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DRAFT EUROPEAN FISHERIES FUND REGULATION
ANALYSIS OF RESPONSES TO THE CONSULTATION

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Executive summary

1. The European Commission published its draft proposals for a Council Regulation to establish a European Fisheries Fund (EFF) in July 2004. Once agreed the Regulation will introduce a new fund which will operate over the period 2007 - 2013 and will succeed the current Financial Instrument for Fisheries Guidance (FIFG). The new regulation will come into force in January 2007 and will replace or modify the provisions of the current FIFG regulation 2792/1999 which expires at the end of 2006.

2. The Executive consulted the stakeholders listed in the Annex for their views on the Commission's. The purpose of the consultation was to ensure that the Executive is aware of stakeholder views and to enable it to use these to influence the terms of the final EFF regulation.

3. The Scottish Executive received 34 written responses to the consultation, 32 of these responses were on behalf of organisations and 2 were from individuals. 7 organisations did not complete the return information form allowing their responses to be made public in the Scottish Executive Library.

4. The majority of responses were supportive of the main aims of the proposal which are to:

• Support the common fisheries policy so as to ensure exploitation of living aquatic resources in a way which creates the necessary conditions for sustainability in economic, environmental and social terms;
• Promote a sustainable balance between resources and the capacity of the Community fleet;
• Strengthen the competitiveness of the operating structures and the development of economically viable enterprises in the fisheries sector;
• Foster the protection of the environment and natural resources;
• Encourage sustainable development and the improvement of the quality of life in marine, lake and coastal areas affected by fishing and aquaculture activities;
• Promote equality between women and men in the development of the fisheries sector and coastal fishing areas.

5. A diverse range of views were received on the detail of the proposals but clear messages to emerge form the consultation were that:

• All want a clearly defined Scottish programme managed in Scotland;
• Areas with significant small-scale coastal fisheries welcome the preferential rates of grant available under axis 1 'Measures for the adaptation of the Community Fishing Fleet';
• Areas that consider themselves to have high levels of fisheries dependence wish to receive support under axis 4 'Sustainable Development of Coastal Fishing Areas';
• There is a general consensus that new groups should not be created to help delivery, this should be based on the existing network of national and local groups;
• Under axis 2 'Aquaculture, Processing and Marketing of Fishery and Aquaculture Products' all are opposed to the proposal to limit aquaculture and processing aid to small and micro businesses.

The Scottish Executive
January 2005.

RESPONSE TO THE CONSULTATION ON THE COMMISSION'S PROPOSALS FOR A EUROPEAN FISHERIES FUND

A number of questions were posed in the consultation and consultees were invited to respond to these. The following summaries reflect the written comments received.

The overall aims of the Commission's proposals (Article 4). Are these appropriate for Scotland? Are any of special importance?

1. The vast majority of respondents were supportive of the main thrust of the Commission's proposals. Only Fishing SOS (Shetland Branch) are directly opposed to the proposals. This opposition is based on its opposition to the Common Fisheries Policy (CFP).

2. Concerns were expressed by the Scottish Fishermen's Federation (SFF), Menzies Campbell and Shieldaig Export Ltd. that efforts through the EFF to lessen dependency on fishing and to encourage diversification out of the industry would be interpreted as an argument for managing its decline.

3. A number of respondents raised queries regarding the definition of terms used in setting out the aims. The Federation of Scottish Aquaculture Producers (FSAP) would like to see more explicit mention of aquaculture in the objectives rather than relying on a presumption that their sector is covered by "fisheries sector" (Article 4c). The Wester Ross Alliance questioned the status of those involved in shore based activities on a seasonal or casual basis, e.g. using nets, who are currently excluded from the definition of "fisherman".

4. Aberdeenshire Council was of the view that the new fund should be focussed on addressing key issues affecting fishing communities. Seafood Scotland was particularly keen on the emphasis placed on socio-economic issues. The Fife Fisheries Development Group (FFDG) while supporting the aims of the EFF noted that a balance would need to be struck between the fisheries and environment priorities, e.g. overbearing environmental protection has the potential to impede reasonable and small scale fisheries operations.

5. The Royal Society for the Protection of Birds (RSPB) felt that the EFF had much greater potential than FIFG to contribute to the sustainable development of the Communities fisheries sector, especially the inshore. However it was concerned that EFF may become a re-branding of FIFG and continue to focus on traditional pattern of capital investment. It felt the focus of EFF should be on reducing the impact but increasing the value of fisheries, i.e. generating more from less.

6. Although not directly the subject of this consultation a number of respondents expressed views on the EFF in the context of wider discussions regarding future financial support from Europe.

• Highlands and Islands Enterprise (HIE) was concerned that EFF would not, unlike FIFG, be a Structural Fund and that this could threaten the trend of integration with other Funds as had been pursued through the Highlands and Islands Special Transitional Programme. HIE was also concerned that with the proposed new dimension of 'Sustainable Development of Coastal Fishing Areas' there was a danger that the new EFF could shadow rather than complement the workings of the European Regional Development Fund (ERDF) and the European Social Fund (ESF). Aberdeenshire Council also stressed the need to ensure that the respective role of individual funds was clear.
• Scottish Borders Council included a document from the South of Scotland Alliance presenting a case for the South of Scotland area to receive additional aid.

Effective 'partnership' between the Commission and Member State will rely in turn on effective partnership between those responsible for managing the EFF programme within the Member State and its stakeholder groups (Article 8). The latter relationship will also be crucial in developing the National Strategic Plan (Articles 15 & 16). What is/are the best way/s of developing such a partnership in Scotland?

7. Many respondents stressed the need to ensure that stakeholders were involved not only with steering the programme once established but also in identifying the priorities in advance of its implementation (SFF, AB Associates, Highland Council, West of Four Fisheries Management Group (WOFFMG), Scottish Quality Salmon (SQS), Derek Louden & HIE). Public meetings to shape plans and to avoid delays in implementation were suggested as one way of taking consultation forward (WOFFMG).

8. There was unanimity that the Scottish EFF programme should be a discrete part of the wider UK programme and that it should be managed in Scotland. Some respondents also proposed that individual areas should have their own sub-plans within the Scottish plan along the lines of the previous PESCA initiative, e.g. the Western Isles (Comhairle nan Eilean Siar), and that the Scottish plan should be built up from the local level. Others also advocated delivery through local PESCA type groups with control of real budget and decision making powers (Wester Ross Alliance & Scottish Borders Council). The provision (Article 57) in the draft regulation for Member States to designate a Managing Authority was seen as an opportunity to devolve power towards local groups (HIE). HIE also felt that some of the timescales for producing Strategic Plans and Operational Programmes were too tight.

9. Fisheries Management Groups (FMGs) have been established to advise on and direct the delivery of the 2000-2006 FIFG programmes. Organisations and individuals that had been included in these generally felt that they had been helpful and that they ought to continue in some form (FSAP, Highland Council, FFDG & HIE). A perceived strength of these groups is that they include a level of expertise that enables consistency to be retained across Scotland. Possible weaknesses are that the membership only includes the 'better organised' parts of the fisheries sector and that the FMG membership might be expanded to more effectively cover environmental and equal opportunities issues.

10. Seafood Scotland acknowledged the difficulties associated with operating a management group of diverse stakeholders with sometimes conflicting interests but felt that the transparency of the decision making process should be improved. The Wester Ross Alliance felt that unless decision making power is devolved to the Coastal Action Groups there will be no significant increase in accessibility to the decision making progress. Aberdeenshire Council would like to see a speeding up of the approval and payment process.

The content of the detailed measures of what will be eligible for support under EFF (Articles 23-45). Do the provisions of the draft regulation meet the future needs of Scotland? Where if anywhere do they fall short? Are there any which are particularly helpful/unhelpful?

PRIORITY AXIS 1 (Articles 23-28):

MEASURES FOR THE ADAPTATION OF THE COMMUNITY FISHING FLEET

11. The SFF considers that the proposals offer little encouragement to progressive skippers and vessel owners and contain little or nothing to assist the efficiency or viability of Scottish vessels. The Orkney Fisheries Association (OFA) is similarly disappointed with the proposals especially that they include nothing that would assist younger fishermen to purchase vessels or to become shareholders. Both organisations agree that a priority should be the re-instatement (Article 27) of measures that focus on quality improvements, care of the catch, enhanced hygiene, crew comfort and safety investments. Further support for this view comes from the WOFFMG, Aberdeenshire Council and the Seafish Industry Authority (SFIA).

12. Seafood Scotland is concerned that eligibility for modernisation aid remains restricted to vessels >5years old. In its view this prevents progressive owners and skippers from receiving assistance to install modern equipment that is only now becoming available. Given that the programme will run until 2013 HIE felt that flexibility should be retained to invest in the fleet in the event of stock and/or socio-economic recovery.

13. The EFF proposals for the inshore fleet (Article 27a) indicate that higher rates of grant would be available to this sector. These proposals are broadly welcomed (e.g. SFF, WOFFMG, OFA, FFDG, Scottish Enterprise, Wester Ross Alliance, Highland Council, Comhairle nan Eilean Siar, Shieldaig Export Ltd.). However, the SFF does not consider that the sector should become the dominant focus for aid to the catching sector. Shetland based AB Associates feel that the <12m length restriction has a southern bias and that 15-18m is more appropriate for exposed northern waters.

14. While there is some support from the SFF for assistance in purchasing more selective and/or environmentally friendly gears (Article 27) it voices a fear that this may act as an incentive to make current gear uneconomic to operate. The RSPB welcomes the proposals and feels that support for gear replacement should be open to all vessels, not just those affected by recovery plans. A number of respondents raise a concern that supporting replacement gears (Article 27.2) could lead to the diversion of effort from sectors where there is over capacity, e.g. whitefish, to fisheries that are currently sustainable, e.g. Nephrops (Comhairle nan Eilean Siar, HIE & Scottish Enterprise).

15. Proposals for the provision of public aid for permanent or temporary cessation are contained in the EFF proposals (Articles 25 & 26). The SFF felt that the Commission would assign the bulk of its EFF to new Member States whereas the known capacity problems are actually in the older Member States who will receive less EFF. The WOFFMG and Highland Council were opposed to further decommissioning but felt that support should not only be made available to vessels impacted by Commission recovery plans but also to those affected by national plans. Scottish Enterprise felt that the impact on downstream shore based businesses of changes in fleet activities needed to be considered. Angus Council is supportive of temporary cessation aid and the RSPB considered that this should also be available in support of the development of marine protected areas.

16. Aberdeenshire Council was supportive of the principle that adjustments in fishing effort needed to be backed up by publicly funded support for those affected (Article 28). Scottish Enterprise felt that given the current difficulties of recruitment to the industry an early retirement scheme was of low priority. Comhairle nan Eilean Siar felt that the package of proposals could be useful to the Western Isles. A note of caution was injected by HIE which noted that support for retraining and training schemes for fishermen is already available through other European funds and regional agencies.

PRIORITY AXIS 2 (Articles 29-34):

AQUACULTURE, PROCESSING AND MARKETING OF FISHERY AND AQUACULTURE PRODUCTS

Aquaculture

17. On the general topic of investments in aquaculture (Article 29) FSAP is concerned that the proposal not to support the 'production of products which do not find normal market outlets or which could cause adverse effects on the policy for the conservation of fishing resources' may lead to an ill conceived precautionary approach being adopted and inhibit the development of legitimate markets. The SFIA wanted purpose built mussel dredgers to be included within any definition of 'production installations'.

18. Comments were received on the eligible measures for aquaculture set out in the proposals (Article 30). With a few qualifications key representatives of the sector (Scottish Quality Salmon (SQS) and FSAP) support the proposals. FSAP supports species diversification but stresses that not all of the effort should be directed at the limited opportunities in this direction. Support for species adapted to ambient environmental conditions in the UK, such as Atlantic salmon and Rainbow trout, should therefore be continued. SQS and Landcatch would like to see support included for selective breeding and egg production facilities.

19. Key representatives of the industry (SQS & FSAP) consider the proposal (Article 30.2) to restrict aid to micro and small businesses to be a retrograde step and not the way to develop a successful commercial scale finfish aquaculture in the Community. Consolidation within the industry will make a significant part of the sector ineligible for support. This view is supported by Comhairle nan Eilean Siar and also by groups including the Wester Ross Alliance which highlights the significant contribution made by these businesses to local employment.

20. While the proposals for supporting aqua-environmental measures (Article 31) are broadly supported some of the questions posed by respondents will require clarification to be sought from the Commission. The RSPB supports the principle of introducing measures to reward farmers for providing additional public goods and services. Freshwater fisheries interests (Atlantic Salmon Trust (AST), the Sea Trout Group and the Association of District Salmon Fisheries Board (ADSFB)) and scientific organisations (Fisheries Research Services) FRS)) all see opportunities here for work that could support problem solving in the farmed fish/wild fish arena. Possibilities suggested include fish farm relocation and changes to the practice of holding pre adult fish in pens in freshwater systems containing salmonids.

21. Specification that support can only be provided in the support of Community regulations is questioned by FSAP, e.g. on environmental audit they highlight that alternative systems are available. While FSAP supports the concept of organic standards for aquaculture the rationale for promoting this particular activity is questioned on the basis that it is not necessarily more environmentally benign than other forms of aquaculture.

Processing

22. For processing and marketing (article 33) there was an overwhelming response that limiting the aid to small and micro enterprises was not acceptable (including Lowland Scotland Fisheries Management group (LSFMG, AB Associates, WOFFMG, SFIA, SQS, OFA, Comhairle nan Eilean Siar, HIE, Lerwick Port Authority, Highland Council, Angus Council, Scottish Seafood Processors Federation (SSPF), Scottish Enterprise, Seafood Scotland and Aberdeenshire Council). The main reasons provided were that this did not reflect reality in an industry where considerable consolidation had already taken place and where medium sized enterprises were the best placed to deal effectively with retailers without detriment to fishermen and fish farmers.

23. Under the proposals for eligible measures (Article 34) the SSPF, Seafood Scotland and SFIA were unclear as to whether or not assistance would be available for live shellfish suppliers. In a similar vein to its concerns regarding aquaculture in the overall aims of the draft regulation SQS wished to see 'landings from the local fleet' expanded to include 'and local aquaculture producers and processors'.

PRIORITY AXIS 3 (Articles 35-41):

MEASURES OF COLLECTIVE INTEREST

24. Respondents supported the broad thrust of the proposals under this measure as they had been helpful under FIFG. However, given the generally soft nature of projects supported under the measure a significant number of queries were raised regarding the eligibility of particular activities. Clarification will need to be sought from the Commission.

25. The proposal provides a description of areas and activities that could be the subject of collective actions (Article 36). Respondents see opportunities to use the EFF to support the delivery of outcomes from the Inshore Fisheries Review including the establishment of local management groups (WOFFMG, Highland Council, Comhairle nan Eilean Siar).

26. The promotion of partnerships between scientists and operators in the fisheries sector is proposed (36c). Aberdeenshire Council was supportive of using the EFF to promote partnerships involving fishermen and scientists with the objective of improving assessment and management. The SFF sees potential opportunities for supporting the fishermen's survey and for participation in Regional Advisory Councils (RAC) activities. The RSPB also sees an opportunity to support RAC activities and also the collection of data and the development of indicators to monitor fishing impacts on target and non-target stocks and the wider marine environment. The British Geological Survey (BGS) suggested using fishing vessels to support surveys of the seabed, this 'survey fleet' could return to its traditional activities when fishing opportunities improved.

27. The measures proposed to protect and develop aquatic fauna (Article 37) raised many queries. The extent to which 'the aquatic environment' could be interpreted as 'freshwater environment' was raised both by those whose main interest was in freshwater fisheries (AST, Sea Trout Group, ADSFB and FRS) and also by others (Comhairle nan Eilean Siar). The main concern here was whether and to what extent migratory fish stock restoration could be supported, the specific exclusion of re-stocking activities was queried (AB Associates).

28. Proposals for investments at fishing ports are included under this axis (article 39). Aberdeenshire Council stressed the need for investment to be made in fisheries infrastructure at ports as did Derek Louden. While recognising the need for this type of support HIE considered it to be a mistake to include it under this axis where it had the potential to draw significant funds into capital investment and away from softer infrastructure projects. A number of respondents (Highland Council, WOFFMG and AB Associates) observed that this article, as currently drafted, will not permit support to be provided to privately owned and operated ports. This is not considered helpful since the current pattern of Scottish fisheries activities uses both publicly and privately owned ports. Queries were also raised as to whether mobile landing facilities, e.g. pontoons, would be eligible for support (Comhairle nan Eilean Siar and Wester Ross Alliance).

29. Measures to support activities for the promotion and development of new markets are included under this axis (Article 39). A query was raised as to whether the definition of 'surplus or under exploited species' would threaten marketing support for pelagic species such as herring and mackerel (SFIA, LSFMG and Seafood Scotland). In addition to being able to provide marketing support for products with Protected Geographical Indicator status a number of respondents also wanted to see support made available for quality products with clearly defined geographical links (SQS, SSPF, LSFMG & AB Associates). The eligibility of support for live shellfish exporters was also queried (SFIA, LSFMG & SSPF).

30. The final two articles of this axis cover provision for pilot projects (article 40) and the modification or reassignment of fishing vessels (Article 41). These attracted relatively few comments but it was noted that pilot projects could be useful in supporting the work of inshore fisheries management groups (WOFFMG, Comhairle nan Eilean Siar & Highland Council). The potential reassignment of vessels towards training and research was also noted (WOFFMG and Highland Council).

PRIORITY AXIS 4 (Articles 42-44):

SUSTAINABLE DEVELOPMENT OF COASTAL FISHING AREAS

31. This axis represents the most significant departure from the provisions within the existing FIFG regulation. As with Axis 3 there was broad support for what was envisaged (Article 42) but many questions were raised regarding the definition of eligible areas (Article 42.3) and how the measures would be delivered (Article 44).

32. On eligible areas a wide range of opinion was apparent. These ranged from the view that all UK fishing areas should be included (SFIA) to those that resources should only be targeted at more remote areas of fisheries dependence (Wester Ross Alliance). The Western Isles felt that it should qualify for support (Comhairle nan Eilean Siar). Areas such as Aberdeen that would currently be excluded from eligibility (on the basis that they include a municipality of >100,000) were of the view that all areas should be included (SSPF & LSFMG). The problems of scale in identifying eligible areas were also highlighted, using too large an area masks pockets of fishery dependence (Derek Louden). Scottish Enterprise also highlighted the need to avoid unwanted or unintended effects, e.g. Fraserburgh and Peterhead should not be excluded due to sharing a geographical area with Aberdeen.

33. On eligible measures (Article 43) there was broad support for the type of measure proposed (AB Associates, Wester Ross Alliance, RSPB, WOFFMG, Highland Council, Comhairle nan Eilean Siar, HIE and Scottish Enterprise). A number of additional measures were proposed for potential inclusion, e.g. support for the development of sea angling (WRA); support for fishermen seeking employment in the aquaculture sector (SQS); support for the restoration of salmonid fisheries and angling tourism (Sea Trout Group) and the protection of migratory sea trout and Atlantic salmon stocks (AST). While opportunities to assist individuals to diversify away from the fisheries sector was viewed as helpful it was also highlighted that this will not replace fisheries employment and should therefore be seen as complementary activity to the main thrust of the EFF (Comhairle nan Eilean Siar).

34. The Commission's proposals for stakeholder participation in the sustainable development for coastal fishing areas attracted a significant response. The proposal for the establishment of Coastal Action Groups (CAGs) was welcomed by most. The proposal for local delivery with devolved finance and decision making powers was particularly attractive and likened to the previous PESCA initiative (e.g. FFDG, Comhairle nan Eilean Siar & Wester Ross Alliance). Larger organisations with experience of this type of initiative stressed the need to avoid duplication of existing networks and groups and also to ensure that the full range of European funds are delivered through integrated actions (HIE & Scottish Enterprise). This view was supported by others (Derek Louden). Examples were provided of initiatives at specific ports or areas, e.g. 'Building Buchan - New Beginnings', that could be used to assist delivery of measures under this axis.

PRIORITY AXIS 5 (Article 45):

TECHNICAL ASSISTANCE

35. This axis was viewed as primarily of concern for the Managing Authority and there were therefore very view comments. The Wester Ross Alliance hoped that Technical Assistance could be used to employ locally based development officers.

The revised arrangements to simplify and increase transparency in the monitoring arrangements (Articles 61-67). Will these increase accessibility to the decision making process for stakeholders?

36. Given that responsibility for these falls mainly to the Managing Authority relatively few responses were received. Stakeholder representation on UK wide groups was seen as essential if Scottish interests are to be effectively voiced and resources allocated on an equitable basis (FSAP). Aberdeenshire Council felt that monitoring delivery of the programme should be focussed on impacts and results with unambiguous indicators.

Other comments

37. On grant rates:

• Scottish Borders Council highlighted the fact that fishing areas do not map neatly onto Commission areas and that differential rates between the Highlands and Islands and elsewhere disadvantage those elsewhere;
• HIE and AB Associates felt that a case could be made for putting parts of the Highlands into the category of 'outermost areas' that would qualify for higher rates of grant.

38. Respondents including HIE and Seafood Scotland were concerned that the eventual size of the EFF programme to Scotland would be small and that the resources required to set up and manage it could outweigh the potential benefits.

39. RSPB does not want the Commission to approve National Strategic Plans if they are not explicitly linked to Natura 2000, it also wants less freedom for Member States to only select those measures it wishes to support.

ANNEX A LIST OF STAKEHOLDERS CONSULTED

STAKEHOLDERS

A B Associates Shetland
Aberdeen City Council
Aberdeen Fish Curers & Merchants Association
Aberdeen Fish Producers' Organisation
Aberdeen Fish Salesman's Association
Aberdeen Harbour Board
Aberdeen Inshore Fishselling Co Ltd
Aberdeenshire Council
African and Caribbean Network
Alexander Buchan Ltd
Anglo-North Irish Fish Producer's Organisation
Anglo Scottish Fish Producer's Organisation
Anglo-Scottish Fishermen's Association
Anglo-Scottish Shell Fishermen's Association
Angus Council
Annan Fishermen's Association
Arisdale Smolt Company Ltd
Aqua-scot
Arbroath Fishermen's Association
Arbroath Fish Buyers Association
Arbroath Fish Processors Association
Ardrossan Harbour Office
Argyll and Bute Council
Associated British Ports
Association for the Protection of Rural Scotland
Association of Salmon Fishery Boards
Association of Scottish District Salmon Fishery Boards
Association of Scottish Shellfish Growers
Association of West Coast Fisheries Trust AWCFT
Atlantic Salmon Trust
Ayr Wholesale Fish Buyers Association
Ayrshire Enterprise
Balta Island Seafare Ltd
Berneray (North Uist) Fishermen Ltd
British Marine Fin Fish Association
British Ports Association
British Trout Association
Buckie Inshore Fishselling
Burgon Eyemouth Ltd
Caledonian Trout Co
Caley Fisheries Ltd, Aberdeen
Caley Fisheries Ltd, Fraserburgh
Caley Fisheries Ltd, Peterhead
CANH Countryside and Natural Heritage
Carradale Fishermen Ltd
Castle MacLellan
Clachan Hatchery Ltd
Cloan Hatcheries
Clyde and South West Static Gear Association
Clyde Estuary Forum
Clyde Fishermen's Association
Clydeport Estuary Control
Cockenzie & Port Seton Fishermen's Association
Commision for Racial Equality
Comhairle Nan Eilean Siar
COSLA
Couper Seafoods Ltd
Crab Processors Association
Croan Seafoods
Crown Estate Commissioners
DARD
David Middleton
Dawn Fresh Seafood's Ltd
DEFRA
Denholm Fishselling Ltd, Edinburgh
Denholm Fishselling Ltd, Peterhead
Disability Rights Commission
Don Fishing Company Ltd
Drummond Fish Farms
DTI
Dumfries and Galloway Council
Dumfries and Galloway Enterprise Company
Dumfries and Galloway Programme Executive
DunbarTrout Farmers Ltd
Dunbartonshire Enterprise
Dundee City Council
Dunstaffnage Marine Laboratory
East Dunbartonshire Council
East Lothian Council
East Neuk Initiative
East Renfrewshire Council
Eastern Scotland Programme Executive
Environment Agency
Equal Opportunities Commission
European Structural Funds
Eyemouth Fish Merchants Association
Eyemouth Harbour Trust
Falkirk Council
Farne Salmon
Federation of Highlands & Islands Fishermen
Federation of Scottish Aquaculture Producers
Ferguson Salmon Ltd
Fife Council
Fife Creel Fishermen's Association
Fife Enterprise Ltd
Fife Fish Producers' Organisation Ltd
Fife Fishermen's Association
Firth of Clyde Forum
Fisher Foods
Fishermen's Mutual Association (Eyemouth)
Fishermen's' Association Ltd
Fish salesmen's Association (Scotland)
Fishing SOS Shetland
Fjord Sea Foods
Food Certification Scotland
Food Standards Agency
Forward Scotland
Fraserburgh Harbour Commission
Fraserburgh Inshore Fishermen Ltd
Fraserburgh Trawlers
Fresh Catch Peterhead
Freshwater Lab, Pitlochry
Friends of the Earth Scotland
G Duncan Salmon Ltd
Gala Fish Farming Ltd
Galloway Fishermen's Static Gear Association
Glasgow City Council
Glasgow Development Agency
Grampian Sea Fishing Ltd
Greenpeace
Hall Aitken Associate
Hebridean Fishery Partnership
Highland Salmon Company
Herring Buyers Association Ltd
HIE Argyll and the Islands Enterprise
HIE Badenoch and Strathspey Enterprise
HIE Caithness and Sutherland Enterprise
HIE Inverness and Nairn Enterprise
HIE Lochaber Enterprise
HIE Orkney Enterprise
HIE Ross and Cromarty Enterprise
HIE Shetland Enterprise
HIE Skye and Locahalsh Enterprise
Highland and Islands Enterprise
Highland & Islands Fishermen's Association
Highland Council
Highland Council Harbours
Highland Shellfish Management Organisation
Hoove Salmon Ltd
Institute of Aquaculture (Stirling University)
Inter-Quo Ltd
International Fish Canners
Inverlussa Shellfish
ISG (J Craw & M McGinlay Scottish Enterprise)
John Eccles Hatcheries
Johnson Sea Farms
Johnson Shellfish
Johnston & Carmichael
Joint Nature Conservation Committee
Joseph Robertson
Kames Fish Farming Ltd
Kergord Hatchery
Kidsons Impey
Kinlochbervie Fishselling Co Ltd
Lakeland Marine Farm Ltd
Lakeland Smolt Ltd
Lakeland Unst Ltd
Landcatch Ltd
Lerwick Port Authority
LHD Ltd
Lighthouse of Scotland Ltd
Live Shellfish Traders Association
Loch Duart Salmon Ltd
Loch Fyne Oysters
Loch Linnhe Fishermen's Association
Lochaber Ltd
Lunar Fishing Co
Machrihanish Marine Farms Ltd
MacDuff Shipyards Ltd
MacKinnon's, Solicitors
Mallaig and North West Fishermen's Association.
Mallaig Harbour Authority
Marine Conservation Society
Marine Harvest Scotland
Marine Laboratory, Aberdeen
Marine Stewardship Council
Mill of Elrick Fish Farms
Moray Council
Moray Firth Fish Processors
Moray Firth Partnership
Moray Seafoods Ltd
Muckairn Mussels Ltd
Mull Salmon Ltd
National Trust for Scotland
Nautilus Consultants
NAWAD
NFFO
Nobles
North Atlantic Fisheries College
North East of Scotland Fishermen's Organisation Ltd
North Uist Fisheries Ltd
Northern Producers' Organisation
Nufish Ltd
Orkney Fish Farmers Association
Orkney Marine Hatcheries Ltd
Otter Ferry Seafish Ltd
Pelagic Freezing
Peter & J Johnstone Ltd
Peterhead Fishermen Ltd
Peterhead Harbour Trust
Portree and Uig Port Users
RSPB
Salar Ltd
Salmon and Trout Association (Scotland)
Scallop Association
Scot-prime Seafoods Ltd
Scot Trout
SANA
Scottish Agricultural Organisation Society
Scottish Association for Marine Science
Scottish Association of Fish Producers' Organisations Ltd
Scottish Borders Council
Scottish Borders Enterprise
Scottish Churches Parliamentary Office
Scottish Civic Forum
Scottish Coastal Forum, CANH
Scottish Council Development and Industry
Scottish Enterprise( Moira Forsyth & Lorna Duguid)
Scottish Enterprise Tayside
Scottish Environment Protection Agency
Scottish Fish Merchants Federation Ltd
Scottish Fishermen's Federation
Scottish Fishermen's Organisation
Scottish Fishing Services Association
Scottish Food and Drink Federation
Scottish Food Quality Certification
Scottish Natural Heritage
Scottish Pelagic Fishermen's Association
Scottish Quality Salmon
Scottish Quality Trout
Scottish Scallop Fishermen's Association
Scottish Sea Farms Ltd
Scottish Seafood Processors Association
Scottish Shellfish Marketing Group
Scottish White Fish Producers Association
Scottish Wildlife Trust
Scrabster Harbour Trust
Sea Fish Industry Authority (SFIA)
Seafood Scotland
SFPA HQ
Shetland Catch
Shetland Enterprise
Shetland Fish Producers Organisation Ltd
Shetland Fishermen's Association
Shetland Islands Council
Shetland Ocean Alliance
Shetland Salmon Farmers Association
Shetland Shellfish Management Organisation
Shian Fisheries Ltd
Skelda Salmon Farms Ltd
Skerries Salmon Ltd
Soil Association
Solway Shellfish Hand Operators Federation
South Ayrshire District Council
Stolt Sea Farm Ltd
Stornoway Port Authority
Tarbert - Harbour Authority (Loch Fyne)
Terregles Salmon Company Ltd
The 10 Metre and Under Association
The Fishmongers Company
Tobermory Oysters
Torhouse Trout Ltd
Torridon & Kinlochewe Community Council
Ullapool and Assynt Fishermen's Association
United Fishselling Ltd
West of Four Fisheries Management Group
West Coast Aquaculture
West Minch Salmon Ltd
West of Scotland Fish Producers' Organisation Ltd
Westside Fishermen Ltd
Wester Ross Salmon Ltd
Western Isles Fishermen's Association
Whitelink Seafoods
WWF Scotland
Youngs Bluecrest
Miscellaneous
MSPS
Clerk of the SP Committee
Clerk of the Environment and European Committees
The Sea Trout Group
Menzies Campbell MP
Lowland Scotland Fisheries Management Group
British Geological Survey
Wester Ross Alliance
Shieldaig Export Ltd
Cadderlie Mussels
Creran Oysters