Marine Harvest ( Scotland) Ltd. Glenfinnan Fish Farm. Production Increase Proposal 2017 A I

Transcription

1 Marine Harvest ( Scotland) Ltd Glenfinnan Fish Farm Production Increase Proposal 2017 A I 1 4,

2 3lenfinpa Glenfinnan Fish Farm Production Increase Aoolication Marine Harvest currently has a CAR licence to produce 225 tonnes of salmon smolt per annum at Glenfinnan Fish Farm in Loch Shiel. The company is applying to increase the consented annual production by 20%, which is a 45 tonne increase, to a total of 270 tonnes. This increase would support the company' s ongoing expansion plans which are vital to allow us to continue to compete with our global competitors and thus gain further investment into Scottish fish farming. Fish farming operations have existed in the loch for over 30 years and there have been no loch chemistry issues during that entire period. bar^ V G Bheinn Ursainn StrPap Creag 511 Blran Stios Carbh 6 3 Spurr an 796 9( en skill Colas- drarn Wh'? nochan c; o nveraiot 2Tc_.. Beir an Beinrr- Darirrr Odlra Mhcr 569 N I Fradadr ` Drtutnsallie Croix, 682 % nt, t lot Kinloc Loch A Beinnsouth Odhar& Bheinn IV Sg rrr SgarrCraobh a' ch V. / qi Beinn j 4' 64 Gaire 5 ( huibhsadrain > G\e N a. / to Sta I Garvan 1 Figure 1. Glenfinnan fish farms ( Salmon Bay NM the northern site - and Black Bay NM the southern site) Consent History Marine Harvest farms within Loch Shiel have held consent to produce 225 tonnes of salmon smolt per annum since Prior to this ( since early 1980' s) the loch held a total consented annual tonnage of 165 tonnes. An application was made in 2006 to increase the production from 165 tonnes per year to 225 tonnes per year. This was granted in 2008 on the basis that the modelled effect of the increase did not result in total phosphorus concentration increasing to levels which would risk degradation of the WFD classification or the oligotrophic status of the loch. In 2011 the South Loch Shiel sites were closed and all of the licensed production tonnage was consolidated into the Glenfinnan site at the north end of the loch. Loch Shiel Environmental Conditions ( WFD) Loch Shiel is currently classed as " Good" under the terms of the WFD and has been since 2012, with the latest reported total phosphorus ( TP) value from SEPA' s sampling regime being 5. 9ug/ I. OECD classifies lochs as oligotrophic if they have p levels between 4ug/ I and 10ug/ l. The majority of WFD ecological indicators are rated as being " High" class and have

3 been since 2007 ( including all biological factors such as phytoplankton and macrophytes). It is worth noting that, as far as MHS are aware, SEPA have not carried out site specific macrophyte sampling in Loch Shiel in any recent years. A survey performed by Ecus in 2016 report and data appended to this document) has confirmed that the latest macrophyte classification should be " good". This is not a reflection that the condition has deteriorated as the original classification by SEPA was not assessed via sampling at the site and therefore it is likely that the classification should have been " good" all along in- line with the overall loch status. The Ecus report also notes that " there is nothing to suggest that the rooted vegetation has been significantly affected by nutrient enrichment associated with the current fish farm location." Paeleoecological Study In 2007 the Environmental Change Research Centre was commissioned by Marine Harvest to carry out a palaeoecological study of Loch Shiel; this was done as part of an application to increase the licensed annual production tonnage at the sites. The survey methodology took a core sample of sediment from a deep area around 2km south of the Glenfinnan Black Bay cage group location. Segments of the core were evaluated for age by using radiometric dating which showed, alongside measurement of depth, that sedimentation had occurred at a regular rate throughout history. The core materials dated back to around Total phosphorus concentrations were inferred from each sub - sample via analysis of diatom content. The study concluded that Loch Shiel was oligotrophic during the late -nineteenth century and that there had only been minor changes to the diatom composition within the sediments in the loch between the early 1980' s and The report surmised that fish farm production had not had an adverse impact on the diatom flora of the loch. This indicated that the fish farming had not significantly changed the ecology of the loch. s 0 Ohl 010 ZL LUD) Olde] o V WOO a ti v: N a m Figure 2 ( extract from palaeoecological study). Diatom inferred total phosphorus levels within Loch Shiel ( 1880 to 2007)

4 Phosphorus Monitorin MHS has contracted the University of Stirling to independently monitor phosphorus levels in Loch Shiel since Samples were taken twice per year until 2005 at which point the frequency of the regime was increased to bi- monthly to provide 6 sampling episodes per year. From the outset the sampling has been designed to provide an indication of levels throughout the entire loch and therefore samples are taken from a spread of locations as shown in Figure 3. At each location samples are gathered from Om depth and 5m depth. T 1 ia. l Figure 3. Sampling locations within Loch Shiel. Yellow = University of Stirling, Orange = SEPA SEPA also carries out sampling on Loch Shiel, taking a sample once per month from a single sample point shown in Figure 3. MHS commissioned data analysis specialists TL Science to statistically examine the two datasets and compare the Stirling dataset against the SEPA dataset ( report appended to this document). TL Science identified the following conclusions: Both datasets contain a large amount of variation when looking at data from individual sample locations. There is no evidence for any overall year on year change or trend in phosphorus level in Loch Shiel according to either dataset. This also means that there is no evidence of any change in phosphorus level brought about by the production increase in The two sampling regimes are not directly comparable due to the differences in their designs in terms of sample locations, replicate numbers and frequency of sampling. An argument can be made that the Stirling sampling regime is more likely to reflect a robust mean of the overall phosphorus levels throughout the loch. Multiple sampling sites, as used by Stirling, would be better able to capture the natural and experimental variability and thus provide a more representative indicator of phosphorus levels; the single site sampling method used by SEPA would be less robust.

5 Figure 4. Sample location for SEPAs TP data for Loch Shiel Figure 5 shows the mean monthly phosphorus levels in Loch Shiel since January 2009, the period which followed shortly after the last increase was granted in The data suggests a downward trend. The 2008 application calculated ( using OECD equations for management of eutrophication of waters) that the additional phosphorus load arising from the proposed tonnage increase at the time, 60 tonnes) would be 0. 82ug/ l; this level of increase is not apparent in the sampling data from the University of Stirling. This suggests that an increase in production tonnage is not directly linked to increased total phosphorus within the loch. It also suggests that model predictions are overly precautionary and actual levels of increase, if any, are likely to be far less. Using the same equation to calculate the theoretical TP increase with the 2016 proposed additional tonnage suggests an increase of 0. 50ug/ I would occur. If added to the SEPA reported loch level of 5. 9ug/ I then this would lead to a new level of 6. 4ug/ I, which is well within the site specific TP boundary of 8. 73ug/ I for Good to Medium classification.

6 Monthly Phosphorus Levels In Loch Shiel: Stirling Data ( ) 1s c 10 La LnLn M M o i H. LnW N N ra m m m a 7 a 1 C i- a c >- a c a a c i n c a 0. c } a c }- a c m : ME v a M I [ c 121 v ti 2 an rs o m v v n Month/ Year Figure 5. Monthly phosphorus levels in Loch Shiel since January 2009 ( Results from University of Stirling) SEPA has a sampling dataset from a single sample point location within the loch; the results of this are shown in Figure 6. The results show a large degree of variation which may be skewing the trend; this could also be indicative of a very large amount of natural variation. The Stirling data by comparison covers a larger number of sample locations and displays much less variation. The distance of SEPA' s sampling location from Glenfinnan fish farm and proximity to the loch' s outflow are further reasons which could contribute to a dataset which is misrepresentative of whole loch conditions, or those local to the fish farm at the opposite end of the loch. Mean Phosphorus Levels In Loch Shiel: SEPA Data ( ) 1s 16 c 14 tw LC. O 8 0. ar- 7a W Ol Ol m O O O rl rh rl N N N m m m r Ln Ln Ln ld C T Q C Q C? Q C? Q C Q C >- Q C T Q fd Q1 c0 ( O N CO fa 4J f0 f0 Q1 ( 9 C6 v f6 fb v fd f6 v f6 2i vi : 2 v) : E U) 2 V Z> N 2i Ln 2i V1 Month/ Year Figure 6. Monthly phosphorus levels in Loch Shiel since January 2009 ( Results from SEPA)

7 Plus+ Modelli The James Hutton Institute ( JHI) produced a report on the current phosphorus status of the loch and its capacity to support additional input. This work was carried out by using the Plus+ model which was developed by the JHI based on OECD derived eutrophication management calculations and land use/ slope data. The modelling methodology was designed specifically to mirror the approach used by SEPA to assess applications for additional phosphorus loading. Loch Shiel is currently graded as having " good" WFD status for phosphorus with a current level of 5. 9ug/ I. The boundary between " good" and " moderate" status is 8. 73ug/ I. The JHI notes that there is capacity for an additional phosphorus input of 3872kg per year before the classification of the loch would change from " good" to " moderate"; an input of 2978kg per year would be required to change the RAG status to amber. SEPA provided a pre -application review of the JHI report which concurred with these capacity statements. The application is therefore conservative in terms of how it relates to environmental capacity as it would only add an additional 324kg of phosphorus per year. Phosphorus Inputs: FCR and Diets Fish farming feed conversion ratios ( FCRs) have improved massively since the farm was installed in the 1980' s and also significantly since the last production increase was granted in This improvement is due to advances in feed composition, equipment, site management and feeding practices. Phosphorus content of feed has also been reduced over the years as feed composition has been improved; Table 1 shows the makeup of example diets fed at MHS loch sites based on a mean phosphorus content of 1%. This diet has already proven successful, retaining high levels of FCR performance and fish quality. Marine Harvest proposes to use diets of 1. 1% phosphorus content ( or less) at the Glenfinnan site. Table 1. Example feed types and phosphorus content Feed Type Proportion of Site Feeding Total Nutra Advance 2 ( 1. 2mm) 2. 6% Nutra Advance LP % mm Nutra Advance LP % mm Nutra Advance LP 50 3mm 55. 2% Average Phosphorous Content Level Diets have improved so that they are more attractive and accessible to the fish, and so that the proportion retained within the fish and converted to growth is as high as possible. Feed delivery has vastly improved so that pellets can be supplied to the fish in an incredibly accurate manner; both in terms of time keeping and spatial distribution. The continuing improvement of automated systems for feed delivery continues to allow reduction of FCRs as human resources can be increasingly used for enhanced levels of control rather than physical labour. The consolidation of the Shiel sites, which was granted by SEPA in 2011, is one of many site improvements which resulted in better site management and equipment. Key factors in this

8 include better control over fish health and welfare and also better behaviour monitoring particularly via investment in underwater camera systems). These measures have all played a part in improving FCR and reducing phosphorus input to the environment. Table 2 shows calculations for the amount of phosphorus discharged into the loch when considering various different scenarios. As mentioned in the paragraphs above, the current and forecasted FCR, is lower than it was historically and this has been reflected in the calculations. The figure highlighted in red shows the projected phosphorus input arising from the proposed additional tonnage. This represents 8% of the available capacity within the loch and therefore is extremely conservative. Table 2. phosphorus inputs from Marine Harvest' s fish farming in Loch Shiel. Input per Tonne Shiel Potential Shiel Proposed Based on Current Additional Additional Input from FCR Capacity to 45 tonne Production Moderate Increase Phosphorus in feed: Feed Conversion Ratio ( FCR) Max Production 1, , 000 kg per annum) 537, 800 Proposed increase in production) Feed Input (kg per 1, , 500 annum) 591, 580 Total P in Feed kg) 6, 507 P entrained in fish kg) Note: this is based on 40.5% of phosphorus within feed being remaining within the fish Amount of P , ( note: this figure discharged ( kg per is only 8% the annum) available capacity noted in the cell to the left) P discharge per kg production ( kg) Medicine Medicine Use Use The The proposed proposed increased increased tonnage tonnage of of fish fish arising arising from from this this site site will will not not require require an an increase increase in in medicine medicine consent consent quantities quantities as as there there are are currently currently no no plans plans to to increase increase the the number number of of pens pens at at the the site. site.