Fishing vessels - economic link: business and regulatory impact assessment

3. Consultation

3.1 Within Government

To date and during the development of the policy, the Scottish Government considered its proposals for revising the economic link licence condition with the following groups across the UK and Scottish Governments:

• Marine Scotland Sea Fisheries: led on the development of the policy throughout.
• Marine Scotland Marine Analytical Unit: provided economic modelling which supported the rationale behind the policy development.
• Scottish Government Food and Drink Division: provided policy expertise on Scottish processors and information on export markets.
• Marine Scotland Compliance: provided details of the practices of Scottish vessels.
• Scottish Government Legal Directorate: informed general policy development.
• Department for Environment, Food and Rural Affairs (Defra, UK Government): high level discussions took place with Defra policy and analytical teams which highlighted the differences between the new economic link licence condition in England and that proposed for Scotland, along with the rationale for the differences. Discussions also focused on the analytical approach and sharing learning to support a robust methodology.

3.2 Public Consultation

A public consultation exercise on changes to the current economic link licence condition started on 30 August 2017, with views sought by 31 October 2017. The consultation presented options for increasing the target for landings into Scotland to 55% per annum (by weight) for each vessel targeting quota species, with gifts of quota to the Scottish Government available as a secondary option for those vessels not meeting that target. For pelagic species, it was proposed to introduce the target at 30% in 2018, which would then increase in steps to 55%, by 2020.

In total, there were 154 responses to the consultation with 104 individual responses and 50 on behalf of organisations. Strong views were expressed in support of and in opposition to the proposed changes. The majority of respondents were opposed to any change (it should be noted that many opposition responses had similar or identical text).

A significant proportion of the responses were from Scottish pelagic fishers. They unanimously disagreed with the proposals because of the anticipated negative economic impact on their businesses. Processing capacity in Scotland was also a concern. Many other respondents not directly connected to the pelagic industry were concerned about the potential negative effects on vessels that land catch outside of Scotland and the possible impact of increased quota gifting on whitefish leasing prices, as Pelagic fishers would have to buy large quantities of whitefish quota to manage their quota gift. Fish processors mainly agreed with the proposals as it is expected that they would result in increased supplies of fish and provide much needed support for employment in the areas of Scotland where they are based. However, they called for higher targets, targets for specific species and for the target of 55% to be introduced immediately.

Local authorities tended to support the proposals overall (though one opposed) some disagreed with the transitional period for the pelagic fleet and the quota gifting arrangements which were seen as a providing less economic benefit than landings. Producer Organisations (POs), responsible for managing the fishers’ quota and marketing the fish, mostly disagreed with the proposals.

As noted above, a key change arising as a result of the consultation process is that the landings target element will now only apply to the eight species with the highest landed value into Scotland (“the 8 key species”). This change is being introduced in response to concerns that for other species there is a lack of market/ processing capacity in Scotland and that vessels could comply with the new provision by landing low value species into Scotland whilst continuing to land high value species outside of Scotland.