A framework for a sustainable future for finfish aquaculture in Scotland

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Globally, our oceans are under stress. This was powerfully emphasised at the recent United Nations Ocean Conference in New York.  One of the many pressures on our marine environment is the harvesting of wild fish stocks.  Aquaculture, including caged fish farming, represents one way to reduce this pressure, but only if it’s done well. If done poorly, it can also cause damage to the marine environment.

SEPA’s role is to ensure that aquaculture in Scotland’s marine environment operates responsibly and with minimum environmental impact. So we intend to modernise and strengthen the way we regulate finfish aquaculture.

We have prepared draft proposals, and we are seeking views about whether our proposals are right. This is a sector that draws strong and often divergent views. We want to hear from as many people and interests as possible across Scotland to inform the finalisation of our proposals.

Scotland’s vision for the future of finfish aquaculture

The Scottish Government has a vision of “an aquaculture industry that is sustainable, diverse, competitive, economically viable, and which contributes to food security whilst minimising environmental impact.”

We believe that if this vision is to be pursued, we must strengthen environmental controls so that the risks to Scotland’s environment from existing fish farms and future new farms are minimised. In our Regulatory Strategy, One Planet Prosperity, we made clear that compliance with legal obligations is not negotiable, and is the minimum we expect of all those we regulate, in every sector. But we also want to support as many responsible businesses as possible to do better than compliance, by helping them further reduce their environmental impact in a way that also delivers economic and social benefits.

In brief, we want to help to create a world-class finfish aquaculture sector in Scotland by:

  1. Minimising the risks to Scotland’s environment from existing and future farms.
  2. Ensuring all finfish farm operations reach and maintain full regulatory compliance.
  3. As far as possible, help operators to voluntarily improve their environmental performance beyond compliance standards.

The current state of play

Aquaculture is an iconic and increasingly important industry for Scotland. Scotland is the largest producer of farmed Atlantic salmon in the EU, and the third largest in the world. The sector is worth over £1.8bn annually, and supports more than 8,000 jobs. It is an ambitious industry, with a strategy to double its economic value to £3.6bn by 2030, supporting 18,000 jobs. There are 242 active marine fish farms in Scotland, operated by 12 companies, and 109 active freshwater finfish farms operated by 51 companies.

Aquaculture is, however, one of the least compliant sectors regulated by SEPA. Around 21% of marine finfish farms and 7% of freshwater finfish farms were not compliant in 2015. Non-compliance was mainly due to unsatisfactory seabed surveys, exceedance of biomass or discharge limits, and effluent quality failures.

This poor compliance performance must change.

How does fish farming affect Scotland’s environment?

Finfish farming is undertaken at marine and freshwater fish farms. Other industries share the water and surrounding environment with finfish aquaculture, including wild fisheries, shellfish, seaweed production and leisure industries.

All human activity and all sectors of the economy have an environmental impact. The task is to identify and minimise these impacts. So what are the key potential environmental impacts from this sector?

Marine fish farms mostly focus on salmon production, in cages anchored to the sea bed. Freshwater farms also produce rainbow trout. Fish are fed feed pellets and, when required, medicines and treatments are administered either in food, by adding to the water in which the fish are grown, or in well-boats. The two most significant environmental impacts from marine cage farms arise from fish waste falling through the cage structure and being deposited on the sea bed, and from residues of medicinal treatments for sea lice. Sea louse infections on salmon farms increase the number of sea lice in the environment and this may have an effect on wild salmon, escaped fish can compete with or breed with wild fish, and freshwater facilities can disrupt wild fish migration.

Freshwater facilities hatch eggs and rear young fish for growing at farms. Eggs may be sourced from other locations, risking incidental transport of disease and non-native species into Scottish waters. Fish farms have a visual impact on the landscape, disrupt some water sports activities, and generate a variety of wastes.

As with many industries, the aquaculture sector comprises an extensive supply chain including feed supply, fish rearing and growing, waste disposal, harvesting and processing, transport, marketing, retail and, finally, consumption, all of which have environmental impacts.

So what is SEPA doing to ensure the environment is protected? Let’s look at the two main issues SEPA is seeking to address: the deposition of wastes on the sea bed and residues from sea louse medicines.

Deposition of waste on the sea bed

Marine cage fish farms are normally situated in sea lochs, voes and inlets, which provide shelter from the weather but also have restricted tidal flows which limit the dispersal of wastes. More exposed sites with strong tides would allow wastes to be dispersed before they build up on the sea bed, but locating farms in these areas is more difficult, and more expensive. SEPA licences determine the level of stocking (biomass) at fish farms, based on computer modelling of the accumulation of wastes on the sea bed. The computer model tended to overestimate the environmental risk in more exposed areas and, as a result, limited the biomass levels permitted. The limitations of the model resulted in SEPA imposing a maximum biomass of 2,500 tonnes at any fish farm. This has made locating fish farms in more exposed areas less attractive.

In short, the 2,500 tonnes limit was based on the best science at the time, but in some cases, has restricted the sector from locating fish farms where the environmental risk would be lower.

SEPA wants to make it more attractive to develop fish farms in more exposed locations where the risks to the sea bed are reduced. This will help give the sector confidence in making investment decisions to operate where the environmental risk is reduced. We are proposing to do this by revising the way we control the amount of waste a fish farm can release, through a new approach called Depositional Zone Regulation (DZR). DZR makes use of an updated computer model, which can more accurately predict risks to the sea bed. It also involves increased environmental monitoring, carried out by SEPA, so that any environmental effects can be detected early and any necessary corrective action taken quickly.

Under this new approach it would be possible for fish farms to progressively increase their stocking above a starting biomass determined using the updated computer model, but DZR will ensure that growth occurs only where the combination of appropriate siting, and new techniques and processes, mean the environment can sustain it.

Residues from sea louse medicines

The issue of residues from sea louse medicines is one that SEPA is tackling head-on. Last year, we were one of the key sponsors of one of the first significant studies into the in-feed sea louse medicine Emamectin Benzoate.  We were then the sole sponsor of a follow-up study which we are now releasing for further comment.

Last year, in the first of these studies, the Scottish Aquaculture Research Forum (SARF) reported a subtle but detectable impact of residues of Emamectin Benzoate on the environment around fish farms. Sea lice are crustacea, and the impact was on other crustacea living on the sea bed. Based on this new evidence, SEPA has reviewed all fish farm licences permitting the use of medicines containing Emamectin Benzoate, tightening conditions for its use.

Following the SARF report, we also commissioned a second study – an independent review of the Environmental Quality Standard (EQS) for Emamectin Benzoate. An EQS sets acceptable concentrations of harmful substances in the water environment. The review found that marine organisms may be considerably more sensitive to Emamectin Benzoate, and may be affected by much lower concentrations, than previously believed. It therefore recommended that the EQS for Emamectin Benzoate should be very much reduced.

The independent review was a desk-top study that will now be supplemented by the gathering of any further relevant data and information. That additional information will be considered and a final review report produced, which will then be taken through an independent peer review process.  When this is completed, the Scottish Government will consider whether a new EQS should be set.

In the interim, as this process takes place, SEPA will take precautionary action to determine new licence applications and variations regarding the use of Emamectin Benzoate.  This is the normal process during the interim period when the science is being reviewed and finalised before any new regulatory position might be taken.

Given the significance of the initial findings and the importance of Emamectin Benzoate to current industry operations, we have found this a difficult judgement to make.

Initially we reflected the draft EQS, as applying to any new applications, in a revised regulatory position for the use of Emamectin Benzoate.  However, a review of the procedure we followed for commissioning the EQS review indicated that it may not have had access to all available data and information in drawing its conclusions. Given the potentially significant implications for the industry in implementing the proposed new EQS, it is essential that this review is both comprehensive and robust, and that all interested parties have an opportunity to contribute their views. SEPA is therefore inviting the medicine manufacturer, research establishments, fish farm operators and non-governmental organisations to consider the initial review findings and submit any relevant additional data or information they may hold which should be considered as part of the review.

We have therefore decided to revise our regulatory position in the meantime, until this process is complete. We have put in place an interim regulatory position to enable any new applications or variations of existing licences to be determined, taking into account the potential for the EQS to change, but providing for a pragmatic and proportionate approach which ensures the environment is protected and the industry significantly reduces its use of Emamectin Benzoate.

In addition, for existing sites, we are asking operators to reduce their application of Emamectin Benzoate by 60%.  We would not normally ask for any action from existing operations in a sector during an interim period, but believe that extra precaution is justified in this case.

Once the review is complete, and if Scottish Government decides to revise the EQS, we will set out a new regulatory position and adjust all licences to reflect this.

Developing a Sector Plan for finfish aquaculture

In March this year we announced proposals to develop a Sector Plan for finfish aquaculture. That plan will set out how we propose to regulate the operators to ensure full compliance. It will also set out the potential for SEPA to work with the sector to explore opportunities to improve environmental performance beyond regulatory compliance, and deliver wider economic and social benefits as a result.

SEPA will ensure a regulatory framework that ensures the environment is protected, makes legal obligations for operators simple and clear and makes it more attractive to locate fish farms in less sensitive areas. We will drive operators to achieve and maintain compliance. We will use a range of approaches from setting clear legal obligations, providing advice and guidance, exploring innovation and using our enforcement powers to ensure compliance when necessary. SEPA will also encourage and support the sector to voluntarily go beyond the compliance standards.

Following public input to our DZR proposals and the review of Emamectin Benzoate, we will publish a draft Sector Plan for public comment. This is likely to be in early 2018. If you would like to contribute to the development of SEPA’s finfish aquaculture sector you will find all the relevant documents on our web site.

In conclusion

Finfish aquaculture is an important Scottish industry. It relies on, and impacts on, Scotland’s aquatic environments, and has wider environmental implications. It is a sector with growth ambitions, but these can only be achieved with adequate environmental protection, and it is SEPA’s job to ensure that. As with all sectors, the opportunities to pursue environmental excellence will minimise its environmental impact and increase its long-term viability. SEPA is committed to playing our regulatory role to work with the sector to protect the Scottish environment and help achieve these multiple benefits for the people of Scotland.

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