Dear Supporters,
Friends of the Sound of Jura is one of more than sixty organisations that have joined the Our Seas Coalition.
Our Seas believes that Scotland’s coastal waters are among the country’s most precious assets, and worth protecting. Our waters are extremely productive, rich in biodiversity and they can support many jobs in coastal communities if they are managed sustainably.
​
Some fishing methods damage life on the seabed, destroying nurseries for commercial fish, such as maerl beds, and harming rare seabed animals. The Scottish Government has identified 11 of these Priority Marine Features (PMF) species and habitats that are most at risk from bottom-contacting fishing (scallop dredging and prawn trawling).
In 2017, a scallop dredger devastated a bed of rare flameshells in Loch Carron.
​
Despite this being one of the best examples of this PMF, the flameshell bed was not legally protected. After a public outcry, the Scottish Cabinet Secretary for the Environment set up an emergency Marine Protected Area, within which it is hoped that the flameshells will gradually recover. She also promised to review the protection given to PMFs from scallop dredging and prawn trawling. This review was launched in 2018 but nothing has come of it so far and the Government’s ambition to protect these PMFs seems to have dwindled almost to nothing. The only tangible action is that trials have started of tracking devices on the smaller scallop dredgers, which would show where the boats are, without being admissible as evidence in court, if the boats are fishing illegally in protected areas.
​
We fear that these devices will be used to claim that PMFs can now be avoided very precisely, so the few areas where this type of fishing is not allowed, such as parts of the Loch Sunart to the Sound of Jura Marine Protected Area, might be opened up to dredging, with just small exclusions around the known PMF locations. Records of PMFs are far from complete and the unknown ones will be at risk.
Although the Government has designated 20% of our seas as Marine Protected Areas, boats using bottom-contacting methods are allowed to continued scraping 95% of Scotland’s seabed, and some boats illegally fish the remaining 5%, where they are banned. Marine Scotland Compliance seems unable to enforce the law.
​
The Scottish Government has control over the management of our inshore area within 12 nautical miles. Its agency, Marine Scotland, is obliged to follow Scotland’s National Marine Plan (NMP) and the Marine (Scotland) Act 2010, which require it to put fisheries on a sustainable footing. The National Performance Framework also commits the Scottish Government,
​
“by 2020 [to] effectively regulate harvesting and end over-fishing … and unregulated fishing and destructive fishing practices and implement science-based plans, in order to restore fish stocks in the shortest time feasible, at least to levels that can produce sustainable yield as determined by their biological characteristics”.
​
The Government has also committed to promote local, small-scale and sustainable fisheries, robust measures to protect vulnerable stocks, and “mechanisms for managing conflicts between fishermen” (Policy FISHERIES 1), so as to manage fisheries in the long-term public interest. Its marine planners must also identify marine carbon sinks and seek to avoid the “Colocaton of damaging activity”. Dredging disturbs the ability of seabed sediments to store carbon.
​
None of these obligations are being met by our Government. In fact, the Scottish Government has failed to meet 11 of the 15 indicators it uses to measure Good Environmental Status, allowing our marine environment to decline.
​
The longer Ministers stall, the more seabed habitats we lose and the harder it becomes for them and the species that rely on them to recover.
​
Our seas are a public asset and potential resource; they must be managed in a way that restores lost marine life and degraded fish stocks, and recovers the marine environment, so it can provide for us all into the future. To restore public confidence, Ministers must be guided by science and policy. We need urgent action to stop further destruction and improve the resilience of our seas.
​
So, what can be done to preserve what’s left and allow recovery?
​
The degradation can still be reversed. If we protect the seabed it will recover. If we take action, environmental and economic benefits will flow.
​
This European Environment Agency report, Marine Messages, states it clearly:
​
"Solutions for halting the loss of marine biodiversity and starting to restore ecosystem resilience, while allowing for the sustainable use of Europe's seas, are obvious and available. They just need to be implemented.”
​
But that is not happening in Scotland.
​
In the absence of any progress to protect and restore Scotland’s seabed habitats and animals, and with the laws on illegal fishing going unenforced, Our Seas calls on First Minister Nicola Sturgeon and the Scottish Government to implement their own policies and stop the chronic destruction of our seabed.
​
Reinstating a coastal limit on bottom-trawl and dredge fishing seems to be the only way for this to be enforceable, so Our Seas calls for the Scottish Government to act urgently on this.
​
Our Seas is campaigning to Bring Back the Fish - Bring Back Scotland's #InshoreLimit
Please help this to happen by signing and sharing the Our Seas petition here
Please join us in supporting this petition:-
https://ourseasscotland.eaction.org.uk/bring-back-the-fish
Friends of the Sound of Jura have recently added their name to support a Global Call for the United Nations Human Rights Council to recognise without delay the human right to a safe, clean, healthy and sustainable environment.
In this time of climate emergency and COVID-19 crisis, we have come together as civil society organizations, social movements, local communities, and Indigenous Peoples to address the attached letter, calling on the United Nations Human Rights Council to recognize without delay the human right to a safe, clean, healthy, and sustainable environment. We respectfully ask you to join with us, support this call, and share it with other organizations that might be interested in joining this call.
Details can be found on the following link:
bit.ly/Right2Environment_SignOn
Friends of the Sound of Jura
www.friendsofthesoundofjura.org.uk
Community Group Member of
The Coastal Communities Network, Scotland
Friends of the Sound of Jura is a Scottish Charitable Incorporated Organisation: SC049740
​
​
Dear Supporters,
Friends of the Sound of Jura is one of more than sixty organisations that have joined the Our Seas Coalition.
Our Seas believes that Scotland’s coastal waters are among the country’s most precious assets, and worth protecting. Our waters are extremely productive, rich in biodiversity and they can support many jobs in coastal communities if they are managed sustainably.
​
Some fishing methods damage life on the seabed, destroying nurseries for commercial fish, such as maerl beds, and harming rare seabed animals. The Scottish Government has identified 11 of these Priority Marine Features (PMF) species and habitats that are most at risk from bottom-contacting fishing (scallop dredging and prawn trawling).
In 2017, a scallop dredger devastated a bed of rare flameshells in Loch Carron.
​
Despite this being one of the best examples of this PMF, the flameshell bed was not legally protected. After a public outcry, the Scottish Cabinet Secretary for the Environment set up an emergency Marine Protected Area, within which it is hoped that the flameshells will gradually recover. She also promised to review the protection given to PMFs from scallop dredging and prawn trawling. This review was launched in 2018 but nothing has come of it so far and the Government’s ambition to protect these PMFs seems to have dwindled almost to nothing. The only tangible action is that trials have started of tracking devices on the smaller scallop dredgers, which would show where the boats are, without being admissible as evidence in court, if the boats are fishing illegally in protected areas.
​
We fear that these devices will be used to claim that PMFs can now be avoided very precisely, so the few areas where this type of fishing is not allowed, such as parts of the Loch Sunart to the Sound of Jura Marine Protected Area, might be opened up to dredging, with just small exclusions around the known PMF locations. Records of PMFs are far from complete and the unknown ones will be at risk.
Although the Government has designated 20% of our seas as Marine Protected Areas, boats using bottom-contacting methods are allowed to continued scraping 95% of Scotland’s seabed, and some boats illegally fish the remaining 5%, where they are banned. Marine Scotland Compliance seems unable to enforce the law.
​
The Scottish Government has control over the management of our inshore area within 12 nautical miles. Its agency, Marine Scotland, is obliged to follow Scotland’s National Marine Plan (NMP) and the Marine (Scotland) Act 2010, which require it to put fisheries on a sustainable footing. The National Performance Framework also commits the Scottish Government,
​
“by 2020 [to] effectively regulate harvesting and end over-fishing … and unregulated fishing and destructive fishing practices and implement science-based plans, in order to restore fish stocks in the shortest time feasible, at least to levels that can produce sustainable yield as determined by their biological characteristics”.
​
The Government has also committed to promote local, small-scale and sustainable fisheries, robust measures to protect vulnerable stocks, and “mechanisms for managing conflicts between fishermen” (Policy FISHERIES 1), so as to manage fisheries in the long-term public interest. Its marine planners must also identify marine carbon sinks and seek to avoid the “Colocaton of damaging activity”. Dredging disturbs the ability of seabed sediments to store carbon.
​
None of these obligations are being met by our Government. In fact, the Scottish Government has failed to meet 11 of the 15 indicators it uses to measure Good Environmental Status, allowing our marine environment to decline.
​
The longer Ministers stall, the more seabed habitats we lose and the harder it becomes for them and the species that rely on them to recover.
​
Our seas are a public asset and potential resource; they must be managed in a way that restores lost marine life and degraded fish stocks, and recovers the marine environment, so it can provide for us all into the future. To restore public confidence, Ministers must be guided by science and policy. We need urgent action to stop further destruction and improve the resilience of our seas.
​
So, what can be done to preserve what’s left and allow recovery?
​
The degradation can still be reversed. If we protect the seabed it will recover. If we take action, environmental and economic benefits will flow.
​
This European Environment Agency report, Marine Messages, states it clearly:
​
"Solutions for halting the loss of marine biodiversity and starting to restore ecosystem resilience, while allowing for the sustainable use of Europe's seas, are obvious and available. They just need to be implemented.”
​
But that is not happening in Scotland.
​
In the absence of any progress to protect and restore Scotland’s seabed habitats and animals, and with the laws on illegal fishing going unenforced, Our Seas calls on First Minister Nicola Sturgeon and the Scottish Government to implement their own policies and stop the chronic destruction of our seabed.
​
Reinstating a coastal limit on bottom-trawl and dredge fishing seems to be the only way for this to be enforceable, so Our Seas calls for the Scottish Government to act urgently on this.
​
Our Seas is campaigning to Bring Back the Fish - Bring Back Scotland's #InshoreLimit
Please help this to happen by signing and sharing the Our Seas petition here
Please join us in supporting this petition:-
https://ourseasscotland.eaction.org.uk/bring-back-the-fish
Friends of the Sound of Jura have recently added their name to support a Global Call for the United Nations Human Rights Council to recognise without delay the human right to a safe, clean, healthy and sustainable environment.
In this time of climate emergency and COVID-19 crisis, we have come together as civil society organizations, social movements, local communities, and Indigenous Peoples to address the attached letter, calling on the United Nations Human Rights Council to recognize without delay the human right to a safe, clean, healthy, and sustainable environment. We respectfully ask you to join with us, support this call, and share it with other organizations that might be interested in joining this call.
Details can be found on the following link:
bit.ly/Right2Environment_SignOn
Friends of the Sound of Jura
www.friendsofthesoundofjura.org.uk
Community Group Member of
The Coastal Communities Network, Scotland
Friends of the Sound of Jura is a Scottish Charitable Incorporated Organisation: SC049740
​
​
Correspondence with Kames Fish Farming Ltd
Our original open letter to Stuart Cannon, Managing Director of Kames Fish Farming Ltd dated 14 September 2017
Mr Stuart Cannon,
Kames Fish Farming Ltd
Kilmelford
​
14 September 2017
​
Dear Mr Cannon,
​
You are no doubt aware that the Friends of the Sound of Jura is a community group that objects to your proposal to site a fish farm at Dounie. Indeed we believe that nowhere in the Sound of Jura is appropriate for fish farming.
​
You have described Marine Harvest as your backers regarding this proposal.
​
On 12th August, Steve Bracken of Marine Harvest was interviewed on BBC Radio 4’s Farming Today. He said: “We will not create a new farm, establish a new farm, unless we have community support. At the end of the day they’re the people that are living there. If the community said they’re not in favour of the salmon farm we wouldn’t attempt to try and start one up.”
​
Dounie is inside the North Knapdale Community Council area. A majority of those on the electoral roll in this ward have signed petitions objecting to this development. The same is true on Jura.
​
Marine Harvest’s public statement seems fair to us. Our community would have to live with this farm. Our community has shown clearly that we are not in favour of it.
​
Please withdraw your proposal.
​
Yours sincerely,
​
The Friends of the Sound of Jura
Response from Kames Fish Farming Ltd dated 27 September 2017
FAO – Friends of the Sound of Jura Community Group
​
27 September 2017
​
I am writing in response to your email regarding our proposal for Dounie, a new marine fish farm site.
​
Firstly, I would like to confirm that Kames Fish Farming Limited has no financial tie with Marine Harvest Scotland Limited. While we are neighbouring operators with whom we have a good working relationship, they are not our ‘backers’. My understanding of the quote you refer to by Marine Harvest, is that this was in relation to community support regarding a proposal on an island community, but this is entirely their business and I therefore cannot comment.
​
In regard to Kames Fish Farming Limited and our proposal, I would like to stress that community support is very important to us. We are a Scottish family owned business operating in the local area for 45 years. Over that time we have supported a great many local community events and organisations, employed staff locally who, along with their families, continue to live, work and play in this area. This in turn supports the local economy, schools, clubs and local businesses, Kames always endeavour to trade with local businesses when possible. Kames believe there are a great many people in the local area who do support aquaculture and who do not object to this proposal.
​
Finally, with regard to the proposal for Dounie, we currently have an application submitted to SEPA for determination, and this process is ongoing at present. We have instructed a more detailed visual survey with more sophisticated equipment to undertake a more extensive survey of the seabed for analysis, particularly in relation to Northern Sea Fans. This will be assessed by SEPA in consultation with Scottish Natural Heritage and we await SEPAs further response following submission. As we have stated previously, the impact of such proposals is modelled scientifically. If there is sound scientific evidence that suggests that there would be a significant or irreparable damage to the environment, it would be at this point Kames would consider with-drawing the application.
​
Yours faithfully
Stuart Cannon
Managing Director
Kames Fish Farming Limited
Our second letter to Kames Fish Farming Ltd dated 30 September 2017
Dear Mr Cannon
​
Thank you for your reply.
​
If Marine Harvest and Kames have no financial relationship, perhaps you could explain why they would state that ‘Marine Harvest currently operate the Rubh an Trilleachain site owned by Kames Fish Framing Ltd’?
​
This comes from the document ‘Marine Harvest response to SEPA assessment of 2016 compliance monitoring survey: Rubh an Trilleachain. Licence number: CAR/L/1109280′, on the SEPA disclosure log (FOI188026).
​
Do Marine Harvest really run your farm at Rubh an Trilleachain without any financial incentive for either party?
​
Since they are copied in, perhaps Mr Hadfield or Mr Bracken would also care to comment about this?
​
If you have no financial relationship, please clarify what you meant when you described Marine Harvest as your backers during the public meetings at which you spoke about Dounie.
It is good that you are community minded but in the communities that are closest to Dounie there is no discernible support for your plans. It’s also good that Marine Harvest feels it is important to respect the opinion of island communities – but why should either of you dismiss the clearly stated opinions of other small coastal communities?
​
Yours sincerely
​
The Friends of the Sound of Jura
Response from Kames Fish Farming Ltd to our second letter
27 October 2017
​
FAO Friends of the Sound Of Jura Community Group
​
I am writing with regard to your email of 30th September 2017. Firstly, my apologies for the delay in responding, I have been away from the office. It would be helpful if you could send any future correspondence copied to our fish@kames.co.uk email address which is checked frequently, it can then be brought to my attention for a more timely response.
​
Your email again queries our financial relationship with Marine Harvest (Scotland) Limited (MHS). As stated in my email correspondence of 27th September 2017, Kames Fish Farming Limited (Kames) are an independent Scottish company and MHS are not our ‘backers’. Kames, as a business, enters into agreements and/or contracts with many other businesses and/or individuals, both as suppliers and customers. This can include contract growing agreements with other aquaculture companies including MHS, (incidentally from Kames perspective this can be with an aim to improve continuity of Kames production), but these are business agreements and in no way indicate Marine Harvest are our ‘backers’ in regard to our proposal for a new site at Dounie.
I would like to reiterate that we are pleased to enjoy an excellent working relationship with MHS; this is greatly valued as we are neighbours working in the same management area.
​
Yours faithfully
Stuart Cannon
Managing Director
Kames Fish Farming Limited
Friends of the Sound of Jura responded on 29 October 2017
Dear Mr Cannon
​
Thank you for confirming that your earlier response was inaccurate and that you do have financial ties with Marine Harvest, including at least one growing agreement. Clearly, if MHS can run your farm at Rubh an Trilleachain, there is nothing to stop such a business agreement being made regarding Dounie in future, once your Scottish family owned business has secured planning permission.
​
As you have not responded to our second question, about respecting the opinion of the communities closest to the site of your proposal, we thought you would be interested to read some extracts from the Scottish Salmon Producers’ Organisation’s Community Engagement Charter, published last year.
​
http://scottishsalmon.co.uk/wp-content/uploads/2016/09/community_charter_2016_digital.pdf
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We appreciate that Kames is not a member of the SSPO, but wonder whether you disagree with any of the following statements in their Charter, given that the SSPO says ‘we believe that these commitments are achievable at all sites’?
​
The Charter says:
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‘We will work with local communities to protect the natural environment in which we are based. So we can be stewards of our shared resources and be ‘good citizens’; the better we are at this, the greater the chance that communities will trust us with their natural and physical environment in the future.’
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‘Stewardship of local resources is a key factor in aquaculture development and it is essential that these resources are considered to include the local community as well as the natural environment.’
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‘…community support and endorsement is important for the farms to operate – a two-way relationship is needed.’ A community should ‘…be given the ‘ability to influence size, scale and location of farms through local expert opinion’.
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‘At the heart of our work is respecting, listening and responding appropriately to issues and concerns raised during the Community Engagement process.’
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Please tell us whether any of these principles should not apply to Dounie, given that the community that would be most affected is the closest to it, in Knapdale.
​
Yours sincerely
The Friends of the Sound of Jura