BY CALUM CAMPBELL
The Scottish Government has made peatland restoration a cornerstone of its climate change strategy. Through the NatureScot Peatland ACTION team, and in close partnership with the Cairngorms National Park and the Loch Lomond & Trossachs National Park, a major programme of landscape-scale intervention is underway. With over 20% of Scotland’s land area covered by peat, the stated goals are ambitious: improve water quality, enhance biodiversity, slow floodwaters, reduce wildfire risk, and sequester carbon.
Since 2012, more than £10.3 million has been spent on peatland restoration. The Scottish Government has allocated £250 million over ten years, with a target of restoring 250,000 hectares by 2030. Claudia Rowse, NatureScot’s Deputy Director of Green Economy, has stated that “increased peatland restoration is vital to combat the Climate and Nature emergencies.”
On its face, this sounds unimpeachable. Who could oppose restoring a natural habitat? However, a closer examination reveals a troubling contradiction. The very act of “restoring” peatlands—typically by rewetting, re-profiling, and removing vegetation—may be destroying rare micro-habitats upon which protected species depend.
The Hidden Ecology of Peat Haggs
The Scottish uplands are a harsh environment. Low temperatures, high winds, thin soils, and short growing seasons create extreme conditions for wildlife. Yet life persists, often in specialised refugia. One such refugium is the peat hagg—a complex of eroded peat banks, pools, and hummocks that creates its own micro-topography and, in turn, its own microclimate.
Peat haggs are not degraded peatland in the conventional sense. They are a distinct, rare, and increasingly threatened habitat. They provide shelter from wind and rain, thermal buffering, and concealment from predators. For several species, they are not optional extras but essential components of their home range.
Mountain Hares
The Scottish mountain hare (Lepus timidus scoticus) is Britain’s only native hare. It is a protected species under the Wildlife and Countryside Act 1981 and is listed as a species of principal importance for biodiversity conservation in Scotland. Mountain hares rely on peat haggs for cover, particularly during the breeding season.
Young hares are born from early March through the summer months. They are altricial in the sense of being mobile but still highly vulnerable. Peat haggs provide thermal refuge and visual concealment from predators such as golden eagles, foxes, and stoats. When mechanical diggers move in to “restore” peatland—by flattening haggs, blocking gullies, and re-profiling eroded surfaces—they destroy this shelter. The question that no official impact assessment appears to have answered is: How many juvenile mountain hares are being killed, directly or indirectly, by peatland restoration?
Birds and Invertebrates: Collateral Damage
Red grouse (Lagopus lagopus scotica) also depend on peat haggs. In wet summers, haggs provide shelter for crane flies (Tipulidae) and a wide range of other insects. These insects, in turn, are a critical food source for young grouse and other upland birds. In hot, dry summers, insects fly high and become inaccessible; haggs offer a low-altitude, sheltered micro-habitat where insect populations can persist. By flattening haggs, restoration removes this insect refuge, reducing food availability for chicks.
If the stated goal is to address a “Nature Emergency,” then destroying the very micro-habitats that sustain protected species is counterproductive. It is not restoration. It is habitat conversion—and in some cases, outright destruction.
The Legal Question: Where Are the Environmental Impact Assessments?
Under the Environmental Impact Assessment (EIA) regulations (The Environmental Impact Assessment (Scotland) Regulations 2017), certain projects require a formal assessment of their likely effects on the environment. Peatland restoration, when involving mechanical digging, drainage blocking, and large-scale re-profiling, would appear to meet the threshold for at least a screening opinion, if not a full EIA.
Key questions that remain unanswered in publicly available documentation:
- Who is walking the ground with dogs to flush out mountain hares and other protected species before mechanical work begins?
- What surveys have been conducted to establish baseline populations of mountain hares, nesting birds, and invertebrates in areas scheduled for restoration?
- What mitigation measures are in place if protected species are found?
- Has any licensed disturbance (under the Wildlife and Countryside Act) been applied for or granted?
- Are post-restoration monitoring programmes assessing not just carbon and water metrics, but species survival and recolonisation?
Without clear answers, the programme may be in breach of both domestic wildlife law and Scotland’s own biodiversity duties under the Nature Conservation (Scotland) Act 2004. NatureScot do have guidelines for doing peatland restoration during nesting season yet what is witnessed on the ground seems to pay little attention to them.
The Carbon Question
The entire justification for peatland restoration rests on carbon sequestration. Yet the basic atmospheric chemistry is rarely debated in policy circles. Carbon dioxide (CO₂) constitutes approximately 0.04% (420 parts per million) of Earth’s atmosphere. Even if Scotland restored every hectare of peatland to a theoretical pristine state, the impact on global CO₂ concentrations would be statistically undetectable.
Some plant physiologists argue that CO₂ levels of 0.06% to 0.08% (600–800 ppm) would be optimal for plant growth and agricultural productivity. We are currently at the lower end of that range. Far from being a pollutant at current levels, CO₂ is a plant fertiliser. The present “green stage” of Earth’s climate—characterised by increased vegetative growth—has been beneficial for global crop yields.
Meanwhile, global emissions continue to rise. China alone built approximately one new coal-fired power station per week in 2025. Ongoing wars in Ukraine and the Middle East have set oil refineries ablaze, releasing colossal quantities of uncombusted hydrocarbons, particulates, and CO₂.
Against this backdrop, Scotland’s aspiration to reach Net Zero by 2045 is admirable but, in global terms, a pointless gesture. It does not justify destroying protected species’ habitats at home.
The Woodland Creation Contradiction
A related but separate policy—woodland creation—exacerbates the problem. Tracked machines are used to mound and plant millions of trees, often on or near peat soils. The process of mounding dries out the peat, releasing stored carbon. The trees themselves, once established, transpire water and further dry the peat. What was intended as a carbon sink becomes a net emitter for decades, if not centuries.
Field operators have reported a striking absurdity: on one side of a hill, a digger is engaged in peatland restoration (blocking drains, re-profiling). On the other side of the same hill, two diggers are digging one million mounds for tree planting. The same peat is being “restored” in one location and “drained” in another. No single integrated environmental strategy appears to govern these contradictory activities.
The Rewilding Paradox
If there is a genuine “Nature Emergency,” one would expect the rewilding movement to be at the forefront of defending existing, threatened species like the mountain hare. Yet organisations such as Scotland: The Big Picture and Trees for Life have focused their advocacy on the reintroduction of Eurasian lynx (Lynx lynx). While charismatic megafauna attract funding and media attention, the ecological case for lynx reintroduction remains contested, and the direct benefits to existing protected species are unclear.
Skeptics have noted that lynx reintroduction would generate new revenue streams through guided walks and ecotourism. There is no comparable revenue stream for protecting mountain hares in peat haggs. This is not necessarily cynical—conservation requires funding—but it does create a perverse incentive: charismatic reintroductions are funded; unglamorous habitat protection is not.
The Volunteer Survey Gap
The Volunteer Mountain Hare Survey project is a commendable citizen science initiative. Sixty-six volunteers surveyed 1,465 square kilometres—a significant effort. However, as the project itself acknowledges, this represents only a tiny fraction of potential mountain hare habitat in Scotland. The resulting data, while valuable, do not provide a comprehensive State of Nature report. They certainly do not provide the fine-grained, site-specific data needed to inform peatland restoration planning.
Without systematic, funded, professional surveys conducted before mechanical intervention, we are flying blind. We cannot claim to be restoring nature while simultaneously failing to count what we are destroying.
Conclusion: A Programme in Need of Audit
The Scottish Government’s peatland restoration programme is not necessarily wrong in principle. Peatlands can be degraded, and restoration can bring benefits. However, the current implementation appears to suffer from:
- Insufficient environmental impact assessment for protected species
- No published mitigation protocols for mountain hares and ground-nesting birds
- Contradictory policies (restoration vs. tree planting) on the same landscapes
- A carbon rationale that ignores the global scale of emissions
- A rewilding focus that prioritises charismatic reintroductions over existing protected species
If the programme continues without addressing these issues, it risks becoming a case study in well-intentioned ecological harm. The mountain hare, the red grouse, and the insects of the peat haggs cannot wait for a policy review. They are being buried—literally—by diggers that no one appears to have asked to stop.
Recommendations:
- Suspend mechanical peatland restoration in areas with confirmed or suspected mountain hare populations until site-specific EIAs are completed.
- Require licensed ecologists to walk the ground with dogs before any digging commences.
- Publish all mitigation and disturbance licences related to protected species.
- Reconcile peatland restoration and woodland creation policies into a single, non-contradictory land use strategy.
- Commission an independent audit of the programme’s biodiversity impacts, separate from its carbon accounting.
Until then, the claim that peatland restoration is an unalloyed environmental good should be treated with the scepticism it deserves. Restoration, like any other landscape intervention, can be done badly. In Scotland today, there is mounting evidence that it is.
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Calum Campbell is a commentator on rural and environmental issues in Scotland.