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
​
​
Newsletters
Home > Newsletters > Newsletter No16
Newsletter No16 25th April 2018
Dear Supporter,
We are pleased to tell you about our new website, which includes a summary of the Dounie campaign’s success. :-
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https://www.friendsofthesoundofjura.org.uk
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We remain concerned that more applications for new fish farm in the Sound will come forward, because the industry has plans to double its size by 2030.
The Scottish parliament is currently holding an inquiry into the environmental and economic impacts of fish farming in Scotland. The Parliament’s Environment, Climate Change and Land Reform Committee invited the Friends of the Sound of Jura to give evidence, as a community group, on 6th Feb.
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http://www.parliament.scot/parliamentarybusiness/report.aspx?r=11359&mode=pdf
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The inquiry started in February will carry on through May. It is taking evidence from many involved in the industry, NGOs and regulators.
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We agree entirely with the ECCLRC's conclusion:
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'Further development and expansion must be on the basis of a precautionary approach and must be based on resolving the environmental problems. The status quo is not an option.'
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The Rural Economy and Connectivity Committee then launched a call for views. The deadline for submissions is Friday 27 April. FoSoJ has submitted written evidence to the REC committee. You can read it here https://docs.wixstatic.com/ugd/2aea85_3d9f1462a5c841fe8910c2697ca9d4b9.pdf
These are some of the concerns we have highlighted in our submission to the RECC :
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That sea lice from farmed fish are affecting wild salmon and sea trout, the likelihood that pesticide pollution is affecting crustacean fisheries, that seals are being shot by fish farmers and cetaceans are being displaced by seal scarers, and that the expansion of the industry is likely to require unsustainable fisheries such as krill, to satisfy its need for Omega3 oil-rich feeds for the farmed fish.
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The difference between industry estimated figures on the benefit to our economy and the reality of the costs versus benefits especially to west coast communities.
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The economic case for expansion that counts the £16.5 million spent on pesticides as a benefit.
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The regular breaches of licences, but the lack of prosecutions for persistent offenders by SEPA and the Fish Health Inspectorate.
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The regulator's reliance on the industry to supply data on its environmental impacts voluntarily.
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The strange situation that, despite the government's 'polluter pays’ policy, aquaculture is the only polluter allowed to discharge its untreated waste in the sea for free.
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SEPA’s acknowledgement that their modelling ignores what happens to waste leaving its limited modelled area. (99% of the waste at the proposed development at Dounie would have been ignored!)
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Harmful algal blooms caused by dissolved nutrients are on the increase. Nutrient inputs from current levels of aquaculture in parts of the west coast already contributes more than 80% of land-derived inputs.
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Unsustainable numbers of wrasse are caught in the wild as cleaner fish (they are killed afterwards).
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We recommend a moratorium on fish farm expansion, at least until the Parliamentary Inquiry report is published and has been acted on, and until sufficient information has been gathered to judge the environmental effects of salmon farming, at its present size and after expansion.
If anybody else would like to add their views or read other evidence this is the link:-
http://www.parliament.scot/parliamentarybusiness/CurrentCommittees/107585.aspx
The ECCLR committee's report makes it clear that sea lice from fish farms cannot be allowed to continue to impact wild salmonids. SEPA has a legal biodiversity duty here and a duty to apply the precautionary principle. SEPA however say that the local councils are the ones responsible for wild fish.
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Richard Kerr of our own Argyll and Bute Council wrote to the ECCLR "responsibility for wild fish interactions has been inappropriately allocated to Planning Authorities, who given their reactive role, are not in my opinion the best placed regulator to address this issue on a comprehensive basis, taking into account cumulative effects."
​
http://www.parliament.scot/S5_Environment/Inquiries/003_Argyll_and_Bute_Supp.pdf
At the RECC hearing on 18th April, Mark Harvey of the Highland Council planning department said:- "Industry has set a challenge to double production but no-one knows the capacity of Scottish waters to absorb that much", adding: "It is a huge amount of work - it feels that we are 30 years too late. In 2018 we should have the answers. We are nowhere near."
Asked at the same hearing whether anyone knew what the carrying capacity of Scotland’s seas is for fish farms, SNH replied "we are quite a long way from that".
Representatives of FoSoJ and CROMACH met Anne Anderson of SEPA to talk about our concerns and were given a presentation about the new modelling system.
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You can read our follow up questions on https://www.friendsofthesoundofjura.org.uk.
There has been a lot of press and TV coverage about the problems with fish farms as they are at present levels of regulation. You can catch up with some of it on https://www.friendsofthesoundofjura.org.uk.
Thank goodness the flapper skate, sea trout, salmon smolts, northern sea fans, soft corals, sponges, juvenile cod, crabs, prawns, yachts, kayakers, swimmers and the rest of the diverse life around Dounie can carry on as normal … at the moment.
Please reply if you would like to opt out of future emails from Friends of the Sound of Jura which will be about developments that affect the Sound, including future fish farm applications.
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Friends of the Sound of Jura