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4 Assessment of alternative Approaches

4.1 Alternatives Considered

A number of alternatives have been considered during the deliberations of the Strategic Review, the resulting Location Relocation Working Group and the Tripartite Sub group. The final choice of action has been agreed upon by a wide representative body of stakeholders - including all statutory consultees. This report examines these alternatives to highlight the reasoning and justification for the preferred option. Most of these options are not mutually exclusive and the final approach should seek to promote the best overall "package".

4.1.1 No change

The Strategic Framework for Scottish Aquaculture clearly highlights the need to tackle the most poorly located farms, in particular where there is a possible impact on wild fisheries. The risk of interaction with wild fisheries was one of the key drivers of the Strategic Review and as a result change of some sort was always likely. However it is helpful to consider the implication of a continuation of the existing situation.

4.1.2 Voluntary / part-funded relocation (the preferred option)

The alternative which has emerged as the preferred programme from the strategic framework and the subsequent working group is voluntary, part-funded relocation of the most poorly located sites. This seeks to identify win : win situations where the concerns of the wild fishery interests are addressed without compromising the economic viability of the industry. Pre-determined criteria will be used to assess relocation proposals supported by both farmers and wild fisheries interests. Those deemed to be clearly within the remit of the schemes objectives, demonstrating a 'net environmental benefit' could qualify for financial support from the Executive. Details

4.1.3 Change in micro- location

Where it is accepted or agreed upon that a change in location is likely to be the most favourable approach to addressing concern over impact on wild fishery stocks, the first consideration could be a small change in cage location. This process would be informed by detailed understanding of hydrodynamics and migratory routes within sea lochs. It may be possible to show that a small relocation from near the head of a sea loch to a nearby bay could substantially reduce risk of interaction between migratory salmonids and farms. This would enable shore facilities to remain in existing locations and would reduce the level of expense and upheaval for both the farm company and its staff.

4.1.4 Change in operational practices

There may be a number of measures which could be taken at farm level to improve operational practices in farms identified by wild fisheries interests as having potential to interact with wild salmon and trout runs. For example, progress may be achieved through ensuring:

• Farms are part of Area Management Agreements, to ensure synchronised year class, fallowing and lice treatments.
• Farms have access to best available lice medicines to ensure efficiency of treatment - reduced flushing at the head of sea lochs is likely to reduce the likelihood of consent for some in feed treatments.
• Farms sign up to SQS codes of practice.
• Operational trials continue with alternative sea lice management strategies.

It is also recognised that many of the poorly located farms are already undertaking most of the above - yet concern persists about the impact of their location.

4.1.5 Salmon and Sea trout Conservation Strategy

At an early stage of the relocation deliberations representatives of Fisheries Research Services (Aberdeen) presented a paper to the Tripartite Working Group on "Relocation of fish farms - a wild fish perspective". An approach was proposed which identifies priority salmon conservation rivers on the west coast on the basis of population size, vulnerability, pristineness and representativeness (see Figure 5). The approach advocates building upon existing Special Areas of Conservation for salmon and pearl mussel, important rivers which do not currently have any aquaculture at their mouth and other sites where the salmon population is at risk to create priority zones where there would be a presumption against new development or expansion, and in favour of re-location outside the zone for any existing farms. This would amount to a strengthening and extension of the existing locational guidelines for aquaculture development and a change to the process outlined in section 2.2 of this report.

4.1.6 Aquatic system rationalisation plan (demonstration project)

This is a facilitated process of bringing the various aquaculture and other interests together to explore relocation and rationalisation of aquaculture and other activities within a defined aquatic system (such as Loch Roag in the Western Isles). It is based on a "system level" EIA which has the advantage of allowing for a rough assessment of overall environmental capacity (and therefore long term limits to production/nutrient discharge) and one-off strategic consideration of other social and environmental issues. In theory it should simplify and reduce duplication of individual farm level EIAs, and lead to a rational development and management plan for a defined aquatic system.

In the assessment below, this option is considered together with the local authority marine planning approach described below.

4.1.7 Local Authority marine planning initiative

There is a range of sustainable marine management initiatives at European, UK and devolved level - such as the EC Marine Strategy Package, the draft Marine Bill, The Fisheries and Aquaculture Bill, and initiatives such as the Scottish Sustainable Marine Environments Initiative ( SSMEI), the Scottish Coastal Strategy, the Scottish Marine Strategy (Seas the Opportunity) and the Marine National Parks Consultation. Many of these initiatives refer directly to Marine Spatial Planning as a key tool in future management approaches to UK terrestrial waters.

Bringing marine management into the sphere of local planning has already begun in relation to Scottish aquaculture since the adoption of the interim measure which passes planning responsibility from the Crown Estates to Local Authority. This transfer of power will be formalised through regulations later in 2006. Some local authorities have already developed local framework plans for aquaculture.

It is therefore appropriate to consider the implications of these changes in relation to the work of the LRWG, and in particular to consider whether the Local Authority should take a lead role in the relocation programme and bring it within a more comprehensive local marine strategic/spatial planning process with aquaculture considered alongside the needs of other stakeholders and amenity users.

Such a process might range from integration and coordination of existing management and regulatory measures, and area or system planning initiatives (such as that described above) through to more ambitious strategic and spatial planning. Suitable zones for further aquaculture development, and other areas with presumption against further development might be identified, based on both local interests and those defined at national level (for example through existing locational guidelines or thorough a national salmon conservation strategy). However, evolution toward a situation where aquaculture occurs in zones could only be achieved over many years.

4.2 Assessment Methods

This report is the culmination of an assessment which began during the development of the Strategic Framework for Scottish Aquaculture and continued through the deliberations of the Location/Relocation Working Group.

The main assessment method used has been fully represented debate and consultation, informed by a series of working papers and submissions to the working group by both technical experts and stakeholder representatives. In addition more detailed research has been commissioned under the Scottish Aquaculture Research Fund ( SARF).

The largely committee based approach to the relocation project has been designed to enable a broad and representative spectrum of stakeholders to contribute to the process and shape its outcomes.

In addition the authors of this report have drawn upon recently published papers and reports, and summarized the balance of evidence and opinion. Neither new scientific assessment nor data collection have taken place to inform this report - this is neither possible nor appropriate at a strategic level. Where necessary, primary data collection will be used at EIA level to inform individual site development applications.

4.3 Assessment findings

The assessment findings are presented in 3 matrices. The first 2 qualitatively assess the potential strengths and weaknesses of the proposed approach to relocation against a series of criteria. These are used to inform the findings and subsequent conclusions.

A matrix was also developed to evaluate the main alternative programme approaches against the key interactions of aquaculture.

The scoring of each combination is a matter for discussion and the table is supported by a summary commentary which seeks to highlight the main issues. The table should be treated as a tool to inform and frame discussion, rather than as a final assessment.

4.4 Matrix assessments of Relocation Process

The following assumes that voluntary relocation guided by the programme principles will tend to lead to farms being relocated closer to the mouths of sea lochs or further offshore, and that these farms will also tend to be larger than those located in inner sealochs.

4.4.1 Implications of larger farms

It is likely that companies involved in relocation exercises will seize the opportunity to consolidate production into fewer larger farms. On average in Scotland farm sizes (and consented biomass levels) are less than 1,000 tonnes with some companies having average farm sizes well below this. In the main competitor countries of Chile, Norway and Canada the average farm size is often well in excess of 2,000 tonnes. The industry is increasingly recognising the cost advantage of producing the same volume from fewer, bigger farms. The intention of the exercise is not to significantly increase overall production - it is recognised that the UK market is saturated in volume terms - and stocking densities will not increase.

This is one method of significantly reducing production costs, enabling more efficient use of equipment and reducing the overall capital expenditure. This does reduce overall local employment but the industry would argue that it is a measure which also helps to safeguard remaining jobs in the longer term.

There is a large degree of uncertainty as to whether fewer bigger sites are better for the environment than a larger number of smaller sites. This has not been rigorously studied, but there are informed opinions which conclude that - assuming all things are equal - both large and small farm sizes have advantages and disadvantages from an environmental and disease control perspective. Larger farms contain more potential hosts and may therefore be larger reservoirs of pathogens, but if these pathogens are concentrated in one area the fraction of wild populations exposed may be reduced. The risk of disease may initially be higher on a larger farm, due to varied smolt sources, but the risk of transmission between farms is reduced by increased separation distances ³².

FRS has concluded that site location and quality of farm management play a far more significant role than size in determining overall impact.

4.4.2 No Change

As reasons for the relocation programme are at least partially motivated by an adherence to the precautionary approach ( i.e. minimise the possible risk to wild populations of salmonids), it is difficult to assess likely impacts of a continued operation of the most poorly located farms - because we have no concrete evidence that they are causing harm in the first place.

It is clear however that the potential for harmful interaction between farmed and wild salmon (in both directions) will remain significant at some sites. More specifically, it is likely that both farmed and wild populations will continue to suffer from periodic infestation - to the detriment of both.

Local water quality, benthic organic contamination and local ecosystem indicators are likely to remain stable or deteriorate, depending on the site and its management. The continued operation of poorly located farms may also undermine efforts to achieve higher levels of environmental quality such as "good overall ecological status" as part of the Water Framework Directive.

With respect to cumulative impacts, landscape, cultural heritage and other users, there will be no significant change from a continuation of operation of poorly located sites. From a socio-economic perspective there may be a longer term consequence of a failure to relocate and consolidate. Poorly located small farms are often less economically viable and production costs may therefore be cut in other ways - to the detriment of management best practice and - potentially - the environment. In the longer term the farm may be forced to close.

4.4.3 Voluntary re-location scheme (The preferred approach)

All else being equal, and assuming standard safeguards are practiced, partially financed voluntary relocation is likely to be beneficial to:

• Interactions with wild fish - both through disease and sea lice
• Overall ecological status for WFD catchment assessments
• Long term profitability

The exact scale of the benefit to wild fish is far harder to predict and will be dependent on site specific factors. Clearly there will be a benefit of relocating sites with greatest sea lice challenge to better flushed areas where lice are less of a problem. However, the dynamics of lice movement remains poorly understood and in particular the significance of surface water, wind-driven vectors may mean that lice from distant farms may still be transported to and concentrated in sensitive areas ³³, whether these be inner sea lochs and river estuaries or offshore migration routes. Wild sea trout may derive less of a benefit from the relocation than wild salmon due to their increased residence time in sea lochs and along the coast more generally.

The preferred approach may have a negative impact in terms of:

• Landscape (headlands may be sensitive landscape features and larger farms in such locations may have greater visual impact)
• Marine mammals (may prefer less disturbed locations away from head of sea lochs)
• Workforce (further to travel, exposure, redundancies also likely as relocation triggers consolidation exercise)

There are a number of interactions of the preferred relocation option which cannot be assessed on at a strategic level, and their impact or benefit can only be determined on a case by case basis through the existing EIA process. These include:

• Water quality (chemical & nutrient) - the new sites are likely to fare better for DEPOMOD34 interpretation as they are likely to be in more dispersive locations - however wider environmental capacity issues including cumulative effects must still be considered and preferably modelled on a wider hydrographic scale.
• Impacts on other users (including other farms, navigation, fisheries, anchorages)
• Interactions with cultural heritage

These assessments are based upon best available information. However, significant scientific uncertainty remains in relation to many of these issues, exacerbated by the lack of specific proposals available at this stage. Perhaps the most important interaction (in terms of the programme objectives) is highly uncertain and has therefore not been attributed either positive or negative:

• Wild fish interactions / genetics: Clearly there will be a benefit in terms of removing the farms from the immediate proximity of the wild fish runs. This is balanced against an increased risk of catastrophic escape incidents in more exposed locations. Some of this can be addressed at EIA but this trade off is an inevitable consequence of relocation.

4.4.4 Minor Changes

Some progress may also be achieved through more minor changes to:

• Location (within the same loch system and using the same shore base facilities)
• Management practice
• A combination of the above.

Local hydrodynamics vary greatly even within a single loch system, with some areas better flushed than others. Some of the original sites may have been located in particularly poorly flushed areas or in sheltered locations with back-eddies. These sites are prone to higher levels of lice infestation and require greater effort and expense on treatments than other nearby farms. In these instances a change in micro-location, perhaps as little as a few hundred metres, may move the farm into an area with greatly improved flushing rates. This would reduce lice burden with considerably less expense and logistical difficulty than a full relocation exercise.

The relative benefit of a change in micro-location compared with a substantial relocation is subject to debate but full relocation to a site considerably further away from wild salmonid runs is a more precautionary approach. In addition a full relocation offers the potential for improvements in overall ecological status - which in turn may lead to more generous biomass consents. Ultimately the merit of each approach to relocation will be judged on the basis of justification included in the application and EIA.

Most farms are already managed to a high standard - making use of best practice, adhering to the industry code of practice and in membership of an area management agreement. However in some cases there may be changes to practice which may reduce the potential for harmful interaction with wild salmonid populations and the environment. The possible changes which could assist in this process may be broadly categorised as:

• Farm practice
• Industry cooperation
• Industry support & available resources

Where farms are identified for relocation it should be first ensured that all feasible steps to maximise best practice are being taken. In particular to ensure that farms adhere to the industry code of best practice and are members of an AMA. If these are not addressed then simply changing location will not resolve all problems, and may be unnecessary. In these instances changes in operation and cooperation may be a far more cost effective mechanism of achieving local improvements.

One aspect which would significantly improve ability of poorly located farms to reduce their interaction with wild populations would be through the licensing of an increasing range of sea lice treatments. Already the benefits of effective 'in feed' treatments are being recognised in Scotland. Other new medicines with proven efficacy in Norway, Chile and Canada could greatly improve farmers ability to mange lice levels. The process of licensing these medicines is not easy and must be addressed at UK and European Commission level, resolving concerns over toxicity on the wider marine environment.

4.4.5 Salmon Conservation Strategy

A more strategic approach to salmon conservation which prioritises farm relocations on the basis of wild population status and risk is the approach which most formerly embraces the precautionary approach. Given scientific uncertainty it is possible that increased precaution will lead to increased benefit, but this is not certain. However, of all of the alternatives it is this approach which is most likely to benefit wild salmon populations. As this alternative could in the long term create large separation distances it may also have an increased likelihood of benefiting wild sea trout populations.

However this approach, dominated by a single issue strategy may be less well suited to addressing other elements of marine management. In particular this could create uncertain interactions with other marine stakeholders. Areas identified as suitable for future aquaculture development from a wild salmonid perspective would also have to be assessed from the perspective of:

• Other resource users
• Other marine fauna - seals, cetaceans
• Other designations

This approach would be likely to lead to widespread industry disruption and cost given that existing siting is often determined according to practical and economic considerations such as workforce, communications links and available infrastructure.

Not all wild salmon interests are advocating this approach and many believe that the preferred approach will help to create progressive change in a way which is not detrimental to the long term viability of the industry.

4.4.6 Relocation within Marine Planning Initiative

The final alternative approach relevant to the wider marine management debate on marine spatial planning, is the integration of relocation into a more strategic local authority marine planning, or more "aquatic system" specific approaches as demonstrated in the Loch Roag Pilot. These approaches can only be assessed in the context of what is practically achievable. In all sectors - from shipping, to fishing to offshore energy generation - a more strategic planning approach to management will come up against problems associated with historical access rights, commercial viability and mixed use. This is no different for aquaculture and there is a limit to which this approach can therefore be applied. Fish farms have a legal entitlement to exist in their current location, so long as they adhere to environmental regulations, and are scrutinised by routine monitoring.

In theory the great strength of this strategic approach is to reduce the scale of conflict between resource users and manage resource use in a way which is complimentary to the environment. It should also offer a more predictable development environment for aquaculture and other activities. When undertaken at the scale of the aquatic system there are also potential efficiency gains in terms of one-off area EIA rather than a large number of partially repetitive EIAs. Issues of biosecurity can also be addressed through agreement to establish substantial "fire-breaks" between farms or groups of farms, and link in with area management agreements and other management protocols.

In terms of wild fish interactions these approaches might also be particularly effective if they were able to draw on both national level guidance on salmonid conservation, the knowledge of local fishery interests, and the findings of any "aquatic system" level EIA.

In many ways therefore this approach scores well, but it should be understood that facilitation and transaction costs will be high, and achievement of broadly agreed strategy and management plans will take a great deal of time.

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