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Net Zero, Energy and Transport Committee

Meeting date: Tuesday, December 12, 2023


Scottish Biodiversity Strategy (Draft Delivery Plan)

The Convener

Our next item of business is an evidence session on the draft delivery plan to accompany the Scottish Government’s new biodiversity strategy. The committee is continuing work that it started last autumn, when it took evidence on the draft strategy. It was clear that the practical delivery of the strategy was going to be crucial, and this session is about the new draft plan. Today, we have a panel of experts on marine biodiversity to share their views on the draft. We will discuss the terrestrial aspects of the plan early in the new year.

This morning, I am pleased to welcome Dr Clare Cavers, senior projects manager at Fidra; Calum Duncan, head of conservation, Scotland, at the Marine Conservation Society; Elspeth Macdonald, chief executive of the Scottish Fishermen’s Federation—gosh, that proved a bit difficult to say—Tavish Scott, chief executive of Salmon Scotland; and Phil Taylor, head of policy and operations at the Open Seas Trust. Vicki Paxton, partnership manager for Moray Firth Coastal Partnership, was going to participate remotely, but she is, unfortunately, unwell and so is unable to join us. Thank you to those who are here. We have just over 90 minutes for the session.

Before we move to questions, I will declare an interest, which I always do when we discuss salmon in any shape or form. So that the committee and the panel are aware, I am the joint owner of a wild salmon fishery on the east coast of Scotland. That wild salmon fishery generates income and employment in the local economy and, to my mind, is not affected by aquaculture on the west coast of Scotland, because the salmon that migrate from the river that I am involved with do not move through that aquaculture zone. For clarity, I take the importance of wild salmon to heart. This morning, I was concerned to see that wild salmon is on the International Union for Conservation of Nature’s red list. There should be no doubt in anyone’s mind that I have an interest. I am and have been passionate about the subject for about 40-odd years, so I am not going to change.

On that note, we will move to questions. I will put the first question to each of you in turn, so you will all have a chance to answer it. I have read your submissions to the committee. I do not think that anyone universally supports the way in which the delivery plan is going forward. Some people think that it does not go far enough and some think that it goes too far as it is. I will start with you, Clare. I am not giving you a platform of an hour and a half, but you can take a couple of minutes to say why it is either good or bad. I will come to each of you in turn.

Dr Clare Cavers (Fidra)

Thanks very much for giving me the chance to give evidence. The plan is a good start; we need a biodiversity strategy. These things always seem to come either too late, or later than we would like.

The first thing that sprang out at me is the lack of strong timelines for many of the actions: some have timelines and have obviously been thought through; others do not.

Secondly, there is a lack of attention to chemical and plastic pollution and their impacts on biodiversity. The committee also has a focus on climate change and its impacts on biodiversity. According to the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services global assessment report, which came out only a few years ago, there are five main direct drivers of biodiversity loss; one of those is pollution and another is climate change. So, pollution is a major source of biodiversity loss and, particularly in Scotland, the chemicals investigation programme has not been as extensive as it has in other parts of the United Kingdom. That needs to be extended and made more transparent. Understanding the pollution that is going into our environment is one of the first steps towards mitigating it, but we do not have enough of that knowledge yet.

Thirdly, there is a lack of attribution of responsibility to different bodies. Some bodies, such as the Scottish Environment Protection Agency, have their names put to some actions, but others have not, which means that gaps appear. As you will be aware, we have seen that happen in relation to salmon farming and wild salmon: there was no direct responsibility, so it was not being addressed directly. In such cases, resources will not be allocated. That has to be laid out quite firmly.

The Convener

I do not want to stop you going through all of the points, but everyone on the panel is thinking, “Oh, she’s stealing all my points”.

I will move on but, before I do, may I say that my manners left me briefly at the beginning of the meeting, for which I apologise. I should have welcomed Finlay Carson, convener of the Rural Affairs and Islands Committee, and Rhoda Grant, both of whom have joined us and will get a chance to ask questions at the end. Sorry to cut you off, Clare. I move now to Calum Duncan.

Calum Duncan (Marine Conservation Society)

Thank you, convener. Following the evidence that I gave last year, I appreciate the committee recommending to the Government that there should be a strategy to tackle the nature emergency.

We are supportive of the framing of the strategy, and of the recognition that there is a crisis. That plays out in the ocean as an ocean emergency, which the United Nations recognises. There is much in the draft strategy and action plan that we welcome. Of course, as we have seen with recent events, there needs to be support, political will and funding and resourcing to make sure that the welcome actions in the strategy are delivered.

The devil will be in the detail, in relation to the ecosystem recovery framework, its licensing and its funding, and in how the national marine plan 2 is developed. Some actions are almost meta-actions. They talk about fisheries management plans, for example, but our concern relates to what detail is in the fisheries management plans. There are a number of dependencies that relate to how the actions that are being recommended are taken forward, and, for us, many of those are around fisheries management. We are supportive of sustainable fisheries and sustainable aquaculture, but we welcome the fact that the strategy recognises that they should be nature friendly. The detail of making those nature friendly depends on how the fisheries management plans and some of the commitments in the Bute house agreement are delivered, because some of those have been dropped.

What does enhanced marine protection look like? We think that that is a key part of the suite of measures that we need at sea. We need strict protection—international science and policy makes that clear—but how will that be addressed through the strategy? How will the fisheries management plans be delivered?

The inshore cap was also mentioned in the Bute house agreement, but the strategy does not mention the second part of that, which is that it must be a ceiling from which you reduce the pressure that disrupts the sea bed.

We welcome the strategy and its framing, but the devil is in the detail. It will be about how the actions within the plan are delivered. We know, straight away, that there are gaps in what features in the strategy and the plan. They do not even refer to the marine nature conservation strategy, which has a welcome three-pillared approach that is a good lens through which to look at improving nature at sea.

The Convener

Okay. Elspeth, I come to you. [Interruption.] It is very confusing; you do not need to push the button. Do not touch it; the gentleman on your left and my right pushes the buttons. It helps us, and I am sure that it will help you.

Elspeth Macdonald (Scottish Fishermen’s Federation)

I should not be let loose to press buttons.

Thank you for the opportunity to give evidence today. As Calum Duncan outlined, a lot of activities, policies and initiatives are already under way in the marine space and are at various stages of development. Some have been running for many years—for example, the marine protected area network—and others are newer to the table, such as the development of the fisheries management plans. A lot of them are being put into the strategy, and it would be helpful to have some mapping from the Government to understand how all the different initiatives are expected to contribute. There seems to be quite a lot of double badging of activities that are under way elsewhere.

A frustration that we have with this piece of work is that, thus far, we have not been particularly engaged with its development. The strategic environmental assessment that accompanies the consultation talks about doing that assessment with relevant stakeholders, but we did not get the opportunity to partake in or be involved with that. The lack of engagement in the creation of the strategy, the draft delivery plan and the SEA is very disappointing.

A concern that we have running through this is the lack of good baselines. Where are we starting from? Where are we trying to get to? That is important when it comes to setting targets and asking whether they should be statutory or are specific, measurable, achievable, realistic and timely or whether a better approach is to look at trends and qualitative assessments. Without a very clear understanding of the starting point and a commitment to the science that will assess whether progress is being made, we have to be very careful about being sure about what we are attempting to measure and assess.

We felt that something that was very much missing from the package that is under consultation is a socioeconomic impact assessment. The failure to include that does not allow us to answer some of the questions that are in the consultation. The consultation talks about trade-offs and looking at the impacts on businesses, the economy and society, and it is difficult to do that without having a socioeconomic assessment. We have concerns, too, around the timescales and having a rolling five-year delivery plan. Five years is a very short period in which to start to see change of the magnitude that is being suggested here.

Although it is clearly a necessary endeavour to consider biodiversity loss and how we address it, there are a lot of issues with the particular package in front of us that we would like to advance.


Thanks, Elspeth.

Tavish Scott (Salmon Scotland)

I thank the Parliament for taking an interest in the matter from the marine side. I share many of the concerns that Elspeth Macdonald articulated, but, at the outset, I say that the salmon sector absolutely supports the Parliament’s intention to tackle the biodiversity crisis: that is a laudable aim for parliamentarians. I look forward to seeing your deliberations on how you pursue the detail, because that has not been looked at with enough parliamentary interest as yet.

As Elspeth said, you cannot see the biodiversity strategy in isolation. You have to see it in the context of all the other strategies that the industry is subjected to: the blue economy, the aquaculture vision, the export, the innovation strategies and the economic transformation strategy that was launched last year. There is a question for parliamentarians about how all those strategies fit together and whether there is a consistency of policy purpose behind them. I suggest that the committee might want to look at that area.

I have two other points. First, on the consultation, we have concerns that the way in which it has been run so far mirrors all the mistakes that were made with highly protected marine areas. As Elspeth rightly said, there is not a baseline on the marine side. Yes, there may be one on the terrestrial side—as you said, convener, there will be a panel on that next year. However, on the marine side, if I have read the proposals correctly, by 2025, when the Parliament will be considering a natural environment bill, the marine data will be 10 years out of date. That is not the baseline that is needed—you just need to remember the HPMAs—for, as Elspeth rightly said, the robust analysis and setting of targets based on real-time information that allows parliamentarians to consider it carefully. That is point one.

Point two is about accountability. We need to be really clear about who is responsible for this. Trying to find out who is actually the minister in charge of these matters is incredibly puzzling. NatureScot has four ministers, as I am sure that you are aware; I do not know whether all four appear in front of you. I have great sympathy for an agency that is directly responsible for this area yet has four ministers. Who is the chief accountable officer? Some of the issues that you have been dealing with in the Parliament over the past number of years seem to have fallen down on the basis of the scrutiny of who is actually responsible. That is really important to business.

The final point is cost. Elspeth Macdonald is quite right: you could also cite the business regulatory impact assessment, which is a formal legislative requirement on the Government when proposals will have a cost. The Parliament will want to satisfy itself that it will know the cost. I notice all the work that the Finance and Public Administration Committee has been doing on financial memorandums. I applaud that work because it is important, particularly in the current challenging times for public finances, for the Parliament to be satisfied that it knows what the cost of this endeavour will be.

Those are my three suggestions for where Parliament might want to exercise some oversight.

Phil Taylor (Open Seas Trust)

Thank you, committee, for taking evidence on this important issue.

You asked whether the draft delivery plan was good or bad, and Clare Cavers started by saying that it was a “good start”. It is not, however, a start: we have had biodiversity strategies in the past; this is not the first. A key learning point for us needs to be that the previous biodiversity strategies have not met their goals, failed to prevent the loss that we have seen in the intervening 10 years and put us on a downward trajectory.

I will focus on seabirds, the great sentinels of the health of the marine environment, in that they pick up the forage fish that everything else relies on. Just last month, the decadal census of seabirds was published and we saw a 40 per cent decline in kittiwakes United Kingdom-wide, a 35 per cent decline in Arctic terns—those are species that rely on top-level forage fish—and an above 10 per cent decline in puffins. Depending on how you cut the cake, you can put different figures on those declines.

We have also seen significant declines in the health of the marine environment and the habitats that underpin it. The Scottish marine assessment that was published at the end of 2020 presented lots of that information. I will not rehearse that here: you guys, as a committee, will have received and understood a lot of that information already.

This plan is not a bad start. What is good is that it is a very welcome occasion on which to acknowledge that there is a nature emergency. My learned colleague Tavish Scott even mentioning the industry’s recognition of this nature crisis in the sea is extremely welcome. That imparts on the Government and this Parliament a real responsibility to address what has happened over the past several decades in our seas and turn it around. What we really cannot have—it would be extremely sad and unfulfilling—is in 10 years’ time, another set of stakeholders telling another committee that, sadly, we have continued those negative trends and need to come up with a new approach.

Tavish spoke about the need to bring principals together in a principled approach. There is a real opportunity for mainstreaming in the nature emergency approach that is being taken by the Government here.

Tavish Scott and Elspeth Macdonald said that stakeholders were not fully consulted during this process. There was a stakeholder forum and I believe that both of their organisations sat on that forum. One key message that came out of that was the need to make sure that the biodiversity elements are mainstreamed throughout policies so that they provide guidance to all the other strands of work and support and mechanisms for those other industrial activities that are designed to help to deliver socioeconomic good, better jobs or better export markets or whatever. They must also have that thread of biodiversity going through them so that we are not working in silos and not competing with one another. That is integral to what we achieve here.

It is a great start—a “good start” is what Clare said—to be talking about a nature emergency here in the Parliament, and it is a credit to you as a committee that you are taking this evidence. However, it is not quite a start; it is a middle. There are ways in which it can be significantly improved, and I am very glad of an opportunity to present some of those ideas today. I hope that we can provide that support.

The Convener

Thank you all for starting off like that. I do not think that anyone will agree that the status quo is acceptable or that we have 10 years to let it run; we probably do not. We will drill down into the questions. The first is from Douglas Lumsden.

Douglas Lumsden (North East Scotland) (Con)

I want to drill down a bit deeper into the delivery plan. Elspeth Macdonald and Tavish Scott talked about the lack of engagement with the plan. Phil Taylor seemed to suggest that there was quite a lot of engagement, so I will go back to Tavish and Elspeth. Was there not a forum that you could contribute to? Why do you feel that there was a lack of engagement while other people feel that there was enough?

Elspeth Macdonald

We felt that there was very limited engagement on the plan and it would be fair to say that the discussion was not particularly balanced.

There was also frustration. Last year, we had a consultation on the strategy, and we contributed to that, but it remained largely unchanged, other than including some references to things that had not been in the first version. Having gone through that exercise last year only to find the strategy essentially much the same, with some additional references to the global biodiversity framework, begs the question of what the purpose of the consultation was.

When we start to look at delivery plans now and at how they will turn into something to be implemented, it is disappointing to find that businesses will not be asked for their views on it and we will not be engaged in the strategic environmental assessment, for example, upon which a lot of the delivery plan is based. It means that there organisations such as ours are missing an opportunity to contribute our perspective. As we said a moment ago, we strongly request that a socioeconomic assessment and a business regulatory impact assessment be carried out on the proposals, and we would absolutely want to be much more engaged in those.

So much is going on in the marine space. Calum Duncan mentioned many of the other things that are going on. We have to cover all the different initiatives, which is absolutely right, and we are here to represent our interests in the different activities and policies that are under way. However, I feel that this is one that has not perhaps gone through that same broad consultative process to get us to this stage.

Tavish Scott

I will add just two thoughts to Elspeth Macdonald’s observations. The first is that there is probably a difference in the way in which the agencies, including NatureScot and others, have looked at land use as opposed to marine use. I suspect that the committee will want to test this, but I think that there is not the same level of expertise in or the same level of baseline information around marine use, which is the point that I was making about baseline information being potentially out of date. That, I think, is a gap and, if it is helpful to say so, Mr Lumsden, there is a bit of a catch-up job to be done by the agencies that are promoting measures to you, as a parliamentarian, that show whether they have the necessary level of expertise and knowledge to pursue and prosecute a biodiversity strategy that has the far-reaching implications on the marine that it needs to have.

My second point is simpler. As Elspeth Macdonald rightly said, we are not dealing with this issue alone. In the past year, my organisation has dealt with 10 Scottish Government and public body consultations, along with four from the UK Government and one from the European Union, and we already know that another 10 are coming up next year. As Elspeth Macdonald rightly said, as trade bodies for our sectors, that is what we do, but please do not see that in isolation. A heck of a lot of other stuff flows at us all the time. You could be critical of us for not attending every meeting, but I do not have enough people in my team to go to every meeting that the Scottish Government invites us to. The Government is trying to do the right thing. It is creating forums for people to meet, but, believe me, I could bore you all day with the number of meetings that we are asked to go to. At times, there needs to be some focus, some pulling together of initiatives and some consistency across policy, which is the point that I was seeking to make to the convener. I am not sure that we see that all the time.

You mentioned baselines. Do other panel members feel that the proper baselining has been done so that we can measure things?

Calum Duncan

There is plenty of data that enables informed decisions to be taken to get on with protecting biodiversity in the ocean. I have been involved with marine protected area management workshops going back eight years. The measures to protect the remaining inshore and offshore sites are seven or eight years delayed. We could start saying, “We need a fresh baseline”, but do we really want to delay for another seven or eight years? We have some good data in the bag and we need to apply it to make sensible decisions.

Some commitments need to be delivered in any case, such as the MPA measures that I mentioned, but, equally, there was sufficient data to inform a policy recommendation to improve the protection of some vulnerable priority marine features beyond the MPA network. Again, that is a policy commitment that dates back about seven years. We have very good records for fragile sea bed habitats, particularly those that we know about. If we wait to collect more data, rather than getting on with protecting those habitats, they might be gone by the time that we get around to taking any action.

It will always be more difficult in the ocean, because satellite images that show the extent of habitats cannot be obtained—one needs to get under the water and do surveys—but there is a comparatively impressive data set. I have been in front of this committee and its sister committees several times over the decades, saying that there is good data in that regard. We can therefore make good, informed policy based on the data that we have. We just need to get on with it.

Phil Taylor

I second what Calum Duncan has said about there being sufficient data to make good decisions now. He and I have been involved for a long time in many of these discussions in which the data has already shown that action needs to be taken. Saying that there is a lack of data is not sufficient; there is plenty of data to provide a baseline.

I will, however, present some ideas and ways in which the committee could progress some of that thinking. Some significant amounts of funding are available from the Scottish Government for various activities around marine issues, which is the marine fund Scotland, and nature recovery, which is the nature restoration fund.


Significant amounts of that money are being put into projects that include data collection. My learned colleague Elspeth Macdonald is running a project for the Scottish Fishermen’s Federation on fisheries observer data that is paid for by public money through the Scottish Government. That data would inform one of the key actions in the delivery plan, which is to identify spawning and nursery grounds for some of the species. We would then understand where those small fish are, where they are being bycaught and how we can develop policies around that. That data has not, in the current system, been made publicly available in that way. There is therefore a real opportunity to ensure that the public money that is used for that work is delivering.

I did not mean to single out that project in an exemplary way. Rather, I simply meant to suggest that projects like that are collecting data and can easily present that data in the spaces in which those decisions need to be made. It is already being collected using public money, so why do we not make it a condition should then be put into a public forum?

You said that that is currently in progress. Does that not highlight the fact that the baseline data is not there and that that work needs to be done first?

Phil Taylor

I do not want to speak for my colleague Elspeth Macdonald.

Elspeth Macdonald

Perhaps I can clarify the programme’s particular purpose. The programme is an independent fisheries science support scheme. As Phil Taylor said, it is about providing data from fisheries observers. It is not a programme that contains a great deal of flexibility. Its whole purpose is that we deliver for the Scottish Government the fisheries data that it is required to produce for International Council for the Exploration of the Sea stock assessments. We have been doing that for about 15 years, initially through the European maritime and fisheries fund and, since the UK left the EU, through marine fund Scotland. The programme is specifically about providing the fisheries observer data that the Scottish Government is legally required to submit to the ICES stock assessment process.

I would add that, although we are exceptionally grateful to the Scottish Government for making those resources available through marine fund Scotland, because it is a really important part of the stock assessment to have that data, we are concerned that we have no long-term funding commitment to it. We enter into a process every year with the Scottish Government to find out whether there will be resources to continue that programme. Obviously, the people who run the programme have to understand what they are doing and be skilled and knowledgeable, and it can be hard to retain such people on a programme when you cannot make any commitment beyond a one-year funding settlement. Obviously, we understand the funding pressures that the Government faces, but that is a good example of how not having that long-term commitment to funding science in the marine space can be a limiting factor.

Douglas Lumsden

I have just one more question. Elspeth Macdonald, I think that you said that five years is not long enough for the plan. What are the everyone else’s views on that? Is five years not ambitious enough? Should we look at a longer period?

Dr Cavers

I agree that five years is not long enough. You could have five-year stages and then reassess every five years, but we would want to put some type of framework in place for at least 15 years. Some of these things will take years to work out. For example, the delivery plan contains a lot of reference to plans but not on how to implement those plans. In five years, you may come up with lots of plans but then find that there is no plan to implement the plans. You need to have a longer framework in place.

Phil Taylor

It might be that we cannot afford to have a longer timeframe than five years in this first iteration, but Clare Cavers’s suggestion that five years be an interim step is a good one. Clare’s point that lots of the proposed deliveries, items and actions are, in fact, plans shows that we need that deadline sooner.

In the marine space, the marine director has an allergy to meeting deadlines. We have talked about the marine protected areas stuff and the fact that deadlines have been failed consistently around that. In June, when Cabinet Secretary McAllan made her statements about highly protected marine areas, she committed to consultations on offshore marine protected areas on the other side of the summer recess. Those still have not been brought to the table. We are coming to the end of the year, and I believe that they have been pushed into next year. That addiction to setting targets and failing to meet them is a serious issue in the marine space and is one of the main reasons that I am not particularly happy with what is in the proposed delivery plan, which itself includes several delays on set targets. We need that deadline soon. We need the targets to be SMART, and we need the deadline to be firm.

I will not suggest that I know more about how you, as a committee, will engage with the Government, but, there is a significant role for a parliamentary committee to hold the Government to account on what it says it will do. We would appreciate that action.

Tavish Scott wants to explain why the industry will not invest in a five-year plan. Or will it?

Tavish Scott

We invest in 20-year plans in our sector, so we have no bother with five-year plans.

To help Mr Lumsden, Phil Taylor’s final point about oversight is right. Calum Duncan and I might have slightly different perspectives on the science, but I do not disagree with his point about the specific areas in which science absolutely has a bedrock and baseline. Taking the marine environment as a whole, no one could argue that. Perhaps it would be better for parliamentarians to ask the marine directorate about its science strategy—I think that we would all agree on that—and the quantum of the money going into science. Whatever we debate today in front of the committee and whatever we forward to you, I am not sure that the marine directorate’s science quantum, or budget, is enough to support our long-term aspirations for all our needs as businesses or as conservation organisations. The committee might wish to explore that.

Mark Ruskell wants to come in, then Calum Duncan also wants to come in. I will then come back to you, Douglas.

Mark Ruskell (Mid Scotland and Fife) (Green)

I just want to make a brief point, convener, to pick up on what Elspeth Macdonald and Tavish Scott said about strategic environmental assessments. At what level would you wish to be more involved in that: at screening stage, scoping stage or development of the environmental reports? I am trying to understand what the missing bit of engagement is and how appropriate it is for you to be involved at different stages. Given what Tavish Scott said about not having enough staff to go to every single meeting, how involved can you be in the science and setting the baselines that are required through that kind of process? What did you feel was missing through your engagement in that SEA process?

Elspeth Macdonald

Certainly, in this case, the environmental assessment had a strong focus on whether restoration or regeneration was the right approach, and whether the time frame should be longer-term or shorter-term. The impression from the assessment is that stakeholders were involved in how that assessment was then presented in the final document.

In general, we are frequently involved in strategic environmental assessments. We would be involved at scoping stage to see what should be in it. We would then be consulted. We were often engaged in that on marine licensing applications, for example. Recently, we were able to contribute to the scoping stage of the SEA for the national marine plan 2. It is very common for us to be involved in those things.

You are absolutely right that, as Tavish Scott and I have said, we are stretched over a number of areas, but we are also good at prioritising our time and understanding where we need to focus and which other areas might have to be put to one side if there is a higher priority. We would have wished to have been more involved in this area. It certainly appears from the document that there was stakeholder engagement in it, but it did not involve us.

Tavish Scott

I suppose, Mr Ruskell, that the balance for all of us who are in business is between stakeholder engagement and how much it affects decisions. You make a good point about what our role is and when it is appropriate. That is a judgment that parliamentarians and, ultimately, NatureScot and Government have to come to. We will attend as many meetings as we possibly can when invited by NatureScot and, indeed, core Government. We will do our level best to always be part of the process. That is why we have highlighted the importance of the socioeconomic study when it comes to those kinds of judgments. NatureScot seems to be sympathetic to that, and I am grateful for its consideration.

You and I might have debated this in the past, Mr Ruskell, but it strikes me that the balance between environmental, social and economic factors will always be at the heart of policy making in this area. We will all come to a slightly different perspective on this, but you will not be surprised to hear that those of us who represent organisations, companies and businesses that seek to create wealth in Scotland will do our best to make a business case. We have great confidence in the systems that the Government has put in place through legislation, notably the business and regulatory impact assessment, or BRIA, to use the jargon, and the socioeconomic study. We hope that they will be part of the on-going process. I take your point entirely and we will do our best to attend every meeting that we can.

Calum Duncan

I want to reflect a little bit on targets, timelines and baseline in relation to this discussion and some of the comments we have heard. In five years, our seas will not be in the state that they should be in but that is not the point. The point is to have the plans commenced so that there are targets that ensure that the decline of nature is halted by 2030—it was supposed to be halted by 2010; I remember that one too—and that we are net nature positive by 2045. We need to get the policy commitments and actions that are already delayed progressed and in the bag. They need to be done and there is plenty of data to do that.

Today’s discussion also highlights the importance of the sister aspect to this, which is the need for nature recovery targets in law. That is where this space is seeking to catch up with the climate change discussion—where there are climate change targets in law. Yes, some targets will be missed, but the difference is that, if we get them into law, it will create leverage to make sure that they happen and drive the seriousness with which policy and sectoral action needs to take the biodiversity emergency. Phil Taylor touched on it: previous biodiversity strategies contained good actions, many of which were not implemented because they did not have a legal hook or some leverage to make sure that they happened. That is one aspect.

To come back to baselines, the other thing to be clear about is that I do not want the committee to have a picture of a kind of blank canvas. There is an incredibly detailed breakdown of data in Scotland’s marine assessment. Yes, some of it is modelled, because, as I said, we do not have satellite imagery that can see through the ocean to the sea bed, but there is incredibly detailed work there.

I beg your patience for the final point. We have submitted evidence of decline, and the biodiversity strategy has that in its introduction, but I just want to update it with the Convention for the Protection of the Marine Environment of the North-East Atlantic—OSPAR—quality status report. According to the 2023 report on the state of the north-east Atlantic: a majority of the 22 fish species are in a poor state; eight of nine OSPAR habitats in the greater North Sea are in poor condition, with one in an unknown condition; six of seven in the Celtic Seas habitats are in poor condition, and the condition of the seventh is unknown; plankton is not in good condition; seabirds are not in good condition; marine mammals are not in good condition; and food webs are of great concern. The experts in the north-east Atlantic present a troubling picture. We need to get on with action.

Okay. Perfect. Douglas, do you want to come back on any of that?

Douglas Lumsden

Yes, I do. I have one final point on the socioeconomic study that has been mentioned by a couple of people. Dr Cavers, Calum Duncan and Phil Taylor, what are your views on that? We have heard from Elspeth Macdonald and Tavish Scott.

Dr Cavers

Socioeconomic assessment is really important, as is a business impact assessment, but they can also follow; the action should not be paused in order to carry them out. A lot of the actions can be started immediately. It is the same with the amount of data that is already available for baseline, as Calum Duncan mentioned. That aside, you do not necessarily need baseline data to start preventing pollution. We now have a UK regulator for chemicals, for example. Each nation can submit to that UK regulator any chemicals on which it would like to see stronger regulation. I do not think that the individual nations know that. We can start looking at chemicals of concern that are entering the marine environment and start working to prevent that, because we know that it will already be having an impact on biodiversity.


Okay. Can you really do the socioeconomic study afterwards? If you have not read it, some of the things that could be implemented might harm the social and economic condition of a community.

Dr Cavers

I am not saying, “Start all the actions, complete them and then do the socioeconomic study”, but some actions can be started. Some are in progress already, and some have been delayed. We do not want to delay any longer in order to do the socioeconomic impact assessment.

Calum Duncan

It is important to do socioeconomic impact assessments of policy; it is part of policy development. It is also important that, when those assessments are done, the socioeconomic benefits of the policy are also looked at. I would like to make that point in this space, because I often feel that there is an unfortunate sort of polarisation—I call it a “false dichotomy”—and a perception that action for biodiversity can challenge wellbeing and economic benefit. If that is the perception, we are doing something wrong.

It is more difficult to get the data to show socioeconomic benefit, including indirect benefits. We saw that with the recent discussions about the HPMA measures. Done right, those conservation measures are about helping to shore up local socioeconomic benefit and provide local sustainable opportunities and local sustainable businesses, whether in capture fisheries, aquaculture or any of the other sectors that are not represented here. I just wanted to make that point of principle.

Phil Taylor

It is a question of where you put the socioeconomic impact assessment. I suppose that that is a question for the Government and then for the Parliament to scrutinise. Elspeth Macdonald spoke about prioritisation and where they would invest their time in evaluating the socioeconomic impact assessments. The delivery plan is a suite of many actions that includes marine, terrestrial and some in the middle, such as coastal. Each of those policies will have a socioeconomic impact assessment when it becomes an action or something that changes on the water, which is where our interest lies.

Take, for example, the priority marine feature protection. That process has been under way since 2017, and it has already gone through several rounds of socioeconomic impact assessment and strategic environmental assessment. As stakeholders, we have been involved throughout that process. So far, the discussion on that has been theoretical and high-level, but, as the process is delivered in a practical way, I presume that the Government—although I will not speak for the Government—will deliver a socioeconomic impact assessment and a BRIA. I will engage with it at that point. I do not know that there is necessarily much value in engaging with it at the delivery plan stage, because the socioeconomic impact assessment will be so big and expansive that it will have to offset the value of, for example, delivering the policy that will deliver economic benefits to low-impact fisheries as well as benefits to the environment, against a policy on upland and moorland restoration that will probably impact on the same community, such as in the areas around Torridon or Ullapool. Both those policies will impact the communities of those villages.

At the delivery plan stage, the socioeconomic picture will be so big, complicated, confusing and overlapping that I do not think that that will be the right stage to engage with it, but I will pay attention to it. The place to engage with it is in the delivery of those policies as they come down. As I said at the beginning, the key opportunity here is to put a thread of biodiversity through everything so that those individual policies and individual official teams—the teams of individuals in government who have to wrangle with competing demand—are clear about how biodiversity should be mainstreamed into, let us say, fisheries licensing, which is, as you know, subject to a legal dispute between us and the Scottish Government. Other examples are upland management, terrestrial planning and offshore planning. That is the key here—that is the real opportunity.

The Convener

I have tried to let the conversation run, which will come back to bite me at the end, because not every committee member will get everything that they want from the session. I will slightly squeeze each person’s time to have answers that are as succinct as possible. I move to Bob Doris for the next lot of questions.

Bob Doris (Glasgow Maryhill and Springburn) (SNP)

After I have asked my questions, I might ask you, convener, to work out who will answer, because that is challenging when I am not in the room.

I have been listening carefully to the evidence that we have received. A lot of this is process driven, but the delivery plan needs to identify meaningful and appropriate actions across key sectors, groups and regulatory areas. I am keen to know where the witnesses believe that that is contained in the draft delivery plan or what more could be done to make sure that it exists in the plan.

The key areas that I am thinking of are fishing, aquaculture, plastics and chemicals, and regional and community coastal partnerships. I acknowledge that, according to the Scottish Parliament information centre, there appear to be no actions in the delivery plan on marine renewables.

What is in the plan that can deliver identifiable, meaningful and appropriate action across key sectors? I want to be clear about what could work well and where the gaps are.

The Convener

If none of you throws your hands up, I will nominate somebody, which is always dangerous. I will not nominate the same person each time. I will start with Elspeth Macdonald and then probably come to Phil Taylor or Calum Duncan.

Elspeth Macdonald

The question is really helpful, and it goes back to what I said in my opening remarks about mapping what is in the delivery plan. The delivery plan is not set out in a particularly helpful way for seeing whether there is a holistic and correct approach to deliver the objectives. It feels a little bit as though it is pulling together a lot of things that are under way. As others have said, we have been working on the marine protected area network for 15 years and on priority marine features for six. We have all been very involved in that.

It feels a little bit as though the delivery plan is double badging in pulling together a lot of things that have started somewhere else and have been designed for other purposes. For example, the fisheries management plans have come from the new UK Fisheries Act 2020 and have to meet lots of objectives, which they have to balance to achieve their overall purpose.

It would be more helpful to undertake some sort of mapping to extract the marine elements from the delivery plan, as Phil Taylor said, because it covers all environments, and to ask whether the actions will deliver the change that we need and, if so, in what sequence they should be done and how they will be resourced. There has been a lot of discussion about the resources for delivery. The timelines that are set out in the delivery plan are all high level and there is not a lot of detail under them. However, a huge amount of detail sits beneath every one of the actions, and a lot of work will be needed to deliver every one of them. None of the marine elements is particularly straightforward or quick to do.

There needs to be a better way of drawing together the different elements of work that the strategy and the delivery plan feel are required to deliver the strategy’s objectives, to map them properly in relation to the marine environment and then to look carefully at what the priority is among those things and how they will be resourced. A huge amount of detail is not in the plan, and the devil will be in the detail of how those things can be delivered.

Bob Doris

Before the next witness comes in, I will check something. I do not have in-depth experience on the subject. Your response was quite process driven and was about mapping what should be in the plan. My question was about what is identifiable in the plan and what might be beneficial and achievable. I get that witnesses think that some things should be removed from the plan and others put in and that things need to be pulled together. I am talking in general terms when I ask the question. Is there anything identifiable in the plan that is of value and would be beneficial?

Elspeth Macdonald

There are the priority marine features, which we have spoken about. A number of years ago, the process of identifying them started with the purpose of protecting biodiversity outwith the existing marine protected area network. That is intended to improve the marine biodiversity situation. We have been engaged in that process, and we absolutely want to strike the right balance between conservation and protection of our marine environment and its sustainable use.

Lots of things in the plan can deliver the strategy’s objectives, but the plan feels too disparate to enable us to see how we go about doing that. We have to be clear that we do not have endless amounts of money for delivery, and it is critical that we spend the money that will be available for it on the right things, at the right times and in the right way.

Calum Duncan

A good question has been asked. I will briefly introduce another strategy—the marine nature conservation strategy, which predates the Marine (Scotland) Act 2010. It is a useful lens that it would be good to look at for organising the actions in the biodiversity strategy for the marine environment. It talks about a three-pillared approach to nature conservation, which recognises species-specific measures, site-specific measures and wider seas measures such as fisheries management and planning. We should use that filter.

There are lots of welcome actions, and I touched on some in my introduction. Some of those things are committed to anyway and should be happening. They should be in the plan, because they are a part of the three-pillared approach.

On the MPA and PMF measures, which are delayed, we might have a slightly different view about how they should be implemented. We think that there should be a whole-site approach to having fisheries protection measures across sea-bed MPAs, for example, and there are discussions about how protecting the PMFs can be done in a spatial way. For transparency, I put it on the record that, in a committee meeting previously, one scenario that I put forward for strategic environmental assessment testing was a distance-from-shore closure of, perhaps, half a nautical mile. There are different ways of putting measures in place.

Lots of things that are in the draft delivery plan, such as seabird and cetacean strategies, should be happening anyway. To answer Bob Doris’s question, there are some additions. The ecosystem recovery framework is welcome. A meaningful framework needs to look clearly at licensing, because it is difficult to license ecosystem restoration—rather clunky existing licences need to be used, such as construction licences. Again, that is an action to have a plan or a framework, but it is something new, welcome and additional that is in the biodiversity strategy.

For that framework to work, licensing needs to improve, and funding needs to be in place. That requires another huge discussion about adequate funding for restoration. We have the Scottish marine environmental enhancement fund, which does not have enough funding. How can we get more funding to support restoration?

There is also the commitment to protect vulnerable marine ecosystems between 400m and 800m. That is a new and welcome addition and, for transparency, I note that we said in the past that the closure should be as shallow as 600m. There is the lens of the three-pillar approach, there are existing things and there are new things in there.

I am sure that you will get the hang of this by the end, Calum. If I cough gently and make a gesture, it means that you need to wind up. That means that I do not have to cut off your microphone.

Calum Duncan

I beg your pardon.

I will let Tavish Scott in, if he can be brief.

Tavish Scott

A fair point has been raised. To help Mr Doris, I will clarify that the point on which I was agreeing with Elspeth Macdonald was that, if the mapping exercise does not take place, the delivery plan and the strategy will be challenging when it comes to the strategic environmental assessment, the socioeconomic assessment and the BRIA. We are trying to help the committee and the promoters of the initiative by pointing out that the mapping exercise gives you comfort that those things are being covered.


Dr Cavers

There are some good references in relation to plastic and chemical pollution. We welcome the action to develop policy by 2028 to address contaminants that exceed the OSPAR threshold values, although we would like a shorter timescale. The commitment to reduce marine litter and marine plastics through enabling improved plastic pellet handling is also welcome. That has a timeline of 2025, so there are some short timelines.

The plan refers to the aquaculture vision, and we support quite a lot of its intended outcomes. However, the timescales for the vision are not great. There are also references to supporting SEPA in the implementation of the sea lice risk assessment framework.

There are good references to plastics and chemicals and to aquaculture. As I said before, there are references to the chemical investigation programme but, in comparison with the other nations, Scotland does not have a lot of detail on that.

Does Bob Doris have any further questions?

Bob Doris

No, convener. That was genuinely helpful. I am conscious that this is a draft delivery plan and that witnesses will want to shape what the final delivery plan looks like. We are therefore hearing about things that are not in the plan and about mapping exercises and other matters. However, it is important for the committee to hear about what in the draft plan is welcome and could make meaningful change. We have got some of that, so I will not come back in.

The Convener

If any witnesses think that we have missed out particular things in the plan, it would help if they commented on that. I will ignore Calum Duncan now, because I need to go to the next member, but if you have additional stuff that you would like to see, please come back to us. The next question will come from Mark Ruskell.

Mark Ruskell

The 30 by 30 targets that are embodied in the global biodiversity framework are hugely important. What are their implications for the designation of marine protected areas and for the management of those areas? Given the comments that were made earlier about mainstreaming, where should those targets sit? Should they sit at the top of the aquaculture strategy? Should they be in the fisheries strategy as well? Should there be an explicit ambition, or a secondary one, for sectors to work towards their delivery? Maybe we could start with the witness on the right and move across the table.

That is your left, I think.

It is indeed. I am left-handed, so I work that way.

Phil Taylor

Thanks for the question. You asked where the targets should sit. The national marine plan is the overarching policy but, as part of mainstreaming, they should also sit in everything that is subsidiary to that. The national marine plan is the key mechanism for delivering spatial management using the key legislation for the management of Scotland’s seas. That is the legislation that gives Scottish ministers powers for the waters beyond 12 nautical miles. The 2010 legislation provides that entire framework, and the targets should be established within that. There should be a mechanism for the distribution and planning of other activities around the 30 per cent by 2030 target.

The key issue with the 30 by 30 target is, as you noted, the lack of management. The majority of the marine protected area network does not have that management, particularly in relation to fisheries activities that are causing harm within them. We evidenced that just last year using our remotely operated vehicle—ROV—underwater data. In fact, over the past 10 years, we have arguably gone backwards, with a marine protected area that was designated to protect spawning and juvenile fish—it is known as the windsock— actually losing protection. Trawling is being permitted in that area having initially been banned. We have gone backwards rather than forwards. I make the point again that the past decade has been a bit of a failure. We need to really step up our game, and there is a real opportunity here for us to do that.

If the targets are to be part of mainstreaming, they need to be in everything. You mentioned a suite of policies that they need to sit within. At the top of that tree, in my opinion, is the national marine plan. We need that to be implemented across industries and policies.

Tavish Scott

I will make two points. Many existing marine designations in the marine space have sea farms in them. As an industry, we have lived for 30 years with a continuous suite of marine designations. They used to flow out of the European Union, but they are now a devolved responsibility of Edinburgh. I made a point earlier about achieving a sensible balance. I suggest that such a balance can readily be achieved between the environment and social and economic factors. We would be happy to submit an additional, more detailed note on that point.

With regard to where the targets should sit, Phil Taylor makes an entirely fair point about the national marine plan. The only observation that I would add is that some of our areas around the coast are way ahead of where national policy has been on this. Shetland was doing a local marine plan in 2000 and 2001 to try to sort out the spatial squeeze issues. That was long before spatial squeeze became an issue that we are all obsessed with. Even at that stage, in the islands that I am part of, we were already dealing with those challenges. The environmental challenge was there. That is why, at that time, we made sure that our local fisheries college put money into science to try to baseline what was going on, for example with the inshore fisheries issues, and it worked.

I entirely take the point that there has to be an overarching marine national plan, but I encourage Parliament to think carefully about the areas of our coastal communities, because they are really good at this stuff. They know it inside out and they have had a degree of success in delivering local marine plans that achieve a sensible balance between the factors.

Mark Ruskell

Would that feed into more designation of marine protected areas? I will not put an H in front of that, but would that approach, which you suggested is working in Shetland, lead to more designation and better management? That is the objective of the 30 by 30 target.

Tavish Scott

I am very comfortable with science, data and evidence being behind the policy consideration of more marine designations. If I may say so, HPMAs fell down because those who were promoting them could not say what the evidence behind them was. I know that you will disagree with that, but I think that some of us argued that very strongly, and the Government accepted that argument.

My plea to you is not to try to do HPMAs by the back door. If you are going to be up front about having more designations, you should say what will be allowed and what will not. As we know, the big challenge with HPMAs was that nothing was going to happen in those areas. Not unsurprisingly, people such as me, who have lived in Shetland all their lives, are never going to accept that as a mechanism. To win your argument, you have to put data, evidence and science behind it. That is a fair way in which to proceed.

Elspeth Macdonald

In relation to the 30 by 30 target and marine protected areas, we are already there with the designations. We have 37 per cent of Scotland’s seas designated as MPAs. However, as others have said—I completely agree with them—the management measures are not yet in place for the majority of those sites. That process has been delayed for both the inshore sites and the offshore ones. The Government has set out its intended timescales for them, but we know that they are behind schedule. However, we are fully committed to engaging with the process. We have been engaged with it from the outset and we will continue to be so. The key challenge is to find the right management measures that strike the right balance between protecting sites, conservation and nature and allowing sustainable use. That harks back to the point that Tavish Scott made.

There is a step before the question of where the targets should sit, and it involves thinking really hard about what targets should be set and how. We have concerns about the setting of statutory, quantitative targets in an area where, for all the reasons that we have discussed, we have data, but not comprehensive data. We know that there will be issues around resources to monitor and check compliance with targets. We have to be cautious about that and think about other indicators.

On fisheries specifically, we now have a legal obligation to deliver on the fisheries management plans requirements of the Fisheries Act 2020, and those plans have to balance a number of different objectives, of which the protection of the marine environment, species and habitats is absolutely one. There are layers in which those will sit.

Calum Duncan

I agree with Phil Taylor that the national marine plan has to be the overarching framework. The biodiversity strategy should be the thread that runs through all sectoral strategies, because it underpins sustainable work and activity. To achieve 30 by 30, we need to have the measures in place, given that much of the network is currently paper parks. We have worked closely with the SFF and others on the measures. We might have to agree to disagree, but it has been a constructive process. To put the matter in perspective, I note that only 0.6 per cent of the inshore area that has historically been trawled is protected within the existing MPA network, so there is a long way to go to get the measures in place for the existing network.

I note that the Convention on Biological Diversity recommends a balance within the MPA network between sites where all extractive activities are prohibited in order to ensure nature resilience and recovery and those sites where sustainable use is permitted.

It is really unfortunate how the HPMA process went. For me, it is almost a framing issue. If you say, “Can we work with you?” to local communities in places that may be less important or places that you want to see enhanced and recovered, international science shows us that you can increase the amount of sea life in those areas by five times. You can say, “Let’s plan this and think about where it could go, as that could help your local fishery.” That is a positive thing. We must not view these things as being draconian or as things that will shut activity down. Rather, it is the opposite. That approach still needs to be part of the conversations and discussions. The science is there and it shows the benefits of those kinds of areas. I will leave it to others to judge whether that was communicated as part of the consultation.

Dr Cavers

I, too, support the overarching application of the national marine plan. However, we need to ensure that there are enough resources for local planning authorities to assess the impacts of things such as aquaculture applications. On paper, we have a lot of protected areas, but how effective are they? The Firth of Forth is one of the most highly polluted areas in the world as far as plastic pellet production goes, and one of the worst areas is the site of special scientific interest in South Queensferry. We have the protected areas, but they are not enough. We need more.

Mark Ruskell

Thank you for your answers. I have one more question. I will put it to specific panel members, as time is marching on. We have touched on this but, thinking about the 30 by 30 target, nature restoration and ecological restoration in our seas, what are your thoughts on the current approach to fisheries management? Is it delivering on the objectives? What needs to change? I will bring in Phil Taylor, Elspeth Macdonald and then Calum Duncan.

Phil Taylor

I do not believe that it is. That is backed up by, in particular, Scotland’s marine assessment, which concluded that fisheries are the main and most widespread pressure on the marine environment. Their impacts include the removal of non-target species through bycatch, much of which is discarded and much of which includes juvenile fish, and surface abrasion, which is a technical way of describing the impact of dragging a net or a dredge across the sea floor.

The way to address that is to ensure that the biodiversity strategy and the thinking around it are integrated into fisheries’ decision making. We have talked about the national marine plan, and I mentioned in passing our legal challenge to the Scottish Government, in which we argued that it must take account of the national marine plan when it makes fisheries licensing decisions. The Scottish Government—I am straw-manning somewhat, but bear with me—argued that it does not have to do that in those licensing decisions specifically. The judges decided in our favour in that case, but it is going through an appeals process. That is a good example of how things are siloised.

The places that we are talking about are really fragile, beautiful places. I would entreat committee members, if they wish, to come out and see them with us in the summer using our underwater drones. They are really beautiful, wild places that are very important for the functioning of the ecosystem. They act as nursery habitats or spawning grounds and they need to be protected. The MPAs and the priority marine features review—as well as the additional delivery plan actions, such as the protection of spawning and nursery grounds, which I would have mentioned if I had responded to Mr Doris’s question—represent real opportunities within the policy to start to deliver protection for the ecosystems and then recover the ecosystem above.

That recovery will be fundamental to places such as the inshore west coast of Scotland, where, as committee members will be aware, much of the ecosystem is somewhat degraded. Rather than being a vibrant, colourful place, it is a brown, flat substrate underneath a grey sea.


Progress has been made on opening up some of the dialogue on the subject and ensuring that biodiversity is considered in fisheries decisions. As Calum Duncan mentioned, he and I have been involved in MPA management for a long time. In 2015, for example, we were involved in a workshop with fisheries stakeholders, including active skippers, to discuss management in a very specific way. That involved looking at the map and saying, “This area is protected and that area is not. How does all of this work out?” That was really detailed but very productive work, in some ways. We came to some agreements and we had to make concessions. A lot of progress was made. However, I was saddened that none of that was implemented following the meeting. It was all taken off the table into back rooms and it was lobbied against.

That is where some of this stuff is falling down. I say to Mr Doris that I do not want to make this a process point, but that is an example of where some of the process issues around the outcomes that we all want need to be better scrutinised and challenged by Parliament.

Thank you. Elspeth—

The Convener

I am sorry to interrupt, Mark, but I am always nervous when we talk about live court cases. I caution everyone that this is not a place to air opinions on either side. We have mentioned it. I would rather that we now move sideways from it and let it take its course through the natural procedures.

Yes. I ask Elspeth to respond to my question.

Elspeth Macdonald

The Scottish Government has an extensive programme of activities around fisheries management, some of which we have touched on. There is the future of fisheries management strategy, which dates back to about 2019 or 2020, and we now have the UK Fisheries Act 2020 and the FMPs that have to come from that—at least 20 have to be in place by the end of next year. There is a lot of policy development under way. For example, the future catching policy will play a critical part in addressing some of the things that Phil Taylor touched on, although he perhaps rather oversimplified the complexity of some of them.

However, we have a real challenge. We have moved from a space where we were able to have constructive discussion, look at proper, practical problem solving and find constructive ways forward into a space where there are, perhaps, too many barriers to practical problem solving and finding ways to do our fisheries management better.

Our industry is committed to good fisheries management. Our future success depends on it. This year, we have been heartened to see a suite of scientific advice from ICES on many of our commercial stocks that is really positive. We have been able to allocate a catch of cod on the west coast for the first time in a number of years. There are some really positive things there. The Scottish Government has a pretty extensive ambition for fisheries management, but the current model of going about that is not helping us to find solutions.

Fundamentally, though, do your members see the need for restoration in the inshore?

Elspeth Macdonald

The strategic environmental assessment was interesting on that. It talked a lot about restoration and regeneration and it tended to come down more on the side of regeneration than on trying to restore something where, due to the climate or whatever, conditions have changed in such a way that we cannot restore it to the conditions of the past. Also, where do you decide the past was? What are you restoring it to? Is it the condition 10 years, 20 years, 100 years, 200 years or 1,000 years ago? How do you decide that? There are probably specific cases where restoration may be a good idea and may be possible. Oyster beds may be an example.

What about regeneration? Do your members support regeneration in the inshore? Is a cap part of that?

Elspeth Macdonald

We have not yet seen any proposals on a cap from Government. The idea of an inshore cap came from the Bute house agreement, but no details have seen the light of day. Until we see the detail on what the Government is thinking on that, it is hard to have a view on it.

You would like to see the detail on that.

Elspeth Macdonald

We certainly support a much more mixed fisheries economy. We think that complete fleet segregation on the basis of geographic limits is an oversimplified approach and that use of the inshore marine protected areas is a much better one. That involves saying to people, “If you have habitats, species or features in your inshore waters that need to be protected, use the MPA network to do it.” That is the process that we all have been part of, albeit that it has been going extremely slowly, and we should allow it to run its course. We should allow the review of the process that is properly built into it to run its course and tell us whether there is still a problem. Is there a problem that we are trying to fix? If so, what is the way to go about that?

Calum, do you want to comment?

Calum Duncan

Excuse me for front loading some of my comments on this subject earlier. I would not have done so if I had known that the question would be asked.

You can keep your answer to this one brief, then. [Laughter.]

Calum Duncan

We run the good fish guide. We assess over 600 stocks and species, and we want as many of them as possible to be green rated. We support sustainable fishing. We recognise that industry will work within the framework and that artefacts can arise from that if the framework is flawed. If there is an unknown, it can create fear and uncertainty, so we have long called for clarity on the spatial management of fishing. The MPA process was productive because there were discussions about discrete bits of sea and how the space is used. I have long said that we need to have that discussion on fisheries, in chunks, for the whole of Scotland’s seas, and that is particularly keenly needed for the inshore.

Going back to Mr Doris’s point, I note that the part that is missing from the biodiversity strategy is a part that we support: the second half of the inshore cap, which would be a ceiling from which to reduce pressure on an evidenced basis. However, all stakeholders would need to be included in a transparent discussion about that so that everyone felt part of the decision. With respect, it is not just about getting the important areas protected and recovered; it is about managing the conflicts in the industry better, and that is particularly the case for the inshore.

In the detailed written evidence that we provided to the committee on the petition on the inshore limit, we said that, if they were implemented well, the range of commitments—some of which are in the biodiversity strategy—could take us towards a low-impact zone inshore. The national marine plan will be key. Within that, general policy 9 needs to survive and to be a thread that runs through everything.

That was a useful exploration of implementation. I do not think that I have time to go into aquaculture, convener, so I will leave that to you.

There is an assumption.

Clare, do you want to say anything?

Dr Cavers

I do not have any particular knowledge of fisheries; that is not my area of expertise. On regeneration and restoration, there is a real lack of attention to additional pressures. We tend to look at degenerated areas, and there seems to be an assumption that regeneration of those will suffice, but there are constant increases in chemical and plastic pollution, so we need to look at the wider picture, especially the source-to-sea network. I appreciate that, today, we are looking at the marine aspect, but I welcome the fact that the plan talks about that to a certain extent and refers to NatureScot’s “Source to Sea” document.

Climate change is a factor as well—

Dr Cavers


—in relation to the wider ecological health of our oceans.

Thank you, Mark. Monica Lennon has a couple of questions.

Monica Lennon (Central Scotland) (Lab)

I do. I will pick up on funding, as well as investment and resources, which have been mentioned already. Before that, I was concerned to hear Tavish Scott say that it was a struggle to keep up with Government invitations, attend meetings and respond to consultations. We will reflect on that, and I am sure that the Government will, too. It is important that all stakeholders have capacity.

What is even more worrying for me is that the broadcaster and RSPCA president, Chris Packham, made a big intervention yesterday, calling for, in his words, the halt of the “catastrophic” expansion of Scottish salmon farms, saying that a moratorium was needed as mortality rates jump. We have heard a lot about the importance of data and evidence and I am keen to get a better understanding, but we are reading in the press that salmon mortality in Scotland has hit record levels this year, which is catastrophic for fish welfare and Scotland’s environment. Is Chris Packham wrong, Mr Scott, or does he have a point?

Tavish Scott

Mr Packham is a well-known opponent of our sector and has been for a long time. He has trotted out his usual arguments. We have invited him many times to visit our farms, meet any of our people and discuss any of the issues. He has never taken us up on that opportunity. If you wish to come, I extend the invitation in front of the convener this morning. Please, do not necessarily read The Guardian, but come and listen to fish farmers, who will describe what they do and answer all the questions that you wish to pose in that area.

Is mortality an issue? Yes, it is. Do we need to tackle it in an ever-greater way? Yes, and we are. Are we determined to do that? Absolutely, and millions of pounds of investment is going into that. The fundamentals to mortality this year and last year have been warmer seas. We have had an El Niño effect and we have had to confront challenges in our marine environment. Much has been learned over the past year. We are an evidence and data-based sector. That is the only way that we can successfully develop our businesses. That is why we have spent so much time working with scientists, oceanographers and others to ensure that we understand what is happening. The most fundamental issue is that, over the past couple of years, we have seen different types of micro-organism in the marine environment that have not been seen in our waters for a decade or more. As fish farmers, we have to find ways to manage that and put in the correct mitigations, and that is what we are determined to do.

You raise a perfectly fair point in a fair way. I would just suggest that, sometimes, others do not.

Are you taking that up with The Guardian?

Tavish Scott

Not at all. I leave The Guardian to write whatever it wishes; I just read it carefully.

Monica Lennon

Okay. I am sure that we have not heard the last of that, because serious issues have been raised, although we will not get to the bottom of them today. However, we have heard many calls for better regulation and better enforcement. That brings me back to resources. In written submissions, many stakeholders raised concerns about the strategy. We have also heard about a big reduction in the budget for bodies such as NatureScot.

I would like to start with Dr Clare Cavers and work along the table: do you have concerns about the resourcing of the strategy, which I like to think of as not just a biodiversity strategy but about Scotland’s nature emergency? Where will the funding come from, or what does the funding need to look like, for it to work effectively?

Dr Cavers

I do not have the solution as to where the funding will come from.

That is perhaps an unfair question ahead of the budget.

Dr Cavers

Yes, slightly. There definitely needs to be more funding. We could, perhaps, look to what happens in other nations where industry supplies some of that funding. We do not oppose industry. As an organisation, we work with industry to try to make sure that it has minimal impact on the environment. We totally accept that industry has to be there, but industry also has to, first, be aware of its limits and impacts and then work to mitigate those impacts. Part of that is extended producer responsibility, and part of it is, potentially, funding mitigating actions.

Going back to your point about aquaculture, the industry itself admits that it has challenges that it needs to address but, at the same time, it wants to expand. Our view is that it should be addressing its challenges and then expanding. That seems to make a bit more sense, otherwise you just seem to be firefighting constantly along the way.


On that point, then, you seem to agree more with Mr Packham, who is calling for a moratorium until we look at the issue with mortality rates.

Dr Cavers

To a certain extent, yes. It does not necessarily mean stifling the industry. The industry, as Tavish Scott said, is very aware of the challenges that it faces. The thing is that it has known about the challenges for a while, and there does not seem to be a real acknowledgement of the fact that climate change is happening and needs to be dealt with. It tends to be used as an excuse. “We’ve had high mortalities this year because of climate change” does not really seem to be an acknowledgement that, “Because the climate is changing, perhaps we should move our farms and do things slightly differently.” Action and innovation are happening, but legislation and regulation could support and push that a little bit. SEPA’s sea lice risk assessment framework is doing that to a certain extent, but these things have been a long time coming.

Monica Lennon

Perhaps panel members can respond to that, but first, in your written submission, you stated that

“there should be ‘biodiversity impact’ screening for any recipient of public funds, including in their supply chains.”

Why is that important?

Dr Cavers

That goes to producer responsibility. Every industry will have an impact on the environment in some way. That is not avoidable. You cannot say, for example, that a new road that accesses a site is not going to impact the environment, but that should be assessed and the biodiversity impact should be part of that.

That is helpful. Thank you.

Calum Duncan

Funding is a concern. We wrote to the Deputy First Minister highlighting the 40 per cent real-terms cut for NatureScot and 26 per cent real-terms cut for SEPA. That is a concern. Mainstreaming biodiversity would also include recognising that improved nature helps wellbeing, so there might be innovative ways to use other budgets as well.

The Scottish marine environmental enhancement fund is welcome. It helps to resource projects, often for actively restoring nature, including seagrass beds and native oyster beds. I support what my colleague to my left, Elspeth, said on that. We support oyster restoration and are involved in projects on that, but it is a drop in the ocean. We need to have more of the industries that benefit from a healthy environment contributing to that pot and helping to be even better local stewards to improve nature where they operate.

We are proud to be part of the Dornoch environment enhancement project, where the Glenmorangie whisky company has demonstrated leadership in recognising that it is a local steward of the Dornoch and wants to go further than compliance. We need more industries that benefit from the sea contributing to the SMEEF fund to help support community aspiration for restoration around our coast.

I will not add to what Clare said about aquaculture.

That is great. Thank you. Elspeth?

Elspeth Macdonald

The short answer to your question about whether we are concerned about resources to deliver it is, “Yes, absolutely”. Be in no doubt that what is set out in the delivery plan is a very resource-intensive set of proposals and I come back to the point that I made earlier: that is why it is really important that careful thought is given to what are the right things to do and in what order and that the resources are targeted at the right things in the right way.

We have a concern, and several of us have touched on it. The marine directorate, which is part of the Scottish Government, has been working on a new science strategy. We are yet to see that, but I fully expect that the resources that the directorate will have to deliver the strategy will be stretched increasingly across a broad range of areas, including all the things that we have been talking about today and all the other responsibilities that it has. I have real concerns about the resources to deliver. It is also important that we think about resources in terms of not just money, but skills. To deliver this in the marine environment requires an extensive range of scientific and economic professions and skill sets. We have to make sure that the investment that the Government and society make in education and how we train people and retain and have the right skill sets in Scotland to help us deliver those ambitions is all part of the mix. It is not just about money; it is also about having the right people with the right skills to do those things.

Monica Lennon

One of the suggestions that we got in our written submissions was that the marine directorate should undertake—if I can read my handwriting—

“a strategic review of its enforcement assets”.

That is looking at equipment as well. The point being made was that we need to have effective deterrence of illegal activities. Is there a concern about equipment?

Elspeth Macdonald

Increasingly, enforcement bodies across different sectors, not just ours, use intelligence-led approaches. They cannot be out there looking at everybody all the time. They use intelligence to identify where there may be problems and then target the resources that they have on those problems. As we have talked about, in the marine environment, everything is a bit different because you cannot see under the sea particularly easily. The compliance part of the marine directorate has vessels, access to aerial surveillance and the use of data from different sources. Again, it is about looking at the skill set that you need, the information that you need and how you are best resourced to deliver that.

Thank you. Tavish?

Tavish Scott

First, I will gently push back on the suggestion that we, as a sector, have not embraced the challenge of climate change. That is why we have a sustainability charter. That is why we are committed to net zero by 2045 in line with your aspirations as a Parliament and a Government. I do not accept the remark that was made by one of your witnesses earlier.

You asked a really good question about regulation. We pay for all our regulation. It is full cost recovery, which I accept; that is as it should be. Business should pay the cost of regulation. We pay all our SEPA charges and local planning charges, and we pay other regulators that we take a service from. Our argument is not for less regulation; it is for better, more streamlined regulation. That is why Professor Russel Griggs reported to the cabinet secretary a year and a half ago on exactly that. We applaud that direction of travel. We never fear more regulation. Regulation can be an asset for business. Good regulation allows business to sell its product into the marketplace with confidence because it is properly regulated. I absolutely accept the role of good regulation in Scotland. We in Scotland are more regulated than any other salmon sector anywhere in the world. I do not want you to go away from today thinking that we are not regulated at all or that it is light regulation; the reverse is the case. I will be crystal clear on your very fair point about resources: we pay for our regulation.

Phil Taylor

I agree with the point that has been made by many: a lot of the delivery plan will require additional action or action that will incur costs and the Government bodies that will be responsible for some of it are slim on resources. There is an opportunity to use some of the existing funds—Calum Duncan mentioned SMEEF, which is one of the world’s worst acronyms, and there is also the nature restoration fund and the marine fund Scotland—to incentivise and drive change better than it is currently being done. Last year, marine fund Scotland paid a huge amount to put solar panels on a fish processing facility in Peterhead and bought boats in fleets that were arguably over capacity, thereby adding to the problems rather than addressing them and driving some of that change.

With the nature restoration fund, there needs to be a slight adaptation of what its current remit allows it to fund. A lot of what we need to do to restore the marine environment is to better regulate impact, rather than taking progressive additional steps. Those additional steps include great projects, such as seagrass restoration and oyster restoration, but those will not address the overarching problem, which is that we still have declining health outwith that very near shore area. I suggest that thought should be given to how those funds can be used to better incentivise change.

Monica Lennon spoke about compliance. The key aspect of compliance that has been agreed by everybody, including Marine Scotland’s science teams, is remote electronic monitoring, which is the monitoring of what is caught and where. That will then feed right into the understanding of where the juvenile grounds are. That will not be a massive cost, but there is a bit of a cost, which will come on businesses. There is an opportunity to ensure that some of those funds, which have already been committed to—the spend is already there in budgets, so you do not need to ask finance ministers for brand-new pots of money—are adapted and opened up so that they can be made more relevant to what is, in effect, marine nature restoration and responding to the nature emergency.

We have spoken a lot about delay, consultation and things that were said to have been delivered but have not. Every year that those delays happen, more money is spent on that project. It feels like there is a bottleneck of all the policies coming together at one point, but a lot of that is simply policies that were due to be delivered a long time ago and are repeatedly being shunted. If we end up getting towards 2030 without having delivered our biodiversity nature emergency plan, we will have 20, 30, 40 or 50 policies that need to be implemented in a oner. There will be huge stress on Government and officials and it will cost a lot more money. Get on and deliver the commitments that have already been made. That is, in itself, a cost-saving exercise.

Thank you. I will hand back to the convener. I am conscious of time so I will keep my questions to myself for now.

The Convener

Thank you very much. That is kind. I will move to the two members who have joined the committee for the day. Would you like to come in now or after them, deputy convener? Whatever suits you; I do not want to upset you.

Ben Macpherson (Edinburgh Northern and Leith) (SNP)

I have a quick question about the points that Dr Cavers raised earlier, and they will also relate to Mr Duncan. When I do beach cleans in my constituency, not too far from here at Wardie bay, for example, the prevailing issue over and above human litter and pollution is nurdles. Dr Cavers, you mentioned the prevalence of plastic pellets on the beaches of South Queensferry. In our considerations today and also, if relevant, in our considerations on the Circular Economy (Scotland) Bill, would either of you like to add anything further about pollution from plastic pellets, otherwise known as nurdles? What is the situation, and what can and should we do about it?

Dr Cavers

I can definitely answer that, and I thank you for the opportunity to do so. As we said earlier, no organisation is directly responsible for dealing with that issue. We saw gaps in the regulation of aquaculture regulation and wild salmon, and it is the same at the moment with nurdle pollution in Scotland. In England, the Environment Agency has approached companies that it has identified as sources of plastic pellet pollution. No organisation in Scotland has responsibility for doing that at the moment, and there is no mechanism for putting such responsibility in place. That could be applied to responsibility for all sorts of sources of plastic and chemical pollution. It is therefore one of the main things to do as we move forward. Responsibility for monitoring and regulation should lie with an organisation.

Have you anything to add, Mr Duncan?

Calum Duncan

Yes, but first, thank you for helping out at Wardie. There is a great community there, and it is to be commended for all the hard work that it does.


Calum Duncan

The Circular Economy (Scotland) Bill is really important for us. We need the economy to be circular so that plastic does not leak into the ocean. That runs through everything that we are doing, and I endorse everything that Dr Cavers has said. Any policy, law or strategy that is implemented has to bear in mind and enact the principle that Dr Cavers mentioned and that is in now in the UK Withdrawal from the European Union (Continuity) (Scotland) Act 2021. That principle is:

“environmental damage should … be rectified at source.”

If we are turning off the tap at source, such items are not getting in the sea. If nurdles are getting in the sea, the people who are making them are not handling them properly. I have been involved with the issue for a couple of decades. I was finding nurdles on Cramond 20 years ago. We had tours of places that make them. If they are still getting in the sea and are fresh, the situation is not working, so ask the people who are making them.


Thank you for that feedback and information. Does either of you see the Circular Economy (Scotland) Bill making a difference in that regard?

Dr Cavers

Definitely. We welcome the Circular Economy (Scotland) Bill. We advise caution around the circular economy, because there is a tendency to focus just on recycling in the physical sense, whereas we must be aware of chemicals. If products and materials with hazardous chemicals in them are being recycled, they are just being kept in circulation. We therefore need robust chemical regulation to go alongside our recycling, and that also applies to things such as compostable substances.

Is there anything more that we can and should do legislatively on plastic pellets specifically, or is the Government required to act here in other ways?

Dr Cavers

Strong legislation is coming out of Europe, and Scotland has ambitions to mirror that. Europe recently passed quite good microplastics legislation. We are going in the right direction, and, as I said, we welcome the reference to plastic pellets in the biodiversity strategy. To bear in mind the impacts on small and medium-sized enterprises probably comes under the socioeconomic considerations that we heard about previously. There is also the matter of support for moving into some of those systems. If we ask businesses to change their practices, we need to ensure that just transition processes are in place to help them to make those changes.

Thank you. Briefly, Mr Duncan.

Calum Duncan

I am happy to come back to you on that.

If you would write to the committee, that would be helpful. Thank you.

Mark Ruskell wants to come in. Unfortunately, Phil Taylor has had to leave for another appointment. There is an empty chair there. He has not been empty-chaired; he had to leave.

Mark Ruskell

We have not chased him off.

I want to go back to the deputy’s convener’s point about a just transition. The committee spends a lot of time thinking about what a just transition will look like for the energy sector. We have also considered how a just transition is embedded in the Climate Change (Scotland) Act 2009. Is it important to embed those principles in this approach? Perhaps we could ask our sector representatives whether there was, say, a transition when inshore fisheries moved away from scallop dredging. Could other economic opportunities arise from that? Is it important that a just transition approach is applied to that? To take salmon farming as an example, in the future, might there be the retiral of open-pen salmon farms, if you can imagine that, and a move towards other technologies? How do you take workers and sectors with you?

Tavish Scott

I am interested in that word that you politicians use: “just”. You need to explain to the 12,000 workers in our sector how just would that be for their futures. We employ people who otherwise would not have a job in lots of parts of Scotland where there is not much employment, with an average salary of £36,000. I am very proud of that. It goes all the way up the west coast to the islands where I live and everywhere else.

With respect, you say in broad terms that you could close down open-net farming, but that would close the industry down in Scotland. Be really clear that you have just suggested would close the industry down in Scotland. You will forgive me, but I will not agree with you on that. First, the technology is not there. Secondly, it has not worked at scale anywhere in the world. Thirdly, the science, data and evidence are not there. Fourthly, the energy costs of what you have just suggested, which is onshore farming, are enormous. When those of you who make that kind of argument think about it, you need also to think about the other side of the equation, not just the one that has possibly been pitched to you by those who make that case.

Mark Ruskell

Perhaps, you are jumping on that as one potential way forward. The whole point of a just transition is that it is led by workers and people in those sectors, so they come up with the solutions, whether it be for sea lice or biodiversity impact, and they use their technical innovation skills to do that.

I do not know what the solutions are for your sector—I do not work in that area—but is there something about the principle of asking, because we have strict biodiversity targets and we need to move forward, how we involve sectors in that change? How do we deliver the change that, I think, you acknowledge needs to happen? It is the same for fisheries as it is for the energy sector. How can such change be driven by the sectors themselves in a way that is just, rather than them just saying, “We do not want the change”?

Tavish Scott

We have changed enormously in the past 10, 20 and 30 years, Mr Ruskell. I will not accept that we sit in aspic and nothing changes. The industry that I knew in Shetland in the 1980s is chalk and cheese compared with where we are today. Again, I am very proud of that. The difference is enormous. You are welcome at any time to visit us and see that change. I am always disappointed that some parliamentarians do not take up our invitation to come and learn, listen and talk to people. You do not need to take my word for it, you can come and talk to scientists and the people who run the businesses and see for yourselves.

You make a good point, Mr Ruskell. If the Scottish Government would give us the regulatory ability to innovate and trial in deeper water areas, for example, you might be on to something, but there are regulatory restrictions. Someone mentioned that we could simply move to other sites, but we can do that only with regulatory approval. If we had a regulatory system such as that which they have in Norway that encourages innovation and that would allow us to do that, we would make the investment—I do not ask you or the public sector to do that; we would make the investment—but, to do that and trial some of the innovations that we would like to, we need regulatory approval. I simply suggest that that is the gap at the moment.

Elspeth Macdonald, do you want to react to my comment? I should say that, a number of years ago, I spoke to a scallop dredger who was interested in making a transition, but to what I would not want to suggest.

Elspeth Macdonald

It is important to remember that the fishing industry, like the salmon farming industry, is innovative and is always looking at how to move forward, what we can do better, what we can do differently, how we can reduce our emissions and how we can reduce our impact. For example, work is being done in universities in Scotland on different types of gear for catching scallops that will have less impact. People in the industry are always looking for better and more efficient ways of doing things and lessening their impact.

We have a new vessel in the prawn fleet in Fraserburgh that was launched earlier this year. The business that runs the vessel spent more money to make modifications in the design and the propulsion of the vessel so that it burns less fuel and has lower emissions. Despite the fact that it cost more to make those modifications, the business sees that as the way forward. That is showing leadership in the industry, and I fully expect others to follow that lead, because they can see the benefits that it will bring.

In all this, we must never lose sight of the fact that Tavish Scott’s industry and my industry produces food. There is a growing global demand for seafood, and we have a growing population. Seafood plays a critically important part in feeding people in Scotland and around the world. If you reduce, limit or constrain how much food we can sustainably produce from the sea, that food will have to be produced from somewhere else, quite likely with higher impacts. Seafood compares extremely favourably with other foodstuffs on its carbon and other environmental impacts. Suggesting that there might be a transition away from food production—I know that that is not exactly what you were suggesting—

No, it is not.

Elspeth Macdonald

A just transition for the oil and gas industry, for example, is a very different proposition from a just transition in food production.

Thanks for those reflections.

Mark, we are quite tight for time, and I would like to give Finlay Carson and Rhoda Grant two questions each but not to every member of the panel. That is just to be clear, Mr Carson.

Finlay Carson (Galloway and West Dumfries) (Con)

Thank you, convener. First, I should probably declare an interest as a species champion for the native oyster bed. I am in the unique position of being a species champion who can actually eat the species that he is trying to protect, and I enjoy the odd one, I must admit. This morning, we have heard about crowded seas and marine spatial squeeze. We are now seeing a policy squeeze, with crowded ministerial responsibilities. One reason why I am here today is that there is still a fluffy idea of who takes responsibility.

We have discussed marine issues in our committee, particularly the lack of fit-for-purpose data. How much is actually collected properly, and how much is modelled? That is a concern. We saw clearly from the Bute house agreement-driven Clyde cod box debacle, that embarrassing situation in which Marine Scotland officers tried to defend inadequate data in order to change policy, that there are issues there. From the rural affairs point of view, we understand that creating a biodiversity-positive marine environment is of critical importance, but we cannot forget the socioeconomic impact of policies; that is equally important. Arguments are often made without touching on the positive or negative aspects of socioeconomic impact, because they sometimes just do not fit the narrative of the groups or organisations that are trying to promote a particular point of view.

In agriculture, rural land use partnerships bring all the stakeholders together and are supposed to look at landscape-scale policies and the impact that they have across the board. I was surprised that no one touched on regional inshore fisheries groups, which are supposed to be the groups in which fishermen and stakeholders can give their input and comment on policies. Does that suggest that the Government is not serious about engaging with the fishing industry through those regional inshore groups? As far as I can see, they are inadequately funded and not really fit for purpose. Could I have your comments specifically on whether regional inshore fisheries groups have a role in ensuring that we can have a biodiversity plan that works for biodiversity and for fishing communities?

Elspeth Macdonald

Perhaps I will come in first on that one. The regional inshore fisheries groups are a good idea, but they are not particularly well resourced to get greatest value from them. Their purpose should be to engage with people at the sharp end of the industry, such as those who are involved, those who are impacted by policies and those who, as Mr Ruskell has just suggested, might indeed have good ideas and good suggestions for ways in which the industry can bring ideas to the Government’s table. During the past year or so, the Scottish Government has rearranged the inshore fishery groups a little and appointed a new set of chairs—I think that there are six of them now—and the intention is to review their effectiveness at some point next year. However, they could work a lot better and there is real opportunity there, but they need to be resourced. It is important that my members and those in the industry see value and a purpose in attending these things. They have to see some benefit, some change or something that is actually being delivered, because these are busy folk, particularly in the inshore fleet. They are often running small businesses and do not have a lot of spare time to go along to a talking shop, so it has to be meaningful and has to deliver something.

I will bring Calum Duncan in, and then I will push you for your second question. You gave quite a long statement.

Calum Duncan

Thanks for championing the native oyster.

Inshore fisheries groups are important. It is absolutely critical that local fishers have a voice in a forum to formulate what they would like to see as policy and management. As I said to the Rural Affairs and Islands Committee, my concern with Scotland is about how inshore fisheries management integrates with other inshore activities, because we still do not have our regional marine plans. I have seen this play out in real time while representing Scottish Environment LINK in the Clyde marine planning partnership, for example, and it is quite challenging to get integration. We look, with a certain amount of envy, to the Inshore Fisheries and Conservation Authorities—IFCAs—in England, because they have regional statutory bodies where conservation and fisheries management are integrated. A lot of the challenges, particularly with inshore in Scotland, arise because there is not that integration and because conversations about the same sea space are happening in different forums. IFGs have a role, but the inshore governance needs to be improved to better integrate the fisheries management with the conservation and also to hear other voices. The IFCAs have boards, and other stakeholders are on those boards, as I have submitted in evidence previously.


Finlay Carson

The delivery plan does not appear to be costed, and you have touched on an equivalent of a financial memorandum. However, it is very ambitious. It is a bit like the Agriculture and Rural Communities (Scotland) Bill in that it is very ambitious, there are no boundaries to it and we do not know how much it will cost. Do we need to be more pragmatic going forward? Ambition is good, but not if you cannot deliver on your ambitions and if there are targets that cannot possibly be met. There is an argument that climate change targets are far too ambitious and that we need to be more pragmatic. Does this plan need to be more pragmatic to deliver effectively?

I will go to Tavish Scott because Elspeth Macdonald answered the last question. Clare Cavers can then come in, if she wants.

Tavish Scott

Mr Carson makes a really good point. Businesses would like clarity, and clarity comes with good definitions and good targets. In fairness to Phil Taylor, he mentioned SMART targets, and I entirely endorse that. That is the right thing to do, and I hope that Parliament will fully scrutinise the nature of exactly that.

I remember that, back in the day, ministers were not hitting statutory climate change targets, but I do not remember anybody losing their job over it. I think that Parliament will want to take a view about that “So what?” If it is to mean something, and Parliament wants business to go with it, the points that Elspeth Macdonald and I have been seeking to put forward about good regulatory assessments are important. We will go with it as long as you show the benefits of it. We will be absolutely with you all the way on that. Yes, I am for making it real to people because it would make my other colleagues’ jobs easier if we could actually understand what we are all trying to achieve. At the moment, it seems all up in the aie.

Dr Cavers

I fully agree with everyone who has talked about SMART targets. There should be more definitive timelines and responsibilities. As I have previously stated, if you are attributing responsibility to organisations and sectors, you will hold people accountable and they will have targets that they have to meet, and, presumably, if they do not meet their targets, there will be consequences for them.

Rhoda Grant (Highlands and Islands) (Lab)

My questions are on the same theme, so I will not introduce them. I was interested to hear about the lack of a socioeconomic impact assessment. We are all committed to a just transition. Can we have one without the other? If you do not know the impact of what you are doing, how can you transition?

Tavish Scott

I agree with that, if that is helpful. I do not have a lot to add, because we have probably done that issue to death. Ms Grant has made a really good point.

There could be a yes or no answer.

Tavish Scott


Elspeth Macdonald

I agree.

Calum Duncan

I agree, but I emphasise what Phil Taylor said. A lot of the policies have an SEIA process as well, so it is not the case that that would not be a part of the process.

Dr Cavers

I agree, of course. There are also actions, such as pollution prevention and monitoring, that do not necessarily have a socioeconomic impact directly. We could do more of that.

Rhoda Grant

Okay. Thank you.

We seem to have focused on fishing and fish farming today, but a lot more is going on in the marine environment. We hear more about a squeeze on fishing and things such as offshore energy. Should we look at those? I am sorry: I am asking two questions in one.

You will get only one answer.

Rhoda Grant

We have also heard about how complex the consultation is. How do we engage stakeholders? What went really wrong with the HPMA process was that it was top down. It imposed things that people largely did not understand or know enough about. There was a huge lump of policy, and nobody disaggregated it and spoke to people about the impact on them. How do we avoid that? This seems to be just the same: it is a big, top-down exercise that does not involve the people on whom it will impact. I fear that it will get the same reaction, given that there is a huge amount of distrust out there.

Tavish Scott

Yes to the first question. Elspeth Macdonald and I would very happily discuss marine spatial squeeze and Parliament’s interest in that. The approach has to be local to do it effectively in areas such as the Clyde. That links to Mr Carson’s point about the right structure in order to achieve the objective.

Those discussions are absolutely needed. We work with kelp businesses, for example. There is a growing seaweed industry in Scotland, and we very much welcome that. I accept and recognise that that may be a bit of a challenge for some of Elspeth Macdonald’s colleagues in the inshore sector, but there is huge potential for us in the biodiversity space in working with kelp businesses. That is very compatible with salmon farming. Good things can happen in that space.

However, the discussion is complex, and the right forum has to be local. You cannot do those things at the national level. They have to be structured in a way that allows the local players to be involved and to make effective and good decisions that are based on good science and data.

I am afraid that that drags us right back to the point about the investment by Government and industry in science that Mr Carson and others have highlighted. That is where we can all coalesce to help us to make sensible decisions.

Does Calum Duncan agree?

Calum Duncan

Absolutely. Having conversations with local people in the room to get their knowledge is absolutely fundamental. There is a lot of information that can inform those discussions. Once that is there and people are looking at maps, they can have respectful agreements and disagreements. If they all know what the purpose is, at least those discussions can be convivial and productive.

An investment of time and resource is required to do that effectively. I know that successful work has been done on that in the common ground work on deer management. People with different views have come together. We absolutely support that. That is also why we support regional marine planning and the integration of fisheries management into regional marine planning. However, that has been delayed, as well. We need to have spaces to have those conversations, and we absolutely respect that local stakeholders know their environment.

The Convener

Okay. I am afraid that we are at our time limit, Rhoda.

I will ask a final question, which will require a yes or no answer and one sentence. You will all get a chance to answer it.

My problem is that what I have heard this morning is that there needs to be a balance between nature, environment and jobs, and that is absolutely critical. However, we have some dichotomies. For example, are there unseen effects on other species from electro-fishing for razor clams? Do we know what that truly means? Is there habitat destruction from dredging, and is a huge length of time required to recover from that?

I am not going to pass comment on aquaculture, except to say that the Rural Economy and Connectivity Committee report was apposite in 2018 and it remains apposite today. However, there are potential conflicts there between wild salmon and other crustaceans.

When it comes to renewables, that balance may affect demersal fisheries, and it may affect the chopping up of seabirds that are suffering from avian flu. Should we be taking steps to stop the sand eel fishery and ensure that seabirds have enough food? What damage is plastic waste doing to our flora and fauna?

We all want to be good neighbours, but we are all competing for the same space. Is it possible to be good neighbours and to develop everything that the Government wants—yes or no? What is the one thing that each of you needs to do to make sure that that happens?

Does Tavish Scott want to start off on that?

Tavish Scott

Yes, it is possible to be good neighbours. I absolutely agree with you on that, convener. The one thing that the sector needs to do is to continue to invest in science. Forgive me for being boring on this, but I cannot emphasise enough how much we as a sector depend on science. I believe that the Government needs that, too. If you were to give me only one thing, that would be it.

That was a long sentence.

Elspeth Macdonald

Yes, I think that we can be good neighbours, but whether we can deliver all that the Government wants remains to be seen. One of the challenges to that is that we need to educate people better about the complexity of what we are trying to do. That is something that we all need to do better. I apologise: this is a very long sentence. We need to educate people in general about the fact that these are not simple things to fix. The issues are really complex, and they cannot be fixed by simple slogans and solutions.

Calum Duncan

Yes. We need to better make the case for why protecting and recovering nature is good for people. We need to continue and increase the conversations about the whole policy area and about how good nature interacts with and benefits local people.

Dr Cavers

Yes, I agree with that, too. Industries involve people, who have lives and lifestyles. We want to see better potential collaboration between industry and different sectors, such as ours, as well as compromise and transparency.

The Convener

Okay. I am walking away with four yeses, which is probably as positive as I can get.

Thank you very much for sharing your expertise with us this morning.

On 9 January, we will take evidence from a panel of experts on terrestrial biodiversity. We will then write a letter to the Scottish Government to input our views on the draft plan before it is finalised. We look forward to sharing that with you.

We will now move into private session.

11:25 Meeting continued in private until 13:10.