COAST's Letter to the Salmon Aquaculture Dialogue (SAD), June 2011

COAST's comments on the final draft standards can be read here. There are additional points we wish to make which do not easily fit into the form, and there is no additional area for general comments on the whole. Firstly COAST, a marine community based stakeholder, is very pleased that at least the industry has talked with NGOs etc about the lack of any world-wide standards for salmon aquaculture. After the disasters in Chile, and disease in several areas of the world, it has come at an opportune time for the industry. This has to be a positive step forward. I attended, for COAST, the dialogue in Edinburgh. It was clear the dialogue was being driven by demands from outside the industry to improve its standards. It is therefore really regrettable that these standards will not be enforceable to the farms in operation now. In 2009 alone, for example, 144,247 tonnes of Atlantic salmon was produced at 254 active sites in Scotland, many of them with poor records on disease, hygiene, escapes and general housekeeping around the sites.

Quotes from the Salmon Aquaculture Dialogue website are in italics:

"Total salmon production has increased three-fold since 1980 to meet this demand. The largest growth has been in farmed, not wild caught, salmon. Approximately 60 percent (1.26 million metric tons) of the world's salmon comes from fish farms."

COAST response: So at least 1.26 million metric tonnes will not be covered by the new standards since in your literature it states that these standards will only apply to those farms developed once the standards are in place.

"Fish caught to make fishmeal and oil currently represent one-third of the global fish harvest. (COAST underline)"

COAST response: As a marine community organisation interested in biodiversity and sustainability of fisheries, it is disturbing to see these figures, and again the standards will not immediately impact on this total. We also know that substitution with soy has huge implications for farms especially for artisan farmers in South America. Their sustainability and life chances have been hugely impacted. Land grab is not confined to fish farmers, but multinational salmon farmers are certainly implicated. Further, soy increases the fat content of salmon, so less healthy!

"Draft standards that seek to minimise or eliminate the key negative environment and social impacts of salmon farming, while permitting the industry to remain viable."

COAST response: In reading the draft standards it is clear that containment is not seen as a viable economic possibility. Yet the dilute and disperse methods to reduce the impact of pollution around the fish farms has been deemed unacceptable on land to water courses in the UK and many other countries since the 1970s. Moving farms to deeper water is no solution.
EIAs should encompass all salmon farms in a vicinity so accumulative effects can be modelled.
Chemical therapeutants and the rise of resistance in fish lice is a serious ongoing problem. Much lower cage biomass is required. The rush in the aquaculture industry to maximise profit by intensification and increased biomass is having long term impacts on biodiversity in the marine environment (benthic and planktonic), wild salmon populations and their smolt stage.

One main concern is compliance, especially around the islands of Scotland. SEPA will have the responsibility for water condition and standards. The new Aquaculture Stewardship Council must be more effective in raising standards than the present MSC. This can only be done if the certifiers are prepared to decline certification through rigorous inspection. If these standards are to be managed in the manner of the MSC standards, COAST has real concerns. Quite frankly MSC certification is now considered by many to be purely part of marketing.  As I am sure you are aware unsustainable fisheries are now marketed as sustainable with the "magic" Blue Label. Whilst these Principles are clearly signalled here as:

•     Develop and implement verifiable environmental and social performance levels that measurably reduce or eliminate the key impacts of salmon farming and are acceptable to stakeholders
•    Recommend standards that achieve these performance levels while permitting the salmon farming industry to remain economically viable

COAST response: It is clear the industry is not sustainable in environmental terms, and has an enormous carbon footprint .Yet already in the press the salmon farming industry is telling the world it is a "sustainable" industry. The language in the document does make it clear that the industry seeks to minimise key negative social and environmental impacts; these words imply the recognition that it is not a sustainable industry, nor ever organically approved, given that the use of chemicals for antifouling, therapeutants for disease, overfished stock as a main component in feed, and a large carbon footprint involved in all the transport of feed, fish, and markets. We therefore hope this dialogue is not a prelude to launching sustainable salmon farms with some sort of new label.

It has always been stated by multinational salmon farm owners, for example the Norwegians, that they adhere to the standards of the country in which they operate (even when there are no standards!) COAST considers that any multinational company should adhere to the highest standards enforced by law of their own country. We hope these standards will ensure there is a higher standard at every fish farm site.

But so far, this is an improvement on what went before. For that COAST is hopeful that these are the first steps.

Yours sincerely

Dr Sally Campbell
Vice chair, COAST