.The RSE made exactly the same comment in relation to the development of the Land Use Strategy.Without an effective framework for making decisions to resolve conflict, and to identify where there is potential synergy of use, important decisions will continue to be delayed, or reached on an ad hoc basis. Increasing sustainable economic growth remains the Scottish Governments core Purpose.There are, however, many reasons to support Scotlands biodiversity that are not directly related to economic growth. Protection of the natural environment will be sufficiently urgent to justify action in its own right. Biological diversity in Scotland has intrinsic value that cannot, and should not, be expressed or measured in monetary terms. Sustaining both economic growth and environmental integrity simultaneously is not easily solved, if indeed there is a solution.The strategy document should articulate this challenge clearly and realistically. Engagement with Scotlands strong research base will be invaluable.The work undertaken by the Main Research Providers (MRPs) will add significant understanding that must underpin effective decision-making for Scotlands biodiversity. It is crucial that policy and decision makers at all levels have access to that information, know who to approach for it and are able to understand the implications of research. But, it is equally important that policy makers are aware of research being undertaken outwith the Governments own programmes, and by Scotlands wider research base (and indeed outwith Scotland). We are pleased that the document provides wider communication of the utility of adopting an ecosystem services approach. However, the discussion of restoration is flawed as the issue of restoration to what? is not resolvable and restoration is the wrong concept.All ecosystems are dynamic, constantly changing and evolving, and hence opinions will differ as to what the aim of habitat improvement might be. Particularly at a time of considerable climate change, we should expect different, and potentially new, ecosystems to emerge during the next century, and it would be impossible to restore them to some pre-conceived notion of a historical state. The references to biodiversity offsetting in the strategy document are very rudimentary and need to be properly developed before any more thought can be given to the possible implementation of such a scheme. Biodiversity offsetting should not be seen in isolation from the use of methods to reduce the impact of development at the site. There is a great deal of international material on the principles and practice of biodiversity offsetting and this should be reviewed by the Scottish Government.
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Background
1 The Royal Society of Edinburgh (RSE), Scotlands National Academy, welcomes the opportunity to respond to the Scottish Governments consultation on the 2020 Challenge for Scotlands Biodiversity. The RSE is uniquely placed to offer informed, independent comment by drawing upon the wide range and depth of expertise which exists within its Fellowship in the areas under consideration. In this context, the Scottish Government will be aware that the RSE has previously engaged with the development of the Land Use Strategy and the proposals for Scotlands first marine plan, and in relation to climate change. This response focuses initially on a number of key issues that need to be addressed to enable the development of a biodiversity strategy that can achieve the desired outcomes for 2020. It then addresses the specific chapters where the RSE has more detailed comments to make. We would be pleased to discuss further any of the issues raised in this response with the Scottish Governments Biodiversity Strategy Team. Indeed, our ability to take a broad overview of the strategy may mean that we are able to identify overlaps in policies or gaps in knowledge that will require to be addressed as the strategy is taken forward.The RSE working group which has prepared this response is keen to contribute constructively to this on-going process. (2) Basis for action and implementation 6 The strategy document contains many laudable aspirations and we welcome the outcome statements, key steps and the what will be different sections as set out in each of the chapters. It is, however, weak on strategic action, despite the fact that this will be essential to successful delivery of the desired biodiversity outcomes for 2020.We realise that this involves a complex set of issues that an early stage strategy document might want to avoid, but the strategy should address how the implementation phase is to be approached and some of the most pressing problems that need to be resolved if action is to be effective.A strategy should naturally lead to a series of recommendations to form the basis of an implementation plan.The development of an action plan will be essential in terms of delivering the means by which the high level outcomes can be achieved. (3) Identifying priorities 7 In this context, greater emphasis should be given to the priorities that require to be addressed over the period up to 2020 and the action that needs to be taken. Chapter four is atypical in the strategy document in that it articulates specific priorities for action (at paragraphs 4.3.9 and 4.4.7) for habitats and protected places, and wildlife, respectively. This is not a difficult undertaking given the information available from the Governments agencies, but it needs to be replicated so that there is a statement on priorities for each chapter. 8 On a more general point, the strategy document would benefit if each of the chapters were to adopt a more consistent style. Identifying priorities and the action needed will help ensure that the limited resources available are targeted much more effectively. It is very important in relation to balancing competing interests and it will be a useful way of informing relevant short and long-term research agendas.

Major issues
4 The strategy document is well aligned with the various strategies that have been developed in recent years pertaining to the land use, freshwater and marine sectors, as well as those dealing with mitigation of, and adaptation to, climate change. It has attempted to demonstrate how a better integration of policy, implementation and administration of Government departments and partnership with NGOs and the public could deliver a more dynamic and cohesive approach to securing Scotlands biodiversity. 9

(1) Biodiversity trends 5 The strategy lacks any assessment of the state of Scotlands biodiversity despite the fact there is a great deal of information available. A review of the current position on species, habitats and ecosystems and the assessment of recent trends is needed to provide the focus for future action and the identification of priorities.The use of the pressure - state - response model, employed by SNH for example, is a valuable tool.This is all the more essential as some of the trends are in a negative direction and will require more action to turn the position round than for those which are in a neutral or positive trend.

(4) Resources 10 In order to achieve the outcomes set out in the strategy document, the Scottish Government must ensure that adequate financial resources are put in place. Current shortage of resources is not recognised in the document, which asserts at 4.3.8 that relatively little investment is needed to restore many natural systems back to full capacity. In practice, we have a number of examples where prolonged action has still resulted in negative trends for some species, such as the capercailzie, and for some habitats, such as upland acidic grasslands. The achievement of the outcomes for Scotlands biodiversity will require a clear demonstration of resourcing and commitment. Chapter seven on measuring progress refers to the availability of a suite of indicators and the establishment of a Scottish Biodiversity Information Forum, but without the funding available to governmental and non-governmental organisations, it will be difficult to evaluate and report on progress.

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11 Part of the problem of resourcing is the sources of funding that are available.The use of the Scottish Rural Development Programme (SRDP) as a vehicle for achieving objectives is important but its administration and the way that it can be used often mitigates against achieving cohesion across the various sectors, in particular agriculture, forestry and freshwater resources. Government has not as yet demonstrated, through its funding allocations, that it is serious in its intent to secure Scotlands biodiversity as a major initiative linked to climate change mitigation and rural economic development. The strategy document fails to be convincing in this respect and a much more positive statement is required in relation to the revision and implementation of Pillars 1 and 2 of the CAP and the other elements of the SRDP. (5) Recognising and resolving conflicts 12 A major failing of the strategy document is that it does not recognise the conflicts between nature and human activities. The strategy document appears to assume that stakeholders are all agreed on the priorities and are moving forward together. This is not the case in many situations and unlikely to be the case in the future. To assume otherwise is nave. The result is that the strategy document fails to provide any explicit means of resolving conflicts. The RSE made exactly the same comments in relation to the development of Scotlands Land Use Strategy, flowing from our report on The Future of Scotlands Hills and Islands and we would have expected acknowledgment of this fundamental issue in the development of the biodiversity strategy for 2020. 13 The Government must ensure that biodiversity outcomes are considered by all its directorates and its agencies.A more coherent and unified approach is essential; this should include reviewing existing single issue or single sector policies which have not been subjected to scrutiny so that their potential impact on biodiversity objectives can be determined. In this regard, the statement in relation to ecosystem health at 1.4.4 of the strategy document,and less demanding appraisal in advance of development is deeply concerning and should be deleted. 14 Without an effective framework for making decisions to resolve conflict, and to identify where there is potential synergy of use, important decisions will continue to be delayed, or reached on an ad hoc basis. (6) Scales 15 There needs to be some discussion about the appropriate scales to use in managing and developing Scotlands biodiversity. River catchments feature strongly in the strategy document but other operating scales such as whole ecological landscapes are also mentioned. There needs to be some consistency of use of the different scales and how they might be layered to give a better understanding of how biodiversity, in the broadest sense of the term require to be managed to achieve targets. It will be very difficult to consider the sustainability of biodiversity against the background of climate change without a proper appreciation of these different scales. 16 Furthermore, while the intention to involve local decision-making is understandable, it is not clear what local actually means. Given that ecological processes operate at different scales, it needs to be recognised that local decision-making will not always operate in the national interest or meet international obligations. The strategy document is silent on this issue and this should be addressed as it could be a major barrier to making progress in some areas. (7) Key drivers 17 Increasing sustainable economic growth remains the Scottish Governments core Purpose. The outcome in chapter two of the strategy document regards natural resources as contributing to stronger sustainable economic growth in Scotland. There are, however, many reasons to support Scotlands biodiversity that are not directly related to economic growth. Protection of the natural environment will be sufficiently urgent to justify action in its own right.As we have stated previously, the strategy document must acknowledge more clearly that conflicts will arise, particularly when seeking to maximise both economic growth and sustainability.As the UNEP report,Decoupling Natural Resource Use and Environmental Impacts from Economic Growth1 has described, sustaining both economic growth and environmental integrity simultaneously is not easily solved, if indeed there is a solution.The strategy document should articulate this challenge clearly and realistically. 18 Biological diversity in Scotland has intrinsic value that cannot be expressed or measured in monetary terms. It is inherent in our wilderness areas, mountains and glens, machair and moors, and the patchwork of habitats that make up our landscape, and has been celebrated in literature, poetry and music. Scottish biodiversity includes iconic species such as the golden eagle, the Scottish primrose and the salmon, but many other species also contribute to our sense of place rowan trees, Scots pines, heather, red squirrels, puffins, garden birds, bumblebees, butterflies and so on. This intrinsic diversity is fundamental to what it means to be Scottish, and provides a sense of national identity that we cherish and hope to bequeath to future generations of Scottish citizens. There is, moreover, a strong sense in Scotland that species have the right to exist, independent of their commercial worth. A topical example is the recent stranding of pilot whales at Anstruther in Fife where there was genuine concern for the wellbeing of the animals involved.

1 UNEP (2011) Decoupling natural resource use and environmental impacts from economic growth,A Report of the Working Group on Decoupling to the International Resource Panel. Fischer-Kowalski, M., Swilling, M., von Weizscker, E.U., Ren,Y., Moriguchi,Y., Crane,W., Krausmann, F., Eisenmenger, N., Giljum, S., Hennicke, P., Romero Lankao, P., Siriban Manalang,A., Sewerin, S.

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19 It is worth noting that the EU recognises the intrinsic value of biodiversity, alongside its contribution to human wellbeing:by 2050, European Union biodiversity and the ecosystem services it provides its natural capital are protected, valued and appropriately restored for biodiversitys intrinsic value (emphasis added) and for their essential contribution to human wellbeing and economic prosperity, and so that catastrophic changes caused by the loss of biodiversity are avoided.2 20 Scottish biodiversity is a national asset, some aspects of which have obvious utilitarian functions (fisheries for example) and should only be exploited within the natural regeneration capacity of the biomass. But much of what constitutes Scottish biodiversity is irreplaceable and hence cannot, and should not, be valued in monetary terms. (8) Well informed decision-making 21 Constructive engagement with Scotlands strong research base will be invaluable to ensuring that the right decisions are made. The work carried out by the Main Research Providers (MRPs) under the eight themes of the Scottish Government research programmes for 201116 will add significant understanding that must underpin effective decision-making for Scotlands biodiversity. It is crucial that policy and decision makers at all levels have access to that information, know who to approach for it and are able to understand the implications of research. 22 But, it is equally important that policy makers are aware of research being undertaken outwith its own programmes, and by Scotlands wider research base. It is only by plugging in to the broad base of expertise in Scotland (and indeed outwith Scotland) including those in areas beyond natural science, for example in social sciences, economics and the cultural value of Scotlands biodiversity that a true picture of the costs and benefits of decisions can be gained. (9) Delivery 23 We recognise that the Scottish Environment and Rural Services (SEARS) initiative which, through collaboration, has sought to bring about a more coordinated rural service in Scotland, has been in operation since 2008. Unfortunately, the strategy document does not present any evidence of its effectiveness and it is not clear to what extent the component organisations are integrated in their functional delivery. (10) Use of Terminology 24 Throughout the strategy document, the terminology ecosystems,ecosystem services,environmental quality and biodiversity are interchanged and used as if they are synonymous. The document also uses a considerable amount of technical terminology, such as ecosystem health, much of which is not clearly defined. Care should be taken to ensure that the terms used are clear and can be widely understood by the public.We strongly suggest that a glossary should be added to the document. 4 Indeed, the preparation of a glossary would be a very useful exercise as it would ensure that the authors consider the tightness of definitions and appropriateness of the terms used. Specific comments on the chapters Chapter 1: Healthy ecosystems and ecosystem services 25 The document provides some wider communication of the utility of adopting an ecosystem services approach. We are pleased to see this as the concept has not previously featured widely in Scottish Government documents, although it has been applied elsewhere for a number of years. It enables the aims and progress to be assessed against the benchmark provided by the UK National Ecosystem Assessment (UKNEA). 26 However, the discussion of restoration is flawed as the issue of restoration to what? is not resolvable and restoration is the wrong concept. All ecosystems are dynamic, constantly changing and evolving, and hence opinions will differ as to what the aim of habitat improvement might be. Particularly at a time of considerable climate change, we should expect different, and potentially new, ecosystems to emerge during the next century, and it would be impossible to restore them to some pre-conceived notion of a historical state. Management of ecosystems must also recognise this dynamism. Much more research needs to be undertaken to define what is actually meant by ecosystem health (this is identified in section 1.5.1). Until this is agreed, and methods of measuring it have been widely accepted, it is unlikely that catchment-scale evaluations can be made. 27 There is an inference in the document that increased natural biodiversity will inevitably result in a higher quality environment, and therefore advantageous benefits arising from the related ecosystems services. Examined on any logical basis this is clearly not the case. Indeed, there are centuries of evidence in Mans successful control and management of natural biodiversity which demonstrate the contrary in pest and disease control, in crop management and in the domestication and management of animals in agriculture. Ecosystem services approach and protected species 28 While an ecosystem approach is undoubtedly important, there is also a need for directed measures aimed at managing species and habitat protection, especially as these are key components of Scottish and European regulations on nature conservation. Surveillance of Scotlands species and habitats is also an important strategic aspect; without appropriate monitoring, changes in Scotlands biodiversity cannot be accurately addressed. In these regards, it is important that the Scottish Government fully respects its international commitments. On its own, the adoption of an ecosystem approach will not address many issues. There are whole series of recommendations internationally that mean habitats, species or groups of species should be considered directly.

2 An EU Biodiversity Strategy to 2020 http://ec.europa.eu/environment/nature/biodiversity/policy/

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Chapter 2: Natural capital and resource use efficiency 29 The UKNEA is a valuable document and a major step forward, but its outcomes must be interpreted at a strategic level. The methodologies do not exist to turn the valuation processes in the UKNEA in to operational and tactical decisions. In 2.3.1 an assessment approach is suggested where the value of natures benefits cannot be measured.We strongly suggest that the assessment methodology should only use valuation information as one of many lines of evidence and the weighting given to it should be informed by the level of uncertainty around the valuation process. 30 WhileThe Economics of Ecosystems and Biodiversity (TEEB) and the UKNEA are quoted as assessing value and natural capital, the approaches are quite different. TEEB attempted to provide absolute values for services, whilst the UKNEA assessed potential change in value, arguing that an absolute value was often practically meaningless.This needs to be bottomed-out before a natural capital asset index can be implemented. 31 While this chapter builds on the work of theTEEB and UKNEA, it does not place it within a framework such as pressure state response (there are more complex, but similar, frameworks). The state of the natural assets can be measured at defined times, but what is important is what pressures are being exerted on them and what the responses are (either by the asset or by policy shifts). In other words, the flows through those assets need to be understood. Natural Capital Asset Index 32 While we support the principles for and new methods of valuing natural capital assets, and in particular welcome the development of the Natural Capital Asset Index, there needs to be a keen appreciation of the difference between standing stocks of natural capital and the turnover of this capital. This confusion has existed in fisheries and is part of the reason that fish stocks have been over exploited, except in that case the emphasis has been on short-term maximisation of flows rather than stocks.The strategy must recognise this difference and the complexity underlying what is being proposed. Biodiversity Offsetting 33 We welcome the request for comments on the biodiversity offsetting process. Biodiversity offsetting can only work effectively in a system where there is a reliable valuation process for biodiversity at appropriate scales and over appropriately long timescales and we are unlikely to have this in the foreseeable future. 34 Biodiversity offsetting should not be seen in isolation from the use of methods to reduce the impact of development at the site.The mitigation hierarchy is now a well established method of seeking to minimise the effects of development at the site and best practice is always to apply this hierarchical decision-making tool at the development site before resorting to offsetting at other locations. 35 The references to biodiversity offsetting in the strategy document are very rudimentary and need to be properly developed before any more thought can be given to the possible implementation of such a scheme. Government will be familiar with the offsetting schemes applied many years ago in the context of mitigating the effects of development on Natura 2000 sites, such as Cardiff Bay in SouthWales. There is a great deal of international material on the principles and practice of biodiversity offsetting and this should be reviewed by the Scottish Government. 3 36 Further consideration must include drawing upon the English experience through the Environment Bank and international experience. Extreme caution must be exercised as inappropriate and flawed methods of biodiversity offsetting can lead to substantial and irreversible losses. Many countries have adopted biodiversity offset regulations (35 countries) and many international operating companies (38 at the last count) have adopted no net loss policies, and some, including RioTinto, have adopted a net positive benefit approach to biodiversity. The Scottish Government should consider all of this knowledge and experience in its development of an integrated policy on environment and development. 37 As its thinking in this area develops, the Scottish Government might consider opportunities for trialling large scale biodiversity offsetting and biodiversity banking in Scotland. For example, the extensive development of onshore wind farms for electricity generation does have a net negative effect on biodiversity at the site and the cumulative effects from existing, approved and planned development will be very significant. The development companies are only providing funds for community benefit and no funds have been sought for biodiversity benefits.The Scottish Government could consider developing a scheme for offsetting the biodiversity losses at upland wind farm sites by inviting the development companies to establish a fund for supporting the improved management of upland habitats on an extensive scale.

3 See for example: ten Kate, K.., Bishop, J., and Bayon, R. (2004). Biodiversity offsets:Views, experience, and the business case. IUCN, Gland, Switzerland and Cambridge, UK and Insight Investment, London, UK.ISBN: 2-8317-0854-0 See: Biodiversity Offsets An Overview of Selected Recent Developments: New Zealand Where to from here? Mark Christensen,Anderson Lloyd Lawyers, April 2007, which reviews experience from a number of countries. See: http://www.iucn.org/ for further information on habitat banking and biodiversity.

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Chapter 3: Biodiversity, health and quality of life 38 Arguably, this chapter is not central to a biodiversity strategy, but flows from such a strategy. That being said, it correctly recognises the importance of green spaces for the health and education of people. However, the policy implication, which is not considered, is that the Scottish Government begins to make a major shift in environmental investment from the biodiversity-rich sparsely populated remote areas of Scotland to the areas of high population density. This raises very difficult choices. Another consequence is whether the funding implications of the opportunities set out in this chapter would be the responsibility of the Health or Rural Affairs budgetary portfolios, or perhaps both. 42 Paragraph 4.3.4 states that nature conservation sites currently cover about 18% of Scotlands land area, while paragraph 4.3.9 indicates that the priority should be to conserve 17% of land and inland water. The reason for the apparent reduction is not made clear in the strategy document. Given the richness of Scotlands environment, it would seem reasonable to at least maintain, if not exceed, the current conservation level. This target also has to be seen in the context of the CBD AichiTarget 11 which stipulates that: By 2020, at least 17 per cent of terrestrial and inland water, and 10 per cent of coastal and marine areas, especially areas of particular importance for biodiversity and ecosystem services, are conserved through effectively and equitably managed, ecologically representative and well connected systems of protected areas and other effective area-based conservation measures, and integrated into the wider landscapes and seascapes.

39 We are impressed by the possibilities outlined in this chapter and the initiatives taken. However, much greater emphasis will need to be given to the delivery mechanisms. Planning Authorities are key, but given the stringent resource constraints, it is not clear whether they are in a position to help deliver what is required. 43 We are concerned that there is an a priori aim in In order to achieve the outcome outlined in this chapter, paragraph 4.4.7 to shorten the Scottish Biodiversity List. it will be incumbent on all parts of the NHS to embrace We would argue that any changes in the list should the emphasis being placed on the benefits provided by reflect: (1) positive trends in the ecological health of environmental goods.The NHS is well placed to play a these special habitats and species; and (2) advances in prominent delivery role in health treatment and knowledge about the changing state of these habitats rehabilitation and through demonstration projects. and species. The Scottish Government should consider the establishment of a specific task force, involving SNH, Chapter 5: Land and freshwater use and management the NHS and COSLA among others, which would 44 The high level comments that we make in relation to provide focussed coordination of effort. priorities, resources, conflicts and scales are particularly relevant here. It is one thing to point out that there Chapter 4:Wildlife, habitats and protected places is intensification of land use due to agriculture and connecting nature renewable energy. It is quite another thing to be realistic 40 While this chapter refers to the importance of about the conflicting priorities this raises and the current ecologically integrated networks, there is a major text does not address this. weakness in that the crucial aspect of connectivity is not given the prominence that is required. It should be noted that neither the SSSIs nor the Natura 2000 sites form a network in the ecological sense; rather they are a suite with the same purposes. It should also be noted, in particular, that the EU Directive on the Conservation of natural habitats and of wild fauna and flora places a responsibility on Member States to develop links between the sites and the wider countryside by instituting special measures under Article 10. We recognise that delivery of this will be difficult, but there is very little in this chapter demonstrating that much thought has been given to forestry, agriculture and sporting estate developments and how incentives might be developed to achieve the desired outcome. 41 Furthermore, there is no mention of the role and value of different ownership mechanisms: community, environmental charity and traditional.This is needed given the review of land ownership legislation instituted recently by the Scottish Government. 45 This chapter does not set out a way of achieving the strategic balance between land that is primarily used for (1) productive purposes (and hence might have relatively low biodiversity value); and (2) biodiversity (and hence might have low productive value, in the traditional economic sense). It is not clear how that balance would be determined and how changes to this would be agreed. 46 In the next section we comment on the marine and coastal-related aspects of the strategy document. However, in relation to freshwater use, it is worth noting that notwithstanding their conservation status, there are presently no scientifically-based conservation catch limits for Atlantic salmon for any Scottish river. Likewise, the lack of information on trout populations is a concern.

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Chapter 6: Marine and Coastal 47 Scotland has a very extensive marine environment, with both inshore and offshore waters. However, these dimensions are underplayed in the strategy document. It is to be regretted that the marine environment is always separated from the terrestrial environment, despite the fact that sediments, nutrients and water from rivers has a profound influence on the sea and especially on the habitats and species of the nearshore zone. Marine biodiversity is too often the case of out of sight and out of mind. Many aspects of the marine environment could have been included in chapters 1 to 5 of this strategy document. 48 That being said, we very much welcome and support the approach set out in the Scottish Marine Nature Conservation Strategy to develop a coherent network of Marine Protected Areas (MPAs) and the criteria to be used to guide the establishment of MPAs. 49 We are, however, concerned, that one of the stated key steps in the Marine and coastal chapter of the strategy document is to bring fish stocks to levels consistent with Maximum SustainableYield (MSY) wherever possible. It is unfortunate that MSY has become embedded in international fishing agreements. Setting levels of MSY implies a degree of scientific certainty that does not exist and may be one of the causes of continuing decline in fish stocks.While the Scottish Government would be complying with international agreements by fishing within the high levels of MSY, the RSE would urge it to go further by committing to fish at levels below MSY. The RSE is strongly supportive of the idea of fish as a renewable resource which Scotland can exploit at ecologically/biologically sustainable levels but believes that the maximum yield for Scottish fishermen will not be obtained through current management objectives. Chapter 7: Measuring progress 50 Much of the detail still needs to be developed under this heading in terms of assessing progress. We also wish to re-iterate our comment in paragraph 10 that it will be difficult to report on progress in the absence of sufficient funding. This chapter emphasises the role of volunteers in developing the evidence base.While the contribution of citizen science is undoubtedly important, we caution against the strategy placing too much reliance on them.

Additional Information
Advice papers are produced on behalf of RSE Council by an appropriately diverse working group in whose expertise and judgement the Council has confidence.This Advice Paper has been signed off by the Chair of the group and by the General Secretary. In preparing this Advice Paper we would like to draw attention to the following RSE responses which are relevant to this subject:

The Royal Society of Edinburghs response to the Scottish Government on the National Marine Plan (June 2011) The Royal Society of Edinburghs Inquiry Report, Facing up to Climate Change: breaking the barriers to a low-carbon Scotland (March 2011) The Royal Society of Edinburghs response to the Scottish Government on the Draft Land Use Strategy for Scotland (December 2010) The Royal Society of Edinburghs Inquiry Report, The Future of Scotlands Hills and Islands (September 2008)

Any enquiries about this Advice Paper should addressed to Mr William Hardie (email: evidenceadvice@royalsoced.org.uk). Responses are published on the RSE website (www.royalsoced.org.uk).
Advice Paper (Royal Society of Edinburgh) ISSN 2040-2694

The Royal Society of Edinburgh (RSE) is Scotlands National Academy. It is an independent body with a multidisciplinary fellowship of men and women of international standing which makes it uniquely placed to offer informed, independent comment on matters of national interest.
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