It is a curious feature of fish farming in Scotland that the great majority of the salmon which are produced in the 250 or so fish farms on our western “aquaculture coast” are not grown from native Scottish stock. They start their lives as microscopic ova, brought across from Norway and Iceland and placed, as smolts, in growing facilities in freshwater lochs before growing big enough to be moved to cages on the open sea.
Figures from the Scottish Government website show that in 2016, no British broodstock were used in fish farms here, while 58.4 million foreign ova were imported. By 2020, the use of British ova had risen to 258,000, against 68.8 million imported.
There is rising concern within Norway and Iceland regarding the risk of damage to the genetic integrity of their wild fish should Scottish smolts escape and interbreed with them. The multinational companies who own the industry here do not share this concern about their own salmon escaping to breed with wild Scottish stock nor, it seems, do our regulators. Until recently Marine Scotland denied the possibility of interbreeding and there have been few, if any, studies undertaken in Scottish waters. However, evidence from places such as British Columbia confirms that it does happen.
Environmental issues within the salmon industry
Environmental issues arise as early as this initial stage in the lochs, when diseases such as saprolegnia, a fungal condition which typically affects fish kept in aquariums, manifest themselves. Currently the main method of dealing with this is by the use of formaldehyde, a highly toxic chemical with a history of use in disinfection and serious industrial cleaning. It is a carcinogen, and industry guidance for its use requires workers to wear protective clothing. In recent years, operators of fish farms have started experimenting with its use in our freshwater lochs.
No doubt as a result of industry lobbying, the Scottish Environmental Protection Agency decided to allow its use, with companies having an obligation to disclose how much they were using. The figures reported by the various companies operating in Scotland added up to a total of 22.4 tonnes of this poison being poured into ten Scottish freshwater lochs between April and December 2019.
The start date of this reporting period is interesting, as it coincides with residents near to some of the lochs in question beginning to experience discomfort, and, in some cases, worrying health issues. In addition,, locals have been notifying SEPA of the presence of vehicles with quantities of formaldehyde in conspicuous containers covered with warning notices.
The ten farms in question are in the Highlands: Lochs Lochy, Arkaig, Sheil, Ness and Garry, (run by MOWI), Lochs Shin, Cooke Aquaculture and Damph, (run by the Scottish Salmon Company), and in Argyll: Lochs Tralaig and Avich, (run by Kames) and Loch Frisa on Mull, (run by Scottish Sea Farms).
Unlike with open sea sites, these operators do not require any permission from the Crown Estate, but they do require a lease from the private landowners.
The problem with a lack of council regulation
The operators also require planning permission. Research in the Argyll & Bute planning portal shows that Kames Fish Farming Limited obtained consents in 1991 for three sites in mid Argyll – the two mentioned above, plus Loch na Losgain Mor, which seems to have escaped SEPA’s attention.
These consents were all limited to six years, after which it was anticipated that the sites would be inspected to check for any environmental damage before possibly being renewed. In this case, this event did not happen. Argyll and Bute Council officials didn’t spot the expiry dates and the operations in all three lochs continued. Recently, Kames applied for retrospective consent for two of their sites, which was duly granted, despite my request that the Council should ask the operators to commission an Environmental Impact Assessment.
On 1 June 2021, the Council emailed me as follows:
“In eventuality, and for reasons I have not been able to establish – all of the involved persons having long left the employment of Argyll and Bute Council – this planning condition was not acted upon when it was first breached in November 1997. In fact, this breach did not come to light until at some point in late 2019 by which time the operations had likely gained ‘immunity’ from any planning enforcement action the Council may have wished to take. Nevertheless, the planning authority took this matter up with the operator of the fish farm as soon as the breach of condition was realised. The subsequent application was made in order to support a claim by Kames Fish Farming Limited that their operations were, by that point in time, lawful.”
Loch Tralaig has a particular problem, in that in the 1950s a hydroelectric scheme was installed, involving the construction of a dam which has since prevented the free flow of water from the loch. The dam is still there, despite the scheme no longer being in use. As a result, there has been insufficient water flow to carry the waste material from the smolt growing cages.
This waste material has been deposited over more thanthirty years, forming a heap of dead material to such an extent that the water depth is greatly reduced. Local residents have reported that there are no longer wild fish in the loch, nor have the ospreys, which formerly nested by the shores, returned. Two years ago, I rowed a dinghy over the loch, while a friend dived down to take the following footage showing the true desolation of Loch Tralaig.
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