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6 Discussion
The process advocated by the Location Relocation Working Group is entirely voluntary, operating with the goodwill of a diverse group of stakeholders. This approach is not perfect but provides a practical and workable solution, able to identify win: win situations where concerns of wild fish interests are compatible with the commercial interests of industry. There are limitations to this approach but the need for a voluntary solution reduces the practical viability of more strategic approaches to relocation or a stricter interpretation of the precautionary principle
It is a fortunate coincidence that many relocation proposals make sound business and operational sense for farmers - particularly where production consolidation results. Many already underway in Scotland would still occur without the impetus of this programme. In order to achieve consent for these relocations, detailed Environmental Statements support the application and farmers recognise the value of highlighting the environmental benefit of the relocation.
Only a small number of these farmer-initiated relocations are wholly reliant upon part funding from the Scottish Executive and most would proceed anyway even if the financial support was not forthcoming - such is the economic argument for consolidation. By contrast the available funding is rarely likely to convince the farmer to voluntarily relocate away from a profitable site - unless it is clearly in the company's commercial interest to do so.
Does this matter and does it create less environmental benefit - or even greater environmental risk?
There are sufficient existing safeguards within the system (in particular within EIA legislation) to ensure that this preferred approach to relocation does not lead to a deterioration in Scotland's marine environment. If well-planned an environmental benefit is quite possible and in many cases a relocated site is likely to reduce the potential for interaction between farmed and wild salmon (for sea trout the potential for significant benefit is less). The exact scale of this benefit and in particular whether alternative approaches would result in greater benefit is unclear.
It is probable that in some instances similar environmental benefits may be achieved in a more cost effective manner through minor changes in location (using the same shore facilities) or through changes in operational practices. The biggest single benefit may be achieved through the licensing of an increased range of lice medicines - although there are considerable obstacles to this.
A more strategic relocation exercise, as advocated by some members of the LRWG, would enable a more precautionary approach, which in theory could lead to an increased benefit to wild populations. This approach could also give greater priority to views of other stakeholders - even going so far as allowing other concerns (beyond those of the wild fish interests) to initiate the relocation process. Such an approach would however be strongly resisted by the industry and could quickly become unworkable.
The only way in which a compromise may be achieved would be through developing a long term strategy which highlights areas appropriate for further development and other areas with presumption against further development. As leases expire or company practices evolve there may be opportunity to slowly relocate aquaculture activity. This could, over time address concerns of wild fish interests in a way that creates minimum long term economic impact on the industry.
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