The Salmon Aquaculture Reform Network Scotland (SARNS) is a growing coalition of individuals, environmental, community and conservation groups covering the West Highlands and Islands area, with shared concerns about the future direction of Scotland’s salmon farming industry.
We are petitioning the Scottish Government to clean up Scotland’s unsustainable fish farming industry before allowing it to expand and do further harm to the health of our coastal waters and habitats which will affect the jobs of many of those whose livelihoods depend on them.
Here are the recommendations SARNS is making to the Scottish Government ahead of their inquiry into the impacts of salmon farming:
Open net salmon farming is environmentally unsustainable as practiced in Scotland at the moment. It is the Scottish Government’s duty under the Nature Conservation (Scotland) Act 2004 to further the conservation of biodiversity. By allowing salmon farming to expand in its current form it is failing in that duty, for the following reasons:
- Sea lice and infectious diseases are out of control among farmed salmon, resulting in the deaths of over 10 million fish per year, the equivalent of 25% of total production. Find out more in the recent report commissioned by the Salmon and Trout Conservation Scotland:https://www.salmon-trout.org/wp-content/uploads/2018/01/Thorstad-Finstad-2018-Impacts-of-salmon-lice-NINA-Report-1449-2.pdf
- Sea lice are treated with toxic chemicals, such as emamectin benzoate. This and other pesticides as well as antibiotics are released into the sea, where they harm other marine animals such as shrimps, prawns and lobsters. The Scottish Environment Protection Agency (SEPA) claims that the limits placed on the quantities of chemicals make them safe, but their use is soaring as sea lice, disease and resistance to these chemicals increase. The industry should not be allowed to expand until sea lice and disease are sufficiently controlled.
- The use of so-called “cleaner fish”, such as wrasse to counteract lice, bring problems of their own. Recent reports show that they too suffer from and transmit disease.
- Escaped farmed salmon pose an even greater threat to the survival of wild salmon and sea trout, which are in steep decline on the west coast, through the spread of disease and weakening of the gene pool of our indigenous salmon. An estimated 2.2 million farmed salmon escaped from Scottish farms between 2002 and 2017.
- The use of Acoustic Deterrent Devices (ADDs) to deter predators from open net cages, causes illegal disturbance and can cause hearing damage to porpoise, dolphins and whales. When ADDs fail, salmon farm operators are allowed to shoot seals. More than 1,500 seals were unnecessarily shot in the last six years in Scotland. Farms could fit anti-predator nets as they do Canada where ADDs are banned, but bullets and ADDs are cheaper.
- On land, polluting industries have to pay to clean up their mess. Uniquely this does not apply to salmon farms! According to the report commissioned by the Scottish Parliament, 200,000 tonnes of salmon produce organic waste equivalent to about half of Scotland’s human population of 5.3 million. By 2030, Scottish salmon farmers aim to produce 300,000 tonnes of farmed salmon, which will produce the equivalent of three quarters of all Scotland’s human sewage, which will be dumped untreated into our coastal waters and sea lochs.
- As dissolved nutrients from salmon farms flow into the sea in ever greater quantities, they increase the risk of toxic algal blooms, which threaten our shellfish fisheries and pose severe health risks. When there is doubt about environmental harm, government and local authorities have an obligation to apply the precautionary principle, to safeguard the environment. This must apply to salmon farming.
- The government must acknowledge that some marine areas are so sensitive and important to our ecosystem that they should be completely protected from salmon farming. More than a quarter of salmon farms are sited within or close to areas of importance for Biodiversity Action Plan habitats or species, and around 10% are within or close to Special Areas of Conservation / Special Protection Areas. Many more are inside Marine Protected Areas. The Scottish Government should urgently amend national marine planning guidance, so there is a presumption against any future salmon farming developments inside Marine Protected Areas.
- Currently the salmon farming industry claims its activities are environmentally sustainable. The industry should stop downplaying the challenges their industry faces and take a much more responsible approach to resolving their major environmental impacts. One example is their feed. Salmon has no health benefits unless it contains Omega 3 fatty acids which it would normally gain from eating other fish in natural, wild conditions. The pressure on anchovies from Peru which are used as fish feed is so severe that they are already being exploited to the maximum extent possible.
- The industry is now turning to a mixture of vegetable protein and ‘processed animal protein’ (the bits that no-one else wants to eat). Vegetable proteins are only sustainable if they are grown on land that was not rainforest, specially cleared for that purpose, or when they do not displace other, more sustainable users of the land.
- Due to its environmental remit, the visual impact of salmon farms on the environment has not been considered in the Scottish Parliament-comissioned report. Scotland’s tourism industry thrives first and foremost because of its unique, unspoiled beauty. Tourism earns 14 times more revenue for Scotland than aquaculture and employs at least 130 times more people than the 1,800 or so directly employed on fish farms. In a 2011 survey done on behalf of the aquaculture industry, about one third of people asked, thought that fish farms adversely affected the Scottish coastline. Approximately a quarter did not want to see any increase in their number and one third did not want to see them get any larger. This survey was based entirely on how they look. Imagine if the visitors surveyed had known what was happening underwater…
- International treaties bind our government to use ‘best environmental practice’ and SARNS believes that salmon farming companies should pay a levy on their profits to ensure this happens. This could be spent on moving all salmon farms to closed containment, ideally on land, as isolating the fish from the sea would solve almost all of the problems in one go. Norway, Canada and the US face the same problems with sea lice and disease in open net salmon farms and are moving to closed containment. In fact, open net salmon farms have been banned in all but one state in the US. A Norwegian company recently invested $72 million dollars in a closed containment fish farm in China. If it can be done there, it can be done here too.
- The report commissioned by the Scottish Parliament shows that our government agencies have done much less research into the effects of salmon farming than the governments of Ireland and Norway, which share the same problems. SARNS encourages the Scottish Government to use this research and improve transparency in developing its own scientific advice and decision-making.
- The industry has grown too close to its own regulators. The government environmental agencies SEPA and Marine Scotland are being influenced by a well-resourced industry lobby, as recent Freedom of Information Requests have revealed. A recent blueprint (http://scottishsalmon.co.uk/wp-content/uploads/2016/10/aquaculture-growth-to-2030.pdf) to double Scotland’s salmon production by 2030, published by the salmon farming industry, shows how it intends to create an “enabling environment” to “unlock growth” by “aligning” regulation with “industry ambition”. The Scottish Government currently appears to be supportive of these proposals which are re-designing our environmental regulation and are already being implemented.
- Significant cuts to the budgets of our environmental agencies mean they do not have the resources and powers to enforce the rules. As a result, fish farm operators are mostly self-regulating, reporting their impact on the environment, but with little oversight and even fewer sanctions for non-compliance. Despite hundreds of breaches of regulations in the past, there has not been one successful prosecution.
- SARNS calls on the Government to fund these agencies properly so they can monitor salmon farms entirely independently of the companies they are regulating. The level of funding must reflect the industry’s expansion and enormous profits. Their sales in 2016 were worth £765m, by the way.
- When salmon farms fail to comply with the rules there must be serious consequences. The companies’ licenses should be revoked when they do not respect their terms. At present, the worst offenders continue to pollute and expand their activities in new sites.
Please voice your own concern by signing our petition on 38 Degrees (https://you.38degrees.org.uk/petitions/clean-up-scotland-s-unsustainable-fish-farming-industry) and by contacting Scotland’s decision-makers to show your support.
On 6th February the Environment, Climate Change & Land Reform (ECCLR) Committee took evidence from the public. You can read that evidence here: http://www.parliament.scot/parliamentarybusiness/CurrentCommittees/107592.aspx
You can also watch the video here: https://www.scottishparliament.tv/meeting/environment-climate-change-and-land-reform-committee-february-6-2018
Now, the Rural Economy & Connectivity (REC) Committee want to hear our views on the impact of salmon farming on the environment based on a recently published report: http://www.parliament.scot/S5_Rural/Inquiries/20180125_SAMS_Review_of_Environmental_Impact_of_Salmon_Farming_-_Report.pdf.
The report is long and detailed, so we have summarized some of the key issues for you to help formulate your letters.
Please write to the Rural Economy and Connectivity Committee of the Scottish Parliament, in Word format, using this template
The email address is firstname.lastname@example.org
Or post a letter to Rural Economy and Connectivity Committee, T3.60, Scottish Parliament, Edinburgh EH99 1SP
There are some notes on the inquiry’s page about confidentiality.
The maximum length of submissions is four pages of A4. Submissions must be about the environmental impact of fish farms in Scotland, ideally referring to the report above.
It is better not to just cut and paste the words from this page if possible. Try to add your personal opinions and perhaps your own experiences on the west coast, for instance if you have been affected by the environmental impact of fish farms or if you are a visitor who might not come to Scotland again because of the visual or environmental or landscape impact of fish farms, then tell the committee. If reading about these environmental impacts has put you off buying farmed Scottish salmon, then say that too!
Remember that the deadline is 27 APRIL 2018!