Response to MoD/Qinetic Consultation.
This Response is on behalf of Applecross Community Council.
The consultation has taken place to a background of leaks, rumours and silence which has not helped the process. There have been only two meetings that I have attended, one at the BUTEC Base in Kyle held by Richard Freeman and in attendance were a sub group of the NWRFA, Ally Hughson and myself representing both the Inshore Fisherman’s Assoc and Applecross Community Council. At this meeting we were shown a map of the proposed Range expansion and the positioning of the new hydro phones which required protection, hence the proposed expansion. We were not to take photos or take the map with us but it is almost identical to the one leaked to the press earlier this summer. There was a distinct lack of answers to direct questions regarding the positioning of the hydro phones and fanning of cables. The point of the design of “creel friendly” hydro phones was brought up but with little positive response.
I also attended a public and un-minuted meeting at Kyleakin five days before the end of the consultation period. A meeting whose date and time were changed at fairly short notice and surprisingly we were told that we were fortunate to attend as they are not standard procedure. Several points were brought up at that meeting with very few specific answers regarding the powers to close the road to the Base at Sand, the need for an Outer Sea Limit to the North of the Range, a socio/economic study on the cause and effect of the Range expansion, studies on where the directly affected gear is to be moved to, loss of earnings to the fishermen directly and the Communities they live in. How does the increased presence of naval activity affect a strong and healthy tourism industry, how will cetaceans be affected by the increase in sonar activity, the powers to close off transit of the Range and the Outer Sea Area to fishing activities during Trials. All these questions remain unanswered or were given non-specific replies.
As a result of these issues there is so much uncertainty surrounding this “robust consultation” process. We are concerned as to why the consultation has been carried out with so little information available to respond to. Indeed there are so many unanswered questions that this response has to make assumptions that may not be factual in the current plans for the BUTEC Range. We were promised in a Parliamentary question that the consultation would “involve a full and proper discussion”. What has emerged has been far from this.
Finally the manner in which the fishermen and communities have been treated leaves a lot to be desired. Claiming that the on going work at the Sand base is merely maintenance disrespects the currently good relations between the fishermen and the MoD. There has been a stream of workmen carrying out the “upgrade” from early summer which includes renewing the cable ducts and putting in place all the cables for the new hydro phones, lorries going off the North Coast Road with huge concrete ducts. This is not classed as maintenance in anyone’s eyes other than Qinetic/MoD. While accepting the need for a BUTEC Range a continued existence, and the current local economy is now reliant on its continuance, there is a need for Qinetic/MoD to acknowledge there is another thriving economy that operates alongside their operations which provides much needed employment on the Applecross peninsula.
It is important to note that the timescale of the consultation has not been nearly long enough to carry out a detailed socio/economic study on the impacts of the Range expansion. The standard timescale for consultations carried out by the Scottish Government is 90 days. While extending the current consultation from 35 to 49 days has been welcome it still is not long enough to gather information to show the detrimental effects of the expanded closure on the local economy.
It is difficult to obtain definitive landings from such a concentrated area as it transcends two blocks, areas 43E4 44E4, but first sale values of £3.4 million have come from these blocks. This will include tonnage from the mobile sector which brings down the average value of the catch. The area of the proposed expansion is one of the few grounds which has a creel only fishery and the value of the fishery per tonne is far higher. An example of the potential impact comes from landings of £271,000 accounting for just seven vessels from June to August 2015, fishing in the affected area. The point to be made here is the proposed restricted area is regarded as one of the most lucrative fishing grounds on the west coast of Scotland. The vessels which fish this area are all under 15m and are locally based, not being the nomadic mobile sector. They land all their catch into the local ports surrounding these grounds.
Given time a socio/economic study would supply the numbers of jobs created that supports the landings, packers, drivers, office and administration work and marketing, advertising and promotion of a top quality product. There is a strong secondary industry reliant on the procurement of this fishery, that of a strong tourist industry. An example of one boat’s landing to one local outlet during the summer over one week totalled £1,000 and this value is trebled by the time the product reaches the plate. This is a locally based economy which is part of the attraction that brings in many visitors over a extended season. The creation of a vibrant sector around fresh and sustainably caught seafood is an important factor in its continued success.
The lack of information elicits several questions over and above the actual flawed process.
Regarding the activities on the water.
What actions have the Range operators taken to mitigate the loss of grounds regarding the Range Inner Sea expansion? Where do the boats place their creels when the restricted area is doubled in size? I am sure they realise that as well as being the most lucrative fishing grounds that are to be restricted the surrounding grounds are already the most heavily fished. The displaced gear will either put boats out of business or create an atmosphere of conflict between static gear men fighting over more limited fishing grounds. As pressure intensifies to the south of the expansion, this conflict has the potential to spill over into a mobile/static gear area. The summer trawled grounds will have more creels for the mobile sector to negotiate leading to gear loss for the creel fishermen and loss of time in the mobile sector.
The concerned following question has been repeatedly asked and has not received a definitive answer but an evasive response. The Range operators have the power to close The Outer Sea Area during trials, how often will this happen and what notice will be given, when this occurs? Due to the increased size and scope of proposed operations on the BUTEC Range and the intimation that Qinetic aim to have the Range active as much as possible. This power and the exercise of this power may well be crucial to the viability of the local fleet.
As the size of the vessels using the Range increases it was intimated that the vessels need a greater area to turn. The Range expansion to the south appears to have more than the protection of the hydro phones as a reason for implementation. Again by implication, does this mean that the Outer Sea Area will be closed more often? While not expecting reassurance for the future the fact that there already has been a request to close off the Inner Sound north of the Crowlins for a trial does not hold any kind of positive prospects for the future.
Have any studies taken place to find any negative effects on cetaceans which are both resident and transitory on the Inner Sound? How does this affect the growing trade in environmental tourism?
Tourism and commercial transport companies are expressing concern about restricting transit of the Range. Have the operators investigated the safety implications of exercising this power?
The considerations of the tourist industry on the Applecross peninsula does not appear to have been addressed. Tens of thousands of visitors come here to enjoy a Sanctuary, the original Gaelic name of the area, establishing a larger commercial base at Sand can adversely affect tourism here. Accomodation is already fully exploited, the Range operators expect a good standard of pre-booked accommodation, will this be available in the future? Has this been investigated? The powers to close of the road to the Base at Sand, how does this affect access to the Sand beach, an established holiday destination?
Tourism is the main employer in the locality and there does not appear to be consideration given to any adverse effects the expansion of the Range will have on this well established industry. The economic prosperity of the locale depends largely on the health of tourism and additional employment from the Range expansion will not replace any job losses. Once Applecross becomes known as a major testing site this will put the “remote and beautiful attraction” of the area at risk.
Conclusion and future
The length of the consultation period and information released during it has meant that there are fundamental flaws in the process.
There has no consideration been expressed by the Range operators on the effects of the proposed plans on the local community and economy.
There are too many concerns expressed locally to include in this submission but one that is uppermost is if the Range is operated in a successful way the shareholders of a private company will benefit. This benefit accrues partly through the denying of access to long established traditional fishing grounds from which small operators have turned over profit for centuries. What have the Range operators put in place to compensate the loss of earnings from these fishermen as there is a CPO being carried out and a transfer of profits from several small businesses to Qinetic.
Important to note that up till now there have been good relations between the Range operators and the local fishermen and we hope this will continue despite the flawed consultation process.
Yours Ali Macleod, on behalf of Applecross Community Council and as skipper of the FV Varuna.