POTENTIAL AMENDMENT C2 (G) - EXTENSION OF THE CURRENT IPPC ACTIVITY DEFINITION AQUACULTURE

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1 POTENTIAL AMENDMENT C2 (G) - EXTENSION OF THE CURRENT IPPC ACTIVITY DEFINITION AQUACULTURE 1. Issue Aim of the study: The present work intends to identify the issues related to the inclusion of aquaculture e.g. sites with a production capacity of more than 1,000 tonnes of fish or shellfish per year (the production capacity threshold included in the European Pollutant release and Transfer Register) - in the list of activities in Annex I of the IPPC Directive, and analyse the related advantages and disadvantages. In practice, the work will also look at sites with other production capacities. The present work is based on background literature survey, meetings with DG FISH, a presentation and discussion with the working group on aquaculture of the DG FISH, and some responses to the questionnaire and interim report by the advisory group members. Background: Aquaculture is currently not covered under the IPPC Directive, and there have been calls for environmental regulation of the sector to be extended by including it in the IPPC Directive. Various definitions of "aquaculture" exist. In general, aquaculture means the rearing or cultivation of aquatic organisms using techniques designed to increase the production of the organisms in question beyond the natural capacity of the environment; the organisms remain the property of a natural or legal person throughout the rearing or culture stage, up to and including harvesting. Issue summary: Including aquaculture in the scope of IPPC could lead to environmental improvements but may also affect the competitiveness of the European aquaculture sector at the international level. Therefore, the cost-effectiveness of such a policy measure needs to be assessed. On the other hand, many of the environmental issues concerning aquaculture are already covered by several other EU-directives, national legislation, and codes of conduct (e.g. FAO, FEAP (Federation of the European Aquaculture Producers)). In addition, many of these issues may not be within the scope of the IPPC Directive, e.g. some problems related to ecological impacts and biodiversity. Aquaculture is also regulated in some countries at the national or regional level (e.g. Norway, Scotland). Following are some of the issues explored to define the scope of the proposed amendment and also to identify potential impacts related to this sector. Problems to explore: Are there specific reasons to include this sector into the scope of the IPPC- Directive? It has to be noted that here we are considering only the aquaculture rearing installations as the processing and treatment of aquaculture products already fall under IPPC directive if the production capacity exceeds 75 tonnes per day. If so, which part of the sector will be taken into account: both fish and shellfish or only one of those? How does other European regulation already affect this sector concerning environmental issues (e.g. Water Framework Directive)? Institute for European Environmental Policy together with BIO, and VITO 1

2 2. Current practice This section details the current status of the sector in Europe and the key aspects of the analysis viz. sector size, environmental impacts, relevant legislation, and available technologies. 2.1 Scope of the sector The aquaculture industry consists of fish and shellfish farming. Within fish farming a difference can be drawn between marine and freshwater farms. We can also classify aquaculture in three main categories on the basis of species: Finfish (salmon, trout, bass, turbot, carp, etc.), Molluscs (oysters, mussels, cockles), and Crustaceans (shrimp, prawn, langoustine, crayfish, lobster, crab, etc.), although crustacean aquaculture has been scarcely developed in Europe. There are different methods and systems of aquaculture production depending on the species and the characteristics of the production places ranging from freshwater areas (lakes, ponds, streams or rivers) to marine areas including estuaries and coastal lagoons. Aquaculture facilities include different types of ponds, tanks, cages, ropes, etc. 2.2 Size and structure of the sector At the European level The total economic value of the sector in Eu25 in 2004 was estimated at about 3.9 billion euros for a production of 1.4 M tonnes of finfish and shellfish (at least 1 2 M tonnes for Eu25 + Norway). Out of these 1.4 M tonnes, 625 kt are finfish (45%) and 760 kt are shellfish (55%). 2 The major shellfish species produced in Eu25 in 2004 are mussel and oyster (about 760 kt, including clams) while the important finfish species produced are salmon (about 170 kt), carps (212 kt), sea bream (62 kt), and sea bass (43 kt) (all marine) and trout (about 215 kt) (freshwater). (see graph below) During past decades, the production of aquaculture has been increasing in Europe with an average annual growth rate of 5 to 15% for many species including salmon, sea breams, see basses, catfish. The following chart illustrates some trends over the period The observed production increases were due to both an increase in the number of fish farms and an increased productivity. Marine fish farming shows the typical market price instability of young agro-food industries enjoying rapid growth. Some of the branches of the aquaculture sector have been exposed to falling market prices since the early 1990s. To illustrate the economic impacts, recent production data suggest that there is a fall in the salmon production in Scotland and Ireland whereas the Norwegian production is increasing which has 63% of the EU market share. The loss of EU competitiveness in the sector can also be argued from the fact that the export from Chile has increased from tonnes to tonnes during Shellfish production from Norway might be missing in this figure 2 Source: FAO Institute for European Environmental Policy together with BIO, and VITO 2

3 European aquaculture production per species (Eu25, 2004, in tonnes; except shellfish) Source: FAO (see Annex A) Total production (except shellfish) Eu25 in 2004 = tonnes Trout Salmon Carps Sea Breams Sea Basses Fishes nei Eels Tuna Turbot Other fish Catfish Cod Sturgeon tonnes (2004) Annual production of major commercial aquaculture species groups, Source: FAO FISHSTAT Plus ( tonnes common, silver and bighead carps salmon, seabass, seabream mussels, clams and oysters trout (rainbow and nei) According to FEAP, European fish farming (for food fish) is structured within 3 main categories: The large producing companies that are active on a national and international basis suppliers of Multiple Retail Stores, strong link to processed products. The medium-size companies often family-owned could be grouped under a cooperative structure or supply processors/stores directly. The small family companies that have limited production capacity and only sell locally. There are also some SMEs in niche markets such as organic salmon production Institute for European Environmental Policy together with BIO, and VITO 3

4 At national level Total annual production in tonnes (all species together) The aquaculture industry is not uniformly spread in Europe. Norway is the largest aquaculture producer in Europe (~635 kt in 2004), followed by Spain (~365 kt in 2004; ~26% of Eu25), France (~245 kt; ~18 of Eu25), UK (~205 kt; ~15% of Eu25), Italy (~115 kt; ~9% of Eu25), and Greece (~95 kt; ~7% of Eu25). Those 5 MS represent more than 75% of Eu25 total production. (data source: FAO, 2004) Aquaculture production per MS (Eu25, 2004, in tonnes) Source: FAO (see Annex A) Spain France United Kingdom Italy Greece Netherlands Ireland Germany Denmark Poland Czech Republic Finland Hungary Portugal Sweden Lithuania Cyprus Austria Slovenia Belgium Slovakia M alta Latvia Estonia Annual production per species Among the countries having such facilities the type of species handled is very different. FAO built a comprehensive database which contains detailed data. The exhaustive compilation of those data to sort them per species (total and per country) would Institute for European Environmental Policy together with BIO, and VITO 4

5 require an important amount of resources which is not compatible with this work. Only partial extraction was done, completed by available literature. Total production per country split between the main species (2004) Source: data extracted by BIO from FAO database Norway Spain France UK Italy Greece Salmon 89% Mussel 81% Oyster 47% Salmon 76% Mussel 37% Sea bream Trout 10% Trout 8% Mussel 30% Mussel 15% Trout 26% Mussel 30% Others 1% Others 11% Trout 15% Others 9% Sea bass + sea bream 38% 11% Sea bass 27% Other 8% Other 26% Other 5% Total 100% Total 100% Total 100% Total 100% Total 100% Total 100% The more recent production sites of sea bream and sea bass are located in the Mediterranean area (Greece +/- 60%, Italy +/- 20%). Trout production can be found in almost every MS including the new MS, while France, Spain, Italy, Denmark, and Germany 3 are its main producers. Except Norway, the UK is the biggest European producer of salmon (90% of Eu25). Amongst the main producers of oysters, mussels and clams are France and Spain (about 30% of Eu25 each). Deleted: Page Break Number of installations Preliminary data on the number of installations are presented in the Annex B. Two types of information are potentially useful for the analysis: number of installations per range of capacity and number of installations per species. Unfortunately, data are still too scanty to be able to draw transversal conclusions such as similarities between countries for instance. Number of installations Total Capacity >1000 t/yr Capacity t/yr Capacity t/yr Capacity < 100 t/yr Spain 780 No data received yet ~450 France small installations 3 8 ~440? ? Italy ~895 No data received yet United Kingdom 517 (1) Greece ~700 No data received yet Poland most of them? Finland ? (2) 500 Portugal Sweden 220 Data not available Cyprus Norway ~3 300 ~200 Data not available 3 There would be a very high number of trout farms in Germany (in excess of 10,000). Institute for European Environmental Policy together with BIO, and VITO 5

6 (1) the capacity is unknown for 46 installations that is why total number of installations is detailed here only for 471 (instead of 517) (2) information available: 12 installations have a capacity higher than 100 kt/yr (3) Norway does not monitor installations according production capacity Summary of key elements about the size and structure of the sector useful for this exercise The aquaculture sector of Eu25 represents about 3.9 billion euros of sales for a production of 1.4 M tonnes of finfish and shellfish (respectively 45% with 625 kt and 55% with 760 kt). The major species produced in Eu25 are: mussel / oyster / clams (~760 kt), trout (~215 kt), carps (~210 kt), salmon (~170 kt), sea bream (~60 kt), and sea bass (~45 kt). During past decades, the production of aquaculture has been increasing in Europe with an average annual growth rate of 5 to 15% for many species. However, more recently, data suggest that there is a loss of Eu25 competitiveness in the sector; for instance there is a fall in the salmon production in Scotland and Ireland (whereas the Norwegian production is increasing) and the export from Chile has been multiplied by 5 during 2005 (up to tonnes). The aquaculture industry is not uniformly spread in Europe. Five countries represent more than 75% of Eu25 production: Spain (~365 kt), France (~245 kt), UK (~205 kt), Italy (~115 kt), and Greece (~95 kt). The main producer in Europe is Norway (~635 kt). The type of species handled is very different from one country to another one. Salmon is mainly produced in the UK (and Norway) whereas trout production can be found in almost every MS including the new MS. And more than 60% of oysters, mussels and clams are produced in France and Spain. As far as the number of installations is concerned, it is very difficult at that stage to assess the total number at the European level and their split per range of capacity. Information coming from MSs is still too scanty. Based on MS declarations and publications, most MS would have between 100 and 800 installations (plus in France and Germany for instance thousands of small farms linked to ponds). The available data suggest that not many installations will qualify the threshold of 1000 t/year and most of them are in Norway (about 200) and in the UK (about 60 in Scotland). In other MS, only few installations seem to have a production capacity greater than 1000 t/year, for example only 3 installations in France. Most of the installations seem to produce less than 500 tonnes / year, with an important number lower than 100 tonnes / year. 2.3 Employment The aquaculture sector plays an important socio-economic role in some areas. Aquaculture ensures financial income to many people and most aquaculture activities are taking place in rural areas, where job opportunities are increasingly limited. This means that aquaculture can provide an important part of the job opportunities in these areas; this has been highly important for example in the coastal areas of Greece, Scotland, Ireland and Spain. French oyster production, one of the most prized seafood products in Europe, is a prime example of this. Aquaculture employment must also be considered in terms of the jobs in associated sectors (e.g. fish feed, engineering, equipment manufacture, fish food processing). Institute for European Environmental Policy together with BIO, and VITO 6

7 Manpower in aquaculture represents a small part of the total fisheries employees. However, this rapidly growing sector has an employment potential and this socioeconomic aspect is of great importance while analysing the impact of any changes in policy measures. Most of the information in this section is derived from a document 4 recently published by the European Commission. European level European aquaculture sector employs about people in the EU This equates to about 15% of the total European fisheries sector (including fisheries, aquaculture and processing). The following table presents the employment according to production regions. In the North Sea region, Denmark and the UK are most important in terms of output and employment. In the Baltic Sea region, 55% of employed is in Poland alone and 20% in the three Baltic republics. Of the total employment along the Atlantic coast, 50% is in France. In Norway, the total number of employees in the aquaculture industry in 2002 was and in 2003 the number was Production region Number of employed ( ) North Sea 1,600 Baltic Sea 3,700 7 Atlantic 40,000 Mediterranean 12,000 Central Europe 7,400 The heterogeneous growth of this sector can be demonstrated by the fact that the employment in certain MS has increased beyond 300% (Spain) while in others a decline of more than 70% (Belgium) can be observed during the period For further details please refer to Annex A. MS level As illustrated in the figure below, approximately half of the employment in the European aquaculture sector was in France or Spain in Productivity varies widely between EU Member States with an average production value per employee of about Euros for EU-25. The large differences in productivity reflect mainly the differences in capital input and manpower required for farming of different species. For example, high productivity in the Netherlands in the following table reflects the high labour productivity of shellfish farming and the fact that in the shellfish processing sector, employment onshore has not been included. 4 Salz, P. et al (2006) Employment in the fisheries sector: current situation. 5 This is sum of full time and part time, not full time equivalents. 6 Source: 7 According to the Scottish Salmon Producers Organisation, this figure would only cover the Scottish salmon farming industry; there would be a significant additional number of people employed in the trout, marine finfish and shellfish sectors, Institute for European Environmental Policy together with BIO, and VITO 7

8 Employment in EU aquaculture sector ( ) Production value per employee ( ) Luxembourg Belgium Estonia Malta Netherlands Cyprus Sweden Slovakia Slovenia Lithuania Latvia Austria Finland Denmark Hungary Ireland Poland Czech Republic Germany Italy United Kingdom Greece Portugal Spain France Country Euro Country Euro EU Austria Italy Belgium Latvia Cyprus Lithuania Czech Rep Malta Denmark Netherlands Estonia Poland Finland Portugal France Slovakia Germany Slovenia Greece Spain Hungary Sweden Ireland United Kingdom Institute for European Environmental Policy together with BIO, and VITO 8

9 As shown below, currently Portugal is the country with the largest per capita employment in aquaculture approximately four times compared to the European average of 142 employees per million inhabitants. 8 The potential for full-time employment is an important component of the profile of aquaculture sector. Nonetheless, for many people aquaculture is also a part time job that provides a supplement to their main employment e.g. in traditional fisheries. It has therefore become an important factor in improving standards of living and enabling people to stay in their home area, even though the numbers of employees in traditional fisheries are declining. Employment in aquaculture per million inhabitants ( ) Luxembourg Belgium Netherlands Sweden Germany Slovakia Poland Italy United Kingdom Austria Estonia Lithuania Finland Slovenia EU 25 Average Hungary Denmark Cyprus Latvia Czech Republic Malta Spain France Greece Ireland Portugal 8 These figures were calculated relative to the total population rather than the active population. Total population figures were taken from EuroStat and refer to 1 January Institute for European Environmental Policy together with BIO, and VITO 9

10 Summary of key elements about employment in the sector useful for this exercise European aquaculture and its related activities employ about 65,000 people throughout the EU-25. This equates to about 15% of the total European fisheries sector (including fisheries, aquaculture and fish processing). Approximately half of this manpower is in France or Spain. The average number employed in aquaculture per million inhabitants is about 140. Aquaculture today is an important and growing source of employment in certain areas (e.g. rural) and countries (in particular Greece, Scotland, Ireland, Spain, and France). 2.4 Environmental Impacts Many of the traditionally conceived environmental impacts of aquaculture linked to the discharges in the water bodies are difficult to generalise as they are species and media (freshwater/marine water) dependant and tend to be more localised, affecting coastal regions and inland water bodies in proximity to the culture sites. Some of these impacts and their specificities with respect to the species or geographic location are presented here (detailed analysis is provided in Annexes C and D). To quantify the environmental impacts, a life cycle analysis (LCA) based approach is developed according to ISO series related to LCA. All the assumptions and calculations are described in a transparent manner in Annex C and only the key results are summarised below. The qualitative environmental impacts of the aquaculture, mostly derived from secondary sources, are presented in Annex D. Eutrophication Some aquaculture systems contribute to nutrient loading through discharges of fish wastes and uneaten feed. In general, N and P release may lead to eutrophication, ammonia formation (which is directly toxic to aquatic life), and formed solids (which can influence turbidity and sunlight penetration leading to a decrease in photosynthetic activity and oxygen production). Waste discharge from aquaculture facilities might exacerbate algal blooms (red tides) through nutrient enrichment. As detailed in Annex C, eutrophication due to Eu25 aquaculture is assessed at about t PO4 eq per year. Institute for European Environmental Policy together with BIO, and VITO 10

11 As illustrated in the figure below, eutrophication is related mostly during the fish farming stage of the aquaculture production. Eutrophication (10-3 t PO4 eq/ton of trout produced) 10-3 t PO4 eq Feed raw material Feed production Hatchery Fish farm Compared to total eutrophication impact in EU25, aquaculture represents only a small fraction (about 1%) as shown in the table below: Impact of Quantity due to For Eu25 aquaculture % Aquaculture Unit EU25 activity (2004) (shellfish excluded) for 2004 for / EU25 activity Eutrophication t PO4 eq ,97% However, when we compare the contribution of other sectors to eutrophication e.g. public transport, paper products 6, pig farming 10 etc., the contribution of the aquaculture cannot be considered negligible. For Eu25 Contribution of each sector to total eutrophication due to Europe yearly activity Paper product (packaging excepted) Note: Please refer to Annex C for details Fruits, vegetables, cereals and sugar Fish aquaculture Pig Production Public transport 2.2 % 72.3 % 0.97% 18.8% <0.1% 9 Source: Study on External Environmental Effects Related to the Life Cycle of Products and Services BIO Intelligence Service for DG ENV, 2003 (performed in the framework of the Integrated Product Policy of the European Union) Same methodology was used for the calculation for the pig farming contribution to eutrophication. For details, see Annex C. Institute for European Environmental Policy together with BIO, and VITO 11

12 A local issue Eutrophication is a local issues and it can contribute from 0.2% to 27% to eutrophication at a local level (see table Annex C). Despite the difficulties to quantify the phenomenon, a link between aquaculture nutrient discharge and growth of selected toxic phytoplankton species has been established in Scotland. It should be noted, however, that the report in question concluded that the impact of these nutrient discharges generally has a small impact and is not a concern, other than in a few of the waterbodies with the most intensive fish production. Energy consumption Determinants in the amount of primary energy used in aquaculture systems include the species under cultivation, the culture system used and subtle differences in production techniques (e.g. changes in feed formulation). In some aquaculture systems, the energy embodied in capital infrastructure represents the majority of total inputs. In contrast, feeds and/or fertilizers typically represent the greatest proportion of energy inputs to most aquaculture systems. The most extreme examples of this occur in net-pen culture systems used to raise salmonids and other high value finfish. In these systems, between 80 and 90% of the life cycle energy inputs up to the point of slaughter are associated with the provision of feed. Trout farming is also a good example as shown in the figure below, where primary energy consumption is mostly due to the feed raw material production. These feed raw materials include soya production, fish meal and oil production as well as captured fish Primary Energy Consumption (MJ/ton of Trout produced) MJ primary Feed Raw material Feed production Hatchery Fish Farm Comparing fish farming activity to other production indicates that the primary energy consumption of aquaculture (per ton produced) is similar to the energy consumption of the pig farming, PVC manufacturing or kraft paper manufacturing. MJ/kg produced Primary energy consumption Trout Salmon Pig Primary steel Zinc PVC moulded by injection Kraft paper Institute for European Environmental Policy together with BIO, and VITO 12

13 Source: Annex C for trout, salmon and pigs; for the other products: Actualisation et enrichissement des données énergétiques sur les matériaux BIO Intelligence Service for the French Environment Agency ADEME 2003 NB: it should be noted that the trout and salmon energy consumption might be closer than appears here (even similar according to Scottish Salmon Producers Organisation). The gap between the 2 values here can be explained by the fact that primary data used do not cover exactly the same system: cooling, slaughtering and processing are included in the case of salmon but not for trout (see Annex C). Scale of magnitude The environmental impact indicators quantified here above use different measurement units (reminded in 1 st column in the table below). To illustrate their relative scale of magnitude, a common unit is used: European per capita contribution to a specific impact. The idea is, for each impact, to assess the number of European citizens who generate an impact equivalent to aquaculture (3 rd column). For that, the impacts generated by one European citizen are used as reference data (2 nd column). This method allows attributing relative importance to the different environmental impact indicators quantified. Such as comparison (see table below) clearly shows that the major environmental impact from aquaculture is eutrophication. Actually, eutrophication caused by finfish aquaculture corresponds to 4.4 million of European citizen equivalent contribution to eutrophication, whereas none of the other impacts exceeds few thousands. Therefore, eutrophication is the most important aspect to be considered while analysing the repercussion of aquaculture activities on the environment. For Eu25 (2004) Unit Impact of aquaculture (shellfish excluded) Average impacts of one European citizen equivalent 11 Number of European citizen equivalents a b a/b Photochemical oxidation t C2H4 eq , Acidification t SO2 eq , Eutrophication t PO4 eq , Primary energy MJ primary Global warming (GWP100) Mt CO2 eq 445 0, Note: See Annex C for detailed calculation for the numbers presented in the table. External costs Externalities (or external costs) are the costs imposed on society and the environment that are not accounted for by the producers and consumers, i.e. which are not included in market prices. They include damage to the natural and built environment, such as effects of air pollution on health, buildings, crops, forests and global warming; occupational disease and accidents; and reduced amenity from visual intrusion of 11 European equivalent is the total Eu25 activity for one year (as assessed by BIO IS in the IPP Study for DG ENV - divided by the Eu25 population ( inhabitants in 2004 Source: Eurostat) Institute for European Environmental Policy together with BIO, and VITO 13

14 plant or emissions of noise. It gives a picture of the approximate financial implications of environmental impacts linked to product or process life cycles. The external cost associated to the environmental impacts of Eu25 aquaculture 12 would reach 60 to 80 M Euros per year, i.e. about 2% of the annual value of the sector (3.9 billions Euros). To further illustrate the magnitude of the external costs of aquaculture, the following figures can be useful: the external cost linked to the environmental impacts of end-of-life vehicles treatment in Eu25 was assessed between M Euros for Eu25; and the external cost linked to the environmental impacts of the entire European economical activity was assessed between 100 to 440 billions Euros (aquaculture externalities would then represent % of total Eu economy externalities). These calculations should be seen as an indication in order to understand the relative magnitude of the problem and the absolute values may evolve with time as the data used in such calculations is being updated regularly on the basis of research. One such example is cost of human life, which was assumed about 150,000 Euros during the IPP study 13 compared to few millions of Euros in recent CAFÉ estimates. Calculations and limitations are detailed in Annex C. Other qualitative environmental impacts Alien species and escapees Alien species are species that evolve in an ecosystem other than the one which it originally came from. They enter the new ecosystem either intentionally or accidentally transported or released by man or by extending their geographical range following natural or man-made changes in the environment. Alien species introduction has significant and devastating ecological and economical impact on the marine ecosystem. For example, in Black Sea, out of 41 introduced species, 34% have been imported for aquaculture purposes and 66% have entered the Black Sea in ballast water or as fouling organisms on ship hulls and the introduction of Mnemiopsis leidyi combined with high fishing pressure was the main cause of the collapse of the anchovy fisheries in the Black Sea 14. Further, the impacts of non-native species can also result in habitat alteration (destruction of exotic and native vegetation), trophic alteration (complex and unpredictable changes in community trophic structure), spatial alteration (competition between non-native and native species), gene pool deterioration (through 12 The externalities assessed cover the impacts on the environment (ecosystems, material and building, forests and crops) and on human health (morbidity due to both chronic and acute diseases, mortality) generated by: air emissions (global warming, air acidification, photochemical oxidation) and water emissions (eutrophicant emissions). 13 EC (2003) Study on External Environmental Effects Related to the Life Cycle of Products and Services BIO Intelligence Service for DG ENV, Sustainable EU fisheries: Facing the Environmental Challenges European Parliament, Brussels Conference Report 8-9 November 2004 Institute for European Environmental Policy together with BIO, and VITO 14

15 hybridization when non-native species are introduced to a habitat), and introduction of diseases. Additionally, escapees escape from aquaculture facilities may harm wild fish populations through competition and interbreeding, or by spreading diseases and parasites. For example, escaped farmed Atlantic salmon (Salmo salar) may threaten endangered wild Atlantic salmon. NASCO is working on guidelines on this topic. Interbreeding occur when hatchery-reared fish are released into the wild to enhance the fishery, as is the case with salmon in the Baltic Sea, or when fish escape into the wild. Some rivers in Norway and Ireland have been found to contain 90% and 50% farm escapees respectively. Fish-farm parasites A new Canadian study 15 provides new insights about the possible impacts of aquaculture on wildlife. The research concludes that sea lice from salmon farms can have severe impacts on wild salmon. The results show that up to 95% of young wild salmon died in the studied area due to farm-origin lice infection. This effect may not be limited to salmon but may extend to other species farmed around the world. Chemicals and antibiotic used A variety of approved chemicals are used in aquaculture(see Annex D3), including antibiotics and pesticides, such as cadmium, lead, copper, zinc et mercury (in cages structure), chlorine, hypochlorite (disinfectant), oxitetracyclin (antibiotic for sea lice treatment). Chemical use in aquaculture is low compared to use in terrestrial agriculture, but antibiotic resistance and harm to non-target species are concerns. The EU Veterinary Medicines Directive requires veterinary personnel to prescribe medicines with a marketing authorisation for food producing fish to safeguard fish health. Furthermore, an environmental quality standard (EQS) is required for each medicine; otherwise it cannot be discharged into the aquatic environment. However, the EQS legislation has not been harmonised across Europe, thus different Member States apply different figures. The quantity of antibiotics released into the water is small (generally about 1g per ton of fish produced 16 ), however, they may have a long-term ecotoxicological impact on marine ecosystem (toxicity of marine biota, uptake of the antibiotic by oysters) as well as on humans (possible transfers of resistant pathogens from fish farming to humans) 17. Pressures on wild fish stocks 15 M. Krkosek et al. (2006) «Epizootics of wild fish induced by farm fish» - A summary published in DG ENV Science for Environment Policy News Alert is avaibable at 16 In the past, it was up to 100 g in case of salmon: according to the Scottish Salmon Producers Organisation, due to the introduction of vaccines for the most important pathogen, antibiotic use has declined in salmon production to the point where the numbers of treatments are insignificant compared to historic data and although values of up to 100g per tonne production may be seen, average values across the salmon farming industry in Norway and Scotland will tend to be very much lower. 17 Review and Synthesis of the Environmental Impacts of Aquaculture Scottish Executive Central Research Unit 2002 Institute for European Environmental Policy together with BIO, and VITO 15

16 Aquaculture puts pressure on wild stocks, either as a source of farm stock or through the demand for feed. For example, farming of trout would require about 3.2 tons of wild fish per ton produced 18. More recent analysis suggest figures lower than 2 tons 19. Farming of eel and bluefin tuna currently depend on the capture of wild fish because controlled breeding is not yet possible. Wild European eel stocks are considered to be below safe biological limits, with elver (juvenile eel) fishing one of several pressures. The expansion of tuna ranching in the Mediterranean is also increasing the pressure on the bluefin tuna stock, with growing concern over its condition and management. The demand for juveniles of wild origin generated by the development of eel and blue fin tuna farming has the potential to harm the status of these already highly exploited stocks. Significant R&D efforts on the production of juveniles for both species seem to be going on. Health and sanitation impacts Of the twenty or so species of phytoplankton in the Northeast Atlantic that produce toxins, some affect fish directly and some may poison people when infected organisms are consumed. This is a particular problem in molluscs, which are filter feeders and accumulate the toxins contained in the algae. The persistent environmental contaminants 20 present in fin fish feed leads to higher body contaminant levels of, for example, fire retardants and PCBs in farmed fish. Bi-direction impacts While analysing the environmental impacts, an aspect specific to aquaculture is that some of the impacts are bi-directional; for example, impact of the water pollution caused by aquaculture will, in turn, influence the production capacity and the quality of product, because they depend on the quality of the very same water. The water quality parameters such as: temperature, ph, alkalinity, oxygen, salinity (for marine aquaculture), depth, and flow rate, all contribute to the well-being of fish. While the biological characteristics of fish vary in their adaptability to aquatics conditions, most species of fish do not tolerate pollution in their environment, and water quality deterioration is to be avoided as far as possible, as it will adversely affect the health and welfare of the fish. This is a further motivation for the producers to keep the water pollution impacts to a minimum for their own benefits. 18 Fish farming and the environment Result of inventory analysis Finnish Environment Institute According to the Scottish Salmon Producers Organisation, the quantity of wild fish used in the production of a specific quantity of farmed fish has been declining steadily over the last 15 years. The UK fish feed industry are currently quoting a figure of 2 kg wild fish to produce 1 kg of farmed Atlantic salmon, due to advances in feed formulation largely driven through R&D sponsored internally by the feed companies. Given the lower nutritional requirements for trout, and consequently the potential for inclusion of a greater proportion of vegetable protein and oil, the figure for trout will now be much lower than 2 kg. 20 which are present in the marine environment; not the result of any procedure in the manufacture of fish feed Institute for European Environmental Policy together with BIO, and VITO 16

17 Summary of key elements about environmental impacts useful for this exercise Although few quantitative data are available, it is common acceptance amongst experts that the environmental impacts are species specific and majority of the potential impacts are related to fin fish rather than shellfish aquaculture (shellfish are more consumers of organic matter than producers). The main environmental impacts relate to water media and biodiversity issues. They include: eutrophication of water (the contribution of Eu25 aquaculture to eutrophication potential can be assessed to ~31 kt PO 4 eq. per year i.e. about 1% of total potential eutrophication generated by Eu25 annual economy, and 5% of pig farming 21 for instance; it can contribute from 0.2% to 27% to eutrophication at a local level); biodiversity issues (due to the presence of alien species and the escape of fish); eco-toxicological impacts on eco-systems (due to chemicals and antibiotics use); and pressures on wild fish stocks (e.g. the demand for feed). The external cost associated to the environmental impacts of Eu25 aquaculture is estimated representing less than 0.1% of total Eu economy externalites and a few percents of the annual value of the sector. 2.5 Techniques for prevention or reduction of environmental impacts Example of techniques and abatement rates The BAT approach to minimise such impacts is not yet adopted at the European level, though the Nordic countries have already taken step in this direction. An overview of attainable levels of nitrogen and phosphorus waste, water and power consumption using different technical options is presented in the table below and detailed description in Annex G. The techniques are focussing on three key areas: reduction of water and power consumption, N and P emissions, and consumption of pharmaceuticals and other chemicals. However, not much information is available on how frequently these techniques are used in practice. Type of System Techniques (non exhaustive list) 1. Land-based aquaculture Techniques for reducing water and power consumption, and N&P emissions a. Hatcheries 22 Supplemental oxygen and a tank-based CO2 degasser Recirculation system with particle- and biofiltration, and oxygenation b. On-growing farm for Recirculation system with particle- and salmonids biofiltration, denitrification filter and oxygenation Recirculation system with particle- and 21 Pig farming contributes to about 18% of total potential eutrophication generated by Eu25 annual economy. 22 Hatcheries may not fall under the scope of the IPPC as the production quantities are limited and they serve as input to the fish farms. However, good practice will reduce the impacts even during this stage. Institute for European Environmental Policy together with BIO, and VITO 17

18 biofiltration, denitrification filter and oxygenation plus sedimentation of particles in the outlet water Micro-strainer and a biofiltration unit combined with simple recirculation technology + aeration of the water using atmospheric air instead of using pumping Recirculation system with particle filter, biofilter, denitrification filter, chemical precipitation of phosphorus and supplement of additional oxygen 2. Sea-based aquaculture Techniques for reducing nitrogenous and phosphorous waste from feed and faeces Techniques for reducing use of pharmaceuticals and chemicals Techniques for reducing the probability of escape of fish from fish farms Feeding systems that detect feed spills and fish activity Technology collecting feed spill and dead fish at the bottom of a net-cage Locating a culture facility strategically with respect to hydrographic conditions Laying the location fallow for a period Use of closed net-cages in the sea Controlling the fish density Use of wrasse to fight salmonid lice Sufficient drying of net-cages Individual vaccination Strategic health management plans, veterinary health plans, bio-security management plans Fitting the type of facility to the specific characteristics of the chosen locality (wind, waves etc.) or using submersible cages at locations experiencing rough conditions Using these better techniques can reduce the important impacts significantly by reducing water consumption by 50-90% and N and P loading by 40-60% 23. Cost-efficiency data It is important to assess the cost-effectiveness of the technologies applicable for the aquaculture sector. This means that the costs of regulation to industry (of compliance) and the regulator (administration and enforcement) need to be balanced against the benefits in terms of emission reductions. In the framework of this preliminary assessment with limited resources, it was not possible to perform an extensive costefficiency analysis. Only some indications are given below, extracted from available 23 Nordic Council (2005) Beste tilgjengelige teknikker for fiskeoppdrett i Norden Institute for European Environmental Policy together with BIO, and VITO 18

19 literature. In the absence of data cost found in Europe, useful information was extracted from available literature published by the US EPA 24. Three sub-categories of facilities depending on the way water flows are managed are distinguished in the EPA study: flow-through, recirculation and net pens. For each of them, three treatment options are analysed, corresponding to different combinations of existing old or relatively new treatment practices, as summarised in the table below. Regulatory options analysed* * BMP = Best Management Practices; in option 1, BMP plan refers to solids control. In the EPA analysis, cost compliance and cost-efficiency were assessed for two types of pollutants: biological oxygen demand (BOD) and total suspended solids (TSS) in one hand and total nitrogen (TN) and total phosphorus (TP) on the other end. The cost-efficiency data obtained are summarised in the table below and converted in Euros. Removal of pollutants amounts to Euros/kg of BOD removed depending on the technology and size of the installations (with an average at 0.35 Euros/kg) and at Euros/kg of TN+TP (average at 11.4 Euros/kg). Cost per unit (pounds or mg) removed Removal of BOD or TSS Removal of TN Removal of TP Removal of TN + TP Subcategory $/lb ** Euros/kg *** $/lb ** Euros/kg *** $/lb ** Euros/kg *** $/lb ** Euros/kg *** Flow-through 0,09-0,39 * 0,17-0,76 19,98 38,89 63,45 123,52 15,19 29,57 Recirculating 0,07 0,14 1,80 3,50 6,12 11,91 1,39 2,71 Net pens 0,04 0,08 0,46 0,90 2,77 5,39 0,40 0,78 Industry total 0,18 0,35 7,23 14,07 30,44 59,26 5,84 11,37 Source: (1) (2) (1) (2) (1) (2) (1) (2) (1) EPA; (2): BIO's calculation * according to the size; higher cost for lower size ** $ 2000 *** 1 lb = kg; assumption: 1 $ 2000 = Euros 2006 (the investment of $1 in 1/1/00 is grown at the inflation rate until 15/12/06; the exchange rate as of 15/12/06 is then applied to the 15/12/06 USD value) 24 Economic and Environmental Impact Analysis of the Proposed Effluent Limitation Guidelines and Standards for the Concentrated Aquatic Animal Production Industry US EPA - September Institute for European Environmental Policy together with BIO, and VITO 19

20 The conclusions drawn by the EPA for TN and TP are as follows: As a benchmark for comparison, EPA has estimated that the average costeffectiveness of nutrient removal by POTWs [Publicly Owned Treatment Works] with biological nutrient removal is $4/lb for TN and $10/lb for TP. On the basis of nutrient removal, the proposed options are within the $4/lb benchmark for recirculating and net pen systems, but not for flow-through systems suggesting that the requirements are not very cost-effective for removing nutrients at flow-through systems. Integrated systems The development of combined finfish-shellfish systems (which perhaps will be the future of aquaculture) such as salmons with mussels, sea basses with oysters may also help in reducing the environmental impacts as the finfish will generate the nutrients loading while the shellfish will consume it. But it should be noted that there may be detrimental effects such as shellfish having the potential to act as a reservoir for fish pathogens. No data was identified to quantify the potential benefits / detrimental effects of such practices. Towards BAT? The aquaculture sector is evolving very fast and the systems of production have not stabilised yet. Further, these methods are species and sometimes depend on the location of the installation rather than the method itself. Perhaps this may lead to the difficulty in defining a realistic BAT which could be generalised over Europe. In such a situation, an ideal approach for the development of BAT for the aquaculture sector has to be multi-tiered, for example, techniques used for installations that can be classified according to the species used and their characteristics to take into account the species specific impacts. the system of production so as to identify the associated risks, and their sensitiveness with respect to the surrounding ecosystem Summary of key elements about the techniques for prevention or reduction of environmental impacts useful for this exercise Some MS have started thinking an approach similar to BAT for aquaculture and this will significantly reduce the key environmental impacts e.g. water consumption, eutrophication, chemicals release in the water bodies, etc (scale of magnitude of potential benefits is 50-90% reduction of water consumption and 40-60% reduction of N and P loading into water). They seem to be quite developed in the Nordic countries at least; however, not much information is available on how well these techniques are used in practice in other MS. Further, these techniques are in continuous evolution and therefore relate very well to the concept of BAT. However, the factors affecting the choice of a technology depend on several sitespecific parameters and therefore a generalised BAT may be difficult to define for the aquaculture sector. An approach for the development of BAT for the aquaculture sector could be multi-tiered, techniques being classified according to some key parameters (sensitiveness with respect to the species harvested, system of production, and surrounding ecosystem). However, such an approach may lead to complexities in its application in practice. Formatted: Border: Right: (Single solid line, Auto, 3 pt Line width, From text: 29 pt Border spacing: ) Institute for European Environmental Policy together with BIO, and VITO 20

21 2.6 Current Legislation Many of the environmental issues concerning aquaculture are already covered by EU legislation, national legislations, and codes of conduct (e.g. FAO, FEAP). Also, many of these issues may not be within the scope of the IPPC-directive, e.g. problems related to ecological impacts and the biodiversity as they are dealt by the Habitat Directive, for example. However, the relevance of such impacts for the IPPC will depend on the cause of the impact. Any impact of the installation related activity (for example, pollutant discharges) on the environment (including ecology or biodiversity) is certainly of relevance to IPPC, but any indirect ecological impacts because of species movement and migration may not be of a direct relevance to the IPPC directive, for example, impacts of catching juveniles. A discussion on relevant EU legislation and voluntary agreements for the aquaculture sector is provided in Annex G. The national legislations for some of the MS are provided in Annex H. The legal inheritance In many EU countries, the legal framework established to control aquaculture activities and set the institutional framework for the direction and the management of aquaculture activities, derives from a diverse international and national legislative basis. This is partly because many of the laws and conventions from which specific aquaculture measures were ultimately framed had their origin in legislation drafted for other purposes: environmental / pollution laws, water quality regulations, capture fisheries legislation, nature conservancy directives, health and disease laws, trade laws, tax laws, etc. Such diversity also stems from the nature of the activity itself, which may depend on the legal status of the waters used, on the legal status and nature of public domain land used. The legal and institutional inheritance (see table below) has been adopted and enforced by means of different regulatory frameworks in some MS, either through primary or secondary legislation, parliamentary resolution (as in Norway), governmental policy decisions as expressed in national aquaculture plans (as in Greece), codes of conduct/practice (as in the Netherlands), departmental/local authority sanctioning or approval processes (as in France and Spain). Existing provisions concern the following aspects: they lay down planning requirements (sometimes in great detail as in Italy); define lead agency responsibilities (as in Scotland); they stipulate permit/authorisation/licence procedures and conditions (as in many MS); they specify permit/licence application, evaluation, granting and review procedures (as in Sweden); they outline the degree and extent of the rights and the obligations incurred. Legal and institutional heritance applicable to aquaculture sector existing laws, institutional arrangements, regulations and procedures governing aquaculture laws and administrative arrangements governing other sectors with an impact on aquaculture (navigation, recreation, industrial development, tourism, archaeology) government activities that affect aquaculture indirectly (taxation, health and safety, Institute for European Environmental Policy together with BIO, and VITO 21

22 environmental protection natural resources conservation, animal health and disease laws) relevant commitments under international law, conventions, EU Directives any guidelines, limitations, practices contained in national economic and aquaculture policy and plans recommendations from producer associations, interested bodies and non statutory codes of conduct/practice laws, institutional arrangements, regulations and procedures governing the management and use of aquaculture resources and planning in the coastal zone Permit/licensing procedures The decision to authorise an operation or award a permit/licence almost always has to go through a pre-defined application procedure, which elicits information from the applicant, requiring details of plans and planning in respect of the technical, biological, geographical, economic and administrative aspects of the operation and making projections concerning future impacts and proposed solutions (see table below which gives a full range). Information requirements for applying an operational permit/licence biological and technical resources/species used, production, rearing, stock health aspects and disease management systems, impact management systems(regarding the environment and wild stocks) geographic aspects administrative and economic aspects location and design of facilities, proximity to sensitive habitats and wild stocks, locations in relation to other facilities resourcing, objectives, targets (including production), interest group involvement, impact assessments, performance measures, operational measures, monitoring, review and reporting procedures The most widely used technique for exercising legal and administrative control over aquaculture operations is through an authorisation system, which may utilise any one or any combination of types of authorisation, licence, permit, lease or concession. The rights conveyed are determined by an interaction of the concepts behind and the construction of the legal document and the information requirements are not standard and vary considerably between countries. In spite of general compliance with EU Directives, the evaluation and consultation procedures which the application must undergo are also dissimilar. Nevertheless, there are common evaluation criteria which are applied in the awarding of operational permits/licences (see table below). Usually, strict conditions, concerning the species, stock, size of the fish, locations, times, durations and methods to be employed, as well as the monitoring, notification and reporting procedures to be adopted are attached to the permits or licenses Institute for European Environmental Policy together with BIO, and VITO 22

23 awarded. Along with the time span of the licence, such conditions define the scope of the operation, and are used as a regulatory tool to control the operation and ensure that it conforms to national and international statutory obligations. Common evaluation criteria for an operational permit/licence 1. Technical feasibility 2. Operational and financial competency of the operator 3. Economic and biological integrity of the project: no adverse effect on the genetic characteristics and stock size no introduction of a disease or disease agent into the environment no adverse impact on endangered species and their habitats the operation is in the best public interest, with due consideration to the costs and the benefits to the producers and the community at large the integrity of the operation in relation to management plans and goals the possession of all supplementary permits and licences Legislation addressing specific aspects of aquaculture As already mentioned, environmental issues related to aquaculture are species dependent: for example, salmon farms have a higher environmental pressure than carp farms. The relevant legislation addressing specific issues and whether these issues are relevant to IPPC are listed following. Eutrophication Water framework Directive, National legislations, etc. This issue could fall under the scope of the IPPC-directive as it directly relates to the pollution generated by the installation. Diseases, parasites Treatment of disease, Transport of animals (also effects on production sites). This issue would probably not fall under the scope of the IPPC-directive because these cannot be considered as direct environmental impacts, however, impacts on environment of use of e.g. antibiotics would be covered. Impact of alien and escapees on the endemic environment At the moment NASCO (North Atlantic Salmon Conservation Organization) is working on guidelines on this topic. A Commission proposal for a Council Regulation concerning use of alien and locally absent species in aquaculture is now under discussion at the Council. If aquaculture were added into the IPPC Directive, it is doubtful whether there would be a basis in the Directive's current provisions to address escape prevention issues. On the other hand, it might be possible to include such a provision for this sector in the event of adding aquaculture in the Directive. Institute for European Environmental Policy together with BIO, and VITO 23

24 Summary of key elements about the legislation useful for this exercise Aquaculture sector is subjected to different national/eu legislations directly or indirectly and these legislations are heterogeneous. This large diversity of legislations and standards across MS reflects the diversity of the sector viz. differences in fish farming technology, the species farmed and the nature and quantity of wastes discharged. Most MS (at least the 10 for which information was gathered, see the table on page 5) seem to issue authorisations and/or permits to operate and most of them would not revised them often. The need for harmonisation has been mentioned in several reports 25, however, not all experts agree that this is possible nor indeed desirable (for instance, authorisation and licensing of fishing facilities exist since very long time in some MS such as France and is adapted to the local culture). The aquaculture legislation can be difficult to enforce from the purely legal point of view because of all the aspects, agencies, laws and regulations which are involved. 2.7 Factors to be taken into account when considering options In view of the discussion of the preceding sections, following factors were identified which may affect the pros and cons of different options. Economic capacity of the sector. Species specific environmental issues. Environmental issues related to the size of production facilities and the environmental state of the recipient. Will inclusion of this sector into the IPPC-Directive lead to a better legislation for this sector? 25 Cowey, C.B., (ed.) 1995: Nutrotional strategies and management of aquaculture waste. Selected Proceedings of 2nd Int.Symposium on Nutritional Strategies and Management of Aquaculture Waste, Rebild, Denmark, April Water science and technology, Elsevier Science, UK. GESAMP, Monitoring the Ecological Effects of Coastal Aquaculture Wastes. Rep. Stud. GESAMP No. 57. Institute for European Environmental Policy together with BIO, and VITO 24

25 3. Options In this section, the 4 options under consideration are defined and a preliminary list of pros and cons is given. They will be further analysed in section 4. Considerations about the threshold definition are also given. Pros: Cons: Option 1: Business as usual i.e. non-action No additional burdens from additional legislative requirements. Because of the high variation of aquatic conditions and species across MS, it leaves each MS/region free to determine optimal control requirements for the specific aquaculture activities in the territory concerned. Missed opportunity to reduce environmental impacts notably water consumption, eutrophication, and emissions related to the use of chemicals (eg anti-fouling agents) and/or pharmaceuticals may be reduced significantly by implementing BAT. Possible inconsistency of approaches between MS/regions, leading to impacts on competition among European producers. Option 2: Addition of aquaculture to the list of covered activities in Annex I, with a production capacity of 1,000 tonnes of fish or shellfish per year (same as E-PRTR threshold). Pros: Cons: Applying BAT could help reduce environmental impacts - water consumption, eutrophication and emissions related to the use of chemicals and/or pharmaceuticals, etc. This threshold would at least cover the large salmon producing installations that are causing the highest environmental pressure of all facilities within the aquaculture sector. Greater consistency of regulation. Regulatory threshold would be clear, although would need to consider carefully what is meant by production (e.g. whole fish/shellfish, parts of fish/shellfish, etc.). Only a few companies in the aquaculture sector as a whole would pass this threshold. If we look at facility level even fewer facilities would pass this threshold (of the order of tens). However, it might be the case that a small number of large installations are responsible for a large proportion of the environmental impacts of the sector. Costs of BAT definition and BREFs production for full range of stakeholders in the Sevilla process. Institute for European Environmental Policy together with BIO, and VITO 25

26 Additional costs of BAT implementation could potentially pass through to affect consumer prices and competition (Salmon is a global industry with high competition) Additional costs for authorities, notably for permits, inspections and enforcement. Risk of operators switching to having a number of separate installations under the 1000 tonne threshold, rendering inclusion in Annex 1 of the IPPC Directive ineffectual. This could cause an increase of smaller facilities that might cause increasing impact on the landscape and in the context of tourism. Production capacity provides only a limited indication of potential environmental impact. The assimilative capacity of the receiving waterbody is an important consideration. For instance, the waterbody scale impacts of a much smaller facility discharging into a waterbody with low assimilative capacity may be higher than a 1000t site discharging into strongly tidal coastal waters with high assimilative capacity. Option 3: Addition of aquaculture to the list of covered activities with a lower production capacity than 1000 t/year. Variant a : threshold of 500 tonnes of fish or shellfish per year - the threshold used in some Member State legislations: e.g. Belgium-Flanders Variant b : threshold of 100 tonnes of fish or shellfish per year - the threshold used in other Member States' legislation: e.g. UK, Greece Variant c : thresholds at different levels for finfish and shellfish, e.g. 500 tonnes of fish and 1000 tonnes of shellfish per year Note: Setting the threshold value will in practice exclude specific types of production Pros: Even greater environmental benefits as the threshold is lowered. More species, countries, production methods and actors are covered by the legislation as the threshold drops. The likelihood of operators switching to smaller separate installations reduces the lower the threshold. Linking to thresholds that already exist in some countries may facilitate design as it benefits from national experience. Division between finfish and shellfish would reflect the differing environmental impacts of these activities. Regulatory threshold would be clear, although would need to consider carefully what is meant by production (e.g. whole fish/shellfish, parts of fish/shellfish, etc.). Defining annual production is also an important issue. For instance, salmon production is carried out on month cycles therefore per year production thresholds are not easy to define or enforce. Institute for European Environmental Policy together with BIO, and VITO 26

27 Cons: Greater costs, with risk of low cost-effectiveness for smaller facilities. Increasing effort needed to define BAT as the thresholds lower and more species and production methods are covered. Additional costs for authorities permits, inspections and enforcement. For small scale installations, potential disproportionate burden on aquaculture activities that support specific socio-economic ambitions e.g. local employment initiatives. Production capacity provides only a limited indication of potential environmental impact, although this could partly be addressed by setting different thresholds. Option 4: Addition of aquaculture to the list of covered activities, using another indicator than production capacity as a criterion: e.g. standing biomass or tonnes of fodder used per year. Pros: Cons: The amount of standing biomass is more relevant towards actual environmental impact than the production capacity and similarly the environmental impact is more linked to the amount of fodder used than to the level of the production. This type of threshold is more equivalent to that used in the pig and poultry sectors in IPPC (number of places) Applying BAT could help reduce environmental impacts - water consumption, eutrophication and emissions related to the use of chemicals and/or pharmaceuticals, etc. Greater consistency of regulation. Standing biomass varies across Europe and changes over time so the thresholds need to be revised. Costs of BAT definition and BREFs production for full range of stakeholders in the Sevilla process. Additional costs of BAT implementation could potentially pass through to affect consumer prices and competition (Salmon is a global industry with high competition) Additional costs for authorities, notably for permits, inspections and enforcement. Determining whether installations exceed such a threshold could be more complicated than use of a simple production capacity threshold. Institute for European Environmental Policy together with BIO, and VITO 27

28 A summary of preferences for specific option(s) provided by some advisory group members and stakeholders is summarised in the table in Appendix I. Remaining members either did not reply to the consultation or did not provide a clear preference for one of the options. Threshold definition In order to evaluate on whether to include or not aquaculture in the list of activities under IPPC and to define some realistic options, one need to look into the ways one can define the threshold for such installations. This becomes even more important because there is a large variation in the size of aquaculture farms across Europe, from very small family owned farms in Austria to large scale industrial production in Norway. - The initial approach was to begin with a conventional production unit (tonnes per year) which does represent the scale of the production but is probably less appropriate to quantify the impacts caused by aquaculture. - The definition of weight can influence the threshold significantly, in case of some species (e.g., mussels) and it can be live weight, whole fish equivalent, or gutted weight. - Different ways to define the threshold are being looked at; some examples are standing biomass (Norway, Scotland), fodder or feeding biomass (option under consideration in Sweden), stocking densities (Scotland). - The environmental impacts of certain group of species are much higher than the others (for example, finfish compared to shellfish). - One must also consider the fact that hydrographical conditions vary throughout Europe that consequently have a direct influence on standing biomass and other impacts. Environmental impact can be controlled by ensuring standing biomass is correctly limited by regulatory authorities to ensure impacts are limited too within the carrying capacity of the receiving environment. In Scotland, for example, the regulatory system used to license fish farming operations and ensure protection of waterbodies sets limits upon the standing biomass and the density of that biomass to ensure that impacts upon the water environment remain within acceptable limits. - Impacts can also be related to the sensibility of the recipient ecosystem i.e. carrying capacity. There are fundamental differences between the Atlantic and Mediterranean (which is very oligotrophic) with respect to the eutrophication. Therefore, maximum carrying capacity of the aquaculture sites is a critical aspect, although this might be difficult to apply as a threshold for regulatory application. To summarise, the important criteria to be considered while defining such threshold are the farmed species, hydrography of the breeding site, and the existing water quality. Institute for European Environmental Policy together with BIO, and VITO 28

29 4. Analysis of options A qualitative approach is adopted for the analysis of the options proposed in section 3. For each of the issue, the relative advantages and disadvantages of the options are evaluated. The impact assessment matrix shown below the summary of the results of the analysis and the through process behind the rating is explained in the following sub-sections. In each cell a qualitative score of Y/N or +, 0 or - has been given. A + signifies beneficial impact with respect to the criterion in question; - a negative impact; and 0 no impact. Increased magnitude of the impacts will be indicated using the notation ++ or --. In some cases, when there are other external influencing factors, a range is used, for example 0 to or even + to -. Businessas-usual: Option 1 Option 2 production >1000 t/y Option 3 Other production thresholds < 1000 t/y Option 4 Alternative approaches General Issues Problems addressed Legislative changes Environmental Issues Eutrophication Energy consumption Pressure on wild fish stocks N/A N/A N/A N/A Ecological and genetic impacts N/A N/A N/A N/A Health and sanitation Economic Issues Impact on firms: cost 0 0 to Impact on firms: competitiveness 0 0 to Impact on public authorities 0 0 to Cross-sector impacts e.g. on tourism development Social Issues Impact on consumers (availability/price) 0 0 to Confidence of public on environmental control and pollution to ++ Number and quality of jobs public authorities Number and quality of jobs in aquaculture sector 0 + to - ++ to -- + to - Other Issues Practicability: is it practical to implement? n/a Y Y Y Clarity and consistency (e.g. with other legislation)? n/a Y Y ID 27 Is it enforceable? n/a Y Y Y +++ : very beneficial effect; ++ : substantial beneficial effect; + : slight beneficial effect; - : negative effect, -- : substantial negative effect; --- : very negative effect; 0 no effect; n/a: Not applicable; ID: It Depends 26 This question looks at whether the design of the option actually addresses the real problem in the sense of focus rather than effectiveness. Effectiveness issues come after. Hence it is the intention and targeting of the option that is assessed here and not its effect. 27 Depending upon the option chosen it can be consistent with the legislation existing in some of the MS (e.g. Sweden, Scotland, or Norway) Institute for European Environmental Policy together with BIO, and VITO 29

30 All the proposed options (except the Business as usual) are intended to impact most of the aspects. However, the magnitude of this impact may vary from one option to another mostly in the increasing order from option 2 to 4. General issues Problem addressed The major problem to address through this potential amendment is to reduce the environmental impacts caused by aquaculture installations. Option 2 concerns a rather limited number of installations in this production capacity range and located in only few MSs (59 in the UK out of which 55 in Scotland, 3 in France for instance, most of them being in Norway, probably several hundreds 28 ). Besides, no data are available regarding the current contribution of those installations to the total environmental impacts of the aquaculture sector assessed in section 2 (their environmental impacts may be bigger than smaller installations, but some of those installations may already use technologies to operate with less environmental impacts per ton of fish than other installations). Thus it is not possible at that stage to assess the scale of the potential environmental benefits associated with Option 2, although benefits can be expected, in particular by making sure all large installations use BAT. Going to a lower production capacity threshold (option 3) will bring a large number of installations under IPPC (the number will obviously depend on the capacity threshold; a majority of installations have a capacity lower than 100 t/yr) and hence the benefits achieved through the reduction of environmental impacts will be higher than option 2 (to be able to judge if those additional benefits would be substantial, data about the current environmental impacts of small installations would be necessary). Option 4 is more peculiar as it uses approaches which have been based on the experience of the countries where legislation in this sector exist since long time and it can be rightly deduced that the real environmental impacts are difficult to relate with the production capacity but linked directly to the amount of fish feed used in an installation. Additionally, taking into account the carrying capacity of the receiving waters may provide a site-specific approach and hence more effective because the aquaculture installation sites are very different from one country to another in terms of farming methods and also the existing quality of the water body. Legislative changes All the options suggesting the inclusion of aquaculture under IPPC will require the changes in the legislation and hence the impact of the options 2, 3, and 4 will be negative on this aspect. 28 Norway does not monitor installations based on their production capacity. Institute for European Environmental Policy together with BIO, and VITO 30

31 Environmental issues For eutrophication and energy consumption, the impacts of the options 2, 3, and 4 are going to be positive and in the increasing order as explained in general issues. However, it should be noted that most of the environmental impacts are specific to the fish species and the harvesting/farming method used and therefore the influence of an option on the issues may be different depending upon the species, for example, energy consumption maybe an important issues for the land-based farms compared to the offshore ones. Further, option 2 will impact only large installations, mostly for Salmon and Trout farming whereas option 3 will influence a large variety of species and hence the benefits achieved will be substantial. Some impacts, such as ecological and genetic impacts and pressure on wild fish stocks may not be addressed directly by the IPPC Directive and some parallel initiatives maybe required. Economic issues Three targets of economic impacts are possible by the proposed options 2, 3, and 4, viz. companies in the aquaculture sector, regulatory authorities, and other sectors. The impact on companies can be in terms of costs and competitiveness, however they are interlinked as additional regulatory costs may affect the price of the product and therefore the competitiveness. Further, this issue of competitiveness can be seen from two perspectives. On one hand, the inclusion of aquaculture under IPPC may act as a playing field within Europe by harmonising the national and EU regulatory obligations of the producers, while on the other hand it means additional costs and perhaps a higher price of the fish in consumer market and the European producers may become less competitive compared to the international ones. The latter is critical as there is an increasing trend in the import of aquaculture products in Europe. Option 2 may not have huge impacts as most of such large installations (mostly belonging to large companies) are already subjected to national (or sub-national) legislations and therefore will be able to adapt to any new EU transposed legislation without much difficulty or have means to do that. For the option 3, where much smaller installation may come under regulatory mechanism, the economic impacts can be assumed to be substantial as it may affect many SMEs and small family owned companies. Concerning option 4, it will certainly affect the companies but it maybe difficult to judge the magnitude of any such impact at this stage. For the regulatory authorities, options 2, 3, and 4 may result in additional workload and related impacts. However, it will not be uniform across Europe as many MS (specially Nordic countries, UK, France, etc.) already have an authorisation and/or licensing system for aquaculture installations and the relevant authorities may be able to take the additional workload related to IPPC permitting. Tourism is one of the sectors where cross-sector impacts of the aquaculture regulatory measure could be felt. Better control measures will mean better managed coasts and water bodies, and hence they will influence the tourism development in these regions in a positive way. However, this aspect is limited to the MS where aquaculture installations sites are found near the sites of tourist attractions, for example, Greece. Negative impacts may also emerge. The application of an IPPC regime with fixed thresholds has indeed the potential to have a larger impact on tourism as operators may seek to increase the number of smaller operations to below the regulatory threshold, leading to larger numbers of facilities and a greater visual impact for tourists. Institute for European Environmental Policy together with BIO, and VITO 31

32 Social issues The direct impact of increased regulation may result in the increased fish price and thus influence the consumer interests. This kind of impact will be higher for option 3 compared to option 2 as more species/installations will be affected. On the other hand, improved regulation and reduced environmental problem may raise the public confidence in regulatory measures such as IPPC. Employment is a critical aspect for this sector as highlighted in section 2.3. Overall the sector, with about people throughout the EU-25, represents a growth in employment and more importantly, this sector offers jobs in the rural sector where not many vistas of employment exist. The impacts on this aspect can range from positive to negative. The positive impacts may come from the fact that the industry may need additional manpower for environmental management of the sites and for regulatory purposes. However, if the additional IPPC permitting influences the competitiveness and survival of some of the installations (specially for the option 3 where many small installations may be subjected to IPPC permit), this may result in loss of job for the people working in these installations. For the public authorities, especially in the MS where no national legislation exist (if any), this may result in the creation of additional job to ensure an effective implementation of the IPPC at the national level. However, this may be a minor impact as all the MS have already transposed IPPC Directive and the national regulatory bodies should be able to handle this additional work for aquaculture installations without significant additional manpower (perhaps not in the case of option 3 where the number of installations may be very large if the threshold is low). Other issues In terms of practicability, option 4 is more practical as it will target the issues and zones where the impacts are more significant and thus more effective. However, from enforcement point of view, options 2 and 3 maybe much easier to enforce compared to option 4 where additional criteria and site specificities will add to the complexity of the permit. IPPC targets overall and continuous improvement of the environment; therefore it will provide an effective means to achieve some of the targets (specially the ones linked to eutrophication) of the Water Framework Directive which insists on keeping the water resources in good healthy conditions. Institute for European Environmental Policy together with BIO, and VITO 32

33 6. Summary The aquaculture industry is heterogeneous across Europe both in terms of the size of installations and the fish species. In addition, media (freshwater and marine) and site specificities add to this heterogeneity. The inclusion of aquaculture under IPPC has distinct advantages and disadvantages as summarised here. Environmental implications A preliminary estimate on the number of installations is presented in section 2.1. Even if a complete picture of the capacity wise installations is not available but looking from the total EU production, it can be concluded that the environmental impacts (especially eutrophication) at the EU level are significant. However, these impacts are not uniform across MS. Further, some species e.g. shellfish cause much less impact to the environment. Inclusion of aquaculture under IPPC will lead to an overall improvement of the quality of European water bodies and the coastal ecosystems. Such an inclusion will also bring this sector in parallel with other types of animal farming such as pig or chicken production which are currently included within the scope of the IPPC Directive. However, aquaculture differs from intensive terrestrial animal production because the significant polluting emissions from fish farming activities are made to the aquatic environment alone and are therefore a single media issue. Legislative implications Like many other sectors, aquaculture is also subjected to different European and national (and sub-national) legislations and the importance to achieve a synergy between the regulation mechanisms at different levels is emphasised by many stakeholders (FEAP and several MS). Also, this will give us an indication on how far to go with IPPC directive by investigating further benefits that can be achieved beyond what is already possible through existing legislations. Many suggestions pointed to Water Framework Directive. However, while the WFD provides a framework to achieve better water quality, it sets out limited detail as to how its requirements for good water quality are to be achieved. In this respect, its implementation is dependent on national laws, policies and measures, as well as Directives such as IPPC, to improve the quality of European water bodies. The experience from the countries where this sector is already covered by local legislation such as Norway, Sweden, and Scotland (UK) suggests that there is a potential to reduce environmental impacts in MS where no such legislation exist. Hence, one of the key advantages of bringing aquaculture under IPPC will be the harmonisation of legislative obligations and administrative burden in Europe. In the beginning, however, this will increase the burden on the countries where the local legislation does not exist and which in turn could affect their competitiveness. Institute for European Environmental Policy together with BIO, and VITO 33

34 Socio-economic implications The aquaculture sector plays an important socio-economic role in some MS. Any change in economic capacity of the sectors will have a direct influence on the number of jobs and overall social development of the regions. However, better regulated installations might raise the public confidence not only for the quality of the fish but also the reduced environmental impacts. Looking at the cross-sector impacts, in tourist areas, the increase of aquaculture activities might hamper the tourist attraction of the area mainly for pollution reasons and aesthetics (although tourists might be interested in visiting aquaculture facilities). Its regulation under IPPC may reduce cross-sector impacts related to pollution. It should be noted that there is a lack of scientific evidence regarding those aspects. Threshold definition a key issue to be resolved if included under IPPC In order to evaluate on whether to include or not aquaculture in the list of activities under IPPC and to define some realistic options, one need to look into the ways one can define the threshold for such installations. The initial approach was to begin with a conventional production unit (tonnes per year) which does represent the scale of the production but is probably less appropriate to quantify the impacts caused by aquaculture. The main difficulty is to identify a common approach for regulation because the environmental impacts depend not only on the factors such as species and the feed quality but also on the local conditions which are difficult to generalise. Further, the countries having such legislation are using different approaches and no common ground has been found to advocate one specific approach. The easiest from the implementation point of view and also to be coherent with E-PRTR is the production capacity, though it does not appropriately relates to the magnitude of the associated environmental impacts. The production volumes may not serve as a good threshold criteria as the measure of impacts on the environment can be linked more easily to the fodder used or standing biomass. Further, the installations greater than t/year is a MS specific issue given that it only applied to a very small minority of countries (e.g. Norway, Scotland, France). Also, most of the large installations are already regulated under national systems and therefore the costs of integrating them into IPPC will not be high. However, costs of integrating smaller farms maybe unhelpful given the high level of competition. To summarise, the important criteria to be considered while defining the threshold criterion are the farmed species, hydrography of the breeding site, and the existing water quality. Institute for European Environmental Policy together with BIO, and VITO 34

35 7. Main references [1] Council Regulation 2792/99 of 17 December 1999 [2] Environmental integration manual. nvman-697.html [3] European Parliament, (2002), On aquaculture in the European Union: present and future (2002/2058(INI)) [4] Communication from the commission to the council and the European Parliament, (2002), A strategy for the sustainable development of European aquaculture (COM(2002) 511 final). [5] EC DG FISH - [6] FAO Fisheries department, (2005), [7] FEAP, (2002), European Fish Farming, [8] Eurostat, (2004), Facts and figures on the CFP, [9] EEA 66/view_content [10] EPA, (2002), Economic and Environmental Impact Analysis of the Proposed Effluent Limitations Guidelines and Standards for the Concentrated Aquatic Animal Production Industry [11] Ymparisto (Finland s environmental administration, 2005, communication to DG Environment. [12] European commission fisheries directorate general by MacAlister Elliott and Partners Ltd., (1999), Forward study of community aquaculture; Summary report [13] Norden, (2005), Beste tilgjengelige teknikker for fiskeoppdrett i Norden. [14] IEEP, (2004), Sustainable EU Fisheries Facing the environmental challenges [15] Salz, P. et al, (2006), Employment in the fisheries sector: current situation Main references specifically used in the environmental impacts analysis: [16] Effects of Aquaculture on World Fish Supplies Naylor, R. L., R. J. Goldburg, J. H. Primavera, N.Kautsky, M. C. M. Beveridge, J. Clay, C. Folke, J. Lubchenco, H. Mooney, M. Troell. Nature 2000 [17] Fish Farming and the environment Results of inventory analysis Finnish Environment Institute 2003 [18] Utilisation de l analyse du cycle de vie pour l évaluation environnementale des systèmes de production piscicoles Aubin, Papatriphon, Petit and Van Der Werf [19] Environmental Impacts of Wild Caught Cod and Farmed Salmon - A comparison with Chicken Elligsen and Aanondsen Int J LCA 2006 [20] Sustainable EU fisheries: Facing the Environmental Challenges European Parliament Conference Report 8-9 November [21] Study on External Environmental Effects Related to the Life Cycle of Products and Services BIO Intelligence Service for DG ENV, [22] Europe s water: An indicator-based assessment European Environment Agency Topic Report Institute for European Environmental Policy together with BIO, and VITO 35

36 [23] Scenario-based environmental assessment of farming systems: the case of pig production in France Basset-mens and van der Werf Agriculture Ecosystems and Environment 2005 [24] Sustainable EU fisheries: Facing the Environmental Challenges European Parliament, Brussels Conference Report 8-9 November 2004 [25] A Scientific Review of the Potential Environmental effects of Aquaculture in Aquatic Ecosystems- Volume 1 Fisheries and Ocean Canada 2003 [26] Review and Synthesis of the Environmental Impacts of Aquaculture Scottish Executive Central Research Unit Contacts/Acknowledgements We express our gratitude to the following persons who provided information on the current state of the art and important data concerning this potential amendment and also useful comments on our approach of analysis. William J.J. Crowe member of DG Fisheries, ACFA WG 2, and UK Representative on Federation of European Aquaculture Producers (FEAP) Erik Nyström Swedish EPA Paula Gama Institute for the Environment, Portugal Hilde Aarefjord Norwegian Pollution Control Authority Iñigo de Vicente-Mingarro Ministry of Environment of Spain Javier Remiro Perlado - Secretaria General de Pesca Marítima - Área de Acuicultura, Spain Richard Vincent Department for Environment, Food and Rural Affairs, UK Dr Neil Auchterlonie - European and Technical Manager, Scottish Salmon Producers Organisation Helmut Eder, Austrian Chamber of Agriculture Chris Dekkers / Pieter Roos, Ministry of Environment Netherlands (VROM) Delphine Dubois / Guy Mottard, Ministère de l écologie et du développement durable, France Ms Elise Sahivirta, Ministry of the Environment, Finland Costas Hadjipanayiotou, Cyprus Environment Service Malgorzata Typko, Ministry of Environment, Poland Indra Kramzaka, Ministry of Environment, Latvia Mrs Gordana Kerekeš, Agency for Environment, Slovenia Joël Aubin, INRA (Institut National de la Recherche Agronomique), France Neil Emmott, Alexandre Paquot, and Christian Hudson European Commission (DG Environment) Donald Litten European Commission (DG JRC) Alessandro Piccioli and Florentina Cruz European Commission (DG FISH) Eva GOOSSENS European Environment Agency (EEA) Annex A: European Aquaculture Production and Employment Data provided below come from 2 different sources of information: FEAP and FAO. It is notable that some figures differ significantly between the two datasets. Without ambitioning solving this problem, one can suggest some reasons. Institute for European Environmental Policy together with BIO, and VITO 36

37 First, the primary sources of information differ: FEAP: the data is reported by the member national federations as they mention The Member Associations of the FEAP provide production data for the activities of their national producers on an annual basis. In addition, forecasts for the coming year are also indicated, based on their own individual reporting systems. The FEAP Secretariat groups this information into Species and National reports that are now published in the Aquamedia site, where fuller details on the species and national data are assembled. All data is reported in metric tons and represent fresh, whole (round) weight. Average price values are also reported in per kg, representing the average ex-farm value (i.e. the value obtained by the producer) and which are annual averages for the year in question. FAO uses data reported by each country (official ministry data). Further, the data of FEAP does not seem to contain shellfish. For instance, this might explain the data difference for Spain where the shellfish production is quite high. Also, FEAP data per species seem to include Norway. Remark: FAO data presented below were extracted by BIO from the large FAO database. Production per species Eu25 Production Eu25 (tonnes) Species or species group 2004 Trout Salmon Carps Sea Breams Sea Basses Fishes nei Eels Tuna Turbot Catfish Other fish Cod Sturgeon Total Source: FAO database, with data extraction by BIO EU25 Aquaculture production and value Countries are classified according to decreasing production (based on 2004 FAO data) Country Production in tonnes Value in 000 euros Institute for European Environmental Policy together with BIO, and VITO 37

38 FEAP (2002) FAO (2004) FEAP (2002) Luxembourg Spain France United Kingdom Italy Greece Netherlands Ireland Germany Denmark Poland Czech Republic Finland Hungary Portugal Sweden Lithuania Cyprus Austria Slovenia Belgium Slovakia Malta Latvia Estonia EU 25 Total Norway Institute for European Environmental Policy together with BIO, and VITO 38

39 Employment in aquaculture in the North Sea region, % change* Belgium % Denmark % Germany % Netherlands % United Kingdom % Total % * It is not possible to determine to which extent the indicated changes are a consequence of changes in statistical measurement and/or definitions. Employment in aquaculture in the Baltic region, % change* Denmark % Estonia n/a 100 Finland % Germany % Latvia n/a 426 Lithuania n/a 315 Poland** n/a Sweden % Total n/a 3,752 * It is not possible to determine to which extent the indicated changes are a consequence of changes in statistical measurement and/or definitions. ** Includes aquaculture located outside the three coastal NUTS-2 regions. Employment in aquaculture in the Atlantic region, % change* France % Ireland % Portugal % Spain % United Kingdom % Total % * It is not possible to determine to which extent the indicated changes are a consequence of changes in statistical measurement and/or definitions. 29 direct employment would be 3,092 according to Institute for European Environmental Policy together with BIO, and VITO 39

40 Employment in aquaculture in the Mediterranean region, % change* Cyprus n/a 127 France % Greece % Italy % Malta n/a 105 Slovenia % Spain % Total % * It is not possible to determine to which extent the indicated changes are a consequence of changes in statistical measurement and/or definitions. Employment in aquaculture in the central European region, % change* Austria n/a 500 Czech Rep. n/a Germany % Hungary n/a Slovakia n/a 233 Total n/a * It is not possible to determine to which extent the indicated changes are a consequence of changes in statistical measurement and/or definitions. Sources of information used in this annex: FEAP - FAO - FISHSTAT - &xp_banner=fi Other sources of information: DG FISH - re05_en%22 Salz, P. et al (2006) Employment in the fisheries sector: current situation. Institute for European Environmental Policy together with BIO, and VITO 40

41 Annex B: Number of Aquaculture Installations and Capacities Information presented are mainly based on replies to the questionnaire sent during the consultation of stakeholders. Some literature review was performed to supplement some major data gap. B1- Largest aquaculture producers of Eu25 Spain No reply to questionnaire has been received from Spain so far. Active research was done to gather some data. Preliminary data are included here. Number of installations per autonomous community in Spain Source: Secretaria General de Pesca Marítima, 2006 Marine Aquaculture Autonomous Community Number of installations Estimation of number of workers Andalucia Baleares Canarias Cantabria Cataluña Ceuta 1 1 Madrid 1 28 Valencia Galicia Pais Vasco 2 91 Asturias 4 22 Murcia 13 0 Total Fresh Water Aquaculture Autonomous Community Number of installations Estimation of number of workers Andalucia Aragon Baleares 1 0 Canarias 1 8 Cantabria 7 29 Castilla la Mancha Castilla León Cataluña Madrid 1 6 Navarra 9 28 Valencia 4 21 Extemadura Galicia La Rioja 7 27 Pais Vasco 5 20 Asturias Murcia 1 1 Total Institute for European Environmental Policy together with BIO, and VITO 41

42 Aquaculture production, tonnes Source: Spanish Agriculture, Fishing, and Food Ministry (Ministerio de Agricultura, Pesca y Alimentación - Junta Asesora de Cultivos Marinos) 4 Freswater Aquaculture Fish Raibow Trout , , , , ,3 Wahoo 12,8 100, ,37 Eeel Sturgeon TOTAL , , , , ,97 Crustacean Crab 0,8 0,8 0,4 0,3 0,3 TOTAL , , , , ,5 Marine Aquaculture Fish Gilthead bream 9.832, , , , ,7 Turbot 3.636, , , , Dea bass 2.269, , , , ,47 Salmon Family 323, MUGÍLIDOS ,8 132,2 154,48 - Sole 42,7 41,9 38,7 57,6 38,33 BAILAS ,8 LISA ,33 Tuna family 4.446, , , , ,17 Eel 258,9 294,9 291,5 362,6 320,9 CORVINA - 5 3,3 14,4 314,33 TILAPIA - 16,5 127,4 3 1,2 Sea bream ,84 ABADEJO ,152 TOTAL , , , , ,772 Molluscs Mussel , , , , ,69 ALMEJAS 4.158, , , ,72 Oyster 4.565, , , , ,89 ESCUPIÑA 0,8 1 1,9 1,5 1,65 PECTÍNIDOS 109,8 2, Cockle 1.567, ,9 969, ,2 520,58 Type of clam 102,3 49, small clam 14,3 22, Pulp 14,6 16,7 10,2 12,6 15,8 TOTAL , , , , ,33 TOTAL * , , , , ,85 TOTAL* * , , , , ,16 TOTAL*=Counting Crustacean TOTAL**=Without counting Mussel Institute for European Environmental Policy together with BIO, and VITO 42

43 France Species Total production in 2002 (t) Number of installations in 2002 a b b/a Freshwater Trout (1) 100 Sturgeon (1) 15 Carp, perch... in ponds (2) <10 Marine Tilefish (1) 100 Gilthead bream (1) 65 Croaker (1) 35 Turbot (1) 115 Marine salmon (1) 90 Shellfish Oyster, mussel (2) 35 Average capacity per installation (t/year) Other calculation: 8 sites of ~650 t ~70 sites of ~25 t (3) Total Source: (1) Ministry of Environment, France, 2006 (2) 2002 FAO profile for France BIO's calculation (3) The calculation on the left end column might give results far from reality (100 / 65 / 35 / 115 / 90); as a matter of fact, 2002 FAO profile for France indicates that 8 enterprises (out of about 50 enterprises in charge of about 52 installations) represent 75% of total tonnages produced. This would imply that 8 enterprises produce about tonnes thus an average capacity for those 8 enterprises of 650 tonnes per yr. Table below gives some information for larger installations. Table above suggests that lots of small installations operate in France (about in the shellfish sector and the same number for ponds installations). Species Trout Production capacity (t/yr) Number of installations in 2005 Estimation of production (t/year) * > Bream/tilefish > Bream Salmon > Salmon > Total Source: Ministry of Environment, France, 2006 BIO's calculation * * Production = nb of installations x 'production per installation'; assumption for 'production per installation' = 1000 t for installations >1000 t or = the mean value of the range in the other cases (for ' t', 750 t was considered) Institute for European Environmental Policy together with BIO, and VITO 43

44 During interviews performed with contact persons at the French Ministry of Environment and Ministry of Agriculture, it was pointed out that the data about the number of installations indicated in this table takes into account only intensive aquaculture installations, by intensive it means the farms where fishfeed is given everyday. Also the shellfish production in France is not subjected to any environmental legislation, the information on such installations were not available (the first table was thus completed by information found in literature). Besides, the legislative control (authorisation, permit, EIA, etc.) are not at the prefecture level and this information is not yet aggregated at the national level. However, a new computerised reporting system for all food production facilities (including aquaculture) is being installed and should be operational by Italy No reply to questionnaire has been received from Italy so far. This data is derived from secondary sources. Species Freshwater Fish Total production in 2001 (t) Number of installations in 2001 Value mill (Euros) Average capacity per installation (t/year) a b a/b Salmonides , (Trout 30 ) Catfish (?) 2,48 3 Carp 700 2,19 Sturgeon 700 4,74 Marine Fish Sea bass ,5 Sea bream ,87 Eel ,49 50 Sharpsnout 400 2,27 Mullets ,07 Other fish Other fish ,36 Total Fish MOLUSCS Mussel ,21 Manima Clams Total Molluscs TOTAL AQUACULTURE Source: Source: Various (2005) Interaction between aquaculture and capture fisheries: A methodological perspective, studies and reviews-(a short overview of the status of aquaculture in the Adriatic countries- A short review of the status of aquaculture in Italy Giovanna Marino, Enrico Ingle, Stefano Cataudella) n , GENERAL FISHERIES COMMISSION FOR THE MEDITERRANEAN, FAO. 30 Taking into account also the added value of fresh products processed on site. 31 Pike, perch, striped bass, shi drum, dentex, red seabream, etc. 32 Total output includes about t gathered from natural beds. Institute for European Environmental Policy together with BIO, and VITO 44

45 United Kingdom Name of Species handled Capacity range (t/year) Number of installations Tot per species Estimation of production (t/year) * Atlantic salmon > Atlantic salmon Tot per species Atlantic salmon Rainbow trout Rainbow trout Rainbow trout < Brown trout < Brown and Rainbow trout Brown and Rainbow trout 69 Mussels > Mussels Mussels Mussels < Pacific oysters Pacific oysters < Scallops < Native oysters < Abalone < Turbot Halibut Cod and char Unknown 46 46?? Total Source: DEFRA, 2006 BIO's calculation * * Production = nb of installations x 'production per installation'; assumption for 'production per installation' = 1000 t for installations >1000 t or = the mean value of the range in the other cases (e.g. for ' t', 750 t was considered; for '<100', 50 t was considered) Based on DEFRA declarations in 2006, the total production assessed amounts at 158 ktonnes. This is an order of magnitude compatible with the FEAP figure of 179 kt for It is 129,000 tonnes for 2005 according to Scottish Salmon Producers Organisation, which shows that calculations made here give a correct order of magnitude. Institute for European Environmental Policy together with BIO, and VITO 45

46 Production per species (2005, tonnes) Source: table above (BIO s calculation from DEFRA data) Pacific oysters; t; 2% Brow n and Rainbow trout; t; 10% Scallops; t; 1% Turbot; 300 t; 0% Halibut; 300 t; 0% Abalone; 150 ; 0% Native oysters; 250 ; 0% Mussels; t; 14% Total production: ~ tonnes / yr Atlantic salmon; t; 73% Name of Species handled Total number of installations per species Atlantic salmon 176 Brown and Rainbow trout 69 Mussels 147 Pacific oysters 47 Scallops 22 Native oysters 5 Abalone 3 Turbot 1 Halibut 1 Cod and char 46 Total 517 Source: DEFRA, 2006 Capacity range (t/year) Total number of installations per capacity range > < Total 471 * * the capacity is unknown for 46 installations that is why total number of installations here is 471 (instead of 517) Source: DEFRA, 2006 Institute for European Environmental Policy together with BIO, and VITO 46

47 Number of installations per range of capacity Capacity > installations; 13% Capacity < inst.; 45% Cap inst.; 13% Cap inst.; 29% Total number of installations: 517 Number of installations per species Scallops; 22; 4% Cod and char; 46; 9% Pacific oysters; 47; 9% Native oysters; 5; 1% Abalone; 3; 1% Turbot; 1; 0% Halibut; 1; 0% Atlantic salmon; 176; 35% Brow n and Rainbow trout; 69; 13% Total number of installations: 517 Mussels; 147; 28% Specific case of salmon marine sites in Scotland Capacity range (t/year) Total number of installations per capacity range > <50 10 Total 193 Institute for European Environmental Policy together with BIO, and VITO 47

48 Greece No reply to questionnaire has been received from Greece so far. Greece produces nearly tonnes of sea bass and sea bream, i.e. over one third of total world production. The number of fish farms has risen from 12 in 1986 to 240 in Following are the species wise aquaculture installations for Greece. Species Number of Installations Seabass, seabream 217 Puntazzo, pagruss, mullet 35 Mussels 343 Trout 99 Carp, mullet 11 Eel 10 Total 694 B2- Other Member States of Eu25 Cyprus Name of species handled Capacity range (t/year) Number of installations in 2005 Estimation of production (t/year) * Tuna ranching Seabass / Seabream Seabass / Seabream Trout < Shrimp < Total Source: Cyprus Environment Service, 2006 BIO's calculation * * Production = nb of installations x 'production per installation'; assumption for 'production per installation' = 1000 T for installations >1000 T or = the mean value of the range in the other cases (e.g. for ' T', 750 T was considered; for '<100', 50 T was considered) 34 Source FAOSIPAM Institute for European Environmental Policy together with BIO, and VITO 48

49 Finland According to Finnish Ministry of the Environment, there are about 500 finfish farms of t and 12 with a capacity greater than 100 t/y in 2005 (according to FAO, there is no shellfish production in Finland). If one considers an average capacity of 50 t for the installations in the range of and a minimum of 100 t for those above, the total production amounts at 500 x 50 t + 12 x 100 t = tonnes. Considering the rough assumptions made here, this order of magnitude seems compatible with the FEAP production data available for Finland ( t in 2002). Poland Name of species handled Number of installations Total production (t/year) in 2004 Average capacity per installation (t/year) a b b/a Carp about ~90 Trout about ~45 Total about Source: Ministry of Environment, Poland BIO's calculation The total production declared by Poland (30 kt for 2004) is with the same order of magnitude than the FEAP figure (33 kt for 2002). Portugal Name of species handled Capacity range (t/year) Number of installations in 2005 Estimation of production (t/year) * Gilt-head sea bream; sea bass; trout Gilt-head sea bream; sea bass; turbot; trout; oyster; mussel < Carpet shell < Total Source: Institute for the Environment, Portugal BIO's calculation * * Production = nb of installations x 'production per installation'; assumption for 'production per installation' = the mean value of the range in the other cases (e.g. for ' t', 300 t was considered; for '<100', 50 t was considered) Institute for European Environmental Policy together with BIO, and VITO 49

50 Sweden In 2003, there were about 220 fish farming aquacultures in Sweden producing about 6 ktonnes, mostly rainbow trout. About 2 ktonnes of shellfish, blue mussels was also produced. Thus a total of about 8 ktonnes, slightly higher than the 5.6 ktonnes given by FEAP for 2002 but the same order of magnitude. B3- Norway In 2005, Norway has delivered more than 3250 licences in the aquaculture sector (our understanding is that a licence corresponds to an installation as considered for the other MS). Name of species handled Number of licences in 2005 Salmon and trout Other fish species 723 (1) Haddock 23 Halibut 134 Hake 7 Marine 20 Turbot 28 Char 50 Wolf fish 32 Cod 556 Eel 15 Other species 72 Shellfish 838 (1) Blue mussels 668 Lobster 18 Scallops 114 Sea urchin 26 Oysters 130 Other species 109 Sea ranching 18 Total Source: Directorate of Fisheries, Norway, 2006 ( (1) Licences for both other fish species and shellfish comprehend several species. In the detailed data given per species, some licences are counted several times consequently. That is why the total number of licences when we sum up the detail data amounts at 937 for other fish species, which is higher than the total number indicated of 723 (and 1065 for shellfish, compared to 838). Institute for European Environmental Policy together with BIO, and VITO 50

51 Annex C: Analysis of Environmental Impacts of Aquaculture (Quantitative analysis) This Annex presents an approach based on Life Cycle Analysis (LCA) that is developed in order to quantify the environmental impacts of aquaculture production. Annex D provides qualitative environmental impact information coming from secondary sources. Content of this annex: Introduction System under analysis Functional unit Elementary data used - Trout farming - Salmon farming Environmental impacts quantified Results obtained per tonne of fish - Finnish Trout Farming - French Rainbow Trout Farming - Norwegian Salmon Farming Factor affecting the impacts: the feeding conversion ratio Results obtained for Eu25 Analysis of the results and discussion - Comparison with the average European activity during one year - Comparison with the pig farming sector - Contribution of aquaculture to regional pollution External costs of environmental impacts Introduction LCA is regarded by many as the most rigorous scientific approach available to quantify environmental impacts of a given 'system' (i.e. the activities to which the technique is applied). LCA is a decision support tool supplying information on the environmental effects of products or process. It provides information on the environmental effects and potential impacts of all the stages of product / process life cycle (from cradle to grave or cradle to gate ), by: Compiling an inventory of relevant inputs and outputs of a system throughout its entire life cycle Assessing the potential environmental impacts associated with those inputs and outputs Interpreting the results of the inventory analysis and impact assessment phases in relation to the objectives of the study. Institute for European Environmental Policy together with BIO, and VITO 51

52 The methodology of LCA is still evolving, but a great part of standardisation has been achieved. Standards in the ISO series describe principles and framework and the four stages of an LCA: Step 1 - Goal definition and scope (ISO and 14041). The products/processes to be assessed are defined, a functional basis for comparison is chosen and the required level of detail is described. Step 2 - Inventory analysis (ISO 14041). The inputs (energy and raw materials used) and outputs (emissions to the atmosphere, water and land) are quantified for each process and then combined in an inventory table (life cycle inventory, LCI). In an inventory table, there is a row for each substance (called an elementary flow such as water consumption, CO 2 emissions, etc.) and a quantity in each column corresponding to a specific step of the life cycle under analysis. It is common to have up to 300 rows in an inventory table. Step 3 - Impact assessment (ISO 14042). Effects of the resources used and emissions generated are grouped and quantified into a limited number of impact categories which may then be weighted for importance. Step 4 Interpretation / improvement assessment (ISO 14043). Results are reported in the most informative way as possible and the need and opportunities to reduce the impact of the product(s) on the environment are systematically evaluated. For the purpose of the study, and within the resources of the project, we started from published life cycle inventories of different species production (i.e. no new primary data -inputs and output- was generated) and we compiled them to quantify the environmental impact indicators. System under analysis A cradle to gate analysis was performed as shown in the figure below (stopping at the exit of the farm and thus excluding the use of the fish). Natural Resources (Primary Energy, Water, Fish, Raw Materials) System Under Analysis Feed Raw Materials Production t t Feed Manufacturing t Hatcheries t Fish Farms t Antifouling paint Escapees Slaughtering Antibiotics Water emissions Air Emissions Emissions to the environment Institute for European Environmental Policy together with BIO, and VITO 52

53 The inputs considered are natural resources (primary energy, fish, raw materials, etc.) and the outputs are water and air emissions. Sometimes, fish escape from the farm, going back to the water body (river or sea). The different stages of the system are the following: The various transport steps (represented by T ). Feed raw materials production: feed raw materials are the materials used to produce the feed. These materials can be (by order of importance in weight): fish meal and oil, wheat meal, soya concentrate, vitamins, soya meal Feed production: this is the feed manufacturing, that is the transformation of feed raw materials into fish feed. Hatchery: this unit process includes the selection of brood fishes, growth and maintenance, the hatching of roe and growth of the broodstock itself. Fish farms: at this stage, antibiotics might be used (upon veterinarians prescription). Antibiotic and antifouling paint: the manufacturing of these products is not taken into account in the LCA. Escapees: during the fish farming stage, fish might escape from the cages. These escapees are not taken into account in the LCA. Because the inputs and outputs can differ significantly from on species to another, calculations were made for trout and salmon for which data were found in the literature. Functional unit The calculations are first presented for 1 tonne of unslaughtered fish produced. Then they are made at the Eu25 level considering the European production. A key parameter is the feed conversion ratio: this is the feed quantity (in kg) necessary to produce one kg of unslaughtered fish. Feeding of fish is affected by many factors, such as temperature, disease and feed quality. Therefore the feed conversion ratio may vary between fish and over time. The past years, feed conversion ratio has decreased due to better feeding techniques. The average international feed conversion ratio for Salmon and Trout is around factor 35 This figure has been showing a continual decline since Scottish salmon industry mean is c. 1.2 according to Scottish Salmon Producers Organisation. Institute for European Environmental Policy together with BIO, and VITO 53

54 Source: Effects of Aquaculture on World Fish Supplies Naylor, R. L., R. J. Goldburg, J. H. Primavera, N.Kautsky, M. C. M. Beveridge, J. Clay, C. Folke, J. Lubchenco, H. Mooney, M. Troell. Nature 2000 However, for Europe, feed conversion ratios tend to be lower (1.29 for Norwegian Salmon Farming and 0.9 to 1.53 for Finnish Trout Farming). Source: Fish Farming and the environment Results of inventory analysis Finnish Environment Institute 2003 Basic data Trout farming Two sources of information were identified for LCIs. The first one relates to Finnish rainbow trout. Source: Fish farming and the environment Result of inventory analysis Finnish Environment Institute 2003 Water and air emission data for the different stages of Finnish trout production Energy consumption for the different stages of Finnish trout production The other one is for French rainbow trout for which the environmental impacts were already available thus they were not calculated again and the impact values were directly used (see results hereafter). Source: Utilisation de l analyse du cycle de vie pour l évaluation environnementale des systèmes de production piscicoles Aubin, Papatriphon, Petit and Van Der Werf Institute for European Environmental Policy together with BIO, and VITO 54

55 Salmon farming Data about Norwegian cultivated salmon was used. Source: Fish farming and the environment Result of inventory analysis Finnish Environment Institute 2003 Water and air emission for the different stages of Norwegian salmon production Energy consumption of Norwegian salmon production Total primary energy consumption: MJ / t of ungutted fish Source: Environmental Impacts of Wild Caught Cod and Farmed Salmon - A comparison with Chicken Elligsen and Aanondsen Int J LCA 2006 Note: this primary energy consumption is higher than the one for the trout farming because this value includes also the energy for cooling, for slaughtering and processing. These stages of fish production should be out of our scope but no data were found to subtract them from the only figure available which for the total. Transportation distances and transported masses per 1000 kg of unslaughtered fish Source: Fish farming and the environment Result of inventory analysis Finnish Environment Institute 2003 Institute for European Environmental Policy together with BIO, and VITO 55

56 Environmental impacts quantified The inventory table is the most objective result of a LCA study. However, a list of substances is difficult to interpret. To make this task easier, life cycle impact assessment (LCIA) is used to evaluate the environmental impacts. Environmental impact categories quantified in this study Primary energy consumption Eutrophication Greenhouse effect (direct, 100 yrs) Air acidification Photochemical oxidation MJ kg PO 4 equivalent kg CO 2 equivalent kg SO 2 equivalent kg ethylene equivalent The characterisation factors used are those from CML 36 method. The definition of those impacts and characterisation factors are presented in Annex E. A general approach to calculate environmental impacts from the elementary flows quantified in the LC inventory step is described hereafter with consistency to ISO standards related to LCA (ISO 14042, 14043). Calculation of environmental impacts from the elementary flows Remark: it should be reminded that LCAs assess potential impacts and not actual impacts 37. The term potential covers three characteristics of LCAs: 36 Institute of Environmental Science, University of Leiden (NL). Characterisation factors developed by CML are commonly used by LCA experts. 37 This specificity of LCA addressing potential and not actual impacts concerns only the environment impacts assessment step. This does not concern the LCI step where inputs and outputs are quantified for each stage individually. It is only when one adds the different step that the potentiality issue occurs. Institute for European Environmental Policy together with BIO, and VITO 56

57 The assessment of LC environmental impacts is dependent on the current scientific knowledge and existing models, which is intrinsically limited. Environmental impacts are assessed and aggregated from inputs and outputs occurring at different life cycle stages which means with different space and time location. When the environmental impact studied is global (e.g. global warming) and the inputs or outputs are cumulative (e.g. greenhouse gases), this does not make any difference. But this is when the environmental impact is local (e.g. air acidification) or the inputs / outputs are not cumulative (e.g. noise) that the aggregation of inputs / outputs contribution to the studied environmental impact results in potential impacts. For instance, adding up local impacts as noise and odour does not make a lot of sense because they are not global and cumulative impacts but rather dependent on the location of the emissions. Thus LCAs assess maximum potential environmental impacts as if all the inputs and outputs occur at a same location in space and time. For a given physical phenomenon (e.g. air acidity), LCAs do not quantify endpoint impacts (such as in monetarisation methods: respiratory diseases caused by an increase of air acidity, etc.); rarely midpoint impacts (e.g. photochemical ozone creation potential) but generally start point impacts, i.e. the influence that pollutants emitted can have on the state of the environment (air acidity in that example). It gives a scale to assess the contribution to the environmental impact but not a quantification of the environmental impact itself (the higher the impact value quantified in LCA, the higher the environmental impact, without quantifying it directly). Start, mid and end point environmental impacts - E.g. for air acidification Type of impact Scope Unit Where it is quantified Start point impact Quantity of air emissions which influence air acidity g SO 2 equivalent LCAs Mid point impact Air acidification (i.e. increase of air acidity) due to pollutants emitted Proton concentration Impact in the air (acidity studies quantity) g H + / m 3 End point impact Social impacts of air acidification on human and ecosystems (such as respiratory diseases) e.g. number of years of life lost External cost analyses Institute for European Environmental Policy together with BIO, and VITO 57

58 Results obtained per tonne of fish Finnish Trout Farming The impacts are computed with the data mentioned in the previous section. The results presented here correspond to a feeding factor of (i.e tonne of raw fish feed is needed to produce 1 tonne of unglutted fish). Environmental impacts assessment for the different stages of Finnish trout production Per ton of unglutted trout Unit Feed raw material Feed production Hatchery Fish farm TOTAL Photochemical oxidation kg C2H4 eq Acidification kg SO2 eq Eutrophication kg PO4 eq Primary energy MJ primary Global warming (GWP100) kg CO2 eq It is notable that feed raw material is the unit process that causes the more damages to the environment, except for the eutrophication for which the fish farming stage is the main contributor. French Rainbow Trout Farming Environmental impacts assessment for French trout production Per ton of unglutted trout Unit trout portion big trout very big trout Photochemical oxidation kg C2H4 eq n.a. n.a. n.a. Acidification kg SO2 eq 10, ,2 12, ,9 15, ,5 Eutrophication kg PO4 eq 46, ,5 57, ,8 65, ,1 Primary energy MJ primary Global warming (GWP100) kg CO2 eq There are no much details in this publication, but the main point to focus on is that the effects depend a lot on the size of the fish. The high variability among categories seems to be mainly due to trout size (degradation of feeding factor with size). Moreover, if one compares the French impacts to the impacts computed from Finnish data, some differences can be observed. However, the orders of magnitude are similar for all the impacts. In the following, the results computed from the Finnish data will be used. Norwegian Salmon Farming The impacts are computed with the data mentioned in the previous section. The feed conversion ratio used in the Finnish study for the Norwegian Salmon production is It is slightly different from the feed conversion ratio of 1.29 mentioned in a Norwegian paper (source: Environmental Impacts of Wild Caught Cod and Farmed Salmon A Comparison with Chicken Ellingsen and Aanondsen 2005) but still consistent. Institute for European Environmental Policy together with BIO, and VITO 58

59 Environmental impacts assessment for the different stages of Norwegian salmon production Per ton of unglutted salmon Unit Feed raw material Feed production Hatchery Fish farm TOTAL Photochemical oxidation kg C2H4 eq 3,9 0,9 0,05 0,1 5 Acidification kg SO2 eq 3,2 0,4 0,02 0,08 3,7 Eutrophication kg PO4 eq 1,5 0,1 2,3 50,2 54,0 Primary energy MJ primary n.a. n.a. n.a. n.a * Global warming (GWP100) kg CO2 eq * As already mentioned, this value for primary energy consumption is higher than the one for the trout farming because it also includes here the energy for cooling, slaughtering and processing, which should be out of the scope of the study (but no data is easily available to do so). Factor affecting the impacts: the feeding conversion ratio The Finnish report on Fish farming and the environment 38 also provides details concerning the impact of the feeding factor. Variation, with the feeding factor, of air and water emissions of the different stages of Finnish trout production Variation, with the feeding factor, of primary energy consumption of Finnish trout production As previously mentioned with the French data about trout farming, those tables clearly show that the inputs/ outputs (and thus the environmental impacts which could be calculated) depend significantly on the feeding factor. Energy consumption is multiplied by a 1.6 factor for a feed conversion ratio of 1.53 compared to 0.9; the multiplying factor for N and P releases into water is around Fish farming and the environment Result of inventory analysis Finnish Environment Institute 2003 Institute for European Environmental Policy together with BIO, and VITO 59

60 Results obtained for Eu25 Assumptions The objective is here to assess the environmental impacts of the aquaculture sector at the Eu25 level, using the impacts calculated for 1 tonne of trout and salmon. Eu25 production data considered for 2004 (see Annex A FAO data): Salmon: tonnes Trout: tonnes Other marine fish (shells excluded): tonnes Because the production of fish others than salmon and trout represents around 36.4% of the total production, they cannot be excluded from the calculation without dangerously minimising the overall environmental impacts due to aquaculture in Europe. In the absence of specific data referring to those species, the weighted average of the results obtained for trout and salmon were taken. The shellfish contribution was excluded because no data on their environmental impact is available as this is negligible compared to finfish. Shells like mussels might have a filtration role and the same impacts cannot be used than the ones used for trout and salmon. Moreover, the primary energy consumption of shells aquaculture is much smaller than for fish aquaculture (mussels culture energy consumption is only MJ per ton produced compared to the GJ needed for salmon production). Source: Sustainable EU fisheries: Facing the Environmental Challenges European Parliament Conference Report 8-9 November Environmental impacts per ton of fish produced for trout, salmon production and weighted average Per ton of fish produced Unit Trout farming impacts Salmon farming impacts Weighted average per ton Photochemical oxidation kg C2H4 eq Acidification kg SO2 eq Eutrophication kg PO4 eq Primary energy MJ primary Global warming (GWP100) kg CO2 eq Other assumption implicitly made was that the environmental impacts assessed for Finnish trout and Norwegian salmon can be applied to other geographical regions. Results Environmental impacts of aquaculture (fish production only) in Eu25 For Eu25, 2004 Unit Eu25 production of Trout Eu25 production of Salmon Eu25 production of other fish Total impacts from fish farming Photochemical oxidation t C2H4 eq Acidification t SO2 eq Eutrophication t PO4 eq Primary energy MJ primary Global warming (GWP100) Mt CO2 eq Institute for European Environmental Policy together with BIO, and VITO 60

61 Analysis of the results and discussion In order to be able to judge about the level of those impacts, it is useful to compare them to other activities. Three comparisons were made: first with the average European citizen equivalent then with the pig farming industry (which is already covered by the IPPC) and other sectors eventually the contribution of aquaculture to regional pollution was analysed. Comparison with the average European citizen equivalent during one year Total impact of aquaculture sector was compared to the one assessed previously with the average environmental impacts of one European citizen equivalent 39. The elementary data used are: For Eu25 Unit Average impact of one European citizen equivalent Photochemical oxidation t C2H4 eq 0,015 Acidification t SO2 eq 0,045 Eutrophication t PO4 eq 0,007 Primary energy MJ primary 170 Global warming (GWP100) Mt CO2 eq 0,009 Source: Study on External Environmental Effects Related to the Life Cycle of Products and Services BIO Intelligence Service for DG ENV, 2003 (performed in the framework of the Integrated Product Policy of the European Union). It is then possible to assess, for each environment impact, the number of European citizen equivalents that generate the same amount of impacts than aquaculture. Comparison of aquaculture environmental impacts to the European equivalent average effects For Eu25 Unit Impact of Fish Farming (shells excluded) Average impact of one European equivalent Number of European equivalents a b a/b Photochemical oxidation t C2H4 eq , Acidification t SO2 eq , Eutrophication t PO4 eq , Primary energy MJ primary Global warming (GWP100) Mt CO2 eq 445 0, The higher the number of Europeans aquaculture sector is equivalent to, the more important the problem. The potential contribution of aquaculture to eutrophication is similar to the impact generated by 4.5 millions of European equivalents, whereas it is only equivalent to about European equivalents for global warming. 39 European citizen equivalent is European equivalent activity of Eu25 for one year divided by the EU- 25 population (population in 2004: Source: Eurostat) Institute for European Environmental Policy together with BIO, and VITO 61

62 Comparison with the annual production of European inhabitant In 2004, Eu25 population was Million. Unit TOTAL impacts of Aquaculture in Europe in 2004 Quantity due to EU25 activity for 2004 % Aquaculture/EU25 activity Eutrophication t PO4 eq ,97% Comparison with the pig farming sector Data used include Finnish data and French data. Finnish data used Source: Fish Farming and the environment Results of inventory analysis Finnish Environment Institute These data include different processes: pig rearing, pig fattening, slaughtering and the production of different feeds and feed raw materials (mainly crop products, grass and soy). French data used Source: Scenario-based environmental assessment of farming systems: the case of pig production in France Basset-mens and van der Werf Agriculture Ecosystems and Environment This article provides environmental impacts for different agricultural practice in the French pig production: Good agricultural practice : intensive or conventional production, optimised with respect to fertilisation practices. Pigs are raised at high density in a slatted-floor confinement building. Organic agriculture : according to the French interpretation of European rules for organic animal and crop production. Red Label : corresponds to the Porc Fermier Label Rouge quality label. The functional unit considered is the ton of pig produced, as live weight at slaughter. First the environmental impacts for Finnish pig production had to be assessed from the elementary data indicated above (and with the CML method used in LCA for impacts quantification as described in the first part of this annex for aquaculture). Then they were compared to the French environmental impacts available in the publication. Comparison of the Finnish and the French environmental impacts of pig production Per ton of pig production Unit Finnish pig production French pig production Good Agricultural Red Label Practice Organic Agriculture Photochemical oxidation kg C2H4 eq Acidification kg SO2 eq Eutrophication kg PO4 eq Primary energy MJ primary Global warming (GWP100) kg CO2 eq Institute for European Environmental Policy together with BIO, and VITO 62

63 The same orders of magnitude are observed regarding Finnish and French data for pig production. In the following, the Finnish data for pig production was used. Using the Finnish data, and an assumption of 21.2 millions tons of pig produced in Europe in 2004 (source: the impacts of aquaculture and pig production in Europe for 2004 can now be compared. The results are given in the table bellow. Comparison of the environmental impacts of aquaculture and pig production for Europe in 2004 Environmental effects for the year 2004 Unit Pig production Aquaculture (fish farming only) Percentage fish farming / pig production Photochemical oxidation t C2H4 eq % Acidification t SO2 eq % Eutrophication t PO4 eq % Primary energy MJ primary? ? Global warming (GWP100) Mt CO2 eq % The contribution of aquaculture to the environmental impacts quantified in this study represent 0.3 to 5.1% (according to the impact) compared to pig production contribution. The highest relative contribution is for eutrophication. These percentages might be underestimated because the pig studies include also the slaughtering stage (which is not included in the fish studies). Comparison with other industrial sectors Source: Actualisation et enrichissement des données énergétiques sur les matériaux BIO Intelligence Service for the French Environment Agency ADEME 2003 Primary Energy Consumption (MJ/ton produced) Trout Farming Salmon Farming Pig Primary Steel Zinc PVC (moulted by injection) Kraft Paper Contribution of aquaculture to location eutrophication As shown in the table below, the contribution of aquaculture to regional nitrogen and phosphorus loads is less than 3% in Portugal, Spanish and Finland, whereas aquaculture has an important impact in Scotland and Norway (more than 25%). Contribution of aquaculture to regional nitrogen and phosphorus loads total Nitrogen (t) total Phosphorus (t) Aquaculture Nitrogen (t) Aquaculture Phosphorus (t) % Aquaculture contribution to total Nitrogen % Aquaculture contribution to total Phosphorus Portugal ,1% 0,2% Spanish Atlantic ,4% 0,5% Finland % 3% Irish Atlantic % 12% Scottish Atlantic % 27% Norway (North + Norwegian Seas) % 114%* Source: EEA *This figure is greater than 100% but the source doesn t provide any explanation. Institute for European Environmental Policy together with BIO, and VITO 63

64 External costs of environmental impacts Method and data Externalities (or external costs) are the costs imposed on society and the environment that are not accounted for by the producers and consumers, i.e. which are not included in market prices. They include damage to the natural and built environment, such as effects of air pollution on health, buildings, crops, forests and global warming; occupational disease and accidents; and reduced amenity from visual intrusion of plant or emissions of noise. The integration of a financial axis in LCA allows policy makers to get a picture of the approximate financial implications of environmental impacts linked to product or process life cycles. The IPP study performed by BIO for the Commission in was a first attempt in developing a suitable methodology to integrate external costs in LCAs. In the present study, the purpose was not to elaborate a new methodology. Instead the starting point was from what was developed in this IPP study : the external costs factors were compiled and applied them to the environmental impacts quantified here. Method used for environmental impacts monetisation For each environmental impact, the calculation method consists in: Where EI x ECFei = ECei EI = quantification of the environmental impact under consideration (e.g. for air acidification, X g SO 2 equivalent) ECFei = external cost factor related to the environmental impact EI under consideration (e.g. for air acidification, Y Euros / g SO 2 equivalent) ECei = external cost obtained for the environmental impact (in Euros) The total external cost EC is then the sum of the ECei of all the environmental impacts assessed. External cost factors used External cost (Euros/ unit) Unit min max Photochemical oxidation kg C2H4 eq Acidification kg SO2 eq Eutrophication kg PO4 eq Global warming (GWP100) kg CO2 eq Source: Various sources compiled by BIO IS, (incl. ExternE, CML, Spadaro & Rabi) Remark: Ranges are used for external cost factors to reflect the diversity of values existing in literature for the environmental impacts monetised. 40 IPP study = Study on External Environmental Effects Related to the Life Cycle of Products and Services, by BIO Intelligence Service for European Commission - DG Env, February 2003 (page 71) 41 IPP study by BIO IS (page 71) Institute for European Environmental Policy together with BIO, and VITO 64

65 Externalities covered by those cost factors are summarised in the following table: Mortality Human health Morbidity (chronic disease) Effects monetised Morbidity (acute disease) Ecosystems Material & building Forests & crops Global warming potential Air acidification Photochemical oxidation Eutrophication 42 Limitations It should be first noted that scientific knowledge about environmental impact monetisation is still under important development. For instance, for SO2, external costs in CAFÉ (2005) 43 are between and Euros / t, whereas in other reference sources (Spadaro & Rabl, 1999 and RDC & PIRA, 2001) they were between 146 and (values used in this factsheet). More research would be needed to fully explain the origin of these differences, which is not compatible with the limited resources of the present work. However, part of the explanation seems to be linked to the fact that in CAFÉ the value associated to the human life was multiplied by a 10 factor compared to previous studies. Apart from the uncertainties which are directly linked to the monetisation methods themselves, some limits occur when combining results from monetisation and LCA. One limit of the overall approach is linked to the fact that it combines potential global impacts (LCA) with actual location and source-specific external cost factors (monetisation). On one hand, the environmental impacts quantified through an LCA approach are indeed both potential and global: Potential because the actual fate of the impact factors (emissions) in the environment and the exposure of natural systems (humans and other living systems) to these impact factors are not considered in the computational models used in LCA approach. Global because emissions which occur in different locations at different times are simply summed throughout a product system lifecycle. This method is valid for emissions which contribute to an environmental impact in a cumulative manner (greenhouse gases or ozone depleting substances). But for others impact categories (human health, ecotoxicology, eutrophication ), this method conducts to an overstatement of actual effects. On the other hand, monetisation methods aim to address the location and source-specific nature of impacts associated with emissions to air, water, land. For instance, the implications of emissions from a 50 m stack are very different to those at ground level. 42 Abatement costs at sewage or industrial plants to reduce emissions contributing to eutrophication 43 CAFÉ (2005) Damages per tonne emission of PM 2.5, NH 3, SO 2, NO x and VOCs from each EU25 Member State (excluding Cyprus) and surrounding seas Institute for European Environmental Policy together with BIO, and VITO 65

66 These general limits are further discussed in the IPP study performed by BIO in section Another limitation comes from the fact that the scope of external costs and the scope of environmental impacts quantified in LCA do not coincide based on the current state of the art: External cost factors do not exist for all the environmental impacts quantified in LCA. On the contrary, some environmental impacts not quantified in LCAs may generate external costs. For that reason, the values indicated here are to be used with extreme care and more for comparison purposes (relative contribution to total external costs for instance) rather than for the absolute values. Results for aquaculture in Europe 2005 External costs of aquaculture (Eu25, 2005) External cost (Million Euros/year) min max Photochemical oxidation 2 3 Acidification 0 4 Eutrophication Global warming (GWP100) 8 21 Total This total external cost of M Euros represents about 2% of the annual value of the sector (3.9 billions Euros). Also it is useful to put those figures in perspective with external costs from other activities. For instance, in a recent study focusing on the ELV directive 44, the external cost linked to end-of-life vehicles (ELV) treatment was assessed between 2 to 10 Euros / ELV (depending on the recovery and treatment options) i.e. about M Euros for Eu For the entire European economy, the external cost was assessed 46 between 220 and 960 Euros / capita per yr, i.e. 100 to 440 billions Euros A study to examine the benefits of the End of Life Vehicles Directive and the costs and benefits of a revision of the 2015 targets for recycling, re-use and recovery under the ELV Directive, by GHK and BIO Intelligence Service for European Commission - DG ENV, millions ELV to be treated in Eu25 46 Study on External Environmental Effects Related to the Life Cycle of Products and Services, by BIO Intelligence Service for European Commission - DG ENV, February They covered the impacts on the environment and on human health generated by: air emissions (stratospheric ozone depletion, air acidification, global warming, photochemical oxidation, human toxicity, human health effects caused by dust and dioxins), water emissions (only partially for eutrophicant emissions, but other emissions into water are not taken into account) and solid waste (disamenity caused by incineration and landfilling) Million inhabitants in Eu25 Institute for European Environmental Policy together with BIO, and VITO 66

67 The monetary impacts can be further subdivided in different steps of the aquaculture production in order to illustrate that the most critical phase is the fish farming. Here an example of impacts caused per tonne of trout is given. Feed Raw Feed Manufacturing Hatcheries Fish Farming Total min max min max min max min max min max Global Warming euro 11,46 28,95 1,87 4,74 0,1 0,24 0,16 0,41 13,59 34,34 Photochemic al oxidation euro 3,05 3,89 0,74 0,95 0,01 0,02 0,1 0,13 3,9 4,99 Acidification euro 0,54 5,43 0,09 0,92 0 0,01 0,01 0,12 0,64 6,48 Eutrophicati on euro 2,28 2,28 0,12 0,12 0,79 0,79 71,33 71,33 74,52 74,52 Total euro 17,33 40,55 2,82 6,73 0,9 1,06 71,6 71,99 92,65 120,33 Percentage of total 18,71 33,70 3,04 5,59 0,97 0,88 77,28 59, Institute for European Environmental Policy together with BIO, and VITO 67

68 Annex D: Analysis of Environmental Impacts of Aquaculture (Qualitative Impacts) Content of this annex: D1- Alien species introduction General definition Aquaculture s role in alien species introduction D2- Fish escapes and biodiversity consequences D3- Ecotoxicological impacts due to antibiotic and metal use for fish farming Impacts on fish and shells Impacts on human D4- Indirect issue: pressure on wild fish stocks Data used Final consumption of fish D1- Alien species introduction General definition Source: Europe s water: An indicator-based assessment European Environment Agency Topic Report A non-indigenous species (also known as alien, exotic, invasive, non-native) is defined as an organism in an ecosystem other than the one in which it evolved. Because it did not evolve there, it may cause havoc in its new environment, for example, by predating on and competing with native species, and disrupting food webs and introducing diseases. Non-indigenous species enter new ecosystems by being either intentionally or accidentally transported and released by man or by extending their geographical range following natural or man-made changes in the environment for example, the construction of the Suez Canal. Aquaculture s role in alien species introduction Source: Europe s water: An indicator-based assessment European Environment Agency Topic Report Institute for European Environmental Policy together with BIO, and VITO 68

69 Introduced freshwater species with an ecological effect Countries Included: Austria, Belgium, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovak Republic, Spain, Sweden, Switzerland, UK. Mode of introduction of non-indigenous species into regional seas About 660 alien marine species have arrived in European coastal waters through shipping, aquaculture and other man-made activities. The Mediterranean Basin has received about 500 such species mostly via the Suez Canal. Institute for European Environmental Policy together with BIO, and VITO 69