The Royal Society of Edinburgh (RSE) is pleased
to respond to the Scottish Executive Environment and Rural Affairs Department
review of the locational guidelines for the authorisation of marine
fish farms in Scottish waters. The RSE is Scotland’s premier Learned
Society, comprising Fellows elected on the basis of their distinction,
from the full range of academic disciplines, and from industry, commerce
and the professions. This response has been compiled by the General
Secretary with the assistance of a number of Fellows with direct experience
of aquacultural and environmental issues.
The 1999 Locational Guidelines serve as an introduction to the nature
and scale of the problems involved in the fish farm industry. However,
the low-key presentation of some of the technical problems involved
(e.g. the impact of anoxia and bacterial growth in the water column
and seabed below salmon cages; the possible impact on wild salmon and
sea trout stocks through escapees, sea lice infestations, disease and
the chemical agents used) may limit its value.
Salmon farming is also a hybrid industry with almost half of the salmon
production cycle taking place in fresh water. Freshwater resources are
much more vulnerable and less available than marine waters and freshwater
lochs, in particular, extremely vulnerable to the eutrophication and
disease issues associated with freshwater culture. The Guidelines would,
therefore, be much stronger if they were alongside a similar one for
freshwater, especially in relation to environmental impact of cages
in freshwater lochs.
The specific issues identified for consideration are addressed below,
although this review will need to be considered as part of the Scottish
Executive’s Strategy for Aquaculture consultation and the Scottish
Parliament Transport and Environment Committee aquaculture inquiry:
The rationale behind the categorisation of areas
There are increasing concerns about the environmental effects of fish
farms and the effects that escaped fish may have on the wild populations.
It will be important that the geographical location of fish farms are
distant from the routes of homing wild salmon stocks. In this context,
the presumption against additional fin-fish developments on the north
and east coasts is important. Furthermore, any increase in capacity
should focus on areas already in use that have been shown to have the
least environmental impact.
In terms of updating the categorisation criteria, the indices of nutrient
release from farms and the impact of organic matter on the seabed might
require updating in the light of current knowledge. In this context,
categories should draw on advice from the Scottish Environmental Protection
Agency which has regulatory responsibility for pollution issues in near
shore waters, especially in light of the EU Water Framework Directive.
There could also be a role for a new category (Category 0) where no
development would be allowed. Appropriate indices for this category
could be the upper index levels of 9 and 10, where it was indicated
that the environment was at very great risk from irreversible damage
if any further development was allowed. Areas with such high index values
could also be especially sensitive to small changes in sea temperature
associated with climate change. In addition, categorisation needs to
consider the potential for conflict with wildlife (e.g. wintering flocks
of ducks in region of proposed mussel farms and avian and mammalian
predators at salmon farms) and the wider concerns of the effects of
fish farming on landscape and tourism.
There is also a strong case for reviewing the area categorisations
in the 1999 Guidelines. For example, upgrading the category for fish
farming in parts of the Firth of Clyde and it's associated sea-lochs
to category 1. Loch Ryan has the last remaining wild oyster stocks which
should be preserved as a priority and the Cumbraes have two major coastal
and intertidal Sites of Special Scientific Interest (not listed in the
annex) and have major scientific research activities as well as being
important recreational areas, including the National Water Sports Centre.
The role of local framework plans
Local government should have a role in the regulatory process, providing
planning consents that take into account the views of other users of
the coastal zone in considering aquaculture development proposals. In
this context, local framework plans have the scope to provide the framework
for planning and should include Tripartite Working Group arrangements
and Area Management Agreements among fish farming operators. However,
there are often disagreements with the impact assessment between the
scientific evaluations that support developments and those of objectors.
Much of the divergence of view relates to the polluting effects of salmon
farms, and to quantitative information on escapes and impact on the
wild population. The divergence of view makes it difficult for local
authorities to assess accurately the potential problems that a new farm
might cause, as they often do not have the necessary expertise at their
immediate disposal. There should, therefore, be mandatory involvement
of the technically based organisations cited in the Guidelines or oversight
of the planning and regulation of the industry by a single independent
advisory body, which would be mandated to provide publicly available
advice on all cases where the parties disagreed.
In addition, the 1999 Guidelines do not well address the incremental
growth of fish farms. For example in Category 2 areas, environmental
impact assessments (EIAs) are only required for modifications of more
than 25% of biomass or equipment. However, annual incremental growth
below that threshold could result in significant cumulative development.
Perhaps requiring EIAs for any increase of 25% or more over a 10-year
period would be appropriate. This requirement should also apply to discharge
consents from SEPA.
The implications of shellfish and new species
There is an opportunity for the fish farming industry to diversify away
from salmon, with sole, halibut, cod, haddock, and sea urchins offering
good prospects. In addition, as assays are developed for algal toxins,
there are also good prospects for expanding shellfish culture. Salmonid
and non-salmonid populations are, however, likely to be farmed in separate
areas as differing management techniques and regimes may be necessary
for the different species, but non-salmonids could be considered in
areas which are not ideal for salmonids, due to the perceived risk to
wild salmonids. The potential introduction of exotic species, however,
could be a cause for concern as ecological damage has often followed
exotic introductions in inland waters. In addition, there has already
been at least one trial within Scotland, in containment, of GM salmonids.
The potential environmental effects of such fish will need to be considered.
Land based sites
There would be merit in the locational guidelines including land-based
and broodstock production sites. Land-based sites are being used for
elements of broodstock-holding and freshwater production, particularly
with valuable stocks (e.g. for broodstock genetic selection and specific
pathogen free germplasm production for salmon, halibut, cod or turbot).
Environmental impact assessment can readily be carried out for these
facilities and there are possibilities of disinfection and filtration
of water supplies and discharges which are not possible in the open
sea. There would also be value in considering a "cordon sanitaire",
restricting the location of other farms within 20 km of such sites by
means of planning controls, for high technology, high investment land-based
sites to ensure Specific Pathogen Free (SPF) production.
The relocation of farms
While category 1 areas restrict any further development, some internal
re-arrangement in such areas could be of great environmental (e.g. moving
cages away from estuaries), welfare and probably economic benefit (e.g.
to allow better site rotation and fallowing procedures). Currently this
is difficult to achieve without major political difficulty and effort
on the part of the farmer and prohibitive cost. Some system of encouragement
to such rationalisation would be very sensible on all grounds but would
require greater planning flexibility.
Separation distances between sites, and between sites and natural
heritage areas
It is important that fish farms are not located within or adjacent to
areas which have been designated as Sites of Special Scientific Importance
or within areas that are designated, candidate or proposed Nature 2000
sites (Special Areas of Conservation (EU Habitat Directive), and Specially
Protected Areas (EU Birds Directive)). Other designations, such as Local
Nature Reserves and National Scenic Areas, must also be of primary concern
in a decision as to whether to site a farm in a particular location.
More generally, care must be taken over siting of fish farms in all
areas so they do not damage the scenic environment on which such forms
of economic activity as tourism depend. There is also concern over the
siting of farms at the mouths of important salmon rivers.
Distances between farm sites should take account of the guidelines
in the Final Report of the Joint Government/Industry Working Group on
Infectious Salmon Anaemia and the Code of Practice to Avoid and Minimise
the Impact of Infectious Salmon Anaemia (ISA) to minimize the spread
of disease. There will also be implications for separation distances
between fish farms sites and those culturing different species and/or
the proximity of other freshwater sites. In this context, Area Management
Agreements and local framework plans should be increasingly used.
Future updating of the guidance
The guidance should be updated on an ongoing basis, perhaps every 3
years, and include some mechanisms for examining the state of the industry
at a national/international level. The Code of Practice on containment
and recapture of escapes should also be developed, and incorporated,
as soon as possible
Additional Information
In responding to this inquiry the Society would like to draw attention
to the following Royal Society of Edinburgh responses which are of relevance
to this subject: Conservation of Salmon and Sea Trout (August 2000);
Protecting and Promoting Scotland's Freshwater Fish and Fisheries (August
2000); Sixth Environmental Action Programme (May 2001); The Nature of
Scotland (June 2001); The Future of the Common Fisheries Policy (June
2001); Scotland’s freshwater fish and fisheries: Securing their
future (November 2001); Strategy for Aquaculture (April 2002).
April 2002
Further information is available from the Research Officer, Dr
Marc Rands |
