CCN Statement: Salmon Farming in Scotland

Coastal Communities Network members welcome the findings published this week in the Rural Economy and Connectivity Committee report on Salmon Farming in Scotland.

The Coastal Communities Network (CCN) has been very active on issues related to salmon farming, with a sub-group of Network members meeting aquaculture officials from Marine Scotland, Local Planning Authority representatives, SEPA and other government agencies. We have presented large amounts of evidence to support our case for a temporary halt to expansion of the industry, until it can be shown to be sustainable.

James Merryweather from Scottish Salmon Think-Tank reflects on the collective action taken to get us to this point:

“The Scottish Parliament’s ECCLR Committee’s report and now the REC Committee’s report almost entirely vindicate what we in Skye and Lochalsh (Scottish Salmon Think-Tank) have been pointing out to the authorities since October 2012, when the south Skye sea lochs were threatened by fish farm development. Concurrently, numerous other coastal community groups were also engaged in their own local battles to get the industry regulated properly and their combined voice as the Salmon Aquaculture Reform Network, Scotland, inspired by the work of Salmon & Trout Conservation, took the case to the government.”

“CCN joined in and together we had a significant influence on the parliamentary committees’ decisions. We acknowledge the positive impact of that combined community effort.”

Environmental Impacts

Fish farms pollute Scotland’s seas more than any other industry and release billions of parasitic sea lice larvae every year, which harm wild fish. This also impacts sustainable jobs in the communities CCN represents, so its constituent community group members welcome many of the recommendations in this important report.

The finfish farming sector and trade press are interpreting the REC Committee’s report as ‘A Charter for Growth?‘ with the Scottish Aquaculture Innovation Centre chief reportedly claiming ‘Now we can go forward and grow’, while Marine Harvest has welcomed it as a ‘guide to growth’.

CCN’s John Aitchison (Friends of the Sound of Jura) remarks:

“Given the scale of the environmental impacts that have been made clear in the ECCLR and REC Committee reports, and in SEPA’s most recent report on the long-lasting pollution of the seabed by fish farm chemicals, CCN, along with many other groups (27 NGOs called for a moratorium), believes there should be a temporary halt to expanding fish farms and creating new ones, until the problems are sorted out.”

“During that time an Environmental Impact Assessment should be done of the whole industry, including the impact of sea lice on wild salmon and sea trout, and of pollution on creel fishing and other jobs, based on first understanding the carrying capacity of the sea for fish farming using open nets.”

CCN therefore welcomes the report’s recommendation that “urgent and meaningful action needs to be taken…before the industry can expand.”

The Precautionary Principle

CCN also celebrates the recommendation that “the Scottish Government should provide strong and clear leadership in ensuring that the precautionary principle is applied, producing appropriate policy and guidance documents as necessary.”

Applying the precautionary principle is a legal obligation and a vital safeguard to protect the environment and those whose sustainable jobs depend on it, when there is a likelihood of harm but in the absence of certainty. It is the application of common sense, when the risk of long-term harm is high.

CCN particularly welcomes the recognition that fish farming impacts those whose work depends on the health of the sea, many of them living in the small coastal communities that the aquaculture industry says it is supporting.

The report recommends giving Marine Scotland much of the responsibility for solving the industry’s problems. We are concerned that Marine Scotland has conflicts of interest, as both the industry’s advocate inside Government and one of its environmental regulators, which can result in a pro-industry bias.

This position is untenable and results in a de facto pro-industry bias without clear guidance on the environmental risks associated with planning and licensing decisions. Going forward, we want greater scrutiny by the RECC of Marine Scotland’s decisions and advice, a co-ordinated approach to environmental regulation and a structure and process established, which produces transparent evidence-based decision making.

CCN has concerns about the gaps created by a lack of coordination between the regulating agencies, which allows issues such as sea lice and chemical pollution to slip past regulators, so we welcome the REC Committee’s call for a more coordinated and tighter approach to regulation.

Meaningful Protection

Sara Nason, from Network member Sea Change, reflects that:

“While it is frustrating that the report does not advocate for reform first it does seem a very positive step forward and we must celebrate that. It is disappointing that the top line still assumes that the salmon farming industry brings a net gain in jobs and income.”

“Until the job losses caused by salmon farm impacts are fully assessed there is no certainty that it is true. In which case the Government’s policy for expansion is based on a false assumption and the economic costs to Scotland could be negative. We do not yet have the full picture.”

Many CCN community groups are also working hard towards meaningful protection within their local Marine Protected Areas (MPAs) and concerns are widespread over the impact of salmon farms within MPAs.

CCN’s Paul Chandler (Community of Arran Seabed Trust) comments:

“We welcome the recommendation that the government prioritise assessing sites which are unsuitable for siting salmon farms and an assessment of their impact on MPAs.  However, the report already recognises that SEPA’s research concludes that pesticides from Scottish salmon farms ‘is significantly impacting local marine environments’ – we consider that the presence of polluting open cage salmon farms in MPAs is wholly unsuitable and call for their removal from within and near protected areas.”

Priority Marine Features

Within the MPA network and beyond there are Priority Marine Feature species, recognised by the Scottish Government for their vulnerability and rarity, which are highly sensitive to fish farm waste or chemicals. These species and the habitats they support are vital to the recovery of Scotland’s fisheries and ecosystem.

This is especially true for maerl. The science on these impacts is inadequate to make good decisions. CCN therefore calls upon the Scottish Government to stop any new farms near these features until the science is adequate to assess the damage being done.

Overall, the Coastal Communities Network welcomes the recommendations calling for more transparency in the industry and its regulators, and for tighter regulation and better enforcement. We welcome the recommendations for better guidance to the Local Planning Authorities that decide on the locations and sizes of fish farms, and for the application of the precautionary principle to these and other decisions.

Scotland should be proud of the health its seas and of its seafood and tourism businesses that depend on them. The Scottish Government is committed to the principle that the polluter pays to clean up their waste. It is now time for the fish farming industry to do so.

The Scottish Ministers, Roseanna Cunningham and Fergus Ewing, must now decide how best to implement these recommendations. The REC Committee has echoed the ECCLR Committee’s statement that ‘the status quo is not an option’.

It is vital that they apply the precautionary principle in a meaningful way, in order to protect the livelihoods of the coastal communities we represent, and the health of the sea on which we depend, so as to ensure that the industry’s ambitious plans to double in value by 2030 do not leave a legacy of harm.

We now await the outcome of this report with interest.