Newsletter No16 25th April 2018
We are pleased to tell you about our new website, which includes a summary of the Dounie campaign’s success. :-
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.
The inquiry started in February will carry on through May. It is taking evidence from many involved in the industry, NGOs and regulators.
We agree entirely with the ECCLRC's conclusion:
'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.'
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 :
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.
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.
The economic case for expansion that counts the £16.5 million spent on pesticides as a benefit.
The regular breaches of licences, but the lack of prosecutions for persistent offenders by SEPA and the Fish Health Inspectorate.
The regulator's reliance on the industry to supply data on its environmental impacts voluntarily.
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.
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!)
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.
Unsustainable numbers of wrasse are caught in the wild as cleaner fish (they are killed afterwards).
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:-
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.
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."
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.
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.
Friends of the Sound of Jura