About you
3. What is your name?
Name
(Required)
Charles Millar
Organisation details
1. Name of organisation
Name of organisation
(Required)
Sustainable Inshore Fisheries Trust
2. Information about your organisation
Please add information about your organisation in the box below
Registered Scottish Charity promoting the sustainable management of Scotland’s inshore waters so that they provide the maximum long term socio-economic benefits to all Scotland’s coastal communities.
Looking back at the 2024 to 2025 budget priorities
1. We would like to know your views on the extent to which last year’s budget allocations contributed to meeting these national outcomes.
Please provide your response in the box provided.
We restrict our responses to the marine element of the budget.
We believe the allocations for marine funding in last year's budget were insufficient to fully meet the primary outcomes relating to marine environment and marine communities. We note that, for example, numerous environmental aspects of fisheries management in the inshore waters, which are the responsibility of Marine Directorate, continue to fail to meet key Objectives under the UK Fisheries Act 2020 (in particular the Ecosystem, Precautionary, Sustainability and Scientific Evidence Objectives). Whilst we recognise that these failings could be a consequence of policy makers' decisions, we believe that the underfunding of Marine Directorate is a crucial factor in the failure to meet the national outcomes.
We would add that it is difficult to scrutinise the budget allocation to Marine Directorate in detail when the granularity of the available data (Level 4) on the Scottish Budget only provides an organisation-wide funding total.
We believe the allocations for marine funding in last year's budget were insufficient to fully meet the primary outcomes relating to marine environment and marine communities. We note that, for example, numerous environmental aspects of fisheries management in the inshore waters, which are the responsibility of Marine Directorate, continue to fail to meet key Objectives under the UK Fisheries Act 2020 (in particular the Ecosystem, Precautionary, Sustainability and Scientific Evidence Objectives). Whilst we recognise that these failings could be a consequence of policy makers' decisions, we believe that the underfunding of Marine Directorate is a crucial factor in the failure to meet the national outcomes.
We would add that it is difficult to scrutinise the budget allocation to Marine Directorate in detail when the granularity of the available data (Level 4) on the Scottish Budget only provides an organisation-wide funding total.
2. We would like to know your views on whether next year’s budget allocations need to change to address these national outcomes more effectively.
Please provide your response in the box provided.
The allocation to Marine Directorate for next year must be raised so that there is sufficient resource to enable it to meet the national outcomes, and achieve the statutory obligations that it is failing to meet and for which it has responsibilities. We note that the allocation in 2024/25 was reduced from 2023/24, and urge that it is increased in next years budget.
3. If you think the budget allocations do need to change, please explain in what ways they need to change.
Please provide your response in the box provided.
As noted in Q1 above, it is difficult to scrutinise the budget allocation to Marine Directorate in detail when the available data (Level 4) on the Scottish Budget only provides an organisation-wide funding total. However we note that, anecdotally, we have been informed by multiple officials from within Marine Directorate that the lack of financial allocation to the organisation has severely reduced its capacity. This is clearly borne out, for example, by the failure of Scotland's seas to meet Good Environmental Status indicators, alongside the declining number employed by the Scottish fishing industry.
Accordingly we believe there should be a substantial increase in the allocation to Marine Directorate.
Accordingly we believe there should be a substantial increase in the allocation to Marine Directorate.
Looking back at the 2024 to 2025 budget priorities
1. The Committee would welcome your views on the extent to which changes to the budget lines in last year’s budget have impacted on service delivery and implementation.
Please provide your response in the box provided.
N.A.
2. The Committee would welcome your views on how the specific objectives of these schemes should be funded in next year’s budget.
Please provide your response in the box provided.
N.A.
Transition to new four-tier system of agricultural support
1. The Committee would welcome your view on the Scottish Government’s proposals so far to fund the different tiers of the new agricultural support scheme and the extent to which these would contribute to the national outcomes set out above.
Please provide your response in the box provided.
N.A.
Budget allocations for the Scottish Government’s Marine Directorate fisheries management of operations and science
1. Does the Marine Directorate have enough resources to provide high-quality research necessary to support evidence-based fisheries management?
Please provide your response in the box provided.
No; numerous fisheries for which Marine Directorate has management responsibility are conducted without adequate evidence on which to base ecosystem based management, as required. A key example is the absence of stock assessments, for example in the wrasse fishery. In this fishery, landings data is collected but there is no evidence gathered regarding stock abundance and biomass. The absence of such data makes evidence-based fishery management impossible. In addition, the absence breaches the requirement under the UK Fisheries Act 2020 to meet the Scientific Evidence Objective. As with previous answers to this consultation, it is difficult for SIFT to know whether Marine Directorate's failure to undertake stock assessments is a deliberate decision, but we believe that lack of resources must be a significant contributory factor.
2. Is the Marine Directorate sufficiently resourced to ensure good working conditions for staff to deliver its core functions?
Please provide your response in the box provided.
We are not in a position to comment on the working conditions of Marine Directorate staff.
3. Does the Marine Directorate have sufficient enforcement resources and technological capability to ensure compliance with fisheries regulations?
Please provide your response in the box provided.
No, Marine Directorate is underfunded in respect to enforcement and compliance. In one obvious respect: the number of vessels operated by Marine Directorate's compliance team is wholly insufficient given the size of the Scottish fishing area. The shortcoming is further compounded by the only partial adoption of Vessel Monitoring Systems and Remote Electronic Monitoring on Scottish fishing vessels. The adoption of VMS and REM in all fishing vessels, along with the technological capability to monitor, analyse and use the data these technologies generate should be a policy priority, if Marine Directorate is to be able to ensure compliance with fisheries regulations.
Other measures to improve the efficacy of fisheries compliance, including for example the bringing of prosecutions against Masters of vessels (given their clear interest in the activities of their vessels) would appear to be less constrained by shortages in funding than by policy decisions.
It is worth noting that the inadequacies of Scotland's fisheries compliance process is well established - an investigation by the European Court of Auditors in 2017 identified ‘less dissuasive’ fisheries sanctions and greater levels of reoffending in Scotland compared to other European countries.
Other measures to improve the efficacy of fisheries compliance, including for example the bringing of prosecutions against Masters of vessels (given their clear interest in the activities of their vessels) would appear to be less constrained by shortages in funding than by policy decisions.
It is worth noting that the inadequacies of Scotland's fisheries compliance process is well established - an investigation by the European Court of Auditors in 2017 identified ‘less dissuasive’ fisheries sanctions and greater levels of reoffending in Scotland compared to other European countries.
4. Are existing forums for co-management and collaboration between industry and wider stakeholders (e.g. Fisheries Management and Conservation Group and Regional Inshore Fisheries Groups) sufficiently resourced and funded?
Please provide your response in the box provided.
No, SIFT is a member of several FMAC subgroups, and from our direct experience we do not believe that the rate of progress of these groups is satisfactory. For example, we have been members of the FMAC Climate Change subgroup since its inception in summer 2023 and are disappointed that despite numerous requests there has only been one meeting of this subgroup and that this inaugural meeting provided no material outcomes. We are similarly concerned about the progress of the FMAC subgroup with responsibility for Fishery Management Plans: the progress of many Scottish FMPs appears to be significantly lacking - both in terms of their content and their prospective ability to meet their statutory deadlines. Whilst other factors may be at play, we believe that underfunding is a significant factor in their underperformance.
5. Do you have access to enough information to understand the Marine Directorate’s spending priorities and funding for marine policy portfolios? If not, what information would be helpful in improving your understanding?
Please provide your response in the box provided.
It is challenging to obtain information relating to the workings of Marine Directorate. SIFT has frequently requested up to date information on the organisational structure of the directorate, including which officials have responsibility for which issues. We have not succeeded in obtaining this information in any useful way.
As noted previously, the available financial data we have seen, at Level 4, provides insufficient information to understand Marine Directorate's spending priorities and funding for marine policy portfolios. We would welcome obtaining information which sets out annual resource and capital budgets for the directorate's various divisions.
As noted previously, the available financial data we have seen, at Level 4, provides insufficient information to understand Marine Directorate's spending priorities and funding for marine policy portfolios. We would welcome obtaining information which sets out annual resource and capital budgets for the directorate's various divisions.
6. Do you have any suggestions for how the Marine Directorate could increase revenues to improve its research and operational capabilities?
Please provide your response in the box provided.
SIFT has long argued for additional revenues for Marine Directorate, and has in particular proposed that Fisheries Management Costs should be borne to a greater extent by the industry itself (as it is a key beneficiary of the fishery management regime).
We have in particular proposed that a landings tax be phased-in at a low but increasing rate across all fisheries. If a landings tax is employed, it should have a differentiated rate based on fishing type and based on their estimated contribution to environmental externalities. It should also have a differentiated rate based on foreign and domestic landings. In the longer term, an additional charge for resource rent could be added to supplement management cost recovery. SIFT's approach to this issue is set out in its paper [https://sift.scot/wp-content/uploads/2019/03/Management-Costs-NEF-SIFT-2018.pdf ] which SIFT presented to the then Director of Marine Scotland.
We have in particular proposed that a landings tax be phased-in at a low but increasing rate across all fisheries. If a landings tax is employed, it should have a differentiated rate based on fishing type and based on their estimated contribution to environmental externalities. It should also have a differentiated rate based on foreign and domestic landings. In the longer term, an additional charge for resource rent could be added to supplement management cost recovery. SIFT's approach to this issue is set out in its paper [https://sift.scot/wp-content/uploads/2019/03/Management-Costs-NEF-SIFT-2018.pdf ] which SIFT presented to the then Director of Marine Scotland.