SCOTTISH KELP and the proposal to industrially harvest up to 40,000 tonnes a year on the west coast
When British naturalist Charles Darwin travelled to the Galapagos Islands in 1835, he was amazed at the sight of giant kelp forests ringing the islands. He believed that if those forests were destroyed, a significant number of species would be lost. These underwater ecosystems, Darwin believed, could be even more important than forests on land. Recent research in California over 15 years has proved Darwin right.
If it hasn’t reached your ear yet, there are plans to mechanically dredge kelp around the west coast and Isles. The initiative No Kelp Dredging has already led a well-orchestrated campaign to prevent dredging.
The scoping information, that is the preliminary description of priority subjects for future environmental impact study, was only placed in the public domain less than a month ago; perhaps those wishing to “harvest” kelp hoped no one would notice. After all it was summer and everyone was enjoying the good weather. The issue was raised by Mark Ruskell MSP – Scottish Greens MSP Greens Mid-Scotland and Fife with the ECCLR (Environment, Climate Change and Land Reform) Committee at Holyrood on Tuesday 18 September. He moved an amendment to the Crown Estate Bill to protect Scotland’s kelp forests and hoped MSPs from all other parties would get behind that proposal to protect coastal communities and protect our environment. The ECCLR Committee vote result on his amendment to block kelp dredging that removes the entire plant from the seabed was: For Amendment: 3, Against: 0, Abstentions: 6. Amendments need an absolute majority, which it received, so this Amendment will go forward: The concerns of individuals, groups and fisheries were prominent in the discussions that took place and it was acknowledged that opposition was consistent from different sectors of fishing as well as communities. So, this will again be addressed at Stage 3 of the Crown Estate Bill and in the meantime the campaign which has done a great job of raising the issue and bringing people into a coordinated effort to present their view will continue. Please click here to see the petition.
So it will be down to those who believe this is a really bad idea to ensure our productive kelp forests and their valuable ecosystems are not destroyed by dredging for short term profits.
Much scientific research has focused on the presence of giant kelp and the range of biodiversity it supports. Many believe this giant alga created and maintained by photosynthesis like all plants is the keystone species of its ecosystem, not only in terms of its structure — a huge forest-like environment under the sea — but also in terms of its tremendous productivity in supplying food for the near-shore ecosystem.
So what is kelp, and where can you see it? David Ainsley has many videos on his site. Scroll down to “Underwater Orkney”.
Laminaria hyperborea is a massive, leathery seaweed, commonly known as oarweed, tangle or cuvie; it is a perennial and lives for up to 20 years. It is a large conspicuous kelp which can grow up to 3.5 m in length in suitable conditions. The blade or frond is broad, large, tough, flat, glossy, golden brown to very dark brown and divided into 5 – 20 straps or fingers (digitate). The holdfast is a root-like structure that anchors the seaweed to the substrate with a claw-like, conical foot, a rough, rigid stem called a stipe which generally sticks up out of the water, and is often covered by red seaweeds when older, attached to the laminate blade up to 1.5 m long dividing into finger-like segments. The stipe is stiff, rough textured, thick at the base and tapers towards the blade, and usually 1m long. The new blade grows below the older from November onwards. The old blade is shed in spring and early summer. Blade and stipe vary with exposure and current. In sheltered conditions the blade has few or no digits and the stipe becomes thin but in exposed conditions the blade is deeply digitate and the stipe becomes thick. Oarweed, the most common of the kelps, is found on bedrock or other stable substrata from extreme low water (1m) to depths dependent on light penetration and sea urchin grazing (typically about 8 m depth in coastal waters to 30 m in clear coastal waters). It grows as dense forests under suitable conditions.
Another large brown kelp, Laminaria saccharina has a long undivided frond, without midrib and with a short stipe. The frond has a distinctive frilly undulating margin. This plant is commonly known as sugar kelp, and also sea belt and Devil’s apron, due to its shape. It lives for 2 to 4 years and grows quickly from winter to April. Depth range is less than 30 m. Identifying features:
• A long undivided frond with wrinkled surface and wavy margins, rising from a smooth flexible stipe.
• Without midrib.
• Small branching holdfast.
• Yellowish-brown in colour.
• Up to 4 m long.
The pictures below are of samples collected off Lamlash Beach, showing both these types that are common around the coast of Scotland. Stella the dog provides a scale of size of material washed up on the high tide mark.
At low spring tides you will see kelp fronds at the surface of the sea forming “underwater forests” (kelp forests) which can extend to shallow oceans. New analysis at the University of California has found that the kelp’s structure is very important for the ecosystem in a number of ways. The physical aspects of the kelp — its size and its presence, the shade that it casts, its effect on flow and the habitat it provides for predators — enhance the reef biodiversity. Although kelp is clearly important as a food resource to some organisms on the reef, its structural effects are important and far reaching. Kelp forests simply by their presence can reduce wave energy thus offering some protection for vulnerable shorelines.
The actual project development proposal by Ayr-based Marine Biopolymers Ltd (MBL) has come up with a proposal for harvesting a large tonnage of wild kelp of one sort, Laminaria hyperborea in commercial operations centred on Scotland’s inshore waters off the west coast. It is the destructive approach to mechanically dredge kelp forests off the coast that has led to an outcry from conservationists, who say it would destroy local ecosystems. MBL would extract natural polymers from the seaweed for uses in foods and pharmaceuticals. In July 2018 a scoping report, commissioned by Highlands and Islands Enterprise at SRSL (SAMS Research Services Ltd), Wild Seaweed Harvesting was published as part of MBL’s work towards applying for one or more five-year licences. This lengthy report put forward arguments for a range of businesses built on seaweed products. Under the plan, the amount harvested would rise over the years from about 1,300 to 30,800 tonnes wet weight by year 6. The harvesting of Laminaria hyperborea would focus on localities with biomass greater than 5 kg/m2 with 35% obtained from the Minch and Inner Hebrides, the west coast of the Outer Hebrides providing 21%, the North Coast and Orkney 20%, and the combined east and west coasts of Shetland 10%. The kelp would be processed at a plant in Mallaig in the West Highlands. A further report addressing the scoping in support of a detailed environmental assessment to be conducted in future has been produced for Marine Biopolymers Ltd by ABPmer in July 2018 on Seaweed Harvesting.
Inshore sustainable fisheries, such as those supported by the Scottish Creel Fishermen’s Federation, West Highland community groups and many environmental NGOs have been involved in a number of consultations in 2018, most notably this year’s inquiries which were heard before the ECCLR and REC (Rural Economy and Connectivity) Committees of the Scottish Parliament into aquaculture and the environment. One matter which has emerged very clearly is that the current system for regulating spatial developments in coastal waters is extremely complicated and fragmented. The five agencies involved in aquaculture are the Crown Estate, Marine Scotland, Scottish Natural Heritage, SEPA and the local authorities. The Precautionary Principle, referred to later, has not been considered in many instances where it should have been. Its application is misunderstood and runs counter to more powerful implementation drivers. This is despite the final Holyrood committee reports on environment acknowledging the harm to Scotland’s natural resources in the marine environment that is patently occurring. Now it is kelp harvesting, the next challenge for the Scottish Marine Environment, its ecosystems, its creel fishermen and its coastal communities, especially on the north west coast and islands. Many, such as Coll and Tiree, singled out on maps in the scoping reports, only learnt about the proposal late in the scoping consultation as it was near to closure.
Many of our small communities are involved in a variety of endeavors to secure their longer term economic viability, survival and growth. The sea provides livelihoods and a magnet for tourism. The complex pattern of relationships between land and sea must be considered:
• creeling and diving
• inshore mobile fisheries
• tourism, hotels, shops, cafes, bed and breakfast, gardens,
• wildlife watching, migratory birds,
• sealife watching by inshore boats, basking sharks, dolphins and whales, small offshore islands for puffins, kittiwakes
• small scale seaweed businesses
• yachting, often with paying visitors
• craft, art, knitting, pottery, sculpture development for sale locally and then on the net
• whisky, gin, beer production, for visitors and export
• transport including ferries
The scoping reports suggest the prospect of 32 Full Time Equivalent (FTE) jobs in Mallaig and “other jobs in communities” is unsupported by any evidence and additionally there is no attempt to reconcile the very real possibility of consequential losses in any areas listed above.
What is the Economic Case for this Industrial Development?
At current prices, and given various risk factors, the harvesting of kelp is not economically viable in Scotland. The SRSL report argues that processors would undertake harvesting (probably at a loss) because they need the raw material. A CEO of the processing company would find it hard to justify the use of more expensive local supplies when imported supplies are cheaper. Indeed, the Report states that imports from China and the far east resulted in the decline in US production. Also, seasonally the French use imported supplies. Perhaps the quality of Scottish kelp is better, or security of supply is perceived to be potentially better. Given the possibility of using imported dry supplies, there is then the question of the logic of siting processing activity in Mallaig. One advantage might be the availability of Regional public subsidy. Notwithstanding this possible inducement Ayr might be a better location if using imported supplies. Importing a product that is being unsustainably harvested is of course a relevant consideration too.
Essentially, the Scottish supply is not a high value resource and never will be, given the locational disadvantage. The value of kelp to Scotland as a supplier of “other ecosystem services” is probably much greater than the economic benefits from removing it through harvesting. The loss in value of these service flows, to sustainable fisheries and other outputs such as tourism, would be an added cost to harvesting. The key point is that these costs whatever they turn out to be must be included in an economic analysis seeking to assess the consequences for Scotland as a whole and this analysis has been ignored to date. This SRSL Report is therefore not very helpful to the Scottish Government or other public policy body evaluating the merits of this development. It would be madness to allow an activity to go ahead which would reduce Scotland’s overall capital wealth comprising of both environmental and man-made capital.
How does Regulation of Scottish Seas work?
The Crown Estate holds the seabed in trust for us all and is subject to long established rights of the public to use for navigation and recreation. As well as managing leasing of the seabed out to 12 nautical miles, it also holds the rights to offshore renewable energy and carbon and gas storage out to 200 nautical miles from the shore. Within the 12 nautical mile limit, it awards leases for telecommunication and electricity cables, oil and gas pipelines, offshore renewable energy projects, fish farms, ports & harbours. It also issues consents for short-term marine works that impact the foreshore or seabed, such as site surveys.
The rapid increase in salmon aquaculture has brought income through leases to the Crown Estate Scotland, which manages the marine environment belonging to the British Monarch. It is part of the “Sovereign’s public estate”, which is neither government property nor part of the monarch’s private estate. The assets are “managed in a sustainable way” that creates prosperity for Scotland and its communities. Crown Estate Scotland was set up following the Scotland Act 2016 and channels all profit from revenue generated through its licencing role to the Scottish Consolidated Fund. In many ways Crown Estate leases in the inshore marine environment have compromised the public right or commons, and now the potential loss of right over potential new licencing for kelp extraction by dredging is of serious concern to many groups who utilise their public right at present. Community groups operating within microeconomies in their localities need to be properly consulted and protected, as they are the life-blood of the smaller communities in NW Scotland. Basically, this scheme, once licenced, would allow a private company to remove kelp for its own private profit despite the fact that kelp is the property of the Crown, that is the public good, and that of course is us. There would need to be a form of public compensation for that loss, and public rights to use the seabed need to be protected in perpetuity.
Why use the Precautionary Principle?
This principle is expressed in the Rio Declaration of 1992, which stipulates that, where there are “threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”
If any department of the Scottish Government can recognise the importance of this Principle, then surely scientists in Marine Scotland and Scottish Natural Heritage (SNH) can? In a written response to the scoping reports, published on the 24th August 2018 SNH expressed considerable scepticism over this kelp harvesting proposal and emphasised the importance of the ecosystem. This is what they have said “SNH supports the sustainable harvesting of wild seaweed, provided that this can be carried out without significant damage to our marine environment”. However, SNH added: “we recommend that the scoping report and approach to the assessment of the proposal is reconsidered to provide clarity on impact pathways and assessment approaches, and to inform the location, scale and duration of detailed harvesting applications. For any new sector, we advise that it is important for an agreed set of baseline studies and impact assessment methods to be discussed and approved to support any subsequent applications. In this way there will be a transparent, audited process that takes account of the importance of kelp habitats and the currently limited evidence base for the impacts of mechanical kelp harvesting in Scottish waters”.
There is plenty of research that shows the importance of kelp beds for ecosystems, nursery beds and protection of vulnerable shore-lines. Year round the kelp beds and sea bed beneath host different ecosystems, be it migrating diving birds, basking sharks for the high productivity of plankton, nursery beds for shellfish, mobile species of fish and marine mammals for feeding, breeding and “meeting”. Ideally a small pilot area should be designated and researched. The scoping studies are an attempt to frame an environmental assessment which is yet to be implemented. A detailed environmental assessment could well come out with the conclusion that this project should not go ahead until the long term implications are better understood. It is appropriate to question exactly what research, if any, has been carried out that has demonstrated the effects of large-scale kelp removal in Scottish waters that can be accommodated without permanent degrading of ecosystem diversity? The suggestion is that up to 33,800 tonnes by year 6 could be harvested to facilitate development and upscaling of the processing plant in Mallaig, which will make the industry financially viable. The marine licences will need to provide for the following quantities (wet wt.) of Laminaria hyperborea over time (based on current projections of estimated demand or MBL products from its customers):
• Year 0 – 1,300 tonnes
• Year 1 – 5,700 tonnes;
• Year 2 – 11,400 tonnes:
• Year 3 – 18,700 tonnes;
• Year 4 – 25,000 tonnes;
• Year 5 – 29,800 tonnes;
• Year 6 – 33,800 tonnes.
This ramp up of production is being proposed ahead of any sea bed demonstration or even more appropriate a series of demonstrations that ecosystems are secure and the sustainability of exploited kelp is a demonstrated fact rather than an item on a wish list. To view the areas selected please click here.
The current oversight of existing Regulation and its effectiveness
At present, the operator obtains a licence, the local communities have concerns but often no voice and not even consulted adequately. Communities have had enough with industrial developments in the marine environment being foisted on them, ignored by the statutory authorities and their local government and having a sense that the Scottish Government through the Cabinet Secretary for Rural Economy and Connectivity is driving the single purpose development agenda. Offset benefits, a mini-bus here, shinty kit there, cash towards local community projects, should not be the norm so that planning decisions are not influenced or compromised by such payments. Spatial planning in coastal waters in Scotland is still a very confused topic with planning bodies often not equipped to make informed decisions and properly communicate with potentially affected communities.
Once a licence was granted how could the exploitation of the resource be completed with the least damage to the environment? Marine Biopolymers Ltd (MBL) confirm in the report produced by SRSL Wild Seaweed Harvesting that by clearing the seabed in strips, with full height areas left in between them, this approach to harvesting is sustainable. What does that mean? How long will it take for regrowth to reinstate the whole ecosystem as before? As an ecologist and scientist, I have the suspicion that what this really means for this company is “until just the kelp is tall enough to cut again”, which is rather like using the same field on land with no rotation or fallow periods to guarantee long term security of agriculture. That is not sustainability in my definition. The first piece of discussion is what does sustainability really mean in this context? Who will be responsible for conducting in the intervening period between repeat harvests, ecosystem surveys of flora and fauna to check that sustainability? Or will the areas for cutting, within a short time frame, result in monoculture, the kelp re-growing and a few grazing sea urchin predators on the kelp before further exploitation ? Rather like the Clyde scenario after the removal of the 3-mile limit and resulting in over-fishing of demersal species with the main “crops” now left in a degraded ecosystem being dredged scallop and bottom trawled prawns (Nephrops)? A result too late to restore the Firth of Clyde to good ecosystem health in even the mid-term. In other words the present state of regulation is not exactly a confidence builder !
Previous Consultation on Kelp Harvesting back in 2016
Scotland over time has always harvested kelp locally, a few tonnes of hand-harvested seaweed in inshore collection. Good as a garden or croft fertiliser, famous for improving the machair soils. Burning of kelp converts seaweed into an alkaline ash – which was used in many applications – particularly the production of soda and iodine. In the past this seaweed derived alkali was used in the manufacture of soap and other commodities and even today kelp is still used to some extent in the production of soap and glass. Alginate which is derived from seaweed is also used as a thickening agent in ice-cream, jelly and even toothpaste and cosmetics.
The Scottish government consultation on kelp harvesting in 2016 showed that while respondents were all confident that small scale harvesting of kelp by hand, which has been conducted for centuries, causes no significant environmental damage, many, including several among the various statutory consultees had serious concerns about harvesting on an industrial scale and effectively stripping bare entire sections of seabed.
The inevitable conclusion is that industrial kelp harvesting should not be permitted in Scotland unless and until proper independent evaluation has demonstrated beyond reasonable scientific doubt that it can be conducted in a sustainable fashion whilst avoiding irreparable damage to ecosystems. Read again what Charles Darwin had to say!
Steen, H., Moy, F.E., Bodvin, T. (2014). Before and after studies of kelp (Laminaria hyperborea) harvesting in Nord-Trondelag in 2012. A report prepared for the Institute of Marine Research. Report No. 4-2012