Mull Aquaculture and Fisheries Association,

                                                                  Penmore,

                                                                        Dervaig,

                                                                          Isle of Mull,

                                                                             Argyll PA75 6QS.

 

                                                                         Tel. 01688 400268

                                                                                            nick.iomo@btinternet.com

 

                            

                                                                                            31st October 2006

 

Scottish Executive,

Environment and Rural Affairs Dept.,

Marine Group,

Victoria Quay,

EDINBURGH EH6 6QQ

 

COASTAL AND MARINE PARK CONSULTATION

 

 

Dear Sir,

We as an Association have read the consultation document and would like the Executive to take note of our introductory statement before attempting to answer the “questions” in the document.

 

We are seriously concerned about the consultation to date and believe that the Executive is not giving individuals within our area the chance to democratically decide if they want to be included in a Park or not.  Sending a “consultation satellite car” almost unannounced and using the responses from this as evidence, is in our opinion, simply not acceptable,  particularly as the car was sent during the Mull car rally when the local population were either away or unable to access it due to road closures.

 

  We are also concerned that this method does not necessarily target those that live in the area and indeed some ministers at a recent parliament debate expressed similar concerns over the consultation process.

 

We would also like to express our doubts regarding the way the questions in the consultation paper are phrased.  The questions do not allow individuals the chance to give their own opinions on the proposed park issues.

 

 This Association believes that a democratic referendum, when all the details of the CMNP are known, is the only fair way to discover whether there is a genuine desire or need for a CMNP. 

 

 

 

Detail is the key word.  Our members cannot be expected to support a Marine Park without having the absolute assurance that a CMNP will have no interest or importantly authority over their industries.  No sensible business signs up to a deal without first knowing the detail.  We are well aware that Mull continues to be in the area that is a frontrunner for a CMNP.

 

Despite these reservations we have decided we have no option but to respond to the questions but we would once again reiterate that it is difficult to make reasonable responses without more information and detail.

 

We would appreciate if the Executive could acknowledge receipt of this letter.

 

We will be balloting our own members with our own questionnaire and will forward the results to the Executive in due course.

 

**Since this letter was drafted a “satellite car” was sent for a further consultation  on the Island on Sunday 5th Nov.  Those of us who attended from our Association were astounded that the Executive used a promotional firm to do the exercise complete with a simplistic video.   A member of the executive was available  in the afternoon.  If anything we are now more concerned than before and have indicated to the Executive that if consultation is to be taken seriously then some realistic dialogue based on accurate detail and guarantees, will need to take place.

 

Chap1. “The added value and benefits of a CMNP”

There are no immediate benefits for our particular industries that we are able to ascertain.

> Possible benefits maybe, improvement of infrastructure including updating of roads and new piers.

> In the absence of any detail we do not believe that a CMNP is the answer for addressing any of our local problems.

> We would need further explanation of what is meant by “other examples that the benefits of a park could bring.”  This is a loaded question and is based on supposition

 

Chapter 2. “Selecting the location of Scotland’s first Coastal and Marine National Park”

> We would simply state the criteria used should be based on an area that needs and wants a national park. 

> Our association does not agree with the strongest case being for the Argyll and Islands.  We do not currently have any evidence to suggest that the population needs or wants a CMNP.  Only by a democratic referendum will we know the views of the local population.  We also are led to believe that many tourist organisations are also stating that they are running at full capacity and that the area does not have the infrastructure to cope with any further increase.  Our association believes that there are more pressing problems, such as housing that concern this particular area other than CMNP.

> We believe that the residents of the Fair Isle have stated that they both want and need a CMNP and therefore, if a CMNP has to be put in place, this would be our recommendation.

 

Chapter 3. “Functions, Powers and Governments”

·                    The Park Plan

> This should not impact in any way on aquaculture and fisheries that are already in place and any fisheries organisation, such as an IFG, should not overruled by a park planning authority.

> As an association we see considerable problems in the details of any park plan. 

·                    Relationships with Town and Country Planning

> We believe that planning control should continue to remain in the hands of the local council and that any park authority should not have a controlling influence on council decisions.

·                    Conservation and Recreation Management

> We believe that zoning is a contentious issue and also divisive.  It has the potential to create conflict between different industries where they didn’t exist before.  We believe that there are enough regulations in place already, for both land and marine use. Fisheries and Aquaculture have many voluntary agreements that have worked well without enforced regulations.    We also believe that with the introduction of various regulatory organisations, such as IFG’s, will be in a better position than a Park Board to make any decisions regarding marine environment.

> We believe that the park authority under no circumstance should be given the last resort “stop” power.

 

 

 

·                    Relationships with Inshore Fisheries Management

> We do not believe that any park authority should have any controlling influence over existing fisheries management or any future management organisation.  A park authority will neither have the expertise or the interests of fisheries management.

·                    Relationships with Aquaculture

> We believe that option E is the only suitable option for aquaculture given the limited choice.  However, this can only be agreed providing the park plan has a substantial input from those bodies involved within the aquaculture industry.

·                    Governments

> Once again, given the limited choice, only option 2 is suitable, with a board being elected by the population within the park area.  A majority of the board should be locally elected.

>If our area was picked, our own Association would want and demand a greater representation on the board, as this is basically a marine national park.

·                    Financial Implications

> Our association would like to see compensation packages for any fishing or aquaculture business adversely affected by the imposition of a CMNP in our area.

> Our association is also alarmed at the amount of cash currently being spent on terrestrial parks in Scotland.  Figures of 5 million pounds are being quoted for the Lomond and Trossachs Park, of which less that 1 million pounds is available to spend in the park area after administrative expenses.  We would hope, should a CMNP be placed in our area, the figures on administration could be kept to an absolute minimum and the larger amount spent on necessary infrastructure problems, such as roads, housing and piers.

 

 

On Behalf of Mull Aquaculture and Fisheries Association

 

 

 

Nick Turnbull----Secretary