(much of this copied from the previous objection against the CAR Licence application from the Scottish Salmon Company for expanding in Portree Bay)
And here we are, offered yet another chance to sacrifice time to voice our opinions on the suitability of a certain sea loch for a fish farm. And my opinion is that I oppose Kames Fish Farming Limited occupying Loch Pooltiel in the strongest possible terms.
In a way it is good that the people are allowed a voice, but in another way this supposed freedom and gift of power is a sham. The government promised China a great leap forward in farmed fish production, meaning that they will push the fish farming industry (as far as it is necessary to push a corporate industry with as primary goal to maximise profit for shareholders) to increase the number of farms in Scotland, as well as the size of the farms, until the required production increase is achieved. So if it’s up to government and industry, the increase in numbers and size of individual intrusions into the sea lochs of a corporate industry which, by its very nature is inherently destructive and therefore completely unsuitable for any location anywhere, will come. And of course they are most likely to come where resistance is least. And, as an added bonus, of course having to sacrifice time for every single application means that people might run out of steam at some point so that resistance slowly dies out. At best, then, the chance to comment on individual applications to tell why a certain loch is not suitable instead of telling that an inherently destructive industry cannot be suitable anywhere, gives the government and industry a good idea of where the most suitable locations are in terms of least resistance.
In fairness, that is not all. There may be genuine intention to find out which lochs are least unsuitable for fish farming, in that they are least vulnerable and/or least valuable. To that end, if I’m correct, SEPA is still working on a map which will show, based on various factors, which sea lochs are most vulnerable and valuable, and which should not be used for fish farming. This grading is quite a common strategy in conservation. It is also one of the great pitfalls in conservation, as Leslie Marmon Silko explains:
“It is dangerous to designate some places sacred when all are sacred. Such compromises imply that there is a hierarchy of value, with some places and some living beings not as important as others. No part of the earth is expendable; the earth is a whole that cannot be fragmented, as it has been by the destroyers’ mentality of the industrial age. […] [O]nce any part is deemed expendable, others can easily be redefined to fit the category of expendable. […] Even among the conservation groups there is an unfortunate value system in place that writes off or sacrifices some locations because they are no longer “virgin.””
Imagine some people in suits knocking on the door of the Scottish Children Protection Agency, telling them that they want to use a number of children to exploit for profit, which will unfortunately mean dousing them with dangerous toxins, will expose them to terrible parasites and diseases, and may just kill them. No way, say the agency people with one voice. Ah, say the suits, but that’s where you’re wrong. The government backs our plans, we have an awful lot of money at our disposal for propaganda, manufacturing consent and rendering resistance non-credible (not a little of it coming from taxpayers like you), and even the law states that we can do this, so do this we will. And besides, you want your country’s economy to do well, don’t you? Oh, ok, say the agency people, give us some time and we will decide which children are least valuable and which ones are least likely to get severely damaged by what you propose to do. Good choice, the suits say with a benevolent smile, that time we will graciously grant you.
Really? Wouldn’t SCPA physically kick the suits off their doorstep and then do everything and anything they could to prevent the suits from finding children to exploit, poison and kill for their personal profit elsewhere? Ever again? Whatever it takes? Without having to first ask Scottish people for their opinion, albeit their opinion limited to specific children and why they are or aren’t suitable for being killed? If not, they should be called SCEFA (Scottish Children Exploitation Facilitator Agency) from then on.
SEPA’s map could be said to protect Scotland’s most valuable and vulnerable sea lochs against fish farming, while in reality it is at best like trying to limit the destructiveness of the inherently destructive war waged against Scottish sea lochs without actually trying at all to stop the war. But the Scottish Environment Protection Agency is hardly protecting the scottish environment by doing this. At best they are limiting damage, which is a very different thing. Limiting damage is extremely important and valuable, but in the end it is only important and valuable if it is a precursor to halting and then reversing the damage. If not, then maximum damage will merely take a little bit longer to accumulate, but the end result will be the same: dead, toxic sea lochs.
And why is that the likely outcome of an attempt to save the most valuable and vulnerable locations? Experience in many similar cases around the world teaches that once the least valuable places have been sacrificed to a certain kind of ‘development’ (an odd term for a practice which destroys a complex living world into dead products for profit and into toxic waste), the developing industry will want, nay need, to grow more and so, helped by the fact that there is a precedent, a new map will willingly be made by some or other environmental group to determine which of the remaining areas are most valuable and vulnerable, sacrificing some of those which fitted into that category during the first selection, but not any more this time. This process can continue for a while, depending on how many areas you start out with and how hungry for profit and destruction the corporate industry in question is, but eventually there will be no more areas left to sacrifice and all will have been ‘developed’ into gigantic dead zones.
To me, salmon farming and the Precautionary Principle (if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking an action) have always seemed like impossible bedfellows. I haven’t had direct dealings with Kames Fish Farming Limited yet, but have had plenty of interactions with people from Marine Harvest, Hjaltland, Loch Duart and the Scottish Salmon Company. The Environment Manager of the Scottish Salmon Company, Rebecca Dean, managed to emphasise several reasons for my ideas on the inevitable clash between fish farming and the Precautionary Principle during two public events the company organised on Raasay and in Portree earlier this year to inform locals of their current plans for dramatically expanding (more than 400%) in Portree Bay, and I think they are very relevant for fish farming as a whole.
Dean described the seabed underneath the current Portree farm as ‘healthy farming environment’. When asked what that means, she said that most of the natural biodiversity is gone and has been replaced by a few species of marine manure worms. She was even surprised to hear of claims from fishermen and -women, as well as from some salmon farmers, that it’s good fishing right underneath salmon farms, because as far as she was aware there usually isn’t much to catch there, and what’s there is not eating very healthily and would therefore not be very healthy eating. But, she assured us, such a pile of toxin-laden muck would be back to most of its former biodiversity within two years, and back to pristine within five. However, when asked if she could send us peer-reviewed reports supporting this claim, she said that she wasn’t aware of such research ever having been done.
In the meantime a study in Canada by Inka Milewski (http://www.southcoasttoday.ca/content/sea-bottom-still-toxic-shelburne-says-marine-scientist) has found that the seabed under a removed salmon farm was still toxic after a year and that marine life hadn’t recovered. A recovery within another year to a situation where most biodiversity has returned seems rather unlikely in that case. And really, this should not be surprising. In comparison, if an old-growth forest is felled and then left to regrow on its own, it literally takes centuries for it to return to a state where all the functions of a healthy forest are performed again by all the forms of life that a real forest requires. It is not just about there being trees and a few deer and some birds, so replanting the area with Sitka Spruce to be clearcut again in a few decades is only going to make things worse. That practice turns the area into one from which vast quantities of nutrients and life is constantly extracted, not just in the shape of trees, but also in eroding and washed-away soil, leaving the former forest devoid of nutrients within three rotations, after which forests will never grow there again within a meaningful timeframe. A real and healthy forest, in contrast, is a place where nutrients are accumulated, where soil is built up instead of broken down, and where carbon is sequestered. In a real forest, apart from trees and some enigmatic macrofauna, it’s at least as much about all the soil fungi, bacteria, worms, etc. Even healthy farm soil (on land, obviously not underneath salmon farms), “may contain up to a billion assorted microbes, a mile or more of fungal filaments plus scores of various macrofauna creatures such as nematodes and arthropods” (http://www.mycorrhizae.com/wp-content/uploads/2012/09/Oct12_Amaranthusetal.pdf) . In a very real way these small organisms are often more important for the whole than the larger ones. We don’t know nearly enough about them to understand even a tiny bit of the extremely complex role they play in the fabric of the community of life, but we know enough to realise that without them the land can never be healthy and will waste away. It is the same with marine environments. Salmon farming not merely pushes away a few seals, large fish and some lobsters; it pushes away or kills the whole diversity of life, including the small beings in the seabed and the water column; the basis of all life in that area. For that to fully recover will take a lot longer than five years.
Salmon farming changes the seabed and water so dramatically in chemical terms and in terms of nutrients (or rather, eutrophication) that it is not unthinkable that the changes will be irreversible and will permanently change the nature of the area by pushing it from one dynamic equilibrium firmly into another. But even if it’s true that it takes five years for a site to recover to a pristine state (whatever that means in a world in ecological collapse) after a farm is removed, what is the relevance of that knowledge if we know that the industry’s and government’s plan is the opposite of removing farms? They want to add more and bigger ones, after all. The intention is, indirectly but inseparably, to damage more of the total seabed and water and all that lives there and to damage it more severely, and to do it permanently, which means an increased chance of the changes being permanent as well. Where is the good news even if it would take only five years for an area to revert to pristineness again if there is no intention to allow that to happen? Even if the farms are left fallow for a year, Inka Milewski’s research shows that the seabed is unlikely to recover even a bit, and even if farms move position every now and then, it will just mean that the harm is spread out more.
On these still very general grounds I find myself feeling as if I should be able to rest my case and finish this document right now. How much more obvious does it have to be made that this particular proposal; the whole expansion and the industry as a whole are an abomination and should be dismantled right now? But sadly of course I do realise that there is a perspective from which all this is acceptable: the perspective of corporate profit. From that perspective it is totally acceptable and even necessary to sacrifice the complex living planet to convert it into dead products for profit and into toxic waste. From any other perspective it’s absolute insanity. Certainly from the perspective of true SEPI (Scottish Environment Protection Initiatives). Alas, this excludes ever more ‘environmental organisations’ which buy into and/or become dependent on the merger between government and corporatism (incidentally, Benito Mussoline called this merger fascism). Some people are keeping score with accountability in mind.
Another own goal made by Rebecca Dean came when we talked about how badly salmon farms were placed a number of years ago, their location in shallow water with little tidal movement guaranteeing harmful build-up of excrement and chemicals as well as infestations of parasites and diseases. Dean said that “we now wonder why farms were placed where they were 20 years ago, but twenty years onwards we will wonder why they were placed where they are now.”
Such unguarded expressions painfully reveal the level of uncertainty present even in people working in the industry while they are at public meetings to try and tell people, whom they realise full well vehemently oppose their plans, how beneficial and safe salmon farming is, and how much better it can get with more experience and technological developments. To use the words “much better” is a clever trick, until people see through it. In reality the phrase should be “potentially slightly less disastrous”. It was truly horrible 20 years ago, so much so that the industry itself admits it now (I’m assuming that they didn’t admit it back then), but things have now progressed to, at very best, merely very horrible now (and this time I know for sure that the industry doesn’t admit that). Does that count as a real improvement? One that should be at the basis of a decision to spectacularly increase salmon farming? Of course not. Not unless the Precautionary Principle has been dumped into toxic muck while being eaten by marine manure worms.
The locations may indeed be better (less bad) now than they were before, but research by SEPA revealed that if that is the case, it is not reflected in the build-up of organic matter and other pollution underneath and around farms (finding this out was yet more reason to be dumbfounded by the fact that SEPA is still included in the chain which facilitates salmon farming and its expansion):
“Occasionally the mask slips, as it has with the disclosure under freedom of information rules of official figures showing that sea bed pollution is “unsatisfactory” at 16%-20% of all active Scottish salmon farms and “borderline” at 10%-12% more. The Scottish Environment Protection Agency (Sepa) has accepted that the figures published by the Salmon and Trout Association’s lawyers are correct and that “unsatisfactory” farms are killing all forms of life, other than marine manure worms, underneath the fish cages and sometimes far into the sea lochs where they are tethered.
“The impact of Scotland’s £500m aquaculture industry […] is revealed in the results of sea bed surveys released by the Scottish Environment Protection Agency (Sepa).
“The surveys, carried out over the past three years, cover more than 250 fish farms run by 23 companies. Some farms have been surveyed more than once. Sepa classed 137 of the surveys (44%) as unsatisfactory, indicating high levels of organic matter, such as fish faeces and uneaten food, on the sea bed.
“Such waste can disrupt biodiversity by killing off flora and fauna. A further 64 (21%) of surveys were deemed borderline — defined as close to having an unsustainable impact on the environment — and 106 (34%) were satisfactory.”
What on earth, if it is so clear that it is impossible to farm salmon without such high percentages of farms having such big problems, is the use of trying to determine if yet another farm is a good idea? Now, if things were likely to get better and better, there might be some reason for optimism about fish farms truly doing less and less damage, but as developments go, the opposite is true.
Let me illustrate that with the matter of sea lice and diseases, directly linked to the use of toxic chemicals. The problem of sea lice and diseases is only getting worse despite less bad locations for the farms. There are at least three important reasons for that:
Lice and diseases are developing resistance against chemical treatments. This process has literally been optimised by the industry having started out in the most favourable possible places for sea lice to progressively more challenging ones. In the beginning they had the best possible circumstances to develop their resistance against ever more chemicals in the fastest possible way, preparing them for ever tougher circumstances. But even without this help, parasites and diseases are very good at keeping up and outpacing developments in treatments against them (more about that later). In this way the influence of moving to ever better (less bad) locations can be more than countered by an increased resistance against treatment, meaning that greater amounts of more harmful chemicals have to be used despite the move.
Rising temperatures of the sea water as a result of global climate disruption makes outbreaks of parasites and diseases more likely and more likely to be serious, and this again means that farmers will have to use more and ever heavier treatments.
- Increasing density of fish in a farm (because farms are becoming ever larger) and increasing density of farms in Scottish waters makes rapid spread of infestations locally and between farms (not to mention wild salmon and trout populations) much easier. Fish farms are ever less primarily fish feedlots and ever more like sea lice feedlots where fish are kept to feed the lice (sometimes to the point where the salmon have to be slaughtered because the sea lice have affected them too much, like is happening in Norway right now: Salmon farms rushing to slaughter 8,000 tonne of fish due to high lice levels (http://bantryblog.wordpress.com/2013/10/02/undercurrent-news-2-oct-2013-salmon-farms-rushing-to-slaughter-8000-tonne-of-fish-due-to-high-lice-levels/) ). After all, they offer gigantic amounts of food and breeding opportunities for the lice, unlike anything they would ever find under natural circumstances, and they are even becoming more and more conveniently spaced so that sea lice never have to go far to find a convenient site to set off yet another infestation. Allowing Kames Fish Farming Limited to occupy Loch Pooltiel would close yet another gap between farms and bring sea lice outbreaks close to yet another few previously relatively unaffected rivers. And so sea lice have no trouble to maximise their reach, their numbers and their effects, leading of course to farmers using ever more and ever heavier chemical treatments.
These reasons should make clear that problems linked to chemical use and more direct effects of diseases and parasites are only going to get out of hand more and more. Think accountability. This will be held against those who participate in this exacerbation in the end. Refusing to be part of this circus any longer will earn you some very serious credit, though, although not from corporatism and government of course. Alas, what an unfair way.. we have no money to offer you for doing the right thing!
Now let’s look at infestations of sea lice and diseases in a somewhat unusual way. From the perspective of salmon farmers, they obviously are a problem. Because of the way salmon farmers have reacted to them, and only because of that, they have also become a directly lethal problem for wild salmon and trout, and indirectly they have become a problem for whole areas and all that lives there because of the heavy and increasing overload of toxins and nutrients (eutrophication). Fundamentally and ecologically speaking, however, parasites and diseases are not problems, but solutions to problems. They can only become problems for salmon farmers because the practice of salmon farming has caused an ecological problem first. This problem is unnaturally high numbers of salmon confined in one unnatural location for an unnaturally long period of time. Essentially salmon farming introduces a situation of extended and dramatic overpopulation with all the problems and threats of disaster that come with that. The response to these threats and problems from the Community of All Life (ecosystem) is the activation of its incredibly complex, strong, adaptable and resourceful immune system, in this case in the shape of sea lice and diseases which affect salmon.
The life cycle of wild salmon is such that this problem does not occur under natural circumstances. They are always on the move and, apart from spawning time, occur in fairly low densities. If or when they wouldn’t, diseases and parasites would start rectifying the unhealthy concentrations of salmon by killing them off very rapidly until balance has been restored. If this natural immune system would not kick in, the salmon would start damaging the place where they are ever more, to the point where the balance is irreversibly lost (although balance will always return, but it may just be one with continuous algal blooms and not much else living in the oxygen-deprived toxic water).
It has to be clear that sea lice and diseases that salmon farmers are dealing with by using toxic chemicals in fact fulfil an incredibly important function in the circle of life, and it should also be clear that salmon farms, like any kind of intensive farming, are absolutely guaranteed to to lead to infestations, and that these infestations will get ever more insistent and effective the longer their vital function is thwarted, even in the face of full-blown chemical warfare. They have evolved to be fast adapting and very, very persistent, because the health of the whole community depends on their actions. Treating the ‘problem’ in salmon farms the way salmon farmers do equals waging a war against the immune system of the sea, just like terrestrial intensive farming is constantly waging a war against the immune system of the land. This is a fight which the farmers can only ever truly win by destroying the web of life where they are farming, which will of course lead to the very quick demise of their undertaking as well. It would be the ultimate dead end.
And this war has one more very important effect. Diseases and parasites, despite working in extremely complex and beautifully adapted ways, cannot distinguish between farmed or wild salmon and trout. They never had to, until fish farms brought about this abominable anomaly. If fish farms create a problem of overpopulation somewhere, then wild salmon and trout nearby, even if their numbers are very far under the level where the immune system would be triggered, will be affected roughly as hard by that immune system when it’s kickstarted by the salmon farm as the farmed fish. This is what is going on around a great percentage of operating fish farms the world over, despite the claims coming from the Marine Institute in Ireland to the contrary. Fortunately many groups and individuals in the know have completely debunked the Marine Institute’s conclusions (http://www.rafts.org.uk/asfb-statement-on-sea-lice/).
SEPA’s own results show that salmon farmers are not winning this war, because the infestations are increasing and increasingly hard to fight despite and even because of the use of ever more and ever heavier treatments (weapons). And once again, it’s a damned good thing they aren’t winning, because the result would be an immunocompromised ocean. The prudent thing to do would be to realise the nature of the infestations, their reasons, and let that lead to a solution. The reason for the outbreaks being salmon farms, the solution should be to not only not expand fish farming, but to take every last farm out of the water. Yesterday.
In relation to toxic chemicals specifically, in May 2013 SEPA reported that 18 out of 24 sampled farms showed detectable levels of toxins, and 12 of those breached SEPA’s environmental standards (http://www.heraldscotland.com/news/environment/pesticides-from-salmon-farms-poison-scotlands-lochs.20994497). Clearly, when 80% of sampled farms shows toxins being present and 50% of sampled farms exceeds poisoning lochs is not an exception in the salmon farming industry, but a rule. Shocking though this may be, the ultimate point of this is that these harmful build-ups took place while the farmers were adhering to regulations and didn’t use more of the chemicals than they were allowed to. The logical conclusion is that neither the salmon farming industry nor SEPA has a clue about how much of a chemical can be used in a certain area to avoid these harmful build-ups which do long-lasting damage to the Community of All life in that area. For all the claims often made by salmon farmers on the Skye Marine Concern Facebook page (www.facebook.com/skyemarineconcern) that salmon farms in Scotland are heavily regulated, it should be clear that when the regulations are nothing more than almost arbitrary guestimates of what might and what might not lead to poisoning of lochs, and it is then found that they do lead to the poisoning of 50-80% of sampled lochs, these regulations are an utter farce. And this doesn’t only go for the amounts of chemicals allowed, but also for the levels of toxins in the water and seabed SEPA deems allowable. These levels, too, are pretty arbitrarily chosen with only the most rudimentary understanding of the long-term effects of these chemical on the complex Community of Life and the processes which take place within it. SEPA can relax, though, because there is a foolproof solution when actual levels of something, anything, start to systematically break through the official allowable levels: raising the official allowable levels! For example, it was done for radioactivity levels in the United States shortly after the start of the ongoing and ever worsening Fukushima disaster. We’ll be keeping an eye on the allowable levels of toxins around salmon farming to see if the trick is applied here as well.
There are countless other reasons why fish farming in general and the proposal for Loch Pooltiel in particular are ideas that need to be abandoned immediately, and I’m happy to see that many other objections have covered most of those points already. My emphasis is clearly on ‘environmental’ grounds, but I have a few more social points as well.
One of the often heard arguments in favour of fish farming, as I have seen repeatedly in the already submitted comments, is that the industry directly and indirectly supports other industries and the local community (suppliers, shops, schools, etc.). This argument always makes me laugh, because it seems to assume that this is something unique to salmon farming, and that those in conventional fishing (many of who have been in that business for generations and are in fact part of the very fabric of local communities), the tourist industry, or anyone else who will move away once fish farming takes hold of an area, all educate their children at home, get their food and other necessities from the glens and hills instead of from local shops, etc.
I would like to add one more view, directly relevant to that point, coming from Neil Robertson, the Elected Non-affiliated Fishermen’s Spokesperson for the Scottish Government’s North West Inshore Fisheries Group (NW IFG):
“The rather dubious claims of employment opportunities offered by these multi-nationals seldom come to fruition. Past experience proves labour-saving technologies are rampantly introduced to cut production costs and increase shareholder dividends. Additional inducements to communities can be initially attractive (such as pier/jetty upgrades, play areas for local school-children etc.), but once the aquaculture interests have ‘moved on’ these facilities are left for the local communities to maintain, sometimes at considerable cost. Communities must be encouraged to think ‘longer term’ as to the ‘benefits’ of these inducements.
“Bluntly, if there is no substantial socio-economic advantage to local communities why countenance the proposed development?
“Also of concern to commercial fishing interests are the proposed ‘foot-prints’ of aquaculture developments. Seldom does their planning application match reality as anchor chains and ‘safety exclusion’ marker-buoys eat up more precious fishing grounds. Added to this commercial fishing interests are further infringed upon by having to allow very frequent passage for the flotillas of large fish-farm service vessels (well-boats) needed to ‘feed’ these sites. From a safety perspective these added impacts are real and growing – vessels frequently encounter fouled propellers and fishing gear from poorly managed sites – with little immediate prospect of compensation for damage and loss of earnings.
“Recent experiences within the commercial fishing sector has bred a growing scepticism towards the aquaculture sector’s development generally.”
I don’t feel the need to add much to those observations coming from the more conventional commercial fishing angle, but for the point about the “additional inducements to communities”. I think that Robertson uses very friendly wording there. I would rather call many of those inducements the manufacturing of consent, or bribing.
The West Highland Free Press has run a good number of feel-good stories lately which reek of those despicable practices. For example, the Scottish Salmon Company have organised a sporting challenge for the benefit of local charities. They called the event “Salmon Run”. Oh, the irony! A recent peer-reviewed report by Inland Fisheries Ireland found that, on average, sea lice spreading from salmon farms reduce numbers of wild salmon returning to their river to spawn by 34%. In other words, Scottish Salmon Company is part of the reason why more than one third of wild salmon runs is killed off. For the Scottish Salmon Company to organise an event called “Salmon Run” is like the tobacco industry organising an event called “Clean Lungs”.
One more example from the West Highland Free Press was the news about Scottish Sea Farms, owned by Salmar AS and the Leroy Seafood Group of Norway (good for a total turnover of almost ₤1,000,000,000), got a very nice bit of much needed publicity by spending no more than 0,0004% of their turnover on an outboard motor they donated to a local sailing club. Now that is good value for money! They must hope that the gracious gift of 4 out of every one million pounds of turnover has won over a few more souls who now believe that salmon farming is a benevolent force for the community and will defend it despite whatever negative environmental and social impacts salmon farming might have. And this is exactly what it is: shameless attempts at bribing and buying consent at a cost negligible to the company, and then blowing their own trumpet about it. And this is all the more true if we keep in mind the intended doubling of production of farmed salmon in Scotland by 2020. A negligible loss of profit now helps to ensure gigantic increases in profit within a few years.
I conclude by emphasising once more that we have to get to the stage where the question is not which loch is least unsuitable for a fish farm, but whether or not fish farming is a suitable industry at all. We have to get to that stage with government, regulatory bodies and the industry, òr without them. And then we answer that last question with a resounding ‘NO’!
Skye Marine Concern