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Non-Technical Summary
This Environmental Report forms a key stage of the Strategic Environmental Assessment of the Scottish Executive's 'Location/Relocation of Fish Farms Programme' as required under the Strategic Framework for Scottish Aquaculture. The report sets out the background to the programme and highlights the principles and process which will underpin future relocation exercises.
The report examines the likely environmental implications of the proposed relocation programme - namely a part funded voluntary approach to fish farm relocation. In addition - and as recommended in the Scottish Executive's Strategic Environmental Assessment Guidelines - the report examines the environmental implications of possible alternative approaches to relocation which were discussed at various stages of programme development.
The programme and its associated principles have been developed to address as far as is practical and feasible some of the environmental concerns that have arisen in relation to salmonid culture, and in particular to reduce the risks of any possible adverse interaction between farmed and wild salmonids. The programme has been developed by the Scottish Executive, with technical advice throughout from the Location Relocation Working Group ( LRWG), comprising relevant government agencies, scientific advisors, and key stakeholders. The objective of the programme is "to reduce the risks of any possible adverse interaction between wild and farmed salmonids, and to generate other economic and environmental benefits where possible"
The programme is based on 8 key principles which summarise the rationale and policy outline developed by the group:
1. Participation of government, stakeholders, and technical specialists in assessment and approval;
2. Bottom-up site selection initiated by local wild fishery interests and local fish farmers;
3. Thorough assessment of social, economic and environmental costs and benefits;
4. Financial assistance contingent on demonstrated "net environmental benefit";
5. Compatibility with other planning and management initiatives;
6. Improvement through testing and demonstration;
7. Streamlining of the regulatory process;
8. Monitoring to determine the scale of benefit.
By its very nature therefore, the programme is likely to result in a net environmental benefit. The purpose of this report is to explore the likely scale of benefit, and whether there are alternatives which might be superior in terms of delivering programme objectives.
The report also provides a summary of the current understanding of the interactions between aquaculture and the environment. This highlights the continuing scientific uncertainty, in particular in relation to interactions between wild and farmed salmon. This uncertainty limits the extent to which firm conclusions can be drawn relating to alternative approaches to relocation.
The main conclusions of the report are as follows:
1. The grant scheme as proposed is unlikely to have a significant negative environmental impact. This is because access to grant aid for relocation will be conditional on demonstration of net environmental benefit, and because any relocation to a new site will still be subject to rigorous assessment through the consents and EIA procedures, and mitigation identified for any contingent negative impacts.
2. In practice demonstration of "net environmental benefit" will be difficult, and in most cases there will be both positive and negative indications relating to different criteria. The relative weight given to these criteria will be critical in determining overall net environmental benefit, both for individual relocations and for the programme as a whole.
3. The scientific uncertainty (relating in particular to wild fish-farmed fish interactions), coupled with the case by case nature of the programme, means that the nature and scale of environmental benefit of the programme as a whole cannot be predicted.
4. More ambitious and strategic alternatives have also been considered. Relocation on a grand scale in order to minimise interaction with key representative and/or valuable salmon stocks would be more precautionary, and would be more effective at reducing the risk of any negative interactions between farmed and wild salmonids. However such an approach was considered impractical, requiring unrealistic levels of public funding, and/or new legislation that might cripple an already struggling industry. Such a strategy could however be implemented in the longer term by ensuring that any new developments or significant expansion took place within preferred zones, or outside exclusion zones. Such a strategy could be implemented through strategic guidance to local authorities, who will have the final say in terms of development consent.
5. Strategic environmental assessment for possible aquaculture developments within an aquatic system, followed by a relocation and rationalisation process (grant aided where appropriate) and development of effective area management agreements is currently being tested in Loch Roag, and appears to have significant merit relative to other options. However it is clear that significant costs will be incurred in developing a "system" EIA, and in facilitating agreement and coordination.
6. Less ambitious alternative approaches are already in place or proposed, and are widely agreed to be effective in generating overall environmental gains. They include area management agreements; informed "micro" relocation based on enhanced understanding of hydrodynamics and salmonid movements; and licensing of an increased range of lice treatments. It is arguable that resources should be directed at these.
7. The relocation pilot projects currently underway began prior to the development of process and principles by the LRWG. This enabled pilots to inform programme development. In taking these pilots forward and in all new relocation exercises it is crucial to follow programme process and principles. If this is proves unworkable then the programme must be revised.
8. The procedure and framework for assessing relocation proposals in terms of delivering net environmental benefit will be crucial to the success of the programme. These are currently being developed and are appended to this report for further consultation.
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