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
​
​
Letter to the Environment, Climate Change and Land Reform Committee
26 March 2018
Dear Mr Dey
I hope this finds you well.
The Friends of the Sound of Jura were delighted to read the ECCLR’s thorough and uncompromising report on the environmental impact of salmon farming. Thank you for listening so carefully to the evidence.
We were interested to read the ECCLR committee's letter to SEPA, posing some outstanding questions to which the agency has not given satisfactory answers. We would be very interested in these answers and hope they be published on the ECCLR inquiry webpage.
The Marine Scotland letter is also interesting and asks some excellent questions. Marine Scotland has a very broad remit, including encouraging aquaculture, which may generate political pressures inside the organisation. This may explain why its advice to planning authorities on wild fish impacts has been criticised by them as being ambiguous and unhelpful. This conflict of interest could compromise Marine Scotland’s ability to be a fair broker on whether wild fish would be harmed by fish farms. We note that at present Scottish Natural Heritage seems to play no role in making these decisions, referring all enquiries about fish farms’ impacts on these two PMF species to Marine Scotland.
We are interested in SEPA’s answers to your questions, in part, because there have been a number of recent applications for salmon farms larger than the previous maximum permitted size of 2500 tonnes. Marine Harvest’s current proposal for Cheesebay, North Uist is one example. This is at the EIA scoping option stage. (Screen grab below - http://planning.cne-siar.gov.uk/PublicAccess/applicationDetails.do?activeTab=summary&keyVal=P5BQUKRO02A00)
Cheesebay has a proposed new maximum size of 5950 tonnes. The same company has applied for planning permission for a 3500 tonne farm at Pol na Gille (Argyll) and is holding pre-application consultations about expanding its North and South Carradale farms to 3750 tonnes each.
Regarding the Cheesebay proposal, SEPA’s response to the screening and scoping request )http://planning.cne-siar.gov.uk/PublicAccess/applicationDetails.do?activeTab=consulteeComments&keyVal=P5BQUKRO02A00) is to note that
they ‘consider it to be at the applicant’s commercial risk to submit a planning application at this time for a fish farm to accommodate a maximum biomass in excess of that which we can licence under the current licensing regime and modelling.’ but add that ‘NewDepomod will be used to predict potential deposition resulting from the farm and to predict a sustainable maximum standing biomass to operate at the farm …'
'…SEPA's current licensing regime and the use of only AutoDepomod modelling, allows a maximum biomass of up to 2500 tonnes. However, we may allow a higher biomass if supported by more detailed hydrodynamic modelling; this would need to be submitted and approved by SEPA’s modellers.'
The site is close to existing farms in Grey Horse Channel, Groatay and Vacassay, so, to their credit, SEPA specify that, ‘an assessment of any potential effects from combined impacts (due to overlap of benthic impacts and sea-lice medicine treatments, both in-feeds and baths) will be required’ and a similar cumulative impact assessment for nutrient loading.
Regarding their Carradale proposals, Marine Harvest say that there has never been a ban on farms above 2500 tonnes but that this size is the upper confidence limit of AutoDepomod. They add that they have had initial discussions with SEPA on using NewDepomod to model pollution from a larger farm at N Carradale and that they will produce a full modelling statement in due course to address SEPA’s requirements.
The industry is clearly pressing on with its plans for expansion without waiting to see what the REC committee’s inquiry concludes.
What concerns us most is that these examples of expansion are based on using SEPA’s unproven NewDepomod computer model, which will be the mainstay of SEPA’s DZR system, if it is approved.
Computer models can be set up to yield the results that best suit their users, and they are only as good as the site validation data they are given. NewDepomod is no doubt better than the current model (AutoDepomod) but at least that was peer-reviewed, unlike NewDepomod, and given that its developers list that it ’supports industry expansion’ as one of its three aims (SEPA FOI 188192 http://apps.sepa.org.uk/disclosurelog/# Nov 2017 ‘20160804_AB_REFINING SEA-BED PROCESS MODELS FOR AQUACULTURE Final Report v4’ pg 1), we feel that its opaque assumptions and its site validation data collection regime should be publicly scrutinised before it is used to predict the dispersion of pollution for the purpose of issuing any licences for expanded fish farms.
One of NewDepomod’s developers, who works for SEPA, agrees that the model fails to be able to predict where most of the waste ends up (because much of it will travel the 1km to the edge of its modelled box and then be ignored) and that a better model would probably be too computationally expensive.
A lot more data is needed about the flow around the Scottish coast for these models to be of much value. The model cannot allow for less frequent but important resuspension events, such as storms.
We have asked a professional user of similar computer models about NewDepomod. He said, ‘I would also like to have 3d turbulence spectra for many sites and depths. Even then I’m not sure the model would tell you much more than that the pollution is very widely and patchily dispersed.’
Surely the central questions that need to be answered before deciding how much more to pollute the sea are:
​
What weight of nutrient is it safe to dump into the coastal environment, and what effect will the patchy wide-spread deposition of sea louse treatments, nutrients and other fish farm waste have on the ecosystem?
Best wishes
Friends of the Sound of Jura
