Dear Cabinet Secretary,
Crown Estate Scotland rent calculations and charges announcement
I am writing to express our sector's disappointment and dissatisfaction with the announcement today that Crown Estate Scotland (CES) plan to implement significant rent increases to our sector. We ask you to review this decision. Our request of Government is based on the following points;
- Our members received correspondence yesterday (24/1/22) from Crown Estate Scotland confirming that rent rises were to be applied to finfish sites including those for nursery site as well as the removal of the OID (Outer Islands Discount). The letter received by our members suggests that the opposition to the changes are emotional positions "arguments put forward by respondents represent heartfelt concerns." I can assure you that the opposition to the changes were based on fact and an appreciation of the wider policy and economic landscape across Scotland. We are disappointed by the manner in which CES seek to dismiss our case.
- CES state that the number of responses received was low. As you know, Salmon Scotland represents the Scottish salmon farming sector including the supply chain across Scotland. The sector contributes significantly to the economy locally and nationally - a point your COP26 speech at our Sustainability meeting in Glasgow highlighted. Having consulted with our 6 producer member companies, we submitted a response on behalf of our industry. Our response was submitted with a wide-ranging consideration of the impacts on our businesses - which can have knock-on impacts to our people, communities and sustainability. These issues are particularly acute in our more remote locations and islands where costs are planned to increase further. Again I am very disappointed that CES would seek to dismiss our industry in this way.
- CES is aware that you appointed Professor Griggs to review how our sector is regulated. Despite meeting with Professor Griggs, CES propose to hike our costs without any reference to the imminent publication of the Griggs Review. Professor Griggs in discussion with our companies has advocated a holistic policy approach that considers the wider consequences and implications of changes. We all agree that is long overdue and the CES approach ignores this wider context.
As I am sure you know, CES plan to:
- increase rent charges on our farmers by approximately 95 per cent across the sector;
- remove the Outer Island Discount - which has been in place for areas of production where higher costs of living, labour and logistics are constants;
- introduce significant charges associated with nursery farms and for those farms where there is no harvested production.
The wider picture
It is well-documented that our sector makes significant contributions to both the national and local economies of Scotland. What is less well-known is that we are a low-use sector in terms of marine resource. Of the c. 200 active sites we farm, fish pens account for less than 170 Hectares of Scottish waters - less than half the size of Edinburgh airport. This is approximately 0.003 per cent of Scottish waters and just 0.02 per cent of the area of seabed covered by the 17 projects of the ScotWind leasing project (at just over 7,000km2)
Over 2,500 of our farmers are located around the west coast, Highlands and Islands of Scotland - some of the most remote areas of the country, providing jobs and economic activity all year round. Our suppliers include over 3,600 companies located throughout Scotland and being part of the fabric of the Scottish economy is something which we are very proud of. It has been key to making us Scotland's most valuable food export.
It is that success which means we are passionate about developing our businesses in a sustainable and profitable manner. It also means that we compete on an international basis. It is therefore important that, after a number of decades of building our reputation and product over a number of decades, we are not exploited with extortionate charges which reduce our international competitiveness.
A strong sector benefits the wider community
Our success is based on our provenance and quality. That comes not only from the fish we produce and supply, but it is also the people and communities which are integral to the process. When CES was formed, it was understood that salmon farming rental income would be used locally for the benefit of our communities. If that information could be accounted for and directly linked to our sector, we would be more supportive in principle. But that simply has not happened.
Having accurate accountability for the contribution our sector makes to our producing regions is something we are keen to have. That should be in place now, before changes are made across the board and so that our communities directly benefit from our contributions. We know the Griggs recommendations will cover this important point.
Our ask is that these Crown Estate Scotland proposals should be placed on hold but should be a key factor in the consideration of the Griggs recommendations. They should all be part of a longer-term discussion which will benefit the wider economy rather than implementing a plan which will realise tens of millions of pounds for CES coffers in the short term. We remain keen to maintaining our open dialogue with your office and with Crown Estate Scotland and hope that our serious concerns can be addressed at the earliest opportunity. I look forward to your reply.
Yours sincerely
Tavish Scott
Chief Executive
