THE SCOTTISH SALMON COMPANY s (LOCH FYNE FISH FARMS) SEA LICE CONTAINMENT AND WELL BOAT BATH TREATMENT PROPOSAL

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1 COAST response to: THE SCOTTISH SALMON COMPANY s (LOCH FYNE FISH FARMS) SEA LICE CONTAINMENT AND WELL BOAT BATH TREATMENT PROPOSAL The proposal The company has submitted an application to Marine Scotland under the Food and Environmental Protection Act 1985 Part 2 Deposits in the Sea (FEPA) for approval to discharge pollutants into the sea from wellboats. There is nothing really new here in that the pollutants are all well-known chemicals or medicines in widespread use for the treatment and containment of parasitic lice infestations of farmed salmon. A description of these chemicals and the way they are used can be found in a recent scientific paper published on the COAST website. These chemicals are either administered through the food over a longer time span or applied in quantity in a method known as a bath treatment where tarpaulins are used over a period of hours to line the cage reducing the tidal flow and flushing of water and thus increasing the contact between fish and chemical before the chemical is lost through dilution and migration into the surrounding environment. Bath treatments require considerable manpower and understandably must be relatively inefficient in gaining contact between fish and chemical. TSSC s proposal is to conduct exactly the same process but transferring the caged salmon to the containment tanks or wells of a wellboat and conducting bath treatments in these tanks before placing the treated fish back in the cage. Having conducted this exercise it is then necessary to get rid of the spent seawater with residual chemicals. This requires a licence to discharge under FEPA in the same way, as any other offshore activity would be regulated in terms of discharges. The Fisheries Research Services Marine Laboratory in Aberdeen administers the UK act on behalf of Scottish ministers, so Marine Scotland, not SEPA and this in itself raises questions of who does what in terms of policing the act. Licences are apparently issued for a twelve-month period so in the Loch Fyne case there is the possibility of revisiting the impact of the newly licensed process before too much damage is done. The comments provided here are solely based on the content of the four documents provided and a more general understanding of what goes on at a fish farm in terms of sea lice containment. The four are :- A formal application for discharge under FEPA A statement of the best practicable environmental option BPEO (an evaluation that covers all options for disposal on the both technical and economic grounds, the key here being acceptance of realistic cost built into the legislation) (Annexes are missing) Two maps identifying the location of TSSC fish farms in Loch Fyne

2 Why the change in practice?! Essentially TSSC claim that the old method of fitting tarpaulins each time a bath treatment is required is logistically difficult now that cage sizes and biomass stocked has increased. TSSC claim that the job can be done more efficiently using wellboats and that this efficiency of treatment means less chemicals are used. What can be extracted from the documents that provide any comfort that this is a better approach BUT more importantly what can be gleaned that raises concerns about TSSC practices and additional environmental impact? TSSC practices and the formal application The FEPA application has been prepared by Rebecca Dean, TSSC s environmental manager, a well-known name from past skirmishes with COAST. The explanatory notes provide a guide as to what is required of the applicant. Apart from the focus on the BPEO it is worth noting here that SNH might well have been asked to comment on significant environmental impact and it would be worthwhile catching up with them. The process of application is required to be placed in the public domain so all the supporting material should be available for reference and be free for discussion. The mechanism for representing public views is not identified. There are a number of key issues that arise from a reading of the licence application. The rationale for the proposed discharge stated in Section 9 starts to ring alarm bells. This states that in Scotland reliance on in-feed medicines such as SLICE has compromised product efficiency. This is tantamount to saying that sea lice have become resistant to emamectin, not a new story! Attention is then drawn to the fact that Loch Fyne has had incidences of sea lice infection and that this is related to the ever increasing biomass stocked in the loch overall. Thus it is implied there is or has been on occasion a loch wide problem and therefore by inference a loch wide solution is needed. This is where the TSSC highly effective treatment strategy referred to in the application comes in. This is said to involve :- A single loch - single company policy. This implies a loch wide approach to control of infestation not just confined to individual farms Synchronicity. This suggests again a loch wide approach and represents an acknowledgement that sea lice infestation at one farm influences another and therefore by implication can affect the wild salmon population throughout the loch Initiating treatment at lower trigger levels. This means more preventive treatment which makes sense at one level but suggests that more quantities of medicine might be needed Using in feed medicines for longer periods. This definitely does mean more medicines are used Quick series of treatments relying on bath medicines late in the production cycle.

3 If this is indeed an attempt to try and contain sea lice throughout Loch Fyne or a part of the loch where TSSC operate an answer is required to the following. What are the implications in terms of effects in the marine environment of using what are well known and approved chemicals (medicines) in the industry but in quantities and in ways that seem not to have been the subject of any overall environmental impact assessment of the loch. There is a regulatory regime in place for each of the 10 fish farms in question and this is administered by SEPA under their consent procedure, which is based on establishing site-specific environmental quality standards. These limits of concentration, set at a certain agreed perimeter, are designed to contain any impact within the operation and in particular the sea bed sediment condition. Site-specific calculations using a standard mathematical model of likely dispersion characteristics are used to determine the maximum amounts of medicines that can be used without exceeding the assimilation capacity of the surrounding waters and sediments. What is not clear at all is how the licensing procedure and outcomes of each specific fish farm licence will be applied to this new proposal to use well boats and different regimes for bath treatment, the subject of the FEPA application. TSSC propose that the spent seawater containing the residual bath medicines be discharged at the fish farm site. This makes sense at one level BUT there is no indication anywhere in the paperwork of any cooperation between the regulatory agencies or any joint consultation. Surely it is necessary somewhere to say that regardless of the technique applied and subsequent approval to use wellboats that the overall outcome will be no different from what SEPA have already consented and that SEPA will go on policing the site as before with the same tools and standards they have already established? The implications are that the loch wide approach, the increased frequency of treatment, the synchronised timing, longer in feed treatments all add up to more medicines in quantity and range being used with greater impact at both individual sites and across the loch as a whole. Yet there is no evidence of SEPA being involved with these new proposals. TSSC claims in the application that environmental assessments have been conducted for each site. There must be doubts however that these statements take into account the new regime of treatment. Apparently the documents in question are lodged with Argyll and Bute Council in Oban. In summary the key here is to find out whether TSSC are bypassing the existing regulatory constraints applied by SEPA in applying for a consent under FEPA. If SEPA have been involved are they supportive of the proposals in that the new approach will still manage to maintain the present standards set for each site? Finally has any overall environmental assessment been conducted of the whole of Loch Fyne to determine the effects of essentially waging war on sea lice in a coordinated way throughout the loch with implications for other crustaceans and the marine ecology generally? The Best Practicable Environmental Option Statement

4 This document does provide a very useful description of the chemicals to be used, the suppliers and the form they are applied and can be read in conjunction with the COAST website paper on sea lice chemicals. The one addition to the list previously reviewed is Deltamethrin, which is a synthetic pyrethroid like cypermethrin. It is a wide spectrum insecticide more commonly used for mosquito control. Section 1.3 does draw attention to the site-specific maximum quantities of the various standard medicines currently approved for use at the listed sites. Presumably the mass and volume calculations are based on the nature of the materials as supplied i.e. liquids of certain concentration etc. This does hint that TSSC do not intend to exceed these existing limits with the new approach but this is not overtly or convincingly stated anywhere. Section 1.4 draws attention to TSSC standard operating procedures for wellboat treatment operations implying this is done elsewhere and it would be useful to refer to Annex 2 of the BPEO document Section 2 gets to the core of the BPEO approach and is self explanatory with the obvious single option of discharging spent bath seawater at the fish farm being practicable as Marine Scotland would forbid that same chemically contaminated water being discharged at a remote location. The document does suggest that the Area Management Agreement (AMA) for Loch Fyne and the Firth of Clyde between other interested parties does provide a basis for consultation and for coordination between companies raising farmed fish in the region. How far consultation within this body has progressed remains unknown and unreported. It is however suggested that this cooperation prevents cross-contamination between sites. There is also the statement that all chemicals will be discharged away from mussel farms or areas known to support crustacean fishing. A further annex provided with the original document is said to provide an account of the quantities of medicines used in the Loch Fyne area over the last five years which presumably conforms with the annual pollution inventory reporting of SEPA available on their website. Conclusion Overall what is being proposed could be a positive move in that is could reduce the overall quantities of medicines used at the various facilities in Loch Fyne from year to year. All these chemicals are in common use already. The evidence for this claimed reduction is however elusive and the vital link between those agencies approving operations appears inadequate at best. There is a real risk that the salmon farming industry will try to throw everything chemical into the battle to defeat lice in Loch Fyne where clearly a major problem exists which is in danger of running out of control; at least that is the inference gained from reading between the lines. SEPA already contains the impact of chemicals on the marine environment through its modelling of dispersion and setting of limits in permitting. Are these same limits going to apply with the new treatment regimes, which includes the use of wellboats?

5 The infestation problem seems to have reached proportions in Loch Fyne where there is a real risk that the industry in its desire to contain an attack on its very survival takes measures that are coordinated throughout the loch and which in turn have a major impact on the entire marine ecology of the loch. If this is indeed so then is it of any importance. Only a loch wide impact baseline study and impact assessment would answer this question. Finally what part do other operators of fish farms in Loch Fyne play in this synchronised approach? John M Campbell 17 April 2011