Fish farm consenting pre-application pilots: independent evaluation report

Executive Summary

Aquaculture, particularly finfish farming, plays a vital role in Scotland’s economy and coastal communities. However, the sector has faced longstanding challenges with a complex and often fragmented consenting process. In response to recommendations made in the Griggs Review (2022), the Scottish Government established a Consenting Task Group (CTG) to improve the efficiency, clarity, and transparency of aquaculture consenting. One key initiative led by the CTG was the development and trial of a revised pre-application management process, piloted across four sites within Shetland and Highland Council areas. These pilots aimed to address the inefficiencies in the current system by streamlining the pre-application stage, improving inter-agency coordination, and enhancing stakeholder and community engagement.

Aquatera Ltd. was commissioned to carry out an independent evaluation of the pilot pre-application process. The evaluation focused on how effectively the pilot process delivered against the four agreed CTG outcomes:

1. Delays in the consenting process are minimised by removing unnecessary downtime, duplication, and non- value-added steps. Improved co-ordination between regulators to facilitate communication and streamline the consenting process.

2. The consenting process provides developers with an early understanding of potential constraints, leading to a reduced time to achieve all consents and ensures developers know and understand information required to support a regulatory decision.

3. The consenting process includes simple, clear mechanisms for informing and facilitating third party engagement. Improved transparency and community engagement by ensuring an effective and meaningful opportunity for communities, consultees, and other interest groups.

4. Identification of any remaining issues or areas for further exploration within a continuous improvement project.

The evaluation also tested the pilot against a set of agreed principles including joint regulator engagement, early and efficient targeting of advice, clarity in information requirements, and maximising early input from stakeholders. The study aimed to assess whether the revised four-stage pre-application process—now streamlined into three stages— improved upon the current system. Through mixed-method stakeholder engagement and data analysis, the evaluation gathered insights from regulators, developers, and advisory bodies, focusing on issues such as resource demands, timelines, communication effectiveness, and perceived procedural barriers. This evidence base informed a series of findings and recommendations to guide the future development of a more effective and coordinated consenting process for Scottish aquaculture, supporting the industry's long-term sustainability and regulatory confidence.

This evaluation adopted a structured, mixed-methods approach to assess the effectiveness of the pilot pre-application process in line with the four outcomes set by the CTG. Engagement focused on stakeholders directly involved in or impacted by the pilot process, including developers, regulators, advisory bodies, and community groups. A Stakeholder Engagement Plan guided all interactions, ensuring a transparent and ethical process compliant with data protection regulations.

Quantitative data was collected through a tailored online survey (Microsoft Forms). It used Likert scales, ranking questions, and skip logic to gather targeted feedback across each of the four pilot stages. Due to the small number of participants, analysis focused on the detail of individual responses. Frequency distributions and measures of central tendency, including the weighted median, were used to interpret stakeholder perceptions. It should also be noted that the survey was conducted when most respondents had not yet completed the pilots and so only those questions specific to Stages 1, 2 and 3 were included in the analysis and the general questions should be interpreted with this in mind.

In parallel, qualitative insights were captured through semi-structured interviews, allowing stakeholders to explore experiences, perceptions, and barriers in greater depth. Transcripts were generated and analysed using Braun and Clarke’s thematic analysis method. This process identified recurring sub-themes and grouped them into overarching themes. The results were presented with accompanying frequency counts that reflect how often each theme or sub- theme was referenced — allowing for multiple mentions by the same participant.

Together, these methods provided a robust evidence base to assess how well the pilot process delivered on the CTG outcomes and to identify practical opportunities for improvement and future implementation.

This evaluation combined quantitative survey data and qualitative insights from semi-structured interviews to assess stakeholder perspectives on the pilot pre-application consenting process. Survey responses (n=11) indicated moderate satisfaction overall, with the average score for general satisfaction being 3 (Moderate) on a 5-point Likert scale. While some stakeholders reported early identification of potential constraints, perceptions were mixed regarding how effectively the pilot streamlined the consenting process.

Qualitative thematic analysis were categorised under the four overarching themes aligned with the CTG outcomes (listed above). Within these, a number of sub-themes emerged — including calls for clearer guidance, improved communication, better-defined stakeholder roles, and concerns around administrative burden and resourcing. Positive feedback highlighted the potential for joint advice and integrated processes to improve predictability and clarity for applicants. The frequency of sub-theme references was used to identify the most commonly raised issues across stakeholder groups, with stakeholder type (developer, regulator, or other) considered in the analysis. Together, these findings offer valuable insights into the strengths, challenges, and future opportunities for a more streamlined, transparent and collaborative consenting regime for finfish aquaculture in Scotland.

From these results, ten practical recommendations were developed to support the continued improvement of the pre application process. These recommendations are structured under the four agreed CTG outcomes (themes) and directly informed by the quantitative and thematic analyses. They reflect the stakeholder experiences captured through both questionnaires and interviews. Each recommendation is presented along with an impact statement describing the impact that is expected to result from the implementation of that recommendation.

1. Provide a structured feedback mechanism for applicants and consultees, to inform the continuous improvement and refinement of forms and document templates.

Impact – provides an opportunity to review and refine the level of detail required at each stage of the process and as such, to reduce duplication of effort, identify opportunities to streamline information and timeframes, provide greater flexibility to incorporate lessons learned, and reduce administrative burden.

2. Monitor timelines to establish key timescale drivers and identify opportunities for improvement and consistency.

Impact – provides an opportunity to reduce delays, improve coordination of document receipt and deadline communication, and work towards the delivery of clear and consistent timelines for applicants and all consultees.

3. Encourage all parties to use language in guidance documents, communications, consultation materials and responses, which reflect a commitment to mutual learning and constructive dialogue.

Impact - improved communication and relationships between all parties, reduced delays resulting from unconstructive communication.

4. Establish a clear mechanism to help ensure all parties are aware of and have access to most up to date templates and guidance.

Impact - Help ensure that information provided and responses received are aligned with most recently agreed and adopted versions, reducing potential for delays and duplication of effort.

5. Consult regulators, stakeholders and industry to explore other ways of improving coordination, including the potential benefits and challenges associated with establishing an ‘independent process champion’ or ‘process coordinator’ to oversee the pre-application journey and wider planning process.

Impact – improved consistency and continuity throughout the process, reducing the impacts of team/staff changes, improved communication between all parties, more collaborative problem-solving and dialogue, single point of contact and dedicated website or area within a website for template and guidance updates and procedural changes, management of key points of contact, facilitation and delivery of continuous improvement.

6. Ensure advice and/or recommendations provided by consultees in pre-application advice are targeted, substantiated, caveated appropriately, case specific and appropriately detailed.

Impact - help manage expectations for all parties throughout the process, help ensure that issues raised or resolved are captured and communicated appropriately during the process.

7. Identify and explore options and opportunities to standardise the way in which advice is provided applicants, including ‘processing agreements’ which can be used to help clarify what advice should be provided by consultees at each stage of the process.

Impact - help ensure a consistent approach across applications and regulatory bodies, help distinguish between broad issue-spotting and detailed feedback, help ensure that advice received is aligned with applicants’ expectations and help applicants frame requests transparently and consistently.

8. Provide guidance on, and promote best practice around early-stage engagement with consultees and communities

Impact - Help improve communication with external consultees, identify and maintain points of contact, a dedicated website or webpage and establish clear communication plans for each pre-application. Help ensure that early-stage engagement with consultees and communities is timely, transparent and meaningful for all stakeholder groups. Provide clarity around how the pre-application process fits within the wider planning process and other early-stage community and stakeholder engagement activities, helping frame consultation as an ongoing, iterative process rather than a one- off requirement, promoting collaboration and ensuring local knowledge is integrated meaningfully into project development and planning processes.

9. Incorporate option(s) for joint meetings between applicants and consultees into the pre-application process and timeline

Impact - Improve early engagement and information-sharing between applicants and consultees, and identify any conflicting perspectives or opportunities at an early stage and facilitate the development of unified responses where possible.

10. Establish a clear process for improving communication with consultees, and formally communicating the outcomes of discussions during the pre-application process

Impact - help ensure that decisions taken, key points discussed and any issues resolved are captured and communicated, which will help manage ongoing expectations between applicants and consultees, reduce ‘knowledge loss’ and reduce duplication of effort.

The recommendations outlined in this section build directly on the thematic analysis of stakeholder experiences and reflect a strong consensus around the key areas for improvement. Across all four outcomes—minimising delays, supporting early understanding, improving engagement, and driving continuous improvement—participants provided detailed feedback on where the consenting process works and where it needs further refinement. By structuring these recommendations in alignment with the core themes and sub-themes, this section ensures a strong connection between stakeholder experience and practical action. Implementing these changes will help build a more transparent, efficient, and collaborative process—one that supports timely decision-making while maintaining the quality, clarity, and integrity of engagement with all parties involved.