SCOTTISH SALMON COMPANY FISH FARM PROPOSAL AT NORTH SANNOX:
SCOPING 19/00182/EIA AND OTHER ISSUES IN THE CLYDE
I consider this proposed development as totally unsuitable for North Arran, and indeed the Clyde. This is a particularly important area of Arran, from archaeology, with old Clachans, geology with the coastline, both significant for studies. But much further than that, this is factory intensive farming at its worst without any pollution safeguards on a pristine coast famed for sea mammals, including dolphins and otters, and basking sharks.
North Arran National Scenic Area is an important habitat for birds. (Check page 27 of Arran Bird Report). The land is part of Arran Moor Special Protection Area with breeding Hen Harrier, Golden Eagle, Peregrine and Red-throated Diver. Further, see Arran Bird Atlas 2007-2012: Shore breeding birds include Common Sandpiper, Ringed Plover, Oystercatcher, Black Guillemot. Off shore this is important feeding area for Gannet, Guillemot, Razorbill, Puffin, Red-throated Diver, plus Black-throated and Great Northern Diver and Manx Shearwater in passage plus wintering sea ducks and grebes including Great Crested and Slavonian.
North Arran with cliffs and seascapes is important to tourism for Arran. It seems to many of Arran’s residents that the time has come for salmon farms to be located in closed containment, on land with adequate pollution control. How can the 2000 tonnes of waste per year be emptied from these 20 cages into pristine waters without thought of any control? This equates to a town of 14,000 inhabitants, over 2 and a half times the size of Arran’s resident population. Already the emissions from the 16 salmon farms in the Clyde are heavily impacting the inshore ecosystems in Loch Fyne, around Bute, Loch Striven and indeed Lamlash Bay. Short term profit over the long term health of our marine environment ecosystems has no added value to Arran or the Clyde and this after Scottish Water has spent millions in the villages of Arran to reduce sewage pollution and to come within the Water Framework Directive guidelines.
Reading the scoping for EIA (Environmental Impact Assessment) paper, it is deficient in many aspects and yet conveniently recommends that key topics be “scoped-out”, in other words left out of further study as unimportant. If adopted, this scoping out will result in completely dismissing many aspects of the marine environment, from visual aspects, value of the green economy, structure under the water, impact of noise and light on marine mammals, otters and seals. Further, the drop down video surveys were carried out between late October, and early November, very briefly and are unsatisfactory in their analysis.
What is really important is looking at potential cumulative impacts. Already in the Clyde, there are 16 operational farms. I attach analysis of the salmon aquaculture in the Clyde for 4 years, 2015-2018. Most of these farms are Scottish Salmon Company (SSC) with Mowi (formerly Marine Harvest) having two, in North and South Carradale in Kilbrannan Sound and hoping for another big one further north in the Sound. All these are under Argyll and Bute Local Authority. Scottish Salmon Company’s farm in Lamlash Bay is under North Ayrshire Council, and had a total of morts (dead fish in the cages) in just one year, 2018, of 44 tonnes with 446 grams of emamectin used. SCC husbandry on their 14 farms in the Clyde has also been poor. Outbreaks of heavy infestations of sealice, great use of hydrogen peroxide are all under scrutiny. A total of 16 farms all producing emissions. Below are the totals for each of the last 4 years. One tonne equals 1000kilogrammes:
Total emissions as follows; the amounts are taken from analyses of data on Scottish Government website.
| EMISSIONS | Total copper from feed and nets (tonnes) | Zinc from feed (tonnes) | Nitrogen (tonnes) | Phosphorus (tonnes) | Total organic carbon (tonnes) |
|---|---|---|---|---|---|
| 2015 | 10.55 | 1.53 | 540.11 | 74.59 | 1732.86 |
| 2016 | 10.97 | 3.24 | 1688.98 | 158.67 | 3686.31 |
| 2017 | 0.74 | 1.36 | 482.05 | 66.57 | 1546.58 |
| 2018 | 4.334 | 4.785 | 1695.00 | 234.07 | 5438.15 |
| Total | 26.59 | 10.92 | 4406.15 | 533.90 | 12403.90 |
It is interesting to contemplate the public money spent on improving sewerage on Arran and in the Firth of Clyde following the introduction of the Water Framework Directive. Yet salmon farmers are exploiting the marine environment without any clean-up costs. Our inshore marine environment and ecosystems pay the cost in the form of environmental degradation. Suggesting that waste will disperse without harm is really appalling. There is enough video evidence that this is just not so. No farm on land, be it chickens, cattle, or pigs would be permitted to discharge these quantities of waste to the environment and into water courses, including marine inshore waters. The long term cumulative effects on ecosystems have yet to be realised. Unintended consequences, especially with the use of neurotoxins, antibiotics, biocides (hydrogen peroxide) and other pesticides are beginning to show negative effects in the life cycles of arthropods, plankton and even seaweeds.
Despite all the “latest” PR from SSPO (Scottish Salmon Producers’ Organisation), the Clyde does not conform to this hyped “better than ever” salmon farmers’ message. We watch tankers of hydrogen peroxide being delivered from across Lamlash Bay, and the figures for morts in Lamlash Bay and the two MOWI (Marine Harvest) farms at Carradale for just 2018 are a total of 44 tonnes in Lamlash, 76 tonnes in Carradale South and a huge 271 tonnes in Carradale North making a total of 392 tonnes in total. At about 250grams per fillet in the Co-op, that amounts to nearly 16 million fillets (although no accounting for the heads being cut off!), so hardly a cheap protein if you consider the damage to the marine ecosystem, or a small carbon footprint. We are all wishing to know what exactly happens to these morts as secrecy abounds; similarly on hydrogen peroxide. Reports from Carradale of tankers discharging their chemical load into the farm are very disturbing.
Further, Arran is also aware that Dawnfresh, if consented, for the proposed off-shore sites at Ardentinny, Isle of Bute, Great Cumbrae and Little Cumbrae, would produce around 14,000 tonnes of trout per 22.5-month cycle. Imagine the waste under those farms! Another push which will do even further damage to the ecosystem of the Clyde. Why are we allowing industry to empty untreated waste into our inshore waters? Maximising shareholder return is putting profit before the health of our marine ecosystem. Do we really want that?
Dr Sally Campbell
March 2019