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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:
As a member of KIMO, SIC supports their ‘Fishing for Litter’ initiative and strongly supports any further measures that makes it an offence to throw overboard any type of litter whilst at sea – for any vessel.

In addition Shetland is home to the KIMO secretariat – the only international secretariat to be based in the isles.

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:
SIC is supportive of the principle of a seafood levy as a means to raising funds to re-invest in the industry. The SIC would wish to see funds raised in Shetland being ring fenced for local investment and tied to local decision making. Any system to collect and allocate funds must be efficient to operate and linked to clear objectives and outcomes.

While SIC is supportive of discussions around the future of local inshore fisheries management, these must take into account existing structures. As an island community Shetland has a defined boundary with the assumption that, along with many years of experience and good practice, sustainable management of the fishery to the 6 mile limit is perhaps more straightforward than many other areas. Expanding the remit of inshore fisheries management out to the 12-mile limit is a significant expansion of the area covered by local management, and will require not only legislative change but resources to deliver. Management of the existing Regulating Order (RO) works well in Shetland but is expensive to deliver, with no guarantee of future Local Authority funding. It must be assumed that an expansion of the area covered by local fisheries management will be significantly more expensive to manage. Any plan for expansion of the responsibilities of local authorities in this area must be accompanied by a plan as to how this will be funded.

SIC is supportive of more efficient measures which enhance monitoring and reporting capabilities of the inshore sector, where it makes economic and business sense.

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:
The SIC concurs with Scottish Government views that permanent access to UK waters and to fishing opportunities should not be conceded as part of the negotiation on future trade agreements.

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:
SIC is one of several local authorities in Scotland that operates a Community Quota scheme, which is made available to the industry and provides an advantage to small scale fishermen, rather than a disadvantage (as is implied in the discussion point). A commitment to end quota speculation must also take into account the differing circumstances of these communities, recognising that the involvement of local authorities in this area leads to direct benefits for the sector, including investment in research and facilities.

The SIC believes that the community quota system is a good example to the rest of Scotland of using part of the quota to promote fishing development and community stability in a sustainable manner with clear benefits for the whole community.

The principle of allocating quota to inshore fishing operators is supported, whether that be additional quota secured after the UK leaves the CFP or the distribution of additional quota separately to the FQA system. In particular this quota should be earmarked for new entrants and smaller vessels that do not currently own FQA units.
SIC would welcome a scheme which supports new entrants but also considers succession issues, which is appropriate to the size and value of fishing assets (including vessels, licence and quota costs), as well as addressing difficulties in obtaining licences and quota.

In terms of succession planning, mechanisms such as employee ownership have proven valuable in ensuring existing businesses in other industry sectors continue once founding members reach retirement age. The fishing industry in Shetland operates primarily as small family owned businesses and employee ownership may offer a solution to retaining business structures, bringing benefits to the employees, businesses and economy alike.

Due to seasonal landing fluctuations, particularly in the pelagic fishery, with its associated significant volumes, SIC considers that the proposal of a 55% landing target into Scottish ports may have a negative impact on the industry. There is the concern that shore infrastructure, such as processors and transport providers would not be able to cope with the huge capacity variations. This is likely to lead to stockpiling product, negatively impacting on quality, price, profitability and therefore the wider economy in general.

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:
The points on new entrants appear to focus solely on increased and additional capacity. It is our contention that there is a significant requirement for new entrants to maintain capacity in the sector. Much of the workforce is ageing and there is a requirement for succession planning (and associated investment in the sector) to replace that workforce which will be leaving. In addition to training requirements there is a need for significant investment of capital for new entrants, so we would welcome discussions around appropriate national measures to assist new entrants for vessels of all sizes and values and to promote the sector as a viable and attractive career.

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:
We acknowledge your recognition of the Shetland Regulated Fishery (Scotland) Order 2012. Our approach to Regional Marine Planning is also well developed.

The Shetland Islands Regional Marine Plan has been developed by the Shetland Islands Marine Planning Partnership (SIMPP) under the guidance of a local advisory group that includes environment, commercial, community and recreation groups. The SIMPP is a partnership between SIC and locally based NAFC Marine Centre. The NAFC Marine Centre brings invaluable input and expertise in marine spatial planning as well as holding a wealth of knowledge, data and expertise in maritime industries - underpinning the sustainability of the local fishing industry.

The Shetland Islands Regional Marine Plan will be one of the first of such plans to be produced in Scotland to support the management of Shetland’s coastal and marine waters. Once adopted, around 2020, it will facilitate integrated and informed decision making to minimise conflict between marine users. The plan recognises the importance of the marine fisheries sector and includes policy to safeguard fishing opportunities and the socio-economic benefits they bring to the local economy. The role of the Regulating Order is also covered in our Regional Marine Plan.

A licence system is currently used in Shetland to allow inshore fishing under the Regulatory Order – up to the 6 nautical mile zone, which provides essential income to manage the fishery. Further discussion would be required on how introducing a licence/permit system to better regulate fishing activity within the 12 nautical mile zone might work in practice, and without affecting current income to SSMO.

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:
There is a need for alternatives to EU structural funds to be progressed and with this comes the opportunity to streamline bureaucratic procedures and redesign support policy in line with local and regional development needs.

Clarity is required on whether the proposed UK Shared Prosperity Fund (SPF) will include replacement schemes for fisheries/marine funding. For decades, financial assistance from the EU’s fisheries support schemes has been invaluable in sustaining and developing Shetland’s fisheries industry.

SIC has a long-standing history of supporting the fisheries sector through various interventions, including investment in research and facilities, and provision of loan finance for business growth. These interventions have been made to grow the sector, to improve standards, support innovation and diversify local interests.

SIC’s experience of offering loan finance has been particularly effective in assisting business growth for established fishermen. However, this form of support may not always be appropriate for first time entrants into the whitefish industry due to the high cost of entering the industry as a shareholder in a fish catching business. The value of assets required to operate (vessels, licences and quota) continues to increase and there is a corresponding requirement to fund and repay that high level debt. Repayments are likely to be restrictively high and potentially unmanageable for new entrants. Ongoing grant funding should not be ruled out, and perhaps a combination of grant and loan, or loan interest subsidy, is more appropriate for those wishing to enter the sector as business owners. Public funded equity in fishing businesses may also be worthy of consideration.

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:
SIC supports the proposal to have the catching sector sign up to the Scottish Living Wage to ensure basic pay for workers is proportionate to the cost of living. This is of particular relevance to Shetland where the cost of living is high, up to 60% higher than the UK average. Ensuring employees are paid fairly will help attract and retain workers within the industry.

In addition to the scientific research undertaken locally by the NAFC Marine Centre, the organisation is also key to the development of the young workforce with the provision of apprenticeships, marine cadets and many maritime related training courses.

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:
SIC shares the view that the foundation to good fisheries management is investment in robust scientific research. The NAFC Marine Centre has many years’ experience in fisheries research including the assessment of local fisheries stocks.

Any plan to raise funding directly from the industry must be accompanied by a clear plan explaining why and how it will be spent to promote the future sustainably of the industry.

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:
SIC supports the collaborative approach being taken to developing fisheries policy and welcomes the opportunity to make comment at this stage of the discussion process.

A SHETLAND CONTEXT:

The sea around Shetland provides the resources that have ensured nourishment and prosperity in our community for thousands of years and fish catching remains a central component of Shetland’s economy. The Shetland fishing fleet comprises some 160 fishing boats, each an individual business, with a total annual turnover (value of landings) in excess of £110 million. Several hundred people are directly employed as fishermen, and hundreds more are employed in associated businesses, ranging from ports, fish markets and processors, to engineering, transport and supply – in the 2017 Employment Survey, 30% of respondents stated that more than half of their turnover was related to the fisheries sector. High quality fish products are also a major component of the local food and drink export from Shetland.

The value of the fishing industry to Shetland comes not just from its current contribution to the local economy, but from the fact that as a properly managed, sustainable resource, it has the potential to go on contributing to the economy, and providing jobs and opportunities for local people, indefinitely. The industry’s contribution is more than just economic, as the development and growth of the seafood sector over centuries has played an important part in shaping Shetland’s culture and identity.

The Shetland fishing industry is also significant in the context of the Scottish fishing industry. In 2017 Shetland boats landed one quarter of all the fish landed by Scottish boats and one sixth of all the fish landed by British boats.

As a local authority, the SIC is highly supportive of the fishing industry with a practical and partnership approach to development and sustainable management. The SIC continues to contribute to this key sector through: financial support and advice to local businesses; development of port infrastructure; marine planning and local fisheries management initiatives; funding fisheries research and training; and quality improvement schemes.

The SIC remains committed to working with local industry and policy makers to develop the strategic direction of the industry and address the challenges and opportunities brought by the current political environment. SIC continues to advocate the importance of subsidiarity in managing local resources to ensure the long term success of our community.

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Shetland Islands Council