Report, March 22, 2003
From: Allan W. Berry, Chairman, Society for the Protection of Salmon and Sea Trout, Perthshire, Scotland, UK
Aspects of Government "Pro sea cage fish farm" Policies
A serious problem has developed over the last 25 years, namely the 'scientific' confusion concerning conflicting views on the nature and quantity of environmental damage caused by open discharge marine fish farming.
Sea cage fish farming began in the Western world around 30 years ago. Promoted vigorously by the industry and its political, administrative and scientific supporters, it soon became a boom industry. Leases to moor cages in sheltered coastal waters quickly became valuable traded assets.
Cage farms are licensed to discharge untreated trade wastes directly into the sea, avoiding and externalizing the expense of waste treatment. This enables fish to be produced for less than a third of the cost, inclusive of waste treatment. Thus, an anomalous defect in environmental regulation (most other intensive livestock producers have to internalize such costs), has enabled an industry dominated by multinationals to become one of the world's largest, wealthiest and most influential sources of licensed pollution.
Those who introduced, promoted and defended the industry adopted the slogan "Jobs come first, nothing must be allowed to come in the way of such a benefit to fragile rural economies. Any environmental damage is a small price to pay." Unfortunately, most politicians do not understand that the economy is only a part of the environment.
Apologists for the industry misrepresent the scale of waste production. Feed conversion ratios are often quoted as 1.1 — 1.4 tonnes of feed to produce one tonne of fish. The 2002 Scottish production of 50,000 tonnes (dry weight) of Atlantic salmon will require around 190,000 tonnes (dry weight) of fish feed, a process generating a huge volume of fish slurry, including 8,000 tonnes of waste nitrogen, discharged to the sea mainly in the form of ammonia.
Intensive livestock production in coastal waters alters the natural balance of Plant and Animal. The degradation of the waste produced implies bacterial biomass production on a similar scale to that of the farmed fish. The alterations to nutrient ratios promote harmful algal blooms and biotoxin production.
Disease and parasitic infestation emanating from intensive sea cage fish farming were initially seen as a perceived risk, although denied by both industry and their captive agency dependents. The government's own scientific advisors were aware that this was an actuality over ten years ago, but their advice was suppressed. Sea lice larvae originating from cage farm stock have since caused the virtual extinction of wild sea trout and salmon in most west coast and island waters where salmon are farmed.
Studies on the genetic link between lice from salmon farms and those infesting wild salmonids in the vicinity of farms (partly funded by SNH) showed such a link existed, namely chemical resistance markers which proved their farmed fish origin. This research was clearly a threat to the industry and was promptly abandoned.
Worldwide, the industry and its supporters still deny the obvious. As long as the truth can be suppressed, they survive and prosper. Indeed, one can fool most of the people most of the time. The survival and growth of the industry is a testimony to the power of organised environmental crime.
The core problem is corruption, deep rooted, founded on ignorance and greed, sustained by deception and denial, and the realisation that proper inquiry would bring the gravy train to an end. Scientists, administrators and others, dependent on the industry worldwide, are using every method at their disposal to protect their interests.
Production oriented scientific service providers compete for lucrative industry business on all levels. Over the last 30 years, close customer/supplier relationships have been formed. Loyalty to favoured industry customers is institutionalised. Proponents of an objective scientific approach have been intimidated and excluded, while some supposedly 'independent' bodies can be accused of operating a protection racket, protecting polluters for reward.
Meanwhile the function of the government science services appears to have been to 'harmonise science with policy'. Institutions such as the Royal Society of Edinburgh favour 'enabling' research on aquaculture.
Presenting the industry as the only way forward, industry promoters have denied the evident environmental damage and deliberately suppressed attempts to bring the matter under proper scientific scrutiny.
The unsustainable nature of the industry and the damage it causes to the marine environment and other related interests has long been evident worldwide. However, by the use of political pressure, complicit administrations and dependent science professionals, no credible assessment of environmental impact has yet been produced. Systematic study of such impact is 'impossible', precluded by 'commercial confidentiality'. Actual evidence of impact is ignored.
Policy is defended by a scienctific establishment charged with harmonising science with policy. The advocates of "Science as a means for wealth creation" hold the 'trustee' positions in the administration of science. Control of funding, reinforced by intimidation, is the means of maintaining control. Declared government policy is pro-development of the sea cage fish farming industry. The ethos of the executive is to avoid any activity that might disrupt policy.
Strategic 'stakeholder' consultation is restricted to representation deemed acceptable by the executive. Only those organisations and individuals adopting an 'inclusive' and 'enabling' approach to sea cage fish farming are invited. Anyone who does not sign up to the view that the existence of sea cage fish farming is a priori, an acceptable status quo, is excluded.
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EC Petition 518 2002 Submitted to the European Parliament / 4th April 2002
by Allan W. Berry, Chairman, Society for the Protection of Salmon and Sea Trout
Declared admissible and examination commenced, 30th Jan 2003.
Summary
Evidence exists to show that the UK government is guilty of fraud, by deceiving the EC regarding the proper assessment of certain projects receiving EC grant aid under the FIFG scheme, and by falsely claiming that proper environmental assessments of marine finfish aquaculture projects have been carried out by the Scottish Natural Heritage or any other government agency, designated as competent environmental assessors by the UK government. The evidence reveals no credible environmental assessments of any Scottish sea cage fish farm projects exist.
The petitioner requests the European Parliament to investigate the UK failure to ensure that sea cage fish farm projects were competently assessed. To investigate environmental damage and loss to others dependent on the quality of seawater, including the catastrophic damage to wild salmonid and other wild fish stocks by the operation of the sea cage fish farming industry. The regulatory failure to recognise and prevent such damage, and the repeated refusal in 2001 by the Scottish Executive to carry out the instructions of two Scottish Parliamentary Committees to set up an independent objective inquiry into these matters.
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Open discharge sea cage fish farming began in Scotland in the mid-1970s. Although some early efforts were made to assess the impact the industry would have on the environment, no credible scientifically-based assessment has ever been produced. This may be because those responsible lack an elementary knowledge of marine ecology or because proper assessment would have precluded the introduction of the industry, which has considerable political and commercial appeal.
When the UK Water Act 1989 confirmed that discharges from sea cage fish farms were required by law to be licensed, approximately 300 discharge consents were hurriedly issued to existing fish farms. No credible assessments or scientific rationale to justify these actions to legitimise the pollution has ever been produced.
The primary biological impact of open discharge sea cage fish farming is to increase the ratio of secondary biological production (heterotrophy) to primary production (autotrophy). This trophic change decreases oxygen production, increases oxygen consumption, increases CO2 production and decreases CO2 consumption. The occurrence of net heterotrophy in coastal waters is associated with many known water quality problems such as enhanced microbial biomass production, the promotion of harmful algae and biotoxin production. The impact on the receiving waters of the input and degradation over the years of many hundreds of thousands of tonnes of fixed carbon in the form of low-density lipid-rich organic slurry, high in phosphates, is virtually ignored in regulatory assessment.
Eutrophication, nutrification and chlorophyll enhancement, the impact criteria used by regulators worldwide, are poorly understood and are inappropriate measures of environmental damage caused by discharges from cage farming to sea water which may be naturally oligotrophic in summer.
The sea cage fish farm industry is now the largest licensed polluter in the areas in which it operates. In the year 2001, the Scottish industry is estimated to have discharged nearly 8000 tonnes of nitrogen as waste ammonia. Discharges are highest in summer when ambient N levels in the receiving waters are at their annual minima. The 2001 intense algal blooms in Shetland are on the balance of probabilities, promoted by the discharges from the nearly 60,000 tonnes of farmed fish produced there in that year...
...The industry in Scotland began using the biocide Tri-Butyl-Tin (TBT) in the early 1980's as an antifouling on cage nets. The discharge of such chemicals without a discharge consent is illegal under the 1974 Control of Pollution Act (COPA), however the regulators refused to prosecute the polluters. Shellfish growers and government shellfish scientists, aware that the French government had banned the use of the compound in shellfish growing waters in 1981, pleaded with government to protect shellfish from the use of this compound. Unfortunately, the government felt the needs of the salmon farm industry outweighed the risk to shellfish, claiming in a 1983 letter to the shellfish growers organisation that there was insufficient evidence of risk to shellfish. However, they proposed carrying out some laboratory tests on scallops under cultivation. Later field studies were bungled and their results kept from shellfish farmers until late 1986.
The salmon farming industry adopted TBT antifouling as standard practice, and although catastrophic damage to the shellfish industry was evident and reported from 1984, when both an oyster hatchery and a turbot hatchery collapsed because of TBT damage and another replacement hatchery and nursery was seriously damaged in 1985, 86 and 87. A ban on the use of TBT on fish cage nets was not announced until February 1987, to be effective from June that year. Despite the ban, damage to shellfish was still occurring near some salmon farms until 1991.
Concerns about the dangers of harmful algae and biotoxins were also expressed by the Scottish Shellfish Growers Association in 1983. The response from the government's Aberdeen Marine Laboratory, stated; "The laboratory has been monitoring the occurrence of blooms of Gonyaulax on the east coast of Scotland for the past 15 years, during which there has been 1 major and a few minor outbreaks. We have also monitored a few areas on the west coast for the past 2 years but so far have found no trace of it. To date we have had no reports of problems with this organism on the west coast, and had they arisen I'm sure we would have heard of them through organisations such as yours or individuals with interest in these matters."
In 1987, shellfish taken from the vicinity of the then largest salmon farm in Scotland, at the head of Loch Fyne, tested positive for Paralytic Shellfish Poisoning (PSP), and again in 1989. It was not until long after the major PSP outbreak in 1990 in west coast waters affected by discharges from salmon farms that the earlier events were revealed. The UK government claimed then, as they do to this day, that such events are natural, and that there is no link with pollution. No evidence has ever been produced to support the assertion.
Shellfish from waters affected by sea cage discharges have since been annually contaminated by biotoxins such as Paralytic Shellfish Toxin (PST), Amnesic Shellfish Toxin (AST), and Diarrhetic Shellfish Toxins (DST). Another long lasting toxin, Asaspiracid, is known to have been found in Scotland, but appears to have been wrongly classified as DST, which it is not.
The evidence will show that on the balance of probabilities shellfish harvesting closures and consequent loss to affected businesses resulting from such closures in Scottish waters are caused by pollution. In areas where sea cage fish farms are the major source of pollution, the preponderance of evidence indicates such discharges are the major causative factor promoting toxin production.
Evidence showing faecal coliform (E.Coli), bacterial contamination of waters affected by sea cage fish farm discharges has been sufficient to downgrade the classification of shellfish growing waters in the vicinity. The regulators know this, have evidence of it, and have deliberately ignored their duty to protect water quality.
There is no credible assessment of the impact of most chemicals used by the sea cage fish farm industry. Once again, this failure may be due to the widespread lack of knowledge and understanding of elementary marine ecology. On the other hand it may be the result of deliberate evasion of sound scientific method, which might produce evidence to preclude the use of the chemicals in question.
The UK government and the Scottish Executive have adopted a partisan and inappropriate approach to the whole matter of sea cage fish farming, deliberately suppressing evidence, which might lead to limits on production.
When the matter of government failure to ensure that proper environmental assessment was last raised with the EC in 1995-6 (see correspondence), then Permanent Under Secretary of State at the Scottish Office, Sir Russell Hillhouse, claimed in a letter of 16 July 1996 that the implementing regulation for the FIFG SPD does not insist that a designated environmental authority be involved in the examination and assessment of applications for FIFG aid. He also stated that the Scottish Office branch responsible was subject to inspections by officials from the Commission and also from the European Court of Audit "who would quickly draw attention to any breach of procedure or non-compliance with EC Regulations." The EC officials I spoke to at the time said no such inspections ever took place and that Sir Russell's interpretation of the implementing regulations was incorrect.
Will the EC please formally examine my concerns and report their opinion of the actions of the Scottish Office (now Executive), regarding the protection of the environment from inappropriate developments. Are they legitimate, and in the light of the evidence presented, what action does the EC propose to take to right the evident wrongs, ensure those who have suffered consequential damage and loss are compensated, and to properly protect the marine environment and the interests of others dependent on clean and healthy seas?
Annexed evidence to support the above is presented separately in mainly Word format on a Compact disc (CD) named AWB 4 EC, which accompanies (by surface mail) this petition.
Allan W. Berry, April 2002
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