SEPA Consultation Response by the SFPG
To: SEPA’s Assimilative Capacity Working Group (ACEWG) –
acewg@sepa.org.uk
From: Don Staniford, The Salmon Farm Protest Group:
www.salmonfarmmonitor.org
Date: 1st June 2004
Please find enclosed the formal response of the Salmon Farm Protest Group (SFPG) to
your recent consultation on “Carrying Capacity: A Priority for Action”:
http://www.sepa.org.uk/aquaculture/projects/index.htm
In summary, the “Assimilative Capacity Working Group Report” is:
- biased in favour of the expansion of the sea cage fish farming sector
- based upon flawed assumptions and scientific principles
- wrong to consider a policy of larger farms
- wrong to focus increased production on large mainland lochs such as Fyne, Torridon,
Sunart, Ewe and Linnhe
- characterised by information gaps
- dismissive of the impact of chemical wastes
Specific points addressed here are:
1) Industry-bias
2) Fundamentally flawed
3) Big is not better
4) Expanding production in large mainland lochs is illogical (and illegal)
5) Information gaps
6) Impacts of chemical wastes
These points are dealt with in more detail below:
1) Industry-bias:
The “Assimilative Capacity Experts Working Group” who produced the report is biased
in favour of the expansion of the sea cage fish farming sector. Marine Harvest (Nutreco)
and the Federation of Scottish Aquaculture producers, for example, are represented but
neither the environmental or wild fisheries sector are party to the discussions.
The report states that “the group may in future seek additional expert assistance as
necessary” (p4). The SFPG therefore strongly recommends that Mr Allan Berry and Dr
Malcolm MacGarvin (author of the WWF report “Scotland’s Secret: aquaculture, nutrient
pollution eutrophication and toxic blooms”: http://www.wwfuk.org/filelibrary/pdf/secret.pdf) are invited to join the Working Group.
2) Fundamentally flawed:
The entire report is based on the false assumption of “assimilative capacity”; namely “the
ability of an area to maintain a healthy environment and accommodate wastes” (p4).
Sadly, the solution to pollution is not dilution. The sea cage fish farming sector cannot be
allowed free reign to pollute with impunity. Scottish salmon (and cod) farmers are being
allowed to use pristine marine waters as an open sewer. Closed-containment systems and
waste-water treatment technology is dismissed in just two sentences:
“Conventional cage design does not permit treatment of wastes before their discharge to
the sea. Cage fish farming as practised in Scotland thus relies on natural dilution and
degradation to assimilate its wastes” (p6)
This statement not only ignores recent developments in cage design and closedcontainment technology (for a review see “Closing the Net” – download via:
www.salmonfarmmonitor.org/documents/indreports.html) but it also ignores SEPA’s
own report into waste-water treatment of salmon farming wastes published way back in
1998 (“Collection and treatment of waste chemotherapeutants and the use of enclosedcage systems in salmon aquaculture”: http://www.fwr.org/fisherie/sr9705f.htm). Waste
collection systems do exist but are dismissed out of hand by salmon farmers as too
expensive. But what about the costs to the marine environment, tourism, the shellfish
industry and wild fish sector?
Similarly, the concept of “Allowable Zone of Effects” (“fundamental to the system of
environmental management adopted in Scotland”, p6) is fundamentally flawed. By
advocating such an approach SEPA is more Scottish Environment Pollution than
Protection Agency. By accommodating the further expansion of sea cage fish farming,
SEPA is cravenly kowtowing to the sea cage fish farming sector.
3) Big is not better
The Working Groups recommendation for “Assessing the potential of a smaller number
of larger fish farm production units to reduce overall environmental impact” (p1 of the
summary) is both illogical and comical. It is widely known that companies such as
Marine Harvest (conveniently represented on the Working Group) want to intensify
production via a policy of super-salmon factory farms (“Big ambition for salmon farm
boss in line of fire” (The Sunday Herald, 16th May 2004):
http://www.sundayherald.com/42008). However, this has everything to do with cutting
costs and nothing to do with reducing environmental impact. As the report states: “The
industry has indicated a wish to produce at fewer but larger sites in order to cut costs”
(p17).
Sanctioning further increases in production is environmentally unacceptable and arguably
in contravention of the UK’s international obligations under OSPAR. Farm size has
already increased dramatically. In 1992, for example, there were only 16 farms
producing over 500 tonnes but by 1999 this had increased to 81. Now there are farms
producing in excess of 2,000 tonnes (a 2,000 tonne salmon farm produces the sewage
waste equivalent to a town of 40,000 people).
Salmon farmers (aided and abetted by the Scottish Government) seem hell-bent on
further expansion at all costs and are desperately trying to squeeze even more production
from existing biomass consents. Rydberg et al (2003), for example (cited on p11 of the
Working Group report but not discussed in detail – see point 5), warns of the increased
wastes from maximising biomass: “There are margins for a higher production within the
limits given: instead of growing one batch of fish for a period of 19 months, which seems
to be the normal case, it is possible to start farming at different occasions and thereby to
keep a maximum biomass for a longer period and also to increase production…..an
increase will have effects on the total waste production and, particularly, on how this is
distributed throughout the year” (p9)
Pollution problems and water pollution incidents involving salmon farms are already
increasing not decreasing (“Fish farming pollution is up by 100%” (The Sunday Herald,
18th May 2003: http://www.sundayherald.com/33928). SEPA should therefore be
reducing not expanding salmon farming production. The SFPG therefore strongly
support Recommendation 7 – “Effects of fewer larger sites”. Namely that: “Research is
needed into the implications of farm amalgamations, and into the effects of a decrease in
number and increase in magnitude of individual discharges of sea lice treatment
chemicals and organic pollutants” (see point 6 for a discussion of chemical wastes).
Moreover, in terms of contamination of sediments with organic pollutants such as PCBs
and dioxins the SFPG would urge SEPA to publish the latest finding from its 2001
“Report on the occurrence and significance of polychlorinated biphenyls in marine
sediments from Scottish fish farm locations”.
4) Expanding production in large mainland lochs is illogical (and illegal)
The report makes a serious mistake in promoting the expansion of sea cage fish farming
in Scotland’s already overloaded mainland lochs:
“The main scope for increased production lies in the large mainland lochs exemplified by
Fyne, Torridon, Sunart, Ewe and Linnhe” (p15)
This statement completely ignores the fact that these same loch systems are also home to
wild salmon and freshwater mussels (species protected under the EC Habitats Directive)
as well as a commercially important shellfish farming sector. In the case of Loch Fyne,
for example, Loch Fyne Oysters have an international reputation for producing shellfish
in pristine waters (even if this image is far from reality). Permitting increases of salmon
farm wastes is a recipe for ruin. Even more so when one considers the fact that Loch
Fyne is already the most densely farmed area in the whole of Scotland.
Rydberg et al (2003), for example (cited on p11 but not discussed in detail – see point 5),
identify “Hot Spots” – areas in Scotland with highest fish biomass. The top “hot spots”
include Loch Fyne (No 1 with 9,240 tonnes of biomass), Loch Roag (No 2 with 7,775
tonnes), Loch Sunart (No 4 with 6,020 tonnes), Loch Seaforth (No 5 with 5,901 tonnes)
and Torridon (No 14 with 3,654 tonnes). How are increases in production in these
already over-loaded lochs compatible with nature conservation considerations?
The SFPG are therefore fully supportive of Recommendation 8 – “Conservation” (p19).
It is heartening to hear that “the EU is funding a project to determine the impacts of fish
farms on SACs, and SEPA, SNH and Marine Harvest are involved in joint research to
quantify fish farm impacts upon maerl beds” (p18). However, given that stocks of wild
salmon are already extinct in several areas on the West coast of Scotland is this not a case
of too little, too late?
5) Information gaps
The introduction of the report refers to an aim of the Working Group (as stated originally
in the Scottish Executive’s ‘Strategic Framework for Scottish Aquaculture’) of
“identifying gaps in existing knowledge”. However, the report patently fails to plug the
information gap. Sea cage fish farming’s “potential to contribute to harmful algal
blooms” (p19) is dismissed in just a sentence and ignores extensive scientific research on
the subject. For a review see:
“The Five Fundamental Flaws of Sea Cage Fish Farming”
(www.salmonfarmmonitor.org/documents/indreports.html)
“Big Fish in a Small Pond: the global environmental and public health threat of sea cage
fish farming” (http://www.watershedwatch.org/ww/publications/sf/BigFishSmallPond(Chile).pdf)
Perhaps more seriously, there is also deliberate censorship of information that is already
in the public domain. For example, no mention whatsoever is made of the Scottish
Executive/SEPA report: “OSPAR Eutrophication Assessment of Aquaculture Hotspots in
Scottish Coastal Waters” (FRS report no 07/03). This report, inter alia, stated that:
“A significant relationship was observed between nitrogen enrichment from fish farming
and N/Si ratios in the areas surveyed” (p3)
Moreover:
“Nitrogen excretion by farmed fish results in the release of soluble nutrient nitrogen into
receiving waters. The remainder of nutrient nitrogen from the feed applied to cage farms
that is not incorporated into fish growth, is released into receiving waters in particulate
form, either as waste feed pellets or as faecal material. Nitrogen in particulate form will
settle on the seabed, usually in the vicinity of the fish farm cages and a proportion of this
nutrient source will ultimately be re-mineralised and contribute to the soluble inorganic
nutrient nitrogen loading of the receiving waters. As has been demonstrated, the Scottish
salmon farming industry has expanded steadily over the last decade. Increasing nutrient,
particularly nitrogen, inputs from salmon farms have been blamed for causing algal
blooms in coastal waters and also to lead to eutrophication” (p13)
And it points out that:
“Overall levels of nutrient discharges from aquaculture have been increasing on a
national scale and are expected to increase further if the industry continues to expand at
its present rate” (p77)
“The total discharge of nutrients from aquaculture in Scottish coastal waters has been
increasing over the past 10-15 years” (p82)
The report also calculated that the total discharge of nutrient nitrogen was 48.2 (per tonne
of production) for farmed salmon but rising even further for other species such as halibut
(67.1), cod and haddock (72.3) and turbot (86.9). The plain fact is that the switch from
salmon to cod production, for example, will increase the waste problem yet further (see
“Fish farming increase 'a serious threat to Scotland's water
system'”: The Scotsman, 23rd June 2003:
http://thescotsman.scotsman.com/index.cfm?id=686232003).
In view of the diversification of the Scottish fish farming sector into other finfish species
such as cod, halibut and haddock should this important information not be incorporated
into any new modelling procedures? The failure to account for these new developments
is a serious omission.
Another paper presented to OSPAR last year – “Application of the ERSEM to assessing
the eutrophication status in the OSPAR Maritime Area, with particular reference to
nutrient discharges from Scottish salmonid aquaculture” – is also not mentioned in this
consultation. For example:
“Salmon farming contributes 6.1% of Scotland’s nitrogen and 13.9% of phosphorus input
to the sea (based on 2001 production figures” (p17)
This represented a rise from 4.8% and 11.2% respectively since 1999. Moreover, “in the
Northern and Western Isles, aquaculture inputs formed that major part of the total load”
(p11). The significance therefore of aquacultural wastes (especially in particular areas
and at particular times of the year – namely the summer) must not be underestimated.
Given the expansion of the salmon farming industry since the 1980s and the projected
expansion of the cod farming sector, aquaculture’s contribution to Scotland’s nitrogen
and phosphorous nutrient loading will increase still further. The risk to the shellfish
sector and the risk to the spread of harmful algal blooms will therefore increase yet
further.
One paper that is mentioned in the consultation (p11) is “The interaction between fish
farming and algal communities of the Scottish waters – a review” (Rydberg et al: 2003:
www.scotland.gov.uk/library5/environmental/algal.pdf). This paper has some important
points worth reiterating but blatantly ignored in the Working Group’s report:
“In enclosed fjords, fish farming may contribute considerably to hypernutrification and
changing nutrient ratios, particularly during summer” (p2)
“The waste loads are highest during the summer, when the net supply of nutrients is at its
lowest in most fjords. During summer, the fish farm nutrient supply if often greater than
other sources, such as river discharges, waste water inputs and fluxes through vertical and
horizontal exchange” (p9)
Moreover:
“Recent estimates on waste production from fish farms seem to converge towards 50 kg
N (Nitrogen) and 10 kg P (Phosphorus) per tonne of fish produced, implying a discharge
of 8,000 tonnes of nitrogen and 2,000 tonnes of phosphorus to Scottish waters in 2001.
On a local scale, fish farming is probably the largest anthropogenic source of available
nutrients in most of the lochs and voes, especially during summer and towards the end of
a production cycle. In some areas, the nutrient contribution from fish farming most
probably results in observable increases in nutrient levels during parts of the year” (p43)
Finally, there is no reference, for example, to Professor Ted Smayda’s report (requested,
like the Rydberg report, following Allan Berry’s PE 96 and ‘Aquaculture Inquiry’ by the
Scottish Parliament) or to the submissions of Allan Berry to the Scottish Parliament’s
‘Aquaculture Inquiry’ or to the European Parliament (who are meeting again in August
2004 to discuss his petition). SEPA (Andy Rosie) has already attended a hearing of the
European Parliament’s Public Petitions Committee (in April 2004) and is certainly in
possession of Allan Berry’s submissions to the European Parliament (if the Working
Group are interested I am sure Mr Berry can provide them with copies). These are
serious omissions and undermine the Working Group’s report.
6) Impacts of chemical wastes
The report fails to tackle the issue of chemical wastes even though it concedes that
“treatment chemicals may have transient toxic effects on resident benthos or toxic effects
on transitory plankton” (p8). In fact, the Scottish Executive admitted in 2000 that
chemical wastes arising from the use of azamethiphos and cypermethrin can stimulate
algal blooms (“Poison linked to fish farms”: The Sunday Herald, 6th February:
http://www.sundayherald.com/6758).
When considering in-feed chemicals the report states that “experience indicates that
residues from these compounds tend to settle and degrade below and close to the fish
farm” (p17). No mention is made of the fact that 90% of the in-feed chemical
Teflubenzuron (trade name Calicide) is excreted into the vicinity of salmon farms and
can be detected in sediments over two years after application (“Shellfish at risk from sea
louse ‘cure’”: The Sunday Herald, 26th November: 2000:
http://www.sundayherald.com/12277 and “‘Dynamite’ report reveals fish pollution”: The
Sunday Herald, 11th March: 2001 http://www.sundayherald.com/14244). Nor is
reference made to the fact that the in-feed chemical Emamectin benzoate (trade name
Slice) has been found recently in the flesh of scallops harvested near a Maine salmon
farm.
No mention is made of the recent SEPA report (published in February 2004) which found
chemical contamination (from the use of Cypermethrin, Teflubenzuron and Emamectin
benzoate) under 11% of Scottish salmon farms (“The occurrence of the active ingredients
of sea lice treatments in sediments adjacent to marine fish farms”:
http://www.sepa.org.uk/aquaculture/projects/index.htm). Yet SEPA has opened the
floodgate to a wave of new chemicals – issuing over 1000 licences for
Azamethiphos, Cypermethrin, Emamectin Benzoate and Teflubenzuron since
1998 (“Concern over fish farm pesticides – Over 1000 licences for chemicals classified
as ‘pollutants’”: The Sunday Herald, 25th April: 2004:
http://www.sundayherald.com/41587).
When reference is made to the long-awaited Post Authorisation Assessment Project
(PAAP) for sea lice chemicals it is only in passing (“The Post Authorisation Assessment
Project will provide useful data and an appraisal of the long-term risks of repetitive use of
various treatments”, p17). No reference is made to the significant environmental impacts
reported by PAAP (“Big catch - fish farming is flourish at the expense of other marine
life”: New Scientist, 27th April 2002: http://list.zetnet.co.uk/pipermail/seatrout-rev/2002April/000164.html). No wonder salmon farmers want to keep a lid on these damning
scientific findings (“Fish farmers ‘blocked’ vital safety study - salmon producers and
scientists furious as leaked secret report reveals catalogue of problems in £4m pesticide
probe”: The Sunday Herald, 28th April: 2002: http://www.sundayherald.com/24181).
In conclusion, the “Assimilative Capacity Working Group Report” is:
- biased in favour of the expansion of the sea cage fish farming sector
- based upon flawed assumptions and scientific principles
- wrong to consider a policy of larger farms
- wrong to focus increased production on large mainland lochs such as Fyne, Torridon,
Sunart, Ewe and Linnhe
- characterised by information gaps
- dismissive of the impact of chemical wastes
If the Working Group would like any further information please do not hesitate to contact
the SFPG (www.salmonfarmmonitor.org).
Don Staniford, Managing Director of the Salmon Farm Protest Group
1st June 2004