Highland Council not told of Scottish Government decision to withhold planning permission from fish-farms with very poor sea-lice records in Little Loch Broom
Salmon & Trout Association (Scotland) calls for closure of the Ardessie B fish-farm and a thorough environmental assessment of Ardessie A, failing which that farm too must close
Two salmon farms in Scotland with very poor sea-lice records are the centre of confusion as to whether or not they have planning permission to operate.
A request made under freedom of information law has revealed that in 2009, Marine Scotland commissioned an audit of the environmental impact assessment conducted for the Ardessie A and B fish farms in Wester Ross back in 2002 and found it wanting (Note 1).
The two fish-farms at Ardessie in Little Loch Broom have a very poor record of sea-lice control (Note 2).
Marine Scotland’s assessment concluded that “planning permission should be withheld” from the two Ardessie fish-farms under the Government’s audit of pre-2007 fish farms (Note 3).
Extraordinarily, the Highland Council, which has had responsibility for enforcing planning law at all fish-farms since 2007, was not told of the assessment or its outcome (Note 4).
Marine Scotland has since stated that the Ardessie farms cannot now apply for Scottish Government approval (Note 5).
In 2008, the Highland Council gave permission for a change in cage configuration only at the Ardessie B fish-farm, but sensibly made that permission conditional upon the Scottish Government later giving approval for Ardessie B, which we now know was declined (Note 6), and therefore, under the 2008 condition, Ardessie B appears to be operating in breach of planning conditions.
Guy Linley-Adams, solicitor to the S&TA(S) Aquaculture Campaign said:
“The Highland Council has now been called upon to enforce the condition at Ardessie B and inform the operators that they do not have planning permission for that site. The S&TA(S) certainly supports that call.
The Ardessie fish-farms have a lamentable record for sea-lice control and that threatens wild salmon and sea trout (Note 7), including the salmon population in the nearby Little Gruinard Special Area for Conservation, which is protected under European law (Note 8).
If a proper environmental impact assessment had ever been carried out at Ardessie, perhaps we would have avoided the awful situation with sea-lice that the wild salmon and sea-trout of Two Brooms have had to endure from Ardessie?
Quite why Marine Scotland did not share its negative audit assessment with the Highland Council is not clear, but we all deserve an explanation on that point.
However, for the protection of wild salmon and sea trout in Little Loch Broom, Ardessie B must now be closed. The track record of very poor sea-lice control at Ardessie, coupled with proximity to important wild salmon and sea trout rivers, means this is not the right place to try to farm salmon in open-net cages.”
At the other Ardessie site, Ardessie A, Wester Ross Fisheries Limited also applied for planning permission to change the cage configuration, this time in 2011. Marine Scotland had already come to its conclusion about the site, but did not tell the Highland Council. Unsurprisingly, the Highland Council concluded that no full environmental impact assessment was required on the basis that this was just an application for a change in cage configuration, with no increase in biomass over what was already there and so the ‘extra’ impact would be negligible – “the only issue under consideration is the proposed change of equipment configuration” and there were ‘”insufficient grounds to refuse, given the relatively minor nature of the change, i.e. from circular to square cages”.
Guy Linley-Adams added:
“Marine Scotland’s 2011 audit shows that no adequate environmental impact assessment has ever been done for Ardessie A. It is hard to see how this complies with European law. Unless this can be regularised, this farm too must now be closed.
This is not a problem of their own making, but since planning permission for fish-farms now rests with local authorities, we have no choice but to look to the Highland Council, firstly to enforce the planning condition at Ardessie B and shut that farm and, at the very least, to require an immediate retrospective planning application, with full whole-farm environmental impact assessment, at Ardessie A”.
- Both Ardessie A and Ardessie B benefitted from a renewed Crown Estate lease granted in 2003. An environmental impact assessment was conducted at the time covering both sites (the whole sea-bed lease area). It is this EIA that Marine Scotland has found wanting in it audit assessment of 1st February 2011 – “the Scottish Government audit identifies several deficiencies in the environmental statement…..in particular, the audit found that the environmental description focused on hydrographic conditions at the expense of fish, marine mammals, otters and seabirds, all of which are present and potentially affected by the farm. As a consequence, the statement’s assessment of mitigating impacts fails to address the farm’s impact on designated sites and species”.
- The latest aggregated sea lice data, published by the Scottish Salmon Producers Organisation (SSPO), shows that in the fourth quarter of 2013 sea lice numbers on farmed salmon were massively out of control in a number of areas with average lice numbers were over thresholds in 13 out of 30 areas for which data is reported by the industry. Particular hotspots yet again included ‘Kennart to Gruinard’ in Wester Ross where there are seven farms operated by two companies, Wester Ross Fisheries Limited and Scottish Sea Farms Limited, including both Ardessie sites operated by WRF. The monthly lice count on farms in this area was between five and ten times the threshold between October and December last year. Lice have been over the threshold in this area for an entire year now, despite three area-wide treatments and a staggering 25 other treatments for lice. The SSPO reports giving aggregated sea lice data from fish farms are available for download via this link: http://www.scottishsalmon.co..uk/science/sea_lice/regional_reports(1).aspx
- For details of the Scottish Government’s Audit and Review process see www.scotland.gov.uk/Resource/0040/00407782.doc
- Letter from Highland Council 19th March 2014
- Marine Scotland has already stated that both Ardessie A and Ardessie B are no longer eligible for consideration through the audit and review process, because they no longer operate using pre-2007 equipment – “through the audit and review process we are only able to grant permission to operate for sites which are using equipment which was place in the water before marine fish-farming became development on 1st April 2007. The sites at Ardessie A and B are therefore not eligible for consideration through our process”.
- The 2008 Ardessie planning permission was made subject to a condition “pending approval by the Scottish Government (in its forthcoming review) of the principle and existing scale of fish-farm development at this site. If the Scottish Government review approves the site – after consideration of the recent representations from wild fish interests and any other subsequent representations – the planning consent for the extension should be for the same term. If the review fails to approve the site or requires a scaling down of production, the consent for the extension should be deemed to have expired”.
- Just what is the problem with sea lice? Adult wild salmon are perfectly adapted to coping with a few sea lice. Background levels of these parasites occur naturally in the sea. However the advent of salmon farming, particularly in fjordic sea lochs, has led to a fundamental change in the density and occurrence of sea lice in parts of the coastal waters of the west Highlands and Islands. Even one or two mature female sea lice per fish within a set of cages housing hundreds of thousands of farmed salmon amounts to a rampant breeding reservoir pumping literally billions of mobile juvenile sea lice out into the local marine environment. The consequences when wild salmon and sea trout smolts, the metamorphosing fragile skin of which is not adapted to cope with more than the odd louse, migrate from local rivers into this “sea lice soup” are devastating.
A burden in excess of 13 pre-adult sea lice is known to compromise severely the survival of juvenile migratory salmonids. Lice feed by grazing on the surface of the fish and eating the mucous and skin. Large numbers of lice soon cause the loss of fins, severe scarring, secondary infections and, in time, death. Quite literally, the fish are eaten alive. Badly infested salmon smolts disappear out to sea, never to be seen again. In contrast afflicted sea trout smolts remain within the locality and they, together with the impact of the deadly burdens they carry, are more easily monitored through sweep net operations.
Marine Scotland Science has produced a ‘Summary of information relating to impacts of sea lice from fish farms on Scottish sea trout and salmon’ which gives the Government’s position – see www.standupforwildsalmon.org
Note that Marine Scotland Science acknowledges that compliance with the thresholds within the Code of Good Practice is not necessarily sufficient to ensure that juvenile sea lice emanating from the fish farms do not damage wild fish.
See also S&TA (2013) Recent research and findings on the impact of salmon aquaculture on wild salmonids – see www.standupforwildsalmon.org
Further information can be found in M Krkosek, C W Revie, B Finstad and C D Todd (2013) Comment on Jackson et al. “Impact of Lepeophtheirus salmonis infestations on migrating Atlantic salmon, Salmo salar L., smolts at eight locations in Ireland with an analysis of lice-induced marine mortality” – Journal of Fish Diseases.
- See http://jncc.defra.gov.uk/protectedsites/sacselection/sac.asp?EUcode=UK0030183