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Newsletter No6 22 June 2017

Evening Event - 16th July in Tayvallich

For the latest news please come to Tayvallich Village Hall on 16th July at 7:30pm.

Underwater photographer Mark Woombs is going to show us the wonders of the Loch Sunart to Sound of Jura Marine Protected Area and John Aitchison will sum up the situation regarding Dounie and suggest what else the Friends of the Sound of Jura might do to make the most of having the MPA on our doorsteps.There will also be outstanding cakes from Cake-away!

Entrance is free.


Dounie's SEPA CAR License Application and Sea Fans

SEPA are still considering the Dounie application from Kames Fish Farming. They say they received around 80 representations about this and will probably take until October to respond. 

In the meantime they have requested that Kames perform another biological survey of the seabed because the one they submitted did not identify rare northern sea fans (despite one being clearly visible in still frames from the video submitted to SEPA). The deadline for this is in mid-August.


Northern sea fans are classed as Priority Marine Features by Scottish Natural Heritage and they warrant protection for that reason. 


While we wait for this process to take its course we are organizing our own diver survey of the bay to map the sea fans independently.


Press Coverage

There has been quite a bit of press interest since the last update. 

For more information please see the Dounie facebook page

and website 

We have a Twitter account too

If SEPA approve the license and Kames apply for planning permission we will push hard for more press coverage.


Looking Ahead

With the Scottish Government aiming to double aquaculture production by 2030 and A&B saying fish farming 'is one of the key industries identified by the Council to assist in the strategy to stem depopulation, the Council's number one priority', Dounie is unlikely to be the last proposal for a fish farm in the Sound of Jura, so it makes sense to look ahead and to get involved in how these decisions are made. 

For that reason some of us recently took part in a workshop in Glasgow (part of the Marine Ecosystems Research Programme, run by SAMS in Oban and Plymouth Marine Laboratory) to try to learn more about marine planning and to make sure that the opinions of coastal communities as well as developers are heard. The same study will include a film, showing various opinions about uses of the sea. Dougie was interviewed for it last week. 


This week a different group met another researcher from SAMS, working on an EU-funded study of social limits to the expansion of fish farming. We explained our community's position and will now be included in her study. 

One of its likely conclusions is that there is little point pushing for fish farms where communities do not want them and while other communities are keen to have them. Whether this will affect the Dounie decision is not yet clear.


The Inadequacies of Planning Permission 

One outcome of these meetings is that it is clear that the council's planning process is not suited to deciding about fish farm permissions. The council themselves acknowledge this. The Planning Committee is not allowed to consider the cumulative effect of other existing fish farms, it has to give permission forever and it has no way to control what happens if there's a subsequent problem caused by the fish farm, for instance if an infestation of sea lice affects wild salmon and sea trout, as is likely at Dounie and elsewhere. The council are aware that they have signed up (as have all public bodies) to having a duty to preserve biodiversity. That includes protecting wild sea trout and salmon. They know they are vulnerable to being sued for failure to do this and so are the government agencies which also fail in this respect. The agencies find it hard to account for the effects of fish farming on the wild fish because they spend part of their lives in freshwater as well as in the sea. No-one seems to want to take responsibility for them, particularly as the evidence has mounted for their decline being mainly caused by fish farming. Strangely it is Marine Scotland rather than SNH that has the most responsibility for wild salmon and sea trout, and the council have the final say.


The Emamectin Benzoate Scandal

The press have revealed a string of failures and bad behavior by some of those with a vested interest in expanding salmon farming. The Sunday Herald in particular has uncovered an attempt to bury the results of a study that appears to show that widespread harm is done to crustacea, including crabs, lobsters and prawns, on a scale of whole sea lochs. The study attributes this to the chemical emamectin benzoate, widely fed to salmon to combat sea lice. This study was published online and without any publicity, only after until it had been 'wrapped' in another document containing the critical views of five anonymous reviewers who pointed out its flaws. Freedom of Information requests have since revealed that four of these reviewers work for the American company that manufactures the pesticide fed to the fish. 

SEPA and a few other 'lone voices' on the board of the government-funded body that commissioned this research objected to this in private emails, but the board decided it was right to maintain the reviewers' anonymity. The fifth reviewer was appointed by the same board.


With revelations of this type it is hard to trust much that the government or its agencies tell us about the safety of the chemicals licensed for use in salmon farms. Much of the monitoring of their use and impact is done by the fish farm companies themselves.


When the first of these revelations was made, SEPA acted, belatedly, on the study's findings. In a letter to salmon farming companies, which we requested to see under FoI laws, they have somewhat reduced the dosing regime for existing licensed salmon farms. Fish farms also now have to let SEPA know when the pesticide is going to be used and (vaguely) they have to do 'biological monitoring'. 

This falls far short of the outright ban that SEPA discussed in private last year with the Scottish Salmon Producers' Organisation, and which they quietly dropped after lobbying from the industry.

It remains to be seen whether the reduced dosage will affect how many fish could be kept at Dounie, and whether this will change the economic viability of the farm. It is clear though that salmon farms are not inspected very often and, once licensed, unscrupulous operators could increase the dose without much fear of being caught.


Rising Sea Lice

Emamectin benzoate is used to treat salmon infested by sea lice. Even the world's largest salmon farming company, Marine Harvest, acknowledges that these parasites are proving hard to control in Scotland, compared to other countries. This graph comes from their 2016 Annual Report. 

Kames describe Marine Harvest as their 'backers' for the Dounie proposal.


In Norway Marine Harvest seems to have acknowledged this problem, and the enormous losses it is making due to sea lice, by saying that it plans to replace open net salmon farms there with closed containment pens. Sea lice can be filtered out and won't reach the caged fish, so the impact of masses of lice on wild fish should be reduced. It is not clear whether the organic waste from the pens and any chemical treatments will still be discharged into the sea. Closed farms at sea will still have a substantial impact on the landscape and access to existing moorings etc, unless they are sited far from shore.


Council Planning Committee

All three mid-Argyll councilors were re-elected in the recent council elections.

Donnie MacMillan and Sandy Taylor are still on the planning committee which comprises 15 members.

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