Figure 1. Scottish open-net salmon farm.
Fidra’s position on the present planning process for aquaculture sites, and how it should be improved.
Scotland’s fourth National Planning Framework (NPF4) is the Scottish Government’s long-term plan to guide where development and infrastructure in Scotland takes place. It will play a critical role to guide all planning decisions in Scotland for years to come, and is under consultation until 31st March 2022[1]. Anyone can respond to the consultation and if communities are concerned about the scale of developments in their local area this is a rare opportunity to put views to the Scottish Government directly.
The NPF4 is especially relevant to communities that are local to salmon farms in Scotland, as planning permission is required from the relevant local authority for a new farm or any changes to an existing farm’s structure, such as increasing the size.
NPF4 and aquaculture
Policy 21 in the draft NPF4 covers aquaculture and is relevant to the Scottish salmon farming industry, which has to comply with planning regulations. The current application process for new salmon farms consists of two public consultations: one for a Scottish Environment Protection Agency (SEPA) Controlled Activities Regulations (CAR) Licence and a second for Local Authority planning permission. To give applications proper consideration, Local Authority planning teams should fully understand the impacts that the farming of Atlantic salmon in Scotland has on the marine and freshwater environment. The continued use of open-net pens can lead to significant impacts from the use of chemical treatments and the discharge of the waste products of the fish.
Increasing efficiency of the planning application process for aquaculture sites.
Both the SEPA CAR Licence and Local Authority planning permission consultations are important, but quite different, and it can be confusing for those that want to raise concerns which is the most appropriate if they are not fully informed on the application process. For example, SEPA’s CAR licence consultation covers the release of waste material and use of chemical treatments, but not impacts on wildlife or the coastal seascape.
Concerns not covered by SEPA’s CAR Licence consultation are expected to be considered through the planning permission application to the Local Authority. However, planning applications for salmon farms are within the remit of the same planning teams for terrestrial planning applications, which often do not have the expertise required to address concerns raised over impacts on the marine environment.
A single consultation process under a single body would be more efficient, allowing all concerns to be raised and considered together. This would also enable the provision of adequate resources and expertise to analyse every aspect of a new farm proposal.
Fidra recognises that following the report of the Salmon Interactions Working Group (SIWG), the Scottish Government has confirmed SEPA as the lead body responsible for managing the risk to wild salmonids from sea lice from marine finfish farms. SEPA is currently consulting on the framework to implement this[2].
A spatial management approach to identify suitability of sites for aquaculture.
Until a single consultation process exists, Local Authorities should have access to and be obliged to consider expert advice to assess the potential impacts of salmon farm developments. Core guidance parameters should be used, including:
- Open-net farms should be discouraged from operating in low-energy[3], inshore sites, due to the increased risk to benthic (seafloor) habitats from waste released from the farm.
- The salmon farming industry should be encouraged to move to offshore high-energy sites, where waste can be better assimilated by the environment (subject to appropriate risk assessments and controls to prevent the escape of farmed salmon).
- For sites that have been identified as unsuitable for open-net farms, permission could be given if an application is for the use of novel technology that minimises/removes environmental impacts, such as technology to capture waste from open-net pens, and closed or semi-closed systems that provide a barrier between farmed fish and the surrounding environment.
Benthic habitat and current data should be used to develop and apply a spatial management approach that identifies suitable and unsuitable sites for open-net farms. To ensure the industry operates as sustainably as possible, it is essential that the right technology is used in the right place. Regulations should therefore incentivise the adoption of novel techniques that can minimise, if not eliminate, the impacts on the marine environment.
A spatial management plan, which could include a constraints mapping exercise, that identifies where different pen designs (i.e. open, semi-closed and closed) are permitted would contribute towards this approach.
Keeping in line with conservation through National and Regional Marine Plans
In addition to developing a spatial plan for the salmon farming industry, it is vital that future development takes place in line with the conservation objectives of the area, and also with consideration of the growth of other marine industries, such as marine tourism, offshore renewables, and other forms of aquaculture. This can be delivered through a reform of the National Marine Plan and within the development of Regional Marine Plans.
It is essential that all aquaculture, including salmon farming, is integrated into Regional Marine Plans (RMPs) to ensure development is spatially managed and the application of an ecosystems approach – consideration of the environment, conservation objectives, and other marine users within a specified area. The integration of aquaculture into RMPs will enable the identification of areas deemed unsuitable for development, which should be designated aquaculture-free zones and apply to existing and future aquaculture sites. It will also allow for the cumulative impact of multiple farms within the region to be considered alongside conservation objectives and other marine users. This will be essential when assessing the impact maritime activities have on marine natural capital and ecosystem services.
Ensuring effective nature protection in Marine Protected Areas
Additionally, the conservation objectives of Marine Protected Areas (MPAs) and the distribution of priority marine features should be considered. Of cause for increasing concern is the continuation of proposals for open-net salmon farms within Scotland’s MPA network, in particular within MPAs that have designated features at risk from salmon farming (e.g. fragile and sensitive benthic habitats such as maerl, seagrass, and flame shell beds).
The MPA network was established to ‘meet national objectives and help deliver an ecologically coherent MPA network in the North East Atlantic, contributing to the protection and enhancement of [Scotland’s marine area]’ [4]. However salmon farms continue to operate within the MPA network and there are applications for more. Prohibiting new farm proposals within MPAs is an essential step towards conserving and improving the health of Scotland’s marine environment.
To ensure production of the Scottish aquaculture sector is truly balanced with environmental quality, a review of all salmon farms (old and new) should be performed to address existing environmental impacts and identify poorly located farms. Therefore where a poorly located farm has been identified, mitigation plans must be put in place to remove the impact, or the farm should be relocated to a suitable location or closed.
Have your say and respond to the consultation here before 31st March 2022.
[1] https://www.transformingplanning.scot/national-planning-framework/get-involved/consultation-process/
[2] https://consultation.sepa.org.uk/regulatory-services/protection-of-wild-salmon/
[3] Low-energy sites are areas where there is low water flow, resulting in less frequent and/or slower flushing than high-energy sites
[4] Marine (Scotland) Act 2010
Tags: aquaculture, Atlantic salmon, fish farm, NPF4, salmon farming, Scottish salmon, Scottish salmon farming