Inshore Fisheries Management Improvement: call for evidence analysis report

Part 5: Governance and Co-Management

Question 13: What stakeholder groups should be involved and how should each feed into development of inshore fisheries management measures?

90 respondents responded to this question and listed organisation(s) whom they feel should, or should not, be engaged in the development of inshore fisheries management measures. These stakeholders fall under a number of key groups which are listed below. Names of specific organisations have not been included in this report, but will be considered in full as this policy is further developed. Where provided by respondents, stakeholder groups are only listed where two or more respondents detailed their involvement.

Table 5 below outlines the stakeholder groups suggested by respondents. The fishing industry or fishing industry representatives were the most common stakeholder identified for participation, shortly followed by environmental groups, the public/ community and ‘all stakeholders’ who were also commonly mentioned. Other stakeholders were also mentioned by some or a small number of stakeholders

Respondents provided some explanation as to how they believed different stakeholders should feed into inshore fisheries management. Key themes identified are discussed below in turn. Where entire models of stakeholder participation were provided by respondents, these are not included in this Call for Evidence report but will be used to inform decision-making.

In addition to describing those who they felt should be included within inshore fisheries management, a small number of respondents also outlined a preference to exclude environmental groups from the development of inshore fisheries management measures.

Themes

Fair representation

Some respondents raised the view that stakeholder representation in inshore fisheries management should be fair. Some respondents felt that all stakeholders with an interest in the management of inshore fisheries should have their views fairly considered, with some respondents highlighting that the interests of the inshore area should be fairly represented. A small number of respondents mentioned that it should be ensured that no one group dominates discussions and that management is unbiased.

Co-management

Some respondents raised themes related to putting co-management in place. Some respondents felt that effective co-management needs to involve the inclusion of all relevant stakeholders in decision-making. A small number of respondents felt that co-management needs to be evidence based. A small number of respondents also raised the view that interested stakeholders should be able to self-nominate themselves to be involved on topics of interest. A small number of respondents felt that co-management should empower local communities and provide them with a meaningful voice. A small number of respondents felt that co-management so far has not been achieved, with one respondent stating it has been skewed towards the large-scale trawling sector. A small number of respondents felt that co-management should result in the sharing of power and responsibility for inshore fisheries management. One respondent felt that co-management needs strong leadership, and another asked whether co-management is really what the Scottish Government intends to put in place.

IFCAs

Echoing responses to earlier questions, some respondents outlined their view here that inshore fisheries co-management in Scotland should operate more like IFCAs in England. A small number of respondents detailed strengths of the IFCA model, including that it has a greater balance and diversity of stakeholders, is evidence based and constitutes effective stakeholder management.

Youth representation

Some respondents felt that there should be a stronger youth voice involved in inshore fisheries management, and that formal youth representatives should be included in decision-making.

Transparency

A small number of respondents felt that inshore fisheries management should be more transparent. A small number felt that all decision making for inshore fisheries management should be transparent, whilst a small number of respondents raised the importance of transparency surrounding who organisations involved in inshore fisheries management represent.

Conflicting views impacting on progress

Some respondents felt that having too many conflicting views involved in decision-making can result in a lack of progress for inshore fisheries management. A small number of respondents felt that having people with polarised opinions or conflict in the same discussion can block progress made by the Scottish Government, leading to potential paralysis in decision-making. A small number of respondents believed there should be separate opportunities for different groups of stakeholders to be involved with discussions with the Scottish Government. A small number of respondents believed there should be a distinction between stakeholders/ direct stakeholders and opinion-holders/ indirect stakeholders in decision-making.

Fairer inclusion of all fishers

A small number of respondents raised concerns about how and who out of fishing interests are involved in inshore fisheries management. A small number of respondents raised the view that there has historically been an overweighting of large-scale trawl and dredge interests involved in decision-making/ in RIFGs, which is weighted greater than the proportion of the industry they make up. One respondent felt that all fishers should be represented equally, and highlighted that fishing organisations do not represent all fishers given that not all fishers are members.

Greater involvement of fishers

A small number of respondents raised the view that fishers should have greater involvement in decision-making about inshore fisheries management than other stakeholders. One respondent raised the view that this is because decisions will affect fishers’ livelihoods, and other stakeholders have less interest in fishing.

Need to sift and weight stakeholder groups

Similarly, a small number of respondents thought that there should be a sifting and weighting process to define those involved with inshore fisheries management decisions.

Managed in the public interest

A small number of respondents felt that fisheries are a public asset and should be managed in the public interest. A small number of respondents raised the view that inshore fisheries have not been managed in the public interest, with the large-scale sector being favoured.

Other

A range of other topics were mentioned by a small number of respondents. These included reflections on FMAC Inshore Subgroup; increased powers to regional groups; integration with Regional Planning Partnerships; inclusion of diverse views; a need for collaboration; for stakeholders to be defined; that the current system does not work; and a reflection that the stakeholders involved may need to differ locally.

Question 14: What checks should be put in place to ensure transparency, fairness and accountability when appraising inshore fisheries management options?

A total of 69 respondents submitted answers to this question. The main themes identified in these responses were consultation and engagement; the importance of clear and defined structures; use of data; transparency; legislation and policy; monitoring and evaluation; balanced participation; enforcement; and, independent review.

Consultation and engagement

Several respondents highlighted topics related to consultation and engagement as important for ensuring transparency, fairness and accountability in inshore fisheries management. Some respondents felt the need for open consultation which enables meaningful participation, where people are listened to. Some stakeholders felt that all relevant stakeholders should be included in consultation and engagement to ensure all groups are adequately and equitably included in decision-making. A small number of respondents felt it important that the fishing industry is consulted when decisions are made e.g. to understand impacts on jobs. One respondent outlined the need for consultations to be clear, neutral and have defined timescales.

Clear and defined structures

Several respondents felt a need for there to be clear and defined structures for groups involved in inshore fisheries management. This included clearly defined and transparent membership, with one respondent highlighting “ongoing issues with west coast RIFGs about who are members and what defines membership… since day 1”.

Various rules were suggested by a small number of respondents surrounding defining membership. These included:

• Membership should only include representative organisations (rather than individual interests);
• Members eligibility to join should be scrutinised;
• Members should detail who they represent and how they are funded;
• Members should detail how they make decisions;
• Conflicts of interest should be checked (including funding and governance);
• All interest groups should be represented fairly;
• Members should not just be opinion-holders, but actively involved in management or policy.

More broadly than membership, it was outlined by a small number of respondents that inshore fisheries management groups should have clearly defined decision-making processes, have clear powers, defined rules, that meetings should be well chaired and that a clear complaints and appeals procedure should be evident. According to a small number of respondents, this should enable groups to have clear responsibilities and accountability, increasing transparency and fairness. A small number of respondents felt this could be achieved by formalising RIFGs as constituted bodies with formal constitutions to hold them to account.

Use of data

Several respondents provided comments about the data used to support inshore fisheries management. A small number of respondents thought that data should inform decision-making, and that how it has informed decision-making should be clearly evident. It was felt by a small number of respondents that it is important that data used to determine management activities should be up to date and regular monitoring should occur. A small number of respondents also felt factors relating to the quality of data, including that it should be independent, neutral, and checked before it is included in decision-making. One respondent suggested that stakeholders could provide data.

A small number of respondents raised the importance of also publishing correspondence, membership lists, the outcomes of surveys and consultations, details of vessel monitoring, performance evaluations, details of termination of membership and data about populations of species. One respondent raised the view that this would potentially reduce the number of FOIs received.

Transparency

Several respondents raised the need for minutes or associated paperwork to be published publicly when deciding how to manage Scotland’s inshore fisheries, as this could help to improve transparency and accountability of the decision-making process. Some respondents further detailed a need for transparent decision making, including providing information on the reasons why decisions are made, who made them, which groups were represented, what evidence was used, and who was consulted. A small number of respondents specified parts of the process which they believed should be transparent, including governance arrangements, engagement and consultation, objective setting, meeting minutes, fisheries management plans, and performance evaluations. Similarly, some respondents felt that data should be accessible and publicly available (e.g. vessel compliance and enforcement, landings, population levels) to enable transparency. One respondent felt that minutes should be published in a timely manner.

Legislation and policy

Several respondents raised the need to ensure that work in inshore fisheries management is in line with national, international and regional policy priorities. It was felt by some respondents that any work to improve inshore fisheries management needs to be accompanied by impact assessments (environmental and socio-economic), and any objectives should be in line with policy and legislation, including national and regional marine plans, the Joint Fisheries Statement, the UK Fisheries Act and work towards Good Environmental Status and other targets. A small number of respondents specified the need for legislation to be updated to align with modern management practices and governance.

National Level Oversight

Some respondents highlighted a need for national level oversight for inshore fisheries management, with one respondent highlighting a need for “genuine determination on the part of the Scottish Government to make it happen”. A small number of respondents felt that overall accountability will be down to the Scottish Government, and that the Scottish Government need to ensure transparency and fairness of inshore fisheries management. A small number of respondents highlighted the importance of having national plans and aims for fisheries management which should be set by the Scottish Government, with regional groups aligning to these. However, a small number of respondents perceived that some parts of inshore fisheries do need to be managed at a national level and not regionally, for instance licensing and to manage species which move over extensive areas.

Monitoring and evaluation

Some respondents felt that there should be regular monitoring and evaluation of any decisions made or measures implemented in inshore fisheries management, to understand whether objectives and national obligations are being achieved.

Balanced participation

Some respondents felt that inshore fisheries management should involve a balance of participants representing a range of different interests who would be impacted by decisions affecting the management of inshore fisheries. One respondent felt that there should be “a broad spectre of people with even numbers. Not all fishing related or all environmentally minded people”. A small number of respondents felt the need for all relevant stakeholders, with a mix of backgrounds, including other interested sectors, and a balance within fishing interests (e.g. large scale and small scale sector, not just those affiliated with associations), to be included and represented in decision-making. One respondent felt the need to limit “’doubling up’ of representation at meetings” to ensure representative decision-making.

Enforcement

Some respondents raised concerns about enforcement of compliance of fishers with fishing regulations, calling for improved enforcement to encourage compliance. Examples given were: more visibility at sea, less obvious, more targeted, greater powers. One respondent raised concerns about enforcement more generally, including the need to enforce legislation to meet environmental targets.

Independent Review

Some respondents felt there is a need for external independent review of inshore fisheries management in Scotland, especially of regional management bodies, with a small number of participants highlighting that audits or review of decisions should take place. Respondents outlined a range of reasons that they thought that this might be beneficial e.g. to help to improve trust in the management process, transparency, accountability, increase the equity of management decisions and to ensure decisions are consistent with relevant legislation and guidance. One respondent suggested that an independent third-party body should oversee the work of the Marine Directorate, to provide “reassurance that management decisions can be held to account”.

Other

A range of other topics were mentioned by a small number of respondents. These included the involvement of local planning authorities in inshore fisheries management; learning from the IFCA model; meetings open to the public; advanced warning of meetings and decisions; communicating through the press; better use of fishery officers; increased power to RIFGs; embracing the principles of environmental economics; and, ensuring decision-making is fair.