The Royal Society of Edinburgh (RSE) is pleased to respond to the Scottish Executive Environment and Rural Affairs Department consultation on the draft Strategic Framework for Aquaculture. I have compiled this response with the Research Officer, Dr Marc Rands, and with the assistance of Fellows with expertise in this area.
The concept of asking all of the stakeholders for their inputs to a Government inspired framework is greatly to be commended. It has produced a document which recognises the major benefits which the aquaculture industry confers on Scotland as well as the ways in which it impinges on the environment and other areas. The Framework will, of course, need to be consistent with and consequent upon the publication of the EC Strategy for the sustainable development of European Aquaculture, and a copy of the RSE's comments on this Strategy is also enclosed.
The specific areas identified by the Framework are addressed below:
In pursuit of the economic objectives
It should be noted that investment will only be encouraged where both profits and risks can be managed. Investment in Scotland will be continually hampered when compulsory slaughter for a range of diseases without possibility of insurance or compensation is the rule. This is more important to limiting investment than simply adjusting Financial Instrument for Fisheries Guidance (FIFG) percentages and needs to be addressed.
Parts of the Scottish shellfish industry have been heavily penalised in the past compared to other countries as a result of the SE making a different interpretation of the legislation banning shellfish harvesting in the event of harmful algal toxins appearing in shellfish tissues. There is still a wide discrepancy in the methods employed to detect algal toxins (eg mouse or rat test, length of time test animal is observed etc.) throughout the European union. Until these methods are replaced by standard biochemical assays, an assessment as to the extent the Scottish industry is penalised would be useful.
Downstream or whole chain commitment
The processing sector is likely to process more farmed fish as capture stocks decline and it is correct to identify this as a key sector. This sector may have to import farmed fish from elsewhere, but currently little attention is paid to biosecurity in relation to such farmed fish movements internationally and nationally. In particular no protocols for factory hygiene in relation to fish viruses as opposed to human food safety, exist and the risk of transfer of fish pathogenic viruses, such as infectious salmon anaemia (ISA), both in the factory and particularly via transport vehicles, is scarcely noted. This is a major area of concern.
Scotland is leading the way in the development of new species for Aquaculture but there is a need for further research funding in this field to ensure that the necessary risk assessments for such speices are backed by appropriate R&D.
With regard to the main risks to fish health associated with the interaction between shellfish and finfish farming, it should be noted that some fin fish pathogens do replicate in shell fish and some shell fish pathogens are very similar to, and can cause positive test results for, fin fish brood stock tests. This does not however, negate the validity of the recommendations. There is, however, no mention of the potential of marine plants in this context of new species.
Encouraging public confidence
This is an important area. The campaign would be strengthened by being manifestly pushed by Government rather than the industry, because if industry claimed the significant benefits to Scotland of a successful stainable industry, it would always be assumed to be in self-interest. Much could be done to rectify the public perception of the relative damage to the marine ecosystem of the wild fishery harvesting vs. commercial aquaculture sectors. This in turn will help fulfil the aims of re-deployment from the fishing to culture sector.
In pursuit of the environmental objectives
The phrase "carrying capacity" is more a concept than a firm scientific criterion. If it is to be used in the Strategic Framework document, it needs to be defined in its current context. Given the present state and public image of Scottish aquaculture, it is going to be very important that the Strategy is effective, taken seriously, and respected.]
In connection with the Scottish Aquaculture Research Forum and research priorities, access to Government research funding should be open to Government research institutes, universities and independent research organisations so that the current aquaculture research capability present in Scotland can be properly utilized through openly competitive and collaborative research efforts. A balance and interplay between industry, the universities and colleges, and Government laboratories is needed.
In terms of the research priorities, further research is also required in the areas of fish health and welfare, genetics and reproduction.
In pursuit of the stewardship objectives
Local authority Zoning Plans for coastal marine waters
Integrated Costal Zone Management plans are essential. The excellent PESCA-CZM report on integrated management for Argyll coastal waters should be implemented as a model, and similar plans should be commissioned for the rest of the coast.
Locational Guidelines for Authorisation of Marine Fish Farms in Scottish Waters
There is no reference in the Scottish Framework to legislation which will either directly or indirectly force the industry to move offshore. The consequences of this should be considered in this document.
The limited availablilty of veterinary medical products for certain animal species and diseases is important and needs to be addressed with significant investment required to develop new products.
With regards to the comments about the Fish Veterinary Society's need for training in welfare issues, members of the Fish Veterinary Society, a constituent body of the British Veterinary Association, (and which is not represented on the Ministerial Working Group on Aquaculture) do have the training, knowledge and experience about welfare issues in fish. Nevertheless, further research in developing welfare indices for farmed fish would be valuable.
Application of Scottish fish health legislation
The recognition that the present regulatory regime needs updating is to be welcomed. The proposed remedy may be adequate but discussions with the Scottish Executive's Veterinary Staff, who have much greater experience of management of notifiable diseases in the analogous pig and poultry industries, would also be useful.
In responding to this consultation 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) and Review of the Locational Guidelines for the Authorisation of Marine Fish Farms in Scottish Waters (April 2002).