COAST Chairman urges Members & supporters to respond to the consultation on the NTZ


	LOCAL COMMUNITY REJOICE AT THE DECISION TO REFUSE CONSENT TO A MASSIVE FISH FARM: PLANNING REPORTER CRITICISES GOVERNMENT SCIENTISTS The subsequent appeal by Marine Harvest (Scotland) against North Ayrshire’s 9-2 planning decision to turn down the development of a huge (800,000 fish up to 4.5kg in weight) salmon farm off the east coast of the Isle of Arran has been unsuccessful and as a consequence the lease of the seabed by the Crown Estate will not now go ahead. Over 100 individual and organisations had objected to the application for this huge industrial site Located less than 1 km south of this proposed fish farm project the first Scottish marine NO TAKE ZONE (NTZ) located in Lamlash Bay on Arran was signed into law and was one of the main considerations taken into account in the appeal process The key issues with new or expanded fish farms relate to the potential damage to the marine environment, to coastal scenery and the pollution which spreads far beyond the “footprint” of the fish farm. Modelling of the movement of marine waters in tidal areas with currents and wind is an inadequate science. It does not cover resuspension of faecal and food waste and the plumes of chemicals used to defeat fish diseases which have become an increasingly major feature in the intensive food farming practices of the sea. Of importance in the appeal was the research done by local Lamlash people, clearly demonstrating that the SEPA (Scottish Environment Protection Agency) standard modelling was inappropriate for that site. By using floats at different depths the Lamlash researchers were able to chart the water movement at ebb tide, which demonstrated clearly that whilst the surface waters did not enter the bay, lower down the water column at depth, waters from the fish farm direction would have flowed over the sea bed of the NTZ, a sensitive nursery habitat for marine life. Farm waste would therefore have invaded the sensitive Maerl beds of the NTZ. The initial application for this huge fish farm dates back to 2006. This was one of 144 applications for salmon farms or renewals, on the west coast of Scotland, presented to the Crown Estate for approval since 1997. 109 have been approved, 25 withdrawn and 10 rejected. There has been much criticism of the Environmental Impact Assessment process (EIA) and the quality of Environmental Statements (ES) required for finfish farms. They are much less rigorous than those required for land-based developments. Using the sea as a waste dump for fish farm faeces, uneaten food and prophylactic chemicals used to fight disease has become much less acceptable and the Precautionary Principle is increasingly demanded by communities and Local Authorities. Discharge of untreated sewage to sea is no longer allowed under EU and member country regulation. Many now question why fish farm sewage is allowed to continue untreated. The proposed fish farm would have produced over the 22 month salmon rearing cycle 1170 tonnes of waste, of which 258 tonnes would be solid waste (157 tonnes of uneaten food and 101 tonnes of excreta expressed as dry weight), and 912 tonnes of dissolved waste, mainly carbon dioxide with some urea and ammonia. In addition there would have been by products of disease control chemicals, some of which are extremely toxic to other marine life. COAST (Community of Arran Seabed Trust) (see www.arrancoast.com) has been working towards establishing a NTZ for over 10 years, following the collapse of fisheries and accompanying biodiversity in the Clyde. Supported by over 1800 members, COAST has campaigned with Clyde based organisations such as the Clyde Fishermen’s Association and the Scottish Creelers and Divers together with wider conservation and sea angling groups to lobby for an area of sea bed that could act as a “nursery area” for regeneration of stock in eel grass and Maerl (a calcareous small seaweed) both known as providing excellent nursery beds for fish, scallops and marine life. The primary reason for refusal of the appeal was recognition of the importance of invoking the Precautionary Principle and the failure to apply the appropriate scientific tests. Mr Donald Harris, the reporter, in his recommendation to the Crown Estate Commissioner condemned the advice from the Scottish Environmental Protection Agency (SEPA), who were supposed to be providing comment on the scientific evidence assembled by Marine Harvest. He called some of the conclusions as to the effects of the proposed fish farm: ‘Fanciful thinking at best and downright misinformation at worst’ He concluded that the Precautionary Principle was appropriate in this case taking into account the risk factors that are generally applied as follows where there is a high degree of uncertainty of the scale of impact where the asset to be protected is of particular value, or where even a low probability of impact may present too high a risk. The amount of waste and the use of sea lice medicines which impact on non-target species, is particularly pertinent when considering the NTZ and its nursery beds for all forms of shellfish- scallops, crabs, lobsters. The fish farm development would have compromised research into the longer term benefits of the NTZ in the regeneration of biodiversity. A subsidiary reason for refusal of the appeal was the perceived detrimental impact of the development on visual amenity from coastal paths. Arran depends on the £30M economic input from tourism, encouraged largely by its superb outdoor environment for rambling. Scottish Natural Heritage made a clear case for refusal based on the beauty of the scenic vistas from Holy Island, and the cliff walks up the east coast of Arran, which is part of the Arran Coastal Way. Those becoming increasingly concerned by the number of finfish applications from multinationals using the west coast seas of Scotland to produce cheap salmon, should take heart from this refusal to grant a license for such a huge industrial site. Cheap salmon can only be produced because there is no clean up of the waste produced; they depend instead on a “dilute and disperse” philosophy which has long been found wanting and which is not legally permitted in discharges to water courses generally from industrial sites. The COAST project is a template for the way seas around Scotland can be managed in the future. Research on the progressive regeneration will provide important data for those who make decisions on the marine environment, sadly neglected in Scotland until now. The Marine Bill for Scotland is at present with the Scottish Parliament, and there is increasing pressure for Marine Protected Areas and NTZs to be the templates for the way the seas around Scotland are managed in future for the benefit of us all. Sally Campbell of COAST summed up local feeling: ‘We told Marine Harvest that putting a massive fish farm next to a no take zone was always going to be a non-starter, but Marine Harvest refused to listen to common sense. They have wasted a lot of their own time and money trying to force through what was always a daft idea, and built up tremendous bad feeling on the island in the process.’ Sally Campbell C.O.A.S.T. www.arrancoast.com 01770-600822 sallya.campbell@btopenworld.com

LOCAL COMMUNITY REJOICE AT THE DECISION TO REFUSE CONSENT TO A MASSIVE FISH FARM: PLANNING REPORTER CRITICISES GOVERNMENT SCIENTISTS

The subsequent appeal by Marine Harvest (Scotland) against North Ayrshire’s 9-2 planning decision to turn down the development of a huge (800,000 fish up to 4.5kg in weight) salmon farm off the east coast of the Isle of Arran has been unsuccessful and as a consequence the lease of the seabed by the Crown Estate will not now go ahead. Over 100 individual and organisations had objected to the application for this huge industrial site

Located less than 1 km south of this proposed fish farm project the first Scottish marine NO TAKE ZONE (NTZ) located in Lamlash Bay on Arran was signed into law and was one of the main considerations taken into account in the appeal process

The key issues with new or expanded fish farms relate to the potential damage to the marine environment, to coastal scenery and the pollution which spreads far beyond the “footprint” of the fish farm. Modelling of the movement of marine waters in tidal areas with currents and wind is an inadequate science. It does not cover resuspension of faecal and food waste and the plumes of chemicals used to defeat fish diseases which have become an increasingly major feature in the intensive food farming practices of the sea. Of importance in the appeal was the research done by local Lamlash people, clearly demonstrating that the SEPA (Scottish Environment Protection Agency) standard modelling was inappropriate for that site. By using floats at different depths the Lamlash researchers were able to chart the water movement at ebb tide, which demonstrated clearly that whilst the surface waters did not enter the bay, lower down the water column at depth, waters from the fish farm direction would have flowed over the sea bed of the NTZ, a sensitive nursery habitat for marine life. Farm waste would therefore have invaded the sensitive Maerl beds of the NTZ.

The initial application for this huge fish farm dates back to 2006. This was one of 144 applications for salmon farms or renewals, on the west coast of Scotland, presented to the Crown Estate for approval since 1997. 109 have been approved, 25 withdrawn and 10 rejected. There has been much criticism of the Environmental Impact Assessment process (EIA) and the quality of Environmental Statements (ES) required for finfish farms. They are much less rigorous than those required for land-based developments. Using the sea as a waste dump for fish farm faeces, uneaten food and prophylactic chemicals used to fight disease has become much less acceptable and the Precautionary Principle is increasingly demanded by communities and Local Authorities. Discharge of untreated sewage to sea is no longer allowed under EU and member country regulation. Many now question why fish farm sewage is allowed to continue untreated.

The proposed fish farm would have produced over the 22 month salmon rearing cycle 1170 tonnes of waste, of which 258 tonnes would be solid waste (157 tonnes of uneaten food and 101 tonnes of excreta expressed as dry weight), and 912 tonnes of dissolved waste, mainly carbon dioxide with some urea and ammonia. In addition there would have been by products of disease control chemicals, some of which are extremely toxic to other marine life.

COAST (Community of Arran Seabed Trust) (see www.arrancoast.com) has been working towards establishing a NTZ for over 10 years, following the collapse of fisheries and accompanying biodiversity in the Clyde. Supported by over 1800 members, COAST has campaigned with Clyde based organisations such as the Clyde Fishermen’s Association and the Scottish Creelers and Divers together with wider conservation and sea angling groups to lobby for an area of sea bed that could act as a “nursery area” for regeneration of stock in eel grass and Maerl (a calcareous small seaweed) both known as providing excellent nursery beds for fish, scallops and marine life.

The primary reason for refusal of the appeal was recognition of the importance of invoking the Precautionary Principle and the failure to apply the appropriate scientific tests. Mr Donald Harris, the reporter, in his recommendation to the Crown Estate Commissioner condemned the advice from the Scottish Environmental Protection Agency (SEPA), who were supposed to be providing comment on the scientific evidence assembled by Marine Harvest. He called some of the conclusions as to the effects of the proposed fish farm:

‘Fanciful thinking at best and downright misinformation at worst’

He concluded that the Precautionary Principle was appropriate in this case taking into account the risk factors that are generally applied as follows

where there is a high degree of uncertainty of the scale of impact
where the asset to be protected is of particular value, or
where even a low probability of impact may present too high a risk.

The amount of waste and the use of sea lice medicines which impact on non-target species, is particularly pertinent when considering the NTZ and its nursery beds for all forms of shellfish- scallops, crabs, lobsters. The fish farm development would have compromised research into the longer term benefits of the NTZ in the regeneration of biodiversity.

A subsidiary reason for refusal of the appeal was the perceived detrimental impact of the development on visual amenity from coastal paths. Arran depends on the £30M economic input from tourism, encouraged largely by its superb outdoor environment for rambling. Scottish Natural Heritage made a clear case for refusal based on the beauty of the scenic vistas from Holy Island, and the cliff walks up the east coast of Arran, which is part of the Arran Coastal Way.

Those becoming increasingly concerned by the number of finfish applications from multinationals using the west coast seas of Scotland to produce cheap salmon, should take heart from this refusal to grant a license for such a huge industrial site. Cheap salmon can only be produced because there is no clean up of the waste produced; they depend instead on a “dilute and disperse” philosophy which has long been found wanting and which is not legally permitted in discharges to water courses generally from industrial sites.

The COAST project is a template for the way seas around Scotland can be managed in the future. Research on the progressive regeneration will provide important data for those who make decisions on the marine environment, sadly neglected in Scotland until now. The Marine Bill for Scotland is at present with the Scottish Parliament, and there is increasing pressure for Marine Protected Areas and NTZs to be the templates for the way the seas around Scotland are managed in future for the benefit of us all.

Sally Campbell of COAST summed up local feeling:

‘We told Marine Harvest that putting a massive fish farm next to a no take zone was always going to be a non-starter, but Marine Harvest refused to listen to common sense. They have wasted a lot of their own time and money trying to force through what was always a daft idea, and built up tremendous bad feeling on the island in the process.’

Sally Campbell
C.O.A.S.T.
www.arrancoast.com

01770-600822
sallya.campbell@btopenworld.com