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
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).