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 publication of this Strategy will be timely and important, given the critical situation in the fishing industry and the somewhat negative public perception of fish-farming at the present time. The strategy is clearly written and, in the main, represents current scientific thinking. In particular the strategy recognises that aquaculture is a young, albeit very dynamic industry, and thus not only is it growing rapidly but it is also showing the typical price instability generally seen in such industries. This not only makes planning very difficult but also makes any Research and Development very difficult for individual companies to fund on a sustainable basis.
The Strategy is also well balanced in terms of the ongoing tensions between the aquaculture industry and the environmental lobby, with long term significant growth in the industry only being likely if there is improvement in husbandry systems that reduce environmental impacts. The strategy is, however, weak on how we should tackle these issues in a structured way.
The specific areas identified by the Strategy are addressed below:
The challenge to develop new species is welcome and is being actively pursued by many agents.
Organic and "environmentally friendly" aquaculture
The "environment friendly" aquaculture concept is rather poorly defined and while labelling products as such may increase sales, it does not necessarily guarantee impact reduction. For example, industrial fishing in Chilie, which provides feedstuffs for companies selling organic salmon, has significant knock-on effects on the local marine eco-system.
The encouragement of more research in fish meal/oil substitution technologies is to be welcomed, but more could have been made in the strategy about only sourcing raw materials from demonstrably sustainable wild stocks.
Competition for space
Integrated Coastal Zone Management
Probably the most significant, all-embracing action in this section is the one in support of Integrated coastal zone management (ICZM). Two excellent model ICZM plans were developed for Bantry Bay in Ireland and Argyll in Scotland by the EO - PESCA initiative. It would be very valuable to develop these into implemented operational programmes as a basis for how ICZM's should be developed for all coastal zones.
Public health issues
Harmful algal blooms
Further research on harmful algal blooms is rightly recognised as a prerequisite to the sustainable growth of the shellfish sector. However, assessments need to be made of the real risk to the human consumer from such blooms. For example, in the case of Amnesic Shellfish Poisoning (ASP) in the scallop, there is no risk to the consumer from the edible parts (adductor muscle and gonad), even during an ASP event, provided these are properly prepared.
Animal health issues
The availability of veterinay medicines for certain animal species and diseases is a real problem for anmal agriculture in general but for aquaculture where new products, more sophisticated, and environmentally acceptable than the spin-offs from human medicine or older veterinary products, which currently apply are required, a serious deficiency exists.
The support for fallowing to allow seabed recovery does not reflect current thinking. Best practice is to ensure that the scale of production is appropriate to the environmental conditions pertaining to the specific site and thus that impact on the sediment is kept within sediment quality criteria. There should then be no need to use extra sites to allow fallowing. Where sites cannot operate at the reduced scales this might impose, then they should either convert to farm some other species, or be closed. In this context, fallowing is meant in the sense used in the document i.e. long term site rotation to allow benthic recovery, rather than short term fallowing to break disease cycles. However, fallowing is often practised for partial seabed recovery, long enough for the Beggiatoa sheets to disappear, but too short for full recovery of the seabed. This is equivalent to moving a cricket pitch frequently enough to allow the grass to recover but not long enough for a mature meadow, let alone a wood, to grow in succession! The encouragement to move large-scale aquaculture further off-shore, however, is welcome.
On-growing of wild fish
The strategy should not be too species-specific as demands for fish can suddenly appear and disappear. For example, the demand for "cleaner-fish" (for biological control of sea-lice) also affected wild populations, as in the case of the goldsinny wrasse.
Environmental Impact Assessment(EIA)
The RSE particularly endorses the section on EIA as the standard of these is rather variable with many examples being mere regurgitation of publicly available material with little actual analysis of the key environmental features associated with developing a specific site.
The statement on re-stocking is highly controversial. Many ecologists believe that restocking programmes have contributed to the decline of many species and should only be attempted when the native population is extinct and the causes of that extinction have been resolved. In this context, restocking can cause as much damage as escapees.
The value of increasing our knowledge is recognised in the Strategy and the importance of research is also developed. A key finding of a recent SAMS review for the Scottish Executive was the acute lack of scientific information on interactions with the environment. Much of this basic research cannot be undertaken by the industry and it would be appropriate for the EU to fund such work. If the EU socio-economic and environmental aspirations are to be realised for this very important industry, then there needs to be a much more focussed approach to such research and probably a step-change in resources.
In terms of industrial research, the state of the industry's markets and financing, and the very immature stage of its knowledge base means there is a very significant need for research and development (R&D), particularly in the small companies. Currently it is very difficult for SME' s to fund their company specific R&D particularly at the D end of the spectrum and changes to the R&D funding regime to reflect this need. In this context, the FIFO has been of limited value to aquaculture, with.the Leader programme being more successful in this respect in relation to aquaculture but availability of such funds in coastal Scotland or Ireland is all but eliminated. Some successful projects have also resulted from collaboration between academia and industry funded inter alia by the EC CRAFT Scheme.
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); Review of the Locational Guidelines for the Authorisation of Marine Fish Farms in Scottish Waters (April 2002) and a Strategic Framework for Aquaculture (January 2003).