Environment, Climate Change and Land Reform Committee

Meeting date: Tuesday, March 27, 2018

Official Report 527KB pdf

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Scottish Crown Estate Bill: Stage 1

The third agenda item is to take evidence on the Scottish Crown Estate Bill at stage 1. We will focus on stakeholders who are directly affected by the management of Crown Estate assets.

I welcome Patricia Hawthorn from Scottish Renewables, David Sandison from the Scottish Salmon Producers Organisation, Mark Simmonds from the British Ports Association and Dr Alan Wells of Fisheries Management Scotland. Good morning to you all. We move straight to questions.

Good morning, and thank you for coming.

I note the diverse range of backgrounds from which you come. What are your experiences of the Crown Estate and Crown Estate Scotland (Interim Management)? In your view, what makes for good estate management? Discuss.

We have wide-ranging discussions with the Crown Estate. The Crown Estate owns about 140 salmon fisheries across Scotland. It sits on several of the boards of our member organisations, the district salmon fishery boards. We have a close relationship with it on the management of wild fisheries.

We also work with the Crown Estate on salmon farming, marine renewables and other developments in the marine environment. For example, we are working with the Crown Estate on identifying and assessing methods of monitoring potential impacts on wild fish with regard to Aquaculture Stewardship Council certification for fish farms and the environmental management plans that come through the planning process for salmon farming.

We work with the Crown Estate on marine renewable leases—we have done a lot of work on the potential impact of marine renewables and offshore wind farms on migratory salmon and sea trout.

Good morning. I am here in my capacity as a director of Scottish Renewables, but I am also a partner in the law firm Shepherd and Wedderburn, which acts for a number of offshore developers, both tidal and offshore wind. I am happy to answer questions from both perspectives, although I am primarily here to represent Scottish Renewables.

The engagement that we have with the Crown Estate is largely through its role as a landlord in the offshore sector in relation to offshore wind and marine wave and tidal projects. In anticipation of this committee session, I spoke to a number of our members. The description that the Crown Estate offered up for itself on its involvement with renewables as being a

“landlord, catalyst and supportive partner”

would broadly be echoed by the industry and most of our members.

The relationship is triggered by the lease process, but the Crown Estate has also been influential in bringing forward licensing rounds for the development of projects and in participating in the delivery of the projects. The supportive role has been important and has ranged from participating in consultations to helping to fund and manage enabling works in the early stages of projects.

Broadly, our engagement is through that landlord and tenant context, but the relationship is a bit wider than that.

Do you expect that positive relationship that you have had to continue into the future?

Yes. It has been broadly a positive relationship and an effective and efficient management process.

Likewise, our relationship with the Crown Estate is mainly based on its being a landlord. We have a significant number of sea bed leases around Scotland’s coastline. Our needs and the scale of the sites that we require for our industry to move forward have developed rapidly over many years, and the landlord-tenant relationship has been productive over that time. Indeed, it is the fundamental relationship, and we view the Crown Estate as a body that has supported our development plans over the years.

My association represents the overwhelming majority of ports in Scotland, and most of our members’ engagement with the Crown Estate comes about because the Crown Estate owns most of the sea bed and, in order to carry out and fulfil their statutory duties, our members have to work with it on leases and licences for, say, dredging and maintaining navigable channels. Not all our members have always found that process to be the easiest; it has sometimes been difficult or time consuming, and at times it has added to development costs or caused delays.

In answer to your question about what would be good as far as the management process is concerned, I would say responsiveness; working with the users of the assets; and ensuring that the process remains affordable. Obviously our members cannot move elsewhere, and they will have to work with the manager of the asset.

Are you reflecting the view across the UK of dealings with the Crown Estate, or are you talking specifically about the experience in Scotland? Is there a difference?

We have found the experience across the UK to be quite similar, but I am speaking today on behalf of our Scottish members.

I was just wondering, because I am interested in finding out, as we move to Crown Estate Scotland, whether you are identifying opportunities for things to be done better.

There is definitely an opportunity for things to be done better, but it remains to be seen whether it will be taken.

Have the delays that your members have been confronted with arisen as a result of environmental concerns, local concerns or other concerns, or have they been caused by the process itself?

It is quite often just the process of, say, extending leases or getting licences for certain activities for which, as I said, our members are statutorily responsible.

Thank you.

I want to ask Alan Wells about his perception of the interface between him and the Crown Estate. Has the experience been positive in the past, and will it be positive going forward?

In general, it has been positive, but because we are dealing with the Crown Estate on a range of issues, the experience with regard to each might well be different.

With salmon fishing, we have had a very positive relationship with the Crown Estate, which leases its fishings occasionally to private owners but very often to angling clubs. As I have said, it also participates on the district salmon fishery boards. We are in favour of the management of those fisheries being devolved further, because that will have lots of benefits not so much from an economic perspective but from a wider environmental and social perspective with regard to encouraging access to fishings and getting more people fishing, which is an issue for our sector.

As far as salmon farming is concerned, the Crown Estate takes more of the landlord-type approach that has been highlighted. It is one of a number of elements of the regulatory system, which the committee has previously looked at, and I think that there is a lot of scope for bringing things together and having a much more coherent system of regulation. The Crown Estate has a role to play in that respect, but as far as our interactions are concerned, we have been involved in several projects with it and our experience has always been very positive.

With regard to marine renewables, we were involved in the MeyGen development on the north coast, and the Crown Estate provided some support in getting people around the table for that project. Again, the experience was positive, but one of the things that we would like to see in the bill is a greater emphasis on sustainable development instead of the economic development that has been emphasised in the past.

11:30  

I will turn to the issue of environmental protection—I assure everybody that there was no plan to have Alan Wells set up my question.

Our committee and our predecessor committee have taken a strong interest in mission statements relating environmental protection. Perhaps the bill gives us an opportunity to clarify some of the issues around that.

As you know, the bill says that managers of assets

“must maintain and seek to enhance ... the value of the assets, and ... the income arising from them”,

and that they “may”—I stress the word “may”—do so in a way that contributes to wider objectives, including “environmental wellbeing”.

In their submission, Professor Ross and Professor Reid suggest that the bill could be amended to “require” managers to take into account the considerations that are listed in section 7(2). They also point out that sustainable development

“encompasses environmental, social and economic wellbeing”.

Would it be valuable to change “may” to “is required to”? Do you have any other comments in relation to environmental protection?

This might not be a popular view, but I am not entirely sure that that would be necessary, because you already need to prove that any activity or development that you undertake that has an impact on the environment takes those considerations into account. I am not sure whether the change that you suggest would add an awful lot—it would simply replicate what developers already do.

In relation to the Crown Estate, the point concerns

“the value of the assets, and ... the income arising from them”,

and whether there should be an obligation to take sustainable development and other objectives into account in the business plan and so on. Your comment is fair enough in terms of applications, but there is a broader issue.

Are there any other comments?

I think that it would be a useful addition. Professor Ross and Professor Reid mentioned that there was a similar duty in the Climate Change (Scotland) Act 2009. Also, the Marine (Scotland) Act 2010 says that

“In exercising any function that affects the Scottish marine area ... the Scottish Ministers ... and public authorities must act in the way best calculated to further the achievement of sustainable development”.

The proposal that you mention is consistent with other legislation, and it would be good to see it in the bill.

We would not have any fundamental objection to sustainability being part of any decision-making process, certainly in the renewables context. Looking at the bill, I do not think that that is the purpose of the provision. I think that its purpose is about balance and people’s ability to move away from that value judgment. That is how I read it, in any case, in conjunction with section 11.

I agree with Mark Simmonds that there are other regulatory controls that are focused specifically on sustainability and environmental protection. We have to get all the forms of regulation to sit comfortably with and respect one another, and not all to be looking at the same thing. We would not be fundamentally opposed to the proposal, but I am not convinced that it is necessary.

We hold a similar view on whether the proposal is necessary. We would like as many opportunities as possible to be taken to ensure that there is good alignment with other regulatory regimes, of which there are many in the marine context. There must be alignment with national planning and marine planning, and regard must be given to the fact that there is already significant environmental protection regulation around our activities.

We would like a cohesive bringing together of the planning functions and the Crown Estate in order to make the system beneficial to all. From that point of view, we would not have any particularly strong views about whether the proposal is required.

I do not think that I am making the question clear. The point is about the assets of the Crown Estate. Managers of those assets have a serious responsibility to maintain and seek to enhance

the value of the assets, and ... the income arising from them”.

In the context of responsibilities in reserved areas that will no doubt transfer at the point of devolution, should there be an obligation on the Crown Estate to look at the provision in relation to decisions on assets, rather than regulation? I hope I am being clearer.

You have thrown them.

I will give an example that might help. I mentioned salmon fishings, which are largely in the central belt. They tend to be on rivers that are not necessarily of high value in comparison with other rivers in Scotland. Therefore, trying to get a huge amount of economic benefit from those fisheries might not be the best way to go.

Another route is to look at getting a great deal more social and environmental benefit from those fisheries by getting people to use them, getting people into the outdoors and putting less emphasis on getting an economic benefit from them.

Are there any other comments?

I think that I get where you are going with that question. It is quite interesting—you might be pushing at a slightly open door. I tend to agree with Alan Wells that there is more than just economic value to be accrued from the Crown Estate and that we should be looking at the wider socioeconomics of that relationship. That might be an opening that would allow you to widen things out.

The committee has previously expressed its view, in the context of its salmon inquiry, on the regulatory approach to aquaculture, and we will not revisit that today. However, how might the Crown Estate’s role in the aquaculture consent process change? We have heard the SSPO’s view. What advantages and disadvantages might such a change provide for the industry, for local communities and, perhaps most important, for the marine environment?

As I think that we have said, we can see an opportunity for better alignment in the process of getting a lease and the various permissions that people need to carry out their activity. There needs to be good alignment. I am not saying that there has not been good alignment, but when we bring things into a purely Scottish context and look at how they might be devolved further, there is an opportunity for it to be even better. That would be a great benefit at a time when we are looking at the overall regulatory environment and finding that some regulation has to be reviewed, changed and made to fit better with what the modern industries that use Crown Estate assets would like to see.

I get why that would be helpful for the industry and, one could argue, for local communities, but what about the marine environment? How would it benefit?

I think that, at a regional or community level, we definitely have to have a view about the benefits of environmental protection to the wider community across the wide range of uses of that environment. With respect to enhancing marine spatial planning and regional planning by bringing in the environmental scrutiny that is required for that process and aligning it to the Crown Estate leasing process, we can achieve that.

I will again give a couple of specific examples. I preface them by saying that the issue probably should be looked at in the round, with the other elements.

The fish health framework, on which work is being carried out at the moment, will require the management areas in which salmon farming takes place to be looked at. Those areas could be changed if there was an advantage in having fire breaks—for want of a better way of putting it—between different areas, so there would not be a read-across. Leasings in those areas that were not leased could be used to create those fire breaks and keep them in place.

The second example is that, if it were found that a farm was not located in the right place, we could decide not to renew the lease in that area.

Obviously such situations need to be looked at within the context of the wider regulatory regime.

On transferred or delegated management, it is interesting that, in the consultation, differing views were expressed on the ability of various sectors to be involved, either with communities or on their own, in managing or having transferred responsibilities. How will the environment be safeguarded in that situation? Mark Simmonds represents ports and harbours: there are perhaps issues to do with harbour authorities having both regulatory functions and commercial interests. In terms of governance, how do you square those responsibilities? If control of the sea bed was added to the functions of harbour authorities, how would those issues play out? How will the environment remain a key concern if functions are delegated or transferred?

As I said in my previous answer, I imagine that all activities that impact on the environment will still be licensable by Marine Scotland or whoever does that. Therefore, the transfer would not have a huge impact on how things are done. Not all harbours are seeking to, or will be able to, take on asset management, so it will not be a particular issue for them all. As I said, there is a separate and fairly comprehensive licensing process for activities that impact on the environment that will still exist.

My understanding is that harbour authorities already have some responsibilities in relation to the environment, because they are responsible authorities for assessments under habitat regulations. How do harbour authorities deal with that in their governance?

It depends. If, for example, a harbour authority has designations in its statutory harbour area, it will already deal with those in a set way. That will depend on the management measures that have been set out for it, which will depend on the designation. That situation will not fundamentally change.

Are harbour authorities fit bodies to take on transferred or delegated management without any reform of the current governance arrangements?

Yes, they are—absolutely. As I said, harbour authorities have statutory responsibilities for assets that they do not own, which sometimes makes it tricky to carry out those responsibilities efficiently. Harbour authorities are generally good stewards of the environment. Development is usually carried out sustainably, and as I said, it is all licensable. If asset management or ownership is devolved to an authority, that will not mean that development activity will go ahead without permissions from the various licensing bodies.

What about other sectors? Does the aquaculture industry have an interest in owning the sea bed or having delegated management of it?

The simple answer is no. However, we do not see any difficulty in devolution of management arrangements. In fact, that will probably result in quite a lot of enhancement, from the point of view of cohesive community planning and our being part of the community planning and local planning processes. The Crown Estate, or whoever manages Crown Estate assets, should certainly have a role in that process, because that gets down to the wider relationships and needs of communities and how best to align with those. From an aquaculture point of view, that would be entirely appropriate.

What is your view on the cases for national management and local management? Who should manage the assets? Does the geographical approach to asset management present any risks to strategic decision making across Scotland, or would it take greater account of more locally specific considerations?

From an offshore renewables perspective, particularly with large commercial offshore wind farms, it is critical that management is done at national level.

An important function would be for one body to look at all the opportunities for development around our shores, and to try to work out where the best combination of developments may be. That process has to be done with an overview of Scotland and Scottish waters as a whole, of all the developers that have indicated interest in developing, and of all the opportunities for development that might exist.

11:45  

Our experience so far is that a centralised process is best, so we are keen to make sure that that approach prevails. Another licensing round is imminent—we think that it will take place at the start of next year. In order to remain competitive in the offshore sector in the UK overall, it is important to have a centralised streamlined process that is able to look at all the opportunities, and then to select the best combination for optimising renewable energy and for Scotland.

What about the interaction between the roles of the Crown Estate and of Marine Scotland for offshore renewables? Does that work effectively?

That interaction does work effectively. Those bodies perform different roles. Marine Scotland is the chief consenting licensing authority and is very much involved in the marine planning process, while the Crown Estate operates primarily as the landlord and the leasor of the sea bed, but it engages closely with Marine Scotland in that process. It is critical that marine planning sits alongside the leasing process; it is an important dynamic that works well between Marine Scotland and the Crown Estate.

On salmon fishing, some of our members have expressed interest in managing fisheries. Fisheries management works best when it is undertaken at catchment scale, and the district salmon fisheries boards and the fisheries trusts operate on that scale rather than on a smaller scale. That element is useful.

On management, since the coming into force of the Aquaculture and Fisheries (Scotland) Act 2013, district salmon fisheries boards have operated under a legal duty to comply with various good governance requirements, including holding public meetings and publishing annual accounts and reports, so they are a good fit for the community organisation category. If they are not in that category, we have a question about whether section 6(1)(b) would allow Scottish ministers to designate the district salmon fisheries boards or the trusts as part of that process, because they are not a clear fit with any of the other categories.

The BPA supports a mix of management options. We do not want to see bodies taking on management of assets within a statutory harbour area without ports being consulted. There are cases in which that could cause competition issues, because the body taking over management might also own other harbours that compete with the harbour in question.

As I said at the beginning, ports and harbours cannot move away; they have no choice but to deal with whomever they must deal. We have questions about the proposals, but our main view is that, whatever happens, we want to ensure that ports are consulted meaningfully.

There is definitely a case for strong national policy settings for what the Crown Estate does in Scotland. However, we do not have any fundamental objection to whatever level of devolution might be appropriate in terms of the different management arrangements. We would like to see consistency in implementation, with checks and balances being included. We certainly need to see that the national policy context is the umbrella that covers that aspect and checks it from time to time.

One of the challenges that Scottish Renewables faces is that it represents a wide range of interests. Among our members, we have islands councils and wave and tidal developers. It is therefore probably right if I add to my previous comments that I see benefit in considering the almost unique opportunities that are offered in the islands for those types of development. I understand that a number of pilot projects are being considered. It seems sensible to approach the matter on that basis.

I welcome Patricia Hawthorn’s seeming to have changed horses slightly in mid-stream.

Mark Simmonds must have been reading my second question as I wrote it down. With the UK Government and the Scottish Government, we have two Governments and 32 councils that do 32 different things in their areas. Should not we be able to diversify and do different things in different areas so that we can innovate and allow organisations such as Scottish Renewables to explore Scotland’s potential?

I added to my comments because we always have to remember that Scottish Renewables has a range of interests within its membership. I can see clearly that there is a need and a wish in the islands councils’ areas to get involved at the community level.

For the rest of the industry, we have large-scale infrastructure developments to deliver. That is a national priority. We have to find the very best developments around Scottish waters.

We are supportive of the position that things should be looked at case by case and that there should be a functional rather than a geographic basis. Large-scale offshore commercial wind farms are a game changer for Scotland, so we have to consider them at national level.

I am going to be really controversial; I am sure that people will come back at me when I say this. Should planning applications for the likes of you guys be decided by national Government rather than by local government?

Our offshore developers value highly their relationships with local councils. All offshore developments come onshore somewhere: the communities that are most directly affected are those that are looking at the applications for substations, cables and other infrastructure that might be required.

The consents for the offshore part of the generating station and the cable are decided at national level, as is correct. One party has the overview of where we provide our major generation assets. However, there is always the local connection because the developments have to come onshore somewhere, so relationships around that are very important. Economic development is based around a substation and the cable.

Thank you. That was a question that I have always wanted to ask.

That moves us on to a question that Angus MacDonald wants to ask, but before that, Stewart Stevenson has a brief question.

Given the powers that ministers have to exercise under sections 36 and 37 of the Electricity Act 1989, which relate to generation and transmission consents, there is a framework within which ministers are applying national policy and considering the overall picture rather than deciding on pretty small offshore wind sites. I doubt that an offshore wind farm would be less than 50MW.

The written submission from Scottish Renewables suggests that the Crown Estate has specialist legal geographic information systems, and consenting and commercial expertise that are not thought to exist currently in local authorities. The Royal Yachting Association’s submission also warns of a potential dilution of expertise. In your respective areas, what expertise, skills and capacity are required by a manager in the Crown Estate?

I am a great believer that skills can be acquired in any context when there is a function to carry out, so I say that skills can be amassed elsewhere. What is incredibly important for our offshore sector is the experience that has built up in Crown Estate Scotland and the Crown Estate’s London office, both of which are still engaging a great deal and in detail about the licensing function for offshore wind. It is not necessarily about the skills—it is also about the knowledge, experience, expertise and ability to compare and contrast opportunities.

I agree. It has been suggested that a national body could be retained to help local and regional bodies with such skills shortages, if they arise.

There are, in the Crown Estate, skills in relation to salmon fishings, but many of the fishings are leased to angling clubs and so on, and there is a lot of expertise in our sector, too.

There is some acknowledgment that there are skills at national level that are very helpful. However, that is not really a problem for the SSPO. We effectively use leasing and landlord arrangements. As long as the body that carries that out is competent in those functions, it will be acceptable to us.

The Smith commission recommended further devolution to local authorities, and your comments on that have been helpful. If powers are devolved, how can we assess whether a manager has the necessary expertise and capacity to manage those assets to meet the Crown Estate objectives?

We would welcome a pilot scheme to test the water before we know the answer to that question. I do not think for one minute that there cannot be further devolution, but it is sensible to go forward on the basis of a pilot scheme. It is not entirely new territory, because the Crown Estate already has different arrangements with the agents that do its work in different parts of Scotland. We should not take too strong a view until we have carried out a pilot scheme.

What would be the implications for the practice of cross-subsidies and financial support currently provided by Crown Estate Scotland for different assets if the management were to be decentralised? Offshore renewables are a considerable earner for the Crown Estate and will continue to be in the future, but agricultural tenancies, for example, benefit from the current approach. I recognise that it is probably not an issue for many of you, but do you have a view on the pros and cons of the two approaches?

That cross-subsidy is an important element and it would be useful to retain it.

Our sector is effectively a cash generator for the Crown and therefore we support several different aspects of Crown Estate business throughout the country. We have no strong view that such a balance should not continue. We see great value in having input at national level to projects that have national significance. However, whatever the new arrangement, as a sector, we would like to see a scheme in which the income from our activities goes back into supporting the sustainable development of our activities for the future and generating potential for growth.

I refer members to my entry in the register of interests, which shows that I am a landowner in the Highlands.

Section 10 would confer on ministers the power to restrict the disposal of certain assets, such as the sea bed. In the consultation, the question was asked:

“Should the existing policy—the general presumption against selling the seabed—be maintained?”

It is fair to say that a significant majority of the respondents asked for that to be case, albeit that some respondents did not. Should the sale of a portion of the sea bed be subject to ministerial consent as per section 10? Should the bill be amended to explicitly prevent the sale of the sea bed?

12:00  

I do not think that the bill should be amended to prevent the sale of portions of the sea bed. Obviously, I am referring only to ports and harbours. Our fairly straightforward view is that, if people have a statutory duty to maintain or work with assets, it is not unreasonable that they should be able to purchase or own them. One or two ports have been able to do that but, obviously, most of them have not. In our members’ experience, that just adds to the cost and the time that it takes to do their jobs. Therefore, we do not agree with that suggestion.

Can anybody point to what the advantage would be of selling bits of the sea bed?

One advantage would be that of not having to deal with the Crown Estate for licensing or renewing leases, for example.

What would the public benefit be?

It would be a more efficient ports and harbours sector. Obviously, ports and harbours bring benefits to the coastal communities in which they are based. They provide direct jobs and support industries such as fishing and manufacturing. If development in ports and harbours is stunted, that will harm the communities in which they are based.

Leaving to one side the environmental consents that are required for dredging, which is a common activity in many ports, would it make it easier for ports if they owned the ground that they have to dredge and so did not have to interact with the Crown Estate? Are there other examples besides that that would help us to understand the sides of the argument?

Yes—I absolutely agree with that. There are plenty of other things that ports do, such as fixing aids to navigation and other things to the sea bed. They interact with the sea bed in their harbour areas in quite a few ways. There is also the general development of harbours through adding new quays, pontoons and whatever else.

Does anyone else have any comments on owning the sea bed? I see that no one has. That is fine.

There are a number of Scottish Government strategies. We have the national and regional marine plans, local development plans, community planning processes, the Scottish energy strategy, the tourism strategy and the food and drink strategy. Obviously, each of your organisations will have members with an interest in those strategies. What do you consider to be the key opportunities for the public management of the coastal and marine assets to contribute to those strategies and other strategies? I realise that that is a huge question, but you should answer it in light of the interests of your members and speak about specific strategies.

That leads me nicely to a couple of points. I completely see the need for the arrangements that we have in Scotland to be well aligned with that range of strategies, which touch on different aspects of life. On the arrangements that might be most appropriate, the focus on community planning, what falls out of it and getting it to work well for everybody—whether that is individuals in the community, businesses or organisations—is appropriate. I would like to see as much alignment as possible between how those things are delivered and how the national policy context is taken into consideration when people go about their business. Throughout Scotland, we can certainly improve our lot by doing community planning well and better.

We have a number of issues to do with migratory fish. The number of fish surviving at sea has gone from about 20 per cent of fish returning to rivers to about 5 per cent, so something is going on at sea that we need to look at.

With regard to overall sustainability, there is an important role relating to what we do in the marine environment, how that is assessed and all the rest of it. However, from our members’ perspective, an important element is having more resource to deal with issues such as huge offshore wind farms, aquaculture and harbour developments. On the wider social and environmental benefit, it would be helpful to have a bit more resource to ensure that decisions that are taken as part of the sustainability process are taken in the right places and for the right reasons. I do not know whether that specifically relates to Kate Forbes’s question, but it is an important element of what we would like to see.

That is an interesting point, because there was a theory two or three years ago—it might still be relevant—that one of the impacts on migratory fish is from the electromagnetic currents that are generated by cables for a variety of offshore activity. Marine Scotland did a piece of work on that that was inconclusive. There is therefore still a question mark about the issue. Given that two major contributors to the Crown Estate are coming together in that regard, should the Crown Estate take a role in exploring that area?

To be fair, the Crown Estate has taken a role in that, although I do not know whether it put money into that Marine Scotland research, which took place in the laboratory in Aberdeen. The research looked at only one form of cabling—I cannot remember whether it was for alternating current or direct current—so there is still a question about that cabling. Along with other organisations, we have had success, in that licensing arrangements have required cables to be buried or to have rock shielding to deal with those issues. However, an awful lot of work is involved in that process. For example, the paperwork for an offshore wind farm is delivered in boxes. My members are relatively small organisations, but they still have to deal with such matters. Some more resource, whether it is top sliced or whatever, would be helpful in ensuring that good decisions come through the process.

My next question might require just a yes or no answer. Do the witnesses support extending the definition of community with regard to the management of the sea bed to cover communities of interest, so that it would include their respective interests?

As I said, we seek clarity about the definition of community. I hope that a district salmon fishery board or, indeed, a fishery trust would be included, but we are not 100 per cent clear about that at the moment.

The other witnesses are nodding their heads at that. Does David Sandison want to come back on that?

Our industry has no desire to be recognised in that way in terms of the functional approach. There is no ambiguity about that.

Trying to define “community” can be very complicated at times, so I am inclined to agree with David Sandison on that.

We have covered all the topics for discussion with the witnesses today. I thank you very much for your time. I suspend the meeting for a couple of minutes before we move on to the next element of our work.

12:08 Meeting suspended.  

12:11 On resuming—