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Home > Info > Follow up to aquaculture meeting with Marine Scotland - unanswered questions

The Head Planner at Argyll and Bute Council asked us to contact Marine Scotland, saying he must recommend that all fish farms are approved until MS tell him that they risk doing significant harm to the wild salmonid population (or risk significant harm to other parts of the environment). The Council has just approved Scotland’s first 3500 tonne fish farm at BDNC Loch Shuna, near two salmon rivers and on a coast used all year by sea trout. This was despite it having only ‘Borderline’ seabed monitoring status in its latest report from SEPA, at its present size of 2500t. Other 3500+ tonne farm proposals are in the planning pipeline or with SEPA.

The Coastal Communities Network met Marine Scotland on 25th July. MS promised to answer our questions. They replied after seven weeks, on 14th September but failed to answer many of our questions.


This pdf document is our response to Marine Scotland, sent 19 September 2018.



We had asked MS quite a lot of questions - a measure of the depth of our concerns - but even from the quantity of blue text in our response (our replies and unanswered questions), you will see that their answers are mostly evasive and unsatisfactory. MS did not answer many of our most important questions, including whether the risk of harm to wild salmonids is significant and would not even tell us whose job it is to decide.

We planned to ask Roseanna Cunningham to address some of the same questions at a meeting scheduled for 24th September. The Minister has now rescheduled this meeting until we have met Marine Scotland again. Yet another delay.

This is one of our key questions: Given that MS / the Government acknowledge that aquaculture harms wild salmonids, many PMFs, crustaceans, cetaceans (by disturbance), and (via its dissolved nutrients) that it has the potential to cause harmful algal blooms, and that MS / the Government do not know the significance of these risks, which may harm national populations of these animals and the existing jobs of those who depend on them, how can the Government allow the industry to expand without determining that significance?

This lack of knowledge was confirmed when the Scottish Parliament’s Rural Economy committee asked Scottish Natural Heritage's aquaculture lead, Cathy Tilbrook, whether the carrying capacity of Scotland’s sea’s was known for aquaculture. She replied, ‘we are a long way from that’.

If there is a likely impact on the environment, but its significance is unknown, the legally-binding precautionary principle should apply - this is that developments should not go ahead when there is known to risk harm to the environment. If the significance of the risk is unknown, the development should be halted until that significance is established. Quite rightly the Scottish Government has restated its commitment to this principle, even after Brexit, but seems reluctant to apply it to some aspects of fish farming.

We have written to ask Ms Cunningham whether she will apply the precautionary principle to protect wild salmon and sea trout from the parasitic sea lice produced by many fish farms, or whether she prefers to oversee the demise of wild salmon on the west coast.

We have also asked her whether she is happy to explain to our shellfish fishermen that the Government is still allowing aquaculture to dump its pesticides in the sea, when all these chemicals are known to harm crustaceans. The impacts of these chemicals on commercial shellfish have not been studied, despite the clear risk to their livelihoods.

(For instance, one study (‘PAMP2’) recently found an average 60% drop in crustacean abundance where fish farms use emamectin. The ‘PestPuls’ study on Norway has found that commercially fished shrimps in Norway die at hydrogen peroxide doses 1000 times less than those used in fish farming. The other licensed chemicals kill commercially-fished crab larvae in Chile, at doses lower than typically used in aquaculture.

If Scottish salmon is cheap it is because the sea, and those who use the sea are paying the price, rather than the polluters.

Rural jobs do matter. We are not asking for the expansion not to happen. We are asking the Minister to lead by example on Scotland’s behalf, by requiring all new farms to expand responsibly, by using closed containment. Norway is doing this. We should too.

It is time to solve the industry’s problems by making this step-change. These companies are making record profits (1 billion Euros operating revenue reported for Marine Harvest this year). They can afford to behave responsibly, as the same companies are in Norway. shows their own site in Norway, which harvested 2000 tonnes of salmon in 2016, having operated closed-containment for six years without any sea lice, while capturing and recycling fish waste for biogas, and also powering the site with renewable hydroelectricity.

Scotland’s farmed salmon industry should be the greenest in the world and something to be proud of. It is time for bold leadership, not time to hide behind waffle, as Marine Scotland have done with their response to our legitimate and strongly felt concerns.

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