With the announcement by Scottish Salmon Company (SSC) that it intends to submit an even more expansive planning proposal for its fish farm in Lamlash Bay the community of Arran finds itself in another battle to save its sea from the harm caused by an expanded fish farm. The community of Arran had thought it had secured a hard won victory against the SSC only to learn a few weeks after an original planning application (‘called in’ by the Scottish Government) had been withdrawn that a larger proposal was to be lodged. The new proposal will be for a far greater increase in the size of the fish farm than previously proposed and will in fact increase the potential biomass of fish up to 2500 tonnes – which is the legal maximum allowed under current regulations. But worse was to come. The SSC have been quoted as saying that Arran is a strong production area and the company wish to strengthen and expand their operations. We as a community should be concerned that Lamlash Bay (known as St Molios) is being used to establish a precedent – if it is successful SSC will see a green light for expansion around the Arran coast.
Apart from establishing a dangerous precedent there are good reasons why the community of Arran should fight tooth and nail against an increase in fish farming around the isle and in particular Lamlash Bay.
There is a growing wealth of evidence that fish farms are heavy polluters and bad for the environment. Rob Edwards in his article for The Herald on 26 Feb 2017 ‘Revealed: Scandal of 45 Scottish lochs trashed by pollution’ is able to show – using data obtained from SEPA that “..at least 45 lochs have been contaminated by toxic chemicals from fish farms..” and further that the chemical used to kill sea lice which infest Scottish fish farms have breached environmental safety limits on more than 100 occasions in the last 10 years including our own Lamlash Bay. Dr Richard Luxmore of NTS has warned that the pesticide emamectin benzoate – also used in Lamlash Bay to combat sea lice – is a neurotoxin highly toxic to birds and mammals. He states that ‘Environmental standards are in place for a good reason..’ and that ‘..it is highly worrying that they have been breached so many times…’ and ‘… the chemical warfare waged by fish farms against sea lice has essentially been lost and the application of toxins to kill them is spiralling out of control.’ Dr Sam Collins of SWT sees emamectin as a major concern because it stays in the environment for a long time and is capable of causing harm to a wide variety of sea life including shellfish such as crabs and lobsters.
All this in Lamlash Bay – in the South Arran MPA and close to the Lamlash No Take Zone!
Don Staniford of the Global Alliance Against Industrial Aquaculture (GAAIA) is also under no illusions about the increasing use of a cocktail of chemicals to try and combat lice infestations in the Scottish fish farming industry. According to data obtained from SEPA by a FOI request amongst the dubbed ‘filthy five’ users of toxic chemicals is none other than SSC which, despite its name, is not a Scottish company but is based in Jersey and listed on the Oslo stock exchange. According to Staniford the chemical resistance of sea lice now means that a cocktail of 5 toxic pesticides are now being used against Scotland’s plague of sea lice. His analysis of the FOI data shows that in the period 2008 – 2011 salmon production increased by 22% . The use of toxic chemicals in the same period increased by a whopping 110%! Worse Mark Macaskill in his Sunday Times article of 1 Jan 17 (see here) claims that from 2006 – 2016 whilst the production of farmed salmon increased by 35% the use of chemicals to control flesh eating lice rose by 932%. Just take a moment to absorb the magnitude of those statistics.Macaskill concludes that the growing use of chemicals to fight sea lice, a parasite that kills millions of farmed fish every year, raises serious questions about the industry’s environmental impact. Perhaps another fact worth absorbing, and also begs the question, is how are these millions of ‘polluted’ fish disposed of?
Readers could be forgiven for thinking, or in fact expecting, that their elected government would be there to regulate such an industry for the best interest of the Scottish people or that SEPA (colloquially known as the Scottish Environment non-Protection Agency) would protect their best interests. That reality is far from this expectation.
Rob Edwards in his Sunday Herald article of 18 June 2017 says that the Scottish Government stands accused of intervening to block the ban of emamectin after pressure from the fish farming industry and from the American manufacturer of the chemical. It is further claimed by campaigners that the Scottish Government put pressure on SEPA to drop their plan to phase out emamectin by 2018 despite scientific evidence that the chemical was causing widespread environmental damage. A FOI request showed that a complaint from the the fish farming industry prompted officials in the Environment Secretary Roseanna Cunninghams’ dept to intercede. No SEPA announcement was made and SEPAs proposal to withdraw emamectin was withdrawn. This came despite Dr Hazel MacLeod a SEPA aquaculture specialist saying in Oct 2015 ‘We are duty bound to make decisions based on the impact on the environment and not on the consequences for industry’. Experts recommended a complete suspension of the use of emamectin within 2 – 3 years. Staniford again has stated ‘Under this government SEPAs powers have corroded away…The scientific evidence is so daming that it demands an immediate ban on the use of emamectin.’.
According to Rob Edwards The Scottish Salmon Producers Organisation declined to comment on his article.
But the rabbit hole runs much deeper than the dumping of toxic chemicals in Scotland’s coastal waters as highlighted by Dr Sally Campbell’s response to the SEPA DZR (Depositional Zone Regulation) Consultation document shows. Issues such as mass escapes as detailed in The Oban Times on 7 Sept 2017 and the effect on stocks of wild salmon; the unacceptably large tonnage faeces, other wastes and parasites that cant be dissipated by the discredited ‘dilute and dispersal’ method of waste management; nowhere is there reference to the European Water Framework Directive nor the Precautionary Principle enshrined in EU environmental law. Yes that’s the same EU that the Scottish Government wants so much to be a part of. Presumably only the parts of the EU that suits its own agenda. And now closed containment aquaculture is a proven viable technology (see here) it is time for our legislators and regulators to push for fish farms to move onto dry land where all of the problems of neurotoxins, faeces, parasite transfer, diseases, mass escapes, marine mammal deaths, wider damage to the marine environment and potential long term effects to human health can be eliminated.
Looking beyond the local there is also the much wider issue of the unregulated extraction of bait fish from poorer parts of the world – depriving poorer fishing communities in developing parts of the world of essential fish protein to feed more commercially valuable fish such as salmon for western consumers. A point further illustrated by Emma Bryce in her article from Anthropocene Magazine 22 Sept 2017 dealing with fish reared in vast quantities which are exposed to an ‘intensive regimen of antibiotics designed to curtail disease outbreaks in their heavily populated pens’ to be turned into fish meal to be fed to fish in western fish farms. Sounds a lot like foot and mouth? No lesson learnt there clearly.
The community of Arran cannot rely on its government or regulators to ‘do the right thing’ by them.The Scottish Government has been accused of pushing revenue generation over the interests of local coastal communities, SEPA have been muzzled and with decreasing resources are arguably no longer fit for purpose. It is doubtful whether they have the will or ability to undertake rigorous environmental testing and there appears to be no appetite in government for any enforcement action against ‘the filthy five’ for breaches of environmental standards. The Food Standards Agency are conspicuous by their absence and there is no testing for toxins such as emamectin in the fatty tissues of farmed fish on supermarket shelves. It is up to us – the community of Arran to fight to save our seas from those who would pollute it, exploit it and ultimately destroy it for profit.
SSC can afford to employ expensive Edinburgh solicitors to fight their case for an expansion of their St Molios fish farm in Lamlash Bay and wider commercial aspirations around Arran’s beautiful and delicate marine environment. It’s up to us to ensure this doesn’t happen. We can expect an SSC planning application to be submitted to North Ayrshire Council (NAC) soon. It is up to us to oppose this. Once the application reaches NAC we must ensure our voice is heard and that we are registered as Recognised Community Consultees that we have a formal input into the decision making process. As a first step I would urge all readers to contact their local MP & MSP expressing concerns about the SSC proposal and when the times comes – which will be soon – to hold NAC to account by demanding Recognised Community Consultee status in any decision making process.