8 Partial Business and Regulatory Impact Assessment (BRIA)
8.1 Question 9: Do you have any comments to make on the BRIA content?
8.1.1 Thirteen respondents provided comments on the BRIA. Several noted that the BRIA's assessment of potential costs and benefits focused on the potential impact of these on the seaweed cultivation industry. They considered that the BRIA should have assessed both cultivation and wild harvesting of seaweed.
8.1.2 Others felt that more information was needed in the BRIA, and provided suggestions, including: the cost of the future consenting process (including EIA) for both seaweed cultivation and seaweed harvesting in the wild; a statement on how the social and financial implications for other marine users will be managed, particularly fisheries but also other users such as tourism, etc.; a "proper evaluation of the losses to the fishing sector in particular, in relation to the interdependent nature of fishing in Orkney" and in relation to "the socio-economic impacts of the cumulative loss of spatial area to fishing in Orkney".
8.1.3 In contrast, a public body felt that further cost analysis was needed, but that the financial implications could not be identified until a clear decision on the consenting process has been made.
8.1.4 A public body stated that they are aware of industry concerns about the current fee system for aquaculture development under town and country planning. They noted that the same fees are applied to finfish and shellfish developments, which may result in lower profit margins for the latter, and cautioned that these concerns may also apply to seaweed cultivation.
8.1.5 A fishing sector respondent reiterated their concern that they had not been consulted previously, and suggested that further consultation with Marine Scotland on these issues and the potential implications for fishermen be undertaken. A seaweed industry respondent agreed that wider consultation should have been held with industry during drafting of the Consultation Document. They also felt that in, preparing the BRIA and the Consultation Document, a supply-based approach was taken. They added that, at present, the market "is very small and nascent", and noted that supply must be undertaken in line with market demand or it "risks the development of the supply side being redundant or ineffective".
8.1.6 A respondent from the seaweed sector noted that while "seaweed cultivation and wild harvesting can be successful, with no environmental impacts as long as appreciation is given to ecosystems", they had concerns regarding over-exploitation of these natural resources. They stated that the seaweed industry must act with "environmental care, awareness and respect, in order to prevent detriment to marine ecosystems".
Partial BRIA summary:
- Thirteen respondents provided comments on the BRIA.
- Several respondents considered that the BRIA's assessment of potential costs and benefits should have included both cultivation and wild harvesting of seaweed.
- Others made suggestions about additional information that they felt should have been included.
- Concerns were raised by some on the supply-based approach taken in the BRIA, and caution given that the market is presently "very small and nascent".
- Concerns were raised regarding the potential use of a fee system for aquaculture development under the Town and Country Planning Act, particularly for the viability of sectors with lower profit margins.
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