2. Overview of responses and cross-cutting themes
In this section we provide an overview of responses and a summary of key themes raised, particularly where these themes were present across the four questions posed.
In section 3, we go on to explore responses to questions in more depth and set out the Scottish Government's proposed Next Steps.
2.1 Overview of responses
- 154 responses were received in total, 107 individual responses and 47 responses on behalf of organisations.
- This included 63 respondents who listed themselves as individual fishermen.
- We identified that many of those who identified themselves as individual fishermen operated on pelagic vessels (45 responses).
- Organisations that responded included: fish processors; representative organisations; Producer Organisations; businesses related to the fishing industry and local authorities.
Analysis of respondents
In replying to the consultation, respondents were invited to provide details of their interest in the subject matter.
At the highest level, respondents were asked if they were replying as an individual or on behalf of an organisation.
If a respondent confirmed that they were responding as an individual, they were given three further sub-choices to describe which best reflected their interest in the consultation. These were:
2. Other, related to fishing industry
3. Other, non-related to fishing industry
Some individual responses did not provide an answer to which of the three sub-categories best aligned with their position – they left this option blank.
If a respondent confirmed that they were responding on behalf of an organisation they had the following options:
1. Producer Organisation
2. Fish Processing sector
3. Local Authority
4. Fish Seller /Vessel Agent
5. Representative Organisation
6. Onshore sector general
7. Port Authority/ Harbour Trust
This information assisted us in analysing responses to the consultation and we have sought to align our analysis along interest group lines.
Due to information within responses, we were able to identify the views of fishers associated with the pelagic fleet (referred to as: Individual fisherman (identified as pelagic) and have sought to differentiate between this category of fishers and fishers more generally (referred to as: Fishermen (not identified as pelagic). Five respondents stated that they were answering on behalf of a pelagic fishing vessel (all of which appear to be on behalf of the same vessel) these responses have been included as individual fishermen.
Responses were received from Producer Organisations in both Scotland and England. A response on behalf of the Scottish Association of Fish Producer Organisations was submitted and the United Kingdom Association of Fish Producer Organisations.
A profile of the respondents to the consultation is contained in Annex 2 and a list of the organisations who responded to the consultation and consented to the publication of their responses, is contained in Annex 3.
2.2 Cross-cutting themes
Many responses raised the following key themes in their response. We summarise these, often interrelated, key themes below.
Impact on the pelagic fleet
Pelagic fishers, some Producer Organisations and fish agents took the view that changes to the economic link licence condition were intended to subsidise the processing sector at the expense of the pelagic fleet. There were recurrent concerns that if pelagic vessel owners were to shift their landings to Scotland from elsewhere in order to comply with the proposed new economic link licence condition, they could suffer financial loss as prices tend to be less competitive in Scotland than in other countries and the change could result in result in processors offering lower prices. Concerns were expressed that the anticipated financial loss could be such that it would impact their viability.
Scottish pelagic processing
Many opponents, including pelagic fishers and some Producer Organisations claimed there is insufficient pelagic processing capacity, cold storage and freezing facilities in Scotland to facilitate increased landings of pelagic stocks.
Some cited a report by Poseidon Aquatic Resource Management Ltd which was commissioned by two Scottish Producer Organisations to consider the impacts of a landings target on the pelagic sector (the Poseidon Report). The report, which focused only on the landings target without acknowledging the option of meeting the proposed new economic link licence condition through quota gifting, suggested alternative approaches to achieving increased landings into Scottish ports.
Concerns were expressed about a lack of capacity to deal with increased landings of certain species such as blue whiting for which there is little processing capacity or internal markets.
Others took the opposite view, with some setting out that pelagic processing in Scotland has suffered from pelagic fish being landed abroad in recent years.
They welcomed the changes, arguing this would provide new opportunities for processors and enable them to plan more effectively; give a sound platform for investment, stimulate confidence in the sector and redressing the balance between fishermen and the onshore sector.
Some wanted the Government to go further, and faster, with a landings target of 55% to be implemented straight away and additional, specific targets for high value pelagic species such as mackerel. It was considered that this would avoid redundancies in the processing sector and the consequential damage this would cause to coastal communities.
Economic impacts – local fishing communities
Processors, some representative organisations, most local authorities, a Producer Organisation and some fishermen considered that landings were the most important factor for distributing the economic benefits from Scottish fish stocks to local fishing communities. Increased landings would provide downstream, socio-economic benefits for processors, the wider onshore sector (such as haulage), coastal communities and Scotland's economy as a whole.
To realise these benefits, increased landings of the most valuable species was needed. Other countries with high domestic landings were mentioned and described as providing a good model of how Scotland could benefit economically from higher domestic landings.
In contrast, opponents considered that the changes to economic link provisions would have a net negative impact on the Scottish pelagic catching industry with negative consequences on associated communities. It was felt there was no guarantee that it would result in greater economic activity overall with some citing the Poseidon Report to support this view.
Impact on the demersal and shellfish sector
There were concerns that the proposed changes would disadvantage Scottish demersal and shellfish vessels landing in other parts of the UK. It was stated that some of these vessels land their catch into UK ports outside of Scotland and transport it to Scotland for sale and processing with the result that Scotland receives the socio-economic benefits of this catch without it being landed it into Scotland. There were particular concerns by those connected to the plaice fishery for which there is limited Scottish processing capacity and for which key markets are abroad.
EU legislation and UK Fisheries Concordat and UK issues
Pelagic fishermen and some Producer Organisations stated that the proposed changes to the economic link licence condition would be in breach of the 2012 UK Fisheries Concordat. Further, it was stated that the changes would be a quantitative restriction on exports and in breach of Article 35 or Article 1 Regulation EU regulation 2015/470.
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