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Chapter 1: Achieving our vision for environmentally conscious and sustainable fishing

1. In Chapter 1 the Scottish Government identified a range of areas around achieving our vision for environmentally conscious and sustainable fishing. Therefore, in relation to these discussion points do you have any views or ideas in regarding the areas identified in Chapter 1?

Please give your comments:
Environmentally conscious and sustainable fishing requires a 'whole food chain' approach from net to plate. To that end, while we usually think about these in terms of the capture sector only, this also needs to take account of energy efficient, waste minimising and responsible processing practices. This should also apply to foreign products that our industry may rely upon, e.g. imported products.

In relation to inshore fisheries, issues such as conflict between sectors (static versus mobile) could be resolved through better use of marine spatial planning. Providing designated zones for use of static or mobile gear would provide certainty to each sector. In addition, other users, such as scallop divers, could co-exist in confidence alongside the static sector. Such approaches necessarily require the use of iVMS with sufficient polling frequency to give all participants a sense that there is a level playing field. Such management systems also lend themselves to user rights fisheries, which have been shown to engender greater responsibility due to the control over the resources within the zones. Such measures have been implemented successfully in the Isle of Man. It is clear that the implementation of such measures needs to be incremental so as not to introduce sudden 'shocks' to the system.

The above measures also lend themselves to greater compatibility with conservation zones and features. Understanding the pressures created by fishing activities on conservation features would support a more sophisticated ecosystem based approach to fisheries management whereby fishery and conservation targets can be addressed simultaneously. Given VMS and currently developed algorithms, it is possible to set thresholds for seabed integrity which act as trigger points for management action.

Data poor fisheries can be addressed by taking a systematic approach to developing a sentinel fleet as occurs in the Isle of Man. Here, vessels have been instrumented with cameras for data capture (not enforcement) and replace the need for observers. Fishers collect the data that feeds into the science. In addition, it is possible to tag and instrument pots so that they collect environmental data. It is impossible to ascertain CPUE from pots without adjusting for water temperature as the latter is what drives crab, lobster etc feeding activities. As water temperatures warm we may see 'false' signals of increased catches and landings which merely reflect the increasing appetite of the target species in response to their physiology.

Taking a whole food chain approach also involves understanding better the DNA and isotopic signature of the species we catch which would provide assurance that the products we land and market are from the claimed origin. Such an approach would give Scottish seafood a competitive edge like none other in the world.

Undertaking an energy and economic efficiency appraisal of the whole fleet would enable a more objective analysis of the sustainability of the food we land. While many fishers are good at catching fish, they may not be operating in the most economic and hence environmentally efficient manner. Landing less but selling for more would simultaneously reduce the days spent as sea and hence human interaction with environment and also the chances of deaths and accidents at sea.

Chapter 2: Governance, engagement and accountability

2. Chapter 2 explores a range of discussion points around future governance, engagement and accountability. With regards the areas discussed what are your opinions of the discussion points raised and any related views on the themes identified in Chapter 2?

Please give your comments:
Scotland has some innovative engagement mechanisms that bring stakeholders together, however, as someone who was recently working outside Scotland, it becomes apparent that there is some duplication. The innovation hubs e.g. Scottish Aquaculture Innovation Centre and Fisheries Innovation Scotland and Seafood Scotland could be brought under one organisation and hence draw strategic alliances in areas of shared interest, e.g. in worker training, processing technologies, assurance, DNA bar coding, development of best-practice and marketing of these attributes. While each of these bodies has a clear remit there is undoubted overlap in issues that affect them.

The IFGs are a useful model but have not achieved the effectiveness of IFCAs in England. Even the latter are under-resourced. The IFGs serve much larger communities over a much larger geographic scale, but they have little or no resource of their own. Partnering them with other science providers (e.g. MSS and the HEIs) would be useful, but there need to be resources to enable this to happen. In addition, schemes such as KTP are not being utilized to lever resource that could be used by the IFGs to answer questions. Despite the existence of MASTS, Scotland needs a virtual 'Centre of Fisheries Expertise' which could act as a portal to science users within Scotland but would also attract collaborations from outside Scotland.

Chapter 3: International

3. Chapter 3 explores areas for discussion around access to our waters and the role of Scotland in future fisheries negotiations as part of the UK. Do you have any views or ideas in relation to the discussion points raised in Chapter 3?

Please give your comments:
If Scotland can put in place a strategy that would underpin a claim of 'Scottish Seafood: at the forefront of sustainability', this would secure the highest quality (and profitable) markets overseas and within the UK. It would also give Scotland the 'moral high ground' when negotiating with external partners in relation to access to fishing rights and would validate requirements for high standards of responsible fishing.

Chapter 4: Establishing fishing opportunities

4. Chapter 4 identifies the Scottish Governments aim to establish fishing opportunities for long term future sustainability and accessibility. Accordingly, in relation to these discussion points do you have any views or ideas to the areas identified in Chapter 4?

Please give your comments:
It would be good to look more closely at use rights. There is some 'fear' about ITQs or Territorial User Rights Systems. However, it is entirely at the Governments whim how it would decide to structure these in consultation. Most stakeholders are concerned about aggregation of rights which has occurred elsewhere, yet it is possible to structure the rights such that they are allocated to a community (which is open to definition) or retained ultimately by the Government. The Isle of Man has used this approach with its 3 nm limit.

Designation of zones for exclusive use by certain metiers would eventually remove the issue of spatial conflict among different users.

Chapter 5: Access to fishing

5. In Chapter 5 the Scottish Government discusses possible options for access to fishing in distant waters and new entrants. With regards the areas discussed what are your opinions of the discussion points raised and any related views on the themes identified in Chapter 5?

Please give your comments:
Comments in response to 1 and 4 apply here

Chapter 6: Inshore

6. Chapter 6 identifies a broad range of themes and points around the future management of the inshore fishing industry. As a stakeholder what are your opinions of the discussion points raised and any related views on the themes identified in Chapter 6?

Please give your comments:
Inshore fisheries are complex. If the IFGs are to truly function, they need teeth and information to help them do their job.

A sensible approach would be to identify some 'test' areas where you identify that you are going to give the IFG total responsibility for making decisions about who fishes where, how much is removed, how often etc, underpinned by science and local ecological knowledge. By acknowledging at the outset that this is an experimental approach, it enables you to 'get it wrong', learn, adapt and try again. At the moment, the IFGs are too big to take on such a big task. Give them a bite size chunk to cut their teeth on and see what happens.

Chapter 7: Funding

7. Possible options for the future funding of the fishing industry are identified in Chapter 7 for discussion. What are your views on the discussion points raised and do you have any other ideas with regards future funding options or opportunities going forward?

Please give your comments:
Quite a number of fishing and other industries are contributing already to science, however this has resulted in 'ad hoc' initiatives because the funding is not strategic but rather opportunistic. Using a mechanism such as the Seafish levy or similar arrangement would be one way to pump funding into FIS or its equivalent to direct science and other initiatives towards problems identified by the industry.

Working more proactively with some charitable donor organisations, and organisations such as google and Microsoft could lever additional resources such as AI and programming and analytical power not available to single actors such as academics.

Chapter 8: Labour

8. The Scottish Government understands that access to labour is a considerable concern for the industry. In Chapter 8 we identify a range of discussion points connected to access to labour and working in the fishing industry – what are your views on this area?

Please give your comments:
Better training is required to improve safety and the status of the job that is being done across the whole food industry. Greater use of technology can replace some of the more basic labour functions but will demand higher skilled individuals to operate such technology. Increasing the culture around safety to something approaching that in Iceland would be a good point to aim for in relation to the catching sector. The processing sector is also somewhat vulnerable to a lack of product diversity (i.e. highly dependent on certain species such as salmon and saithe and Nephrops), broadening the range, format and type of products would secure the industry from shocks such as disease outbreak in the e.g. the salmon industry

Chapter 9: Innovation, Science, and Technology

9. To ensure long term sustainability of the fishing industry the Scottish Government believe it is right for the fishing industry to contribute to costs associated with science, research and development in the future. Chapter 9 consider options for this but what are your view and thoughts on the discussion points raised in this chapter?

Please give your comments:
We need a stronger partnership between the HEIs and MSS and the industry to identify the priority areas for science data collection and innovation. We need a more collective, pre-competitive mentality to dominate, where we recognise that different institutions are well placed to deliver science in a particular locality but may not be the leaders of the actual project.

Bringing those interested in the REMs area would accelerate progress in this area. The SIFIDs project is excellent but is only one approach to the problem of automating data collection. For example, in Wales and the Isle of Man camera derived images are being processed for data collection which might be better for more complex assemblages or organisms.

Instrumenting parts of the fleet and their gear would improve oceanographic and met models, would enhance our understanding of catch covariables such as temperature, salinity, turbidity and would refine our estimates of stock status.

A better understanding of connectivity for certain sentinel species e.g. scallop, Nephrops, saithe, cod, whiting etc would provide an better understanding of appropriate stock units for management purposes.

Applying a more ecosystem based approach to critical habitats for certain life history stages e.g. settlement substrata for scallop spat, would free up potential bottlenecks for recruitment. Such an approach was suggested for scallop fishing in the Cardigan Bay SAC in Wales.

Chapter 10: General comments

10. Finally, thinking about ensuring the long term sustainability of the Scottish fishing industry for future generations do you have any other ideas or proposals that you would like to be considered that are not covered elsewhere in the discussion paper?

Please give your comments:
No further comments, but happy to elaborate in person.

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Michel Kaiser

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Heriot-Watt University