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Email to Scottish Ministers 16 Nov 2019 top

Email to the Scottish Ministers 16 Nov 2019

Home > Info > Email to the Scottish Ministers 16 November 2019 and their response

From: Friends of the Sound of Jura <>


Date: 16 November 2019 at 15:11:27 GMT




Scottish Ministers, 

The Scottish Government, 

Environment and Forestry Directorate,

Environmental Quality Division, 

Area 1-D (North), 

Victoria Quay, 












Dear Ms Cunningham,



The Friends of the Sound of Jura coastal community group objects to SEPA’s decision to grant a variation of authorisation under CAR, for the expansion of biomass at the Bagh Dail Nan Ceann fish farm in Loch Shuna by 20% to 3000 tonnes.


The expansion of this farm represents a direct threat to jobs in our community that depend on the health of the sea. 


As shown by the graph on the right side of the screen grab from the Scotland’s Environment website below, the degree of seabed pollution around this farm has already caused it to fail multiple environmental monitoring surveys, when its biomass was substantially lower than it would be after the proposed expansion. 

Screengrab from Scotland's Environment w

The most recent of these seabed surveys (report attached below) was conducted by MOWI staff in December 2017 and judged ‘borderline’ by SEPA. In fact the text of the survey report shows that the seabed quality failed on several counts. 

Despite this, MOWI has applied to SEPA for permission to increase the biomass at the BDNC Loch Shuna farm by 40% to 3500t.


SEPA has decided that its pollution modelling software supports a 20% biomass increase at the site (500 tonnes more fish), and that this increase would reduce the amount of organic waste falling on each square metre of seabed. SEPA’s decision does not make it clear enough that this reduction in grammes per square metre of waste deposition is only possible because the agency is allowing a large increase in the area of seabed that would be severely polluted. 


Under SEPA’s new regulations, a farm’s ‘pollution mixing zone’ depends on the surface area of the farm. MOWI already has planning permission to expand this farm from 10 to 12 cages and to moor the cages further apart. This increases its surface area and enables SEPA to calculate a larger pollution mixing zone. The overall amount of organic pollution will of course increase by 20%, in line with biomass. Any chemical bath treatments discharged into the water will also increase by 20%, as will the number of sea lice larvae released into the sea through the farm’s open nets. 


SEPA and the industry both acknowledge that the agency’s computer modelling of the dispersion of fish farm bath treatments is inadequate, and that their impact beyond the immediate area of the farm is unknown. One of these chemicals, hydrogen peroxide, is not even regulated by SEPA, yet 5000 tonnes are discharged into Scotland’s sea each year, including at BDNC Loch Shuna. The ongoing Norwegian ‘PestPuls’ study shows that hydrogen peroxide can kill commercially fished crustaceans 1-2km from farms and up to three days after treatments, at doses typical of use on fish farms.


At its existing size, BDNC Loch Shuna has had catastrophic levels of mortalities this year, with around a quarter of the fish dying of disease and algal blooms. The rest have been killed early, to prevent them succumbing in the same way, and the farm is now empty. The same thing has happened at most of MOWI’s farms in Argyll, and as far afield as Rum. According to MOWI’s Director of Communication; ‘These 12 sites lost a combined total of 737,000 fish over the three month period, or 2,600 tonnes in weight’ between July and September.  This was twice the usual death rate and cost the company £7.6 million. The company says this was exacerbated by warmer water temperatures, which will become more likely as the climate warms.


The Fish Health Inspectorate visited the site on 26th June, reporting that lumpfish had suffered ‘issues with mortality increasing with the warmer weather’….’This was visible when inspecting the pens as some fish looked very lean, and others with a clear fungal challenge'. MOWI was also censored in September 2019 by the Animal and Plant Health Agency for failing to look after the welfare of its lumpfish, saying that ‘Not taking effective decision at earlier date has prolonged the period while the lumpfish still at the site have been in need to be protected from suffering and disease’.


The Scottish animal campaigns charity, OneKind, ranked BDNC as one of the worst for animal welfare in Scotland. That was based on an analysis of death rates, overcrowding, lice infestations and other factors in 2017.


The BDNC Loch Shuna farm is clearly already stocked beyond its capacity to sustain so many salmon, yet MOWI has already started the process of applying for planning permission to add another two cages to BDNC Loch Shuna. Once it has 14 cages in place, the farm’s area will have increased again, allowing SEPA to recalculate a yet larger mixing zone, and to give permission for a further variation of authorisation of the CAR licence, to the 3500 tonne biomass that MOWI wanted in the first place, making this the largest single salmon farm in Scotland.


SEPA will be able to use the same illogical justification that it has this time, that the quantity of waste falling on each square metre of seabed has not increased, while failing to point out that the area of seabed so affected has grown enormously.


There is no end to this step-wise increase of seabed pollution, as neither SEPA nor aquaculture’s other regulators impose a maximum size on the area that fish farms can occupy, so their pollution mixing zones and the area of seabed around each farm that can be severely polluted can continue to grow indefinitely.


The assumption that seabed pollution does no harm is based on the out-dated and unsustainable assertion that the marine environment can assimilate large amounts of organic waste, providing only that two species of burrowing worm survive to aerate the sediment, and that this would allow the seabed to recover in the medium to long term, in the unlikely event that the farms were removed. Hardly any fish farms have ever been removed - instead the industry and Scottish Government are intent on doubling their capacity - so the area of severely polluted seabed continues to grow.


SEPA confirms that fish farms are the largest polluter of Scotland’s seas. They are allowed to dump their waste in the water for free, with the cost borne instead by coastal communities. This is not consistent with the polluter pays principle or with tackling pollution at source. 


Despite the recommendations of the ECCLR and REC Committees more than a year ago that the status quo is not an option, there has still been no thorough assessment of the cumulative environmental impact of waste from multiple farms, or of the capacity of the marine environment at the waterbody scale or larger to assimilate the organic and chemical waste discharges from fish farms.


Besides the harm to other marine life and to local jobs, the ongoing pollution, welfare and disease disasters are doing tremendous harm to the reputation of brand Scotland, especially the food and drink sectors. Scotland’s farmed fish are falling very far from being demonstrably the best in the world.


Please call in this decision and do not allow this farm to expand.



Yours Sincerely


Friends of the Sound of Jura

Community Group Member of

The Coastal Communities Network, Scotland

Response from Scottish Ministers 26 Nov 2019

The following response was received from the Scottish Ministers:

Scottish Ministers to FOSOJ 26 Nov 2019.
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