Sustainable Seas

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Bad Practice.

People; Part Problem - Part Solution?

Plastic, Plastic, Plastic.

Scottish Parliamentary Petition: Closed Containment.

Official Shot Seal Numbers.

Man and Nature can Coexist

BUT it needs to be a case of the

Environment over Profit.


The Seaspiracy documentary is now trending on Netflix.

For a summary of today’s global ocean problems this documentary sums it up well.

Lifted from the Seaspiracy website:






The following listed facts are worrying.  




















Some Examples of 'Bad Practice' and

Some ideas on how to improve.

The Scottish government coined the phrase, "Maximising Sustainability", it was an attempt to gain support from commercial industries during the scrutiny of the Marine (Scotland) Act 2010. The words, 'maximise' and 'sustainable' when considering the marine environment do not fit comfortably in the same sentence.

The use of 'No-Take-Zones' would however go some way in sustaining the future use of Scotland's marine resources.

2019 has seen a ‘Teenage Take-over’: Politicians and governments are failing both us and the marine environment, teenagers still at school have picked up the campaign, highlighting the MAJOR issues which face Global Concerns, this IS their future! 

Will we listen, more importantly, will we ACT? Will our actions be enough? Will our actions be in time?


It is about time that environmental issues were taken 'outside' of political parties...

A Cross-Party, A Cross-Country Concern! A future that actually utilises the Precautionary Principle, a future that actually understands and defines the word and meaning of  ‘SUSTAINABILITY’ as an environmental criteria for the long term not as is often seen as a cheap publicity stunt, banded about like confetti for the advantage of short term commercial activities.  

EU & UK 'Protection'

Part of an SAC

(Special Area of Conservation)

for Common Seals.

38 were shot in 2 days

50 were shot in one season.

The salmon farm can be seen, the six ringed structures, along with feed barges. The floating structure nearest the haul-out carries a generator and fuel dump.

The closest structure seen in this Google image is 20m from the 'protected' haul-out.

About 40 years ago salmon farming in Scotland was seen as an industry to overcome employment issues in more remote regions and the islands.

The industry grew with little concern to the environment. Currently it appears that the Scottish government in interested in expanding, in order to sustain the Chinese market.

It should be noted that a one percent increase would require close to a 50% expansion in Scottish waters.

Currently little is done to mitigate issues created by the multi-national salmon farming companies. These issues include; pouring tons of chemical treatments in to the sea, shooting seals, not as a matter of 'last resort', as required by law but in the first instance. The latest 'advance' is to fish wild wrasse from elsewhere, exploiting these fish and killing them each salmon harvest.

These are just some of the issues, the concept of catching wild fish to feed them from already over exploited fisheries is yet another.

Lismore Special Area of Conservation (SAC)

The Scottish Sea Farms site within the Special Area of Conservation (SAC) for Common Seals.

Google Maps Image and position (2019) 560 32’55.9N  005029’02.2W. Don’t take our word for it check it out for yourself simply Copy & Paste:  56 32’55.9 N 5 29’02.2W and web search it.


The Lismore SAC is made up of five component islet areas around the main island of Lismore. There are currently 14 salmon farm cages within the bay close to this one designated haul-out, several feed barges and fuel dumps/generators, the largest of which actually contains a HOUSE!


Despite a declining seal population, mass (past) shootings, disturbance/harassment, including debris and mooring tackle on the islets, recent shooting under Marine Scotland License and three separate European Commission complaints, this salmon farm is still located there and little is done about it, apart from a 'management' group set up with restricted membership. When the farm is left ‘fallow’ (a salmon farming term, when there are no fish in the structures, supposedly to allow for the seabed to recover, normally insufficient time is allowed) some of the seals return.

One of the Five Component Sites that make up the Lismore SAC

(Google Image 2019)

Most issues concerning salmon farming could be mitigated by utilising 'closed-containment' pens; but they are more expensive and without public and/or government pressure, current damaging methods continues unabated.

This French trawler company had four of its fleet run aground in a matter of months. The waters around the west coast of Scotland are notoriously difficult with a limited buoyage system in place.

The outer isles experience storms and wild seas; the decision to disband the 'full-time' ocean going tug was fool hardy at best.

The folly of cut-backs in such a relentless remote environment is a retrograde step, it will only be a matter of time before the 'real' cost is felt.

A Coastguard, ocean going tug, pictured here refloating a French trawler which ran around.

Without an ocean going tug permanently situated on the west coast of Scotland serious incidents will occur, not a matter of if, rather when.

People - Part of the Problem, BUT Could be Part of the Solution!

At Marine Concern we run with the principle that we are part of the ecosystem, we could live alongside Scottish wildlife without adversely effecting the ecosystems that support them and the fisheries that arguably support both. This can only be done if we take stock of what we have done, what we are doing and stop damaging the marine environment that supports food stocks, the tourist industry and so much more.

The Royal Commission for Environmental Pollution's 25th Report; 'Turning the Tide' suggested that in order to maintain future extractions and preventing biodiversity loss we need 30 percent of Scottish seas to be 'No-Take-Zones'. These are areas that do exactly what it says; - NO-TAKE. Around the world areas that use areas of no take have seen greater fish diversity, larger species and more fish. Fishermen have targeted the boundaries of these reserves and have found greater catches for less fishing effort. We just need to make the change.

A reintroduction on the" mobile fishing fleet; of the 'Three-Mile Limit', preventing damaging dredging and benthic trawling in fish nursery grounds would be a start in the right direction.

A Common Seal shot during a 'Seal Conservation Order'; dispite being reported, no action was taken!

Pictures for Thought;

Good Practice V's Bad Practice

When marine mammals indeed any animal interacts with us as long as we use caution any potential problem is minimised. Actively searching them out and contravening Marine Watching Guidelines is not good for the animals and maybe not good for us either.

Sea of the Hebrides; The Author was joined by Dolphins.

Souviners, what used to be seen as the 'norm' is now frowned upon and may cause untold damage to vulnerable ecosystems.

This salmon farm is situated within the Lismore SAC, a protected area for common seals. The floating diesel generator can be seen to the right of picture just 20m from the protected haul-out. Despite so called protection seals are shot here. Acoustic deterrents are routinely used in an attempt to 'scare' seals from the area. This region is a known 'hot-spot' for porpoise, acoustic deterrents are known to adversely affect porpoise. Porpoise are 'protected'. This type of activity, along with many other offences are not sustainable.

Common Examples of Problematic Human Interaction with Sealife.

A sperm whale was reported in Oban Bay. People flocked to see this rare sight. The whale was well out of its normal habitat and was probably ill and distressed. Boats obstructed its passage and got far to close. This kayaker probably touched the whale with his kayak. Apart from not being ethical it is illegal and dangerous. Whales are a protected species.

When done sympathetically with nature, sea kayaking is probably one of the least invasive marine activities. Watching/approaching without due concern, such as getting too close to seals while they are hauled out can cause stampedes, which can kill pups. Seals need to 'rest' and warm as part of their lifecycle, especially during the breeding season. Harassment is now an offence in Scotland with potentially large fines and imprisionment.

Plastic Plastic Plastic

The following pictures were taken in what is commonly thought of as a 'clean' sea loch.

They were also taken from the lochsides which run parallel to the prevailing winds; therefore

plastic accumulation would not be expected as at the leeward end of the loch.

The 'plastic' problem is Global and needs to be addressed from both a global and local perspective. As with single use plastic shopping bags we have proved that we can act and can make a difference. This issue is huge and needs to be addressed now, before it is too late, with an attempt to clear up the current mess which is now in the food chain, adversely affecting species and geological sediments.

Long term accumulation of plastics, some will never degrade

during our lifetimes.

Polypropylene, the World's second most widely produced plastic. Rope remains in tact for millennia. It kills indiscriminately.

Discarded and lost fishing nets continue fishing until they are recovered...

often never!

Deeply embedded plastic

within the strandline

Ring ties, bag handles and an array of other shapes trap animals of all sizes...please cut all loops and rings before putting out into the rubbish bins.

Marine Concern's Petition

To The Scottish Government 


Closed-Containment For Salmon Farms


The Coastal Communities Network, Aquaculture sub-group

Officially supports petition 01715.

Petition Update

Marine Concern's petition ran over Dec. ‘18 - Jan. ‘19)

Calling on the Scottish Parliament to urge the Scottish Government to ensure that the salmon farming industry

solely utilises a closed-containment method with full water filtering in Scottish waters.


The PUBLIC PETITIONS COMMITTEE held on Thursday 7 February 2019,

the Committee agreed to write to the Scottish Government and key stakeholders to seek their views

on the action called for in the petition. (PE1715 on Closed-Containment for Salmon Farms in Scotland).

Scottish Public Parliamentary Petitions

Closed-Containment for salmon farms in Scotland PE01715

Currently before the;

 The Rural Economy and Connectivity Committee

Update from Wednesday 22nd January 2020

Concern mounts from environmental and community groups

over apparent lack of engagement.

The good news is that the petition has been kept open, the REC Committee are to ask SEPA for information concerning legislation/regulations etc. concerning the trialling of closed containment systems in Scotland.



You can watch the Committee meeting on Scottish Parliament TV in Committee Room 2: 


Alternatively, you can watch in the public gallery in the Committee Room at the Scottish Parliament in Edinburgh. Information on attending is here:


Current RECC paperwork before the committee can be viewed here.

The Petition was heard on the 7th Nov. Very short and referred back to the REC Committee. Not sure how useful that will be as the Scottish government has all but ignored the findings of both the ECCLR and REC Committee findings (please see below). There did appear to be some confusion as to closed-containment being just on land. We have written to the MSP that raised the point, slightly worrying as this MSP also sits on the REC Committee, stating that they had already covered matters in some detail. We will report back when we know more.

Closed-Containment for Salmon Farms in Scotland: References used, Further information and Links


Salmon farms were established in Scotland in the early 1970's, they were seen as a panacea to providing work in remote rural areas especially the western and northern islands of Scotland, as well as raising Scotland's GDP. Environmental concerns soon became evident and the industry gained a bad reputation in not complying with environmental legislation.


Poor practice was compounded by planning that was and still is based on terrestrial templates, very little that occurs in the marine environment can be on a par with farming on land. The Scottish government and its Agencies forged ahead with expansion with little thought to the environmental costs.


The salmon industry has seen a 50% increase in salmon production since the mid 1990's, the environmental damage has been recorded and much is now known about the devastating effects that mass production including its 'medicines' and 'treatments' have. We are now facing yet another 50% increase in production with what currently appears to be little change in the operation process.


Salmon is Scotland's second largest food exporter at an estimated £600million in 2017 but using out-dated production methods it comes at a cost to Scotland's pristine coastal waters and the other industries and reputation which reply on Scotland's past 'clean' credentials.


Salmon farming does not have to be the bad neighbour as it is currently referred to; there are alternatives such as 'closed-containment'. By utilising closed containment systems on land or afloat the industry could expand without causing more damage to the marine environment, save the fishing from depleted waters especially those that third world countries rely upon as their only protein source.


Several major issues surround salmon farming, namely that Planning is still seen as 'Presumption in Favour' of production, despite the damming findings concerning the salmon farming industry from the Scottish government's own, Environment, Climate Change and Land Reform Committee (ECCLR) Report, "The Environmental Impacts of Salmon Farming" and the Rural Economy and Connectivity Committee's (RECC) "Salmon Farming in Scotland" Report. The Scottish government is failing in addressing the issue it cannot even answer a request for the definition of 'sustainable', yet quotes the word widely. Scottish government and its Agencies along with Councils where applicable have developed a somewhat 'cosy' relationship making any real opposition very difficult. The multinational industry is well resourced and highly opposed to change, which affect profits.


There is insufficient space here to fully cover extant issues surrounding salmon faming, what follows is more of a list with further reading and references used. Two Reports cover the major issues particularly well; the Scottish government's own ECCLR Committee findings and the CRRU Report. Other links can be found at the end of this posting. Marine Concern's background has been to highlight current marine environmental situations using seals as top end predators and extensive background in seal/fish farm worker interactions, an example of industry's abuse to the systems, we will expand on this below.

Many Seal Haul-Outs were NOT Designated; WHY?

One Question Marine Scotland has NEVER Answered.

 US MMPA Update: Imports/Seal Shooting

The Marine Scotland website has produced the following in respect to the effect of the US Imports under the Marine Mammal Protection Act with regard to the shooting of seals by UK fish farms.



“Part 6 of the Marine (Scotland) Act 2010 seeks to balance seal conservation with other pressures and requirements, such as species conservation. On 1 February 2021 changes to Part 6 came into force which removed two reasons for which licences to kill or take seals could be granted. These are protecting the health and welfare of farmed fish and preventing serious damage to fisheries and fish farms:

  • it is an offence to kill or injure a seal except under licence or to alleviate suffering
  • a number of seal conservation areas around Scotland have been introduced, designed to protect vulnerable, declining Harbour seal populations
  • a seal licensing system, providing a well-regulated and monitored context for seal management in Scotland is in operation”.




Nobody knows how many seals are shot each year under licenses issued by Marine Scotland, part of the Scottish government.


no authority is actually counting! Bad enough you might think but read on, it gets worse, much worse.


The official Marine Scotland website will tell you that 245 Grey Seals and 113 Common or Harbour Seals were shot during the one year period covering 2017, but this is based on self reporting from an industry that has a very poor record for complying with environmental legislation (see the estimating methods devised by Marine Concern and accepted as the current best up to date method by several NGO's below).


PBR's and Counts

Permitted Biological Removal (PBR's) methods are used to determine how many seals can be 'taken', without having an adverse affect on the population. By definition when a population is in decline, the PBR should be zero but government paid scientists refuse to stand up to the mark.


Under the European Commission's Habitats Directive, a report on the 'conservation status' of species must be submitted every six years. In the UK this falls on the Special Committee on Seals and in Scotland the counts are conducted by the Seal Mammal Research Unit (SMRU). Counts were done on a yearly basis but now it appears that a rolling estimate over a five-year period has been adopted. This method cannot be as accurate as yearly counts and opens the whole system up to short-comings during a crisis, such as the PDV virus out breaks which have decimated huge colonies of Common Seals around Europe, up to 85% in some areas.


Making matters worse is the use of 'polygon' counts and alteration of the sizes of the polygons or the choosing of different populations, which has the ability to off-set the 'decline' ratios on Scotland's west coast.


Seals are inquisitive animals, they like to investigate; structures in the sea and oceans are known to attract species including fish, fish attract other predators, many seals will approach salmon farms as a result of these additional interests including wild fish. Many salmon farms have been placed along seal transit routes some even in Special Areas of Conservation for seals and even in protected areas Marine Scotland deem it fit to issue licenses to shoot seals.


The Scottish Rural College (SRUC), Inverness, currently holds a contract to record and investigate seal strandings in Scotland. This work is funded by the Scottish Government and is designed to support the new seal licensing system. It is worthy of note that that despite being part of the Marine Scotland license requirement only 2.3% of the Grey Seals shot and returned and 4.5% of the Common Seals shot and returned were subject to necropsy (animal autopsy).


Scientists from the Rural College stated concerns that only 'clean' kills were being returned, this has been covered in the online publication by Frontiers of Marine Science, with one quote, "Marksmen may choose to only recover seals that have been shot well".


Evidence from the report of necropsies indicated seals were being shot in the neck, the jaw and included multiple shots. "Clear evidence of seals being shot in ways that do not follow the Scottish Seal Management Code of Practice".


A very small number of seals, less than 10% actually predate on salmon installations and these have become known as salmon specialists. Of the shot, seals returned their stomach contents following necropsy indicate just 2 to 3% salmon studying both ear bones (otoliths) and DNA testing. Some of the shot seals returned from salmon netsmen had no salmon in their stomachs at all.


More than 35% of necropsied seals were found to be either pregnant or lactating and this creates huge welfare issues, the seal pup picture on Marine Concern's 'Contacts' page is one such pup left to die for over a week; emaciated. The Conservation of Seals Act 1970 has restrictions for the breeding seasons; the Marine (Scotland) Act 2010 however, does not.


There may be more than 50% of shot seals considered under the 'Struck and Lost' numbers that is the seals that have been shot but escape, often to die a long painful death. A conservative figure given to those that have been under reported or not reported at all is set at 25%, although this figure might be much higher. Adding these figures together with the pregnant or lactating figures takes the latest government figures up to at least 752.


Marine Concern's Method of Accounting for Seals Shot in Scotland

Marine Scotland's 'official' figures

Additional numbers added due to being pregnant and/or lactating     (35%)

Additional figures added due to 'Struck and Loss'                               (50%)

Additional figures added due to lack of reporting, [conservative]        (25%)


Seals Shot in Scotland More Likely to be 800 plus per Year!

Dispite around 2,000 Seals, Marine Scotland still refused to Designate the Ythan as a Protected Haul-out.

The Protection eventually came after mass public pressure.

The CRRU Report states: "The current system of self-regulation within the industry is clearly inadequate and officials in offices fail to acknowledge the shortfall in reporting. Evidently, numerous kills go unrecorded, multiple kills may not be reported, unlawful sinking and/or dumping of carcasses deliberately occurs, plus there is no accounting for "struck and loss" figures (which may account for up to 50% of all reported clean kills)".


Mind-Set.It is worth noting the 'mid-set' of those in the industry when thinking about seals being shot, as it is not your normal 'town or country' public perspective. Under the Conservation of Seals Act 1970, which is still in force in England and Wales the term 'rogue' developed. Rogue seals could be shot under the terms of the Act. The associated industries turned this around, with many stating that ALL seals were 'ROGUE' and therefore could be shot. There have been personal accounts witnessed (Pers Comms) of fish farm workers laughing about it on site and in local hostelries.  Even under the new Marine (Scotland) Act 2010 this false and illegal ideology exists.


Not Listening. Marine Concern and previously Hebridean Partnership have been involved with the seal shooting issue for more than 20 years. During that time communication with the relevant authorities and the Scottish government has been attempted, with limited success. Often the criteria set by the authorities is altered to exclude 'conservation' groups, in the case of the Scottish Seals Forum a leading member of the Scottish government stated, "I have no intention of creating a balance in the group", which at the time was three to one in favour of the commercial industries.


Recent contact with the government once again called for a 'level playing field’ that includes ALL 'Stakeholders', which includes the public and NGO's. That's nothing new and is laid down in the principles of the Rio 'Earth' Summit under Agenda 21...involving communities. However, the government failed to even supply a definition of 'sustainable', a word currently being banded about by politicians like confetti.


'Sustainable', was covered in The World Commission's Report, 'Our Common Future', known as the Bruntland Report states,"Development that meets the needs of the present without compromising the ability of future generations to meet their own needs", however current authorities and politicians generally appear not to want to adopt this widely accepted reference when dealing with growth in their own back yards!


Currently salmon production in Scotland is far from being 'sustainable'. Closed-containment would go someway to enabling expansion of the industry without further damaging Scotland's pristine coastal waters and good reputation.





References Used, Further Reading and Links


Environment, Climate Change and Land Reform Committee: report on the environmental impacts of salmon farming


Robinson, K.P. (2014) A Fishy Business—Of Seals, Salmon and Fisheries in Scotland. Cetacean Research & Rescue Unit, Banff.


Scottish Association for Marine Science (SAMS) Report for ECCLR Review of the Environmental Impacts of Salmon Farming in Scotland 02468_0001, Issue 01, 24\01\2017




Time for change in Scottish salmon farmingSWT


Report of the World Commission on Environment and Development: Our Common Future


Marine Scotland Seal Licensing




Plus much more, if you would like futher information please contact Marine Concern via the Contacts page.



Seals are Inquisitive Animals; they can be Shot for just being Friendly.

2018 Update on seal numbers being shot under license


The Scottish Government is required under the Special Committee on Seals (SCOS) to provide updates on the seal populations and situation. In Scotland much of this is conducted by the Seal Mammal Research Unit (SMRU) and on occasions Scottish Natural Heritage (SNH).


The figures listed for 2018, correct as of the 31/03/2018 are: -

245 Grey Seals and 113 Common or Harbour Seals.


Scot. Gov. Figs.                                      358

Struck & Lost (50%)                               180

Pregnant or lactating (30%)                   161

Unreported (25%)                                  175


Estimate of Seals Shot in Scotland   =   875


Figures rounded and likely to exceed 900 seals shot in Scotland under the current license system administered by Marine Scotland.

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