Fishing vessels - economic link: island communities impact assessment (ICIA)

Step Three - Consultation

Is there are information already gathered through previous engagements?

How will you carry out your consultation and in what timescales? Public meetings/Local Authorities/key Stakeholders

What questions will you ask when considering how to address island realities?

Separate consultation events for Island communities/Local Authorities?

The views of island communities - Information gathered through consultations

The consultation took place before the Islands Scotland Act 2018. However, there was a great deal of engagement with key stakeholders - including island stakeholders.

Indeed, to inform their consultation response the Shetland based PO (Shetland Fish Producers Organisation) which represents Shetland based pelagic vessels alongside the Scottish Fishermens Organisation (which represents many mainland based pelagic fleet vessels) commissioned consultants to conduct a review of amendments to the landings target.

There were also consultation responses from a number of Shetland stakeholders, such as the local authority and Shetland Fishermen’s Association, along with fishers based in the area.

Representatives from Shetland were also spoken to as part of the Business Regulatory Impact Assessment.

We would note that prior to the public consultation, there was engagement with pelagic industry representatives on increasing landings into Scotland, including whether the policy objective could be achieved through non-regulatory means. These meetings included representation from Shetland and the North East.

Having reached the conclusion that the policy objective could not be achieved through non-regulatory means, on 30 August 2017, the Scottish Government issued a consultation seeking views on proposed amendments to the economic link licence condition contained in all sea fishing licences for vessels over 10 metres in length landing more than two tonnes of quota species. [8]

The consultation included a detailed explanation as to why changes to the economic link licence condition were being considered and sought feedback on the proposed changes.

154 responses to the consultation were received, with 107 individual responses and 47 on behalf of organisations. 63 individual fishermen responded, many of whom were pelagic fishermen.

Fish processors mainly agreed with the proposals as it was expected they would result in increased supplies of fish and provide much needed support for employment in the areas of Scotland where they are based. Some called for higher targets (in excess of the proposed 55% target), for specific species only and others called for the target of 55% to be introduced immediately.

Many respondents associated with the pelagic catching sector voiced opposition to the proposed change and in particular noted (i) concern about the impact on their businesses as a result of the change and (ii) concern about Scottish processors’ ability to manage an increase in supply. Some other respondents, not directly connected with the pelagic industry, were concerned about the negative effects on vessels which land the majority of their catch outside of Scotland but into other parts of the UK, and the impact of increased quota gifting on whitefish leasing prices.[9]

Local authorities tended to support the proposals overall but 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.

Orkney Islands

There was support for the policy change from the Orkney Fisheries Association. They agreed that additional landings into Scotland would result in socio-economic benefits. The association supported transitional arrangements as this would give time for catchers and processors to adjust.

Shetland Islands

Though there was general support for the aim of achieving greater landings into Scotland there was opposition to the mechanism for doing so as set out in the consultation document. Those opposed included: the Shetland Fishermen’s Association, the island’s Producer Organisation and local authority.

The reasoning given for opposition to the change by stakeholders in Shetland were in line with reasoning from those against the change elsewhere in Scotland.

Key themes highlighted were:

• Arrangements should continue as they are (as they believe this returns the greatest socio-economic benefit),
• There was a perceived lack of processing capacity within Scotland to handle the increase in pelagic stocks to be landed
• Scottish processors lacked access to key markets
• The change could impact on the viability of individual vessels to continue.

Western Isles

There was support for the change from the Western Isles Fishermen’s Association and Comhairle nan Eilean Siar. They agreed that the change would bring socio-economic benefits to Scotland. They agreed with the staged approach for the pelagic sector. There were calls to change the methodology for allocating gifted quota- to allow quota to be distributed beyond the 10 metre and under sector only.

Argyll and Bute

Argyll and Bute Council (which includes some island communities) supported the proposed policy change. They wrote of the socio-economic benefits to fishing communities and the additional resilience that the change would bring. However, they supported the phased introduction of the policy change to ensure sufficient processing capacity.