11 Key Issues and Trends
11.1 Overall, opinions on most of the issues in the Consultation Document were strongly divided between the aquaculture industry and freshwater fisheries/other environmental stakeholders.
11.2 With a small number of exceptions, the aquaculture industry was largely critical of many of the proposed Bill provisions, with most aquaculture industry respondents aligning themselves with the response provided by the SSPO. The opposition appeared to relate to concerns about excessive regulation of the industry, and adding unnecessary red tape to a growing industry. Several felt that the Scottish Government was sending out mixed signals, with aspirations for industry growth being undermined by proposals for tighter regulation. The industry was generally supportive of many of the proposals outlined in Section 4 of the Consultation Document.
11.3 Concerns also related to perceived financial and reputational damage to the industry and the likely increases in cost burdens and reduced ability to be competitive in worldwide markets. A potential increase in liability of aquaculture industry operators and their workers resulting from strict liability and fixed penalties was also highlighted by both company responses and individuals working within the industry.
11.4 In contrast, freshwater fisheries bodies were largely supportive of proposals for the Bill, with the exception of some opposition to the proposals in Section 4 of the Consultation Document (i.e. relating to salmon and freshwater fisheries management). The freshwater fisheries respondents largely referred to the response of the ASFB, with several consultees adding additional comments on specific issues.
11.5 There were also contrasting views between the coarse angling/mixed fishery industry operators and a number of DSFBs. Several anglers requested greater involvement in DSFB activities. Some were disappointed that other fish species are not included in the Bill provisions, raising concerns about the potential loss of these fisheries.
11.6 The existing and proposed measures in Scotland were often compared with those in other countries. Several respondents suggested adopting measures or systems currently used in Canada (British Columbia), Norway or Ireland. These suggestions related largely to data collection and publication, site monitoring and arbitration. Several respondents argued that most of the aquaculture industry firms operating in Scotland are multi-national and would be familiar with other regulatory regimes, Norway in particular.
11.7 The potential financial implications of the Bill were also raised by a range of stakeholders. Many were concerned at likely increases in costs associated with the adoption and implementation of the proposals in the Bill and questioned who will pay for them. Aquaculture industry respondents, including the SSPO, highlighted large potential losses to the aquaculture industry in meeting the proposed requirements, although most did not state a particular monetary figure. Possible costs to the public sector were also raised, specifically relating to implications for the budgets of SEPA and DSFBs arising from increased requirements and responsibilities under the proposals.
11.8 Several respondents, from across the stakeholder groups, called for additional consultation on some provisions in the Bill. These included arbitration, unused consents, collection of samples, wellboat controls, carcass tagging, conservation measures, data collection, paying for progress, strict liability and fixed penalty notices.