Open letter to Roseanna Cunningham – sustainable local fisheries depend on pristine MPA

Dear Roseanna Cunningham,

re: Sharing our concerns and response to SEPA’s Consultation on the ‘Regulation of Marine Cage Fish Farms: Updating the approach to protecting the sea bed’.

Sea Change Wester Ross has voted as a group to oppose new or expanded fish farms in Wester Ross Marine Protected Area if the evidence suggests this would harm the marine environment.

A whole ecosystem, west coast community & sustainable fisheries point of view.

Forgive us for sharing such a comprehensive account of our concerns. Like many other west coast community groups we want to ensure the Government is aware of all the potential harmful impacts that concern us. Our perspective is from the point of view of the whole ecosystem as well as community businesses and fisheries, hence by necessity this is wide ranging and long.  Our appeal to you to understand these concerns, is on the basis that there is evidence to suggest a thriving marine life, and an intact ecosystem has much greater socio-economic benefit (as well as underpinning our heath and well being) than multinational’s short term profit objectives and a handful of jobs, however valuable these are.

Sea Change does not have the capacity to investigate every concern. We simply pose the questions and encourage SEPA and the Government to examine them before any proposed expansions are authorised. We seek a robust stand for the wider public interest. History shows us that too many well-meaning ‘good ideas’ end up costing the ecosystem and coastal communities dearly in hindsight because they are not tested adequately. Whether for or against fish farms, due diligence needs to be applied, as well as to grasp the opportunity for reform where necessary.

Underwriting this approach is the OSPAR convention which enshrines the precautionary principle. “preventive measures are to be taken when there are reasonable grounds for concern that human activities may bring about hazards to human health, harm living resources and marine ecosystems, damage amenities or interfere with other legitimate uses of the sea, even when there is no conclusive evidence of a causal relationship. A lack of full scientific evidence must not postpone action to protect the marine environment. The principle anticipates that delaying action would in the longer term prove more costly to society and nature and would compromise the needs of future generations.”

MPAs are Scotland’s insurance policy, building resilience into the marine ecosystem so our seas can withstand increasingly unpredictable outcomes from climate change, ocean acidification, plastic and chemical pollution as well as loss of biodiversity from industrial methods of fishing and aquaculture. The network of MPAs, of which Wester Ross MPA is just one, were created to conserve important and vulnerable species. By default, MPAs also happen to protect key nursery and spawning grounds within the richest areas of biodiversity in Scotland which help seed other areas outside the MPA boundary thereby supporting our fisheries.

Wester Ross MPA is rated by MIAP as the highest risk for wild fish possible

The Scottish Government acknowledges that sea lice and disease have caused the decline of wild salmon and sea trout in west coast rivers. A risk assessment carried out in Wester Ross for Managing Interaction Aquaculture (MIAP) Project 3 on locational guidance and Zones of Sensitivity showed Wester Ross MPA rated in the blue and purple category. Blue denotes an area of the greatest sensitivity possible and purple the category below which is “high sensitivity”. Loch Kanaird was considered so sensitive that relocation of existing farms was recommended. In other words, the MPA sea lochs are as sensitive a site to wild fish as it is possible to find. The existence of fish farms in the area has socio-economic costs that need accurate assessment.

The global challenge we face as a species, and the high risk context.

Given the seriousness of the proposals to expand both the number and size of fish farms, and the potential impact, the questions below need very careful consideration. They also need to be assessed within the context of the alarming loss of species and biodiversity already underway in our seas. The world is facing rising world populations as well as extinctions, which the media has dubbed the “6th wave of mass extinctions” – whether it deserves this label or not there is an urgent need for new thinking about what true sustainability means and how to achieve it.  Multinational profit making in exchange for a handful of jobs, whilst overlooking the environment is not aligned with sustainable objectives. Pioneering companies elsewhere in the world are demonstrating that taking care of the environment and people can actually improve profits. Least of all because consumers are becoming more aware and are demonstrating their care.

It is therefore not sufficient to assess risk of SEPA’s proposed expansions by focusing on the depositional zones for faeces and food particles in total isolation from this wider context. We need joined up thinking which accounts for all the impacts as well as the whole picture. Where there is doubt, there needs to be an application of the precautionary principle.

We are grateful to SEPA for recognising the need to monitor fish farm impacts rather than rely upon self-regulation which has contributed to the impacts acknowledged in recent statements in the SEPA’s “Regulation of Marine Cage Fish Farms: Updating our approach to protecting the sea bed”. I repeat these for your convenience.

Today’s farming techniques release fish faeces, uneaten feed and used medicines directly into the sea where they can interfere with marine ecosystems. The techniques also leave farms vulnerable to outbreaks of fish diseases that can result in severe losses in fish production……..”1   and “Where wastes build up beneath and around the cages, this pollutes the seabed reducing the health and diversity of sea life. ….Current fish farming techniques are unable to prevent such damage from occurring and it will take time to develop and implement new farming systems capable of reducing or even eliminating this adverse effect. 2

A costs benefits analysis of socio-economic impacts?

Please note the statement made by SEPA’s Chief Executive in his Foreword, to this consultation document “Aquaculture is an important industry for Scotland, helping to sustain economic prosperity in the rural and coastal communities of the north and west.”3

This assumption, promoted by the aquaculture industry, is based on a number of jobs created as well as profits, which are indeed important. However, this is rarely assessed against the costs of aquaculture to the socio-economic fabric of coastal communities in terms of jobs lost to other fisheries and related businesses. Sea Change would like the Government to investigate the assumption that the socio-economic benefits of fish farming to our coastal communities outweigh the economic costs and impacts on coastal communities. If this remains unquestioned and the longer term costs to jobs and the environment are ignored, then an interim period of expansion may be assumed to be logical, as articulated below by SEPA in the above mentioned consultation document.

“In the interim, because of the economic and social importance of the aquaculture industry, our regulatory framework will continue to permit a controlled zone of impact on the seabed around fish farm cages.” 4
We believe that the focus should be on answering these questions  before expansions are considered, and where failures are identified, reform should be enforced. We hope you will consider these below, as they offer a holistic viewpoint. They may also make clear the costs of salmon farming which might give clarity about where the industry could be encouraged to invest.

Questions specific to Wester Ross MPA

Maerl beds and flame shells have ‘recover’ status and other legally protected species have ‘conserve’ status. SEPAs consultation is on whether deeper water and strong tides mitigate damage. In SNH’s Plymouth University’s Research in “Impact of fish farms on maerl beds in strongly tidal areas” (Vol. 326: 1–9, 2006) MARINE ECOLOGY PROGRESS SERIES. (footnote 5)

Page one of the report summarises the conclusion that the research demonstrates strong impacts on the benthos even in strong tidal areas. With reference to maerl it states:

Visible waste was noted up to 100 m from cage edges, and all 3 farms caused significant reductions in live maerl cover, upon which this habitat depends. Near-cage infaunal samples showed significant reductions in biodiversity, with small Crustacea (ostracods, isopods, tanaids and cuma- ceans) being particularly impoverished in the vicinity of cages, ….. Relocation of fish farms to areas with strong currents is unlikely to prevent detrimental effects to the structure and organisation of the benthos, and ‘fallowing’ (whereby sites are left unstocked for a period of time to allow benthic recovery) is inadvis- able where slow-growing biogenic habitats such as maerl are concerned, as this may expand the area impacted.
Further questions:

  • At what distance from the fish farm cages would added nutrients, faeces and food particles impact legally protected species such as maerl,  flame shells and sea pens? Or even important habitats like sea grass?
  • At what distance from the cages do chemical pesticides impact the surrounding habitat and protected species?
  • Do chemicals stay in the mud and impact protected species such as sea pens or sea weed communities? If so, for how long are the chemicals active?
  • Given that seabed surveys in the MPA are incomplete and on-going and there is expected to be more undiscovered mearl as well as flame shells, what will added nutrients, waste and pesticides mean for these protected species even at a distance from the cages? Is this known by science?

We assume there may already be an impact on maerl, with legal recover status, in Loch Ewe. This is in light of the results of benthic impacts surveys which have lead to a reduction of biomass capacity of the fish farm in Loch Ewe three times. This impact needs urgent investigation given the recover status of maerl.

Before Sea Change could feel there was sufficient evidence of ‘no harm’, we would require a proper baseline sea bed survey of the MPA and answers to the questions we pose in this response. We need long term research on accumulative impacts before expansions are allowed, given that the precautionary principle is required by law if these are unknown.

General concerns about the socio-economic costs of salmon farms
  • Do we know the migratory routes of Salmon smolts? With no location specific detail and limited knowledge of migration routes how can we ensure these farms are away from migration routes so no further harm is done to wild salmon?
  • What are the losses to tourism from the decline in angling on the Scottish coast as a result of the impact of sea lice on salmon and sea trout?
  • What are the job losses and vital ecosystem knowledge lost, as a result of the decline in sea and river angling due to sea lice infestations and changes to genetic integrity?
  • What is the loss to creel fisheries from lost creel ground?
  • What is the loss of abundance of crustaceans (prawn, crab, lobster) due to chemical pesticides? and what is the cost to these fisheries?
  • Do chemicals used impact mussels and scallops?
  • At what distance and for how long do salmon farm nutrients and chemicals impact crustaceans.
  • How long do the chemicals stay in the mud and impact other fisheries (creel and dive)?
  • What is the cost to the wider ecosystem and habitats, as well as spawning grounds and nurseries which support fin-fish fisheries, from deposits of faeces and food particles and the impacts of pesticides?
  • How do salmon farms impact the spawning grounds of particular species such as skate? (Common Skate are on the endangered list)
  • Do salmon farms in warming seas present a risk of more algal blooms? I.e. the risks of extra nutrients or even morts dumped at sea triggering algal blooms or diseases which impact other fisheries?
  • With warming seas how will the industry control disease?
  • What guarantees are there that salmon farms do not exceed the doses of chemicals they claim to use?
  • Are the pesticides ingested by other species and enter the food chain, if so, what risks do they pose?
  • Is there a difference between the jobs promised on application and the actual jobs created?
  • Are profits from Norwegian companies invested in Scotland?

Warming seas and increased storm surges combined with added nutrients in the sea can cause toxic algal blooms. Mean sea temperatures are increasing at about 0.4 Deg C. per decade, making open net cage units more susceptible to algal blooms and Amoebic gill disease (AGD)

Scotland’s fish farms release dissolved nitrogen (as ammonia) and phosphorus (as phosphates) into the sea as well as huge amounts of copper, zinc and dissolved chemicals. The annual amount of phosphate (in fish food ) which enters the marine environment from salmon farming  is equivalent to half of the amount of phosphate in Scotland’s human sewage for a year. In 2016 salmon farms put about 1581 tonnes of phosphate into the sea. see footnote **

Looking ahead: could investment in developing sustainable and ethical closed containment operations in remote rural communities be incentivised so that fish farming can continue to benefit communities without ecosystem damage?
With phosphorus having a finite supply – could it be recycled?

If one looked at the costs above would closed containment look cheap?

It is unlikely that the problems caused by Salmon farms will be solved purely by greater dilution and faster currents. This overlooks some of the more fundamental questions about salmon farms.

Climate and energy costs

SEPA says: “The Scottish Government has a clear vision of ‘an aquaculture industry that is sustainable, diverse, competitive, economically viable and which contributes to food security whilst minimising environmental impact.” (footnote 6)

The government’s vision for minimal environmental impact may be in conflict with the desire to expand farmed fish production on the basis that farmed salmon is a carbon intensive food. The carbon impacts can only increase proportionately under current proposals to locate more and larger fish farms in deeper waters with stronger tides as these are likely to be further offshore and have even higher carbon footprints. We would like to ask SEPA to investigate and publish the answers to these further questions before making a decision to proceed:

  • What is the current total Energy Return On Investment (EROI) of existing open cage salmon farms in inshore areas?
  • What would the EROI be of open cage salmon farms in deeper water?

Does the EROI of open cage salmon farms square with the Scottish Government’s Low Carbon Strategy which is meant to underpin all other national strategies?
According to a study – (Tyedmers, P. 2001. Energy consumed by North Atlantic Fisheries. In ‚Fisheries Impacts on North Atlantic Ecosystems: Catch! ( 7),  Farmed salmon has an EROI of 0.02.  For every 50 calories of energy from fossil fuels used, we get 1 calorie of edible salmon. Industry improvements may or may not have been made since 2001, so this data may not be up to date as a way to assess the EROI of salmon farming to ensure it is a sustainable method of food production, given the priority of climate change.  Accurate assessments needs to include the carbon costs of transport and air miles for importing marine protein and fish feed from around the globe. This also needs to include the energy cost of the fisheries which supply the feed, and the impacts of exploiting ecosystems in other parts of the world.
In addition to this, what is the ratio of fish in to fish out? Is this an efficient use of global resources? If the world is to solve the issue of population expansion, climate change and increasing pressure on resources, we need to focus on low carbon food production that is ethical and sustainable. We therefore need a comprehensive assessment of the EROI as well as other factors involved in production to weigh up the full costs.

Given the proportionately high consumption of energy for every calorie of food produced, the figures does suggest that salmon farming uses more energy than it produces on top of a high carbon footprint if feed is accounted for,  whilst damaging other fisheries elsewhere in the world and polluting inshore sea lochs with organic pollution (faeces and food particles) at home.  Add to that, ever increasing levels of chemical pollutants are being used to combat sea lice and disease amid resistance to treatment of parasitic and viral organisms which is outlined below.

In SEPA’s Corporate Plan 2017-2022, the following statement was made articulating SEPA’s core vision: “Scotland is thriving in a low carbon world”
If the figures indicate that Salmon Farming does indeed fail to meet this goal then the Scottish Government and SEPA should be looking at radical reform rather than expansion of fish farming given that supporting open cage fish farms may run counter to the government’s commitment to sustainability, not just nationally but globally.
Might it not be the case that we would be better off eating the fish caught to feed the salmon ourselves or allowing developing nations to eat their own food?
Below are our answers to the questions SEPA posed when seeking responses to the consultation above.

Question 1 – Do you support the principle of trying to make it easier and more attractive for fish farm businesses to develop in exposed, deep waters with strong tides?

Sea Change would not support this unless adequate reassurance is given to the questions posed here and the precautionary principle applied if these cannot be known. Our MPAs are an insurance policy against the worst kind of ecosystem collapses and they should be sacrosanct.

A recent FOI request (Shuna Cottage) discovered a staggering number of mortalities on a site operated by Marine Harvest for Kames, located on a SEPA disclosure site.  Newspaper articles have also reported a very high level of ‘morts’ – around 10, 000,000 dead salmon in 2016 (estimated at 22479 tonnes) This seems a huge waste of an iconic Scottish species!  Can it be guaranteed that mortalities will never be dumped at sea, potentially contributing to the risk of algal blooms? See  Fish farms in the dock | HeraldScotland

In Wester Ross MPA Scottish Sea Farms shipped tonnes of diseased fish off Tanera farms in the Summer Isles (Wester Ross) during the period in which they were presenting the idea for expansions to the community. It seems warming waters is adding to the risks of salmon farming.

Escapees and risks to indigenous genetic stocks 

Deeper water with stronger currents in more exposed areas where there are severe weather conditions presents a potentially higher risk of escapees. There are already examples of fish farms being destroyed by bad weather resulting in mass escapes. Given that climate change is pointing to more extreme weather it is likely to be a genuine risk. How does SEPA plan to ensure there are no more escapees and how will they enforce meaningful sanctions to encourage fully secure anti-predator nets?

The Scottish Government accepts the science that demonstrates that sea lice from salmon farms impact populations of wild salmon. Increasing the size of fish farms means sea lice larvae have a much higher chance of infesting wild salmon on migration routes and with west coast wild salmon populations plummeting this could be the final nail in the coffin for a species we were once world famous for. Can you be sure this would not be the case?

The charity Salmon and Trout Conservation, sea lice can impact salmon as far as 35 km from cages. Deeper waters and faster tides may not address the issue of sea lice at all, especially as smolt migration routes are still unknown. Larger farms may add to the impact.

Question 2 – What are your views on our proposal to remove the current cap of 2,500 tonnes on the maximum fish biomass that a farm can stock?

This appears to be a very high risk strategy with insufficient information given.
We would like to know what stocking densities SEPA is recommending as a limit to prevent mortality through disease and how regularly SEPA would monitor the quantities of waste faeces, food and levels of chemicals for treating and preventing disease and sea lice, in order to guarantee these were not allowed to accumulate unmonitored.
Reports indicate that levels of emamectin benzoate in sea-bed residues are exceeding environmental standards, as well as impacting other species, whilst sea lice are becoming resistant to it. Ending it’s use leads to a sea lice problem and, as we also have concerns about the impacts of removing large quantities of  wild wrasse from the ecosystem, it is unclear how lice and disease will be managed without damage to wild fish. In light of recent information on pesticide impacts (referred to in the points below) it seems an odd time to be considering licensing expansion rather than limiting or banning this pesticide’s use.

Question 3 – Do you support our proposal to allow fish biomass to increase by up to 10% per production cycle, provided compliance with the proposed seabed standards is not threatened?

Newspaper reports have indicated that environmental standards have been broken repeatedly. Can SEPA supply evidence that it has studied the conditions around fish farms for a long enough period of time to be confident that expansion will poses no threat to the environment?

Anecdotally, lobster and crab creel fishermen have reported lower catches when fish farms are in the area, as have scallop divers and in other area’s mussel farmers have too. Can this be investigated?

For example does SEPA know how long chemicals used stay active in water, mud or the sea floor, and how much they impact the food chain or the salmon itself? If we are not aware of these impacts, then the precautionary principle under the OSPAR agreement would be the only legal response.

There is some distrust around whether EIAs are adequate and some existing farms do not even have them. Until this is rectified the public cannot be sure that compliance means what it says.

Equally, the proposal could mean enormous fish farms 6-8000 tonnes (Norwegians by contrast limit their own farms to 1000 tonnes due to concerns about waste) and in light of the questions posed it is hard to see how larger farms can meet the demand for sustainability.SEPA’s own specialist called this ‘utterly unsustainable’. see Footnote 8
HeraldScotland Outrage over secret plans to base world’s biggest salmon farm in Scotland |

It is relevant to note that most multinational salmon farming companies are Norwegian. It would be interesting to know where taxes are paid and profits invested. In Norway they limit their biomass capacity to 1000 tonnes, why not in Scotland?

Question 4 – What are your thoughts on our proposal that, for DZR sites, we will take on responsibility for monitoring the effects of the farms on the seabed?

SEPA needs to take on the monitoring for ALL fish farms. However, first the Government needs to restore public faith that salmon farm can and will meet environmental standards.

To enhance transparency and public trust could SEPA make it compulsory for salmon farmers to produce a public annual statement declaring their approach to disease and lice control, and numbers of employees as well as proposed developments. This would aid public accountability as well as regulation.

It has been reported in The Sunday Herald that SEPA was considering a ban on the use of Slice, (emamectin benzoate) but bowed to pressure from the Scottish Salmon Producers’ Organisation that doing so would undermine commercial confidence.

The Scottish Salmon Company PLC’s report of August 29 2017 stated:“In June SEPA, the environmental regulator in Scotland, published a report for consultation making recommendations to reduce the volume of SLICE (emamectin benzoate), an approved treatment for sea lice. While SSC is proactively engaged in industry projects to develop alternative treatments, SLICE currently plays a vital role in controlling naturally occurring parasites. SSC is working closely with the industry body, the Scottish Salmon Producers’ Organisation (SSPO), to respond to this consultation and will challenge these recommendations where necessary to avoid excessive regulations that unnecessarily hamper industry production and growth.”

SEPA is between a rock and a hard place. In-feed pesticides and bath treatments are reported to be highly toxic and impact other fisheries, and the communities around Wester Ross MPA rely more on fishermen such as creelers and divers, as well as tourism and anglers, than fish farms so this is significant.  Especially given there have been reported breaches of (CAR) licences due to pollution but no prosecutions.

The research “SARF098: Towards Understanding of the Environmental Impact of a Sea Lice Medicine – the PAMP Suite”, flags up the issues.
The PAMP2 (SARF098) study indicates that emamectin benzoate (fed to fish and toxic to crustaceans) damages sea life and spreads further from fish farms than previously considered likely, staying in the sea bed for longer too. The study also reports that emamectin benzoate remains in the fish itself and takes months to excrete.
WRC plc’s Review of Environmental Quality Standard for emamectin benzoate, February 2017 says on page 22 of the report “ It is of note that between 2002 and 2015 the amount of biomass in Scottish fish farms has doubled whereas the total mass of emamectin benzoate used in Scottish fish farms has increased six fold over the same period.”

It also says the chemical is detected in treated fish and takes 3-4 months to lose half its toxicity once it reaches the seabed.

see link:
Two papers accessed by the Freedom of Information Act (June 2017) are revealing.
Refreshment Study – SEPA Response Options.
2- SARF098 PAMP Refreshment Study – SEPA Response Options paper- draft
The quotes below are taken from them.
In the SEPA report FoI: SARF098 PAMP Refreshment Study – SEPA Response Options Paper – DRAFT released by SEPA June 2017, an aquaculture specialist wrote:
The arena in which these products are deployed has however changed, resistance in sea lice to the available actives is not freely admitted by the sector but is evident from patterns of medicine use.”
“….…in almost all cases, higher than standard dose rates are being used … this usage coupled with the long half-life leads to a circumstance where the product is almost continually present in the seabed around farms.
‘…the waters in which salmon farming is practiced are usually the same waters in which Scotland’s valuable crustacean fisheries are located…
‘…it is not tenable for SEPA to adopt a position where commercial shellfish species are impacted by the day-to-day activities of fish farms, activities which SEPA will have knowingly authorised …..SARF098 reveals that there is a significant risk of failure to provide such protection.”
It concludes
” In light of the imminent publication of the SARF098 report is recommended that SEPA put in train a process to withdraw the use and discharge of Slice at fish farm premises in Scotland”

The recommendation was that SEPA should withdraw emamectin benzoate (the active ingredient in SLICE) from use due to problems of enforcement as well as its toxicity. “we come to the option of withdrawing the product from use in Scotland. For the reasons discussed above, it seems that this is the only practical means of securing the ongoing health of crustacean populations in Scottish coastal waters.”  and “… we have a situation where the use and discharge of a chemical has led to widespread impact upon a substantial and important part of the marine benthos.”  It is difficult to see how we could continue to sanction the use of Slice in the face of the evidence that is presented and in the absence of a significant programme to re-design our licensing system. Should it be proposed to undertake such a re-design, it would seem imperative to withdraw Slice from use until such time as that review was complete.”
‘As the likely outcome of the re-design will be a tighter environmental standard with likely recommendations on limits on use to perhaps once per growth cycle, the medicine would no longer be practically useable on any fish farm in Scotland.’
An exponential rise in the use of pesticides is reported in the Times, this is a quote from the article : “The use of toxic chemicals to fight sea lice on Scottish salmon farms has soared by almost 1,000% in the past decade, according to official data that has sparked fresh criticism of the billion-pound industry. Between 2006-16, farmed salmon production increased by 35% while the use of chemicals to control flesh-eating lice rose 932%.” (footnote 9)

Given this evidence  how will the Government ensure that safe levels for the use of such a long-lasting, highly toxic chemical are set and kept? Research is needed on the long term economic costs and environmental impacts of continued use of this pesticide on the wider economy and the ecosystem itself.

This concern for  west coast fisheries is is underwritten by the warning in the research below: lethal-to- crab-larvae/
Published in July 2017 in Chemosphere 185 (2017) 1019-1029 called Lethal and sub-lethal effects of commonly used anti-sea lice formulations on non-target crab Metacarcinus edwardsii larvae.

Highlights of the research are below:

  • Cypermethrin, deltamethrin, and azamethiphos affected 100% crab larvae at concentrations lower than used against sea-lice.
  • Hydrogen peroxide at the concentration used as an anti-sea lice treatment had lethal and sub-lethal effects on M. edwardsii 164 zoea I.
  • Repeated exposure to azamethiphos (0.0625–0.5 μg L /−1) increased mortality, but did not affect zoea I developmental time.
  • Chronic exposure to hydrogen peroxide (187.5–1500 mg L / −1) had a lethal effect on larvae.

It appears that these toxic substances kill crab larvae at the doses used in fish farming. Has research been done on the levels of these pesticides used in Scotland and the impact on prawn, lobster as well as crab? We also do not know the long-term effects of pesticides on scallops and mussels. Again, anecdotal reports suggest that the farms may be impacting stocks. These shellfish are critical for each and every community on our west coast. This raises very significant concerns about whether these chemicals might enter the food chain and bioaccumulate. As a volunteer community group we cannot investigate the impacts as they apply in the specific circumstances of our MPA, but these reports have such serious implications we feel it requires a full and independent review of the use of chemicals in the industry as a whole, particularly its use of pesticides, for the sake of public health as well as other fisheries.
Chemicals such as TBT and PCB are all chemicals used which in hindsight would not have been licenced, or at least would have been carefully controlled. We therefore ask for the application of the precautionary principle until this review is complete and for their use to be banned immediately in sensitive areas such as MPAs. The evidence we have seen would suggest a very knotty problem given the need to withdraw this product to protect local fishermen who fish for crabs, lobsters and prawns in areas close to fish farms whilst also finding a way to protect wild fish from sea lice.

SEPA’s role is to protect the public by regulating industry.  SEPA should take full charge of monitoring all salmon farms with unannounced spot checks on existing farms before any expansions are considered. There is also concern in light of recent articles in Ireland in which allegations were made against Marine Harvest suggesting that stock densities exceeded the agreed level by 26% but would be hard to prove in court. Can SEPA be sure that this is not the case in Scotland and the salmon farmers are not taking advantage of a difficulty to take issues to court? The Sunday times (Ireland edition) article is below

It most onlookers it would appear that self regulation has failed.

Question 5 – What are your views on our proposal that there should be a break in production if seabed standards are breached to allow the seabed to recover?

We would agree to this as long as monitoring is done by SEPA and there is a commitment to regular checks and an end to self-regulation. Stock density also requires monitoring and regulating.

Question 6 – What are your views on our proposal that, under DZR, the maximum area of seabed that can be affected by the deposition of farm wastes would be standardised to 0.5 km2?

Given the questions we have  raised above, much greater research and monitoring by the regulatory industry is needed before expansions can be endorsed on the evidence.

Question 7 – Are there any other comments or suggestions you would like to make about the proposals?

Cetaceans already suffer from a wide range of impacts such as ingested plastics, toxicity (PCB’s), sound pollution and entanglement. We have a responsibility to these highly intelligent creatures to do no more harm. Their attraction to tourists also has a significant economic implication in Wester Ross. Sea Change sees the potential to build our MPA’s reputation as a destination for nature tourism based in part upon the attraction of marine mammals. Fish farms are obvious visual signs that the sea is less than pristine and is not generally what visitors expect in a ‘protected area’.  More importantly, if farms use acoustic deterrent devices, they impact cetaceans, dolphins and porpoise.. Popularity of the area for tourists interested in these species rely’s upon Tourist safari boats sightings of marine mammals as well as sightings from the land too. Studies show that porpoise are disturbed even several kilometers away from ADDs.The European Protected Species, Habitats Regulation 39, states “It is an offence to deliberately or recklessly… disturb any dolphin, porpoise or whale (cetacean).” It is also a violation of Article 6(3)of the EU Habitats Directive. (Footnote 10)

Equally, seals tend to be shot to protect the fish rather than build really secure cages. Seal colonies in the Summer Isles are part of safari boat tours so whilst we acknowledge population issues, shooting them may not be the best response in the MPA given The Marine (Scotland) Act 2010 states that seals should only be shot ‘as a last resort’.

It would solve the problem if it could be made compulsory to fit strong netting in all existing farms as well as any future ones.
Concerns about Pacific, pink or humpback salmon as an invasive species on the east coast which may be escapees is a problem that needs monitoring. Can we afford further stresses on this iconic wild fish? See article: Are pink salmon colonizing Scottish streams? | Far North Science

Recent acknowledgement by SEPA of some of these impacts comes late in the day for those who have been reporting these impacts for decades and being largely ignored. Can SEPA restore public faith in the compliance of Salmon Farmers? If expansion proceeds without the concerns and questions above being addressed, trust could be lost for good.
Is there any reason why there is no encouragement or incentive from the government to explore land based closed containment, with proper consideration of stocking density and animal welfare concerns and where nutrients can be recycled, rather than continue expansion in the sea? Could SEPA support the development of closed containment systems on land which would comply with environmental standards and provide food security without use of toxic chemicals that end up in the environment? It might be the cheaper option in the long run. We would encourage the Government to look at reform before considering expansions into deeper water with bigger farms.

Most importantly, if we are to create real sustainability and avoid food shortage with an expanding world population we need to improve the EROI of all food production: we cannot continue to wreak havoc on our environment without ultimately harming ourselves.

Given everything outlined already SEPA’s statement below under the heading ‘Making it easier to develop farms in exposed sites’ under point 2.2 in “ Regulation of Marine Cage Fish Farms: Updating our approach to protecting the sea bed” gives cause for alarm. The nub of the consultation seems to suggest that the idea is to create enormous farms as is hinted at here: “There is potential to farm a much greater biomass of fish in these exposed locations than is currently farmed at any farm in Scotland”
and “Exposed waters with strong tides are better able to cope with fish farm waste than shallow, sheltered parts of the coast. However, the risk assessment methods that we have used to date when evaluating proposals for farms in exposed waters have tended to overestimate the environmental risk to the health of the sea bed. This has had the effect of constraining the size of farms (in terms of fish biomass) that we have been able to authorise in such waters.”

Should this not read underestimate?
Some of the questions as well as the research has been supplied by a handful of dedicated individuals around Scotland and Wester Ross who make up a network of people within coastal communities concerned about Aquaculture. These people are willing to trawl through massive amounts of research in order to supply concrete examples for the kind of concerns discussed within groups such as Sea Change. We are grateful for their help raising these questions.
The questions have been compiled because of our commitment to protect the sea in our area. We believe it is essential to resist pressures to deliver short term economic benefits at the expense of other fisheries and the ecosystem. We seek to learn from history and avoid hubris on all sides of the debate in order to work together to discover a way to build on what is good for jobs, profits and the planet.  Political expediency does not outweigh the legal necessity for the precautionary principle. We share these points to help find solutions to the issues and hope you will take the time to examine these questions,

Yours sincerely, Members of Sea Change Wester Ross

 1 Foreword, “Regulation of Marine Cage Fish Farms: Updating our approach to protecting the sea bed”, Terry A’Hearn, SEPA Chief Executive

2Regulation of marine cage fish farms Updating our approach to protecting the sea bed page 6 (c) New depositional zone limits

3 Foreword, “Regulation of Marine Cage Fish Farms: Updating our approach to protecting the sea bed”, Terry A’Hearn, SEPA Chief Executive

4 Regulation of marine cage fish farms Updating our approach to protecting the sea bed page 6 (c) New depositional zone limits
 * * Scottish demography and the UK government food survey data with USDA and Danish agriculture department chemical and energy analysis of foods - original calculations done by John McIntyre.
 5 In SNH’s Plymouth University’s Research in “Impact of fish farms on maerl beds in strongly tidal areas” (Vol. 326: 1–9, 2006) MARINE ECOLOGY PROGRESS SERIES. Jason Hall-Spencer1,*, Nicola White2, Ewan Gillespie3, Katie Gillham4, Andy Foggo1

6 Foreward by Terry A’Hearn SEPA Chief Executive Regulation of marine cage fish farms Updating our approach to protecting the sea bed

7 Tyedmers, P. 2001. Energy consumed by North Atlantic Fisheries. In ‚Fisheries Impacts on North Atlantic Ecosystems: Catch! Effort and National/Regional Datasets‚ (D. Zeller, R. Watson! and D. Pauly, Eds.), Fisheries Centre Research Reports 9(3), 12
8 Outrage over secret plans to base world's biggest salmon farm in Scotland | HeraldScotland

9 Salmon industry toxins soar by 1000 per cent | Scotland | The Times The Sunday Times

10 ADDS are unlicensed and in breach of Habitats Regulation 39 and Article 6(3) of the EU Habitats Directive: says “Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.”

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