To the Rural Economy and Connectivity Committee (RECC) on Salmon Farming In Scotland

To consider the current state of the salmon industry in Scotland, identify opportunities for its future development and explore how the various fish health and environmental challenges it currently faces can be addressed.

Response submitted by Sea Change Wester Ross to the committee on the 27th April 2017

(Please note the first section of this report summarises the evidence on the environmental impacts of salmon farming and gives the context for the socio-economic study based on our argument for building an alternative economy   –  the second section of the response also attached as a PDF link is the socio-economic report exploring a case study on an open cage salmon farm proposal in Wester Ross MPA)

Sea Change Wester Ross emerged as a community group set up to protect Wester Ross Marine Protected Area (MPA) and give the public a voice for improved management of the marine environment. We speak for those in the community who care about the potential for the recovery of the ecosystem, the coastal economy and the fisheries,  which are all interconnected. Since dredgers were banned, Sea Change has evolved into a think tank making our own conclusions on scientific and government papers. These are often different from the prevalent industry view, and sometimes also that of their authors. The context for our concern is that the greatest challenge humans face is to find solutions to rapid population expansion and an equally rapid loss of biodiversity combined with over fishing, warming seas and ocean acidification.

The Environment, Climate Change and Land Reform (ECCLR) Committee produced a report on the environmental impact of salmon farming in Scotland.  The accumulated evidence in this report, along with other submissions to the RECC underwrite our concerns and demonstrate beyond any reasonable doubt that open cage salmon farming has a negative impact on the marine environment. 

 The many risks outlined in the report provide the Scottish Government with a warning: to proceed would be irresponsible as it risks damaging other fisheries and businesses which help the economy in the Highlands maintain some diversification.

The only logical way forward for the industry is to move to land-based closed containment salmon farms, with fish welfare standards considered. To promote this the Government could give incentive payments to encourage location in remote areas to support communities, and to help the industry develop this technology so that it genuinely is sustainable.  

The October 2016 Government and Industry Aquaculture Growth Plan to broadly double production by 2030 is not a viable option. It is neither sustainable nor likely to produce more jobs in the longer term, given the cumulative impacts. It is illogical to try and feed the world by undermining the ecosystem. The only way we will feed the world is to encourage the ecosystem’s restoration and to support land based aquaculture which allows other truly sustainable fisheries to also provide food.

The Government’s intention to double salmon farms also ignores the limits of the ecosystem and the cumulative impacts it can absorb. Coastal economics in particular cannot be separated from the marine environment yet many reports we have read focus exclusively on benefits to one industry and assume limitless capacity. Those of us in the think tank have an alternative coastal economy in mind – one built on an understanding of the interconnections within the ecosystem and true sustainability. This alternative economy would work with nature to build on the positive benefits restoration affords. Alistair Sinclair of the Scottish Creel Fishermen’s Federation (SCFF) (the creel and dive fisheries) has spoken of a vision for an alternative coastal economy built around support for high value, low impact fisheries. We whole heartedly support this and it is with this in mind we outline our 2018 Socio-Economic Review of Wester Ross which explores a specific case study and outlines the elements of this alternative economy. The socio-economic report follows this overview.

Our report is based on a specific salmon farm proposal by aquaculture company Scottish Sea Farms Ltd (SSF), which is currently at the scoping stage. The intention is to site this in the heart of the Summer Isles Archipelago which is within the Wester Ross Marine Protected Area. The MPA designated was given because of the area’s high levels of biodiversity and widespread maerl beds. Our 2018 Socio-Economic Report is based upon our former Socio-Economic Report presented in 2015 (this in turn was based on the North-West Sea Lochs and Summer Isles BRAI). We ask that you take our report into account, despite the length, as the research is as thorough and accurate as time allows. We recommend the Government commissions a full review based on the questions raised here, as well as reform of salmon aquaculture before any expansion in Wester Ross MPA is considered.

The 2018 Case Study Chosen

Our Socio Economic Report outlined below is based on a case study of a new salmon farm proposal in Wester Ross Marine Protected Area. This is considered within the context that there are 3 new or expanded salmon farms currently in scoping within the Wester Ross Marine Protected Area. However the study focuses on one particular new farm proposed by Scottish Sea Farms at Horse Island as an example of expansion leading to 3-5 new jobs.  It explores the potential negative and cumulative impacts, where possible on other coastal jobs and income.

In order to understand the figures and data in the socio-economic report it is necessary to fully describe the situation locally in order to make the logic behind the figures, transparent.

There are short term gains to be reaped from doubling of salmon farms and these may appear attractive. However the depletion of the environment on an industrial scale by multi-national salmon farm companies is on top of damage done by the mobile fishing sector (trawl and dredge).  This cumulative impact cannot be ignored, as the ecosystem does not operate in isolation of different economic sectors. With this in mind we ask for the RECC’s Review to be a turning point with regards to the Marine Protected Area Network and specifically Wester Ross MPA. In our view the Scottish Government needs to urgently amend National Marine Planning guidance, so there is a presumption against any future salmon farming developments inside Marine Protected Areas.

We are told salmon farming supports an otherwise fragile economy in the Highlands. The Highlands does indeed need jobs. The question is rather what kind of jobs and what economy is best to build?  Our report hopes to provide some answers with regards to the alternative economy we envisage, which would be preferable to an economy based on salmon farm expansion at the cost of many other business potential.

We would like it noted that we are unable to extrapolate the full future benefits to the alternative economy that we believe would be possible if a robust recovery in the MPA  was supported and if the ecosystem and fisheries were properly protected and able to return to a previous, more abundant, baseline. (Which new salmon farms in the area, would be undermining). Recovery over a number of decades is difficult to predict. However it is important to start because this alternative economy is more likely to reap a sustainable future and we cannot allow this to be undermined by more salmon farms which deplete sea trout, wild salmon, creel and dive fisheries. It also negatively affects  tourism,  other finfish fisheries as well as nursery and spawning grounds. Given that the future benefits of a full regeneration of the ecosystem cannot be assessed in Our Wester Ross Socio-Economic Report – the focus of this study is on the more immediate impact of our Scottish Sea Farms case study below.

It is important to note that it is this future potential which is really at stake if the policy to expand salmon farm goes ahead, particularly in MPAs. Well protected MPAs around the world have been proven to produce great economic benefits. Importantly it is the well protected aspect which is the key to producing this benefit. We want Wester Ross MPA to be able to demonstrate this full benefit, and if it proves successful it can be modelled across the west coast. Therefore we hope our Socio-Economic Report below serves, in part, as a microcosm for other areas and helps support an economy based on real sustainability for the sake of generations to come.

In addition, our Socio-Economic Report questions the assumption that we need open cage salmon farming for jobs. Whilst there is uncertainty about the exact figures, we believe that more salmon farms will produce a negative impact on jobs. Set this against the other global impacts of the industry and the environmental costs of feed and the global carbon  footprint of salmon farms – an alternative economy, as outlined in Sea Change’s response looks very attractive indeed.

Marine Scientist, Professor Callum Roberts has this to say on salmon farming.

“The multiple environmental problems associated with open-cage salmon farming have been thoroughly established by scientific research. Individually, many impacts represent a serious risk to the conservation objectives of marine protected areas. Collectively, they guarantee an unacceptable level of impact. Open cage salmon farms are incompatible with the conservation objectives of protected areas and should not be sited within them.”

The report by Highlands and Islands Enterprise (HIE) and Marine Scotland called The Value of Aquaculture to Scotland (June 2017) assesses ‘impacts’ but these are in fact benefits and there is almost no focus on costs to the economy from the displacement of creel and dive fisheries or other environmental impacts on wild finfish fisheries and tourism. The assumption is made over and over again in reports like these that open cage aquaculture provides a range of social and community benefits to fragile and remote areas where salmon farms and related activities are located.

Not one report to date has balanced these benefits by looking at the often subtle and slow accumulation of COSTS to other business enterprises and incomes. We hope to provide at least a good first attempt at evaluating these very real costs.

The north west of Scotland has the most concentrated salmon farm production. The Highlands and Wester Ross MPA is in this region and are therefore most at risk from this expansion. Reports that advocate salmon farm expansion never acknowledge that this region contains vulnerable habitats or other species of socio economic importance. Wester Ross MPA was established to protect and recover maerl; a species known to be very sensitive to impacts of salmon farms.   Quoting from HIE’s report The Value of Aquaculture to Scotland Report (2017,  1.1.5. “Social and Community Impacts”):

:

“The employment that the sector provides in rural areas has helped to compensate for long term declines in agriculture and fishing employment as these sector have increased their productivity, whilst yearround employment offered by the sector has contributed towards the sustainability of family livelihoods, with tourism and agricultural employment in rural and remote areas highly seasonal. “

It is true that jobs are needed outside of seasonal employment and salmon farms do provide this – but it is economical with the truth. It does not explain that salmon farming has in part contributed to this decline with creel fishing and a great deal with sea trout and salmon as well as others fisheries. It also does not mention that these fisheries are vulnerable already, and we are currently fishing the bottom of the food chain. The HIE report does at least acknowledge the problem of sea lice on wild fisheries (item 1.1.8) yet not nearly enough given that the Salmon Fishery Stats for 2017 report that catch is 80% of the previous 5-year average and this is the fourth lowest on record.

If the wild fisheries were restored and a full recovery was supported by the Government this valuable wild fishery could help bring back many jobs to the region and could match the number of jobs supplied by the increasingly mechanised salmon farms – but in an ecologically sensitive manner. http://www.gov.scot/Publications/2018/04/2149/1

The HIE report suggests salmon farming compensates rather than adds to the decline of some of the other industries in the area. This is simply not factual.

FERGUS EWING HAS OVERLOOKED THE EVIDENCE

Fergus Ewing the Scottish Government’s Cabinet Secretary for Rural Economy and Connectivity does not seem to have these other coastal businesses in mind. At the Seafood Expo in Brussels on the 24th of April 2018 he ignored all the evidence of the ECCLR Committee report (unless he has plans for insisting upon closed containment) saying to salmon industry leaders:

‘I’m determined to give what leadership I can to make sure that no matter what challenges are thrown at it you double growth.’

https://www.fishupdate.com/minister-champions-salmon-sectors-growth/ https://www.fishfarmingexpert.com/article/cabinet-secretary-we-fully-support-2030- growth-plans/

From the point of view of an observer looking at the facts at a local level this looks like regulatory capture, even if well intentioned. In our opinion this policy is misguided and does not serve the public interest unless Mr Ewing does indeed intend to support a move to land based farms.

In the HIE report under the heading “Summary of Challenges and Opportunities” (1.1.6)  it mentions the loss of jobs to mechanisation:

Creating additional relatively skilled and well paid jobs……as the sector grows through a transition from manual work to supervisory and technical roles as mechanisation increases – particularly in processing.”

In other words expansion creates more environmental damage for less jobs and the northwest Highlands pays the price. In Wester Ross Scottish Sea Farms (SFF) cannot recruit enough staff from within the community and there have been recent departures of senior local staff. Often skilled jobs are brought in from outside of the area. There is no problem with that, but the alternative economy we speak of builds and expands upon the skills of existing local populations. One salmon farm might add a few jobs but a sea-safari business based on nature tourism or a cottage industry making crafts for tourists might add just as many jobs without damaging the environment and impacting other businesses. Scotland should not allow large Norwegian multinationals to exploit Scotland’s natural assets with little concern for these jobs.

The HIE report on The Value of Aquaculture To Scotland which looks at impacts, published in June 2017 must have been written around the time Scotland’s salmon and trout farmers were having to dispose of a record-high volume of 22,479 tonnes of dead fish in 2016 – so it appears that just as the industry was planning expansion, somewhere between six and ten million fish were being slaughtered. Quoted here:

This study report provides material that will help inform the considerations of the newly formed Aquaculture Industry Leadership Group (AILG) and complements the industry-led strategic plan, “Aquaculture Growth to 2030”, published in October 2016, which sets out the industry’s objectives and aspirations for growth (broadly to double production by 2030)

This astonishing number of mortalities in 2016 was widely reported in various newspapers only much later in 2017 .

On the 5th of October in 2016, the day Scottish Sea Farms held a community meeting in Wester Ross to announce their expansion plans for a new farm of around 2000 tonnes at Horse Island and an expanded farm at Tanera East ( an amalgamation of existing smaller farms into one larger farm) it shipped around 30 tonnes of dead salmon off the farms.  According to eye witnesses, this made a stinking slimy mess of the local harbour which is used by creel boats and the local sea safari boats too – so visible to tourists. 25% of Scottish production in this year ended up incinerated. In other words it became rubbish. This was not intentional but this is no way to feed the world. Fish farm mortalities hit unwanted record in 2016. (Ref FishFarmingExpert.com at https://www.fishfarmingexpert.com/article/fish-farm-mortalities-hit-unwanted-record- in-2016/)

We believe the HIE report on impacts (June 2017) is inadequate for decision making. It has a flawed and unexamined premise and the evidence is partial throughout. It spends 95% of the time on Industry benefits and gives a very cursory glance at the costs. This is partial and unfair. It cannot be used to make sound judgements, particularly when these judgements impact many other local people. The  glossing over of costs suggests it has fallen for Industry PR.

One of the environmental impacts it overlooks is outlined in the PAMP2 study (SARF/SAMS) which found that at sites in Shetland(the only place where there was enough data to test this) the use of emamectin benzoate correlated with a mean drop in crustacean numbers and abundance by an average of about 60% outside the Allowable Zone of Effect (AZE) so very far from the fish cages. (and to perhaps 3/18 of its normal abundance in the most extreme examples). Prawns, crabs and lobsters are vital fisheries on the west coast. This is highly significant. Not only that, these toxic chemicals may stay in the environment and accumulate higher up the food chain.

A research paper from Chile 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”, backs up the argument that chemicals used in the salmon farming industry  have impacts on larvae of commercially-fished crabs. https://www.fishfarmingexpert.com/news/recommended-lice-drug-doses- lethal-to crab-larvae/

In the Scottish Environment Protection Agency (SEPA)’s own internal report Options Paper (FOI) Q1 4-2, 132, released in June 2017, an aquaculture specialist wrote…

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 under CAR

‘Indeed, one of the significant considerations and drivers of the authorisation process for all sea louse medicines has been the protection of commercial shellfish species, SARF098 reveals that there is a significant risk of failure to provide such protection.’ 

THE REGULATORY REGIME: INDUSTRY SELF REPORTING

The regulatory regime is not sufficiently robust.   It relies on self reporting and has no individual farm by farm lice reporting. It fails to monitor the use of toxic chemicals and there have been no prosecutions or penalties for known violations.  Inevitably there is little trust in the government’s willingness to hold companies to account. Furthermore as the ECCLR enquiry heard, both the autoDEPOMOD model and newDEPOMOD models are inadequate to assess impact in an MPA with maerl beds.

Only hydrodynamic models are able to assess cumulative impacts in anywhere near the degree of accuracy needed to understand the risks to other jobs and fisheries on the west coast with multiple salmon farms in the area.

INADEQUATE MODELLING OF IMPACT

In the Argyll and Bute Council’s submission to the ECCLR committee they note that all of the consents that have been granted to date depend on an outdated model of deposition (autoDEPOMOD) that does not deal effectively with deposition in areas with irregular topography or high currents.

 IMPACT ON CREEL FISHERIES

There are two or three open cage salmon farms in scoping proposed within Wester Ross MPA to add to the 7-8 active existing farms within the Marine Protected Area (not to mention those on the borders which add to the cumulative impact). The ground taken from creel fishermen at the heart of the Summer Isles is highly significant to these fishermen’s incomes especially as many of these are proposed within some of the best prawn fishing ground. These farms in total amount to over 100 hectares in size and this is just the ground that is taken by the cages and moorings. This does not include the Allowable Zone of Effect nor the unknown impacts outside of this which SEPAs existing model is unable to determine.

The Extract below is taken from the ECCLR report from the Scottish Creel Fishermen’s Federation (SCFF)

The Scottish Creel Fishermans’ Federation highlighted concerns about the cumulative impacts of several farms in inshore areas and the impact of biomass and accumulation of waste. In written evidence they state that the total mass of emamectin benzoate increased six-fold between 2002 and 2015. They are concerned about the impact of this on arthopods (including prawns, lobster, crabs) and state the long-term effects of neurotoxin pesticides on scallops and mussels remain ill defined. Scallop stocks appear to be declining in areas with salmon farms. They also have serious concerns on the impact of anti sea lice formulations on target crab (metocarcinus edwardii). They consider there is too little independent research on bio-accumulation and on the longer term effects on inshore water ecosystems.

Sea Change Wester Ross fully supports this statement because of an increased likelihood of a toxic algae bloom due in part to increased water temperatures combined with added nutrients. Add to this concerns about sediment and chemical impacts on shellfish as well as the impact on habitats like maerl which are supportive of scallops, and other fisheries (finfish), then it becomes clear that these expansions undermine creel ground and deplete hand dived scallop jobs in the area. This costs local communities. Whilst with salmon farming the financial value is transferred to mostly foreign multinationals.

The vast majority, nearly 90 percent of fishermen, are inshore. According to SCFF creel boats make up 80% of the 1452 small fishing boats in Scotland’s inshore commercial fishing fleet which generated £40.98 million for the Scottish economy in 2015.  Most of them work on the west coast sea lochs and inshore waters, most often in remote communities. For every boat it is estimated 3-4 permanent jobs are created in the supply chain. Just one large salmon farm can impact many fishermen across a wide area.

The Scottish Sea Farm proposals examined in our chosen case study are directly on prime creel ground. See the chart below showing the proposed farm at Tanera East and Horse Island sites with creel fleets marked.

Toxic chemicals degrade fisheries in sometimes subtle and invisible ways. How much they do this, is still an unanswered question. Recent modelling shows that gross deposition can take place 3 or 4 km away from the farm. It would be utterly irresponsible to proceed with the farms above.  Land Containment may be the only solution. At the very least this option must be fully explored for viability.

IMPACTS 3-4 KM FROM THE FARM SITE

I would like to refer to a report, ( which is given much fuller treatment in Sara Nason’s personal response to the REC Committee Enquiry ) Her response outlines in much more detail the impacts of salmon farms on maerl which were the conclusions of the research undertaken by Plymouth University working with Scottish environment agencies and Marine Harvest, ” Investigation into the Impact of Marine Fish Farm Deposition on Maerl Beds Commissioned Report No. 213  (2006) (Research commissioned by SNH, SEPA and Marine Harvest..  Wester Ross Marine Protected Area was set up to legally protect maerl beds in order that they recover.

This research shows that the study was not designed to assess impacts on maerl beyond 100m. So it remains unknown if impacts extend beyond this distance as the research did not measure beyond this. To quote the report,

“ It should be noted that these distances represent the outer survey points on those transects and therefore it is likely that the footprint extends beyond this distance”

Hydrodynamic modelling of cumulative impacts will be a better way to model the impacts of multiple salmon farms in an area.  Even then the research is insufficient as it does not model impacts specifically on maerl beds which are highly sensitive. It is clear that the chemical and sediment impact of salmon farms can be at very great distances from the actual salmon farm site so this cannot be overlooked.  Maerl is legally protected and it must be able to recover, so no impacts are allowable. Yet salmon farms are still trying to locate themselves in a Marine Protected Area set up to recover maerl, and close to them. This is whilst the extent of maerl beds is still being found and mapped and what is under the waves is not fully known.  (Sea Change Wester Ross surveys have made many discoveries reported on elsewhere)

Equally extra nutrients in the water from salmon farms are not only likely to impact sea grass which impacts fisheries (as a habitat that supports biodiversity) but these also add to the possibility of algae blooms which impact shellfish – and there is no research on nutrient impacts on maerl as far as we know.  This is a gap which needs closing.

There is no research that indicates what the safe distance of a salmon farm from a maerl bed is. So the precautionary principle must apply.

New or expanded Salmon farms will undermine the restoration of finfish fisheries and angling, creel and dive fisheries as well as nature and marine tourism which could become the building blocks for an alternative economy. This potential to regenerate an economy in a truly sustainable manner would be lost in the drive for ever larger salmon farms, combine this with the existing impacts of the mobile sector in inshore waters and it is a recipe for erosion of wealth and long term economic decline.

IMPACT ON FISHERIES AND CONSERVATION FEATURES

The SAMS report (Review of the Environmental Impacts of Salmon Farming in Scotland 02468_0001, Issue 01, 24\01\2018) which was submitted to ECCLR to begin the Parliamentary enquiry,  points out in Salmon Farms and Conservation Features: (page 79.)

Richard Luxmore of the National Trust for Scotland says:

“with Reference to SARF 046 (the proximity of fish farms to protected features) predates the establishment of MPAs and there is virtually no consideration of this important impact. The mention of SEPA having “addressed Priority Marine Features (PMFs) and Marine Protected Areas (MPAs) with respect to fish farming in its interim EMB policy statement” is simplistic as it only addresses one aspect of the impact and, moreover, there is evidence the implementation of this guidance by SEPA has been inconsistent. The (SAMS) review has made no mention of the work by SNH and Marine Scotland in assessing the potential impact of aquaculture on PMFs (through the FEAST tool). This is an extraordinary omission, particularly in view of the urgent need to review this guidance.”

Research that assesses the sensitivity of priority habitats and Priority Marine Features (PMFs) to the effects of aquaculture is extremely limited. The report also points out that the greatest concern is for burrowed mud habitats containing sea pen and burrowing megafaunal communities, flame shell and maerl beds. (Burrowed mud is a habitat for the prawn or langoustine fishery) Given the inaccuracies of the dispersion modelling as well as the uncertain knowledge of rates of decay, (which may vary substantially according to chemical and physical conditions) and the lack of knowledge of the bio-accumulation in the ecosystem, it is clear the precautionary principle must apply. EMB decays only slowly in sediment; it is especially toxic to crustaceans, but affects physiological processes more widely.

WESTER ROSS AND MAERL

Wester Ross  is a Nature Conservation MPA with Maerl beds. Maerl is highly sensitive to sediment smothering from salmon farms. 

Wester Ross is unique because it is one of just a handful of MPAs which has full protection from dredgers, it is also the largest of the 2014-2015 raft of ‘maerl’ MPAs which were designated to recover maerl. Maerl beds are widespread across the whole MPA. It is to be noted that species of conservation importance which are protected in the MPA, often derive their importance from the fact they support high levels of biodiversity and are nursery grounds for a wide range of fisheries which in turn has economic benefit.  Maerl is of European and international importance. Wester Ross MPA has not yet been fully mapped for maerl or other Priority Marine Features but is one of the few MPAs with a real chance to recover it’s fisheries due to the ban on dredgers. This ban creates an umbrella recovery effect for a broader range of species and habitats that do not have legal conservation status. Whilst this is not perhaps the purpose of the MPA, it is of great importance to local fisheries and makes Wester Ross highly significant within the whole MPA network.

The scientific intention behind the MPA network is “good environmental status” and recovery which will in turn seed other areas. If the Government were to allow time for MPAs to recover species and habitats then an alternative economy becomes viable.

Wester Ross MPA already has 7 or 8 active salmon farms (and sites not currently in use). More farms are within a few kilometers of the border of the MPA and so cumulative impacts are important to assess, in order to know what the ecosystem can absorb. We are already fishing the bottom of the food chain with no commercial finfish fisheries left locally and just prawns, crabs, lobsters and scallops. There is a real chance to restore fisheries over time, but this chance could be thrown away by the policy of doubling salmon farms.

CUMULATIVE IMPACTS OF SALMON FARMS ON PRIORITY MARINE FEATURES AND FISHERIES

Applications requiring Environmental Impact Assessment are designed to address cumulative impacts in association with other developments, so an applicant in an MPA would be expected to address not only wild fish interactions on a cumulative basis, but also these impacts on protected species. Yet there is inadequate research into salmon farm impacts on the 81 Priority Marine Features. Maerl and flame shells support biodiversity and fisheries, particularly scallops, which are known to settle on maerl. Both maerl and flame shells have recover status in Wester Ross MPA.

Please note these issues below:

• Salmon farming within Wester Ross MPA already takes place close to known maerl beds and flame shell beds.
• SEPA has recently set a much lower allowance for emamectin use within MPAs but as far as we know SEPA has given no instructions to limit the use of emamectin in the case of farms pre-existing the MPAs designation – this is deduced from the licence allowances on Aquaculture Scotland’s website.
• Maerl has recover status. Kelp and seaweed communities on sublittoral sediment have conserve status. Both are near proposed farm sites currently in scoping.
• Marine Harvest’s salmon farm in Loch Ewe is around 500m to 1 kilometre from a maerl bed. Given new accepted distances of impact this maerl bed could be within the range of harm.
• The Marine Harvest Salmon Farm in Loch Ewe has never passed its benthic test. It also uses emamectin and other harmful chemicals. We do not know what harm it has done to the maerl bed and other species. No research as far as we known covers this. This is of legal concern.
• In Loch Broom the salmon farm is less than a kilometre from flame shell beds. No research on impacts of salmon farms on flame shells is known to us and so impacts are impossible to know. There are only a few examples of flame shell beds in Scotland …possibly only around 7-8 so this and other aspects of biodiversity are an attraction for recreational divers, and there are some who visit the MPA from Europe – degrading these habitats can impact the attraction to divers as well as the fisheries they support. Flame shells have recover status.
• Herring and other species may spawn on maerl beds too, which may improve their survival rates.  Winter spawning herring was recently found just south of the MPA probably targeting maerl beds. This  vast 2km x 1km spawning ground for winter spawning herring was found just south of the MPA in the Wester Ross economic zone near Gairloch. Herring is an important fishery and  if allowed to recover, could become one of Scotland’s top fisheries again.
• There are other spawning and nursery grounds in inshore waters and we do not know what other species are impacted.
• Burrowed mud habitat with conserve status is also close to salmon farms. The half-life of emamectin benzoate is quoted variously as less than 180 days to 200 days (the latter D. Sinclair in the SEPA internal ‘Options Paper’. In publications SEPA’s modellers assume that it won’t have completely degraded in less than 4.5 years. Apparently it almost stops breaking down in the dark and anaerobic conditions – ie if buried in the seabed. (We imagine trawlers may re-suspend this if it ends up in the mud in this habitat and impact prawn stocks, but we do not know?)
• Seagrass is a Priority Marine Feature ( PMF) and is highly sensitive to nitrogen in the water. Areas of seagrass in Gruniard bay may be vulnerable within the MPA to the gross organic output from farms.
• We also have wild wrasse being fished locally within the MPA in order to supply Wester Ross Fisheries Ltd and possibly other salmon farmers too. This potentially leads to a further imbalance in the ecosystem and a  knock on impact on other fisheries.
• There is evidence that shellfish farming can be impacted by salmon farms too.

SEAGRASS – Tracking Nitrogen Source Using δ15N Reveals Human and Agricultural Drivers of Seagrass Degradation across the British IslesBenjamin L. Jones1,2*, Leanne C. Cullen-Unsworth1,2 and Richard K. F. Unsworth2,31Sustainable Places Research Institute, Cardiff University, Cardiff, United Kingdom

TOURISM IMPACTS & MARINE TOURISM

The creel and dive fishery is a vital part of the socio-economic fabric of the community, however the Wester Ross economy is more dependent upon tourism for its survival. This includes marine tourism. The ECCLR Committee’s report  contains evidence supplied by the Whale and Dolphin NGOs regarding the impact that salmon farms have on marine mammals. The shooting of seals and the use of Acoustic Deterrent Devices by the aquaculture industry to prevent predation not only reduces the seal presence but also that of whales, dolphins and porpoise.   The acoustic deterrent devices are harmful to these popular sea creatures that are by loved by many tourist and residents.

The Hebridean Whale and Dolphin Trust’s submission to the ECCLR committee says

“Cetaceans serve as charismatic flagship species underpinning many financially important ecotourism activities in the region, such as whale watching, which in 2015 generated an estimated £3.7 million in indirect revenue from an estimated 51,200 whale-watching passengers on vessels operating on Scotland’s west coast (Conor et al. 2018).”

With whale sitings unpredictable and rare, seal haul out sites become a more reliable tourist attraction. Two of the Salmon farms in scoping in Wester Ross MPA have seal haul out sites extremely close to them and these seals risk being shot if the farms proceed. Sea safari’s would loose their key attractions – with sea birds on the decline, this risks reducing the attraction for sea safaris and even their economic viability. 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 has a significant economic implication. See below a chart showing proposed salmon farms in scoping marked near the Summer Isles with red crosses at the seal haul outs: