Planning & Development Service
Highland Council
Glenurquhart Road
Inverness
IV3 5NX
By post and email: eplanning@highland.gov.uk
4 October 2013
Dear Sir,
13/02838/FUL - Objection to Marine Fish Farm: Loch Pooltiel Sea Loch In The
North West Of The Isle Of Skye
Please consider this a formal objection by Protect Wild Scotland to the above
application by Kames Fish Farming for a new site consisting of 14 circular cages each
90m in circumference with automated feed barge of dimensions 10.5m x14m in Loch
Pooltiel Sea Loch In The North West Of The Isle Of Skye.
Salmon farming is fundamentally flawed – here’s five ways in which salmon farms
impact on wild fish and human health:
1) Diseases & Parasites:
Salmon farms act as incubators and reservoirs for infectious diseases and parasites
such as sea lice. A scientific paper published by the Royal Society of London in
November 2012 calculated that sea lice from salmon farms kill over a third of wild
salmon!
The lack of published site specific sea lice data is particularly alarming and
represents a potential breach of the UNECE Convention on Access to Information,
Public Participation in Decision-making and Access to Justice in Environmental
Matters (Aarhus Convention).
Protect Wild Scotland is a company limited by guarantee registered in Scotland under
number 454505 and having its registered office at 6 Argyle Street, Ullapool, Ross-shire, IV26
2UB.
From the information that has been published, we know that Kames Fish Farming is
a company plagued by sea lice infestations. For example, a report published in May
2013 revealed that Kames Fish Farming breached sea lice limits at their salmon farm
at Shuna Castle in Argyll.
2) Toxic Chemicals:
Many of the chemicals used on salmon farms are designed to kill sea lice – a member
of the crustacean family – making them lethal to shellfish such as lobsters, crabs and
prawns. The Guardian newspaper reported in September 2012 how Scottish salmon
farmers “use record amounts of parasite pesticides”.
The Guardian also reported in May 2013 how Marine Harvest was “under
investigation after its salmon farms polluted a Scottish loch with toxic pesticide
residues hundreds of times above environmental limits”. The Scottish Environment
Protection Agency “found chemical levels breaching its recommended limits at 72
sampling sites, nearly a tenth of the 792 sites it tested.”
Data sourced from SEPA published in 2012 revealed that the salmon farm operated
by Kames Fish Farming in Loch Slapin was classified as "Unsatisfactory". Data
published recently via the 'Scotland's Aquaculture' database reveals that Kames Fish
Farming discharges Nitrogen, Phosphorus, Zinc, Copper and Organic Carbon. The
data also reveals that Kames Fish Farming uses the toxic chemical Emamectin
benzoate.
Data obtained from SEPA via FOI also reveals that during 2011, Kames Fish Farming
reported the use of the toxic chemicals Emamectin benzoate, Azamethiphos and
Deltamethrin (see attached Excel spreadsheet).
3) Escapes & Genetic Pollution:
Escapes from salmon farms spread so-called ‘genetic pollution’ by interbreeding
with wild salmon. A scientific paper published by the Royal Society of London in
2003 warned that repeated escapes from salmon farms caused “an extinction vortex
in vulnerable populations”.
In February 2012, the Sunday Times newspaper reported that “as many as one in
four wild Atlantic salmon from Scotland has been genetically “tainted” by
Norwegian fish”. Analysis of almost 1,500 wild salmon from the west coast found
369 possessed genetic markers unique to the Scandinavian fish.
Data published recently via the 'Scotland's Aquaculture' database reveals that Kames
Fish Farming suffered an escape of 7,000 farmed fish in March 2013. Kames Fish
Farming reported another 12,000 farmed fish escaping in 2006.
4) Waste Contamination:
Salmon farms discharge untreated wastes directly into Scotland’s sea lochs. WWF
Scotland calculated back in 2000 that the phosphorus wastes from Scottish salmon
farms was equivalent to 9.4 million people – almost double Scotland’s entire human
population!
5) Feed & Food:
The final and the fatal flaw is the fact that salmon farms are dependent upon a feed
supply which is both contaminated and depleted. Scientists have calculated that it
can take up to ten tonnes of wild fish for use in farmed salmon feed to produce one
tonne of farmed salmon. Read more via a letter to Kofi Annan: “Farming Salmon is
Stealing Food from Poor People & Our Oceans”.
The prestigious journal Science reported back in 2004 have Scottish farmed salmon
was contaminated with cancer-causing chemicals such as PCBs, dioxins, dieldrin and
DDT. In July 2013, Norwegian scientists warned once again that the consumption of
farmed salmon was a human health hazard.
In conclusion, the weight of peer-reviewed scientific evidence detailing significant
environmental impacts of salmon farming is now overwhelming (read a literature
review online here).
Protect Wild Scotland objects to the policy of expansion of salmon farming,
particularly on the West Coast of Scotland. The current policy of Scottish Ministers as stated via ‘Scotland’s National Marine Plan’ (2011) - to increase salmon farming
production by 4% annually throughout this decade is fundamentally flawed and
legally unsound. The First Minister’s stated “aim of increasing production by 50 per
cent on 2009 levels to 210,000 tonnes by 2020” ignores the latest scientific research
(including its own Marine Scotland Science publications) and blatantly disregards
impacts on wild salmon and sea trout.
Highland Council must therefore heed the scientific evidence along with the dozens
of public comments opposing Kames Fish Farming and refuse this application.
Protect Wild Scotland concurs with the conclusion of Skye Marine Concern in their
objection yesterday to another salmon farm application on Skye; namely:
"We have to get to the stage where the question is not which loch is most suitable (or
least unsuitable really) for a salmon farm, but whether or not salmon farming is a
suitable industry at all. And then we answer that last question with a resounding
‘NO’!"
Yours sincerely,
Don Staniford
Director, Protect Wild Scotland
Cc:
Colin Wishart: Colin.Wishart@highland.gov.uk
James Bromham: james.bromham@highland.gov.uk