Inshore Fisheries Management Improvement: call for evidence analysis report

Part 4: Regional Inshore Fisheries Management

Question 8: Do you favour or oppose a potential transition to a more regional model of inshore fisheries management in Scotland?

96 respondents provided an answer to this question (see table 3). A majority of respondents (76) favoured or moderately favoured a more regional model of inshore fisheries management in Scotland. Some respondents (10) opposed a more regional model.

Table 3: Responses outlining whether respondents favour or oppose a potential transition to a more regional model of inshore fisheries management in Scotland.

	Number of respondents
Strongly favour	61
Moderately favour	15
Neutral	10
Moderately oppose	7
Strongly oppose	3
Not answered	4
Total	100

68 respondents provided an explanation for their opinion, of which 7 had responded neutrally, 8 had opposed a more regional model and 53 favoured a more regional model. Due to the low number of respondents who selected that they opposed or were neutral towards a regional model, responses are detailed in the text where three or more respondents detailed a theme, to enable greater explanation of these views. Views have been described under the headings of favour, oppose and neutral for ease of reading.

Favour

Local approach

A common theme across respondents was the view that a more local approach would generally result in more successful outcomes. Several respondents felt that local approaches would be better tailored to suit local needs, with a small number highlighting that this would increase transparency and policing of local management, as well as making it more responsive to changing circumstances. In addition, a small number of people felt that a local approach would help to increase a sense of ownership and responsibility for fisheries. Some felt that a more local approach would increase accountability to ensure that management is fit for purpose locally whilst helping to meets wider national objectives. Finally, a small number of respondents felt that a local structure would support research at a local level, helping to develop a local evidence base that can better inform management.

One respondent felt that currently priority is given to areas with more fishing vessels and bigger ports, and felt that a regional approach would be beneficial for all ports and in particular smaller fishing communities to ensure all fishers are heard. Another felt that a more regional approach would benefit from development of local strategies to underpin management decisions. One felt that a small area would enable a local representative to be more readily available to support local management.

Stakeholder engagement

Among those who favoured a regional approach to inshore fisheries management, there were some conflicting views regarding stakeholder engagement at the local scale. A small number of people felt that management should be led by local fishers within the given region, whereas some felt that a much wider group of stakeholders who have an interest in the local marine management should be involved in fisheries management discussions.

Some respondents felt that regional management would be beneficial because it would allow local communities and industry to have a voice in fisheries management, with some highlighting that it would be important to allow representation from all with relevant interests. A small number expressed views that management must be inclusive and fair/balanced across stakeholder interests. One respondent felt that a regional approach might improve communication by making it easier to make contact the appropriate representatives.

Diverse industry

Some respondents felt that a regional approach to fisheries management would enable better management due to the diversity of the industry across Scotland. A small number felt that this would enable a more tailored approach more appropriate to each region, with some flagging the different environments, fisheries and priorities around Scotland’s coast. A small number also felt that this would enable adaptive management that is more responsive to change. One respondent simply felt that the industry was too diverse to be managed at a national scale.

National framework

Some respondents, whilst supportive of a regional model, outlined the need for regions to operate under a national framework to ensure consistency and accountability. In particular, a small number flagged the need for a national component to the model to ensure accountability against national and internation biodiversity commitments. One respondent felt the a national framework/plan should be a subset of the National Marine Plan. Another felt that there should be a national group with oversight that should mirror the regional groups in order to support understanding of the system by all.

IFCAs

Some respondents identified IFCAs in England as an example of regional management that is perceived to be working more effectively than current management practices in Scotland (e.g. allowing regions to tailor their fisheries approaches to local areas; clear aims and objectives), and felt that potential regional management in Scotland should be guided by the IFCA model. One respondent felt that:

“The argument that such a system is unaffordable…is simply not credible. While a consultation is welcome, excluding this proven and effective management model from consideration is unacceptable.”

In addition, a small number of respondents felt that a regional model akin to that of the IFCAs could be beneficial to enable collection of locally important data.

RIFG criticism

Some respondents favoured a regional approach but cited criticism of the RIFG networks. A small number of respondents felt that the area covered by each RIFG is too large and they do not properly represent people at a local scale. Finally, a small number of respondents felt that the lack of statutory footing underpinning the RIFGs has limited their ability to make a difference or resulted in their inability to deliver local management, and felt they should be held accountable to deliver on clear objectives.

Resource

A small number of respondents were supportive of a regionalised model but flagged that it must be properly resourced and should enable sufficient resource for science. One respondent suggested using resources currently used to maintain Marine Directorate’s coastal Fishery Offices to instead support an IFCA-like entity.

Improved management

A small number of respondents felt that local decisions would be more effective so long as it is properly set up, enabling it to be more transparent and increasing how easily resulting management can be enforced. One respondent cited an example where local management was felt to have resulted in improved fisheries management.

Technology/ data

A small number of respondents who favoured a regional approach mentioned technology. One felt that encouraging fishers to adopt new technologies such as REM would lead to improvements in fishing efficiency. They also felt this would increasing a sense of ownership/responsibility as fishers become more connected to the data that informs decision making. Others felt a need to data to be gathered locally and that it should be sufficiently accessible to enable it to effectively inform local fisheries management.

Considerations for implementation and subsequent management

Although this question sought input to inform the development of a new management model, some respondents provided comments relating to implementation and specific management tools.

Some respondents were supportive of regionality and felt that the Scottish Government should apply an ecosystem approach when developing a new framework, focussing on the needs of the ecosystem when determining regionality to ensure that local, national and international environmental commitments are met. One respondent felt their support for alignment with the Convention of Biological Diversity’s Ecosystem Approach which supports decentralized systems.

A small number of respondents took the opportunity to suggest specific localised management tools that they felt could be used under a new management framework, in particular some sort of regional permit/licence system. One suggested this would enable all permitted fishers in a given region to be consulted in an open and fair way on management decisions; another felt that a committee made up of local fishers and Fishery Offices should be responsible for administering such a system.

Other

Other responses provided by respondents included criticism of centralised decision-making; criticism of the current model; marine spatial planning; examples from the Shetland model and the Mull creel limit pilot project; and a need for strict enforcement.

Oppose

Responsibility

A small number of respondents felt that there was insufficient detail available about where responsibilities within a regional management system would lie to support it, flagging that we need to be clear about this if we proceed with a regional model.

License/ permits

A small number of respondents flagged issues that they felt would come about if some sort of regional licence/permit system were brought in. One felt that regional variation would result in the dilution of licence conditions and subsequently make it more difficult to buy and sell vessels. Another felt that existing examples of local management schemes with discrete permits have resulted in expensive permits and that it had not benefited the local fleet.

Would not work

A small number of respondents felt that a regional approach would not work well. One felt that too much variation of control may impact on supply changes. Another felt that boundaries could cause displacement and overfishing in specific areas. One felt a regional system would make it harder to take account of legitimate interests from users who live outside of the area.

Fishing in many areas

A small number of respondents felt that some fishers in Scotland require flexibility to fish in a number of areas (“nomadically”), and that a national approach is therefore preferable. One felt that boundaries could cause displacement of fisheries, leading to overfishing in specific areas (though they were supportive of larger scale regional control with geographical boundaries).

Other

A range of other topics were raised by a small number of respondents who were opposed to a regional approach. These included; the Shetland Regulatory Order, negative impacts of creating division, and issues with resourcing.

Neutral

National plan

A small number of respondents did not have issues with a regional model but felt that a national plan was necessary; both to ensure clarity of strategy and accountability, and to ensure fairness across the board.

Other

A range of other topics were raised by a small number of respondents. These included; the Shetland Regulatory Order, an ecosystem based approach, and local decision making.

Question 9: What should we be mindful of when considering the potential transition to regional inshore fisheries management in Scotland?

79 respondents raised themes that they thought we should be mindful of when considering a potential transition to regional inshore fisheries management in Scotland. Answers can be summarised into five themes: governance; stakeholder engagement; fishing differences; environmental considerations and speed of delivery. Each theme will be detailed in turn, with sub-topics within these themes discussed in order depending on how frequently they were mentioned by respondents.

Governance

National level governance

Several respondents raised the view that any move towards regional management will need to be mindful of national obligations and will require national level structure. Some respondents raised the view that any regional management will need to be integrated consistently with national planning and policy and help to deliver on national and international commitments (e.g. National Marine Plan; Good Environmental Status; Marine Strategy Framework Directive; OSPAR). Mirroring comments made in response to question eight, it was felt by some respondents that there is a need for an overarching national strategy, national standards and that the Scottish Government will need to define what regional management will look like (e.g. legislative instruments; how decisions will be made; consultation; rules; how obligations will be met; objectives; what will be decided nationally vs regionally). A small number felt there is a need for national level oversight, with strong management (perhaps through Steering Groups, or skilled facilitators) and a clear framework. Some respondents felt that integrating regional inshore fisheries management into regional spatial planning could be a key way to ensure fisheries are not dealt with in isolation, and could provide a good framework for action.

Resources

Several respondents raised a need to be mindful of resources when considering a potential transition to regional inshore fisheries management. It was raised by some respondents that it was necessary for the Scottish Government to commit to adequate funding of local management at an early stage, which should be sustainable long term and ongoing, to enable effective regional management. A small number of respondents felt that local management will be ineffective without appropriate resource, and resources will constrict how effective management is. It was felt by one respondent that a move to a regional model will be a net cost, and a small number of respondents raised the need for use of funds to change to support this approach. Some respondents raised a range of additional areas which require further funding, including supporting participation in regional management, funding science and monitoring, education, employment, enforcement and enabling fishers to diversify. However, a small number of respondents simply felt that the Scottish Government has limited resources with one highlighting that there are not enough funds to support regional management.

Data

The importance and quality of data collection and analysis was reported by some respondents. It was felt by a small number of respondents that there is a need to gather quality scientific data to inform decision-making for regional inshore fisheries management. A small number felt that data collection and analysis could occur both nationally and regionally, and that it could be shared between industry and scientists. One respondent felt the importance of defining a structure for how data will be collected and used. A small number of respondents felt the need for a national depository of data and sharing between regions, with a small number highlighting the importance of data being accessible. A small number of respondents felt new technologies could improve data being collected, with one respondent highlighting the need for scientists to keep up to date with Artificial Intelligence (AI) tools to assist with analysis. It was highlighted by one respondent that any data collection will require resources, with another respondent highlighting that data collection could be improved.

Enforcement

Some respondents felt that we need to be mindful of enforcement when considering the transition to regional inshore fisheries management. It was the view of a small number of respondents that there needs to be a regional/ local ability to enforce compliance with fishing rules. A small number felt that modern technology could help to improve enforcement. Additionally, one respondent felt that it could be difficult to ensure enforcement when rules vary regionally. Another highlight that resources are needed for enforcement, whilst one respondent suggested that license points or disqualification could be suitable methods of penalty to deter non-compliance.

IFCAs

As echoed in some responses to question eight, some respondents responded to this question with their view that we should look to the English IFCA model to learn about how regional inshore fisheries management could be facilitated. Successes of the IFCA model were outlined by a small number of respondents, these included: the power to make byelaws; remit to protect the environment and fisheries interests; resources for monitoring, implementation and local enforcement; heterogeneous membership; integration with national policy; and the involvement of local authorities. A small number of participants outlined perceived issues with the IFCA model, with concerns about reliance on local authorities, inadequate funding, and relationships between IFCAs cited.

Local authorities

A small number of respondents felt it important that strong links are created between local authorities and any regional inshore fisheries management groups. It was raised by a small number of respondents that this could help increase democratic accountability of inshore fisheries management.

Stakeholder engagement

Balance of stakeholders

A common theme raised by respondents was the importance of being mindful of balancing interests of stakeholders and ensuring inclusive engagement in making decisions for regional inshore fisheries management. It was felt by some respondents that involvement in regional inshore fisheries management needs to be well balanced in the participation of stakeholders. Balance was raised by several respondents in reference to including a full range of different fishing interests (all different forms of fishing, non-fishing interests, communities, viewpoints) as well as including a range of non-fishing stakeholders, including local interest groups, businesses, local communities, environmental groups, and recreational groups. It was felt by one respondent that:

“participation in regional governance must be fair and inclusive, ensuring that marginalised or under-represented voices are identified and brought in”

It was the view of a small number of respondents that any engagement should be inclusive of voices that might not otherwise be heard. They felt that all stakeholders should be truly listened to and not drowned out, with not all ideas coming from the Scottish Government. A small number of participants felt the importance of ensuring the right people are involved in decision-making to ensure unbiased priority setting. It was raised by a small number of participants that engagement needs to be planned in advance, with processes well defined, including potentially supporting involvement through financial assistance (e.g. of small-scale fishers). It was the view of a small number of respondents that management should involve a balance of interests - “in balance with available stocks and having a healthy marine environment”. One respondent outlined their view that it was important that managers have connections to the local area, but also recognised it would be challenging to ensure these individuals do not have a financial interest in coastal areas, which they felt would bias their inputs.

Involving local communities

Some respondents outlined the importance of being mindful of local communities when considering a transition to regional inshore fisheries management. A small number of respondents felt a need to work closely with local communities, genuinely listen to local communities, hear their concerns and gain their support. One respondent felt that “local stakeholders must feel that their opinions count”. A small number of respondents outlined the importance of enabling local communities to get involved in fishing/ fishing management, and the importance of giving agency to local communities.

Fishing differences

Variation in the industry

Some respondents felt that we should be mindful of regional differences associated with fishing (including traditions), and the varying forms of diversity within the fishing industry (e.g. different gears, target species, views of fishers and sizes of effort) when considering a transition to regional inshore fisheries management. One respondent felt that every area is different and that there is “not a one size fits all approach”, with another highlighting that regional management allows “custom approaches to fisheries management”.

Different rules in different areas

Some respondents raised concerns about potential adverse impacts of regional inshore fisheries management due to there being different rules for fishers in different areas. Some respondents felt that fishers might be displaced between areas to avoid local rules which could impact local areas, with a small number of respondents raising concern about regions needing to work together to ensure that management in one area is not negatively impacting other areas. A small number outlined the view that some fishers are nomadic and regularly move their effort between different areas. A small number of respondents felt that fishers might find it difficult to be aware of varying rules in each area, may end up overfishing areas and it may also be harder to enforce rules that vary per region. A small number of respondents felt that regional management could result in different solutions to the same issue. One respondent felt that “harmonisation of fisheries management measures across boundaries should be considered”.

Protecting fishing

A small number of respondents raised the view that fishing should not be negatively impacted by a transition to regional inshore fisheries management. For instance, they felt that it should not adversely impact the movement of boats allowed, should ensure fish stocks are protected, that the industry is profitable, and should be well managed to make it a viable career option for young fishers. One respondent felt it would be beneficial to focus on the economics of the fishing fleet.

Local management

A small number of respondents outlined the importance of local management when considering a transition to regional inshore fisheries management. Similarly, a small number specified views around the importance of those managing inshore fisheries having local knowledge of the marine environment and fisheries, and connections to local communities. A small number of respondents felt it important to involve local fishers from the grassroots in decision-making.

Environmental considerations

Environmental impacts

Some respondents felt it important to be mindful of environment impacts and protecting the environment when considering a transition to regional inshore fisheries management. One respondent outlined the need to consider changing fishing practices in response to climate change and other marine conditions. One respondent highlighted the importance of ensuring that “economic interests must not take precedence over environmental protection”.

Just transition

Some respondents felt that it is important to be mindful of ensuring a just transition (for fisheries/ the environment/ communities) when considering the transition to regional inshore fisheries management. A small number of respondents highlighted the importance of ensuring stakeholders are listened to in order to enable a just transition.

Speed of delivery

Change takes time

It was the view of a small number of respondents that it will take time for a move to regional management to occur, with one respondent highlighting the importance of the process being completed gradually.

Other

A range of other topics were raised by a small number of respondents. These include: monitoring and evaluation; fisher input; acting with haste; ecosystem-based management; including local knowledge; flexibility in management; set objectives; licensing and well considered management.

Question 10: Could any of the existing coastline delineations (as outlined above) be used for regional inshore fisheries management or do we need a new/different approach/delineation?

54 respondents provided details of coastline delineations that they thought could be used for regional inshore fisheries management (see table 4). Some respondents provided more than one answer. The most frequently mentioned delineation was Scottish Marine Regions, of which 20 respondents suggested a preference for this option. 12 respondents felt that Regional Inshore Fisheries Groups should be used (7) or inshore fisheries management should use the delineations already used (5) whilst eight respondents thought that a new approach is needed, and eight respondents detailed other options. Five respondents referenced specific geographic areas and five respondents thought that small areas are better. One respondent thought that Coastal Operations Districts should be used, whilst no respondents thought Fisheries Offices, Scotland Island Regions or Scientific Stock Assessment Areas should be used.

Table 4: Respondent’s suggested coastal delineations for a regional management model.

Delineation	Number of respondents
Scottish Marine Regions*	20
Regional Inshore Fisheries Groups*/ keep how it is	12
Coastal Operations Districts*	1
Marine Directorate Fisheries Offices*	0
Scotland Island Regions*	0
Scientific Stock Assessment Areas*	0
New approach needed	8
Smaller areas are better	5
Reference to specific geographic areas (e.g. The Hebrides/ Firth of Clyde)	5
Other	8

*these delineations were listed as examples within the Call for Evidence text.

35 respondents gave details of why they selected their delineation, however there was very little consensus amongst respondents. Due to the low number of respondents who selected different delineations, responses are detailed in the text where 2 or more respondents detailed a theme, to enable greater explanation of these views. The only delineations with any consensus (more than 1 respondent) in their explanation was for ‘Scottish Marine Regions’ and for a ‘new approach needed’. For Scottish Marine Regions, a small number of respondents thought they should be used to align with marine spatial planning, with small numbers of respondents also stating that: RIFGs are too big, new delineations would delay action and that management should be up to 12 nautical miles. For a ‘new approach needed’ a small number of respondents simply thought that the current system and existing delineations are not working.

Question 11: Please explain why the delineation you suggested above would work better than others? What are potential benefits/strengths of this approach?

48 respondents provided explanations as to why they thought the delineation they selected for regional inshore fisheries management would be better than others. Due to the low number of respondents who selected different delineations, responses are detailed in the text where 2 or more respondents detailed a theme, to enable greater explanation of these views. Explanations are first detailed for specific delineations, with some general comments which were present for multiple delineations detailed subsequently.

11 Scottish Marine Regions

Align with marine spatial planning

Some respondents felt that Scottish Marine Regions should be selected as a delineation for regional inshore fisheries management because they would align with the delineations already used for marine spatial planning. Some respondents felt that the use of Scottish Marine Regions would make it easier for regional inshore fisheries management to be integrated with marine spatial planning, which could be beneficial. A small number of respondents thought that regional inshore fisheries management should be delivered through marine spatial planning. A small number of respondents thought that tis delineation should be used as it is already clear and legally defined and would be simple to use and reduce overlap. One respondent believed that aligning with marine spatial planning could lead to better stakeholder management.

Areas are of a manageable size but make ecological sense

Some respondents felt that using Scottish Marine Regions to manage regional inshore fisheries would result in areas that are of more geographical sense than currently used. A small number of respondents felt that this would result in areas being used that are of a large enough size to be significant, but small enough to be ecologically relevant. A small number of respondents felt that division by Scottish Marine Regions would be more consistent with geographical features and better represent geographical differences than the current division into RIFGs.

Better than defining new areas

A small number of respondents felt that defining new areas would be unnecessary, potentially complicated and confusing and could lead to delays in management, and so felt it better to use the already established Scottish Marine Regions.

Need to be local

A small number of respondents thought that Scottish Marine Regions would be appropriate for managing regional inshore fisheries as they are in some cases smaller and more local than current delineations. A small number of respondents thought this could help to encourage local engagement and could lead to decisions being more tailored to local areas. One respondent highlighted concerns that larger areas may not be fully accountable to local concerns, with another calling for a larger number of small management units to be used.

RIFGs are too large

A small number of respondents outlined that Scottish Marine Regions should be used as they felt current RIFGs are often too large and not local enough.

Areas smaller than Scottish Marine Regions would be too small

A small number of respondents felt that delineations smaller than Scottish Marine Regions would be too small to manage. One respondent felt that this could lead to micromanagement with another highlighting that this could lead to the need to manage areas with very little fishing effort.

6 Regional Inshore Fisheries Groups (RIFGs)

Divisions make sense

A small number of respondents felt that RIFGs are already well divided into areas which make geographical sense, so should continue being used.

RIFGs enable local management

A small number of respondents felt that RIFG delineations allow for local management, with one respondent highlighting that they group local fishers, and another stating that they enable local management and enforcement.

National discussions

A small number of respondents felt that national discussions still need to take place even with RIFG delineation, with one respondent highlighting the role of FMAC or national RIFG meetings, and another highlighting that national fora need to be aware of what is occurring regionally.

New approach needed

Existing delineations do not work

A small number of respondents felt that a new delineation approach is needed for regional inshore fisheries management, with one respondent highlighting that current delineations are “dysfunctional” and another stating the system as a whole does not work.

Smaller areas are better

Increase benefits to local areas

A small number of respondents felt that smaller areas than those currently used would be beneficial future delineations for regional inshore fisheries management, so that benefits to local areas can be increased, with more relevant management. One respondent thought that smaller management areas have been successful in certain areas.

Reference to specific geographic areas

The Hebrides/ Outer Hebrides

A small number of respondents felt that the Outer Hebrides is an already defined management unit that has been successful. A small number of respondents felt that the fishing stocks of interest in this area, shellfish, tends to be localised and therefore easier to manage locally than more transient species such as white fish.

General comments

A few overriding themes were provided as explanations for the selection of a number of delineations. These were the importance of areas being local; using existing defined areas; and topics of scale.

Local

Several respondents mentioned the importance of management being local. Some respondents felt that management should involve local people, with local interest and knowledge making decisions about how the local area is managed. A small number of people raised the view that most fishers fish locally, with management of their local stocks therefore important. One respondent felt that it would be easier for fisheries managers to focus efforts on a smaller local area.

Existing defined areas

Some respondents felt that using areas which have already been defined would be better than defining new areas altogether. Some respondents felt that where delineations are already working or in place, it would be unnecessary to create new delineations. A small number of respondents felt that creating new delineations could be a waste of effort, lead to confusion or result in delays.

Geography and scale

Some respondents outlined the importance of geography and scale when discussing delineations. A small number of respondents felt that divisions should be based on geographical features, with a small number highlighting that the scale selected needs to be ecologically significant. A small number of respondents felt that existing areas are too large, whilst conversely a small number of other respondents felt that areas are too small, with one commenting that the size of RIFGs varies too much. A balance of sized spaces are needed that are both local and large enough to manage according to a small number of respondents. One respondent felt that the geography is not the most important factor.

Question 12: What are potential challenges/weakness of the delineation you suggested above?

46 respondents provided potential challenges or weaknesses that they thought the delineation they selected for regional inshore fisheries management would have. Due to the low number of respondents who selected different delineations, responses are detailed in the text where 2 or more respondents detailed a theme, to enable greater explanation of these views. Explanations are first detailed for specific delineations, with some general comments which were present for multiple delineations detailed subsequently.11 Scottish Marine Regions

Resource constraints

A small number of respondents raised the view that they thought resource constraints may act as a challenge towards using Scottish Marine Regions as delineations for regional inshore fisheries management. A small number of respondents felt that moving from RIFGs to Scottish Marine Regions might require increasing levels of resources. One respondent felt that it would be challenging to implement regional inshore fisheries management unless adequate funding was made available.

Local authority involvement

A small number of respondents raised local authority involvement as a potential challenge to using the Scottish Marine Region delineation. A small number of respondents raised the view that several local authorities may need to be involved or work together under this delineation. A small number of respondents raised the view that to ensure democratic governance and accountability management should be under local authority/ joint local authority control.

Political will

A small number of respondents raised concerns about political will for regional inshore fisheries management, with one respondent highlighting that there has been a lack of political will when it comes to regional marine planning.

Nomadic fishers

A small number of respondents raised concerns about nomadic fishers if moving to smaller Scottish Marine Regions, with one respondent highlighting that it will be important that fishers can move between different areas and another highlighting concerns about having different rules across boundaries.

6 Regional Inshore Fisheries Groups

Resource constraints

A small number of respondents raised concerns about resource constraints, with one respondent raising concerns about potential different levels of resources between different regional groups.

New approach needed

Resource constraints

A small number of respondents raised concerns about resource constraints, with one respondent concerned that any change to inshore fisheries management will require resources which the Scottish Government lacks.

Other approach – combining council areas into larger areas

Resource constraints

A small number of respondents raised concerns about resource constraints, with one respondent believing this approach would be more expensive than using RIFGs and another raising concerns about a lack of suitable trained staff resources.

Did not select a delineation

Involving the right stakeholders

A small number of respondents raised concerns about getting the right stakeholders involved. A small number of respondents felt the need for anybody involved in managing the system to be there for the greater good, rather than for personal benefit. One respondent raised the view that those involved should reflect the interests of all people from coastal areas.

General comments

Resource constraints

Some respondents raised concerns about resource constraints and delineations of regional inshore fisheries management. A small number of respondents raised the view that changing delineations, especially into smaller areas, might be more expensive than the current RIFG model. A small number of respondents felt that resources are already stretched, with a small number of respondents highlighting the difficulty in ensuring the right people with right skills are involved. One respondent felt it necessary that funding is ring fenced whilst another raised concerns about different levels of funding for different regions.

Nomadic fishers

Some respondents raised concerns about delineations in regional inshore fisheries management affecting nomadic fishers. A small number of respondents felt it important that fishing vessels could regularly move between different management areas, with one respondent stating that “it should be possible for fishers to migrate between different areas with minimum bureaucratic resistance”. A small number of respondents demonstrated concerns about the impacts of vessels being displaced as a result of varying local rules. A small number of respondents raised concerns about the difficulties that different rules may cause for people working over boundaries of management areas.

Enforcement

A small number of respondents highlighted concerns about enforcing regulations which might vary between regions.

Oversight

A small number of respondents felt there should be oversight of regional inshore fisheries management at a national level.