Aquaculture: external review of the current regulatory processes involved in fish farming

To: Professor Russel Griggs OBE

From: Ms Gougeon, Cabinet Secretary for Rural Affairs and Islands

Dear Professor Griggs

I am writing to you today to request that you initiate a review of the current regulatory framework for Scottish aquaculture, with a view to providing recommendations for future work which will improve its efficiency as well as inform any work on more fundamental reform. 

As you are aware I am commissioning this work to support the SNP Manifesto Commitments for aquaculture which are attached at annex A.

Scottish aquaculture is a significant contributor to Scotland’s rural economy, providing well paid jobs in some of Scotland’s most fragile communities and a source of home grown healthy low carbon protein. It will be an essential component of Scotland’s green recovery and our transition to net zero.

The regulatory landscape is contentious, made clear during the 2017 and 2018 Parliamentary fish farming debates. The impetus for change goes back many years and there are a number of reports highlighting the need for improved efficiency and regulatory change; most notably the 2016 Independent Review of Scottish Aquaculture Consenting and the latest being the Salmon Interactions Working Group report of 2020, to which I am currently considering the Scottish Government response.

I must stress that this review is not just to be about efficiency. I want Scotland’s aquaculture regulatory regime to be regarded as one of the most efficient but also most effective and transparent in the world.

By effective, I mean that it must provide clear direction and decision-making based on protecting our environment, enhancing our communities and growing our economy.

By transparent, I mean that it must be accessible, with decisions that can be understood and seen to be in line with our ambitions on local governance and a vibrant, inclusive democracy.

In terms of scope, it needs to work for and benefit all the sector - not just fish farming, but also shellfish farming, since both are currently governed by the same consenting regime[1].

I intend to approach the review in two ways – first, by exploring what can be achieved within the current regime, in terms of organisational development and performance improvement; and, second, considering options on how to deliver more fundamental reform in the longer term.

As a starting point, it is clear we need a strategic analysis of the issues that need fixing, based on a good understanding of work to-date, sound evidence on the current workings of the system, and an accurate appraisal of what people actually think about its operation. That analysis will provide us with recommendations on the further work that may be needed in support of the efficiency and reform perspectives I mentioned above.

I would like you to lead this first phase of our review - initial scoping and fact finding over a period of about 3 months commencing in August.  The Terms of Reference are attached in annex B. I have also included here an illustrative outline to our phased approach to the overall review at annex C.

My officials have started work on a scene-setting paper which will be provided following acceptance of the terms of reference attached.

I should be grateful if you would read through the terms of reference and, if you are content, please let me have your agreement. 

Yours sincerely

Ms Gougeon, Cabinet Secretary for Rural Affairs and Islands

Copied to;

• Ms McAllan, Minister for Environment and Biodiversity
• Mr Arthur, Minister for Public Finance, Planning and Community Wealth