Freedom of Information Request - CRRU Licences
Date: 29 September 2025
Our ref: SIR181531/A5428466
Information Request – CRRU Licences
Your Request
‘For how long is it acceptable to pursue the same cetacean in a powerboat?
For at least 75 minutes today, CRRU were pursuing the same Minke Whale off the coast of Macduff. It's my understanding the Marine Wildlife Watching Code suggests no longer than 15 minutes. However, I am aware that CRRU have been granted a special licence by NatureScot.
I, and other local shore-based watchers, are unaware of the terms of the licence and therefore whether CRRU were breaching the license terms on this occasion, and numerous other occasions when CRRU have been seen pursuing cetacean species including Bottlenose Dolphins, and even Sperm Whales, at close proximity for long durations.
NatureScot, please
- confirm the terms of CRRU's license
- advise how many complaints have been received (both formal and informal) regarding CRRU
- what NatureScot has done with regards to investigating said complaints
- has NatureScot involved Police Scotland.’
Our Response
Following a search of the information we hold our response is below.
Confirm the terms of CRRU's license?
The active CRRU licences are attached separately, which set out the licencing terms and conditions.
Please note, the following condition is also included in the covering email when a licence is granted:
“It is a legal requirement that you provide a return detailing what work was carried out under your licence. Full details of what this return should include can be found on the relevant condition of your licence. Even if no action was taken under the licence you must report this back to let us know.
Without the correct return information being submitted we are unable to issue further licences. Submitting return information in a timely manner ensures that future requests for licences can be dealt with quickly and efficiently.”
Licence returns have been requested from the licence holder. Once these returns are received, we will carry out a compliance review and advise on whether any breaches have occurred.
We also direct the licencing holder to our guidance, ‘Guidance: accompanying notes for survey and monitoring licences’.
Advise how many complaints have been received (both formal and informal) regarding CRRU?
We do not have any information about any formal logged complaints regarding CRRU. Some correspondence concerning informal complaints is attached separately. A compliance review was undertaken in response and no breach identified except a failure to submit a recent annual return, which has been addressed.
What NatureScot has done with regards to investigating said complaints?
Has NatureScot involved Police Scotland?
NatureScot does not have any power of investigation for alleged offences under the Conservation (Natural Habitats) Regulations 1994 (as amended). However, if we receive a complaint of a suspected cetacean disturbance or other offence it will be forwarded to our compliance monitoring officers, who review the information provided. If required, we will then report directly to the relevant divisional Wildlife Crime Liaison Officer (WCLO) or the Police Scotland and NWCU Wildlife Crime Investigative Support Officers where there is no WCLO. We assist the police in any investigation through the provision of information and advice, including expert witness statements for use in court.
We have marked out (redacted) personal data in the documents provided. Releasing personal data into the public domain in response to an access to information request would breach the Data Protection Act 2018. We are therefore withholding the information under EIRs Regulation 11(2) (Personal data). We have also redacted out information not relevant to your request.
How We Handled Your Request
We believe you have asked for environmental information as defined in the Environmental Information (Scotland Regulations 2004 (‘the EIRs’), so we are dealing with your request under those regulations. To be able to use the EIRs, we must apply an exemption under section 39(2) of the Freedom of Information (Scotland) Act 2002 (‘FOISA’). The Scottish Information Commissioner’s guidance recommends that public authorities apply this exemption to environmental information and handle request under the EIRs.
If you would like to find out more about the access to information legislation, there is a guidance booklet available on the Scottish Information Commissioner’s website.
Review and Appeal
I hope this information meets your requirements, but if you are dissatisfied with how we have responded to your information request, please write to us within 40 working days explaining your concerns. You can contact us at Battleby, Redgorton, Perth, PH1 3EW or email us at [email protected]. We will carry out a review of our response and contact you with our findings within 20 working days.
If you are not satisfied following this, you can make an appeal to the Scottish Information Commissioner within 6 months. The Scottish Information Commissioner can be contacted at:
Scottish Information Commissioner
Kinburn Castle
Doubledykes Road
St Andrews
Fife
KY16 9DS
Telephone: 01334 464610
Yours sincerely
FOI Officer,
NatureScot
