Our response to the SEPA Consultation on the proposed new regime for polluting the seabed.

Response by Ewan G Kennedy on behalf of the saveseilsound Campaign Group to the SEPA DZR Consultation

Introduction

About us

In 2011 a  planning application to relocate and expand a failed fish farm at Ardmaddy at the North end of Seil Sound to a point further South created considerable concern locally and further afield, resulting in over 800 objections. A group of local residents decided to form saveseilsound as a campaign group to carry out research and inform ourselves about what was going on under the surface in order to ensure that our contribution to the debate was based on science and not emotion. While we value our area very highly for the quality of its environment, wildlife and scenic beauty, our concerns were not solely about ecology, but also for our local micro-economy, which in common with most of mid-Argyll is almost entirely dependent on tourism and leisure.

The saveseilsound campaign group now includes a central core of technical specialists, including marine biologists, experts in water flows and hydrology, some scientists now retired from government service and thus free to assist us and myself, a lawyer with some experience of litigation matters, who serve as honorary secretary to the group. We are totally unfunded and beholden to no person and nothing apart from the environment that we respect.

After the Ardmaddy application was granted unanimously, followed by several other grants processed by officials without going to committee, we decided that our resources would be better used in trying to compel the agencies charged with looking after our health and environment simply to comply with the regulatory regime that they, including yourselves at SEPA, are supposed to be working under. To date we have had some success with our complaint to the EU in relation to the Animal Waste By-Products Directive, which produced a welcome legislative change in 2015.

We have in preparation a further Complaint in respect of the failure of governmental bodies properly to comply with the Environmental Impact Assessment Directive. The Directive specifies a number of elements that statements should contain, including that they should be comprehensive. This has never happened in our area, indeed many applications have been granted without any assessment.

About our area

Visitors come to the area from all over to enjoy the beauty of this still largely unspoiled wild fringe of Europe and the numerous still visible pieces of history, the duns and castles, the standing stones, the islands which among other things roofed the world, contributed to religious thought and had impacts throughout the world from America to Australia. Recently films created against a Scottish backdrop, art trails such as Artmap Argyll, wild life cruises to see cetaceans and raptors plus the Argyll Sea Kayak Trail (http://www.paddleargyll.org.uk/kayaktrail.html) have intensified this interest and created more demand for local facilities and services.

There is scope for visitor numbers to be considerably increased by publicising what rural Scotland has to offer, but this is directly threatened by fish farming. Bays that are  hosting a fish farm are effectively out of bounds to kayakkers and in hard conditions could even present a threat to life. Argyll & Bute Council failed to commission an archaeological survey at Ardmaddy South, with the result that a Viking boat noust on the shore was not spotted. Visitors now see a huge industrial installation next to prehistoric Dun Fada and the legendary Castle of the Dogs on Torsta.

The employment figure in the policy statement by the Scottish Government cannot go without challenge. The industry has for years quoted figures for employment created far in excess of the official statistics produced by central and local government, occasionally admitting that it claims the benefit of all employment in local services. It is absolutely certain that the jobs created in the most fragile micro-economies total far less than 8300. For example, how many are resident on Seil? Or Luing?

The area will continue to depend on tourism and leisure long after the fish farm owners have sold out and taken their profits to tax havens.

Question 1 – Do you support the principle of trying to make it easier and more attractive for fish farm businesses to develop in exposed, deep waters with strong tides?

This question conceals what seems to us to be a complete reversal of the approach to handling the enormous pollution produced by industrial fish farming, by abandoning a policy of containment and allowing the oceans to become effectively a gigantic dustbin.

Going back to an earlier period in the history of the industry, when guidelines were produced by Strathclyde Regional Council, the principle was to keep fish farms to a size that seems miniscule by today’s standards, just a hundred tonnes or so. It was acknowledged that installations would pollute, so leases were limited to ten years with a presumption that they would not be renewed on the same site. Ideally they would be sited in areas of limited tidal flow, to keep the poisonous debris confined to an “allowable zone of effects” that would be sacrificed but would hopefully recover when the farm moved.

As we all know this approach proved aspirational only. Leases were renewed without being moved, AZEs were relentlessly increased and this powerful industry, largely driven by foreign entrepreneurs who were subject to strict environmental laws back home, found that Scottish politicians of all colours could be seduced by talk of creating employment in fragile communities,  “producing animal protein and … food security” - this despite the ration of wild fish required to produce the salmon, formerly about 10 to 1 and now down to about 4.5 to 1, with Agriprotein (using insects) now being discussed!

To make matters worse the Crown Estate changed the rules to allow long leases of the seabed effectively creating rights of property which would be very difficult to cancel.

Anecdotal evidence began to come in from divers that the seabed was being progressively ruined under the farms. I do not dive, but have spoken to some divers who have worked for fish farms and many recreational ones, who have confirmed this. I was present on the dive boat when the following video was made at Pol na Gille and will testify if necessary to its authenticity.

Video of the seabed at Pol na Gille

What is absolutely clear is that allowing industrial fish farming in inshore sea lochs and voes is deadly to local wildlife, poisons the sea bed and ruins the prospects for small local businesses.

Even without fish farming the sea loch system comprising Seil Sound, Shuna Sound, Loch Shuna and Loch Melfort (Seil/Shuna/Melfort) would be under pressure from shore-based developments and visitors. Apart from several hundred domestic properties, some with but many without proper septic tank facilities, there are two failed public systems installed by Scottish Water at enormous expense, two commercial boatyards doing pleasure and fishing boat repairs, a marina and several mooring areas together hosting several hundred yachts, two substantial hotels and several working farms.

All of the foregoing discharge into what is truly one single, moderately-sized sea loch in all but name. As is well known, tidal flows on the West coast run from South to North and with virtually no exit to the North via Clachan Sound and only minimal flushing via the Cuan essentially the same water is moving back and forth in each tide.

This argument was developed more fully, with a detailed analysis of the seabed and tidal flows, in the comment which we submitted to you in response to application no CAR/L/1000800. In line with our usual experience SEPA did not engage with us and duly allowed the increase that was sought.

Subsequently Mike Russell MSP lodged written questions regarding the possible redesignation of Seil/Shuna/Melfort as one sea loch, to no effect. Here is the exchange:

Question S4W-28411: Michael Russell, Argyll and Bute, Scottish National Party, Date Lodged: 11/11/2015

To ask the Scottish Government whether it will designate the Seil/Shuna/Melfort loch system as a single sea loch for the purpose of better regulating fish farming in the area.

Answered by Aileen McLeod (24/11/2015):

The Scottish Government has designated Disease Management Areas based on separation distances, tidal excursions and other epidemiological disease risk factors. Disease management area 16d includes the Seil/Shuna/Melfort loch system as well as the Loch Craignish system. This is considered as one single area for the purposes of disease management.

The Seil/Shuna/Melfort loch system forms part of a Farm Management Area, area M40 as designated in the Scottish Salmon Producers Organisation’s Code of Good Practice. The Aquaculture and Fisheries Act 2013 requires fish farmers to be party to a farm management agreement or to maintain a farm management statement which must contain provisions about the following matters – fish health management, management of parasites, live fish movements, harvesting and fallowing.

To ask the Scottish Government, further to the answer to question S4W-28411 by Aileen McLeod on 24 November 2015, whether it will designate, for planning purposes, the Seil/Shuna/Melford loch system as a single entity and ensure that it is treated as such at all levels of the planning process.

Answered by Alex Neil (17/12/2015):

The protection that the planning system affords these waters would be a matter for Argyll and Bute Council to consider through the development planning process. The council's current development plan largely takes a criteria based approach to guide proposals to the most appropriate locations. The impacts that any specific proposal might have on these areas will be a material consideration when determining any planning application. The Scottish Government will monitor the situation closely.

To ask the Scottish Government, further to the answer to question S4W-28816 by Alex Neil on 17 December 2015, in light of Argyll and Bute Council being bound by guidance on the inshore sea lochs and voes set out in Marine Scotland maps, whether it will move the southern boundary line on those maps for the Seil/Shuna/Melfort lochs from its present location to a line between Ardluing and Craignish.

Answered by Alex Neil (13/01/2016):

There is currently no intention to amend the areas to which the Locational Guidelines for the Authorisation: Marine Fish Farms in Scottish Waters apply.

You will note that the Minister Alex Neil appeared to be in ignorance of the legal requirement for Argyll & Bute to follow the guidance of Marine Scotland. This is typical of the situation that has arisen with a divided system of control, enabling the various public bodies, local authorities, Marine Scotland, SEPA and the Crown Estate to pass the buck, unhindered by Ministers who do not understand the system.

There are now about ten current installations in Seil/Shuna/Melfort hosting hundreds of thousands of caged salmon in an area that any sane person (and indeed the industry, but seemingly not the Scottish Government) can see is effectively one single, largely enclosed sealoch. The evidence we have assembled to date confirms that such things should not be placed inshore. Moving them offshore would certainly help to solve our local problems, assuming they could be moved and the leases cancelled without the claims about expropriation of property that the operating companies would inevitably make.

We do not have the expertise to offer a view on the likelihood of offshore locations succeeding in overcoming huge logistical problems. On the face of things we suppose that the pollution would still end up somewhere, just not, we hope, on our doorstep. Taking things to extremes, if installations were moved many miles offshore the problems would become international and the seabed would be too deep to monitor.

We have the following detailed observations:

It makes no sense to allow the industry to expand offshore unless this results in a corresponding reduction in biomass in the existing inshore locations.

Offshore must mean well offshore, at least outside the 3 mile limit. We would strongly oppose any farms in areas of offshore islands such as Garvellachs, Slate Isles, Sounds of Jura and Sound of Luing, which are areas of high conservation importance.

There must be no farms in or close enough to impact on MPAs and SACs and existing farms must be moved out of these protected areas.

The use of ADDs must not be allowed within the porpoise SAC, because they exclude porpoise from important habitat for around 7.5 kilometers from the ADD.  Double nets should be fitted to any farms where there remains a problem with seals and shooting of seals should only be allowed  “as a last resort” when a seal is actually inside the net.

Question 2 – What are your views on our proposal to remove the current cap of 2,500 tonnes on the maximum fish biomass that a farm can stock?

This looks suspiciously like an acknowledgement that SEPA is in fact unable to control what is going on and intends to surrender to the demands of the industry, supported by Ministers blinded by the prospect of a quick solution to the problems of fragile coastal economies.

For several years we have been following the lack of activity by SEPA in enforcing existing limits in a system that relies on companies to self-report any misconduct. You will be aware, as we have discovered by examining the figures reported on your website, that there have been many hundreds of failures to keep within permitted limits. Recently we engaged with you by way of FOI requests in relation to what appeared to be clear breaches at Pol na Gille, in an attempt to find out if SEPA had reported matters to the Crown Office. As you will be aware we were unsuccessful, as a blanket exemption was applied. It seems that in the whole history of the CAR there has not been one single case brought to court.

We can understand the difficulty in using reports filed by junior employees of a company, often no doubt working in adverse weather conditions, to produce evidence of a sufficient standard to establish criminal liability, given difficulties of authentication and the privilege against self-incrimination. We can fully understand the embarrassment no doubt felt in the Crown Office and its reluctance to disclose the reasons for its decisions not to prosecute.

Given current restrictions on finance it does not seem likely that resources will be made available to provide an underwater police force to produce evidence to a proper standard. Efforts must be made to enforce the present system before allowing much larger installations in sites which it seems will be even more difficult to police.

Question 3 – Do you support our proposal to allow fish biomass to increase by up to 10% per production cycle, provided compliance with the proposed seabed standards is not threatened?

No

Question 4 – What are your thoughts on our proposal that, for DZR sites, we will take on responsibility for monitoring the effects of the farms on the seabed?

Of course you should, see our Answer 2 above. You should do this for all sites, not just new ones and must lobby for resources to do so.

Question 5 – What are your views on our proposal that there should be a break in production if seabed standards are breached to allow the seabed to recover?

The original policy referred to in Answer 1 was sound and it is tragic that it has been ignored.

If, in the case of a land-based installation, the tenant commits a serious breach of the terms of the lease the landlord has the legal power to irritate (i.e. cancel) the lease and recover possession. This could be an effective way to ensure compliance with, for example biomass rules, leaving the site fallow for however long it proved necessary for the seabed to recover.

Question 6 – What are your views on our proposal that, under DZR, the maximum area of seabed that can be affected by the deposition of farm wastes would be standardised to 0.5 km2?

We have no views on this. In a deep water site monitoring would be impossible anyway.

Question 7 – Are there any other comments or suggestions you would like to make about the proposals?

The public detest self-regulation, whether it be in the police, the legal profession or the doctors, and for good reason. Land-based agriculture is subject to external regulation, as is the entire food production chain, but fish farming is for some reason exempt, whether it be in relation to compliance with CAR regulations or shooting seals. The single best thing that could be done to enable SEPA to do its work effectively would be to give it the resources to enforce existing regulations.

This response has necessarily been kept short, but we shall be happy to expand on any issues when you engage with us.

What happens to the dead fish?

Our greatest failure to date was our campaign against an application to plant a huge industrial fish farm Port na Morachd, the lovely bay in the above image. Although there were over 800 objections the application was duly rubber-stamped by Argyll & Bute Council.

That process led to our greatest success to date, our complaint to the European Union, which led directly to a change in the law regarding the disposal of dead fish.

In the course of campaigning against the applications at Ardmaddy members of saveseilsound discovered that 82,663 mature salmon had perished at Ardmaddy over a few months, ending in December 2011. 

The total waste created thereby was reported by the operators as 256 tonnes.

Ardmaddy is an extremely remote site, with no road access. Residents were alarmed at the possibility that this enormous quantity of waste might simply have been dumped at sea. Even worse, what if the dead fish had been recycled into fish food for fish farms?

We decided to find out and were astonished to discover that nobody in officialdom knew!

Argyll & Bute Council didn’t even know that this disaster had happened. 

SEPA had learned some months after the event, when Lakeland Marine Farm sent in its mortality figures, but they hadn’t bothered to do anything. 

Nobody outside of Lakeland knew the cause of death.

We then found that this was all entirely within the law as it then stood, because the UK had negotiated a special derogation from the Animal By-Products Waste Directive exempting almost the entire aquaculture coast from environmental protection.

The Directive was brought in after the BSE “mad cow” scare and of course at that the fish farming industry was much smaller than it is today.

Strictly this belonged to the field of public health and safety and we took our complaint to the section of the EU Commission in Brussels with specific responsibility for this.

The Complaint was lodged in April 2012 and we didn’t hear much until we got a message on 24 June 2015 as follows:

“Extensive correspondence has taken place between the Commission services and the UK authorities in the context of the EU Pilot investigation which was triggered by your complaint. I can inform you that the UK authorities have in this context presented an action plan which includes an envisaged amendment to the Animal By-Products (Enforcement) (Scotland) Regulations 2013 and improvements to the official control activities, in particular in relation to contingency planning for large scale fish mortality disposal. In order to maintain the necessary trust-based cooperation between the Member State and the Commission during the pending EU Pilot investigation, further details of the action plan submitted by the UK authorities cannot be explained at this stage. However, the timeline provided by the UK authorities shows, inter alia, that the legislative amendment is envisaged to enter into force by the end of year 2015. The Commission services are closely following up with the commitments of the UK authorities in this context.”

Success dressed up as failure

In April 2016 we learned that the law had now been changed, as we were told that the Complaint had been shut down on the basis that it was no longer necessary!

We hadn’t spotted that in late 2015 the Scottish Government had held a “public consultation” on the Animal Waste Regulations. This was plainly our fault, but it might have been courteous for the government to have informed us and given us the opportunity to comment. Instead the invited consultees were virtually all from the industry.

Among the options given was for the law to be left unchanged and in continuing breach of the EU Directive, which would have involved the UK constantly breaking the law and being fined. It’s odd that this was even considered, but it seems that a cost benefit analysis showed that it could be more expensive to pay the fines than to dispose of the waste safely. 

And also a threat to health and safety maybe?

In the event the safe option was chosen and the new law came into effect in January 2016. As a result all waste has to be treated by a process called ensiling, basically the dead fish are put in a vat of formic acid which turns them into smelly slush that can be safely disposed of in landfill. Small amounts can be handled on site, while larger quantities are dealt with industrially.

Incredibly, there is still no supervision. As in all its operations the industry is self-policing and companies are trusted to behave.

We decided to find out who had taken part in the Consultation and what  they had said. We sent a Freedom of Information Request to the Scottish Government and have now received copies of the consultation responses.

The majority of responses were from either local authorities or land-based industries. SSPO agreed that the law should be changed, as did Dawnfresh, who operate in Loch Etive. One of the currently operating companies, who  insisted on their identity being withheld, sent the following gem:

So, this company were actually happy that the consequences of some catastrophic repeat of Ardmaddy in future would just be dumped on a local landfill site, whose workers and an  unwitting local population would be left with the consequences!

Bruce Sandison on Fish Farming

Sadly, we recently lost Bruce Sandison, who for many years was undoubtedly the leading defender of Scotland's wild fish and a gifted writer. In 2011 he gave me permission to publish as a guest post on another site the following article, which had appeared recently in the press.

Farming salmon seemed like a good idea at the time, back in 1965; the perfect adjunct and enhancement to subsistence crofting in remote rural areas of the West Highlands and Islands of Scotland. It was believed that the industry would provide much-needed employment by attracting young families to the area who would then sustain and expand every aspect of community life; new faces and new ideas, a bustling economy and busy shops, more children at local schools, a golden age of growth and prosperity.

Other people were less sanguine and predicted that the end result would most likely be tears and acrimony, pollution on an unprecedented scale and environmental disaster. They claimed that insufficient research had been carried out into the environmental consequences of salmon farming and that to proceed without a sound scientific base upon which to build would be irresponsible

Fifty years down the line the doubters seem to have been right: conflict and acrimony currently surrounds the industry. Many communities in the West Highlands and Islands are mounting furious battles to try to keep the fish farmers out of their back yards; thousands of people sign petitions opposing the expansion of salmon farming into new areas; conservation groups are considering legal action, accusing fish farms of driving distinct populations of wild salmon and sea-trout to the verge of extinction. They allege that the sea lice that breed in their billions in the farmers fish-packed cages attack not only farm salmon, but also wild fish that pass by farm cages.

These allegations have been vigorously denied by the industry who say that there is not enough evidence to suggest that sea lice were responsible for any declines in wild fish stocks. None of these claims and counter-claims is new: for more than twenty years the industry and those concerned about the adverse impact they say salmon farming is having on the marine and freshwater environment have been fighting over this same ground. All of the many attempts at finding common purpose through consultation have failed: meetings, joint committees, discussion papers, aquaculture framework strategies, codes of conduct, et al.

Salmon farming is judged to be one of Scotland's most successful industries and is estimated to be worth upwards of £450 million pounds to the Scottish economy. The industry also supports 6,500 jobs, many of which are in remote rural areas where other employment opportunities are limited. Scottish farmed salmon is one Scotland's biggest export earners, second only to whisky in value, and yet, in spite of this, the Scottish fisheries minister, Stewart Stevenson has now suggested that new legislation planned for later this year might see farms banned from areas that are important for wild fish stocks. The minister also revealed that he is considering forcing fish farmers to publish information about sea lice levels on specific farms; a measure that is already in place in Norway to protect their iconic stocks of wild salmon and sea-trout.

Like many observers of the irresistible rise and rise of salmon farming, I am puzzled by this apparent sea-change in the minister's attitude towards an industry that heretofore has appeared to be beyond reproach; an industry that has benefited mightily from continuous support by governments regardless of their political persuasion. Since the 1980's, when doubts about the environmental impact of salmon farms began to be voiced, many alleged government shielded the industry from any form of meaningful public scrutiny and repeatedly resisted all calls for an independent public inquiry into these murky waters.

At the heart of this dispute are matters of vital importance, now, and to future generations: on the one hand, is a perceived risk to the health and integrity of an irreplaceable part of Scotland's natural heritage, on the other, the economic wealth that the fish farmers say they bring to the nation. With both parties entrenched in intractable positions, finding a solution is not going to be easy. But there has to be a solution and a new initiative by government has been launched in an attempt to bring the warring parties together. An influential Scottish parliament committee appears to be promoting this initiative, led by its Convener, MSP Rob Gibson. The committee is determined to get to the bottom of the bitter argument raging between anglers and the fish farmers and propose to invite interested parties to round-table discussion to address their concerns.

The beauty of the wild lands of the Highlands and Islands of Scotland draw thousands of visitor each year to enjoy the majesty of their mountains, moorlands and myriad lochs and rivers. Visiting yachts anchor in sheltered bays, their crews coming ashore in the evening to local restaurants and hostelries to relish wonderful seafood; scallops, mussels, lobsters crab and prawns, freshly delivered each day. Children splash in crystal-clear shallows and play on white-sand, near-deserted beaches. Local communities rely on income by providing visitors with bed and breakfast accommodation in their homes, self-catering cottages and caravan sites and other services. Guesthouses and hotels also provide accommodation and extensive employment opportunities.

Rod and line sport anglers prized the salmon, sea-trout and brown trout that thrived in pristine, unpolluted waters. But now many lochs and rivers that once supported remarkable numbers of fish are virtually devoid of these species because, it is alleged, of the impact of fish farm sea lice. The Loch Maree Hotel in Wester Ross, where some 2,000 sea-trout could be could caught be each season and which employed eleven gillies to guide anglers to the best fishing spots has closed its doors. Other West Highland and Islands fisheries that enjoyed a world-wide reputation for the quality of sport have suffered a similar fate; such as Stack, More, Shiel and Eilt, and the rivers Dionard, Laxford, Inver, Kirkaig and Ailort.

The late Mrs Pauline Cameron-Head of Inverailort House is credited with bringing the benefits of salmon farming to Scotland. In 1965 she agreed to lease her land for use as a shore-base from which to service a fish farm in Loch Ailort; a sea loch on the famous 'Road the Isles' close to where Bonnie Prince Charlie landed in 1745 to try to reclaim his father's lost kingship of the British Isles. The fish farm company involved in the deal was Marine Harvest, then a wholly-owned subsidiary of the multi-national Unilever organisation, now Norwegian-owned and the largest producer of farm salmon in the world. The company operate a fish farm in Loch Ailort to this day.

Loch Eilt and the River Ailort, which drain into Loch Ailort used to be counted as amongst the most prolific sea-trout systems in Europe that could produce 1,500 sea-trout each season. Now, the numbers of sea-trout caught may be counted on the fingers of one hand, with some fingers to spare. A picture, taken in1941 of Lochan Dubh, an extension of the river, shows just how many sea-trout used to run the system. It was sent to me by Iain Thornber - historian, archaeologist and author from Morvern. He explained that explosives were used to kill the fish in the picture; a criminal offence, hence the soldier with the fishing rod strategically placed to try to suggest that the fish had been caught legally. All of the fish were sea-trout and used to feed Special Operations Executive commandos stationed at nearby Inverailort Castle. Iain remembers Pauline Cameron-Head telling him that the number of sea-trout in the system was so great that the noise they made splashing to upstream spawning grounds could be heard from the castle.

The assumption that fish farming would be initiated and carried out by crofters never materialised; capital costs were high, disease episodes and consequent loss of stock frequent and the expertise required to successfully rear fish to slaughter-weight was woefully absent. This knowledge gap was filled by fishery scientists from government agencies, the Fisheries Research Services, now renamed as Marine Scotland, and by scientists from a number of Universities, including Aberdeen, St Andrews and the Department of Aquaculture at Stirling University. Funding grants to further research programmes into fish farming came from the European Union, UK government and industry bodies.

Within a short time the industry began to consolidate into fewer and fewer farms owned and run by fewer and fewer multi-national companies, the majority of which were Norwegian. In the 1980's when 20,000 tonnes of farmed salmon were being produced annually the industry directly employed in excess of 2,000 people on their farms, fulfilling the claim that they were creating jobs. However, by the mid-1990's when production peaked at nearly 150,000 tonnes, employment figures, because of advances in technology - particularly automatic feeding systems - the number of jobs had fallen to below 1,000. Indirect employment, however, soared, reaching an alleged 7,000 people; but almost 50% of these jobs were taken by immigrants for Europe, the Middle East and Iberia and some 25% of those were illegal entrants to UK.

The industry claims that it is one of the most highly regulated businesses in the world and open to constant scrutiny and control. This is substantially true, but those worried by the fish farmer's actions suggest that such scrutiny is poorly implemented and ineffective; one anomaly being that for most of its existence the Crown Estate had the sole right to issue sea-bed licences to operate fish farms and to issue planning permissions. The Crown Estate benefits to the tune of approximately £2 million a year from fish farming and this suggested a clear conflict of interest. After more than seven years of government promises, the planning role was given to local authorities. The Scottish Environment Protection Agency (SEPA) also has to give their approval for operating cages in the sea and generally did. For instance, during the period 2008 to 2011 SEPA received more than two hundred applications, all but fifteen of which were approved.

The problems for wild salmon and sea-trout from fish farms are, however, vividly illustrated by comparing wild fish numbers in East coast rivers such as Spey, Dee, Tay and Tweed with those in the West Highlands and Islands: whilst there has been a total collapse of wild stocks in many of the later, with few signs of recovery, stocks in the former are currently producing record numbers of fish returning to spawn. There are no fish farms in East coast waters because, when fish farming began, it was decided to adopt a precautionary principal to protect these major rivers, and give the industry free reign to operate amongst the smaller rivers in the West. In substance, this is the core of the present dispute: wild fish that have survived in these waters since the end of the last Ice Age are being sacrificed for the financial benefit of a few, against the express wishes of the many.

There is a way out of this impasse that would, I believe, be of benefit to both sides of the argument: move the industry into closed containment systems by building a solid barrier between the fish in the container, and the sea water in which the container floats. There would be immense financial savings for the industry, including freedom from sea lice attack and other sea-born diseases, reduced expenditure on chemicals and medicines, fewer escapes from these new farms and a more secure work-platform for staff. Water from the containers could be cleaned and recycled back into the sea. Even better, and more secure, is to operate these containers from land-based, onshore sites.

For anglers, wild salmon and sea-trout would have unhindered and safe access to their natal spawning grounds to get on with what they do best, the propagation of their species.  Such systems, tried and tested, already exist and are being introduced in Canada. The Norwegians themselves are also showing great interest. It makes sense; at least it does to me and it offers a realistic opportunity to bring this sad, sorry, costly and unseemly conflict to an end.

This photograph shows Major Donald Gilchrist greeting Mrs Pauline Cameron-Head, who wears the green beret, a privilege extended to her by the Commandos in recognition of either her ability to keep them under control off-duty or her skills at blowing up fish for their dinner with dynamite, I'm not sure which. I also don't know which would have been the more dangerous.

The Joys of Thermolicing

The weird and wonderful monstrous machine above is a Thermolicer, the incredible secret bullet that the fish farming industry has bought to deal with the menace from sea lice. Judging by recent reports there are some problems with it:

Salmon Farm Reveals Impact of Sea Lice

Here are some (Soon to be) 

Frequently asked Questions

The industry may have bought the machine, but who paid for it? 

Perhaps we did!

Here is part of a news release from last October:

The drive to reduce sea lice and increase harvests of Scottish salmon has received a £1.76m boost, following a successful application to the European Maritime Fisheries Fund (EMFF).

Coordinated by the Scottish Aquaculture Innovation Centre (SAIC) on behalf of 11 companies, the award will enable a range of alternative technologies and approaches to be trialled in Scottish waters so that they can be evaluated for their ability to reduce sea lice – a naturally occurring parasite that affects farmed fish, costing the global industry over $1bn each year.

Says SAIC CEO Heather Jones: “The technologies being explored are capital intensive and their outcomes in Scottish waters are as yet unknown, therefore the financial and operational risks to industry are significant. By reducing those risks, this EMFF award will help catalyse trials on a commercial scale as opposed to an ad hoc or local basis.”

It’s not just the companies involved in the supported projects that stand to benefit. As part of the EMFF award, SAIC will commission a research project to capture the lessons learned, and share best practice with the wider sector and supply chain. There is also the potential to develop next generation technology for sale at home and abroad.

Amongst the alternative solutions being trialled is hydrolicer technology which uses low pressure water jets to dislodge sea lice; an innovative ‘bundle’ of technologies that brings best practice approaches into a single system; and a Thermolicer device which capitalises on the parasite’s low tolerance to sudden changes in temperature by briefly bathing fish in warmer water.

Comments Jim Gallagher, Managing Director of Scottish Sea Farms and one of the partners involved in the Thermolicer trials: “Everyone is clear on the real and urgent need to reduce sea lice. However significant capital investment is required to trial new solutions. The EMFF award is contributing additional resources to those invested by industry, enabling Scottish trials on a commercial scale. The new equipment will be accessible by many companies in Scotland’s salmon sector, supporting the industry’s common purpose in accelerating the widespread adoption of effective sea lice controls.”

So, how does the Thermolicer work?

According to the manufacturers Steinsvik

"The Thermolicer is a machine for commercial scale dip or bath treatment of fish. A sudden rise in water temperature is a well-known method of killing lice. We have developed a machine that does this on a commercial scale.

The fish are crowded and pumped into the machine where it passes through the processing loop in 25–30 seconds. Treatment water holds 30–34 degrees depending on ambient sea temperature. The treatment water is filtered, aerated, oxygenated and reused in the system. This simple and environmentally friendly treatment has an effect that goes beyond the expected in traditional treatment agents like chemicals and medicines."

If it's so terribly good, why did it kill the fish?

You will see from the BBC report reference to the fish suffering from Amoebic Gill Disease. The Thermolicer is of course not a treatment for AGD, so it seems likely that the fish had the disease and were also infested with sea lice. This is fairly common, because AGD, a sort of fish breathing disease weakens its victims and makes them more likely to be compromised by sea lice. Correspondingly, sea lice infested fish are bound to be weaker and more susceptible to disease.

34 degrees is the temperature at which sealice die, but it seems to have been simply too hot for its patients.

What is the maximum temperature which a salmon can endure?

Like most “cold-blooded” animals, salmon have little ability to regulate their internal temperature, so their body temperature is usually very close to that of the surrounding environment.

Research a few years ago Steinhousen et al and Eliason et al showed that salmon acclimatised to European water temperatures of a maximum of about 12 degrees began to show cardiac issues at temperatures above 21 degrees. Ambient water temperature in Scotland is rarely much above 8 degrees, so one can only guess the impact of a sudden increase to four times that. It seems likely that even healthy fish would be at risk of being compromised.

Does anybody care about whether or not the salmon suffer, being heated to four times what they're used to?

Seemingly not!