Marine Concern's Petition
To The Scottish Government
Closed-Containment For Salmon Farms
More Details on the Petition, Further Reading and References, Mid-Page Sustainable Seas
Voluntary Groups, Non Government Organisations (NGO) and Individuals.
Marine Concern was formed shortly after finding this dead seal pup. An associated NGO, Hebridean Marine National Park Partnership submitted the first EC complaint against the UK Authorities, Marine Concern submitted the second. The Scottish governments action and that of its Agencies were despicable. It is our opinion that Scotland's marine protection is little more than a paperwork exercise, hence the need for sites such as this;-
People Power works, but people need to be informed.
One Bullet - Two Lives!
This common seal pup was found by a tour-boat operator on a known seal haul-out, close to a fish farm near Oban. Shooting had been heard in the area a week beforehand, the fish farm is known to shoot seals.
This was probably a case of 'one bullet - two lives'; it has been recorded that pregnant seals and lactating seals are shot indiscriminately. This pup died from emaciation, a long, painful, lonely death.
Marine Concern supporters recovered the body and buried it. Under the old Conservation of Seals Act 1970 there was no requirement to keep records, report the numbers of seals being shot or even to recover the bodies. This Act is still current in England and Wales.
This was the start of the second seal complaint to the European Commission under the Habitats Directive concerning the UK Authorities.
Conditions concerning the shooting of seals in Scotland changed with the introduction of the Marine (Scotland) Act 2010. seals were still being shot but under licence issued by Marine Scotland. There are no independent checks, no restrictions to seals being shot during the breeding season; so seals like the pup pic. above can now be shot legally.
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Harbour Seals on one of the five component parts of the Lismore Seal Special Area of Conservation.
These seals are afforded 'protection' under the European Union Habitats Directive.
Despite being protected, these seals are subjected varies types of harassment including acoustic deterrents,
by salmon farms.
This is also a 'hot-spot' for porpoise, porpoise are a 'protected species' and acoustic deterrents are known to cause them problems with echo location and hunting. Marine Scotland and Scottish government agencies do little, often nothing to prevent this form of abuse, sound pollution is a major issue at sea for these species.
Typical west coast vistas. We are an island race, our 'wellbeing' relies upon a range of factors, coastal regions and interaction with wildlife is a vital component. We owe it to our future generations to look after this environment. It is not ours, we are simply the guardians. Lack of wellbeing has a cost, the NHS is already at breaking point, how much more will be destroyed before we act and protect?
Common sights are sometimes not all that common and becoming more and more rare. Species are becoming extinct and certainly locally extinct. Animals unfortunately to bear the name 'common' are often most in peril.
This section could be under Sustainable Seas but here the whole point is about being involved, real 'communication' that involves two or more parties that actually listen to each other and more importantly act....that said those parties need to be at the table in the first place, something that Marine Scotland and Scottish Government Agencies are not so good at. What follows is a record of a real situation that occurred in a west coast community in the 1990's and the effects of which are still felt today.
A Scottish Example:
Marine Concern follows the ethos that we are part of the ecosystem, it is not feasible to simply remove us or our effects as if we do not exist, that said we are supposed to be the intelligent species so it is down to us to coexist with the very systems that support us and the entire marine ecosystem. We need to adhere to extracting marine resources in a way that the environment comes first; profit led damaging commercial industries must no longer be the main driving force. We do not own the seas resources we are guardians for future generations. This will be our legacy, what we leave future generations depends on our current actions.
The Historic Legacy.
Before the Wildlife and Countryside Act 1981 there were no legal provisions for establishing Marine Nature Reserves, in deed the government were extremely reluctant to engage and it was only due to NGO pressure and a chance that the whole Act would fail that provision was included. The results of these actions meant that the Act contained critical weaknesses; one was that none of the byelaws imposed by the Nature Conservation Agencies to protect SMNRs could interfere with the functions of any other relevant authority. This is vitally important today, as it is relevant with a current proposal to lobby for a Coastal and Marine National Park without controls in Argyll.
The onset of the Habitats Directive enabled opportunity to develop Special Areas of Conservation and on the back of that Marine Nature Reserves. In the early 1990's a proposal for a MNR in Loch Sween was published, however there was little in the way of consultation or even a 'heads-up'. It was taken as an irreversible act, on first viewing it appeared draconian in approach even to some environmentalists. As a result, the Loch Sween Joint Action Committee engaged, car bumper stickers such as, -
"Let Loch Sween live, say no to the NCC"
In hindsight an inadvertent use of terms as one of the very special species that was marked for protection, as I am aware, is no longer apparent in Loch Sween. Locals and commercial enterprise saw this as 'City Suits' dictating and they were having none of it. The power, network and ability to apply pressure on local communities of the fishing associations and salmon farming aquaculture should not be under estimated
The adverse effects of this massive 'officialdom' blunder attempting to establish a Marine Nature Reserve in Loch Sween still hold true today and it appears that little has been learnt from the experience. At the time as a direct consequence, the Nature Conservation Agency (NCA) stated that it did not intend pursuing any further SMNRs in Scotland. This embarrassment was met with a 'no-more' attitude rather than a 'lets-learn' from our mistakes and the effects have carried over to other designations for the following 30 years to the present day.
Following this government blunder a scientific paper titled, -
'Marine Nature Reserves in Britain: past lessons, current status and future issues'
covered the issues at that time which included a lack of suitable legislation.
The impression of 'West coast' apathy and militant response crept over into the potential UK Biosphere Reserve status for Taynish and Mid-Argyll. The following are extracts from a Report by Hambrey Consulting for DEFRA/UKMAB April 2009.
Biosphere Reserve based on Taynish NNR, -
"The existing Biosphere Reserve at Taynish in mid-Argyll no longer meets the revised UNESCO criteria. Although of exceptional ecological quality.
Possibilities include a modest area encompassing Knapdale, and across east to Lochgilphead and north to the Crinan Canal; or a much larger area covering the whole of mid-Argyll.
Our impression is that there is limited appetite for an additional similar initiative"
In addition to historic events, the past and current pressure from the fishing associations and salmon aquaculture industries have further fuelled the fires for animosity much unfounded and not scientifically robust. Local people have been threatened and intimidated, being left to feel unable to speak out in small rural locations due to recriminations. The industry pressure is still apparent but people's resolve and knowledge is stronger and growing.
The Friends of the Sound of Jura group ( www.friendsofthesoundofjura.co.uk )
Local groups such as this one are a clear indication of renewed bottom up interest. The Friends of the Sound of Jura held an open meeting in Tayvallich recently, the hall was full to bursting, two excellent presentations were given one showing local underwater pictures and film followed by a well researched talk on the current situation and proposed growth of salmon farming in that region.
As a former lobbyist for Marine National Parks (Founder and Chair of Hebridean Marine National Park Partnership) I asked to give a final address. I commented on the huge amount of support and how it was fitting that some 30 years after the government gaff which adversely effected and just about scuppered ALL successive marine initiatives in Scotland that it was fitting that the change was born in Loch Sween.
As Chair of the Hebridean Marine National Park Partnership, we were delighted when the government at that time held a consultation into the potential for Scotland’s first Coastal and Marine National Park in 2006.
The Partnership endorsed this route as the National Park (Scotland) Act 2000 was already in place and Section 31 allowed for a marine element to afford protection to Scotland's unique coastal and marine features. Change of government and legislation led to a change in tack for the Partnership and protection was achieved through the new Marine (Scotland) Act 2010.
The new Local Development Plan for Argyll and Bute (2017) raises the possibility for a coastal/marine Argyll and Islands National Park and a consultation. However, this proposal appears that the process maybe at odds with its Aims.
The Report seeks to explore and to lobby the Scottish Government to consider designation of a new National Park focused on the western seaboard of mainland Argyll and extending west to include the Argyll Islands.
Three major issues arise from the consultation document, namely as laid out in Question MIR 15; -
•"The Council retains the town and country planning function and
•That the Park should have at its driving force the aim of securing the social and economic development of our communities;
•The Park should not in anyway jeopardise our indigenous local industries of fishing, agriculture, aquaculture and tourism;"
The consultation document suggests that the proposal is centred on an economic development focus, rather than a nature conservation focus.
These conditions have the potential to be contrary to three of the four Aims of the National Park (Scotland) Act 2000. Extract from the legislation:
The National Park aims
The National Park aims—
(a) to conserve and enhance the natural and cultural heritage of the area,
(b) to promote sustainable use of the natural resources of the area,
(c) to promote understanding and enjoyment (including enjoyment in the form of recreation) of the special qualities of the area by the public, and
(d ) to promote sustainable economic and social development of the area’s communities.
Historically National Parks result in an influx of people and increased pressure on the very fabric of the point of interest. Take away the 'protective' measures and you are left with a 'honey-pot' without any method of restricting or protecting the maritime region. Combine this with the status quo of profit and expansion of commercial activities over the marine ecosystem and the whole concept in its current form is set up to fail.
However should the proposed Park adopt the original concept of a National Park and that of an effective Park Authority the area could benefit both economically and environmentally.
We are ALL Stakeholders
All too often interested parties and NGO's are excluded from important meetings concerning marine environmental issues. Decisions are often made using a terrestrial template and influenced by the commercial sector, then when and if they are able to make an appearance at these meetings much of the work concerning important issues have already been decided, usually with a commercial bias. When 'environmentalists' engage and try to 'catch-up' they are often labelled troublemakers.
The Health of the Nation: An Island Race
Apart from anything else, the well being of people is vital, we are an island race and the sea is very important to the majority of us. Take away our very special coastlines and habitats and that has an effect on our well-being and this can pressure the already struggling NHS. Houses and homes are the most high valued commodity that most of us purchase in our lifetimes with putting so much into the areas that we choose and love we are indeed ALL stakeholders and ALL must be allowed to engage in a meaningful way, anything else is stretching the definition of democracy.
The Precautionary Principle
Even with our strides in marine knowledge, we still do not fully understand the intricate interactions within marine ecosystems, which are complex at best. Many found it highly worrying when SNH during their submission to the RECC stated that they 'don't know', their remit is to 'advise' government. They are increasingly being further detached from the public view and reality some have even said, not fit for purpose. Two recent examples spring to mind that of allowing acoustic deterrents in areas known for and protected cetacean hot-spots and terrestrially, the recent controversial raven cull.
SEPA also stated that they did not know about the effects of salmon farms, little to no work has been done on accumulated effects, which potentially brings them into the same; not fit for purpose category as SNH in these roles.
Unfortunately Marine Scotland fair little better, some have asked the question is it a case of the tail wagging the dog...it appears that this Trio is so mixed up it begs the question, which end is the dog? In the case of the first draft from the Clyde Forum I was asked to give an opinion, I took one look at the seal’s section and to my astonishment; there were not any seals in it...despite many seals being resident in the Clyde. I was asked to give evidence at a Public Hearing on Bute, the Inchmarnoch case, where some 600 seals haul-out. I was heavily involved during the seal 'designated haul-out' process. I was told that there are no designated seal haul outs in the Clyde. To me a clear indication as to the fishing and aquaculture industries being in FULL control.
If the facts are not known then the
Precautionary Principle Should, Must be invoked....Often it is not.
Times are a changing
Maybe previous forms of attempting marine protection were before their time or maybe simply the commercial industries were too powerful. The concept of 'Out of sight, Out of mind' prevailed. In fact some of the old terms on the west coast still persist, like, 'Tip it in the tide', when dealing with rubbish. Technology has played its part, underwater cameras and videos are now commonplace and the internet provides the perfect forum on which to display the actual atrocities that occur everyday in our coastal waters. With more than 17 million people watching the BBC's Blue Planet ll on its first viewing people were shocked into acting.
This new advance in public education has not been as seen before and interest and concern has grown in momentum. The BBC's One Show has shown repeated clips on plastic rubbish at sea; recently not a week has gone by without reference to the problems of microfibers and single use throwaway society. Primetime TV! Images of a convoy of lorries dripping rotten and potentially toxic liquids from dead salmon throughout the Highlands remain engrained in the minds of many.
The Scottish Parliament’s Environment, Climate Change and Land Reform (ECCLR) Committee, recently held an inquiry into salmon farming’s impact on the environment, the report was damming to the salmon industry. The ECCLR committee’s report is among submissions being considered by a larger inquiry by the Rural Economy and Connectivity (REC) Committee into how best salmon farming can proceed.
Confusing messages from the Scottish government
Meanwhile and despite the Committee's findings Fergus Ewing while in Brussels, (who spoke to the REC inquiry), made it clear he does not share the reservations of some of his Holyrood colleagues. The Scottish Government Cabinet Minister said, “Our farmed salmon is worth a staggering £600 million and we fully support the plans for sustainable growth that the Industry Leadership Group have said to double production by 2030".
'Rural Economy Secretary Fergus Ewing has given unequivocal and emphatic backing to plans by the Scottish salmon industry to double production by 2030'.
The Scottish Parliament TV, item 3. Salmon farming in Scotland: The REC Committee taking evidence from Fergus Ewing, Cabinet Secretary for the Rural Economy and Connectivity where he reiterated his support for the expansion of fish farming. The Minister's evidence starts at 10.05.
This should be ringing alarm bells; why on the one hand has the Scottish government engaged in the costly research and committees, looked into the potential effects of salmon farming and then once discovered just how damaging the industry is goes ahead and voices publicly the intended doubling of capacity? It appears that little has been learnt, little has been taken on-board and expanding the salmon industry without modification will undoubtedly lead to the collapse of the industry with the potential of severely damaging Scotland's pristine ecosystems and other industries that rely upon them.
I believe that there is potential for the salmon industry to coexist without adversely damaging Scotland's marine environment BUT it has to be a case of controlling and curtailing current out-of-hand, sometimes illegal practices. Closed containment with fully contained circulatory systems would be a start and should be the minimum requirement.
Fishing can prosper, the Royal Commission Environmental Pollution's 25th Report, 'Turning the Tide' gave estimates for differing levels of future-proofing fish stocks. We are now 14 years down the road since publication but if we want to future protect then 30% of our seas need to be 'No-Take-Zones'.
New Zealand was the World leader in this direction, their pressures were different and they started a long time ago, therefore they were able to section just 10%, the differences in species abundance, species size and quantity, even animal behaviour was amazing. The bottom line in marine protected areas that include restrictions to fishing etc. result in increased catch for less fishing effort on the boundaries of the Reserves. Reserves by whatever name given that do not include No-Take-Zones are little more than paperwork exercises, a meaningless gesture.
We can provide for our future and that of our future generations but we need to address and alter the current commercial free for all: The Status quo is not an option, not sustainable.
Written by Mark Carter
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