Fish farm consenting pre-application pilots: independent evaluation report

5. Next Steps and recommendations

This section presents the practical recommendations 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 thematic analysis discussed in the previous chapter. 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.

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

As outlined in the earlier thematic analysis, stakeholders cited concerns regarding delays in meeting timelines and inefficiencies resulting from unclear guidance and coordination. Although it was acknowledged that improvements had been made within the timeline of the pilots, these occurrences of extended wait times for draft reports highlighted the need for process streamlining. Administrative burden was also a key sub-theme, with excessive paperwork and unnecessary steps adding to the overall timeline.

The importance of leadership and coordination was especially evident in the sub-theme calling for an external coordinator or to guide applications and maintain consistency.

To address these issues, the following recommendations are proposed:

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.

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

As highlighted previously, early dialogue was often viewed as essential to avoiding wasted effort and late-stage objections. This proactive approach to identifying risks aligns with the sub-theme on early identification and underscores the importance of formalising pre-application discussions.

To address these issues, the following recommendations are proposed:

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.

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.

The theme of third-party engagement revealed a strong desire for earlier, more transparent, and coordinated communication with community stakeholders. Participants emphasised the need for engagement to begin well before Stage 3. The sub-theme of “conflicting stakeholder perspectives” underscored the importance of synchronised input and shared understanding across regulatory bodies.

To address these issues, the following recommendations are proposed:

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.

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

This final outcome highlights the opportunity to embed continuous improvement throughout the consenting process. As demonstrated in themes around pilot process changes, and the tone of cooperation, there is an appetite among stakeholders to refine the process iteratively.

One key sub-theme falling under this outcome was the “unclear level of detail required in early stages.” Several participants voiced uncertainty around expectations for pre-application submissions. These reflections suggest a need for standardised expectations and clearer guidance.

Recommendations made under previous themes encompass the points raised under Theme Four. No further recommendations made under this general theme.

Conclusion

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 previously discussed, 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.