The Long Read: Despite Millstone Point, our campaigning is not yet done!


From Deep Sea to Inshore Scottish Waters

By Sally Campbell

Featured image shows Deep sea life in the Azores – Spiral Tube Worm. Photo credit: Greenpeace Gavin Newman

Deep Sea Issues

Greenpeace’s report In Deep Water provides a comprehensive overview of the environmental risks posed by deep sea mining and calls on governments to agree a strong Global Ocean Treaty in the next 12 months that puts conservation, not exploitation, at the heart of ocean governance.

‘The health of our oceans is closely linked to our own survival. Unless we act now to protect them, deep sea mining could have devastating consequences for marine life and humankind.’ says Louisa Casson, ocean campaigner at Greenpeace. ‘The deep sea is the largest ecosystem on the planet and home to unique creatures that we barely understand. It should be studied not exploited’.
As companies queue up to extract metals and minerals from the ocean floor, the report reveals damning evidence confirming that the mining industry too is aware of the risks and that their activities could result in the extinction of species that form the first link of the food chain. It also explains how deep-sea mining could drive the climate emergency by disrupting ‘blue carbon’ stores in sea floor sediments, and sheds light on how weak and ineffective ocean governance is allowing the placement of corporate interests above marine protection.

Deep Sea Life in the Azores – Thermal vents. Photo credit: Greenpeace Gavin Newman

The UK Government has recognised some of these threats despite holding licences to exploit more of the international seabed than any government apart from China. The report highlights how the UK is among a number of countries positioning themselves as leaders on marine protection whilst simultaneously investing in deep sea mining. Although commercial mining has not yet begun, 29 exploration licences have been granted to a handful of countries who have laid claim to vast areas of the Pacific, Atlantic and Indian Oceans, covering an area of 1.3 million Km2 – five times the surface area of the UK.

The report casts a spotlight on the failings of the International Seabed Authority (ISA), the UN body responsible for regulating the putative deep-sea mining industry, which is prioritising development over robust protection. ‘The ISA is not fit for purpose to protect our oceans. It is more concerned with promoting the interests of the deep-sea mining industry and lobbying against a strong Global Ocean Treaty’, says Louisa Casson of Greenpeace. Greenpeace and scientists are calling for a Global Ocean Treaty that can create a network of ocean sanctuaries covering at least a third of the global oceans by 2030. For more information see Protect the Global Oceans: Why We Need a Global Ocean Treaty.

But other evidence is appearing about damage to the sea floor, and potential carbon. A report in Nature (March 2021) finds that a substantial increase in ocean protection could have triple benefits, by protecting biodiversity, boosting the yield of fisheries and securing marine carbon stocks that are at risk from human activities. The results show that most coastal nations contain priority areas that can contribute substantially to achieving these three objectives. A further report in Nature (January 2021) shows clearly that bottom trawling causes potentially irreversible erosion of the sea floor and could reduce the ocean’s capacity to store carbon.

Commercial fishing fleets worldwide practise bottom trawling, in which heavy gear and massive nets are dragged along the sea floor to maximize catch. To study the method’s impact, a group at the Autonomous University of Barcelona, Spain, analysed sediments taken from a trawling ground in the northwestern Mediterranean Sea during the trawling season, when intensive trawling was occurring, and also during seasonal closures. The authors compared the samples with sediment from untrawled sea floor nearby. They found that the continuous contact of bottom-trawling gear with the sea floor caused erosion and changes in sediment composition. After a two-month closure, the disturbed sea floor had barely recovered, and the disrupted sediment was severely depleted in organic carbon. It could take decades for enough sediment to accumulate to slightly reverse the effects of erosion. On a global scale, commercial bottom trawling threatens to impede the ocean’s capacity to safely store carbon on the sea floor, the authors conclude. Bottom trawling clearly also poses a threat to fish populations by destroying habitat. In comparison to untrawled areas, the continuous erosion and sediment mixing in trawling grounds led to coarser reworked sediments impoverished in organic carbon (∼30% loss) and promoted the degradation of labile compounds (52–70% loss).

What about closer to home in the Clyde?

After the unanimous refusal by North Ayrshire councillors of the Scottish Salmon Company’s application for a salmon farm at Millstone Point, North Arran, we must not become complacent! The multinational salmon farming companies are upping their game to expand in Scotland. The next application, this time by Mowi for North Kilbrannan, at Cour Bay, comes before Argyll and Bute Council very soon. See application 20/01345/MFF: Formation of fish farm (Atlantic Salmon) incorporating twelve 120m diameter circular cages and siting of feed barge: North Kilbrannan Fish Farm North, Off Cour Bay Kilbrannan Sound East Kintyre (Argyll And Bute Council).

Whilst Arran became aware of Mowi’s North Carradale fish farm failure of mooring lines on 20 August 2020, the tally of the disaster has now been quantified: 48,834 farmed salmon escaped, of which 30,616 died and the rest of the 250,000 in the nets harvested from North Carradale farm. Each weighed about 4.1kg. Many dead were washed up on local Kilbrannan Sound beaches, including on Arran.

Certification and salmon farms

It appears to me that the latest “name of the game” with salmon aquaculture is certification, the more it is certified at every stage the more it can claim with their constant PR, to be sustainable! Mowi is no exception. Yet many of these certifications are self-serving and have become big businesses in themselves. We have read about AkerBiomarine MSC (Marine Stewardship Council, initially set up by WWF) certification for Antarctic krill, and now Mowi Scotland has earned certification from the Aquaculture Stewardship Council (ASC) for four seawater salmon farms in January 2021, bringing the total number of ASC certified farms in its portfolio to eight. These ASC standards are a result of the Aquaculture Dialogues, initiated by WWF USA and founded the development of “verifiable environmental and social performance levels that measurably reduce or eliminate the key impacts of salmon farming.”

ASC’s PR reads: “ASC certified farms demonstrate that they are well managed and minimise adverse environmental and social impacts. When you see the ASC logo, you can be assured that you are buying seafood products that come from farms working towards environmental sustainability and social responsibilities.”

We all know these assertions are rarely true! Each farm individually assessed. No cumulative impact assessment, no good modelling of dispersion of all the types of waste.

A few additional facts from Mowi 2020 Report:
• Carbon footprint break down page 51: 75% from feed and about 10% air freight (ie about 200,000tonnes CO2).
• 2 million tonnes of CO2 were emitted in 2020 due to their operations, directly and indirectly

Another certification: ‘As a member of the Sustainable Air Freight Alliance (SAFA), a buyer-supplier collaboration between shippers, freight forwarders, and air freight carriers we will continue to promote tracking and reduction of GHG (Green House Gas) emissions from air freight and promote responsible freight transport’. It is obvious that clearly one important way to reduce GHG to zero is not to fly salmon to markets!

Salmon Feed

Based in Kyleakin on the Isle of Skye, the new Mowi feed mill started production in the spring of 2019, and it moved into full production in 2019. The feed mill produces the full range of feed required by Mowi’s operations in Scotland, Ireland and the Faroe Islands. It will also deliver seawater and freshwater feed to the Norwegian operations. When operating at full capacity, it can produce up to 240,000 tonnes of feed pellets a year. “Sustainable Feed is a key component in ensuring the best possible fish health and performance”. In any life cycle assessment (LCA)* of salmon farming, feed also makes the largest contribution to its environmental footprint. LCA determines the environmental impacts of products, processes or services, through production, usage, and disposal. In 2020, the sourcing of Mowi’s marine and vegetable raw materials was 100% compliant with their sourcing policy. 100% of their marine raw materials were either MSC, MarineTrust Standard (former IFFO-RS) certified or part of fisheries improvement projects aimed at achieving the MarineTrust certification.

Latest Salmon Feed content for MOWI 2020

21.2% veg. oils
1.6% guar products
2.5% corn products
9.5% beans and peas products
14.5% fish meal
11.6% fish oils Total Fish 26.1%
18.9%wheat products
17.4% soya products
4.2% supplements

So in total: 26.1% from fish products and 73.9% vegetarian and supplements. For a carnivorous fish that is quite a change in diet and I wonder about the effects on the welfare of the fish and whether this change makes them more susceptible to disease.
Soy purchased from Brazil in 2020 was 100% ProTerra certified. The ProTerra Standard is based on ten principles, focusing on biodiversity conservation, environmental management and effective environmental services, the protection of Amazon, Cerrado and Chaco biomes, the protection of community rights and the promotion of working and agricultural best practices especially related to sustainable land use and reducing the application of pesticides. Land areas converted after 2008, be it by human intervention or natural causes, are not eligible for certification under ProTerra under any circumstances. In 2020, all Mowi’s SPC suppliers from Brazil have committed to implement a 100 % deforestation- and conversion-free soybean value chain with 2020 as their cut-off date. No soy grown on land deforested after this deadline will be traded. That’s a bit late I would say, the Cerrado and Amazon areas with severe damage to their ecosystems and their human, often indigenous populations. See Campbell (2020).

So the report goes on and on in an attempt to convince its readers/shareholders that they are doing us all a great service, good profits, without compromising world resources, ecosystems and communities, be it fish, soy, GHG, or indigenous communities, let alone our inshore marine ecosystems in Scotland with their externalisation of costs to the environment, both short and longer term.

The Challenge that is modern salmon farming in Scotland

The challenge here for us all is clearly to recognise that at present this salmon aquaculture industry is contributing to a major source of protein rich food in richer parts of the World that can afford to support the necessary transport and distribution infrastructure. That the rich world is able to afford such a food source is simply that the real costs to us all are not being effectively internalised within the industry. Of course, this rings true of other sources of food production too and we see that more graphically illustrated in intensive feedlot farming of beef cattle as distinct from grass and silage supported grazing cattle, and also broiler chicken rearing. What are these costs that are not being internalised, in other words not being paid for by the salmon aquaculture industry? There is clearly something wrong when we rely on the freshwater and marine environment to assimilate without harm the uncontained discharge of contaminants that are related to industrial salmon feedlot farming. Such an approach to containing environmental impacts was outlawed in legislation applied to industry as a whole in the UK back in the 1970’s when dilute and disperse, ie. the assimilation approach, was largely abandoned in favour of the polluter pays approach to containing environmental impact at source. The salmon farming industry does not comply with that legislation. We already have evidence that this industry is steadily degrading our marine environment through its use of chemical treatments harmful to surrounding biodiversity, its sources of eutrophication elements nitrogen and phosphorus, its faecal solids, and finally its consequential promotion of parasitic organisms harmful to wild fish all uncounted in the marketed product today. The complexity of this industry from feed to farm to plate makes it ideal to hide the environmental and community costs to us all and to the benefit of shareholder value and short-term profits.

It is true that worldwide we have overfished our natural resources to a degree that many traditional sources of fish protein are overexploited and diminishing to a tipping point where it is impossible to return to sustainable yield even if we turned the tap off now. This is true of the waters of the Clyde where the nursery grounds have been destroyed by sea bed dredging and in genetic terms the larger mature fish providing the gene pool have been removed from the generational succession as they simply do not survive for long enough to ensure that healthy succession. In a recent PR attempt to influence public thinking in Scotland the salmon aquaculture industry is saying that they are performing a benefit to the World by meeting ever more demanding need for food so no one goes hungry. Of course, this is a false claim. Yes, more food is going to be required as world population goes on increasing for some years yet, BUT the only sustainable way of producing that food needs to be thought through locally and produced locally or perhaps regionally and driven by full cost evaluation. Scottish and indeed Norwegian, Canadian and Chilean farmed salmon reared in open cage feedlots would fail at the first hurdle: Why? Because all salmon aquaculture depends on feed commodities produced from unsustainable wild fish and crustacean fishmeal sources, often sourced many thousands of miles away, as well as crops such as soya and palm oil produced by large agri-industrial businesses reliant on methods destroying soil structure, and diversity for short term gain. Crustacean (krill) capture in Antarctica for fishmeal is right now robbing penguin colonies of their key survival food source.

You hear messages from nutritionists and food scientists that we need to move away from animal protein sources if we are to feed the 9.7 billion human population in 2050. This means consuming less meat and fish and more vegetable protein. In the same way the salmon aquaculture industry has striven in recent times to persuade farmed salmon to become vegetarian dependent on land-based crops rather than fishmeal and fish oils. There has been some success but such an approach compromises the product on two counts, productivity and therefore financial bottom line, and also compromise on taste and much higher fat content.

So where does all this take us here in Scotland where it has to be recognised this salmon aquaculture industry does support jobs in rural coastal communities, it does provide a revenue stream for both communities and government to contribute to public services, and it provides the cheapest animal protein for our society in supermarkets? There is no doubt the industry could be run more sustainably with a much lower impact on its marine surroundings with its feed demands being sourced more locally. This would mean smaller units with much lower stocking densities, minimal chemical interventions and shorter distribution networks BUT this would mean offshore companies sacrificing their almost obscene profitability. It would also mean the product returns to its original status as a luxury food to be consumed on high days and holidays! There would be fewer jobs that might be offset by much more local involvement in management and development of other types of marine and tourist businesses. The government would lose income. Another alternative might be to either go further offshore in huge engineered facilities or bring the entire farm onshore in a closed containment system with its own water treatment facilities. However, in the longer run tinkering at the edges is not the answer. Food production from whatever source is going to require planning and coordination across the board and the future for Scotland could be the promotion of truly environmental, social and economically sustainable approach to commercial sourcing of food from the sea. The free-for-all plundering needs to be contained and managed by local communities guided by national strategic involvement with protection where appropriate and interventions such as exclusion zones to protect the cores of biodiversity and productivity essential to sustain commercial yields. Sustainable aquaculture but very different from what we see today is likely to play a vital part.

An election is coming. Quiz the candidates on their vision and strategy to make Scotland more self-sufficient in food and their management plans for the social, environmental and economic protection of Scottish marine waters for the future of Scotland’s communities.

Campbell, S., (2020). The Long Read – Soya and the Cerrado. Soya and its Relationship in Brazil’s Cerrado Destruction. (2020) In Deep Water: the emerging threat of deep-sea mining (2019) Protect the Global Oceans. Why we need a global Ocean Treaty
MOWI integrated Annual Report 2020.
Paradis, S., et al. (2020) Persistence of Biogeochemical Alterations of Deep-Sea Sediments by Bottom Trawling. Geophys. Res. Lett. December 2020 and Nature 2021
Sala, E, Mayorga J, and Lubchenco, J (2021) Protecting the global ocean for biodiversity, food and climate. Nature 17 March.

Sally Campbell March 2021