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5 Mitigation & Monitoring
5.1 Mitigation through project approval procedures
Thorough appraisal of individual proposals for relocation to ensure 'net environmental benefit' will form the basis for mitigation of relocation projects and for the programme as a whole.
The Strategic Framework for Scottish Aquaculture and the LRWG both identify the need for decisions on farm relocation to be guided by objective criteria to assess the appropriateness of a relocation proposal. This desire for objective and quantifiable criteria is understandable, to ensure informed and transparent decisions. However, objective measurement in relation to many criteria is difficult, and the overall assessment depends on the choice of, and subjective weight given to different criteria.
A multi-criteria rapid assessment tool is proposed and presented as an annex to this report. This does not seek to measure or quantify "net environmental benefit" but rather to generate an informed opinion, and to ensure that all key issues are considered in the site selection and assessment process. It is also designed to flag up problems so that they can be further explored and discussed, and mitigation proposals developed.
It is proposed that the farmer makes the initial assessment, assisted where possible by local fishery interests and other interested parties. This can then be examined by local statutory consultees who may amend it before it is forwarded to the national group. Given the scientific uncertainties, the overall assessment will be a matter of judgement; the key will be to ensure that the process is clear and transparent.
Where an EIA is still required, this summary assessment would also serve as the starting point for the EIA, and would help focus more detailed assessment on critical issue.
Prior to investing time and effort in an evaluation, eligibility should be determined simply by ascertaining the spectrum of support for the proposed relocation. If there is not support, in principle, from the farmer, the wild fish interests and statutory stakeholders then an application should not be made via this programme.
5.2 Mitigation in relation to specific projects
Relocation away from salmon rivers and poorly flushed sites mitigates against many environmental factors - notably interaction with wild salmonids and localised nutrient enrichment.
Further mitigation measures which should inform location and operation of a new site are already contained within routine planning / consenting procedures and industry codes of practice - and in particular the newly released Code of Good Practice for Scottish Finfish Aquaculture 35.
Any significant relocation, involving a completely new site or significant increase in biomass consent at an existing site will be subject to EIA, and identification of practical mitigation measures is a key part of EIA.
Area management agreements are a further crucial mitigation tool and farms should cooperate with such a group, if already in existence, or establish a group if there are other farms within the same hydrodynamic system. AMAs help to ensure:
- Synchronised fallowing
- Synchronised lice treatments
- Matching year class
- Data sharing
- Good husbandry
Further mitigations may be possible in the future, in particular in relation to interactions which are not fully resolved by relocation and adherence to existing best practice. A breakdown of these mitigations is appended as an annex to this report and includes:
- Improved cage design
- Access to further lice treatments
- Extended fallowing
- Maintenance of 'fire breaks' between AMAs
5.3 Monitoring
As part of the Ardmaddy Relocation project, the Executive have agreed to support monitoring of wild fish to address concerns from the river improvement group. The principle focus of this work will be the numbers of returning wild salmon during the lifetime of the project.
In addition Professor Crawford Revie will examine sea lice statistics provided by companies in Loch Broom - an approach which could be extended particularly if industry were to openly share lice level data - although clearly there may be commercial implications to this.
The difficulty with these approaches to monitoring is that it fails fully explain the reasons for observed patterns. For example, if wild populations recover following relocation is it certain that the programme is responsible? The ROAME project proposes to compliment fishery and lice statistics with genetics assessments of population health. This is a further piece in the cause and effect jigsaw, but even this fails to fully explain observed patterns.
Monitoring must be highly complex, multi-faceted and expensive in order to conclude reasons for observed patterns within anything like acceptable confidence limits. In practice a similar, though scientifically less robust, level of understanding may be possible through analysis of existing data sources such as catch returns and lice monitoring.
Fisheries Research Services are due to report back to the LRWG on a proposal for monitoring, and in particular the cost - benefit of a more complex monitoring design.
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