Fish farm consenting pre-application pilots: independent evaluation report

4. Discussion and conclusions

This section presents the discussion and conclusions from the thematic analysis of stakeholder views on the piloted pre- application process, based on data gathered through interviews and questionnaires. It draws on the findings described the previous section and explores how these data reveal opportunities for improvement, areas of concern, and perceptions of what is currently working well within the process.

The analysis is organised into four overarching themes, each representing a key area of focus identified during data collection. Within each theme, a number of sub-themes were explored to provide a more detailed understanding of specific issues or perspectives raised by participants. These sub-themes are supported by direct quotations from stakeholders, which serve to illustrate and contextualise the points being discussed. Where quotes have been shortened for readability, this is clearly indicated to preserve the integrity of stakeholders’ words.

The section aims to present these insights in a structured and accessible way. Each theme is introduced with a short overview, followed by an explanation of each sub-theme. The inclusion of participant quotes helps to retain the authenticity of the data and foreground the voices of those involved in the consenting process. Any gaps in supporting evidence or areas requiring further clarification are highlighted throughout.

4.1 Limitations of the methodology

As with any evaluation of this nature, there are a number of methodological considerations to note. The study draws on thematic analysis to explore qualitative feedback, which is a well-established approach for identifying patterns in stakeholder responses. While this method naturally involves interpretation, care was taken to ensure consistency through a structured coding process, the use of a small and consistent analysis team, and regular peer discussion throughout the development of themes.

The quantitative element of the study, based on Likert scale survey responses, provided useful directional insights into stakeholder perceptions. While this type of data does not allow for in-depth statistical analysis, results were used in combination with qualitative data to build a more comprehensive picture of stakeholder experiences.

The use of auto-generated transcripts for interview data supported timely analysis and accessibility. These were reviewed manually by the analysis team to ensure accuracy, and any inconsistencies were addressed through cross-referencing with notes and interviewer recall.

The evaluation aimed to include a wide range of stakeholder views. While participation was voluntary, efforts were made to ensure balanced representation across stakeholder types. Where numbers were smaller, data were treated proportionately and used to identify indicative trends rather than definitive conclusions.

Finally, as with all self-reported data, there is the possibility of response bias. However, the study design encouraged open, anonymous input, and the findings are strengthened by the consistency of themes emerging across multiple sources and stakeholder groups.

4.2 Theme 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.

Sub-themes within this theme include;

• Clearer guidance required
• Delays to guideline timeline
• Guidance was clear
• Lack of clear coordination (Confusion over who is responsible for what tasks)
• Perceived lack of transparency within the process
• Resource and capacity management (Issues with staffing capacity caused resourcing issues throughout the process)
• Uncertainty in meeting future timelines

Stakeholders consistently described how inconsistent guidance, unclear responsibilities, and a lack of communication across regulatory bodies caused confusion and delays. One consultee noted that “there was maybe inconsistency in how we received requests… it was unclear if we were supposed to be feeding back advice directly to a developer or to SEPA.” Others raised the issue of unclear or outdated forms, with one developer asking “where would you find the current forms?... It just seemed a bit haphazard.” The lack of a central, accessible repository for up-to-date documents was seen as a basic but critical gap.

Several participants described duplicated effort due to misaligned timelines and expectations between consultees, with one consultee explaining, “we had to reach out to SEPA to confirm that [the project] was part of the pilot scheme.” These kind of comments illustrate how limited coordination can undermine the intended streamlining benefits of the pilot process.

Several participants pointed to the administrative burden of unclear or shifting timelines. One consultee shared their frustration “...just a bit frustrating... then that was not actually the deadline in the end…” while a developer described the need to constantly chase responses: “...a lot of extra effort on my part to have to constantly follow up...”

Delays were widely reported, with several participants highlighting how guideline timelines were routinely missed. One developer recounted that, “we're talking like 13 weeks before we received the [draft]... it was, I think, 23, 24 weeks before we actually got the final draft report…” While some recognised that guidance was generally clear, this view was not consistently echoed across participants.

Some stakeholders also emphasised that inconsistent or vague language in consultation requests affected the quality of their responses. As one consultee put it, “Some just request showstoppers, some go into a lot more detail, and that may affect the level of detail we give.” Another added that “some standard wording from applicants would be useful for consistency… if they could be clear exactly what we are being asked.” This lack of clarity contributes to misaligned expectations and fragmented responses across organisations.

Coordination between agencies was another area of concern. In several cases, responsibilities were unclear, requiring stakeholders to chase responses or seek clarification themselves. As one consultee put it, “The request for pre-app advice came in directly from the applicant. We had to reach out to SEPA to confirm...” A developer raised concerns about language used in documentation, saying, “showstopper is not a great word to carry over into a formal document...” suggesting that tone and terminology used in communications can impact perceptions of transparency and fairness.

Some regulators reported confusion around roles, expectations, and overall coordination. There were comments about inconsistent communication, unclear guidance, and a lack of a central point of contact for example “We had to go in a bit of a search mission at that point and find out well, what is the expectation for handling this process. Who are we responding to? What is this process?”. The absence of clearly defined responsibilities—particularly at early stages—led to missed or delayed engagement, varying interpretations of expectations, and challenges aligning inputs across agencies.

Some regulators noted they were unsure whether feedback should go directly to the applicant or through SEPA, and there was uncertainty about how to engage with evolving templates and procedural documents. In several cases, feedback processes were described as disjointed or duplicative, particularly where the same information was requested multiple times or presented without clarity on how it would be integrated into the overall assessment.

While some participants acknowledged improvements later in the pilot process, particularly as relationships and expectations became clearer, early-stage coordination issues remained a prominent barrier to effective engagement and timely responses.

Transparency itself emerged as a concern, particularly around perceived rigidity in the process. A regulator shared, “...everyone thought it was really rigid... we always said from the start it was going to be an iterative process...” while another observed inconsistency in how different companies approached pre-application engagement.

Capacity constraints added further pressure to the process. One consultee commented, “One of the biggest problems we have is the resource … to deal with it and process it...”, highlights the challenges faced by under-resourced teams.

A suggestion made by a few stakeholders was the appointment of a central coordinator. As one participant explained, “...still in the situation, where it's incredibly uncoordinated...” and one developer emphasised, “...we very firmly believe a ringleader is key to the process...”. and another consultee said “On one case… person is going to be assigned to you and take it right through. That's really important.”

It should be noted that some participants added to these points that some of these issues have been improved throughout the pilot process, with more clear guidance and templates having been developed and issued at various stages throughout the pilots.

While many stakeholders highlighted areas for improvement, there were also clear indications that the pilot process had led to positive changes. Several participants noted a growing familiarity with the process among agencies and a clearer understanding of roles and expectations over time. In some cases, stakeholders were engaged earlier than they had been in previous applications, aligning with the intended aim of front-loading consultation. There were also examples of improved coordination, such as regulators proactively confirming consultation periods and communicating more effectively with consultees. These examples suggest that, although implementation challenges remain, the pilots have implemented improvements over time.

4.3 Theme 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.

Sub-themes within this theme include;

• Early identification of key risks within a site (Proactive process of identifying potential impacts or risks that could deter the application in later rounds of the planning process)

Participants expressed value in opportunities to identify key risks early in the process (although this was low in frequency of occurrence, relative to other sub-themes (See Figure 3.1)). They described how early dialogue could prevent wasted effort and reduce the likelihood of issues emerging late in the application. One consultee appreciated the value of formalising this early engagement, stating, “...having this formalised version means that if there are concerns, we could have a joint meeting with a developer at an early stage.” Another consultee noted how a simple early conversation might have avoided significant issues in an historical example citing: “...there was no way we could support it... navigational issues... a simple chat before would have avoided the pain...”

This sub-theme underlines the benefits of shifting from reactive to proactive engagement, allowing constraints to be addressed at the earliest stage.

4.4 Theme 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.

Sub-themes within this theme include;

• Concurrent stakeholder engagement (Stakeholder engagement running in parallel with process, not only completed in Stage 3)
• Conflicting stakeholder perspectives (Differences of opinion between regulatory bodies causing confusion in reports)
• Earlier engagement with community and stakeholders required
• Feedback mechanisms with stakeholders
• Impact of terminology on public perception (Use of scientific wording creating potential negative connotations within the public, e.g., showstopper).

The process of engaging third parties—particularly communities and consultees—was identified as an area in need of improvement. Participants called for engagement to occur much earlier and more holistically, rather than sequentially. As one put it, “The engagement with third party public and community stakeholders needs to commence much earlier...” This view was echoed by another participant who valued being able to understand how others were interpreting the application: “...handy to know how everybody else was viewing them…”

However, this broader engagement sometimes introduced complications. There were reports of conflicting messages from different agencies: “...a couple of the respondents had come back with slightly conflicting information.” Such inconsistencies could undermine confidence in the process and add complexity for applicants.

The use of some language was also flagged as problematic. Terminology such as “showstopper” was seen as potentially alarming or off-putting to non-specialists. One participant raised concerns about the wording, stating, “...concerned about some of the comments and language used... not too happy [with] how it was worded...” This highlights the need for sensitivity in how technical judgments are communicated to broader audiences.

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

Sub-themes within this theme include;

• Administrative burden (Excessive paperwork, redundant work, and unclear instructions leading to more work for developers.)
• Expansion of pilot (Potential expansion to other regions/all of Scotland/further afield)
• General positive feedback
• General uncertainty over process
• Improved communication needed
• Need for external coordinator (The need for external management or a central coordinator to guide these applications through the process)
• Pilot process changes
• Quality assurance within reporting (Errors and Structure issues within reporting)
• Streamline next processes (Recommendations or comments on how to streamline the next processes, e.g., scoping and EIA)
• Tone of cooperation needed (Tone, and feel of communication throughout the process needing to be changed more to cooperation)
• Unclear level of detail required in early stages

The final theme captures a range of suggestions and reflections on how the process could evolve. Some feedback was positive—with participants recognising the value of collaboration—there remained uncertainty about how the process was meant to function. One participant reflected, “...working together... can only help for better... quality decision making...” but other aspects, such as what level of detail was expected at early stages, remained unclear. One stakeholder asked, “...what is the expectation for this pre application sort of stage...” while another noted that, “...it seems like... there's more work to be done at the beginning, but it will speed up the application process at the end...”

Communication was seen to be improving, with one participant saying, “Hopefully we're all collectively learning from... the last year,” but the consensus was that more structure and support were needed.

The pilot process itself received mixed feedback. Some felt it added complexity: “...another step to a process [was] one more thing that you have to try and find time for...” whereas others recognised the potential value of an evolving model, saying, “...providing the system works efficiently, it’s a good way of doing it.” Concerns about report quality, including grammar and structure, were also noted.