Response to the consultation on the long term management of the Crown Estate in Scotland 27 March 2017

Introduction The Royal Yachting Association Scotland (RYA Scotland), is the governing body in Scotland for all forms of dinghy and yacht racing, motor and sail cruising, RIBs and sports boats, windsurfing, narrow boats, and personal watercraft. We refer to these disciplines collectively as ‘boating’. Boating takes place wherever people take to the water in boats. This can be on purpose built facilities and reservoirs, inland waterways or canals, natural fresh water lochs, rivers, estuaries, coastal areas and on the open sea. Our purpose is to promote and protect safe, successful and rewarding boating in Scotland. We represent a community of about 50,000 people actively engaged in boating activity, over 6,200 of whom are individual members. We support nearly 300 local clubs and training centres, the majority of which are within Scotland’s coastal communities and work with a diverse range of partners to achieve the outcomes described in our Strategic Plan. RYA Scotland is volunteer-led with up to 60 volunteers engaged in our committee structure at any one time.

Background Recreational boating and marine tourism in Scotland is recognised as a significant contributor to the leisure economy of Scotland. Our members across the United Kingdom, value greatly the warm welcome from local communities across Scottish cruising waters and are great ambassadors for our waters as a cruising destination on a world stage. The community we represent draws interest from people of all social and economic backgrounds for whom boating is their recreation, whether this be a large yacht in a marina or a small powerboat maintained in the garden. RYA Scotland has a very constructive working relationship with the Crown Estate in Scotland. We have worked with the Crown Estate over many years to ensure that the interest of recreational users of the Scottish coast and the seabed belonging to the Crown is understood and taken into account when possible developments have been under consideration. In particular we have developed excellent relationships with the Crown Estate's Marine Officers whose expertise and knowledge, backed up by the Crown Estate's cartography systems, have been critical to the efficient management of the seabed. The Crown Estate acting as a single point of contact has enabled both organisations to address issues in advance of leasing rounds before they become contentious, consequently our approach has always been to facilitate responsible development and it is very rare for us to raise an outright objection. The opportunity to engage at a strategic level with a single body operating at a national level is greatly appreciated by a not for profit organisation with limited resources. We have been a committed contributor to the Stakeholder Advisory Group on The Crown Estate since its inception and were the lead body in the creation of Scotland’s Marine Tourism Strategy, Awakening the Giant. Our interest is primarily the coastal and marine environments and the implications of the future management of the Crown Estate assets in Scotland in this regard but also in consideration of those areas of inland water which fall within the scope of Crown Estate assets.

Overview RYA Scotland has no particular view on the devolution of powers if, and provided that, any agency or body controlling the seabed continues to uphold and vindicate the public right of navigation (including anchoring)and the public use of the foreshore.

Similarly, we understand the benefits of further devolution to local authorities where there is an established competence in the management of marine assets as in the case of Orkney and Shetland. However, we do have concerns about the proposed further devolution or decentralisation of the exercise of these powers to local levels where there is as yet no established competence to implement or manage the complex and interconnected interests around what are currently Crown Estate assets in Scotland and, while we know that some other Local Authorities have qualified staff for dealing with marine matters, we believe additional staff would be needed In light of the current economic circumstances, we are concerned that the bodies receiving these new powers may not have the financial or staff resource to properly discharge their duties in respect to marine seabed and foreshore management with the required degree of competence. We perceive a degree of interest from parties who have only noted the financial return from managing these assets and have not understood the associated liabilities. The obligation to maintain the seabed and remove derelict equipment needs to be seen as the corollary of obtaining income from it. RYA Scotland believes that the current model for seabed management in Scotland has been efficient and cost effective. We recognise the importance of increased local accountability but have significant concerns that current proposals to decentralise the work of the Crown Estate could lead to a fragmented, inefficient and inconsistent approach to seabed management which may be detrimental to resident maritime users, visitors to our world class cruising waters, public rights of navigation and to the affected coastal communities. We believe marine licensing should remain the responsibility of Marine Scotland to avoid any perceived conflict of interest between licensing and revenue raising powers and there is a risk that funds available become so diluted that consequent investments have a lower return than would be the case if strategic investments could be managed and funded nationally. We would favour long term arrangements for the management of Crown Estate assets in Scotland which:

maintain the public right of navigation (including anchoring) and the public use of the foreshore,

provide a national body to oversee a framework of policy and practice which guides local decision making,

maintains service provision at reasonable and uniform cost,

engages the full range of stakeholders (including communities of interest) and

provide a process for appeals and or complaints relating to actions taken or not taken by a body managing Crown Estate assets.

Questionnaire responses Q1: Should the future approach be changed from the duty to manage the assets on a

commercial basis? A1 YES

RYA Scotland sees the benefit in some assets being managed in a way that realises benefit beyond financial return to the specific asset, with possibilities for wider impact on the communities the assets serves. For example, the recent research undertaken to benchmark the current economic impact of Marine Tourism in Scotland identified a shore side spend of about £23.00 per person from a visiting yacht or motor cruiser. Crown Estate support to establish visitor moorings or a pontoon style jetty for ease of landing is unlikely to be justifiable based on the overnight charges for visitors alone particularly when maintenance and replacements costs are taken into account. However the combined economic impact for a coastal community realised through the initial investment is almost always a significant return on the investment.

Q2: If YES, should there be a power to take account of wider socioeconomic or other benefits?

A2 YES As above.

Q3: If YES, which assets should be managed on a commercial basis and which should be managed differently? (Please provide details in the space below) A3

We do not see the management style being delineated by the type of asset. Rather we believe the manager could be empowered (within the context of a national framework) to judge the intention of a lease or activity as being purely commercial or having wider benefits and charge accordingly. In that context, activities undertaken for commercial gain, which would include the seabed being leased for aquaculture enterprises and renewable energy installations, would be managed commercially. Other activities which have wider community benefit, such as laying visitor moorings, or are community led would be managed differently.

Q4: Should the requirement on ‘good management’ be retained? A4 YES Q5: Should the requirement on ‘good management’ be amended to take account of

environmental implications in relation to the management functions?

A5 YES Scotland’s natural environment and its world renowned coastal waters are one of the

country’s greatest assets. We believe that future management arrangements need to include an obligation to protect this resource from overexploitation.

Q6: Should the existing Crown Estate portfolio in Scotland be preserved in its current form? A6 RYA Scotland has no particular view on the sale of the Crown Estate assets in Scotland,

other than the general presumption against selling the seabed, and so long as such disposals do not reduce or otherwise affect access to water which is currently in place.

Q7: Should Scottish Ministers’ approval be required for sizeable sales? A7 YES And more so, ministerial approval should be required for all sales. The disposal of the

existing assets should be subject to rigorous scrutiny and through an open and transparent process of stakeholder engagement.

Q8: Should the existing policy - the general presumption against selling the seabed - be

maintained? A8 YES RYA Scotland is in full agreement with the Ministers intention to maintain the general

presumption against selling the sea bed. Q9: Do you have any other views on how the management of the Crown Estate in Scotland can

ensure delivery of the duties in the Scotland Acts 1998 and 2016? (Please provide details in the space below)

A9

Ensure provision of a process for appeals and or complaints relating to actions taken or not taken by a body managing Crown Estate assets decisions, not seen by communities as in their interests.

Q10: How can transparency on the sale and management of the Crown Estate assets be enhanced? (Please provide details in the space below) A10

RYA Scotland would favour a process which obliges managers to ensure all stakeholders have an equal opportunity to engage in decision making processes. This must include both local stakeholders, such as the immediate geographic community, and wider stakeholder groups, such as RYA Scotland, who may represent a large community of interest with a wider viewpoint. In line with our previous comments, we believe all sales of existing assets need the highest level of scrutiny which would attract stakeholder engagement naturally.

Q11: How can the devolution of the management of the Crown Estate contribute to community

empowerment? (Please provide details in the space below) A11

RYA Scotland welcomes the principles of community engagement and empowerment and recognises the benefits of greater local inclusion in the decision making processes that affect local communities. We believe strongly that the long term arrangements need to extend the description of ‘community’ to include communities of interest in order to embed this principle and for there to be an obligation on future managers to recognise that key stakeholders in an area of interest are not necessarily those people who live nearest to it. We have concerns relating to the fragmentation of decision making giving rise to disparate approaches to service provision, management approaches and costing structures. Such disparity may lead to competition between adjoining communities and has implications that relate to mooring charges and development investment.

Q12: How can the devolution of the management of the Crown Estate contribute to land reform? (Please provide details in the space below) A12

RYA Scotland considers the Land Reform (Scotland) Act 2003 and the associated Scottish Outdoor Access Code to be an exemplary piece of legislation and guidance. We see the devolution of the management of Crown Estate assets bringing local people closer to the decision making processes that protect access to our natural landscape and quite possibly enhancing the freedoms we enjoy.

Q13: How can we further improve alignment with Scottish Ministers’ objectives to deliver on the national outcomes? (Please provide details in the space below) A13

Marine tourism is supported through the provision of visitor moorings and pontoons and the protection of anchorages. This helps communities, especially those in the more remote and fragile communities, to better achieve their economic potential with better employment opportunities for local people. Ineffective management of these facilities would hinder the achievement of this objective. The Crown Estate has valued our built and natural environment through its duty of stewardship and has protected it and enhanced it so that we and future generations can enjoy it. Sailing is an activity enjoyed by all ages and contributes to our living longer, healthier lives. There should be a review after 5 years to establish refined guidance for delivering Scottish Ministers' objectives.

Q14: Do you have any views on the proposed application of the above principles to guide the

long term framework for managing Crown Estate assets?

A14 YES

Comment: In line with the first principle, RYA Scotland would reiterate our position that the ability to influence decisions in the long term framework must include communities of interest who may have a greater stake in a given asset than the people who live in the immediate locality of the asset. We hope that the pioneering work by the Crown Estate in presenting their annual report and accounts in terms of total contribution rather than just a financial statement can be retained and built on so that non-financial benefits can be properly taken into account.

Q15: Which of the three proposed options for managing Crown Estate assets in Scotland do you prefer? A15 Option 3 (hybrid)

RYA Scotland believes that the Crown Estate's economic assets would best be managed in a governance framework that retains a national oversight and engages local community (and communities of interest) representation, with the expectation that the principles of a national, consistent approach would continue.

We believe that a national entity providing a framework of policy and practice to guide local decision making is an essential element for ongoing effective strategic management of the Crown Estate in Scotland. Further devolution to local structures brings decision making closer to individual communities and is in line with the Governments stated objectives on community empowerment and inclusion. There are good examples of existing local management agreements such as the management of moorings in the Island of Gigha, or the running of Tobermory Harbour where this approach has proven successful. Similarly, West Highland Anchorages and Moorings Association and the Clyde Moorings Committee are both communities of interest that span more than one Local Authority area. Any changes should not compromise their ability to facilitate the management of anchorages. This does however present the risk of disparate local policy and practice, which is particularly important in terms of the application of charges for moorings, launching and berthing of recreational craft and the potential impact of disparate charging policies on the wider economic contribution of the recreational and marine tourism sector. By way of example; a day launching fee on Loch Lomond for a motorised craft of any size is £15 while an optimist sailing dinghy (ages approx. 8 – 12) would be free. The same two craft at any Aberdeenshire Local Authority harbour would each pay the same fee of £30. We have some concerns about devolving the leasing for wave and tidal energy out to 1nm, 3nm or 12nm to councils or communities as there is a need to balance local benefit against wider disadvantage, for example by extinguishing navigation rights, including anchoring, particularly where these relate to issues of safety. Bodies such as the Northern Lighthouse Board and the Marine and Coastguard Agency must have a role but bodies such as RYA Scotland and indeed, fishermen’s associations also need to have a right to be consulted. A national framework would ensure a degree of consistency within which local needs and aspirations can be included and a consistency in handling associated obligations such as the maintenance of the sea bed.

Q16: If OTHER, what approach to management do you propose?

No response

Q17: Should a geographic or a functional approach guide the reform of the management of the

Crown Estate in Scotland? A17 OTHER

RYA Scotland understands that the management needs of assets such as land assets as opposed to marine assets are likely to be considerably different. Similarly, while we acknowledge the established ability of Orkney and Shetland Island Councils, the capacity of other Local Authorities and local communities to manage these assets effectively will vary.

We note that in the case of developments such as marine renewables, the development itself may fall within one marine region and the economic and other impacts in another. This argues for an approach that enables a broad view to be taken. In line with our response to Q15, we believe that the management approach cannot be defined as simply geographic or functional. Local authority boundaries do not always align with water boundaries. This might lead to different approaches being taken around a single stretch of water (eg. around estuaries) which could have unwanted impacts on water usage. The preference of RYA Scotland would be for a national entity to give oversight on a functional basis, for example marine and land, with the option for a local or geographic arrangement where the capability for effective management is evident.

Q18: Do you have a preference for management on a geographic basis being led by either local

authorities or communities?

A18 In the context of our previous answer, where geographic management is deemed appropriate, RYA Scotland has no particular preference on whether this falls to the Local Authority or a local community. Our only position being that the capability and capacity of the managing body to provide for effective management must be evident.

However, where communities manage resources successfully through an existing Local

Management Agreement we feel that this devolution of power should be protected. Q19: Should Scottish Ministers have the power to hand responsibility for management of the estate, or parts of it, to a particular person or persons? A19 NO

RYA Scotland believes this approach could only be considered with heavy caveats on the individuals taking up the management responsibility. We would have deep concerns that individual or group agendas would pervade the management approach leading to unilateral and unchallengeable decision making which may overlay established rights or misrepresent a minority position within a community.

Q20: Should Scottish Ministers have a power to vary management arrangements held by other parties over time? A20 YES

Although we would advocate that existing local management arrangements and those which enable local moorings association to function should be maintained for at least five years and then only varied if there is evidence of inadequate management or opportunities for improvement.

Q21: Should Scottish Ministers have the power to extinguish rights currently held in the Crown Estate where management of the asset can be adequately covered by other legislation? A21 NO.

RYA Scotland believes if an existing right can be adequately managed to the benefit of the local community then there is no need to change the procedure for maintaining those rights.

Q22: Do you have any views on which assets should be managed at the (i) national level (ii) by local authorities or (iii) by communities? (Please provide details in the space below) A22

Box 12: Crown Estate Assets in Scotland RYA Scotland View

The land forming the seabed of Scottish coastal waters i.e. inside 12nm

This requires a mixed approach with national oversight encompassing local input. We note that this seabed will be within areas ultimately covered by Regional Marine Plans which may constrain some management options.

Seabed rights within 200nm: (gas) storage rights energy rights (offshore renewables) mineral rights (not hydrocarbons) powers to lay cables and pipelines other leasing rights

National level

Foreshore rights. RYA Scotland has no opinion subject to existing access rights being upheld.

Rural estates: The Whitehill estate in Midlothian The Glenlivet estate in Moray The Applegirth estate in Dumfries and Galloway The Fochabers estate in Moray 1 and 2 Kings Park Cottages, Stirling 10 the Homesteads, Stirling

RYA Scotland has no opinion.

Commercial estates: 39 to 41 George Street, Edinburgh the lock-up garage at 3 and 5 West Thistle Street Lane, Edinburgh the car parking spaces to the rear of 37, 39 and 41 Frederick Street, Edinburgh the land at Rhu Marina on the Firth of Clyde

RYA Scotland has no opinion.

Salmon fishing rights (rivers and coastal waters)

RYA Scotland has no opinion subject to existing access rights being upheld.

Rights to naturally occurring gold and silver

RYA Scotland has no opinion.

Reserved mining rights

RYA Scotland has no opinion.

Any other property, rights and interests held by Commissioners on behalf of the Crown – including internal waters, the land owned by Her Majesty in Scotland

RYA Scotland has no opinion subject to existing access rights being upheld.

Q23: Should local authorities or communities be expected to make a case for further devolution? A23 YES

RYA Scotland believes this is essential to establish competence of the interested parties to provide for effective management and that the process should enable scrutiny by stakeholders to provide check and challenge on expectations and realistic understanding of potential gains versus liabilities.

Q24: If YES, should they demonstrate the capability to ensure appropriate management, to maintain service delivery and to deliver increased benefits? A24 YES As above Q25: Replicating functions in each area is likely to lead to fragmentation of the estate which would pose significant risk to realisation of new revenue – how can these risks be avoided? (Please provide details in the space below)

RYA Scotland believes that the Crown Estate's economic assets would best be managed in a governance framework that retains a national oversight and engages local community (and communities of interest) representation, with the expectation that the principles of a national, consistent approach would continue. Replicating functions also brings a risk of losing economies of scale. We believe that a national entity providing a framework of policy and practice to guide local decision making is an essential element for ongoing effective strategic management of the Crown Estate in Scotland and would ensure a degree of consistency within which local needs and aspirations can be included. This body could also provide for arbitration on contentious issues.

Q26: Should shared services be a requirement of devolution to the local level of decision-making on property, rights and interests of the Crown Estate? (Please provide details in the space below) A26

Where these will lead to improvements in the management of assets and in line with our response to Q25 we would broadly agree with the principle of shared services applying to devolution to local levels. Shared services should also help achieve greater financial efficiency and a greater likelihood of sustaining continuity of expertise.

Q27: What are the opportunities, if any, of further devolution? (Please provide details in the space below) A27

RYA Scotland recognises that further devolution will give local communities greater influence in the decision making process that affect them, particularly for remote coastal communities where the marine environment is closely associated with the local economy, employment opportunities and the range of opportunities available associated with marine tourism.

Q28: What are the challenges, if any, of further devolution? (Please provide details in the space below) A28

We believe the major risks of further devolution lie in the potential for fragmentation of approaches, the loss of national oversight and local decision making being adversely affected by minority interests or local elected members politicising the management of the Crown Estate through influence on Local Authority officers. A further risk is that that the funds available, if devolved, become so diluted that consequent investments have a lower return than would be the case if strategic investments could be managed and funded nationally. There are also risks from dilution of expertise and loss of scale economies with a consequent increase in the cost of support services.

Q29: Is there a need for strategic planning and a long term investment strategy, in order to co-

ordinate work to enhance the value of the estate? A29 YES Q30: Do you have any views on the value of a national framework to guide local decision-

making? (Please provide details in the space below) A30

With reference to our response to Q25, RYA Scotland is in agreement with the proposals for a national framework as defined in this consultation.

Q31: Should there be consistent charging approaches between areas to avoid competition

between different parts of Scotland? A31 YES Q32: Are there any other issues that should be covered by a national framework for management of Crown Estate assets in Scotland? (Please provide details in the space below) A32

Ensure provision of a process for appeals and or complaints relating to actions taken or not taken by a body managing Crown Estate assets, not seen by communities as in their interests.

Q33: Should the future arrangements in Orkney, Shetland and the Western Isles be considered

first? A33 YES

RYA Scotland acknowledges that Orkney and Shetland have established their capability to manage local resources effectively and in a manner commensurate with good community engagement. This does not however include the position of Western Isles where we are aware of an inconsistent approach to charges for mooring and berthing and a fragmented approach to the development of local pontoon facilities which we believe has created oversupply for the potential market and a risk of inadequate resources for maintenance and replacement and is likely to lead to one or more of these facilities failing.

Q34: Is a phased approach needed to introduce reforms to the management of Crown Estate assets across Scotland?

A34 YES

Such an approach will allow all affected stakeholders to prepare for and adjust to any significant changes.

Q35: Is there value in a pilot scheme prior to implementing reforms? A35 YES

However RYA Scotland is clear that any pilot option cannot be focussed around the island councils of Orkney and Shetland. These councils are uniquely positioned both geographically and in terms of capability and conclusions based on such a pilot would be entirely inappropriate for the rest of Scotland. Any pilot must include both a land based Local Authority with coastline and a community managed asset to ensure the breadth of capability is appropriately tested and stakeholder engagement at each of these levels remains inclusive.

Q36: How can people influence decisions in relation to the management of the Crown Estate assets? (Please provide details in the space below) A36

We believe that all stakeholders, including those representing communities of interest such as RYA Scotland, should have a statutory right to access the decision making bodies who manage Crown Estate assets in the new arrangements. RYA Scotland signed a non-disclosure agreement with the Crown Estate so that proposals for lease for marine renewable developments could be scrutinised at a very early stage to identify risks and impacts that were not captured in the MaRS system. This worked well and led to an efficient application process. Further; bodies who manage Crown Estate assets should have an obligation to consult meaningfully all stakeholders with an interest in their operation,s embedded into their authorisation to manage Crown Estate assets. We would expect such engagement to be in line with the Scottish Governments National Standards for Community Engagement (2016)

Q37: How should the long term governance arrangements differ from the interim arrangements? (Please provide details in the space below)

No response

Q38: Should the future framework include flexibility for Scottish Ministers to vary the proportion of revenue retained by the manager? A38 YES See response to Q39 Q39: Should the arrangement where the capital value of one part of the estate can be used to enhance opportunities elsewhere in the estate be continued? A39 YES

This arrangement and the similar arrangements for the distribution of revenue, have proven their value in the past where the national interest has been an important factor. For example in marine tourism considerations or for transferring support from areas with a strong economy and high value assets to areas in need of investment.

Q40: Should the current duty of maintaining the value of the estate and the return obtained from it be continued or amended for the investment of capital proceeds? A40 CONTINUE Q41: Should capital proceeds from a sale in one area be invested in the same area, or should there be discretion to invest anywhere in Scotland? A41 Discretion to invest anywhere See comments to Q39 Q42: Should it be possible for the capital or maintenance requirements for an individual asset to be funded from another part of the estate, even if management of the assets are devolved to the local level? A42 YES See comments to Q39 Q43: Should funding of strategic activities from Crown Estate resources continue? A43 YES Q44: If YES, should these strategic activities be managed at the national level? A44 YES Q45: Should the person taking on the responsibility for management of an asset normally take on the responsibility for managing the associated liabilities? A45 YES Q46: Should the liabilities for land restoration and residual liabilities after decommissioning of marine infrastructure be managed: A46 In line with our response to Q45, RYA Scotland believes that the obligation to maintain the

seabed and remove derelict equipment needs to be seen as the corollary of obtaining income from it. We do not therefor see this issue as lying either locally or nationally, rather it lies with the body taking on the management of an asset and in particular where an income is generated. One disadvantage of devolving responsibility for this is that by bad luck some bodies may incur much greater costs than others.

The body taking on the management of an asset should be made responsible for the removal and disposal of all redundant and derelict material relating to moorings and marine aquaculture. This means having an obligation to monitor and remove unlicensed or unsafe moorings for which payment is taken and clearing all remnants of redundant and derelict aquaculture infrastructure when the company is bankrupt or is otherwise unable to remove these items.

We would have concerns if liabilities were retained nationally. This creates the opportunity

for local management bodies to take on management without the need to consider longer term liabilities such as removal of derelict aquaculture infrastructure or abandoned mooring tackle, or indeed enforcing the positioning of moorings and removal of unlicensed moorings. Pooling of risks through an insurance type of arrangement may need to be considered if such liabilities are devolved.

Q47: Should the costs associated with management of liabilities be included in the overheads for estate management? A47 YES Q48: Do you have any other views on the devolution of the management or revenue of the

Crown Estate? (Please provide details in the space below)

A48 YES We believe there is a need for an identified process for appeals and or complaints relating to actions taken or not taken by a body managing Crown Estate assets. Particularly in relation to the obligation to maintain the seabed but also to deal with unlicensed or unsafe moorings and redundant aquaculture infrastructure and that this process must be retained at a national level.

Q49: Please tell us about any potential costs or savings that may occur as a result of the proposals, and any increase or reduction in the burden of regulation for any sector. Please be as specific as possible. (Please provide details in the space below) A49

The proposals may require require that representative bodies like RYA Scotland engage with a greater number of decision making bodies created through further devolved local management arrangements. This will create additional costs for attending meetings, supporting volunteers to attend consultation meetings and additional staff commitment to co-ordinating responses to issues that involve multiple bodies whose management arrangements are co-terminus on or along a contiguous body of water.

Q50: Please tell us about any potential impacts, either positive or negative, you feel any of the

proposals contained in this consultation may have on the environment. Please be as specific as possible. (Please provide details in the space below)

A50

We believe the proposals offer greater opportunity for protection of our natural assets through greater local involvement which is likely to have a strong appreciation of the intrinsic value of our natural environment. However, this must be within the national nature conservation framework. We do also believe there is potential for the loss of our visual resource and/or access to areas for recreation where industry has an undue influence on decisions.

Q51: Are there any likely impacts the proposals contained in this consultation may have on particular groups of people, with reference to the ‘protected characteristics’ listed above? Please be as specific as possible. (Please provide details in the space below)

We do not see any likely impact on those groups specifically identified by the protected characteristics. However to RYA Scotland equality is more than characteristics and our interest in the proposals includes everyone with an interest in boating as well as activity on or in the water. We believe the further devolution of management arrangements risks disempowering communities of interest such as the 50,000 strong boating community we represent, unless adequate measures are put in place to ensure ongoing stakeholder engagement in the long term arrangements.

Q52: Please tell us about any potential impacts upon the privacy of individuals that may arise as

a result of any of the proposals contained in this consultation. Please be as specific as possible. (Please provide details in the space below)

No response from RYA Scotland

James Allan Chief Executive Officer RYA Scotland