 Fy loedd yn fawr i'r 5th gyrscrifeis ar y syniadau yma i'r Prif Weinidog, i'r cwrs ac i'r gŵr yn ymwneud wrth yr ydych chi'n gweithio'r cymdeithas i'r bwrdd hynny yn ei ffawr i'ch gweithio'r cymdeithas i'r Cyfrwyr Iesifolau. I want to remind everyone present to switch off electronic devices of any description as they may affect the broadcasting system. Can I also welcome Edward Mountain MSP to the meeting? Mr Mountain is attending in his capacity as an individual MSP in this instance. We move to the first item on the agenda, which is for the committee to consider whether to take item 3 in private. Are we all agreed? We are agreed. The second item on the agenda is to take evidence from two panels on the committee's inquiry into the environmental impacts of salmon farming in Scotland. Before we begin, I would like to remind everyone present that the focus of the committee's inquiry is on the report commissioned by SPICE and undertaken by SAMS into the environmental impacts of salmon farming in Scotland. We will therefore not be discussing any non-environmental issues today. The committee's report on this work, however, will be considered as part of the rural economy and connectivity's wider inquiry into salmon farming in Scotland. I therefore ask all the witnesses who will be giving evidence today to restrict their responses to environmental impacts only. Let me welcome the first panel, John Acheson, who is a member of the Friends of the Sounds of Dura. Sam Collin, the convener of the Scottish Environment Link Aquaculture Subgroup, and a marine planning officer at the Scottish Wildlife Trust. David Sanderson, general manager of the Scottish Salmon Producers Organization. Gentleman, welcome. Let's get right into some questions. Can I ask you whether you think the environmental impacts and concerns regarding salmon farming have changed in any way since 2002, or are they fundamentally the same? Sam Collin. I think the salmon's report highlights a lot of key concerns that we consider very important. But what's worrying for us is the fact that some of these key questions we still can't answer, and they were questions that were raised in 2002. So we've got a growing body of evidence that shows that there's a case for an environmental impact on the environment from salmon farming, but we're still lacking enough data to clarify what that impact is. So without answering those being unable to answer those questions, I don't think that we've seen much change in the actual practices of salmon aquaculture. David Sanderson. Yes, if I may. I welcome the opportunity to come here and discuss the report, and it's very good that you've taken a view that you're looking at that in comparison to where you were with the 2002 report. It's fair to say that the risks associated with the business of salmon farming will be exactly the same risks. They're well-quantified, well-known risks. The issue that probably comes out of the report is whether or not we understand the impacts of activity, and have we got the right information in Scotland to measure that impact? I think the report's quite reassuring from that point of view, and so far as when it looks at the actual analysis of those risks, then it puts most of them in the category of being quite low. Clearly, there are one or two that are very... I'm sure they're going to get your focus. They are the risks that are still being dealt with and managed, and we're going to have to continue to find the answers that we're still seeking in those areas. I think that's the important bit that we need to discuss more today. John Heson. I can't agree with that, I'm afraid. The problems are the same, but the scale of the problems is much worse. There's been an enormous increase in sea lice. Solid proof that the sea lice affect populations of wild salmon, including sea trout, not just salmon. The pollution aspects are much clearer now than they were before. The pollution of 45 sea locks with industrial chemicals, the chemical use is enormously higher because of the sea lice. It's on a different scale and the impacts are much larger. What about the science and the data that's available to inform policy in this area? How much progress has been made since 2002? How much better is our understanding of the impacts? There's no information on almost every subject when you look in there. Every category says it's amazing how little information there is. One of the big ones is why is there so little information from Scotland, which is the excuse for not dealing with sea lice usually, when Norway and Ireland and other countries are doing enormous amounts of work on that and it's not done here. It's fair to say that when you look at the issues that face our industry, fish health and the aspects of fish health that are most important to success, if you like, in growing our livestock, is the core of our business. In that regard, we understand and acknowledge that there are gaps in data and we could definitely enhance that further. In that regard, I would like to confirm today for the committee's benefit and for the wider public that industry has been chasing for a long time now about supplying information on sea lice numbers in the farms in Scotland. I can confirm that from here on forth with, we will be publishing all data associated with sea lice counts on farms on a farm-by-farm basis in Scotland. That backs up the decision of the industry SSPO board that was taken in November last year and is now in the public domain. Why now? We believe that we need to move the debate forward. We hear all the arguments, we hear all the background noise but we want to have a proper, open, honest dialogue about the actual status of farm sites in Scotland and if people feel that that data can be of use to the scientific and research community and can move us forward, then fine. Absolutely no problem whatsoever in being completely open and transparent with that data. There's nothing whatsoever that we wish to hide away. Given the concerns that have been expressed previously about how that data might be used, would you be publishing with a time lag? We haven't got to the point of the actual detail. Never do we have to have some time lag because it takes time to gather it and check data before you can actually release it. I think that there's some detail that's under discussion at the moment within the group that's been formed to look at the fish health framework for Scotland for the next 10 years. That's a government and industry group that has representatives from many regulators on board and in that group I believe the detail of how that data should be used and published will be part of their remit. Sam Cole, I think that you want to come in. Yes, thank you. First I would just like to say that it's welcome news that the industry will be publishing new data but the concern being that we would like to see historical data published as well. When we're talking about adaptive management and learning from impacts and data collected that takes time to collect data. It takes time to monitor and that will delay any action and any conclusive results. With the historical data we can begin with a wealth of data and start making changes now. Davies Sanson, you're nodding your head. Is that going to be available? I think again we are very happy to look at what we can provide that would help the debate. There is data there because it's not as if the industry hasn't been gathering and publishing this data. It's been published in regional format for the last five or six years in quite big detail. So I think we need to look at that data. Data is extremely important. We need to know how to use it for the best advantage of all. Ron Eitcheson. This is welcome but it's been forced by the information commissioner enforcing a decision which the Government refused to do which was to publish this data because the industry said they didn't want to initially but it's good that it's happening now but what the aggregate data that has been before has concealed is the massive spikes of sea lice in many farms. For instance, one in Shetland has 20 sea lice, adult female sea lice per fish when the threshold for action is eight and eight is very high the threshold for action used to be one so that was the code of good practice threshold for action. So if those spikes, those are the ones that are doing the biggest harm and that information needs to be not just published but acted on instantly as a billions of sea lice produced by those farms kill sea trout and damage and kill salmon. Mark Ruskell. Will the industry also be publishing data on salmon mortality broken down by farm with the reasons for those salmon morts as well broken down? The answer to that is yes. We will provide mortality data at farm level and we will give commentary on any disease issues that may be associated with that mortality from time to time. Will that be historical data as well alongside the sea lice? Part of the commitment that we've made with the fish health framework group that's sitting looking at the 10-year strategy is that we're going to provide five years of historical mortality data that will be annualised and it will be comparative year on year and at the moment we have that data up to 2015 clearly 2016 and 17 we still have to complete the production cycles for those years. We'll be straight into sea lice and I think we'll move to that in a second but before we do a question about the more general direction of travel as a scene setter any of you or all of you point to examples where the growth of the sector has been influenced by the precautionary principle? It's very interesting hearing Professor Faspo when you asked him that question on behalf of that whole panel about the scientific evidence that he squirred around and said there's been an attempt to work together historically that was the precautionary principle that has been annunciated to this committee that was very poor there's none that's not been applied David Sanderson There are a plethora of examples one of them is that there's an arbitrary limit on the scale, the maximum scale of a salmon farm site in Scotland that's been in place for a long long time so the modelled scale of a farm in Scotland can only be a certain size so that is basically because of an element of precaution within every consent that's given for the activity on a salmon farm the environmental quality standard that's used to set that consent is set at a very precautionary level and for that reason alone there's significant precaution built into the consenting process our consenting process in Scotland is world leading we're renowned for having a strong regulatory background for what we do in Scotland and I think we have to acknowledge that built into that will be an element of precaution Sam Cohen I just wanted to pick up on the 2,500 ton limit on salmon farms that's actually a limitation of the depot mod model that's been used which so that's why it's been an arbitrary limit it's not been a precautionary limit and secondly the new depot mod model has vastly improved the old model and therefore this 2,500 ton limit has now been removed and we're seeing more interest in much larger farms now Okay We've already gone in for a 3,500 ton farm Okay, thank you Let's address the CLI data in greater detail now Claudia Beamish Good morning to you all it is indeed a welcome statement that you've made today David Sanderson about the CLI's data You'll recall no doubt that I took through an amendment which didn't actually become law in the aquaculture bill about farm by farm reporting Can you give us more detail please for the record today about what you mean by real time and why there would be a delay on that Could you go into detail on that and could you also tell us and then I'd like to move to comments from the rest of the panel as well about whether you see or indeed other panel members see a reason for making this a statutory obligation in view of the fact that not all the members not all the salmon farms are members of your organisation and I'd like a comment on that and also on whether there's the opportunity to make sure that salmon farms are protected which I understand at the moment it's only salmon within the cages that would be affected which is a broader question than perhaps you can answer OK, you've asked me quite a lot there OK, let's look again at what we mean when we say we'll publish everything and I'll explain or paint a picture of what actually happens on farms Every single salmon farm in Scotland counts its sea lice levels on a weekly basis and that has to be resourced it has to be properly recorded that information has to be gathered at first of all company level then it has to be passed on and collectivised so there's an inevitability that that will take more than a week and we anticipate and subject to agreement with all parties including the regulators we would anticipate that we will we will look at farm by farm probably on a month by month basis clearly there'll be some lag in the timescale for presenting that publicly it's really difficult for me at this stage to say exactly what that'll look like because this is an on-going discussion and as I've said already the on-going work of the 10-year fish health framework will be the place in which the detail of that will be thrashed out and I'm sure that we'll hear more about that probably within the next two months because that group is due to report in late spring You recognise obviously the importance in terms of the usefulness of the data that not only in terms of the immediacy of it but also the possibilities of research that this should be on a farm by farm basis in view of evidence that was given to us in the scientific report about the difference in localities and sea locks and tides and a whole range of issues If I can try to say something useful about that I'll go around a little bit Clearly there's an interest in having data as soon as possible but there needs to be some sense about what we're trying to achieve what we're going to do with that data what we're actually going to gain from having that data available and quite frankly data in snapshots as if no use to anybody it needs to be collected in a way that it can be then used to meet wider objectives longer-term objectives but frankly the fact is we are prepared to do that and there's nothing going to be held back the data will be used we hope for the benefit of the wider industry The statutory obligation to report could you comment on that please from your perspective should it be or should it be voluntary in your view? We have no particular view about that If it was statutory we'd be doing exactly the same thing we'd like to make sure that we're ahead of regulation as much as we possibly can be in that regard we have no problem in making sure that we do that and if statute is required to back that up we've had experience of that already with the way that the existing Aquaculture and Fisheries Act acts as a backstop for our code of best practice Right, thank you Could I take comments from other panel members please on the issue from your perspective I certainly believe that it should be a statutory requirement to provide sea lice data Certainly the more regular the data can be provided the better and the sooner the better if we're trying to identify rapid spikes in sea lice numbers you want to identify as quickly as possible and act as quickly as possible to solve the problem I think part of the process of improving that would be identifying a clear methodology a standardised methodology for collecting and presenting sea lice data so that it can be easily accessible and analysed Of course, openness is good secrecy is poison in these discussions communities like mine don't trust the results otherwise so the process not just the figures that are collected but what's done with them and that whole explanatory process needs to be clear and it should be a statutory obligation The fish health organisation that's part of Marines to Scotland is only for the health of farmed fish as you know and the wild fish are not protected by that these figures are only used for protecting the fish in the cages and there's no enforcement so that example from Shetland with scores home 20 lice per fish the only enforcement notice that's been served was served there and all they did was say they're going to be harvested anyway in October you can just keep them with that level of infection till October there was no protection, there was no precautionary principle there's nothing involved in helping wild fish there and nobody does there's no agency that's responsible except that SEPA still has it on its books and should be using biomass reduction to protect wild fish How would you see that going forward then do you have a view on that? In any detail? Yes, the councils do it at the moment it's part of the planning process planning applications and they say they get inadequate data from Marine Scotland it doesn't give advice on the population impact they don't have enough data about where the sensitive sites are because there's nothing known about migration routes for instance how Garland Butte councillor just pointed that out in their response to the committee so they don't have the data the farm data they can't in the planning process look at more than one farm at a time so they can't look at cumulative effects lot of farms have nine fish farms if a new one comes up they look at that one only the new one so they can't see what the consequences are and then they have farm management agreements which only apply to the one farm and planning permission is permanent so you can't get back in and do anything about it the council don't monitor they don't have resources really a shambles and at the moment the wildfisher not represented by anybody they need their own agency that takes in the data, analyzes it decides what to do and enforces it rapidly and in the pharaohs for instance they cull after three adult female fish for three weeks cull all the fish very quickly before the convener brings in in others whether you and indeed others when you're commenting further have a view on what agriculture consenting review which suggested the exploration of removing the consideration of potential wild salmonoid impact from planning to be considered in a separate more appropriate regulatory process I think it needs some careful thought more than can be done here but yes the planning process is no good but critically communities only get access to this decision making process the public, the people affected by it on the ground through the planning process there's no other way to comment we can write to CAR David Sanderson wants to come in and then Stuart Stevens first thing I would like to say is that in the industry's opinion the management of sea lice in general in Scotland is vastly improved to where it was 15 years ago and the management tools that we have in our disposal are many so what I would like to say about the comments that I'm hearing here is the industry is working exceptionally hard at trying to manage down the levels of sea lice across all farm sites now inevitably there's information out there that shows that that's not always successful and we must do better at all times to get those numbers down but it's in our best interest to do so and we do so every day the resources that are thrown at the the whole management regime around sea lice are absolutely huge and we've had some great success and what I've seen in the last 15 years in terms of the comparators between the 2002 position and now is an industry that's developed significantly the companies are much better resourced better managed, better co-ordinated area co-ordination of problems is being put into play much more readily now than it was 15 years ago when you had a significant number of small independent farms you couldn't get that level of co-ordination now we can bring in all the tools that we need if a problem arises to deal with it the final thing I'd like to say there is if we're faced with a problem we usually have tried everything to try to resolve it there's nothing that I'd believe that any other agency could come in and try to do that the industry is not already trying to do itself and if we work with our regulators if we work with our fish health inspectorate people closely we can come to a point where we decide what's best for the livestock on that farm everything is done on the veterinary supervision and effectively we have the tools to do the job comments David Sanson on the issue around the trigger of the amount of sea lice that is involved in the reporting mechanism for the regime at the moment we have we still work to a national treatment strategy and what we try to do is to manage down sea lice adult sea lice numbers so that they are no more than one per fish now clearly there's lots of information out there that shows that they are more than one per fish the trigger is for us to instigate a treatment or instigate an action to bring that number down again it doesn't mean to say we don't go above it it's the trigger for us to take action and there's a difference between that and some sort of bar that we're not supposed to cross when we report, as we do at the moment under legislation to Marine Scotland we are reporting at higher levels because action needs to take place at a higher level because clearly there's been a failure somewhere I just wanted to go back to John Heson alone on his statement that the planning system is not allowed to take account of cumulative effect every part of the planning system that I'm aware of is required to take account of cumulative effect when turbines, housing and so on can he point me to the part of the law or regulation that prevents cumulative effect being considered in planning decisions in relation to fishwell I'll just read what the Argyllunbieg Council said about it because it's in their response to... Sorry, I'm really looking for the law not for what individual councils choose to do because often they restrict themselves in ways which it turns out are not required by the law I'm not speaking about Argyll when I say that in particular but I would be interested where the legal basis is Yeah, it would as well It doesn't sound to me as though you should talk to Argyllunbieg Council really shouldn't you if you think they might be not obliged to do what they're doing wouldn't it be sensible for them to be informed about that Do forgive me You said there was a legal barrier I'm interested in what it is I said that the council say that they can't an EMP so an environment management plan can only relate to specific measures on that farm site it cannot affect the management of other sites in the same farm management area so there could be 10 active farms with a single farm being managed by an EMP this farm could be following the EMP but sea-life levels are higher because the farm is affected by the management of other farms which are not managed by the EMP Convener, perhaps we should write to the council and see if they are in effect failing to look at cumulative effect because I'm a bit suspicious it may well be I'm absolutely good faith I understand that the sound is being quoted but I don't like the sound but I'm certainly worth clarifying David Sanderson, brief way I don't really have a comment specifically about the legal position but what I could offer you is that clearly you're talking to a Highland Council planning official later today so perhaps there's an opportunity there also just to add to that that when we look at environmental management plans which is quite a new thing in the parlance what we have already planned for fish farms and what we do collectively in industry is we stock whole areas synchronously and we follow whole areas synchronously so we do think about things in terms of the overall zone area that's affected by our activities okay we need to move this on John Scott Thank you convener and good morning gentlemen thank you for coming to give us evidence today I want to broaden out the conversation just a little and last week we heard that there are the top three environmental impacts of salmon farming or the feed supply the future of the feed supply for fish farming long term chemical effects in terms of diffuse pollution if you like and also the impacts on the wild salmon population shall we start with so just to move on from the sea ice problem into the long term chemical effects of the pollution that may result from the dispersion in the environment and the potentials for that as you see them If I may start as far as the consented licensed products that we have in use in Scotland go clearly they've gone through a relatively formulated licence for use in the marine environment we monitor their usage we have to regularly report back to SEPA on every treatment that takes place and there are sampling protocols for looking at the sediment and the benthos to see what the net effect of our operations would be now clearly there's already some debate about whether or not that footprint is telling us everything we need to know or if that's the correct footprint I believe that frankly again opening this up so that monitoring can happen at whatever level is required is absolutely fine there's some work going on to look at specifically what you've mentioned in terms of emmectin benzoate whether or not the fate of that is as we understand it to be there's research going on to further clarify some assumptions about that and we await and we welcome that research again we live on the back of the evidence that's out there as to whether or not the impact is an acceptable impact and we've got a proper regulatory system to control it others yes certainly the amount of chemicals being used is obviously of a concern in particular emmectin benzoate obviously SEPA's recent reduction in usage of emmectin just highlights how little we really know about the impact it has particularly in low concentrations assessments at the moment focus particularly on the benthic environment surrounding the farm but we know that emmectin can impact certain species at low concentrations so it could be that the impact of emmectin could be much larger the footprint could be much larger than the current monitored area the reason the chemicals are being used so much is because selis have developed resistance to them so that's the main problem all of them need reviewing it says in the SAMS report that the levels that they've been set out and the widespread effects they can spread eight kilometres if you put as a methodos into the sea it can get an eight kilometre plume the monitoring is inadequate the PAMP2 science of this was looking at that and said that the only statistical analysis they could do was in Shetland disjunct and didn't match up they couldn't use it to do a big analysis in other areas what they discovered was that crustaceans are depressed by 60% very far from the fish farms when the emmectin is used much further than CEPA's modelling allows for and the SAMS report says that there's no understanding of the long term low level widespread impact of these things and if I may just a quote from CEPA this is from an internal document from FOI fish farming is unique in that it's a sector which is allowed to discharge substantial quantities of biocides some of them priority substances in terms of the water framework directive or at least list two substances in terms of the dangerous substances directive into waters which salmon farms practically using the same waters in which Scotland's valuable crustacean fish is located it's not tenable for CEPA to adopt a position where commercial shellfish species are impacted by the day-to-day activities of fish farms when I'm going to paraphrase when CEPA have knowingly authorised the use of those under the CAR right, I think in the interest oh sorry before we move on to the other headline items of Donald Cameron on this specifically yes, thank you Cair to my register of interest and fish farming and fishing therein I just want to carry on this question of the effect of discharge of medicines and chemicals can I start with a very general question in terms of monitoring and the system of monitoring because it seems to me that CEPA take a role at the start of the process in terms of the EQS and then the issuing of the licence do you have any observations on what happens thereafter in terms of monitoring okay you give a couple of indicators about that when we are consented by CEPA the consent effectively states clearly that any medicine treatment that takes place is done under veterinary control so the very first thing that happens here is that when you decide you need to treat your fish you have to involve the advice of your veterinary adviser or your veterinary practitioner so everything that's done from there on with the use of a treatment is done under that supervision mental as well as that CEPA then lay down the monitoring requirements within the consent and you have to produce regular reports to CEPA, quarterly reports which show what you've done on the site and also you then have to produce sediment bentos samples on an annual and bi-annual basis and those are analysed in relation to your compliance with that consent and whether or not CEPA need to take any action to either alter or now that's a well trodden path and I think there's quite a lot of in fact there's absolutely eons of information out there about exactly how that's worked over the last 20 years I don't think there's any deficit in regard to the monitoring of the activity that goes on Yes Ms Conn So CEPA sets like a limit based on the biomass of the fish farmed at that site and on the deeper modelling impact of the dispersion but what we don't see really is whether that limit if a farm operator uses less than that limit and is still able to control the sea lice does that mean that there's an adjustment in the limits on all the amounts of chemicals that operator can then use and are there adjustments through long-term monitoring of that we're not clear on the process there and certainly in terms of monitoring the benthic environment and monitoring the amount of chemicals in the sediment but not necessarily which species are found in these sediments and how the species composition has changed over time through the use of this chemical and how the amounts of chemical being used how that in effect has an impact on the benthic community as well Thank you CEPA modelled this with a computer model so there's a map from the example where I live in the town of Dura about Duni and it shows in purple here is what the existing model that CEPA used to model where the waste the solids and the emomectin benzoate will go it suggests it's all underneath the farm and that they said 99% of it would be swept away as soon as it leaves that black square they don't care where it goes it's gone as far as they're concerned then they did a test with the new model and it showed it all went there not all of it actually because 86% still leaves the square and they still don't care where it's gone but the bit that goes here in the red area is a kilogram per meter squared per year of waste with the emomectin bound in that's excreted by the fish so it sits on the seabed so what I'm saying really is that this model here the old model the one that's actually still currently in use and has been used for 15 years to do all this EAR permission for pollution is inadequate because it's ignoring it's a flawed model it ignores the fact that the seabed slopes the reason that that red and the purple areas are different is because the seabed slopes there but the model doesn't account for that the industry is expanding into places like this more fast currents, steeper slopes more complicated bathymetry and the model that are used at the moment is inadequate they have a new one which will be better but it still exports 86% of the waste then it's ignored, it's gone away it hasn't gone away, it goes somewhere else and it settles to stop the coast if there's another fish farm a kilometer away it gets 86% of the waste from this one that's not in the model so I just spoke to Ann Anderson we wrote to her in October she's from seabed she does a consenting compliance we wrote in October they've apparently replied, I haven't seen the letter yet but apparently it's been posted saying that they're going to use the new model instead of the old one and no one knows what assumptions it has built into it it really should be publicly independently scrutinised because the assumptions of computer models determine the outcome and that model was defined as one of its goals, enabling industry expansion that's not what we base this for setting any levels for anything and you talked to some of the committee members in micro-school does the panel believe there's a case then to ban momectin or simply just to reduce its use I mean I'm assuming here that not even industry would want to increase its use but I may be wrong at the moment and the industry's consulting the ban was proposed and sepal withdrew it apparently under pressure from the industry through the government I mean this is what's in the press and the herald so it does lead us to distrust it and then temporarily a new level's been set from momectin and inside mpa's only and there are two that have just been passed and the industry can run fish farms have been passed without that condition they're in mpa's so it's not being applied even though there's been a precautionary thing applied in that one instance sorry I'll ask a very general question we've concentrated a lot on fish farming in the sea and the report itself we've focused on that obviously a lot of fish farming happens in fresh water a lox time is short but do you have any observations on the environmental and the light of the report on the environmental impacts of fish farming in fresh water yes, Sam Collin I think certainly one of the concerns for farming in fresh water is to do with escapes and escapes of juveniles to do with river systems and their integration and interbreeding eventually with the wild populations of salmon so that's one of the main concerns with the fresh water farming question and also Mark Ruskell's one as well if I can take that one first and come back to Mark's one please in terms of where we are with fresh water small production we have significant fresh water production in Scotland which has been there and has been well monitored we don't really see any fundamental issues with fresh water usage however the industries general move in the future will be towards recirculating aquaculture systems and systems which will control the small production in a different way that's not a wholesale move away from what we do at the moment it's as well as so we don't see any fundamental problem with the way that the fresh water is operated I acknowledge what Sam is saying about the potential and the potential impact of escapes but there's no solid evidence of a problem we acknowledge that it can happen and there is an escapes issue but there is nothing that as far as we are aware has demonstrated an actual impact so again science is important we need to really work on that to find out whether or not we're there and at the moment we're relatively comfortable with what we do in fresh water and we're complying with river basin management planning and so on if I can return to Mark's hypothesis about MMEctin let's just make it absolutely clear we have very few actual licensed medicines that we use very few and I would want to state quite clearly that our actual medicine usage is on the decline we're moving away from reliance on chemical usage to use a wider suite of things to control sea lice we're using biological controls using grass and lump fish and we're also significantly investing in what we call physical removal of parasites and there are many many things that are currently in the industry being used which have to be perfected and we need to see the outcome the results of using those along with chemical treatments so over time we believe that we'll not have to rely on it's not a case of the industry needing to grow and using more chemicals I think we have to widen the suite of tools available for us to manage that For those of us who worked through the passage of the aquaculture bill we were told then that RAS would be the answer to this that would get us where we are here we are 2, 3, 4 years later and we still have a significant sea lice problem it always seems to be we'll get there tomorrow on the cleaner fish story that is an extremely good news story there's a lot of really positive outcomes happening with the use of cleaner fish in airfarms and I would dispute the fact that the lice issue was out of control I think we'll see from the actual statistics that the lice issue is not out of control and in fact the lice numbers are declining rather than increasing Mark Ruffalo, do you want to come back? If I take your response to that question at face value that you have other tools in the box to control lice then why would you not support a ban on the use of MMectin? Because I don't believe that there's a case being proven for MMectin having the impact that is alleged I think we need to wait until the studies that are currently under way are completed and then take a view as to whether or not we've now got to the point where we can under peer reviewed evidence got the information that we have to make such a decision I don't believe at this time that that's appropriate and I would also see that as another example of a precautionary approach where we've already agreed with the regulator that we should reduce its usage We need to move on The two other headlines that were identified last week were the sustainability of feed supplies and then the effect on the wild populations John Scott on the feed supplies Thank you very much looking to the sustainability of feed supply in future How do you see the expansion of the industry carrying on with cutting to the chase the lack of availability of omega-3s in terms of a sustainable catch of the food supply? We could spend quite a lot of time on this one but I'll try and say something which could be helpful to the committee In regard to what our future outlook is for feed supply we do not actually see any issue in terms of our ambitions for growth and that's because we've moved away from complete reliance on marine ingredients towards a mix of marine and plant stroke vegetable ingredients and in terms of fish meal there really isn't an issue we're already able to substitute and maintain the right level of the important omega-3 elements that we need to retain in the diet and as a result we don't see any issues we will have a pressure on the fish oil element of what we put into our diets and that's the one that we do need to have sound solutions to already however we've got significant developments in relation to things like algal oils and other substitutes from plant and vegetable oils that do provide the omega-3s that we need for the diet and one thing I would say however is that there's a finite resource of marine oils out there globally our industry is best placed to utilise as much of that marine oil as we possibly can and that's our strategy for looking forward to the future we'll continue to use the appropriate level of marine oil and we would regard ourselves as the prime customer for such a resource rather than it being used to frankly be put into other products which are maybe not providing the same protein package and healthy food stuff that we provide I think it's important to clarify the moment that the resources for the salmon farm feed are already stretched particularly for marine resources when we were talking about fish oils just last week it was mentioned that the anchovetta population in South America is already at maximum sustainable yield and that was a main source of fish oils for the industry so that is a limiting factor if we want to maintain the omega 3 values secondly one thing that's not really considered when talking about sustainable feed is the high level of mortality rates in the industry at the moment so figures of 10 million fish dying in 2016 we have to recognise that a lot of the feed has gone into feeding these 10 million fish which eventually go to landfill and don't go to market so when we're looking at conversion rates we need to look at feed used and the amount of fish that actually goes to market rather than the number of fish being fed and finally on just the requirements for feed if we're moving towards the use of cleaner fish to control sea lice this is another farmed fish essentially that will need supplementary food source that also needs to be factored into the requirements of food they don't live on sea lice alone not alone, they feed on them so that's not the only thing they eat and they do require supplementary feed as well thanks for that information basically it's not sustainable and the industry says it is it ought to not be allowed to say that it's sustainable when the food that the fish are fed is not sustainable and sounds quite right about mortality they're not included in those figures for the outcome of fish produced the input of fish fed to the fish forgive me I thought the scientists who said that we were at the limit of maximum sustainable years but that we were at that limit but alternatives would need to be found but you're saying that's not correct that's right because for one thing we're planning to double the capacity so if we're at the biomass limit for sustainable fisheries for anchovies for instance where's that going to come from going to new fisheries including krill for instance which is the next thing on the list of foods that contain omega 2 that you could feed to salmon and the other thing is if you feed plant proteins to fish you have to justify where they come from and if you're feeding mainly soya which is what is fed to them primarily it mostly comes much of it comes from areas where the forests have been felled in order to grow it and then there's the question of whether you're taking agricultural land out of production producing food plant food that people could eat in order to feed it to fish to less efficiently convert it into food that people can eat David Standerson wants to come back on that I think we can certainly debate sustainability long and hard however let's just get some facts straight in terms of the actual usage of the Scottish salmon farming industry of fish meals and fish oils in our feedstuffs they are 100 per cent source from sustainable sources that are either certified IFO responsible fishing scheme or the MSC and we acknowledge as I've already stated that there's a finite resource that we need to better manage we're not going to magically find more fish and we're certainly not going to be looking for species that are not appropriate to our feeding regime yes we've got to find alternatives and yes we've got to make sure that we properly manage plant and vegetable alternatives however we don't see any problem in so doing this is a question I think simply from Mr Standerson it's been suggested to me that retailers are laying down minimum quantities of fish based content to feed that might be different from lower levels that the industry believe they could undertake to what extent are retailers influencing what salmon are being fed in this particular domain it's a circular discussion retailers reflect what consumers are telling them and consumer panels etc will tell consumers certainly in the UK that they have a preference for the knowledge that a farmed fish is fed a marine diet or substantially a marine diet so our preference is to maintain a higher marine oil in our fish than other countries so for instance if you buy a Norwegian salmon or a Norwegian fillet or a Chilean fillet it will have a lower level of marine oils in it than Scottish salmon now that might well be a good point of difference for us to maintain I see absolutely no reason whatsoever why we shouldn't be the prime customer for the available marine ingredients that are there for that purpose that is the best use of that product let's move this on to look at the impacts of fish in Lile thank you Cymru I want to turn my attention to escapees from fish farms with potential effects on wild population if I was a farmer I would take every step to ensure to increase my production through environmental ways if I was a salmon producer I would take every step to ensure no product loss yet we've told thousands of salmon and I see you nodding your head Mr Sanderson why is that, why are we losing thousands if you want to increase production and you want to ensure that you grow the industry why are you allowing thousands of salmon to disappear of your pens I think the first thing I have to say and you're not going to be surprised to hear me say it is that the first thing we're going to do is try to make sure we don't have any escaped fish it's the product that we want to get to market and we do not have escaped fish and I'll mention now if I may that the industry has worked with regulators to produce what's known as the Scottish technical standard now that is a standard to try and up the game to keep driving down the level of escapes in the industry and I know it's difficult when we're talking about quite large numbers to get that into perspective but we have around about 65 million salmon in operational sites around Scotland at any given time and I think the literature that the SAMS report has provided shows that on average we may have a hundred over quite a long period of time the average is 146,000 fish per year out of a population of 65 million and I can't quite do the sums but it's quite a low percentage now I'm not trying to diminish the issue of escaped fish because clearly even 146,000 average per annum is at an acceptable level and the industry's intention is to do everything possible to drive that figure down from lower to zero so do you and to bring in the panel do you believe that this is avoidable or unavoidable in open water and what can be done to them you say 147,000 is negligible I didn't say that I would say 147,000 is not negligible as far as I'm concerned one escape is enough I didn't say it was negligible if I can make a further point on that the other thing about it is that the actual number of those fish that might survive in the wild is very small and we don't believe we have an actual problem have you any proof about that any data about that I don't think so we don't have hard numbers but what we do know is that fishermen catch a lot of them and seals eat a lot of them I have another two questions sorry the panel may want to answer the first one but I'm coming to the second question in regards to that seals eat most of the ones that escape the report, the SAMS report is very clear about the number that go into rivers the effect it has that the genetic mixing as a result is unequivocable evidence that interpreting and genetic mixing of the farm salmon and wild populations can have impacts on the life history of wild populations and negatively influence the dynamics and viability of populations a population level that's the one criteria that's difficult to prove normally on something as nomadic as a wild salmon there's proof, population impact escapes in Norway the biggest reason even above sea lights for the harm to wild fish and really it's unacceptable to say half the Scottish population of wild salmon are allowed to escape that number every year it's an underestimate because there's a drip escape through damaged nets it's just nonsense that it makes no difference so it's your contention that there is genetic mix and effect yeah it's a definitive okay you've covered the second question I want to ask what action would you suggest that the industry take do now and consider in the future to prevent escapees escapes and prevent integration where escapes do occur Eamont, there must be contained in tanks not in nets because nets are vulnerable to damage and loss I think certainly strict protocols on how fish are managed to try and count the human area will be really important but in terms of the equipment being used much stronger netting would be an easier way just to ensure fewer fish escape but also if you can contain fish and create a solid barrier between the farmed and wild fish that would obviously cut down escapes a lot so Mr Sanderson before I finish would you agree that you have to do better yes we would agree we have to do better I'll refer again to the Scottish technical standard which actually covers off quite a lot of what the gentleman is asking about here I'd also say that we need to be continually innovating in terms of case design we're obviously moving into more robust exposed waters as we do so we have the technology and the studiness of cage structures to do that and we're not going to go into more exposed areas unless we're absolutely sure that we've got the right kit to do so and again I would say I'm not in any way to mention the numbers or trying to make a case that we can live with that I think the numbers as they are at the moment can be driven down further and our industries intent on doing so before I bring Alec Rowley and Mr Sanderson just a little confusing here in November of last year the Scottish Salmon Producers Organization produced a report called Sustainable Scottish Salmon and in the forward the cabinet secretary makes the point that he's determined to see the growth of the sector achieve without detriment to the wider environment but not once anywhere else in this report is there a reference to environmental responsibility and sustainable practices is there not a disconnect there between what we're hearing today and what's in this document I don't think there's a disconnect in the minds of anybody in our industry in that regard every policy that's set by the Scottish Government and the regulatory agencies that work on behalf of the Government clearly defines the balance needed between the industry's economic obligations or objectives to do that in a manner that's in tune with the environment and it's absolutely written into the script as far as we're concerned we work in the natural environment every day 365 days of the year we can actually be probably seen as in a good place to be guardians of the environment from that point of view and we can be of assistance to agencies in many many ways in terms of what's going on out in the natural world Alec Rowley The Richard Lyle talked about and asked the question why you lose millions of fish every year because they're misgating but I think a lot of the public are starting to wake up and ask the question why you lose millions of fish every year to disease and if I could perhaps come to that a bit I know that the Marine Scotland science, fish and health inspectorate has said that throughout the 1990s and 2000s there was around 20 per cent mortality of farm salmon throughout the production cycle they go on to say that this seems to have increased from 2014 to the present day so my first question would be what level of mortality is there throughout the production process currently and what is the main causes for this level immortality and how does the industry deal with this massive number of dead fish The first bit of the question there is about the numbers and the historical and current position the numbers are the numbers as reported I'm not able to give you a specific current set of numbers because until we have those reports finalised and in the hands of the fish health inspectors they speculate about the numbers the average that you've described we would look to a normal farming operation to be lower than that we wouldn't accept that that's a norm we've had a couple of bad years where we've had significant issues on top of what you would call normal operating issues mainly caused by gill health challenges the gill health challenges in themselves have led to probably increased mortality in some cases there are other problems in terms of the need for those fish to be cared for in terms of treatments that are more difficult because of the gill health challenges so we have a complex set of reasons why mortality has increased in terms of how we deal with it you've quite rightly said that attention has been focused on the fact that there's large volumes of fish that have to be transported from remote areas to central sites to be disposed of and that's one that we wish to see solid biosecure control over we don't want to see any problems in that regard but that's the disposal route that's available to us there's a set of waste regulations in Scotland that we have to comply with in terms of the proper disposal of fallen stock and that applies across a range of different livestock sectors the fallen stock issue is one that has to be dealt with the same in fish farmers and it would be in any other livestock production so we have to dispose of those fish in a biosecure manner to an approved facility I'm just going to pick up on figures mentioned earlier by David David mentioned that there's about 65 million farm salmon in Scotland and we know that in 2016 there were 10 million fish that were mortalities so this suggests that there's still a 10 to 15 per cent mortality rate which is clearly unacceptable so I just wanted to clarify that sometimes higher some farms, Collinsay lost 150,000 fish last summer so we're looking at sometimes they're getting up to 40 per cent some of these things and at the previous hearing somebody asked what the normal levels would be in a farm and it's about 4 to 8 per cent for chickens and this sort of thing people care about this, they watched the one show they saw those trucks with 160,000 dead fish coming off Lewis dripping waste onto the road people watch television, they watch Blue Planet they care about the sea they're demonstrating it, they're joining networks of groups like the one I belong to so this isn't something to just think, oh it's only an isolated thing it only applies to fish farming it applies to all the people in Scotland we care about the sea, we rely on it being clean for our jobs, we mind Don't these mortality figures suggest that somewhere online you're getting this approach wrong I mean this is a huge mortality rate and all its guises I'm going to tell you as an industry you've got a real problem here I'm not going to try to diminish the scale of the challenge that we have here and what I would say is that there are factors that have to be understood about why those mortality events are happening, I've mentioned gill health gill health is caused by changes in the environment where we have jellyfish and algal bloom issues and planktonic movements which affect our fish we must do better at preparing for that eventuality and being in the best place to do something to try and negate it the trouble is that we are actually we are actually affected by it we then have to take management decisions as to how to deal with it from time to time that will affect us worse than other times and we've had a couple of particularly bad years that's not the picture mortality is something that fluctuates quite a lot over the time period and if we look at mortality data it does go up and down two colleagues want a brief supplement before I come back to Alec firstly Edward Mountain then Mark Ruskell thank you convener and I'd like to declare an interest that I have in a wild fishery just on the issue of mortality if I may one of the issues is gill disease and the report identifies that that's a factor of increasing temperatures and that happens in a lot of cases in summer months and that would bear out from the figures that I've seen could you just confirm to me whether you think mortality is going to lessen i.e. the temperature increase that we've seen is just passing and therefore isn't going to be a future problem and the second point is that one of the ways to combat gill disease is to harvest fish earlier and therefore my question to you is mortality might be being masked by early harvesting would you like to comment on those two questions and understand it a bit better please in terms of whether we think that the the forward trajectory is that we're going to have more of the same which is I think what you're saying there is a definite difference in sea temperature over the last say 15 years it's one of these things that is extremely difficult for us to fully understand the implications of that and again we need more science we need more evidence to back up a type of change in the marine environment so we'll work very very closely with anybody who wishes to try to help to better understand that and I can't really say more than that in terms of whether we think that's here for the future in terms of how we deal with the challenge of gill health might I look at some of the solutions that we're actually already in a position to try to put into play we're investing heavily in the ability to treat fish with fresh water in wellboats or in other contained units so that we can actually do away with most of the gill problems that actually affect those fish washing those gills with fresh water and putting them back into the cages again is a very good way of dealing with part of the problem and I think we need to see how that progresses and whether that helps us to overcome the difficulty ultimately when we have a situation where gill health is deteriorated beyond the point at which it's sensible to keep those fish in the sea or harvest those fish out early it's in the best interest of those animals to come out sorry just to understand that so understand that when you treat fish that they stress and the more stress you put under them under the more likely they are to die but what you're saying is is that when you identify there's a gill problem and you can't treat it you will harvest them and put them through normal production methods into the food chain yes absolutely these are not diseased fish there's no implications in terms of public health in terms of the status of those fish I think we need to make that absolutely clear there's no issue about the fish coming through to the market from that sort of an outcome it seems to me this is a general point as well that why would you expand an industry which has got all these problems without fixing the problems first it's fundamental isn't it these are big problems of illness and stuff why don't we fix them and then expand and one way of fixing them is to separate the fish the wild fish from the farmed fish by enclosing the farmed fish in containers brief we sound gone although these diseases do exist naturally in the environment it's actually the density at which these fish are farmed that is the cause for these outbreaks and if we're increasing the size of these farms and the number of farms we're only going to see the number of these outbreaks increase and if you then add increasing sea temperatures which will increase the rate of outbreaks this clearly isn't a problem that's going to go away soon Mark Ruskell forward by Alec Roward with John Scott if I could just go back to David Sanderson in answer to my earlier question about mortality rates that a single farm in Scotland will produce its own mortality data and there will be the causes of that mortality broken down by disease is that correct? what we'll have is a report which has a commentary which highlights where a disease issue is at play and there will be a percentage for mortality and if that percentage is obviously something that's not normal then we'll explain what the reason for that mortality is so what you're saying now is that the gill disease is the major cause of mortality is that correct? no because I'm trying to get clarity at this point as to what the picture is you focused in on one particular disease I'm trying to work out whether this is the main reason why you've doubled the mortality rate within three years is that the main reason or not? no not on its own right if I might say that as far as we're concerned fish health in Scotland is actually very good indeed but fish health is actually very good what we have is a situation where we're impacted by environmental conditions which from time to time will affect the fish that then is compounded by potential complex gill issues and that makes the fish more susceptible to other problems including the effect of parasites so we'll have a complex situation where there's less ability for those fish to be optimal if you like in terms of their performance and that then makes us have to take choices about what we do about that from time to time those algal stroke jellyfish issues will be the main reason why large fish kills happen if you look at the statistics a lot of the mortality is around natural conditions that lead to the death of fish earlier Mr Sanderson fish health is the core of our business and with 20-25% fish dining disease then you would have to clearly say there's a problem at the core of your business and would you not agree that rather than expanding that business you actually have to look at what these problems are today in terms of I'm not getting a clear view there is a clear understanding of what the issues are in terms of data and data being collected in the point that you've just said you seem to announce that data will now be collected farm by farm but you don't seem to suggest that the industry actually knows the detail of the causes of why millions upon millions of fish are dining disease and therefore what plans is in place and would you not agree and the rest of the panel agree that we should actually halt the growth of this industry until we actually get to some answers on what is a significantly serious problem that would seem to me for the industry that almost seems to be just being ignored we'll keep going and we'll keep farming more and if we farm more that will not matter because we'll get more to the market that can't surely be the way ahead If I may start with where you've finished there about how we're not doing anything about it I just think that we obviously require to get more information to this committee and others about what we are doing about it because we are significantly trying to address those challenges and we're actually overcoming significantly those challenges as well I don't believe for one minute that we're not taking that seriously and in terms of whether we believe we've set ourselves ambitious targets any industry that's successful will try to be ambitious and it will set its targets and it will set quite clear plans out as to how to achieve those targets but we are the first ones to say will not achieve those targets unless we overcome some of the challenges that we've faced in recent times we have a consenting regime in Scotland that's extremely robust any growth that we get in Scotland will be in line with the consenting regime that we have to go through to get that growth in place we are not going to achieve that growth unless we can actually keep our fish in good health and as I'll repeat again fish health is the absolute priority we do fully understand exactly what's happening with the fish in our care we understand exactly whether the complex variety of reasons why mortality as it builds up to accumulative total is a difficult figure to try to talk around we can talk about how we break it down I don't think that's going to help us we just have to make an improvement across the board in terms of that we fully understand what's going on in our farms and we think that we've got the tools to deal with those challenges we need to work in partnership with Government regulators and others to make sure that we can all contribute to that because we don't necessarily have all the answers and we welcome assistance and help from others who might actually be experts in the field that we're in and assist us in that objective perhaps Mr Sannad let's get some quantification around your answer to Mr Rowley's point you said earlier that you would work with anybody to develop the science as a sector could you outline for us how much the sector has contributed financially to the development of science in the last few years and the extent to which it feels it should be contributing going forward if we're to develop a robust scientific base what sort of sums of money is the sector putting in I'm not going to give you one number because I don't have one number if I may but I can try to maybe build some information here that could be helpful if we look at what's happening across the whole sphere of what we call R&D across the whole salmon industry then that number is a very large number it will include work that's done across nationally because some of the work that's done is just as equally applicable in Scotland as it would be in say Norway or Canada and I don't see any problem with that there's an international community we have European-wide projects that we've invested in in terms of the necessary science and development understanding that we have specific to Scotland because we heard last week that in Norway the sector contributes quite markedly to the development of science what specifically is the Scottish industry contributing Over the piece I would say that the range of the answer to that question would be between £15 million and £25 million a year However, as I say some of that will be collaborative projects that have got an EU element not specific to Scotland If you don't have the detail beyond that and I understand you may not have today perhaps you could write to us with that information to flesh out that answer to follow up on for others to come back on Mr Rowley's questions Mr Rowley, thank you Can I just summarise it it seems to me the sea lice week in the fish lots of sea lice then disease and treatment kills the fish some of the sea lice kill the fish too then the industry says that's okay we can kill them early and sell them to people to eat and then it's okay to expand on that basis and then incidentally the expansion plan has become government policy without thinking of these things until now after the expansion is approved so then it depends on the consenting regime but the consenting regime doesn't include the impact on the wild someone it's and there's proof in these reports that there's a population effect there they're not represented by an agency of any type so they're not in this really and then the reports says there's no data Mr Sanderson says there's no data there's no public data about the effect of diseases and then the industry relies everybody relies on the industry to sample these things itself and we're asking what funding the industry puts into science why doesn't the industry put funding into independent monitoring like happens in other countries in Alaska for instance with the fishies where there are independent preservers who do the sampling it would make sense to separate the industry from the regulator the moment they're like this they're really close and we don't trust it I just wanted to make a comment really on the targets of the industry and the government targets as well and how these targets are calculated certainly coming from an industry perspective I've read 300 to 400,000 tonnes by 2030 and that's clearly based on the growth of the industry and public demand but this target doesn't take into account at all the capacity of the environment to actually farm that quantity of salmon what we need to do is to take a much more ecosystem based approach to planning the growth and development of the industry by figuring out where salmon farming can actually take place and what is the carrying capacity of that environment we talked a lot about the assimilative capacity in the salmon's report on how to calculate the carrying capacity and it's this information we need to be able to set realistic growth targets that fall within environmental limits Briefly Mr Sanderson do you want to come back on that? I actually wanted to just add some into the previous question about research taken on board that you're looking for more information one of the areas where we we're putting significant effort in recent times is in the Scottish Aquaculture Innovation Centre which is a significant body of work going on some of the main issues that we're dealing with today that body have calculated that for every £1 of public funds that goes into the work that's carried out there that then multiplies up to £6 in terms of the impact from industry contributions that's not direct cash contributions always that's the calculation of the industry contribution across all sectors A number of colleagues have got brief supplementary John Scott followed by Stuart Stevenson followed by Claudia Beamish Thank you convener I declare an interest as a farmer I particularly well understand what you say Mr Sanderson about the combination of diseases and challenges to fish having a cumulative effect and weakening them at different periods in their life and at different periods in cycles Is there any research that you could let us have in that regard about the synergies of combinations of challenges working to cause deaths please because I think that would be helpful and if it doesn't exist I think it's a piece of research that should be made because it might go some way to explaining these deaths which apparently in my view are all interconnected in all probability I further want to ask you the views of the panel generally and as I said declare an interest as a farmer I'm very aware of the spread of disease subject to climate change particularly in the land based industries such as blue tongue and Schmallenberg's disease which are coming from Mediterranean temperatures and north and in sub-Saharan Africa Is that where this guild disease is that attributable to that type of similar spread north because of temperature change I would welcome all your views Okay In terms of the first question about whether we have research evidence about the cumulative impact of different types of challenge disease I'm afraid I'm not in a position to give you a definitive answer I don't actually know However I'm very happy to take that away and talk to the veterinary profession and it may well be that this committee could do some input from the veterinary advisers as to what the potential scenarios there may be In relation to why this is happening there is definitely some effect from climate change what we've tended to see with the Meebic guild disease is that it's spread from the southern hemisphere to the northern hemisphere and when we saw how it spread throughout Scotland it started in Ireland and moved north so there's something in that but again I don't think we've got enough science to illustrate that that is of any significance and is it completely related to that I don't think that's a completely understood hypothesis either Thank you Comments Firstly in terms of the spread from the southern hemisphere to the northern hemisphere and then the potential spread from Ireland north that doesn't necessarily mean it's a natural movement of the disease it could also be human transportation and malpractice as well so certainly biosecurity is a large issue there when talking about spread of disease coming back to the effects of climate change as I mentioned previously the main reason we get these outbreaks is the density that these fish are farmed at and that's why we get these outbreaks and certainly climate change and warming sea surface temperatures will only exacerbate that problem Thank you There's also several mentions in here of fish carrying disease so the rats are caught wild many of them they're breeding one tenth of the number needed a predicted number needed of 10 million there's two examples of diseases in rats and one in lump suckers and Norwegians are really worried about lump sucker disease it says in their fish health report from last year so some of these solutions are not solutions necessarily they may bring in other problems Stuart Stevenson before by Claudia Beamish in the wild salmon population age cohort by age cohort are they more or less likely to die in the wild than they are on the farm in other words what's the baseline against which we measure another area where there's a lack of information and maybe should the Government have looked for this information sooner because you certainly need it before you plan expansion but one thing that's really clear is that the young fish, the smolts more than the big fish coming back and the smolts that spend the longest time close to the shore are sea trout which are priority marine feature and should be protected by our rules so they spend the longest time, they get the highest level of sea lice, they die and the ones that pass through the salmon smolts generally are getting more infections, more sea lice as they go north the ones from the very north west corner of Scotland get away and the ones facing west get away quicker with less exposure So you're saying there's a difference between the east coast and the west coast where there are farms and not farms because that's not the evidence I've been able to have Actually not what I was saying, although that is true there's a graph there I've given you all about that but the what I was saying was that this is sea lice not disease but the sea lice are affecting the fish that spend the longest in the coastal waters and sea trout which we've generally ignored and Sam's report is very muddled about this and it's wild salmon, wild sea trout and the sea trout are also protected and they're also impacted by by salmon farming, by the lice from the salmon farming we should be protecting sea trout too it's an obligation by diversity protection and also the precautionary principle So Mr Sanderson are they more likely to survive in the wild than they are in a farm? If I may start by saying that industry recognises that we will have some impact at all levels as a result of all our experience and we will have some impact on wild salmonids in regard to what that impact is I don't think that's easily measured however, what I would say is that in terms of that impact vis-à-vis what happens out in the marine world in terms of marine survival of wild salmonids it is insignificant in terms of the impact from marine survival in terms of general marine survival from a number of different reasons I think we have to get that absolutely clear Thank you, convener and I've got two questions which I appreciate the panel could answer very briefly in terms of time and that doesn't obviously reflect the importance of any of these issues I want to return to the transportation and disposal disposal of dead fish and panel members may be aware that in March 2017 last year that there was an accident where transport lorry on the A9 shed its load is the regulation and are the protocols and enforcement regimes clear, fit for purpose or if not should they change and if so how so that's my first question and my second question because it's nearing the end and there are others that want to come in again could you be brief a brief comment which I think I'm John Aix and you've already referred to but on the relationship between marine protected areas and fish farms Could I start with that one Marine protected areas have a lower EQS that's the allowable quantity of anomectin that's the specific limitation but it's not being applied at the moment by CEPA, they've just approved two farms which don't have this limitation but it applies to marine protected areas where there's a sensitive feature that the report, the Sam's report says there's hardly any information about which of the 81 priority marine features actually are sensitive to chemicals or other impacts of of salmon farms also some of these marine protected features can swim, I mean the flap escape where I live which are critically endangered as rare as rhinoceroses and they can swim away for them in the world and they can apparently swim away so it's not true that there's no impact on wild salmon when they go to sea and come back again that most of them die at sea it's a 33% difference in Ireland up to 33% of the ones that come back to spawn limited reduced by what happens to them from the sea lies on infection and transportation I don't know the answer Could I really just pick up on marine protected areas and our concerns I agree with John that the Sam's report does very little to address the impact on marine protected areas particularly a network of nature conservation NPAs maybe due to a lack of resources available but that's something we need to look into particularly in light of the fact that protected growth will impact in short nature conservation NPAs many of which have protected features that are at direct risk from agriculture activity and in terms of disposing of salmon mortalities I'm not in a position to really answer that We'll start with the last one first as others have done again in terms of vis-a-vis NPAs our industry absolutely recognises the suite of different designations that have been placed throughout Scotland for a variety of reasons whether it be for protection of specific species or not we recognise how we have to live within that environment in terms of the sighting that we need to think about when we're putting farms in place we don't believe however that means that we can't have a farm it depends on what exactly we're trying to protect so again we'll work with all agencies to make sure that we're complying with the expectations surrounding the designation and we'll also help with the management of the designation where that's appropriate I think we're in a good place to do so in some cases so we have absolutely no issues whatsoever with the regulatory environment that pervades around about protecting the marine environment I think that's an absolute given in terms of the appropriateness of the regulation around transport and specifically whether it's working or not I really don't believe I can comment we understand the regulatory position and we do everything we possibly can in terms of biosecurity I can't say an accident will never happen I don't know the specific details of the accident that you mentioned whether that led to any problem or not what I would say again is if there's any evidence whatsoever of biosecurity measures for the transport of waste or anything else for that matter we want to know about it we need to know that there's a problem and then we'll fix it it's probably a question for the next panel then it may well be thank you, moving on, Mark Ruskell thank you, convener can I turn to the issue of waste nutrients, feces, food all that stuff that's lining the seabed we've got new depositional zone regulations on at the moment which on the face of it would seem to allow the expansion of fish farms in more exposed locations while requiring a tightening up of the monitoring of nutrient waste we had some evidence last week Dr Hughes in relation to the DZR approach said, as is his words it's difficult to say whether scientific evidence supports a move to DZR because we don't know what such a move would mean can I get opinions from the panel then about what you see the impact of DZR actually being if I could start and let others come in one of the things that came out of the report last week which we read with great interest and then had to think a wee bit about was the concept of adaptive management we quickly came to the conclusion that we've been doing that for a long time and we have lots of examples of adaptive management we probably haven't called it that up to now it's a good phrase however and actually probably in relation to what's being proposed or at least consulted about in terms of a new approach to regulating that potentially is quite an interesting way of taking forward an adaptive management approach so from that perspective I think we would welcome that approach and we'd like to sit down with regulators and have more productive discussions about how we move it forward in the consultation phase I think we're open to suggestions and input from all sides on this one we're looking for the best way to improve the regulatory environment for fish farming and I think that we should all try to do that so I think Mr Sanson that the current consultation suggests that this new DZR approach should be applied to fish farms that are expanding in more exposed locations do you believe that this regulation should be applied to all fish farms including existing fish farms in more inshore waters? I think there's a combination of things here we obviously are looking at this in relation to whether or not we can properly model and look at site-specific modelling that is more appropriate to the actual location of an existing site if we find that we've got a better model than the one that's been used in the past or we can look at adding to that model and better understanding what's going on at that level that's good we should do that so you would welcome this new regulation being applied to every fish farm in Scotland is that right? no because there are some sites which as they're currently located if you apply a strict interpretation of how it's presented at the moment that would be detrimental to those sites detrimental to the sites or to the businesses that operate on those sites well clearly if it's detrimental to the site it's detrimental to the business so I'm not going to try and split hairs on that one the fact of the matter is we should take that into consideration if we're going to change the regulatory system okay could I take other views on DZR certainly our focus is really on the environmental impact and mitigating those impacts so we have a new assessment in place a new modelling technique that is more accurate give a more detailed view on the environmental impact then that's the one we want to be seeing used so if it's an improvement of previous models then we would like to see this new improved model used on all fish farms to ensure that they're all meeting these new standards that are within this DZR consultation the DZR works it's proposed to work it's not approved yet it's to work by not using the existing idea of a conservative limit on how much using biomass to limit the impact on the bottom or around it's to say let's not limit it we won't have a cap on biomass the farms can be 8,000 tonnes instead of 2,500 tonnes but we'll work the way up to 8,000 monitor what the effect is and then allow an increase allow an increase until we detect an effect the capacity at that level the problem with doing that is that as the SAMS report and PAMP2 study all these studies have shown is that the impacts are not immediately recognisable you might find out 10 years later that there's been an impact because momectin lives for four and a half years in the seabed and is still poisonous for instance and these things are cocktail effects they accumulate, they bio accumulate in animals the computer modelling that drives DZR allows in the case of honey which isn't offshore by the way it's one of the places they would have applied to DZR because it's dispersive, it allows the waste to go away it allows 86% of the waste to leave and then it's not modelled so that's not really minimal impact that's a discredited idea from the 1970s that you can dilute pollution until it doesn't make any difference anymore without knowing where it's gone so DZR adaptive management is what's been saying what's been happening already what's been going on before, it's not a new thing creationism is intelligent design it's a marketing thing to say we're going to do something different we're going to be more intelligent about this whereas in fact what the intelligent bit is is collecting proper data analysing it for patterns responsibly independently, transparently and then making sure that you apply the precautionary principle wherever you don't know the answer which means now and then work out what to do before you do it you don't do what Professor Tett said do it anyway and see what the effects are and then work out if you mind the effects afterwards because you can't tell what the effects are for 10 years sometimes Do you believe that there's anywhere in the world where that regulatory approach is successful in terms of delivering environmental objectives I mean Iceland was mentioned last week They haven't started in Iceland it's a proposal to do it from a blank slate in Iceland so if they do in Iceland what happens in the pharaohs where they have much less problems with sea lice for instance their DZR approach would be to say we'll have zero tolerance of sea lice so they kill all the fish if there are three sea lice per fish for three weeks I mean that's adaptive management that's quite an intelligent thing but adaptive management is just a term for a broad idea of let's do it and see what happens it's not a solution it's a really vague term that doesn't mean anything David Sanderson I really don't think I can let that lie this committee will obviously have a transcript of what's being said and it's simply not true that in the pharaoh islands they kill all the fish if they've got more than three lice I'm sorry that's just not a fact I can give you the information I can speculate this later on I think I'm pretty much done there's only to the last question I had on this is about whether there could be any unintended impacts of pushing effectively fish farms out into more exposed locations on MPAs but I think we've already had some commentary on MPAs but as to what extent those are appropriately assessed the more exposed location thing is the implication is there'll be far offshore and won't do anything and nobody will see them and it'll be solving many of the problems but actually all that is required the criteria for dispersive environment is strong currents it could be the pent of Firth, it could be the sound of Jura the north channel between Northern Ireland and Isla it doesn't mean far away and it just means the stuff spread further there's a model that just shows that sea lice from Argyll from the mainland can reach the outer heparides it's just been published this year so that's a dispersive thing just to add to that a lot of the research has shown that some of these chemicals can have an impact at very low concentrations and so when you move these farms into more exposed environments you then increase the footprint of an area that can be exposed to low concentrations so really we need to know more about which chemicals are being used and in what quantities and what their impact is at low concentrations Finlay Carson's got a brief supplementary on this issue Thanks, convener it's regarding multi-trophic agriculture obviously the salmon and fishing industry wants to ensure that that as much of its resources can be put back into the system so we see a huge level of nutrients being excreted by salmon that at the moment sit in the bottom of the sea what sort of research are you looking at into how that could be reused and put back into the the chain if you like As the scientists from Sam's said last week there is some hypotheses about this that actually looks like a good idea and in various locations where salmon farming takes place there are projects that are taking place looking at small scale multi-trophic approaches so growing seaweeds and mussels and other species in the vicinity of a farm to get a balance in terms of nutrients within that environment at a local level, at a small level I think it works very well indeed and I think there's certainly a case if we can expand that methodology I don't think it's going to be what I'd call a big ticket in terms of changing the whole balance but I think anything that can help aquaculture to be positive from that point of view we should be looking at doing more of an example would be in the place I come from the Shetland Isles where we produce three quarters of the blue mussels in Scotland they live quite happily in salmon farming areas and the co-existence of mussel farming and salmon farming is very productive I just wanted to highlight in the salmon's report when talking about multi-trophic approaches there is this spatial disparity where in their report they say one hectare or salmon farming requires ten hectares of I believe it was seaweed growth so we're talking about huge areas of space that are required multi-trophic I'm not saying that it wouldn't have any effect or it's not a useful approach to look into but at the moment we're talking about huge areas of sea that would be required move us on to Kate Forbes great thank you very much I'd like to move on to seals and acoustic deterrent devices firstly on lethal control measures related to seals the report states that although the present licensing system has resulted in a decline in the number of seal shooting licenses issued, there are several areas where additional attention is required and it looks at, for example, the reintroduction of closed seasons for shooting corresponding to the main nursing period for seals what measures do you think are necessary to ensure that any welfare concerns around the shooting of seals is dealt with certainly Link would discourage the use of shooting seals as a predator management control we think that there are alternative methods that are available such as tension nets that can resolve many of these problems sorry, John, if I may there's no real way to make it sound good if you have to shoot a seal so therefore we're not going to try to play the numbers again however the numbers that we have driven this down to are very low indeed and we've stated that we intend to continue to drive them down towards zero by deploying whatever methodologies we possibly can before we have to resort to using a license to shoot a seal the numbers are very low indeed we're into single figures per quarter however from time to time a seal will actually be inside a cage of fish and it's predating on the stock it's extremely difficult to do anything other than those circumstances all the measures that we're talking about whether it be tension nets, predator nets ADDs etc etc are all part of of the cameras we work on and in relation to ADDs and whether they're appropriate in some cases they are the idea that they're left on continuously and have a massive effect on other marine mammals I would refute because they're used selectively they're not switched on they're used when there's a problem Can I pull you up on that there was an FOI request from 2016 that indicates that 60% in the case of salmon farms using ADDs 60% are listed as having these always on that's surely odds of what you've just said with respect That doesn't concur with my knowledge of the situation but I would need to take that away and look at the FOI to see if there's any light on that that's not my knowledge of how industry practice operates at the moment because you would recognise it's not appropriate to weave ADDs on a permanent basis We recognise that there's an impact on potential impact on marine situations within a certain zone around those farms and therefore you'd have to use those appropriately Sorry Mr Colin Widen the point and then I'll bring you in a comment from Marine Scotland in 2011 said that despite being a licensed condition most such shot seals are not presently made available for necropsy thereby preventing an independent assessment of whether seals are shot according to the Scottish seal management code of practice and in such a manner to ensure against a prolonged and painful day The thing is I think just to stop shooting seals and it would solve all these problems and the industry needs to anyway if it wants to sell salmon to America and that's coming quite soon so it seems like a no-brainer just don't do it anymore if there are so few being shot that it makes no difference if it's single figures in quarters then it's how many is that a year it's nothing so just stop doing it ADDs are not proven to work it says in the salmon's report they're unmonitored the council say they can't regulate them they're expanding because the industry's expanding and the effect is cumulative and they exclude porpoises and one farm porpoises are protected species that happens in SACs the SAC for porpoises in the mynchers and Firth of Lawn so mobile species they can swim away it's just nonsense Can I just quickly add to that that although Mr Sanderson said that there is not a lot of evidence on the impact on citations there is a growing body of evidence on the impact on harbour porpoises they induce stress they cause hearing damage and they cause displacement they change the behaviour of harbour porpoises restricting them from going to certain areas so there is a growing body of evidence that ADDs although not proven to be effective on seals do have a significant impact on citations Do you suggest that we should just not deploy them or deploy them selectively? I think I'll go back to my previous answer where there are alternatives such as tension nets that we would prefer to be used and the use of ADDs to be discouraged as much as possible Why are tension nets not used more? Can I maybe just clarify that farms use all these things net tension systems and ADDs together it's not one or the other these things are all available for us to use depending on what the most appropriate things are for the environment we're in and the type of predator interaction that we have so it will not be a single solution for all locations because we don't need a single solution for all locations we need to know what's most appropriate for those locations I think we've quite clearly stated that we'll do everything we can to stop having to go and use a licence to shoot a seal and yes it's simple to say let's just stop doing it well we are stopping doing it and we do know that there's a threat to certain markets if we don't comply with their requirements so we've got to take acknowledgement of that and we'll drive those numbers right down How could you propose better monitoring of ADDs so if there's conflict for example about how often they're on continuously etc how would you better monitor it? The problem is they shouldn't be used because they can't be monitored that's the difficulty to monitor them they're not monitored at the moment because it's very difficult to monitor them SNH have a role in deciding whether they should be or shouldn't be used but they are used in places like that SAC even though there is a role basically SNH are ignored most of the time but there must be a means of identifying their uses because that FLI request appears to provide the evidence which presumably came from the farms themselves so Mr Sanderson's position that he doesn't recognise those figures I think it might be useful if you came back to us on that because there's clearly an issue here I certainly will come back to you and I'm sorry if I'm not aware of that information however we're the best people to tell you what's happening on farms and we have absolutely no reason not to so I think whichever agency needs to know that information I think our industry would quite happily freely give that information about whether that's the appropriate use of ADDs Moving on briefly to RAS Finlay Carson I believe that there are some concerns over the exploitation of RAS populations and potentially that will get worse as the farming scale increases Will the industry be able to achieve its targets of cultivating RAS that it uses by 2019 and if it doesn't do you believe that the wild fisheries for RAS requires more regulation? Okay two parts to that maybe the first part is that we've already started to make the big investments necessary in the hatchery facilities required to grow the numbers of RAS that we believe we could use in the environment the latest one being the approval to go ahead with a new hatchery at macrohannish with a £14 million investment we believe that we'll have enough RAS in production by 2019 to meet our needs if we don't then we're quite happy to engage with whoever we need to about voluntary measures in terms of the existing RAS fishery now not in 2019 to make sure that we're not doing anything at all which might impact on the overall sustainability of that fishery I'd like to pick up on just the cultivation question both points really certainly when we're talking about cultivating the number of RAS or lump sucker fish required to meet the demands of the industry we're talking about a whole new form of aquaculture really a whole new RAS and lump sucker fishery which requires resources which requires food which will require pest management as well and over time if we're cultivating these species we're going to have some genetic traits chosen over others the same as we have with farm salmon more adapted or better reducing sea lice numbers this raises concerns for example if you were to have a large scale escape of farm salmon you also have an escape to farmed cleaner fish too which then go into the wild population and we have similar problems that we see with wild salmon escapes on the wild populations there certainly going forward there will be a need to fish wild RAS even if it's to brood stock the cultivation of cleaner fish and certainly we've seen RAS numbers drop, we've seen actions already take place in the south of England through the IFCAS to introduce management plans over great concern that the RAS numbers are dropping so we certainly need more information on stock assessments catch sizes, RAS behaviour to try and identify catch limits and manage it as a fishery can I come out as well? The macrohannish thing is going to produce a million fish it takes a year and a half to grow them 40 million pounds the predicted demand in the SAMS report is 10 million fish a 400 million pound investment to produce the found ones are they really going to put 400 million pounds into farming RAS and the reason for doing all this is because the RAS eat the sea lice so it's back to the sea lice problem again closed containment fixes that problem completely, no sea lice if you put RAS in a cage to do this and they pick up disease from the salmon you have then to do something with the RAS at the end of the production cycle so every 20 months they kill all the fish, all the RAS and that's the plan in Norway they're released, I assume it's the case here are they all going to be killed in Scotland? They are, okay they're all going to be killed in Scotland so is that sustainable? Let's we've covered a a very wide-ranging number of topics today but let's conclude this session by looking at the issue of mitigation Alec Rowley I'm quite struck that in the report itself and I just quote this paragraph it says recirculating agriculture systems are the most important and the most important agriculture systems RAS might seem a logical solution to many of the environmental problems associated with salmon farming by isolating fish from the natural environment RAS provides security from disease, infestation and predators and eliminates the risk of harming wild salmon by retaining waste they prevent organic and nutrient impacts so when I read that I thought to myself therein lies the solution to this and I see that there's a Norwegian firm announced plans for the £500 million investment in an agriculture plant in land in America so it certainly seems to be that there is investment taking place is that the big ticket as you said if I may in terms of the big ticket I would view that as being something for the future in addition to what we do in the marine environment and supplementing what we do in the marine environment and enhancing what we do in the marine environment if we look at the footprint of what we do now in the marine environment and try to supplant that into a complete change of tack and going into land-based recirculating aquaculture systems the carbon footprint and the physical footprint of that would be out of all proportion to anything we can think of here it's in the report it shows you the comparators between carbon footprint from a marine farm operation comparative to a land-based one and it's a factor of 1,400 per cent more in terms of carbon footprint we farm in the sea extremely efficiently we have an excellent efficiency ratio in terms of how we produce really healthy protein trying to then balance that with the impact we would have on land with the consent required and the space required and the footprint required to do that it's not even worth starting to think about however if we're going to expand in the future we should develop what we're already doing with the recirculating aquaculture systems for small production and try to build on that and no doubt there will be people who will look commercially at that equation and say at some scale or other we can start to build land-based aquaculture facilities if we're going to feed the planet we're going to have to find ways to do it and that's definitely not off the table altogether in my book but it isn't the big ticket in terms of solving all the problems a lot of the problems that we have in the industry we believe we can solve them we have the ability to face up to those challenges and try to find new solutions and I don't think that we should abandon the way we farm at the moment to supplant it with something else John H. The thing is with that that's fine, there is a problem maybe with the amount of energy involved in doing containment on land but what that does is conflate one problem with the next problem the first problem is it's cheaper to farm salmon in the sea because the sea is used as a free waste disposal for all the pollution if you pay for the pollution which every other industry has to do every other industry has to do that then it costs what it costs in Norway and Norway are moving completely even Marine Harvest in Norway say it's necessary to move to containment to complete separation of fish on the sea because they're an environmental country they do carbon audits on everything and they think that the risk is greater of farming open nets than close containment even Trump's America is doing it I mean for goodness sake so we can't carry on like we're doing we should fix the problems that exist now and then not expand until we've worked out how to fix the problems it's a precautionary principle, we're obliged to do that Sam Cohen I certainly think that close containment technology has huge potential for alleviating a lot of these problems and obviously that comes with other environmental concerns but there needs to be some clear cost benefit analysis done to adequately compare these two different approaches but what is this pointing is that there is a huge amount of investment in this technology in other countries like Norway and there doesn't seem to be anything happening here, pilot projects anything and I think we recognise that this is an early stage of the technology and that we can't expect it to happen tomorrow but there are a lot of other technologies out there at the moment for some kind of semi-closed containment through keeping fish at certain depths to reduce the sea-life problem there are other things happening out there that aren't being investigated or put into use here in Scotland so there are many interim methods and strategies that could be put into place whilst we're waiting for close containment technology to become an economically viable option To back that opportunity the technology around close containment is transferable so if we're going to invest in Scotland it should be on all those kind of measures and others will develop those technologies that we can import Scotland's behind, we're on the back foot I'm always leading this are we wanting to be as cheap as chilly and compete on that basis that we're cheaper and making a lot or should we raise the standards and compete on being the best Scotland's good at this stuff it's good at engineering Do you want to come back with further questions Donald Cameron and then John Scott I think what I'm hearing from you all is that it realistically speaking the Sam's report is right when it concludes and I quote it seems likely that the majority of salmon production in the sea will for the foreseeable future continue to take place in net pens I think that seems to be what everyone says I've got a question for Mr Sanderson and it is this it would be much more expensive would it not for your industry to commit to recirculation systems than what you're currently doing financially speaking I like the idea of a cost benefit analysis I'm sure we need to do that we're really up for innovation we're really up for trying different growing systems in the sea we don't have a problem with closed containment systems being applied in the sea even looking at how we can implement effluent treatment within those systems we already have substantial investment in wellboats for carrying out an awful lot of the rudimentary work that we need to do on farm sites in terms of moving fish and treating fish we can now have effluent treatment built into those wellboat systems we can have capture and filtration systems built into those systems yes, we're investing heavily in all these things and we're moving forward the whole time in terms of investment so there's always a cost benefit analysis wherever you take any decision about how to move forward and I'm not suggesting one minute that we're going to stand still and not do that I hope it's not a controversial point to make but surely it is cheaper for you to do this at sea in open nets than in closed containment is that right? John Scott fall by Mark Russell to conclude Thank you coming from an engineering background I would like to see an engineering solution to much of what you propose at the moment there is nothing happening in terms of the deposition and the sea bed and the alternative is closed containment in between there must lie an engineering solution which would essentially be that as fish cages are suspended are they not in the water then something similar to a tree of a similar dimension could be suspended beneath it and cleaned out on a regular basis and that culture did old things like Dunspert or the conveyor belt which moved all the stuff to one end you put it into a pipe suck it out and they're shipping away you go with it clean it out once a week why would you not be doing something similar to that in terms of innovation it's an engineering solution I don't believe it's an impractical thought and I cannot understand why it hasn't actually already been developed as an idea and clear off a nest that causes so much problems with sea bed with the other mectons lasting for a long time in that environment take it away and dispose of it in a proper manner thereafter why not I believe it's happening in Norway there's research going on into this but maybe you'll tell me more about it there are methods recently in Tasmania where they use a funnel that's underneath the salmon farm which apparently catches up to 60-70% of the waste and then that's funneled out and part of that's converted into fertilizer in the rest of the region Can we ask how much money industry and the government puts into research in close containment in Scotland because there's a trial at McRahanish a Norwegian company that's concluded successfully but there's almost no information about it so investing in it what I heard was Marine Scotland said we're watching with interest that was their submission to the salmon and trout conservation petition to this committee previously watching with interest Are they paying for it? Is anybody putting money in? If I come back to what you've asked about in terms of an engineering solution again I would reiterate the fact that as an industry we're absolutely 100% committed to innovation in all areas of our operations there are a number of things going on already in terms of engineering solutions none of them have been brought through to be fully commercial fully implemented in terms of becoming mainstream in terms of how we deal with problems because they're not proven yet there are some systems out there that you can buy off the shelf, lift up systems ways in which you can capture some of the effluence from farming operations and indeed some of them are in use in Scotland already in our operations there are significant attempts to try to minimise the amounts of things that we're effectively better off treating if we can do so and I think we will look for the technology we will look for an engineering solution that the solution is not there yet but there's nothing to stop us from actually working towards that Before I take the final question can I just point it out for the record that the salmon and trout petition was lodged with the Rural Economy and Connectivity Committee I'll just note that for the record before the convener of that committee seeks to point it out perhaps so it appears that the main concern with closed containment systems is the energy that's required but with open pens we have the problem of nutrient waste is there not a way that we can take nutrient waste that will be captured with closed containment systems and maybe put that through anaerobic digestion and actually generate the energy and do you know of any research that's currently under way along those lines? One would be the one to look at and the Norwegians say a study was done in no way that proved it was economically equal to farming open nets in the sea done by a Norwegian university so it's worth having a look All I would say to that is that there are a number of attempts at a land-based closed containment out there that have been done over a year some have come to conclusion some are still happening I think that the committee would be well advised to find out as much information as possible about outcomes of some of that work to date The only other issue that I've not touched on in terms of how we would see what we do in the sea supplants into a land-based system would be in the relation to whether or not it improves the overall wellbeing and health and welfare of our fish We would say that it's more than likely that the stock and densities in some of these experiments that have been done around the world already would be significantly higher The stock and densities that we farm fishing in the sea Three of sea wise Let's wrap it up at that point Can I thank all of the witnesses for their time this morning I think that that's been a very useful exercise in exploring the various issues I'm going to suspend very briefly for five minutes till we change the panel Thank you for your time Started, please We started Welcome back to this meeting We will now take evidence on the environmental impacts of salmon farming in Scotland from our second panel I'd like to welcome Ann Anderson from SEPA Mark Harvey from Highland Council Mark McKee from Marine Scotland and Rob Reynard from Marine Scotland As you will understand we've got a series of questions for you I want to look at how things have progressed since 2002 In two regards perhaps As you may have heard us asking the first question Perhaps you could illustrate for the benefit of the committee examples of where the precautionary principle has been deployed in the expansion of this sector and also to look at the issue of regulation because it strikes me that we have fish farms leasing the sea bed from the crown estate they obtain planning consent from the local authority they are then policed by SEPA and the fish health inspectorate and yet there does appear at face value to be insufficient coherence of oversight of their activities so are we regulating sufficiently sufficiently effective way so we could take those questions together and kick off with those Mark Harvey On the precautionary principle the precautionary principle of course is embedded in European environmental legislation so we obviously can't ignore it so it's a principle that's applied I have to say, speaking as a planner I don't like it I don't like it as an approach because I think we're actually paid to take decisions and those decisions in my case obviously are we recommending approval or recommending refusal for definite clear evidenced reasons not because we're not sure so we don't feel like taking a decision that said just to wind myself back a little we have recently started to use environmental management plans so we mentioned earlier and those are they're embedded as conditions within planning permissions they're a a method of engaging with the industry over time so they're a monitoring condition effectively and then allow us to involve ourselves in the lifetime of the consent which may be considerable in terms of monitoring such things as sea lice control and and escapes and I would say that that is very much a sort of precautionary approach it's not the hard enforcement that planning and authorities are often in where there's a clear parameter set if it's breached it's enforced against in a clearly defined manner it's a sort of softer approach and I would suggest that that is probably at the moment where the precautionary principle is coming in most clearly and in terms of regulation of the sector is it sufficient given what we've seen in this report is it sufficient it's difficult I came into this job this responsibility a couple of years ago from a development management background enforcement background I think this is probably as difficult a job as the local authority planning authority as difficult a sector as it has to deal with in anything else and yeah the regulations are from a planning authority point of view quite frustrating and we don't feel we're able to come up with very clear answers as recommendations to our committees and so forth consequently the environmental management plan is that slightly soft edged approach to monitoring as opposed to perhaps the more hard edged monitoring that we would apply to other areas of our work and Anderson in terms of SEPA's role in licensing we set environmental quality standards so in respect to the precautionary approach there are controls mark referring to the style of controls used within the planning regime within the car consent regime we set environmental quality standards that protect outside as own of impact and those standards relate both to organic and to chemical modes they are used in terms of a baseline so in terms of the application process there is a baseline assessment required and we use modelling tools to predict environmental impact setting the limits in terms of size and scale based on those predictions monitoring is then undertaken in respect to compliance with those levels both the limits in terms of size and scale of the facility but also in terms of the environmental monitoring and the outputs from what is known as benthic analysis also chemical residue sampling largely done by the operators and SEPA undertakes a compliance monitoring programme undertaking sampling and analysis in respect to compliance and audit checks so in terms of precautionary it is set where the environment so every environmental quality standard is set through the use of EU directive specifically within this industry in respect to water framework directive and we are currently going through a process of assessing and improving the EQS in respect to Emma Meckton-Benson which has been previously mentioned in respect to standards that are actually set where in the absence of you go to the environment and to protect the environment so in terms of risk factors they are set specifically where there is any uncertainty for a higher level of factor and therefore a tighter control I think that David Sanderson mentioned that earlier in terms of Scotland's environmental controls within the fish farming industry Thank you You said that largely the sector provides a lot of the information and the data for the monitoring Could you quantify that? I mean to what extent does SEPA do its own independent monitoring and analysis as opposed to not being based on what you are being told by the sector? So as an environmental regulator we regulate the sector in the same way as we do every other environmental activity be it land or water base The predominant theme is that there is operator monitoring, reporting of that and then we have a resource that is there allocated against the findings The actual percentage I don't have in front of me but I will provide that But in effect wouldn't the industry have to self incriminate itself in order to be regulated? Yeah, in essence we require, there is a requirement to notify of analysis that has been undertaken that allows us a window of time to then do an audit of that analysis and that does occur There also is the ability then for us to then go and undertake those additional audits Last year we did a programme in Shetland over an eight week period specifically assessing around our capability in terms of the future regime reference made earlier to DZR which is actually enhancing the volume of the type of analysis that is being undertaken in the industry so in terms of providing additional sound science and scientific evidence that the monitoring protocols are likely to be changing through the course of this year and into next So there's no programme of unannounced visits across the sector is there? There is as a regulator that's how we undertake our business is predominantly unannounced and either are at inspection at the facility so not all our regulatory activity is down to scientific sampling and analysis There is other means of tracking, use of medicines, feet quantities so there's a range of different regulatory tools that we take in respect to monitoring and regulating this to develop our understanding of how this works in practice How often? How many unannounced visits would be made annually across Scotland, across its fish farms? Again, I don't have the figures right in front of me but I will provide you with the details of that. This is a risk-based assessment that we take in terms of inspections and announcements There are approximately about 400 licensed marine cage fish farms any one time there's about 290 to 300 in operation and then it's a programme of inspections which also includes sampling and analytical capacity as well as the regulatory role that I shall provide you with the full details. Okay, thanks. James Wickey do you want to come in here? Yes, our position from my regular position is slightly easier in the sense that we operate in a complementary way to the main regulators being SEPA and SEPA in terms of how we would see reacting to a situation where perhaps you'd have to undertake an investigation Yes, indeed it is dependent on the timely submission of information at key points in time that allows you to take into consideration whether you would need to then take any particular investigative action or take any further consideration Rob Reynard In terms of the role of the fish health inspectorate isn't it a bit bizarre that you would look inside the cage but not outside it and I realise you work to the rules that you work to but looking at it from a layman's perspective should that not be part of the regime that you follow looking at the impacts immediately outside those cages? Well, I mean since 2002 the big change in fish health has been the aquatic animal health regs, 2009 there is a focus around the biosecurity on the farm that legislation covers a number of listed and notifiable diseases and in relation to those diseases where we find them we do look outside the farm into whether wild fish have been affected by those diseases or indeed whether the presence in wild fish might impede or have a bearing on how we treat the farm to eliminate the disease that's for the listed diseases that are part of the EU framework that's implemented in Scotland it requires authorisation of farms various specific measures that farms have to have in place specifically around the biosecurity record keeping disinfection the way in which they stock farms and they specifically have to address how the veterinary assistance that is called on in times of disease will be made available to individual sites so there is a remit outside the farm with regard to that but it's not a big part of the work the other big change since 2002 is of course the Aquaculture and Fisheries Scotland Act and 2007 and laterally 2013 in relation to that again it's very much focused in the farm in relation to escapes it does give some reference to the ability to trace escapes outside farms so that is part of that and the other thing coming back to the animal health regs one of the biggest threats that we have in the Scottish Wild Salmon is of course exotic disease particularly a particular threat from a parasite called erudactylus solaris is eliminated at the moment through the measures we have in place to prevent risk of import through trade so that both enhances or protects entirely protects all stocks both farmed and wild in Scotland from that particular parasite so that's an example where the powers we have do cross boundaries for listed diseases Is there not a risk that you all do your own thing and we end up with a system that does not regulate an industry in the way it might most appropriately regulate it? I think in relation to my own area of fish health certainly through the programme for governments developments of the farm fish strategic health framework that involves a number of regulators to deliver an optimisation of an improvement in the overall fish health in Scotland that involves SEPA as well as Marine Scotland and there are other examples where in relation to the EMPs the environmental monitoring programmes are discussed there's a reliance on science within those programmes because industry will have to demonstrate that they aren't having an impact and science is very important for that although it's not a fish health inspectorate aspect if I may in relation to Marine Scotland's science there is relevant work that we draw on in the fish health inspectorate we rely on scientific knowledge to make risk-based and evidence-based decisions so just in relation to the work we're doing on the wider aspects we've got a long-term programme of research that's looking at the distribution of wild salmon and the migratory routes and we can use this to inform together with information on the location of lice in the environment can inform a planning process or inform the planning process through that knowledge it's not a finished area I think salmon's referred to at least a 10-year programme to get there but we've started on it and there are several published peer review reports that aren't in the salmon's report so we focus more on the coexistence of the sectors and being able to advise on planning but we've developed tools for the monitoring of lice in the environment the migratory routes of salmon and sea trout and we have evidence of in relation to settlement and impacts on individual trout and that's available we're not yet there in terms of understanding how we take that to a population impact and there's research which is recently, and I started about three years ago through the Scottish Aquaculture Research Forum of Funding which aims to identify impacts on wild salmon okay to add in in respect to our own controls we would be unable to operate without having close dialogue with Marine Scotland quite the link between fish health and the use of medicines so as an environmental protection agency always to try and reduce the impact on the environment be it either organic loading or chemical loading working with them in respect to the fish health and changes therefore it's quite integral that we're referring to and the potential therefore to ensure that what we put into any car licence doesn't then lend itself to perverse practice is relevant for ourselves as much as it is for any other regulator sitting at this table in terms of the interdependencies between each of the regulatory strands of work okay, before we open this out of the course it's just one kind of wrap-up question as regulatory practitioners what are the big gaps in regulation that you can see that are required to be filled for the benefit of the environment at Markle? I think the most obvious one from our point of view is the protection of wild fish particularly in respect of sea lice as the planning authority we're generally content to rely on the other regulators and their work on disease control obviously inside the pens and in terms of benthic modelling and deposition of material around the cage that's as comprehensive a regulatory procedure as we would deal with in other areas but it does seem to us that the issue of the externalised impact on wild fish through sea lice is something that we've had to actually move ourselves as a planning authority forward on simply to satisfy ourselves that something is being done which sort of takes us back to the precautionary principle in order to avoid having to say well we can't take a decision here because we just don't know we've had to move that one on and I think that's from our point of view that is a problem that's shared with Marine Scotland a consultee for us but of course are not in a position to support or object on sea lice impacts on wild fish because that scientific data is not there in order to allow them to defend that should it be challenged Interesting, thanks Let's open us out on fish health immortality Kate Forbes You'll have heard as we did the comments from the earlier panel about the level and the cause of fish mortality what would your response be to those comments in terms of the extent of fish mortality So perhaps I could kick off with that That was from the panel this morning Although I could widen it further What is your view on the level and the cause of fish mortality With regard to the level I think I'm not excusing this but with any livestock production there will be health challenges and the agriculture industry is no different to that The causes of the mortality we don't have absolute rigorous scientific evidence attributable to every event and every cause but I can summarise what we do know and that is last time we looked at this in detail through a cross section involving one big company we showed that about one third of mortality is caused by infectious disease and two thirds were caused by other causes particularly challenging in relation to what David Sanderson was saying harmful algae phytoplankton microscopic phytoplankton that damage the gills cause irritation of the gills likewise quite unpredictable jellyfish blooms as well which can cause issues as well as other events such as storms in recent times the mortality has increased and I would agree that the complex between the gill health challenges and the bath treatments associated with those ring with our what David said about those ring with our experience that the mortalities might not be necessarily attributable to a classical infectious agent but are a complex mix of environmental factors including the presence of a para-omeba which is associated with the gill health problems and that's a natural amoeba we don't precisely know where it comes from but it has been found to grow on the surfaces of farm equipment so it could be that there's a place in the environment for this naturally and that it's found an opportunistic place in farm salmon in terms of the infectious agents we see some viral diseases particularly resulting in some heart problems in fish and of course you mentioned the synergy between different problems if fish are affected by heart issues then and the gills are also affected then it puts a respiratory challenge on the fish I would also agree that the availability of the veterinary advice and this is another thing that's changed since 2002 the availability of specialised fish vets has expanded massively we've got laboratories that support them so the industry do have access to vets who obviously have an ethical obligation for the care of the welfare of the animals so that aspect is certainly covered in terms of the legislation Does anybody else have any comments? Could just come in from the planning authority point of view the actual mortality rate is to say will not be a material consideration for the planning authority in making its decision there's enough positive obviously we take our decisions in reference to policy, national and local and there's certainly enough positive policy in existence to suggest that the industry as a whole the whole setup of of agriculture is something that the government wants to support and local authorities should support it one of those factors that we would take into account there Alec Rowley in Mark Ruskell Just on that point you made about the material consideration would the material consideration be however that we've seen that the level of immortality was around the 90s and 2000s 20 per cent of fish stock and that's risen in recent times by 25 per cent how that's disposed of so we see the lorry runs the salmon runs as they call them the lorry loads a dead fish millions of fish that are being killed is that a material consideration when looking at planning? It could be it's not one that's been raised with us but I think if it was raised that we needed to think carefully about how dead fish would be moved from the site and presumably through the road system I'd certainly be looking for comment from my roads colleagues and Transport Scotland perhaps on the appropriate way of doing that and other regulators if indeed the transport of dead fish raised other regulatory issues it's not something that's been done so far but I think that that would be material a physical impact on the road system or raises other issues Robin Meenard Marine Scotland Science the fish health inspectorate a statutory consultee in the planning process and in relation to our responses with regard to our responsibilities on fish health we will be taking account of whether the farm has in place the provision for dealing with large scale mortalities and indeed on the authorisation process that we undertake with the farm through the biosecurity measures plan they do have to have in place protocols and procedures for how they will be handling mortalities in fact removing mortalities also from the cages environmental effect the farms are removing mortalities on a very regular basis and that's of course is minimising pathogens going into the environment in relation to the impacts on wild fish which is referred to in the Sam's report from disease we take a slightly different interpretation to themselves on the Wallace 2017 paper which we interpret as and it was conducted by Marine Scotland Science we interpret that as including a lot of very structured surveys that provided the evidence that in actual fact the impact of infectious disease on wild fish was likely to be very minimal and on that basis we've actually focused our resources on to trying to understand the sea lice interactions as being a more beneficial use of the resources that we've got available but thank you convener could I just take up the issue which my colleague Alex highlighted about the transportation and disposal of dead fish which is particularly important in view of the mortality that's been discussed this morning and ask any of you as regulators or as a local authority whether you have a view on whether the regulations and the protocols and the possibilities of prosecution and enforcement are appropriate and I just refer you to an FOI which produced evidence about something that I quoted in the previous panel session about an accident on the A9 and the FOI shows that the police only reported this is what the FOI shows I'm just clarifying that only reported that to Bear Scotland and the incident was a photographic evidence shows that the incident was that there was a lorry with simply a tar pulling over it and I stress it was photographic evidence which I've been shown so I wonder if there's any comment in view of the amount of mortalities about if we've got it right and if not, how we should change it so CPL doesn't regulate the animal byproducts order but we certainly regulate the transportation of waste and in respect to the mortalities now that there is no longer a derogation for disposal at landfill sites we are concerned about the previous question about concerns around the level and volume the facilities that they're receiving these dead fish are licensed by ourselves under different pieces of legislation and quite concerned to ensure that when they arrive that they're not then giving rise to problems within the locality like any other waste stream particularly organic wastes so there is and we will be exploring in more detail with the industry because we license on the basis of environmental impact concerned that the numbers are then not lending out to the product in which they're been licensed for and the sustainability of that from an environmental perspective together with the transportation and then the on-going issues that may then present themselves further flung locations transportation is any delay can then give rise to a problem at the point of receipt and clearly that is part of that wider focus in terms of our regulatory approach which is to look at the entirety of a sector in this case the fish sector and looking at all avenues in which we regulate it to ensure that there is full compliance down that line that is the discussions that we're having at the present time to have as we move into the sector-based regulatory approach that we're doing underneath our regulatory strategy Just before anyone else comes in if they want to could I just ask you for the record how the dead fish are disposed of so there are energy from waste facilities that do receive that material so anaerobic digestion plants that receive it, they are further flung so one of the key things is identifying a proximity solution for a range of organic wastes and I think that that is an essential part of the discussions that we're having Is there any other comment on that question? You're interested in what happens in terms of the environmental aspects of the waste there's a report by Zero Waste Scotland in 2017 that I don't know if you've seen it but it looks in essentially it says that this waste is actually quite valuable because of the lipids and the proteins that are in it it's actually high quality lipids and proteins and it identifies routes in which the products can be used even in areas of farm cuticles Right and thank you for that, I didn't know about that but also in terms of the actual transportation or remit Transportation, no That you have concern about We're concerned for sure that the transport needs to be contained from the spillage point of view How should it be contained? It should be contained to prevent Is a truck with a tarp pull and a top acceptable? There's no what generally speaking is regulators who don't specify this isn't my area of regulation So whose area would it be? I'm not trying to quiz you I just want to find out whose area would it be because there has been concern expressed about this environmental aspect of spillages and that The answer is I don't know is that it might well fall to either the roads authority as a local authority or the trunk roads The animal by-product regulations are enforced by the animal and plant health inspectorate and in respect to the transportation like any organic waste you would expect certain levels of containment from an environmental perspective concerned about the potential in that particular scenario that you made reference to must be around discharge into watercourses and the on-going issues that might present but in terms of animal by-products it is the animal and plant health that are the inspectorate purely because it is an animal by-product in any other context it would be duty of care and under the environmental protection act fall to waste legislation controls which would be SIPA but there is a lead authority purely because it is an animal by-product and that is not ourselves but another agency Cross call wants to come in briefly Mr the issue of transportation of ever growing numbers of dead salmon is really a symptom of a wider problem so can I come back to the issue of salmon mortality again can I ask Rob Reynard what is an acceptable level within a salmon production system we have seen figures referred to in the previous session of 4% 40% from a fish health perspective what do you see as an acceptable level for a production system I don't think we can identify what is a desirable or acceptable level it's 40% acceptable it depends what's driving the cause how that's a recent change what's the industry doing about it I think the context is critical and I do know genuinely that the recent increase as I said before is largely driven by environmental factors and industries including those in Norway are joining forces with Scotland to actually understand what those are and what the solution is it's not something that we like nobody likes but people are quite concerted in the way that they're approaching it and it's an international approach to solving it there is the there's an international group called the Gil Health initiative they meet annually it's industry, researchers, regulators they actually look at how the science has moved on what's causing this, what are the solutions and we heard some of those solutions from David this morning and those types of fora are where best practice is developed to tackle that so if the industry has a high mortality and nothing's done about it is that acceptable, no if they're tackling it and it's driven down is that a good thing well that is a good thing it was mentioned before that other livestock industries have mortality issues you mentioned there about context the context of this inquiry is that the government and industry want to double production by 2030 do you believe that salmon mortality will go up or down if we double production as a percentage terms and what do you see as an acceptable level of salmon mortality, is it acceptable the caution of the fish die before they go to market just to clarify a point the aquaculture industry leadership group identified the target the Scottish government support the target if it's reached sustainably and that is the question so would we support a doubling of production with such a high mortality that's a more difficult thing to say but what was coming out from the discussion this morning was that the industry will need to address these mortality issues in order to be able to expand so is it being reached is that target being reached sustainably at the moment given the mortality levels that we have I think mortality levels at a certain level given that if the mortality is having an environmental impact then it's an environmental issue but a lot of the mortality at the moment isn't having a big environmental aspect and is more of an economic sustainability and in terms of economic sustainability that is more for companies to address so just to quantify this let's come at this from another direction to assist the line of questioning Mr Ruskell's developing mortality rate in Scottish aquaculture compared to aquaculture elsewhere take Norway for example okay so Norway are currently experiencing mortality events in the region of about 20% which the long term average in Scotland was around 20% and it's gone up largely through these gil health environmental issues and the associated treatments to tackle that but the mortality the mortality in Norway is also something that the industry and regulators are keen to tackle as they are in Scotland so we're not saying it's acceptable but we were told last week that there was considerably more science taking place in Norway than there is here to look at these issues is that the case? by and large that is the case and we often the techniques and technologies that are developed in Norway are often transferred across into Scotland and Ireland and indeed Canada and Chile and I mentioned the gil health initiative which brings industry and scientists and regulators from across the sector, the international sector together to share best practice I think everybody wants to drive the mortality down and in terms of what the government is doing through its development of the farm fish strategic health framework is the right thing to do bring everybody together and tackle this cohesively okay just to wrap up this section Richard Lyle briefly in my mind's eye I am getting picture of dead fish on a lorry swallowing about in the road depositing liquid on the road surely that is not the case surely we have a big self contained lorry that does not leak on the road surely that is the case of Amarón yea right sometimes tankers can be used tankers are very sealed I guess it comes down to the availability of vehicles at the time but it is not that is no excuse for not complying with what is required of the regulation why can't it be handled on the site if fish are dying locally at a fish farm is it because 3% has got to go to a certain place or is it because the facilities are not there or is it because they are not invested in something that they could do something with fish there are small bi digesters that are available to put into sites that can deal with in most cases there are small mortalities that are almost inevitable but these large scale mortalities they are of such volume that they really have to be dealt with off site the maintenance of a digester for example that could handle 150,000 fish would be huge but it might only be needed on a site once every five or six years if that so it's about the cost and benefits proportionality very briefly one is that we saw the BBC following lorries along narrow roads stuff coming at the back I want the roads and whatever we've seen that transportation of the dead fish is not what should be but could I pick up on the point you made Mr Reynard, where you seem to say that having all these dead fish did not have any impact on the environment it was simply an impact an economic impact I mean that would be stretching that a bit surely there is with that level of mortality and there is an environmental impact there is then what the companies are doing to try and tackle stuff like sea rice so is it not a big leapy face to say that there is no environmental impact of fish farming and the fact that 25% of fish farmed are basically being killed because of the disease a clarification I guess there will be some environmental impacts but what I was trying to put her forward was that in terms of disease because the mortality is removed on a regular basis the environmental risk from the disease is minimised and then it becomes as you say the environmental aspects of the logistics or the loss of biological production by the business which has had environmental import to generate there is that aspect to it so yes there is an environmental aspect just quickly perhaps just to put that in a more ground package that hasn't been mentioned so far most fish farm planning applications come in as they're considered to be environmental impact assessment applications to cover that ground and come in with an environmental statement I think I'm right in saying that most environmental statements will include a short section on disposal of of mortalities I suspect certainly in my mind now that maybe that's an area that planning authorities just need to put a little bit more emphasis on or indeed the applicants need to put a little bit more emphasis on to cover these questions because these questions really shouldn't shouldn't be existing if it's a feature of the farm in its production then at least the impact on the road is an environmental impact that needs to be addressed and perhaps in that context identifying a location for the disposal of these fish as well picking up on an Anderson's point I think you'll probably need to go that far yes do you look at the discharge of medicines into the marine environment John Scott? A quick question for Sipa for Anderson can you tell the committee about the recent work you've done around the environmental quality standards for emecton benzoate and where do we go from here so Sipa ememecton benzoate has been operating to environmental quality standard that was set a number of years ago and in respect to the recent work that we've done we commissioned a desk-based study of all the available intel in respect to ememecton benzoate that concluded that and recommended a tighter environmental quality standard that particular piece of work is going to the UK technical advisory group on a body that is set up under WFD which utilises the principles under the environment European Union directives to ensure that there is consistency in the setting of environmental quality standards so that particular report is going to the UK TAG body for a peer review exercise as is common with any scientific document and out from that particular process do we expect to get a response to the body of work that's been commissioned to date the intent then is for it to be provided to Scottish Government which again is consistent with environmental quality standards under WFD and receive a Scottish Government direction for the use of that standard in the interim period we have information that lends itself for a tighter control of MMI and have put into place a position statement which accommodates the current situation up to the time when that piece of work is concluded the focus and protection is at the precautionary end in respect to all new applications where there is a marine protected area or a priority marine feature identified through that planning and application process where there are features that are believed and identified in the process where MMI may impact that tighter standard is being adopted and is placed in respect to that measurement and usage of so at the present time that process is under way it's moving through to the UK TAG over the course of the next month and then we're waiting for the output from that particular piece of work we utilise the best available information and we then identify where we need to employ that stricter standard and certainly in this case we have done so in areas where MMI has not been utilised before and specifically where we have a population or sediment of concern Thank you and can I just ask you as well generally about should sediment quality be incorporated into Marine Scotland locational guidelines as suggested by Professor Tett last week and all those you've put out so we use in terms of the assessment process there is a locational guideline document that we use and we also use the additional information to hand so there's a range of different packages of information clearly having it all within the one frame would be a step forward it would be a positive improvement the overall assessment of cumulative impacts and spatial locations is an area that I'm certainly very keen to explore with other regulators and we've been discussing that aspect because there are as I think identified last week there are gaps in the information and ability to fill those gaps is key I'm going to bring Mark Ruskell in the minute to a supplementary question and to move this on into the issue of nutrients but can I just pick up on the more general issue of marine protected areas and protected features the report indicates in 2003 there were 16 salmon farms sighted above Merrill beds we've learned since that there are currently 25 located within MPAs that are designated for Merrill beds we also told it two years of following does not allow recovery of beds why and after we allowing the salmon farms anywhere near these features in respect to the information available at the time we do a baseline assessment that is undertaken and we analyse the information available from other bodies so every application is assessed on a range of environmental factors in respect to the Merrill beds there are recorded in and around the reference stations reference stations are outwith of the zone of the actual impact so they're the baseline set aside and in terms of that available data we have got recognised information it forms part of the key aspects of a planning of the car application process the need to do that baseline and seabed assessment and provide that information at that stage to identify whether or not there is a marine protected feature present and in this case Merrill beds so sorry in layman's terms do we have fish farms located sufficiently close to Merrill beds within the NPAs where they could be having an impact is that happening or isn't it so the information I have is that there are 29 sites which are currently recorded positioned in and around areas where Merrill beds are present of those 29 Merrill has not been recorded to be present recently at 13 of those facilities so the answer would be yes there are in and around the location of and the identification of that those are existing and on-going facilities so they're having a detrimental effect on the Merrill beds I am I can in terms of that the facts I have is simply that there have been recorded presence of Marl there is now currently 13 recorded to be present at this time period and that's from respect to recent information right Mark Ruskell Do you think that there should be a phase out on the use of Emma Meckton and if so, over what timescale? SEPA has undertaken a reduction in the use of Emma Meckton blanket variation applied to all active and closed operating fish farms so those operating currently and those that could operate in the next cycle of the quantity of use of the medicine the environmental quality standard the tighter environmental quality standard itself the position and the assessment point hasn't changed that in itself will require a reduction in the use of Emma Meckton by default Do you think that that could lead to a ban on its use? I think that in terms of the decision and the output I'm aware that there are additional research being undertaken at the present time in terms of the ecotoxicity of Emma Meckton then to it so I referred to a desk study that was undertaken based on laboratory information there is a proposal and a research project under way which ties to mimic as best the marine environment so the output from that obviously add to the science in this area it continues and we as a regulator keep informed and react to that changing scientific information If I could turn to nutrients you heard the last panel on their reflections on the new DZR regulation which SIPA are putting forward but you also would have heard some concern about the lack of scientific evidence to underpin that Where do you see the DZR regulation going and should it not expand perhaps to all fish farms why has there been an approach on only looking at expansions in more exposed locations why not the entire industry I don't understand this The DZR consultation has closed we are currently reviewing we received 144 pieces of information from a range of stakeholders both industry communities and other regulatory bodies part of the approach is in respect to the transition so the introduction of a new regulatory approach to fish farming I would envisage that being a transition across the entirety of the fish farm licence process DZR introduces additional monitoring it adds to the information base it also is an approach that allows what has been referred to as adaptive management there's an element of that under the current car environmental licence controls and it's how SIPA as a regulator works is to take the evidence and then to pull back and undertake an action if it's not predicting the environmental impact that was expected so DZR is actually providing a greater level of monitoring greater level of evidence and for us then to be able to assess against that and for the business then to adapt within it's zone of impact Claudia Beamish I think there's a supplementary before we move on to the COIs Thank you convener Could I come back to you please Ann Anderson and ask you in relation to MPAs whether you've highlighted mill beds whether in relation to either mill beds or any other protected feature there is any regulation opportunity if thought necessary to actually stop the activities of a fish farm if it's environmentally affecting an area which is protected and what would that process be if it exists part of the car consenting regime and I will provide details of that particular process to you so I'll do my best just to summarise with that aspect SIPA is a competent authority in terms of Natura we undertake a habitat impact assessment and we also consult with SNH to ensure that we've got the accuracy of the information part of that is to ensure that where we are permitting that that permit is in compliance with the range of environmental information so the habitat impact assessment is done in those instances and specifically with the view as we do on land based activities with SSI process is the same level of protection is provided recently with the MMX Invento we extended that to include priority marine features as we recognised the species rather than the fixed place an identification of a species within an area was particularly important given that it was a medicine thing so in terms of the controls that we put into play that does form part of that assessment process and is something that has become more self-evident over the recent years some of the facilities we referred to earlier are facilities that have been established for quite some period of time if you like of the Finfar sorry I still don't understand in your answer in terms of what I asked is there the possibility how is it monitored once it's happening and is there the possibility of stopping activity if there is shown to be a detrimental environmental effect and if so what is that process in terms of the seabed monitoring and the limit in terms of benthlic and that's based on the information that's present at the time of the application in respect to MPAs there is that assessment that's undertaken under the habitat impact assessment process that's a body of work under natural legislation then any non-compliance with the benthlics requires additional seabed monitoring do we have video evidence of the seabed underneath so there's a stage approach that's then taken in that process and clearly if there is an impact we have the ability then to adjust and or revoke licences any examples of licences being revoked in those circumstances I'm not familiar with but I will check and ensure we certainly do reduce the quantity of impact from farms when we have had failing benthlics it's a very common approach as a regulator to pull back I'm not aware of the specifics of that but I will ensure that I capture that so they may be scaled back in what they're allowed to do is what you're saying but I'll be interested to know how often that has happened and also whether there have been instances where a licence has simply been revoked because of the impact that was identified and revoked but I will provide you with that the accuracy in the detail Claudia Beamish on COAs and indeed if there is the power to do so to revoke yeah, thank you right, so if we could move to sea lice and I'd just like to highlight from the SAMS report for the record as I did last week that some sea lice are a key impediment to the Scottish salmon farming industry in the marine environment and that's the scientific research the peer reviewed research that we commissioned as a committee you will have heard today the announcement by David Sanderson I think about the real time public reporting of sea lice data which was something that was bought forward but not accepted in the aquaculture bill which of course is now an act over five years now do you have any comments any of you from your perspective on the situation in terms of real time reporting and if there are benefits to the reporting being publicly available and if those are in relation to either disease or research that would be very helpful I think any publication of information in this area is really important for ability to be transparent SIPA publishes on Scottish aquaculture website information that we receive and any aspect then is something that any access for any particular work is a beneficial move that the industry have chosen to do and I think that the information around sea lice mapping and locations relate to I mentioned earlier about the interdependencies so being better informed can only be a good thing going forward just before we move on I should have also posed a question to you Ann Anderson about whether in your view or do you have a view as to whether that should be a legislative requirement of the industry I think if it is consistently provided that's the key point what if we believe that there is a need for it I think a regulatory control it requires that to be then applied as I think was pointed out the Scottish salmon producers organisation don't represent the entirety of the Scottish industry and I think it is relevant that we are talking about the entirety of the impact on an industry in Scottish waters that all that information is available at the one time to add weight to the to Arn and D work are there further comments from the panel on that particular aspect of the sea lice issue could I come in just to say it's very welcome publication of the data I suppose I speak obviously because we represent that local democratic and public accessibility to our work is part of our day to day I think it could make a very big change to our work because it's always been a frustration that information about sea lice numbers were difficult to come across certainly on a site by site basis if that's to be available I think one can expect to see a great deal more public comment upon it and certainly we as a local authority are going to have to be ready to be able to handle that comment the other point I wanted to make of course is it it effectively answers one of the questions that our use of environmental management plan conditions has been aimed at achieving which was to allow the authority access to site specific information on sea lice and because of sensitivity about FOI and so forth we are trying to work out arrangements to receive that information on a face-to-face basis so there wasn't any exchange of information hopefully that will not now be necessary and that will allow the focus of the EMP to become to move much more on to the issue of wild fish monitoring the other aspect of it so I think that that openness within the planning system is just a good thing full stop it should be statutory because that allows regulators such as myself to be able to rely on it without getting into unnecessary arguments and costly requests for further information and so forth Are there further comments on that? Thank you Yeah I think good access to data is important for the research and the provision of advice from that research regarding planning etc I think it's not just about real time I can see that real time might be of interest to local authorities etc often from a research perspective one is looking at long-term data sets and you want to be able to compare fish data with sea lice data so having availability to historic data is also quite important strategically I mean our approach at the moment is to work in collaboration with the industry on the availability of data to a large extent that's worked quite well but there have been occasions where it's as Mark has mentioned where it's a bit more difficult there's the work in addition to what David has said that is being focused on in the fish health farm fish strategic framework group availability of data in general and so you know I guess we don't mind how the data is made available but it seems that that availability is improving right thank you and I've got I have three other questions about sea lice I'm going to ask them all at once and please do not feel an obligation to answer if it's not within your scope obviously I'd like to know Mark Harvey's already touched on the potential wild salmonoid impacts of sea lice and I would like to know whether there's a view on removing that from planning into a separate regulatory process would be something that's being considered and is it of any value in your view how is the duty under the Nature Conservancy Scotland Act 2004 discharged with respect to salmon farming and that is as you will know a record that all public bodies are required to further the conservation of biodiversity and finally are there any comments on the appropriateness of the triggers in relation to sea lice for the reporting mechanism and so I would just open that up to panel members please Maybe I can kick off with the last element of your question of the triggers Essentially yes, for the first time we have a need to report sea lice above a certain level it's an average of three female lice per fish and then there's another level which is statutory intervention level of eight how appropriate are they I think the purpose for what they're designed to do which is to enable the industry to avoid the occasions where big peaks occur then they are appropriate the basis for that is the both through discussions with industry's own experience of where lice have got out of control on individual farms that keeping lice below three is a very important level and where lice get above three there's obviously increased risk that numbers escalate on a farm without a plan in place so the new measures allow the plan to be put in place the fish health inspectors to monitor the outputs of that plan and to take enforcement action should that not deliver the results so could I just ask you on that I understand that the SAMS report says that there's no published scientific account of the basis of the setting of the trigger levels in the new sea lice policy so could you clarify for us how those were decided and why do they differ from the code of practice levels so you're correct it's not published the level of three fits with the we did some analysis the long term analysis of the data that industry provides through the SSPO's reporting areas when that is modelled three emerges as the kind of upper mean level which indicates that most of the industry are staying at an acceptable level the requirement of the law is to have measures in place for the prevention, control and reduction of sea lice and demonstrating that the measures are in place we felt was indicated by whether one could stay below three or not so that graph that I spoke about fits with the decision to make three it's not based on pure science that really is a kind of adaptive approach and we've agreed to it's obviously bedding in we've agreed to review that after 12 months which will be July this year and the analysis that we've made of the industry data what we've got there is a Scottish model that we're about to publish on that so unfortunately it wasn't available for Sam it will be published very soon and that's showing that the seasonally adjusted level sea lice go up and down based on season and the seasonally adjusted level at the moment is the lowest it's been for the past three years so it's come down over three years from about an average national level of 2.5 to around about 1 so that's one average female louse per fish as a national average but of course the measures we've got in place are ensuring that individual farms don't lose control thank you sorry I should point out that the SSPO's codical practice numbers of 0.4 and 1 aren't limits that are set by either the SSPO or ourselves they are the level at which veterinary intervention should be consulted right thank you so are there very briefly any comments on the other questions from yourself or anyone else on the panel I've come just again planning authority views slightly different you've mentioned the biodiversity duty the biodiversity duty is very much in planning authorities we need to understand their minds when it comes to the protection of wild fish in respect of sea lice that's really where we continue to emphasise that we need to show in taking a positive planning decision that we are addressing that biodiversity duty as well as we possibly can there's room for debate there this discussion of triggers probably your first and your third question from my point discussion of triggers probably is a good example of why these matters are best left in the planning realm not exclusively but I think it's important that there's loads of control because it seems to me that this assessment must be site by site in our own area we have SAC rivers so that these are protected rivers some of them protected because they represent some honoured breeding areas some of them because they contain freshwater pearl mussel populations which rely on some honnids to distribute the young mussels and continue that process clearly when we're looking at a planning decision therefore there are sites of greater and lesser sensitivity and I think it would be appropriate therefore that we're applying perhaps less tight control on control on sea lice numbers so I think a one regulation or one set figure that suits all is not necessarily appropriate we can move on actually to perhaps the issue of wildfisher at a later point any other comment thanks Richard Lyle I've got two questions I'll try and be brief there is a desire to double our salmon production but we have as I see it amongst others two problems 20% fish mortality over 20% in fish escapes over two million fish have escaped in the last 15 years ok people may say oh it's only 147,000 a year but it's 147,000 too much so does a fish farm face any regulation consequences if fish escape and do the report escapees to anyone at present yeah so reports of escapees are provided to fish health inspectors there's a requirement for Fisheries Act for businesses to report an escape or even suspicion of an escape there's a requirement for farmers to have in place measures to prevent and control escapes as well following an escape fish health inspectors will visit the farm and investigate whether or not they consider best practice in relation to containment had occurred at the moment much of the inspection is focused on the elements of the codical practice which is considered to be best practice plus record keeping elements that are required by statutes and as mentioned before David Sanderson mentioned that there's an development of an industry a Scottish containment standard that could become part of that in the future to make things more robust so the inspectors will take any enforcement action depending on what they find so they find are they fined or is it just a you lost fish so try and do better than next time no there's no fine for escapes in Scotland there's the measures that are in place under the act are that an enforcement notice can be issued and that's obviously not complying with an enforcement notice is a criminal offence but many of the issues that are found are dealt with through written correspondence so no one's taking to court no I'll move on there's a notification to assist on that line of questioning the 140 odd thousand fish every year that we know escape is that indicative of a widespread problem or is it largely made up of a number of relatively small incidents of large a small number of large scale escapes the large scale escapes tend to be associated with extreme storms often storms where people end up dying in Scotland which is we don't want any of that to happen but occasionally it does the data for the last three months is there were five escapes reported one had six one had about sixteen hundred two had zero because they were suspicion, they reported suspicion of escape so that would be maybe a small hole because the nets are frequently inspected maybe a small hole is found and that's reported as a suspicion and another one was five hundred so it's pretty varied it is varied, yeah so there's quite a lot of incidents then based on what you've said to us smaller amount but why you've varied what monitoring research is taking place to understand levels of integration in Scotland does more need to be done in this area yeah I can maybe continue with that one Marine Scotland's exploring the development of a regular system to of national assessment for interagression one of the challenges there has been research looking at integration in Scotland it's reported in the SAMS report what's not mentioned in the SAMS report is that something that's hindered the research has been the past practice, it doesn't happen now but historically some farmed fish were deliberately released for restocking purposes into some rivers and those genes because those genes are present from historic it's not really anything related to escapes because they're there historically it means that the genetic tools that have to be developed are much more difficult to do so but Marine Scotland have an assessment in place to look at that okay, thank you thank you Mr well, Stuart Stevenson a very quick question with a quick answer I suspect do the Government and any of the regulators have a role in regulating farmed salmon food nope, I've got a shaking head there oh sorry nesan doesn't under dependent on the scale and size of the feed processing plant we do have feed processing plants in Scotland that are required to have a permit under pollution prevention control legislation and there are areas within that that pertain to raw materials and resource efficiency would that address the issues sustainability and influence the balance between sea based product and vegetable product it certainly allows the potential to have those discussions to date they haven't taken that route because it has largely been a resource efficiency issue around energy and water and other materials but in terms of our approaches going forward it will be featuring right, so we have the powers we're not yet using them right, moving on the report we have as a committee it says a number of things on the list additional regulation of shooting could improve seal welfare e.g. through the reintroduction of closed seasons for shooting corresponding to the main nursing periods for sales validation of shooting reports and additional post mortems and shop sales could increase the proportion of clean kills is there seen by any of the panel members as a need to act on any of these issues yes in relation to the shooting aspect I think it's important that we always maintain a position which is clearly that the shooting regulation, if you like, the legislation was brought in to helpfully reduce it in terms of the restrictions you would place in terms of protecting the population yes, those facilities are available within the regulations and conditions can be applied to licences to restrict during periods of concern with respect to say season etc ok, thank you and finally on the issue of ADD noise related pollution is there a case for better monitoring and licensing well absolutely in the sense of the interest in the subject earlier on today one can tell for discussions that are quite different opinions which makes it rather difficult sometimes to bring some sort of common place some common theories into place however, the bottom line is that in the SAMS report identifies the necessity to do more work we would agree with that it's important for that to happen Marine Scotland as an entity has a desire to pursue that we would work collaboratively Scottish natural heritage I think that what's most important is that in making decisions on whether you want to regulate need to regulate, there's a requirement to regulate it has to be based on good evidence and in doing so we have to be able to collect it there are pretty much pretty good bits of evidence out there but they are quite different so you have to be able to take a balanced view which is really difficult in respect to making proportionate decisions and look into what you might actually be restricting in the future if that's the route you would take so at this point in time we don't lose sight of the necessity to give it a very rigorous consideration and we would work towards trying to get ourselves to a place to make a decision Who's got the lead, is it Marine Scotland or SNH? Marine Scotland would work collaboratively SNH yes very much so SNH would be important to that decision making as would others like the CMAMO research unit and indeed others like Marine Scotland Do you forgive me who's got the lead? It would be ourselves who would presumably be able to take the lead in that we would expect to do so at the moment Oh yes Sorry, it was only that this issue of ADDs was rather thrust on us in the last couple of years because my general area of work is sky and the water surrounding sky are now a candidate SAC for harbour porpus so it immediately became a much more important material consideration for us. Our response to that is actually to put a condition on any permission granted that requires the operator to retain a log of ADD use but actually more importantly and above that through discussion with SNH because SNH obviously are also facing a situation where retrospectively they may need to look at the use of existing ADDs on existing farms and potentially take action in terms of requiring adjustments to the way in which they're used As a result of that we've also been looking at whether particular equipment can be tuned because obviously we're talking about sound frequencies underwater here whether it can be tuned to affect seals but not of course affect harbour porpus and indeed other cetatons which is a similar problem so both the planning application stage and subsequently through the compliance of the condition we are trying to control this one because obviously the existence of an SAC makes it a pressing issue for us. I don't want to open up a huge subject but presumably we're monitoring noise at the torpedo range adjacent to Sky which is adjacent to the SAC anyway. Yes although we're not feeding that information we're not trying to feed that information at the moment. I'd like to ask Mr McKee about the regulations that we have in place which allow the killing of seals in Scotland. My understanding is that this falls foul of the United States Marine Mammal Protection Act which quoting the act prohibits the intentional killing or serious injury of marine animals mammals in all fisheries and as a result of that we could be facing an export ban just on Scottish salmon but indeed all of our fisheries products in four years. Can you tell us what Marine Scotland is doing to try and address this situation? Are you for example looking at withdrawing that regulation which allows the intentional killing of seals or are you lobbying Mr Trump to try and change the regulations? Thank you. The position is at the moment in relation to how we're tackling it directly is that's a matter which is being dealt with part of Marine Scotland and indeed in a wider part Scottish Government to understand exactly what it means in terms of what's required, what the expectations are and then from there that will then feed back into how we then react from a regulator perspective so we don't yet know exactly where we are going at. How much concern is there around this because the words in the US Act are any regime which allows the intentional killing or serious injury so intentional killing is what we actually have in relation to seals. We have a license regime for that. Whether serious injury caused by ADDs or other techniques which may scare away Marine mammals is another question but I think it's quite clear we've got intentional killing. Obviously I have to say that from my perspective clearly I'm at the sharp end there's people who are sitting behind that and it is a case of, it is a concern yes it is a concern, it's been treated as a concern and discussions are underway to try to verify and consider exactly what it means and then obviously that will then help to feed into the decisions going forward. Time scale for that because if the salmon industry loses the US market I would imagine that's pretty chunky. I appreciate that point I don't know the answers to that but clearly that's something we would need to come back on. Can we see on that to the chair? That would be a good use. No problem, thank you. Thank you, Finlay Carson. In the use of wras as a cleaner fish is there any need for additional regulation of the well fisheries to deal with any impact? I can answer that. So Marine Scotland's holding discussions with all stakeholders in the industry and fishermen as to what management needs to be put in place we're quite, obviously quite serious about needing to protect the environment with the numbers being taken out and we know that the fishery in south west England is managed sustainably so what we've done already is licensed the fishermen required data collection from landings and that will be important data that's put into the management subsequent management of the fishery and there's discussions going on this month to decide what needs to be put in place before the fishery starts in April Finlay, just on the subject of mitigation Alex Rowley Good question Fisheries Management Scotland have said that the regulation system for the salmon farming industry is unusual because there is no formal requirement for pre-application or post-consent monitoring of well fish as there is for many other developments why is that the case and does it need to change? In terms of post-consent monitoring we'll go back to the environmental management plans that we've started to introduce in planning applications I think that's as far as it gets so I think the answer from a planning authority point of view is yes we do think there's a need for post-consent monitoring these are unusual planning commissions and obviously they are permanent planning commissions they last forever different cycles it's not like granting planning commission for a building it's there, you can pretty much work out what it's going to do these are active and consequently there's very much should be subject to ongoing monitoring I don't claim the EMPs are the perfect tool but they are something moving in that direction The final question from John Scott John Scott You may have heard me discuss the possibility of engineering solutions in terms of scooping up when gathering the detritus in below FISFARMS and the possible development of that to scoop up the waste Do you think that engineering solutions are part of the answer to the deposits that are placed in seabeds that carry all the attendant risks that may carry the attendant risks that we have defined thus far so do you believe engineering solutions are the way forward I think you're absolutely correct there is a range of solutions we've heard reference to complete containment but there are many different steps up to that point and accessing through is an element that we've been particularly looking at globally a colleague has recently come back from the Tasmanian project that Sam Collins referenced earlier and that is very much centred around the capturing of as much of the detritus so I think that definitely is something to be looking to the future Given that you've done that piece of work there's obviously something on your sight has anyone looked at the point that was made in the earlier session of the increased carbon footprint of moving to closed containment onshore, rearing a fish set against the environmental benefits of that approach so that's an area of work that we're looking into at the present time I made reference to SEPA's regulatory approach at a sector level for finfish farming so we are looking at all of its activities from the generation of that egg through to the production of the final product to plate part of that is assessing these new technologies and is it a substitution of another pollution problem is very much featuring in that assessment at the present time Does anybody else want to come in on those two points Mark Harvey I suppose the issue about sustainability of one environmental impact versus another depends on how sustainably Scotland's producing its electricity if it's to run on electricity for example I mean it's a relevant question it's reliant upon on other things it does seem to me that land-based containment raises a bit of a planning problem it is land hungry these would be quite large installations I don't think any planning authority could guarantee that it could immediately identify enough sites so that also raises an environmental issue I think it's suggested in the report of our member correctly that each of these sites would need its own sewage treatment plant yes that's why they're energy I mean that's technically quite feasible but of course requires energy to drive it to add in there are some early research into the use of research catchery wastes for the purposes of that future sustainability recent project that SEPA is involved with in industry and other partners around identifying sustainable uses one of those elements will be considering the detritus that falls from the bottom of the cages so there is work underway with that very aspect in mind okay I'm interested in this idea of a lander as it were going from where we are to ultimately land-based solutions there's a lot of steps in between and I think those should be investigated I must say there is a range of different products that are being trialled globally certainly discussions within the Scottish scene around the usage of them I think it is also very much locational and the flexibility around different solutions for different locations is absolutely fundamental to those conversations at the present time thank you for that thank you all of you for your evidence this morning I thank the first panel as well at its next meeting on the 20th of February the committee expects to consider a draft report on its air quality in Scotland inquiry we will now move into the private session and I ask that the public gallery is cleared as the public part of the meeting is at an end thank you