ORKNEY TROUT FISHING ASSOCIATION Environment Sub Comm AGM Report Feb. 2019

Fish Ladder at Mill of Ireland.
OTFA volunteers built up the stones displaced from the fish ladder back in October after a big spate.  We are currently monitoring the situation but need to look into a longer term solution as the current sticking plaster is temporary.  If external funding can’t be found this may be a project on which OTFA could spend some modest funds.

Scottish Parliament ECCLR Committee Salmon Farming Inquiry
Soon after the 2018 AGM the sub committee provided written evidence to the Scottish government’s Environment, Climate Change and Land Reform (ECCLR) Committee’s first part of a wider Scottish Government “inquiry” into the environmental impacts of salmon farming.  This was to be the first part of a two part inquiry by MSP’s.

In March the ECCLR committee published their report from their findings, following evidence received and heard from a wide variety of sources.  The report contained many critical observations on the current status of Scottish aquaculture regulation and it’s failings in Scotland.  This report was to inform the next part of the wider inquiry.

Government could not have received a clearer, more evident, cross party interpretation of the environmental impacts and wide spread concerns regarding Scottish salmon farming than if they had held a full blown legal inquiry.

Call for Moratorium
In late April, OTFA and 26 other organisations including the Atlantic Salmon Trust and the National Trust for Scotland supported a call from Salmon & Trout Conservation for “a moratorium on new open cage marine salmon farms or expansion of existing sites, until issues raised by the ECCLR committee in their report to the Rural Economy and Connectivity Committee (were) properly addressed.”  Sadly a fickle, Brexit saturated media failed to engage. 

Scottish Parliament REC Committee Salmon Farming Inquiry
We then compiled a further written response for the Rural Economy and Connectivity (REC) Committee’s Inquiry into Salmon Farming in Scotland, call for evidence. They in turn published their own report.

Despite the media managing to report this as if the report’s conclusion was that they ”…could see no reason why the Scottish Salmon Farming Industry couldn’t continue to expand”, the actual report quickly focused on the fact that this would be impossible unless aquaculture immediately addressed a whole range of serious environmental concerns.

Key conclusions and recommendations in the REC Committee’s report include:

So far the result of these inquiries seems to be the setting up of more “talking shops” which really makes us despondent. The issue was recently debated in the Scottish parliament and with disappointing predictability the usual apologists for Salmon Farming drowned out the relatively few MSP’s who’d actually taken the time to inform themselves.  This sadly suggests that the industry can guarantee protection from relevant politicians for evermore.  We need a sea change in political will to strive for a truly sustainable version of this industry…

SEPA Finfish Aquaculture Consultation
In a very timely manner SEPA recently launched a nationwide consultation following their own investigation and Fish Farm Survey Report which they described as an “Evaluation of a new seabed monitoring approach to investigate the impacts of marine cage fish farms”. 
SEPA have taken this consultation on the road and we attended the Kirkwall event in late 2018 from which we were able to make the following observations:

We got the impression that SEPA themselves had been shocked by the results of their own study, forcing them to initiate this consultation in the face of the usual sector protectionism associated with those in power.  At best, we could be looking at a watershed moment regarding the regulation of the industry.  We hope against hope that this is the dawn of a new phase in establishing a much more truly sustainable form of the industry. 

To this end we put together an extensive and detailed written response from OTFA in the week leading up to Christmas.  The remit was quite broad, despite having main focus on their intention to limit the future use of chemical treatments. We implored SEPA to take more responsibility for independent sea lice counts and control measures, as self-policing has got us into the mess we currently find ourselves in.  We also underlined the obfuscations currently used by industry to put to already overstretched and under pressure decision makers, few of whom possess a marine biology degree.  Following two highly critical reports from government sub committees, we hope SEPA will step up and accept responsibility for independent monitoring of sea lice.  This last point being a major recommendation in the final REC committee report. 

Salmon Farm local applications
We responded to new applications for Yinstay east and west SEPA consultations (this was prior to SEPA’s consultation on limiting future chemical use).

Hunda was refused but is currently under appeal. Since last AGM, Lober has been passed subject to conditions.

We had also been notified of a new EIA for an existing application for West of Glimps Holm.  This stems from an SNH objection regarding access route in the original.  Our original objection still stands but the application has had further objections from various entities and is going to committee soon.

One would hope that all these new reports, concerns and consultations emanating from the powers that be, will at last encourage OIC planners to look properly at the precautionary principle.  MSP’s highlighted in both committee reports that they were surprised that this principle hadn’t been used currently, given the sheer amount of growing legitimate concerns surrounding Salmon farming.

Bigswell Burn
In the days leading up to the festive period a number of the sub committee noticed canalisation of the burn above the brig, on the Finstown side of Stenness village. Other members had noticed canalisation below the brig.  SEPA informed us that it had already been drawn to their attention and that they are currently considering a course of action.

Orkney Biodiversity Action Plan
The Local Biodiversity Action Plan (LBAP) administered by the OIC, invited the OTFA to join and provide input on sea trout populations.  A species action plan is being drawn up for sea trout - one of only 2 aquatic species that will have such a plan. This plan appears to focus on interactions with aquaculture, so we will monitor it closely. 

On that vaguely optimistic note, I’d like to apologise for the lack of actual sub committee meetings this last year and to thank sub committee members for actions and efforts above and beyond the call of duty, often having to react to situations of short notice.  At least some of which, when they should have been cleaning the lum to enable safe entry for Santa. 

Have a good season and enjoy your fishing.

Colin Kirkpatrick,
Chair, OTFA Environment Sub Committee.