Newsletter No3 10th March 2017
Thank you for supporting the campaign to protect Dounie Bay and its surroundings from being filled with more than a million caged salmon or rainbow trout, and the damage this enormous fish farm would do to the coast we all love. Here is an update on how it's going:
We've done all we can with SEPA since the deadline for objections to their CAR license to pollute has passed. SEPA is still considering the application.
We are unable to do much more with the council and its planners until the planning application is received - then it will be all hands to the pumps to convert the petition signatories into well-informed letters of objection. This may not happen for months if SEPA takes a long time, as looks likely.
SNH have written to SEPA with concerns about the impact on the crustacean food of the rare skate, and made a request for more survey work to be done by Kames, having possibly identified a rare community of seabed animals (sponges and northern sea fans) in the video footage supplied by the company. Kames told SEPA that there was no wildlife of conservation concern at Dounie, apart from the skate.
There has been terrific support from local communities and individual people, locally and further afield. As of 6th March the local petition had passed 533 signatures and the more recent 38degrees online petition had 464 signatures on 10th March, totaling nearly a thousand names! (https://you.38degrees.org.uk/petitions/no-to-fish-farm-in-the-sound-of-jura)
At this stage, while we wait for SEPA's decision and for the council planning application, it's mostly about spreading the word, showing the council, our MSPs and so on, that many people care and that we will not be easily dismissed, so please keep circulating news of these petitions and the campaign to your friends by any means you can.
When the time comes to object to the council planning department we will contact everyone who has provided an email address on either petition. Once the council receives a formal application for planning permission there will be a 21-day window within which to write, quoting the planning application number. In the meantime we are gathering information on the most effective kinds of objections and will circulate this when the time comes.
Keep in touch!
Please keep in touch with the campaign via the Friends of the Sound of Jura Facebook page, the website and on Twitter.
In the meantime we have been organizing events to draw attention to the proposal. The chilly protest swim at Dounie in February was featured on the front page of the Argyllshire Advertiser and also in the Glasgow Herald, and a sea kayak protest at Dounie is planned for 11th March.
We are aiming to send at least one letter a week to the Argyllshire Advertiser. There were letters to the editor in the 10th, 17th, 24th February and 3rd March editions.
There was an article in the Sunday Mail on 29 Jan 2017 about a possible threat by the fish farm to the endangered skate.
In the wake of recent and extensive coverage on sea lice and overuse of chemicals by fish farms, the Sunday Herald published a report and opinion piece (16th Feb 2017), calling on SEPA to consider 'the sheer weight of opposition' to the Dounie fish farm application.
Friends of the Sound of Jura was also mentioned in an opinion article by the Scotsman (21 Feb 2017) about the 'unbridled expansion of Scottish fish farming'.
On 26th February and 5th March the Sunday Herald ran articles and opinion pieces on pollution from fish farming in 45 lochs in Scotland, alleging that SEPA had failed to act immediately on a new pollution study because of pressure from the fish-farming industry. One of the industry's key anti-fish louse chemicals has proved to be lethal to lobsters, crabs, prawns and other crustaceans on a 'sea loch scale' and apparently has no safe minimum level. This is big news as it has caused SEPA to review every fish farm license for that chemical.
It's yet another factor that will increase the number of sea lice, which is bad news for the wild salmon and sea trout they also affect - and yet another reason to oppose the plans for Dounie. (More on this below)
We have also written to the angling press this week and there's a plan to get an article about skate into the Argyllshire Advertiser, with another article coming out soon in Yachting Life.
We are looking at ways to broaden coverage by the press and to engage TV and radio soon as well.
In January, we met Michael Russell MSP. As a Scottish Government minister he supports the sustainable expansion of aquaculture but he quickly agreed that Dounie is not an appropriate site for a fish farm and maintained this position even after a meeting with Kames Fish Farming. Mr Russell wrote on our behalf to Fergus Ewing MSP (Cabinet Secretary for the Rural Economy and Connectivity, Scottish Government) and to the Cabinet Secretary for the Environment, stressing that this proposal would need very careful consideration. Mr Ewing recently replied, taking the line you would expect from his position, that the planning process will assess all factors including environmental issues and local concerns. Our task is to show that Dounie is incompatible with the government's stated position that fish farm 'growth must be sustainable, with due regard to the marine environment and alongside other marine users'. Mr Ewing also said that if an application were rejected and the applicant were to appeal, it would be referred to Ministers.
Michael Russell MSP offered to arrange for us to meet Fergus Ewing, when we have our petition ready to present to him. It's important to get the timing right to make the most of this opportunity.
We have written to all the MSPs for our area and we are also contacting the Green Party centrally.
One MSP, Pauline McNeill, the 'sea trout champion' has been invited to a Salmon and Trout Conservation Scotland event for MSPs in Holyrood next week, at which S&TC will explain in detail the dangers posed to wild fish from inappropriately sited fish farms and what MSPs can and should do about it. Wild salmon and the rare skate do not have MSP 'species champions' of their own.
On 16th February several of us met mid-Argyll Councillor, Dougie Philand. At the meeting, we asked Cllr Philand for clarification on the Council's planning application process, especially whether they would require the applicant to produce an Environmental Impact Assessment. He has forwarded an answer on this from Mr Kerr, the planning officer:
'We will almost certainly require an EIA for Dounie. The applicants EIA screening and scoping request is currently out to consultation from us to the likes of SEPA, SNH and HES. Their responses will inform our screening response (whether an EIA will be necessary) and our scoping response (what it should contain if one is required). Generally the situation with fish farms is that we normally require EIA for new sites, but are less likely to do so for extensions or alterations to existing sites – unless they are in especially sensitive locations.'
Having an EIA will give us a better chance to publically scrutinise the applicant's plans but it could make quite biased arguments, playing down some important aspects, so we are gathering as much information as possible in advance.
Especially useful would be any details of the economic losses that local businesses feel they would suffer as a result of the fish farm. Please get in touch if this might be true of your business or of any others you know that might wish to join the campaign for this reason.
Local groups and other organisations
It was good to see the recent launch of CROMACH (Craiginsh Restoration of Marine and Coastal Habitat) in Ardfern - another local organisation campaigning to maintain and improve the health state of the sea locally - https://www.facebook.com/cromach/
We have had several meetings with other local organisations, including Community Councils. Community Council objections count heavily with SEPA and the council as they are 'statutory consultees', so it is vital that when the planning application is received we do everything we can to urge all the local CCs to formally object. North Knapdale Community Council opposes the fish farm proposal and Dunadd CC and Lochgilphead CC also objected to SEPA. Craignish, Ardrishaig and Lochgilphead CCs are considering what to do.
We gave a presentation to the Lochgilphead Angling Club about the potential impact on the River Add fishery. At its recent AGM, the club agreed to oppose the proposed fish farm and urged its 250 members to write to the Councillors. Many have signed the petition, thanks largely to Dugald Mcgilp.
We are lobbying yachting organisations about the impact on the practical use and the charm of the established anchorage at Dounie - hoping that they will object formally.
We are trying to get commercial fishing organisations (specifically creelers) to object too, as they are statutory consultees in the planning process.
We are trying to engage the local tourism associations and will discuss Dounie with the various businesses that form part of the Heart of Argyll Tourism alliance when they meet later this month, likewise with ACT - another tourism body.
We are looking into the impacts of the fish farm on the view from Castle Dounie, which was designated as a scheduled historic monument in part because of this view.
Wider press attention
The campaign has coincided with a lot of press interest focused on chemical pollution and the impact of sea lice. Fish farm expansion has also been receiving scrutiny in the press recently. The most significant development was reported in the Sunday Herald last weekend. A study published back in August 2016, to no press attention, showed that the in-feed sea lice chemical SLICE (emamectin benzoate) appears to harm crustaceans more than SEPA's regulatory regime has previously accepted. This is one of the chemicals found to have polluted 45 sea lochs at levels over the previous officially permitted thresholds. SEPA have taken until now to act on this report. Meanwhile freedom of information requests show that SEPA have been discussing with the salmon producers how best to limit this PR disaster. Only when the Sunday Herald published this information did SEPA announce that they are reviewing all fish farm licenses for SLICE, but that they are not contemplating banning the chemical, despite the report saying there is no safe minimum dose.
It hardly fills you with confidence does it? SLICE is one of the chemicals Kames has applied to SEPA for permission to use at Dounie. Another one, azamethiphos, 'failed to achieve a compliant pass' in SEPA's pollution dispersal model, according to Kame's own application. SEPA have not confirmed what this means.
The fish farming industry and its regulator are clearly in disarray and, if deprived of the two main anti-sea lice pesticides, how will Kames or any other salmon farmers stop infestations of sea lice getting out of control at Dounie and elsewhere? Ours is the worst region for sea lice problems in Scotland and Dounie is right by the wild salmon and sea trout of the Add.
The greatest risk to them is when the smolts make their way to sea. Returning adults can tolerate a higher lice load than young fish and they get into freshwater fairly soon which causes the lice to fall off. Once a smolt picks up a louse it's there for life and many of them will be killed by the parasites before they can return to the Add to breed.
Kames have been stating in the press that Dounie would be a rainbow trout farm and that trout don't have many problems with sea lice, but this is simply not true. They've applied to SEPA for both salmon and trout permission. A much smaller rainbow trout farm in Loch Etive has had to treat its fish with several chemicals (including SLICE) for sea lice month after month.
Here are some of the treatments given last year:
'All farms (except Etive 2, which was fallow at the end of last year) were treating regularly for sea lice in autumn 2016, in fact every month (except Etive 4 in December, probably because they were starting to harvest out there) … this is a very substantial change from the 2010 position, where no chemical treatments were needed on Etive.
Clearly, the Etive lice issue goes on, carrying on where the lice left off last summer ... There was constant treatment for lice through the spring and summer at Etive 4, which treated for lice in March, April, June, July and August with azamethiphos, and in September with deltamethrin. Etive 6 treated in June, July, August and September with deltamethrin, as well as with emamectin in September. Etive 5 (Ardchattan) treated in July, August and September with emamectin, as well as with deltamethrin in September after restocking in July. '
You can see there's a lot going on with the campaign and a lot still to do, so let's keep up the momentum while remembering that we may be in for a long haul.
The spring and summer are a good chance to gather support from visitors and especially to prove that tourists really don't like fish farms - something the industry contests.
Well done and thank you to all the people who are working so hard to protect us all from this development.
Friends of the Sound of Jura