Massive Expansion at Dunstaffnage gets approved by SEPA

SEPA has just issued notification that it intends to allow the fish farm at Dunstaffnage an increase in permitted biomass from 1300 tonnes to 2350 tonnes.

Save Seil Sound had registered an objection to the application, as had the Argyll District Salmon Fisheries Board. To nobody’s surprise Marine Scotland had found nothing wrong with the proposal. There’s no sign of any comment from Scottish Natural Heritage at all.

As we know, using biomass data filed by the operating companies as a guide to what is actually happening below the seabed is currently under review, with the industry lobbying hard against the use of feedstuff tonnages as a proxy. Once again a company is rushing through an application, just in case the Scottish Government wakes up and does something rash like imposing a system of regulation that actually works.

Or even incentivises operators to move production onto land, using taxation allowances for those who do and polluter pays penalties for those who don’t!

The Dunstaffage farm is located just outside Oban in a spot that’s widely used by local residents, having one of Argyll’s very few sandy beaches. People are swimming from here in all Seasons.

The permit will allow the operators to dump in our Scottish water column not only “Fish excreta, uneaten food and other substances” but also a catalogue of rather unsavoury materials including antiseptics and biocides, including the deadly Emamectin Benzoate, use of which is currently subject to investigation at UK level, the UK TAG report having been delayed thank to the December General Election.

For those who don’t know, EMBz kills all crustaceans and stays active on the seabed for several years, traces having been found in measurable quantities four and a half years after the fish farm in question was removed.

SEPA know this - it was their own research that proved this. When they first got the results and warned the industry that they proposed to ban its use the result was a declaration of war by the SPPO and threats of legal action by the American Merck Corporation, who employed tame scientists to trash the SEPA research. As a result SEPA ran further trials on various sites and had the results peer reviewed. Everything they had said at first was confirmed, but the industry had won another couple of years to poison our environment.

Astonishingly, the new consent will allow each treatment to use, over over a 7 day period, a total of EMBz not to exceed 898.95 grams. They might as well have made it a round kilogram.

Checking the seabed for a healthy environment will, as always, depend on there being found two species of “re-worker polychaete worms” toiling away on the seabed to clean everything up!

Given that the biomass is to go up by 48% one might be forgiven for expecting to find that conditions on site right now were just lovely at 1300 tonnes. Sadly, on checking SEPA’s website that doesn’t seem to be quite true.

The latest figures on SEPA’s website are only up to September 2019 and right now scotlandsaquaculture has a glitch that prevents Dunstaffnage being checked. From what’s available it seems that the current production run began in May 2018 and by September 2019 biomass on sIte had grown to 919 tonnes. During the period in every month salmon had been dying in the cages, ending with a total of
81750 kilograms.

That’s to say nearly 82 tonnes of salmon died over the period, not too bad compared with some farms that produced mortalities of up to 40% in the same period.

An update will be posted as soon as figures are publicly available.

Finally, you might think that the “Scottish” Sea Farms Limited would have some concern about the Scottish environment, or even that they might in fact be Scottish, but that’s not the case. They are registered in England and wholly owned by a Norwegian company that in turn belongs in equal share to Salmar ASA and Leroy ASA, both Norwegian. Happily for them their “Scottish” operation generated profit of £59.735 million in their last accounts, on a profit margin of 31%. On these figures they probably think they can accept some dead fish along the road.

The bay on a wintry day, when wild women were swimming.

Back in Norway the boss is watching.

Climate Change 2045

Save Seil Sound were represented yesterday at the Glasgow workshop for the Scottish Government's Climate Change for Action initiative.

We were interested to find what steps are proposed in relation to our coasts and seas, given the enormous extent of Scotland's territorial waters, coastline and seabed.

Of the seven interest categories on offer we selected LULUFC, which translates as Land Use Land Use Forest Change, for the morning session, but quickly learned that "land" means dry land and not land covered by sea. While the session was most interesting and showed that Scottish Government have a very good grip on issues around urban and rural planning and forestry, we opted for the "agriculture" table for the afternoon.

Again the focus was on dry land and most interesting. An issue for our farmers is bluntly that in the absence of current EU subsidies they simply won't be there in a few years time. Our hosts were confident that the UK Government has undertaken to replicate farm payments, for a few years at least, which may give some comfort.

There was an important contribution from Evie Murray, founder of Crops in Pots, a city farm in Leith, on the possible linking of city based food production and school meals programmes.

Among this group were several with a tangential interest in the health of our seabed and water column. Those contributors had strong views about the inability of Marine Scotland to maintain proper scientific independence, which our hosts would have noted.

Aquaculture stands in the way of efforts to reduce carbon emissions, before one gets to the other ways it damages the environment. World wide, huge amounts of energy are used in hoovering up from the World's seas unmarketable "trash fish", to use a term found in sections of the industry, ranging from sand eels to small immature fish that would be marketable if allowed to grow, then transporting them here. There follows the growing process itself, carbon emissions therefrom and finally transporting the finished product around to markets far away. We can add the sheer waste through onsite mortality, with resultant transporting and dealing with waste.

If these negatives are assessed and factored in to the calculations they will surely impact very badly on attempts to meet the Scottish Government's 2045 target.

Fishing Quota and Brexit

The Fisheries Bill is now making its way through the UK parliament, having been introduced in the House of Lords.

In the House of Commons the former UK Environment Secretary

Theresa Villiers said:

“This new bill takes back control of our waters, enabling the UK to

create a sustainable, profitable fishing industry for our coastal

communities, while securing the long term health of British fisheries.

Leaving the EU’s failed common fisheries policies is one of the most

important benefits of Brexit. It means we can create a fairer system.”

Former UK Fisheries Minister and now UK Environment Secretary George Eustice said:

“The Fisheries Bill gives us the powers to implement our own independent fisheries policy, improve our marine habitats and make decisions based on the health of our fish stocks not vested interests.

For many people in coastal communities, taking back control and leaving the Common Fisheries Policy is at the heart of getting Brexit done, and this Bill delivers for the environment, fishermen and the Union.”

Strong words, but here is Lord  Gardiner, speaking in the House of Lords, sounding much more cautious:

“It creates the powers that the UK needs to operate as an independent coastal state and fulfil our international obligations. From 2021, the UK will be an independent coastal state, able to control who can fish in our waters. We will be responsible for setting annual total allowable catches of fish species within our waters. For stocks that are shared with other coastal states such as the EU and Norway, we will negotiate to agree fishing quotas. Currently, the EU distributes quotas between its member states using a principle called relative stability, which provides a fixed percentage of quota based on fishing patterns from the 1970s. This gives an unfair share of quota to UK fishers, not reflective of what is found in UK waters, and so we will negotiate to move towards a fairer, more scientific method for the allocation of shared stocks.

…Unilateral restriction on access to fishing in the UK EEZ would almost certainly lead to reciprocal restrictions being placed on UK vessels fishing in the EU EEZ. This would also have a profound effect both on the fishing industry in the EU and on the UK fleet that relies on fishing outside the UK EEZ. Some form of mutual access arrangements must therefore be negotiated.

The historic reluctance of Member States to renegotiate the relative stability key suggests that negotiating new quota allocations after Brexit will be difficult. Such difficulty will be accentuated if these negotiations overlap with the wider negotiations on EU withdrawal. The Government could use access to fishing within the UK EEZ as a lever for achieving a better allocation of quotas but must also bear in mind that co-operation will be crucial for the long-term sustainability of stocks.

As an independent coastal state the UK will in principle be able to ‘walk away’ from negotiations with other coastal states if the compromises reached on TACs or quota shares are not aligned to UK interests. Walking away would, by leading to unilateral management of shared stocks, risk undermining the sustainability of fish stocks. It would also invite retaliation in other areas, including trade. Consequently, walking away should be a last resort.

Trade in fish and seafood is essential to the wider seafood industry, which relies heavily on importing raw goods at reduced or zero tariffs for domestic consumption, and on exporting domestic catches and production. Any disruptions to the current 

trading patterns could have profound effects on both the catching and processing sectors. Trade with the EU in fish products will be a key factor to the future success of the UK fishing industry and fish processors. We therefore urge that the fish sector should be included in the Government’s consideration of priorities for a future trading relationship with the EU.”

The Bill has been welcomed by the representatives of the largest fishing interests, including Barrie Deas, Chief Executive of the National Federation of Fishermen’s Organisations, and Elspeth Macdonald, Head of the Scottish Fishermens Federation. Last week both gave evidence in the House of Lords, along with Jeremy Percy, New Under Ten Fishermens Association and Andrew Kuyk, UK Seafood Industry Alliance. 

Of the four witnesses, Ms Macdonald was the most bullish about Brexit, claiming that “getting back control” and “sovereignty” over UK coastal waters would bring enormous benefits to the UK fleet. This was effectively a continuation of what her predecessor Bertie Armstrong was preaching in the years leading up to the Referendum and led to a split in the SFF.

Mr Percy and Mr Kuyk were much less enthusiastic about the “benefits” of Brexit. They confirmed that in the last forty years fishing patterns have greatly changed, as has the distribution of the target fish themselves. In some parts fishers are unable to catch up to their quota, in others they can catch their years allowance in a couple of weeks. To redress this there are proposals to create new quota and share it in ways that reflect current patterns. Doing this will not be  easy and conflict with countless vested interests.

During the hearing Mr Percy read out a prepared statement from the Scottish Creel Fishers Federation, so they were represented by proxy. The statement confirmed their concerns over certification and transportation of live and highly perishable catch. The Committee acknowledged bluntly that this would be a consequence of Brexit and no comfort of any sort was given.

The rest of this post attempts to answer a simple question. We know that most if not all of the smallest members of the fishing fleet, who are of course also the most important for survival of their local communities, are extremely worried about Brexit, but why are the major operators, based in the big North East ports and owning almost all the quota, not equally concerned? 

There’s a lot of mystery about how the ownership of quota is structured and the ownership of the owners themselves, where they are companies and not individuals.

In her evidence Ms Macdonald claimed that the SFF represents 80% of the Scottish fleet, and holding almost all of Scottish quota, which she said is 80% owned by Scottish owners. This ties in with what we already know about the composition of the ownership of the Scottish share of quota, that it’s almost all under the control of a few major families based in the North East. There should be a caveat here: it’s quite possible that some of the Scottish registered boats are owned by limited companies that have in turn foreign shareholders, or shareholders that are in turn companies owned by other interests. It would be a surprise if this were not so.

Mr Deas confirmed that a good part of the remainder of UK quota is no longer owned by British interests. In particular, French and Dutch investors have bought out quota over the years. Perhaps people shaking their fists at Dutch super-trawlers off the coast should be looking closer to home?

World wide fishing quota is created as part of the attempts to conserve fish stocks and share fishing opportunities by way of  permission given to an operator to catch a specified amount of a specified stock in a specified period. Available scientific data is used to work out “total allowable catch” and the result allocated on the basis of traditional fishing activity. 

In the EU it’s been part of the much derided Common Fisheries Policy.  Not all species are included, in fact most of the Scottish West coast fleet is probably fishing for non quota species, such as shellfish.

The original allocation of quota was based on what was known about the distribution of target species and the fishing patterns of the various fleets active in EU waters. Percentages were worked out and then given, without payment, to the fishing boat operators who were active at that time. 

As both the allocation within each member state’s fleet and the subsequent administration were matters for that state it seems that the rules could have required an operator on giving up fishing to surrender its quota, again without payment, in order that it could be reallocated to a new operator entering the industry. Sadly, during that period the UK was under the control of free market, neo-liberal governments which allowed quota, not just for fishing but for other commodities such as milk, to be sold. I suspect that other states took a different approach, which would have made UK quota particularly susceptible to buy-out. 

This problem isn’t just a UK one. Here’s a quote from a Canadian website:

“As it stands right now, British Columbia’s policies are different from anywhere else in Canada or Alaska in that quotas and licenses can be owned by anyone, including large, non-Canadian corporations. We often call those owners “slipper skippers” or “arm-chair fishermen” because they never set foot on a boat. BC quotas and licenses are bought and sold like hedge funds. On average, 70% of the landed value of the catch goes to these shareholders, leaving precious little income for the hard-working people trying to make a living in their coastal communities.”

I attended the Marine Scotland meeting on fishing policy in Oban last July, at which fishermen owners of quota pointed out very forcibly that there are now no longer people in the industry who got their quota for free and that current owners see it as part of their retirement funding. This means that in turn, as has also been pointed out, anyone entering the industry has to buy a share of quota, which may cost as much as the boat itself, finding in effect that the bottom two rungs have been cut off the ladder. The effect, of course, is to concentrate ownership of quota in wealthy people who quite probably don't themselves go to sea.

So, what do the owners of quota know that the rest of us don’t?

I suggest that they are aware that under the European Convention on Human Rights, which has of course absolutely nothing to do with the European Union, the owner of an item of property cannot have it removed without being given due compensation. By accident or design, successive United Kingdom Governments have allowed quota to become precisely that, property that has legal protection.

If this is correct we are likely to see over the next few months a considerable rowing back from extreme “taking back control” positions, perhaps the creation of some new quota to pacify some interests, business as usual for the major players and disaster for much of our West coast fleet.

Post script: for another take on this problem has already highlighted by Greenpeace, see the link here: Unearthed - the Millionaires hoarding UK fishing Rights

Freedom Food Limited

On 3 February Save Seil Sound wrote to the Scottish Charity

Regulator, OSCR, raising issues about Freedom Food Limited,

as follows: 

“(We are) … a campaign group consisting of ordinary citizens in mid Argyll concerned about the damage that is being caused to our local environment and wild life by the massive expansion of aquaculture. I am writing on behalf of the group to ask that you investigate and review the charitable status of Freedom Food Limited (“FFL”), a limited company incorporated in England and Wales (02723670), but which is registered with you as a Scottish Charity under SC038199. According to its published accounts the company is beneficially owned by the RSPCA, whose charitable activities seem to be confined exclusively to England and Wales.

For convenience I quote the sole object registered by FFL with you, as follows:

“To prevent cruelty to Animals by the promotion of humane farming. transportation, marketing and slaughter of farm animals, In particular but without prejudice to the generality of the foregoing, by Implementing a set of rearing and handling standards approved from time to time by the Royal Society for the Prevention of Cruelty to Animals ("the RSPCA)”

As far as can be determined from the information published in their accounts and on the RSPCA website the sole activity carried on by FFL is running a scheme now known as “RSPCA Assured”, in terms of which companies operating various forms of battery farming are able to acquire a badge that eventually appears on the products retailed in supermarkets.  To quote from the website:

“RSPCA Assured, previously Freedom Food, is the RSPCA’s farm assurance and food labelling scheme.

It aims to improve the welfare of animals farmed for our food. RSPCA Assured assesses farms, hauliers and abattoirs to the RSPCA’s strict welfare standards. If they meet every standard, the RSPCA Assured label can be used on their product.

RSPCA Assured allows free range, organic, indoor and outdoor farms to join its scheme as long as the RSPCA’s welfare standards can be met. 

The only way of knowing if a product is RSPCA Assured is if it has the label on it. If it doesn't have the RSPCA Assured label then it is unlikely to have been reared to RSPCA welfare standards.”

In relation to aquaculture it can be estimated from analysis of the accounts that about two thirds of the aquaculture companies operating in Scotland are currently members of the scheme. Payments from these companies are a mixture of membership fees plus a sort of royalty based on the tonnages in the farms. (In recent years an average of 25% of the total stock in Scottish fish farms has died of disease, or has been lost through escapes and it’s not clear if the payments include these.) However there is no published list of members and thus no possibility for members of the public to know from which “farm” a particular product has come. Indeed some retailers have made up false names, such as Marks & Spencer’s “Lochmuir”.

This lack of transparency about the source means that it is impossible for anyone to know if the product he or she is buying has been produced by methods involving the deliberate infliction of cruelty, whether on the actual salmon or on other living creatures. Those opposed to industrial fish farming are so on a number of grounds. Those relevant to animal cruelty include the following:

1 Caging many thousands of salmon, a migratory species, can be  said to be intrinsically cruel. This is evidenced by the totally unnatural behaviour patterns, with the stronger fish on the surface constantly jumping to escape, while the weaker ones below gradually suffocate. This applies to each and every unit.

2 An inevitable consequence of the close confinement is that sea lice are now rife on the West coast. Almost all units are carrying burdens of lice in excess of limits set by the regulatory bodies. Plumes of sea lice eggs are emitted, drift long distances on the tides and attach themselves to wild salmon and sea trout. Individual campaigners have produced photographic evidence showing fish in serious distress, some with gaping holes where flesh has literally been eaten away. Again this problem is endemic.

3 On discovery of excess lice levels operators are required to take action, including in serious cases to cull the fish and put them out of their misery. There have been cases where this has only happened after visits from campaigners. 

4 Companies are now “delicing” salmon by pumping them through tubes into vats of hot water in wellboats, that then discharge the residual waste directly into the sea. On occasions salmon have not survived this process, which seems fundamentally a form of animal cruelty.

5 Salmon farmers routinely obtain government licences to shoot seals. In exchanges on social media representatives of the RSPCA have acknowledged that this happens on at least some of the farms they certify.

6 Accoustic Deterrent Devices, otherwise known as seal screamers, are routinely used to frighten off local seals, despite it’s being known that they damage the hearing of non-target species such as whales, porpoise and dolphins.

7 Companies are now routinely trapping wrasse and lumpfish, “cleaner fish” whose natural function is to keep the shallow inshore waters clear. They are then added to the fish cages to predate on the sea lice on the salmon. On conclusion of the growing cycle these are killed along with the salmon.

All of the foregoing processes are intrinsically cruel and some or all are practised on farms licensed by FFL. It can be argued that instead of preventing cruelty the company is promoting it.

One would expect a genuine certification process to have at least three components, (1) truly independent monitoring, (2) a proper system of inspection and (3) publication of results. Examination of what the RSPCA place on the public record suggests that each is lacking.

Regarding (1), monitoring is via a list that can be accessed here:

https://science.rspca.org.uk/sciencegroup/farmanimals/standards/salmon

It can be seen that the vast majority belong to fish farm companies operating on the West coast. Regarding (2) and (3) no details of inspections are given and nothing is published.

I respectfully suggest that rather than operating as a charity in Scotland, certainly as far as aquaculture is concerned, FFL are operating a licensing scheme to raise money for their sole shareholder, which does not operate here. I suggest that you ask them if any of the companies on the list participate in the scheme, if there have been actual inspections of sites in Scotland, if so for details of the results and to explain why nothing is published. Further it would be useful to know if they have ever refused an application from a fish farm company to join the scheme.”

We were surprised to find that OSCR do not get involved in charities regulated in both Scotland and England. They passed our complaint to the Charity Commissioners, who have now replied as follows:

“Thank you for your email which was referred to us by OSCR for our consideration, in which you raised concerns about FREEDOM FOOD LIMITED - 1059879.

Thank you for taking the time to notify the Charity Commission of your concerns relating to the charitable status of the above named organisation

Your concerns have been assessed by a senior case worker.  We have decided to keep the information you have provided on the charity’s records.  This means that we will reassess this matter should further information come to light.

I would also like to reassure you that the information you have provided will be used by the Commission to highlight particular areas of concern to the public and to drive improvements across the charity sector. We review all matters of concern that come into the organisation on a regular basis to inform our regulatory work and to identify issues or threats of harm to the sector as a whole.

We will also use this information to inform our proactive work with charities to address issues of concern.  This can result, for instance, in a spot check on a charity, a letter to trustees, or a regulatory alert to a particular group of charities

At the Charity Commission we want to ensure that charity can thrive and inspire trust, so once again I appreciate the time you have taken to contact us.”

So, to paraphrase the reply, 

“Thanks for trying Jimmy, now just shove off!”