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2 The Location / Relocation Programme
2.1 Background
The Strategic Framework for Scottish Aquaculture 5 sets out a shared vision for the industry in Scotland:
"Scotland will have a sustainable, diverse, competitive and economically viable aquaculture industry, of which its people can be justifiably proud. It will deliver high quality, healthy food to consumers at home and abroad, and social and economic benefits to communities, particularly in rural and remote areas. It will operate responsibly, working within the carrying capacity of the environment, both locally and nationally and throughout its supply chain".
The strategy also sets out a number of requirements in respect of location/relocation of fish farms.
These are summarised as follows;
- Para 3.49 Take action to minimise any anthropogenic influence which might be endangering wild fish stocks. i.e. fish farm sites in poorly flushed or sensitive areas.
- Para 3.50 Set up a stakeholder group to prepare criteria against which to assess whether or not any finfish aquaculture site is poorly located with an explanation of the underlying scientific rationale. It will list sites considered to be inappropriately located and explain why and consider whether alternative sites can be located near the shore based facilities designed to support them. It should also look at the opportunities to for species diversification to reduce impacts on salmonids.
- Para 3.51 The stakeholder group will also assess benefits of relocation of those farms sited close to rivers important for migratory fish. This will follow a scoping study reviewing research and data on relative sea louse infections.
- Para.3.52 Financial assistance for relocation will be considered.
2.2 Relocation Programme Outline
In practice the working group ( LRWG) had some difficulties in developing and applying agreed criteria, and in generating an agreed list of inappropriately located sites.
Although a set of criteria (social, economic, environmental) was developed by a sub-working group (Paper LRWG 2(05)), and also through parallel SARF funded research 6, sites could not be scored objectively against individual criteria because of lack of knowledge, uncertainty or different stakeholder values, and the relative weights which should be applied to the many different criteria were difficult to agree.
A simpler and more pragmatic approach was therefore adopted which relies on the agreement of fish farming and wild fisheries interests to voluntarily relocate farms which perform poorly and which could pose a risk to wild fisheries.
2.2.1 The Programme objective
To reduce the risks of any possible adverse interaction between wild and farmed salmonids, and to generate other economic and environmental benefits where possible
2.2.2 The Programme Principles
The LRWG have developed a set of principles which serve as a rationale for relocation and to inform deliberations:
1. Participation: The process will be guided by the location/relocation working group ( LRWG) comprising major stakeholders from government, regulators, wild fish interests and the aquaculture industry.
2. "Bottom-up" initiation. The identification of poorly located sites should be initiated by local wild fisheries interests or the local industry, motivated in particular (but not exclusively) by the potential effects on wild fish populations.
3. Thorough assessment: Any proposal for relocation should include a thorough assessment of likely social, economic and environmental costs and benefits associated with the relocation, based on agreed criteria, and should ensure in particular that the initial reasons for relocation do not re-occur at new sites. The programme will also be assessed in respect of river basin planning and the requirement to meet Water Framework Directive 'good ecological status'.
4. Net environmental benefit. Financial assistance to support relocation will only be made available from the Scottish Executive where the National Group agrees that the relocation will generate a net environmental benefit.
5. Compatibility with other planning and management initiatives. Relocations must be compatible with TWG concordat and the development of Area Management Agreements, and with existing and developing Local Planning Frameworks and location guidelines.
6. Improvement through testing. The programme will be informed by pilot & demonstration projects to identify and record benefits and barriers to relocation.
7. Streamlining of regulatory process. The programme should not increase the regulatory burden on fish farmers and should contribute to a streamlining of such processes where feasible, but without compromising compliance, assessment of impacts and consultation.
8. Monitoring. The programme will be supported by appropriate monitoring to determine scale of benefit (in particular to wild fish populations) - and to safeguard against deterioration at new sites.
2.2.3 The Relocation Process
The process for the relocation of fish farms has been designed by the Location / Relocation Working Group to create a simple and transparent system - informed by programme principles. The process should enable swift processing of applications whilst ensuring that standard safeguards are met.
The process as currently developed is summarised in a simplified flow chart. In situations where farms are considered poorly located the relocation process may be initiated by:
- An approach from wild fisheries interests, or an Area Management Group to the farmer
- the Farmer with support of local wild fisheries interests,
If the farmer is in support of the relocation proposal they must initially contact planners, SEPA, SNH and other stakeholders as appropriate to discuss the feasibility of the relocation. If the statutory authorities offer initial, qualified (but not binding) support the outline relocation proposal, the farmer will submit a full application to the National sub-group within the LRWG for consideration.
The proposal will be assessed against the set of criteria to determine its overall compatibility with the objectives of both the relocation programme and the Strategic Framework for Scottish Aquaculture. If the proposal meets the programme objectives and criteria - specifically the "net environmental benefit test" - financial assistance may be made available.
The farmer then proceeds with a full planning application, supported by Environmental Statement, leading to a full consultation exercise. In a limited number of cases it is proposed that the process may be expedited. For example, if biomass is being relocated from one site to another - where consent already exists - it may be unnecessary to go through a full planning appraisal. However, SEPA would still be required to assess the impacts of an increase in biomass.
The Location/relocation working group has promoted two pilot projects. These are already underway and have provided important input to the development of the programme process and principles outlined above. However as this process was not fully clarified prior to commencement of the pilots their development does not always exactly match the process and principles outlined in this report. Both projects have already provided valuable insight into programme development.
- The Loch Roag Site Optimisation Demonstration Project has shown that relocation and rationalisation within a defined area such as a loch can give benefits to all stakeholders. A generic environmental assessment was carried out to support each lease application and an area management agreement will be possible after relocation is complete.
- The Loch Riddon to Ardmaddy relocation pilot project has demonstrated that the relocation site is as important as the original site. Relocation of sites should reinforce and be integrated with the development of area management agreements (synchrony of production, lice treatment and fallowing).
Figure 1: Proposed process for financially assisted relocation
Benefits
1) Financial assistance to relocate
2) NGO support for planning applications
3) Positive PR for initiatives taken
4) Improved competitiveness
5) Farmers and Fishery interests are key initiators of process
6) All stakeholders have involvement in process through NG or Formal Planning Process
7) SERAD chair the National Group structure which considers applications for written support and/or funding
2.3 Relationship to legislation, programmes and initiatives
Any relocation must take account of a wide range of legislation and initiatives concerned with marine planning, management and environmental protection. A full list of these is appended as an annex to this report. For any relocation which requires a completely new site or an increase in biomass consent above 100 tonnes, EIA, discharge consent, and planning consent will be required and would take account of all relevant legislation and programmes.
In instances where new consents are not required, these issues would nonetheless be taken into account in the assessment of any relocation proposal, and the various statutory consultees at local and national level will be able to ensure that regulations are not compromised and that opportunities are identified.
Relocation should be seen as an opportunity to promote and test more integrated approaches to marine planning and management. In particular it is important that relocation initiatives connect up with River Basin Management under the Water Environment and Water Services legislation, Sustainable Scotland Marine Environment Initiative (where relevant), local framework plans, Coastal Fora and Area Management Agreements.
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