SCOTLAND’S salmon farmers have raised several concerns over the proposed regulatory overhaul by the environmental watchdog, outlined in a report published in November.
The Scottish Salmon Producers Organisation (SSPO), which represents the sector, said in a statement on its website that it is ‘delighted SEPA [the Scottish Environment Protection Agency] proposes to give salmon farmers the support they need to grow sustainably over the long term’.
However, it warns that SEPA’s ‘one-size-fits-all’ approach is not appropriate for Scotland’s salmon industry.
SEPA recommendations to relocate farms, tighten monitoring, and tackle non-compliance require more detail, and more time to implement, and need to be science based.
The SSPO said it is ‘keen to pursue this new agenda as soon as possible’ but there is still a lot of work to do.
In a written response to SEPA’s aquaculture sector plan, the salmon body said: ‘The sector would like to progress with the new framework with pace, to allow farming in the most appropriate locations, but there is a need to get this change right rather than change it quickly and get it wrong.
‘The proposal for new farms entering this new regulatory framework, with 2019 as the stated implementation date, is challenging, given the details still to be completed with regard to the determination process and licence conditions.’
SEPA’s proposals include moving farms further offshore, closer monitoring of waste, tighter controls on medicines, and the creation of an enforcement unit to ensure ‘compliance is non-negotiable’.
On the siting of farms, the agency said ‘this may allow for the approval of larger farms than would have been traditionally approved previously, provided they are appropriately sited in sustainable locations’.
But it has alarmed smaller operators by saying it anticipates there will be fewer fish farms in shallower, slow flowing waters and more fish farms in deeper and faster flowing waters.
The SSPO asks SEPA to define what it means by a small site in terms of footprint size and biomass.
‘We are concerned that the impact on small companies does not appear to have been taken into account when developing the sector plan. The modelling, monitoring and sampling requirements are extensive in terms of cost and resource.
‘Innovations like high energy sites and RAS are not necessarily within reach, financially, for small companies. Support for alternative innovation which can benefit smaller companies should also be considered.
‘There is some concern that the ‘one-size-fits all’ approach does not necessarily suit the diverse nature of the Scottish finfish sector.’
In other comments, the SSPO said farmers would welcome a simpler licensing system: ‘The current licence arrangements are not fit for purpose and compliance with them does not provide a true reflection of environmental impact.
‘Under the existing regulatory regime, non-compliance in the finfish aquaculture sector has been dominated by failures in benthic surveys,’ said the SSPO.
‘These compliance failures are, in the main, where the farm’s footprint does not match the model prediction. This does not necessarily mean environmental harm has taken place, but it does mean that the footprint is not where it was predicted to be.
‘Moving to a position where compliance is based on actual environmental harm is welcomed by the sector and we believe it will demonstrate a step forward in our compliance performance.’
The SSPO also said it would welcome further work to protect wild salmonids, which should include ‘consideration of all other pressures identified as potential impacts’.
It expressed reservations over the switch to new modelling, saying SEPA’s NewDepomod requires ‘significant work to develop it into a useable format and will need upskilling of staff and a commitment to development’.
‘The economic impact on a small company or start-up in the sector which needs to develop a hydrographic model linked to NewDepomod could be excessive.
‘Assisting smaller companies to become more efficient/update equipment or move to other locations should be considered. The current proposal would be a barrier to entry to the sector.’
To read the SSPO’s full response see http://scottishsalmon.co.uk/wp-content/uploads/2019/01/sspo-response-to-sepa-sector-plan-dec18.pdf
Picture: SSPO chief executive Julie Hesketh-Laird