Download objection from the Global Alliance Against Industrial Aquaculture

From: Don Staniford [mailto:[email protected]]
Sent: 19 January 2017 22:49
To: '[email protected]'
Subject: Objection to Kames Fish Farming Ltd's Dounie Marine Cage Fish Farm, Sound of Jura
(CAR/L/1152438)
Please consider this an objection by the Global Alliance Against Industrial Aquaculture to the
application by Kames Fish Farming Ltd's Dounie Marine Cage Fish Farm, Sound of Jura
(CAR/L/1152438):
According to the Non-Technical Summary, the proposed site is a mega-salmon farm with a
maximum biomass of 2,500:
Please note that 2,500 tonnes is the largest of any salmon farm currently operating in
Scotland and the industry average is 1,159 tonnes. Even with such high biomass limits there
have been significant breaches of biomass limits:
[Read more via Press Release: "Recipe for Ruin - SEPA Lifts Limits on Salmon Farms"]
By contrast, the maximum biomass for salmon farms in Norway is less than 1,000 tonnes:
"The maximum allowable biomass per licence is 780 tons, except in the counties of Troms
and Finnmark where the maximum allowable biomass per licence is 900 tons. There are also
biomass limitations on the individual production sites. The biomass limitation varies from
site to site and is determined by the carrying capacity of the site."
[Quoted from the Norwegian Government's web-page "Licence Requirements in
Aquaculture"]
According to the Chemicals and Medicines document, Kames Fish Farming Ltd may be using
a dangerous cocktail of chemicals including Azamethiphos, Deltamethrin, Emamectin
benzoate and antibiotics:
Over two decades of scientific evidence has shown how the chemicals used to kill sea lice
can also be lethal to shellfish such as lobsters - read via "Scientific backgrounder: Ecotoxicity
and chemical resistance".
Data obtained by GAAIA via FOI last month also revealed that the use of toxic chemicals to
kill sea lice has increased ten-fold in the last ten years due to chemical resistance and the
expansion of the industry.
Read more via
Press & Journal: "Scottish salmon farming ‘fighting a losing battle’ against sea lice"
The Times: "Toxic war on salmon lice soars 1,000%"
Press Release: Scottish Salmon's Lethal Legacy
The Sunday Times: "Salmon industry toxins soar by 1000 per cent"
Moreover, research conducted by SEPA has consistently revealed benthic contamination by
chemicals used in salmon farms - including areas in Argyll & Bute region:
Read more via:
Revealed: the dirty dozen salmon farms that contaminate lochs with pesticides
Revealed: the toxic pesticides that pollute our lochs
“Pesticides killed my business” reported The Sunday Herald in 2011 following reports by
SEPA of chemical contamination near salmon farms: "I’m convinced that the prawns were
killed by the chemicals used by fish farmers to treat sea lice," said creel fisherman Donald
Macleod. "There’s hardly any prawns to be found in Loch Shell any more unless you go
some distance from the salmon cages, he claims," continued The Sunday Herald. "And
prawns aren’t that different from the sea lice that the chemicals are designed to kill."
In fact, we know from data submitted to SEPA (and published online via Scotland's
Aquaculture) that Kames Fish Farming Ltd uses significant quantities of toxic chemicals and
has significant mortality problems at their sites. For example, here's a data entry for July
2016:
According to data obtained by GAAIA via FOI from SEPA here's ten instances since 2010
where Kames Fish Farming Ltd has used the toxic organophospate Azamethiphos:
And here's the instances of the use of the marine pollutant Emamectin benzoate since 2008:
The toxic chemicals used on salmon farms - specifically labelled by chemical manufacturers
as "Marine Pollutants" - were designed for use in terrestrial farming systems to kill pests on
land with specific caution that they are "very toxic to aquatic organisms" and hence must not
be used near waterways let alone in the sea on salmon farms (read more via "Silent Spring of
the Sea").
The chemicals used on salmon farms target and are designed to kill sea lice parasites which
are crustaceans. "Deltamethrin is a potent biocide, which formulated as AlphaMax is
designed to kill small crustaceans in the form of sea lice," admitted SEPA in 2008. You
therefore do not need to be a rocket scientist to work out that chemicals designed to kill sea
lice can also kill lobsters and other shellfish (read more via "Silent Spring of the Sea";
"Scottish Salmon's 'Silent Spring of the Sea'"; and "New Scientific Paper: Salmon Farming
Chemical Kills Lobsters!!" ).
Here's the top 20 instances of the use of Deltamethrin by Kames Fish Farming Ltd
(acccording to data obtained by GAAIA via FOI from SEPA):
The salmon farming industry's increasing dependence on toxic chemicals has led to drug
resistance as well as significant environmental concerns (read more via "Drug resistance in
sea lice: a threat to salmonid aquaculture" published in Trends in Parasitology in 2015;
"Chemical use in salmon aquaculture: a review of current practices and possible
environmental effects" published by WWF in 2008 and "A Review and Assessment of
Environmental Risk of Chemicals Used for the Treatment of Sea Lice Infestations of
Cultured Salmon" published in Environmental Effects of Marine Finfish Aquaculture in
2005).
Chemical resistance has been reported since the 1980s when sea lice developed resistance to
the organophoshate Dichlorvos and salmon farmers responded by developing more lethal
weapons in the ‘war on sea lice’ (read more via ‘Silent Spring of the Sea’). A chemicals
‘arms race’ has been waged ever since as salmon farmers fight a losing battle against their
nemesis - the sea louse (read more via "Sea lice - a never ending battle"; "Sea lice resistance
to chemotherapeutants" and "Plague of ‘Super-Lice’ Threatens Wild Salmon"). Scientific
papers reported sea lice resistance to Azamethiphos in 2004, Deltamethrin and Cypermethrin
in 2005 and Emamectin benzoate in 2008.
A scientific paper - "Repeated sublethal exposures to the sea lice pesticide Salmosan®
(azamethiphos) on adult male lobsters (Homarus americanus) causes neuromuscular
dysfunction, hypoxia, metabolic disturbances and mortality" - published in Ecotoxicology
and Environmental Safety in December 2016 adds to the weight of scientific evidence
detailing lethal and sub-lethal impacts of Azamethiphos on lobsters and in mussels (read
more via "Sublethal impact of short term exposure to the organophosphate pesticide
azamethiphos in the marine mollusc Mytilus edulis" published in Marine Pollution Bulletin in
2006; "Seasonal lethality of the organophosphate pesticide, azamethiphos to female
American lobster" published in Ecotoxicology and Environmental Safety in 2005; "The
lethality of Salmosan (Azamethiphos) to American lobster (Homarus americanus) larvae,
postlarvae, and adults" published in Ecotoxicology and Environmental Safety in 1999; and
"The effects of cypermethrin (Excis) and azamethiphos (Salmosan) on lobster Homarus
americanus H. Milne Edwards larvae in a laboratory study" published in Aquaculture
Research in 1999).
Resistance to Azamethiphos has been reported for over a decade (read more via "Mechanism
behind Resistance against the Organophosphate Azamethiphos in Salmon Lice
(Lepeophtheirus salmonis)" published in PLoS One in 2015; "Evidence for occurrence of an
organophosphate-resistant type of acetylcholinesterase in strains of sea lice (Lepeophtheirus
salmonis Krøyer)" published in Pest Management Science in 2004; and "Analysis and
management of resistance to chemotherapeutants in salmon lice, Lepeophtheirus salmonis
(Copepoda: Caligidae)" published in Pest Management Science in 2002).
Emamectin benzoate use in Scotland is increasing (up from 34 kg in 2005 to 71 kg in 2015)
and not surprisingly the scientific community is reporting resistance issues (read more via
"Transcriptomic responses to emamectin benzoate in Pacific and Atlantic Canada salmon lice
Lepeophtheirus salmonis with differing levels of drug resistance" published in Evolutionary
Applications in 2015; "Emamectin benzoate resistance and fitness in laboratory reared
salmon lice (Lepeophtheirus salmonis)" published in Aquaculture in 2013; and "The Efficacy
of Emamectin Benzoate against Infestations of Lepeophtheirus salmonis on Farmed Atlantic
Salmon (Salmo salar L) in Scotland, 2002–2006" published in PLos One in 2008).
The ecological impacts of Emamectin benzoate have long been recognized by the scientific
community (read more via "Joint Action Effects of Emamectin Benzoate and Cypermethrin
on the Marine Copepod Tigriopus californicus" published in Ursidae in 2016; "Toxic Effects
of Antiparasitic Pesticides Used by the Salmon Industry in the Marine Amphipod
Monocorophium insidiosum" published in Archives of Environmental Contamination and
Toxicology in 2014; "Effect of emamectin benzoate on the molt cycle of ovigerous American
lobsters Homarus americanus is influenced by the dosing regimen" published in Aquatic
Biology in 2010; "Chemical use in salmon aquaculture: A review of current practices and
possible environmental effects" published in Aquaculture in 2010; "Environmental effects of
the anti-sea lice (Copepoda: Caligidae) therapeutant emamectin benzoate under commercial
use conditions in the marine environment" published in Aquaculture in 2006; "Relationship
between dose of emamectin benzoate and molting response of ovigerous American lobsters
(Homarus americanus)" published in Ecotoxicology and Environmental Safety in 2007;
"Acute toxicity of emamectin benzoate (SLICE™) in fish feed to American lobster, Homarus
americanus" published in Aquaculture Research in 2004; and "Toxicity of emamectin
benzoate in commercial fish feed to adults of the spot prawn and dungeness crab" published
in OCEANS 2003).
Whilst the use of Cypermethrin in Scotland ceased in 2012 (due to resistance issues) the use
of Deltamethrin has taken over but there are now resistance concerns to both Deltamethrin
and Azamethiphos (read more via: "Surveillance of the Sensitivity towards Antiparasitic
Bath-Treatments in the Salmon Louse (Lepeophtheirus salmonis)" published in PLoS One in
2016; "Mechanism behind Resistance against the Organophosphate Azamethiphos in Salmon
Lice (Lepeophtheirus salmonis)" published in PLoS One in 2015; and "Determination of
reduced sensitivity in sea lice (Lepeophtheirus salmonis Krøyer) against the pyrethroid
deltamethrin using bioassays and probit modelling" published in Aquaculture in 2003).
The use of Deltamethrin has also caused concerns regarding ecosystem impacts on non-target
species such as shellfish (read more via "Dispersion and toxicity to non-target crustaceans of
azamethiphos and deltamethrin after sea lice treatments on farmed salmon, Salmo salar"
published in Aquaculture in 2014; and "Toxic Effects of Antiparasitic Pesticides Used by the
Salmon Industry in the Marine Amphipod Monocorophium insidiosum" published in
Archives of Environmental Contamination and Toxicology in 2014).
We know from the Scotland's Aquaculture database that Kames Fish Farming Ltd has
exceeded SEPA's Environmental Quality Standard for Emamectin benzoate in sediments at
their salmon farm at Shuna Castle Bay in 2015 testing:
And at the same site in 2014 testing:
Kames Fish Farming Ltd also has a huge problem with mortalities (totalling 2177491.6 kg
since 2002). Here's the worst 20 sites (according to data obtained by GAAIA via FOI from
SEPA) since 2002:
The 'Feed Composition' document strangely fails to list the ingredients - merely stating:
This information is simply unacceptable. Kames Fish Farming Ltd should surely be specific
and list all the ingredients. For example, does the feed contain any Land Animal Protein
including chicken and beef products as recently mooted by the salmon farming industry?
Read more via: Mail On Sunday: "Coming soon to a fish counter near you, the salmon that's
truly fowl...."
Does the feed contain PCBs, dioxins, dieldrin, toxaphene and other cancer-causing
chemicals?
The so-called 'chemical analysis' provided is missing key data.
For example, scientific research published in Aquatic Conservation in 2005 showed chemical
contamination under salmon cages (read via "Presence and distribution of PAHs, PCBs and
DDE in feed and sediments under salmon aquaculture cages in the Bay of Fundy, New
Brunswick, Canada").
SEPA's own scientific research published in 2001 showed contamination of PCBs under
salmon farms:
A Scottish Government report - "A review of hazardous substances in the Scottish marine
environment" - published in 2004 also stated:
And:
Moreover the report stated:
Why does Kames Fish Farming Ltd not include data on chemical contamination via feed
ingredients?
SEPA's own 'Risk Assessment' concedes that "the proposal is likely to impact on the water
quality":
SEPA knows full well that untreated wastes from salmon farms can lead to water pollution,
eutrophication and algal blooms.
Read more via:
Scotland's secret? Aquaculture, nutrient pollution eutrophication and toxic blooms
A big fish in a small pond: the global environmental and public health threat of sea cage fish
farming
Harmful Algal Bloom Communities in Scottish Coastal Waters: relationship to fish farming
and regional comparisons - a review
Harmful Algal Blooms and Mariculture: Stoichiometric Perturbations and the Production of
Nitrogenous Biotoxins
In fact, we know from data submitted to SEPA (and published online via Scotland's
Aquaculture) that Kames Fish Farming Ltd discharges significant quantities of copper, zinc,
nitrogen, phosphorus and organic carbon from their sites. For example, here's a data entry for
2015 at their Shuna castle Bay site:
And another data entry for 2015 at their Rubh an Trilleachain site in Shuna Sound:
As a company, Kames Fish Farming Ltd has already revealed itself to be a noxious
neighbour. For example, here's water pollution offences involving Kames Fish Farming Ltd:
Read more via Scottish Farmed Salmon Exposed
GAAIA is also surprised that the application appears to contain zero documentation on
impacts on wild fish, infectious diseases and sea lice infestations. In terms of the latter,
GAAIA recently obtained FOI documentation revealing escalating sea lice problems across
Scotland (read via: "Policing Lice-Ridden Scottish Salmon"). This mega-salmon farm
application by Kames Fish Farming Ltd will serve only to exacerbate the sea lice problem
even further.
Please note that Salmon & Trout Conservation Scotland reported in December 2016:
"Over the year to September 2016, regions representing 66.4% have been over three adult
female lice per fish for at least one month, the level at which the Scottish Government
now requires individual farms to produce a “site specific escalation action plan”.
Over the year to September 2016, regions representing 18.2% have been over 8 adult
female lice per fish for at least one month, the level at which the Scottish Government
announced in May 2016 would result in enforcement action, including the potential to
require reduction in biomass.
To date, S&TCS understands that there has been no such enforcement action."
Salmon & Trout Conservation Scotland reported in June 2016:
“When it comes to the most serious threat to wild salmonids, sea lice produced by the billion
on salmon farms, Scotland essentially relies on what are little more than gentleman’s
agreements and unenforceable codes of good practice with the industry which have no status
in law. In contrast, the Faroese have almost zero tolerance of any build-up of sea lice and the
Norwegians accept no more than 0.5 lice per farmed fish. Yet the Scottish regime now allows
up to an astonishing eight lice per farmed fish before any serious remedial action must be
considered.”
In 2012, GAAIA also published documentation (obtained via FOI from the Scottish
Government) detailing the extent of the disease crisis via Amoebic Gill Disease (read via
"Gill diseases: Scottish salmon's dirty big secret"). This application by Kames Fish Farming
Ltd, especially by farming in an area at greater risk from rising sea temperatures (AGD
causes more problems at higher temperatures), will serve only to increase disease risks yet
further.
The scientific literature linking sea lice infestations from salmon farms with declines of wild
fish is also now, to steal a phrase from SEPA's former director Professor David Mackay,
"beyond reasonable doubt". Here's the weight of two decades scientific evidence (read
online via Policing Lice-Ridden Scottish Salmon - New "Enforcement Regime" following
£300 million losses):
:
Finstad, B. (2016). Advances in understanding the impacts of sea lice on wild Atlantic
salmon. NASCO, CNL (16) 46.
Shepherd, S. et al (2016). Aquaculture and environmental drivers of salmon lice infestation
and body condition in sea trout. Aquaculture & Environment Interactions 8, 597-610.
Murray, A. (2016). Increased frequency and changed methods in the treatment of sea lice
(Lepeophtheirus salmonis) in Scottish salmon farms 2005–2011. Pest Management Science
72 (2), 322-326.
Vollset, K. W. et al (2015). Impacts of parasites on marine survival of Atlantic salmon: a
meta-analysis. Fish and Fisheries 17(3), 714-730.
Murray, A. & Hall, M. (2014). Treatment rates for sea lice of Scottish inshore marine salmon
farms depend on local (sea loch) farmed salmon biomass and oceanography. Aquaculture
Environment Interactions 5 (2), 117-125.
Middlemas, S.J. et al (2013). Relationship between sea lice levels on sea trout and fish farm
activity in western Scotland. Fisheries Management and Ecology Volume 20, Issue 1, 68–74.
Torrissen, O. et al (2013). Salmon lice – impact on wild salmonids and salmon aquaculture.
Journal of Fish Diseases 36 (3), 171-194.
Peacock, S. et al (2013). Cessation of a salmon decline with control of parasites. Ecological
Applications 23 (3), 606-620.
Skilbrei, O.T. et al (2013). Impact of early salmon louse, Lepeophtheirus salmonis,
infestation and differences in survival and marine growth of sea-ranched Atlantic salmon,
Salmo salar L., smolts 1997–2009. Journal of Fish Diseases 36 (3), 249-260.
Krkosek, M et al (2012). Impact of parasites on salmon recruitment in the Northeast Atlantic
Ocean. Proceedings of the Royal Society B.
Gargan, P. et al (2012). Evidence for sea lice-induced marine mortality of Atlantic salmon
(Salmo salar) in western Ireland from experimental releases of ranched smolts treated with
emamectin benzoate. Can. J. Fish. Aquat. Sci. 69, 343–353.
Middlemas, S.J. et al (2010). Temporal and spatial patterns of sea lice levels on sea trout in
western Scotland in relation to fish farm production cycles. Biology Letters 6.
Penston, M.J. & Davies, I.M. (2009). An assessment of salmon farms and wild salmonids as
sources of Lepeophtheirus salmonis (Krøyer) copepodids in the water column in Loch
Torridon, Scotland. Journal of Fish Diseases 32 (1), 75-88.
Penston, M.J. et el (2008). Spatial and temporal distribution of Lepeophtheirus salmonis
(Krøyer) larvae in a sea loch containing Atlantic salmon, Salmo salar L., farms on the northwest coast of Scotland. Journal of Fish Diseases 31 (5), 361-371.
Ford, J.S. & Myers, R.A. (2008). A Global Assessment of Salmon Aquaculture Impacts on
Wild Salmonids. PLOS Biology.
Frazer, L.N. (2008). Sea-cage aquaculture, sea lice and declines of wild fish. Conservation
Biology 23: 559-607.
Holst, J.C. (2007). Mortality of Seaward-Migrating Post-smolts of Atlantic Salmon Due to
Salmon Lice Infection in Western Norwegian Salmon Stocks. In book: Salmon at the Edge
by D. Mills. Blackwell Scientific Publications, Oxford, UK. pp.136 - 137.
Krkošek M, Ford JS, Morton A, Lele S, Myers RA, et al. (2007). Declining wild salmon
populations in relation to parasites from farm salmon. Science 318: 1772–1775.
Gillibrand, P.A. & Willis, J.W. (2007). Dispersal of sea lice larvae from salmon farms: a
model study of the influence of environmental conditions and larval behaviour. Aquatic
Biology. 1, 63–75.
Cunningham, C. (2006). A review of research and field data on relative louse infection levels
of wild salmon smolts and sea trout and the proximity of fish farms to river estuaries.
Fisheries Research Services Internal Report No 12/06.
Butler, J.R.A. & Walker, A.F. (2006). Characteristics of the sea trout Salmo trutta (L.) stock
collapse in the River Ewe (Wester Ross, Scotland), in 1988-2001. In: Sea Trout Biology
Conservation & Management. (Graeme Harris & Nigel Milner, Eds). Proceedings of the 1st
International Sea Trout Symposium, July 2005, Cardiff, Wales, 45-59.
McVicar, A. H. (2004). Management actions in relation to the controversy about salmon lice
infestations in fish farms as a hazard to wild salmonid populations. Aquaculture Research
35(8): 751-758.
McKibben, M. & Hay, D. (2004). Distributions of planktonic sea lice larvae Lepeophtheirus
salmonis in the inter-tidal zone in Loch Torridon, Western Scotland in relation to salmon
farm production cycles. Aquaculture Research 35 (8), 742-750.
Penston, M.J. et al (2004). Observations on open-water densities of sea lice larvae in Loch
Shieldaig, Western Scotland. Aquaculture 35 (8), 793-805.
Butler JRA, Watt J (2003). Assessing and managing the impacts of marine salmon farms on
wild Atlantic salmon in western Scotland: identifying priority rivers for conservation. In:
Mills D, editor. Salmon at the edge. Oxford: Blackwell Science. pp. 93–118.
Gargan, P.G. et al (2003). The relationship between sea lice infestation, sea lice production
and sea trout survival in Ireland, 1992–2001. In Salmon at the Edge. Edited by D. Mills.
Blackwell Scientific Publications, Oxford, UK. pp. 119–135.
Holst, J.C. et al (2003). Mortality of seaward-migrating post-smolts of Atlantic salmon due to
salmon lice infection in Norwegian salmon stocks. In Salmon at the Edge. Edited by D. Mills.
Blackwell Scientific Publications, Oxford, UK. pp. 136–137.
Butler, J.R.A. (2002). Wild salmonids and sea louse infestations on the west coast of
Scotland: sources of infection and implications for the management of marine salmon farms.
Pest Management Science, 595-608.
Edwards, R. (1998). Infested waters. New Scientist 2141, 4 July.
Birkeland, K. & Jacobsen, P.J. (1997). Salmon lice, Lepeophtheirus salmonis, infestation as
a causal agent of premature return to rivers and estuaries by sea trout, Salmo trutta,
juveniles. Environmental Biology of Fishes 49, 129-137.
A Scottish Government paper - "Summary of Science: summary of information relating to
impacts of salmon lice from fish farms on wild Scottish sea trout and salmon" - includes:
Read more via the Scottish Government's: "The interactions and effects of sea lice on wild
salmon".
Or to steal the words of Dr Richard Shelton, former head of the Scottish Government's
Freshwater Fisheries Laboratory, speaking to New Scientist back in 1998 the link is "as plain
as the nose on your face".
Kames Fish Farming Ltd is also a company with an appalling track record on escapes - here's
data published online via Scotland's Aquaculture detailing at least 10 escape incidents
totalling over 20,000 farmed fish in the last ten years:
Again, the scientific evidence showing lethal impacts of escapes of farmed salmon on wild
fish is incontrovertible.
Read scientific paper via "Fitness reduction and potential extinction of wild populations of
Atlantic salmon, Salmo salar, as a result of interactions with escaped farm salmon"
More background via:
Scottish salmon in "extinction vortex" | New Scientist
Scottish Salmon's Great Escape
Wild salmon put at risk as a million farmed fish escape - Telegraph
Locating a salmon farm in such an exposed location is an open invitation for ecological
disaster.
If SEPA approve this application, you will be signing a death warrant to wild fish and
shellfish.
Sadly, it seems (from a review of the data on the number of salmon farming applications
approved vs. those rejected) that this is merely a rubber-stamping exercise. "Another
freedom of information response from SEPA reveals that it has given the green light to 585
fish farms around the country since 2006, and rejected just one," reported The Sunday Herald
in 2013.
Read more via "Say No to Scotland’s Yes Ministers!"
In conclusion, please say no to this application by Kames Fish Farming Ltd's Dounie Marine
Cage Fish Farm, Sound of Jura (CAR/L/1152438).
Please provide a receipt for this objection.
Thanks,
Don
Don Staniford
Director, Global Alliance Against Industrial Aquaculture (GAAIA):
http://www.salmonfarmingkills.com
<((((º>`·.¸¸.·´¯`·.¸.·´¯`·...¸><((((º>¸.
·´¯`·.¸. , . .·´¯`·.. ><((((º>`·.¸¸.·´¯`·.¸.·´¯`·...¸><((((º>