In August last year, SEPA published our regulatory strategy: One Planet Prosperity. This sets out our ambitious aims to transform the way we regulate the environmental performance of Scottish businesses. It is a strategy firmly focused on the challenges and opportunities of the 21st century, and on SEPA’s Statutory Purpose to protect and improve the environment; in ways which, as far as possible, also contribute to health and well-being benefits and sustainable economic growth.
Our aims are twofold. Firstly, we want to get every regulated business into compliance with Scottish environmental regulations. By global standards, we already have high rates of compliance. But high is not good enough. Compliance is non-negotiable. We have made it clear that we want and expect all businesses to comply.
But compliance is only the first step towards reaping the very real benefits of excellent environmental performance, which is the basis of our second aim. This is to help as many businesses as possible to improve their environmental performance beyond the compliance standards. This will further improve the Scottish environment. We hope it will also help create more lasting and inclusive economic and social outcomes for Scotland.
At the core of our new approach is the concept of Sector Plans. We will be developing a Sector Plan for each sector we regulate. These plans will guide our engagement with the sector, both in terms of driving compliance and going beyond compliance, making sure we use every means possible to achieve the twin aims of our strategy with each business sector.
As this is a completely new concept, in January we selected four sectors to start with: Landfills, Whisky, Fin-fish Aquaculture, and Oil and Gas Decommissioning. These sectors have different compliance records, and are different in structure and issues. This makes them an ideal mix to start with. Sector planning will drive our regulatory approach. So we want and need the widest possible range of input and review to make sure this new approach is as effective as possible. The experience from our first four Sector Plans will inform the development of plans for the remaining sectors SEPA regulates. That will take place over the next two years.
You can expect to hear a lot from us about our first Sector Plans over the coming months. To start this off, we want to talk about our initial work on the Fin-fish Aquaculture sector. Over the past five years the compliance rate in Scotland’s aquaculture sector has varied between 82% and 88%. SEPA is determined to regulate this sector in a way that improves its environmental performance. We want to drive up compliance levels and help operators to go beyond compliance and ensure Scotland’s world-class coastal environment is fully protected. In doing this, we will direct any industry growth to where the marine environment has the capacity to cope.
The two key environmental issues faced by fish-farms are the fish wastes that are deposited on the seabed and the control of sea lice, especially through the use of medicines.
The key to protecting the environment from fish wastes is minimising the amount of waste leaving a caged fish farm. There is currently no way to catch, and either re-use or process these wastes, so the main way of minimising their environmental impact is to limit the number of fish that can be kept in a fish farm. We currently do this through a condition in the licence issued to a site.
We will soon be consulting on proposals to change the way in which we license fish farms, particularly in relation to the zone impacted by each farm. We believe our proposal for Depositional Zone Regulation (DZR) would improve the regulatory framework for aquaculture, and ensure effective environmental protection. It will help the industry direct development of the sector towards those locations where the environment can accommodate it, while maintaining tight limits on fish numbers (biomass) to protect areas where the environment is more sensitive.
This sector has ambitious growth plans. DZR will ensure that growth only occurs where the combination of appropriate siting, and new techniques and processes, mean the environment can sustain it. It will be supported by Marine Scotland’s recently-developed computer modelling software, which will provide more accurate assessment of environmental effects; and by increased environmental monitoring, carried out by SEPA, to ensure impacts remain within acceptable limits. Under these conditions, we believe some fish farms, particularly those in deeper waters where tidal flows more effectively disperse wastes, could grow incrementally, by about 10% per year, beyond the current biomass limit.
We plan to launch our consultation on the DZR approach later this month. Aquaculture is a sector which elicits a variety of strong and divergent views, and we welcome the widest and fullest possible response from all those involved in the debate. We need an informed solution which protects the environment and meets the needs of the fish farming industry, the other industries also based in our coastal waters, other coastal water users, and the communities in which fish farms operate.
The second major issue arises from the management of fish health, in particular the control of sea lice. These small marine parasites occur naturally on many species of fish, but can become a problem when large numbers of fish are concentrated in fish farms. The most common method for controlling sea lice on farmed fish is the use of a medicine authorised by the Veterinary Medicines Directorate (VMD), either in a bath or in feed. The use of in-feed medicines, and any associated release into the marine environment, is regulated by SEPA, under conditions included in a fish farm licence. SEPA ensures adequate monitoring of dose rates and levels, and any impacts of the medicine on the environment. Where robust evidence shows that current regulatory arrangements are not providing the expected and required level of environmental protection, SEPA takes action to reduce those environmental effects.
For example, in 2013 evidence convinced us that the ongoing use of the sea louse medicine Calicide (with the active ingredient teflubenzuron) was causing failures in environmental quality standards, despite licence conditions significantly restricting its use. Following discussions between SEPA and the company marketing the product, Calicide was removed from the market in Scotland.
More recently, SEPA proposed and part-funded a Scottish Aquaculture Research Forum (SARF) investigation into the environmental impacts of the sea louse medicine SLICE (with the active ingredient emamectin benzoate). This study, completed last August, confirmed a subtle but detectable, and unexpected, association between impacts on the marine environment and the use of SLICE, where very low concentrations of the medicine may have affected crustaceans in the seabed. Based on this new evidence, SEPA is reviewing all fish farm licences permitting the use of SLICE, tightening conditions for the medicine’s use after discussions with VMD. We are beginning the issuing of these new licences this week, and this will be completed by the end of April. This restriction will remain in place while SEPA and the industry carry out further research to either confirm or confound the apparent link between SLICE use and possible environmental effects.
We are also now considering the findings of a review we commissioned of the environmental quality standards for SLICE to ensure they are up to date and provide adequate environmental protection. In this way, the impacts of sea louse medicines are monitored by SEPA on an ongoing basis, and corrective regulatory actions taken where necessary.
As part of our sector approach, we will continue to encourage and support efforts to develop and implement alternative sea louse treatments. For example, novel in-feed medicines are already in use, or undergoing trials, in other countries, but as yet have not been authorised for use in Scotland. Thermal treatment, cleaner-fish which feed on lice, ultrasound, and lasers which target individual lice, are other innovations being developed by the industry as alternatives to medicine-based solutions.
These are the foundations for the development of our Fin-fish Aquaculture Sector Plan; ensuring operators achieve full compliance, working together to resolve the environmental challenges facing the industry, and providing a regulatory framework which provides robust environmental protection, enabling growth only where the environment can sustain it. The basis of plans for other sectors will be similar, although the challenges and opportunities will differ. But we are convinced that through our Sector Plan approach we can establish the conditions for positive and constructive engagement with all of the key sectors we regulate. We will use our full range of tools, from enforcement to partnerships, to drive up compliance and help as many businesses as possible to go beyond compliance and realise the many economic and social benefits of excellent environmental performance. Together we can help make One Planet Prosperity a reality.