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THE KEY THEMES

What follows is a more detailed outline of each of the five key themes of the Renewed Strategic Framework. The issues, as identified by stakeholders during the pre-consultation exercise, are highlighted within each theme as well as how they relate to other themes and the strategic objectives of the Scottish Government's Economic Strategy

HEALTH

Desired outcome: A secure long-term future for the industry by protecting the asset through adoption of disease-control strategies which also contribute to minimising impacts on the environment

Integrated Sea Lice Control Strategy

This is essential for the health and welfare of farmed fish and also to limit infection from or to wild fish populations. It is vital to have an effective, integrated sea lice strategy using medicines but also to employ alternative non chemical methods including management of sites to reduce infection and natural control methods such as the use of cleaner-fish.

There is evidence of a build up of resistance in sea lice to the limited number of available treatments. SEPA has recently commenced issuing licences for the new treatment, AMX™ and authorisation for use of this chemical is also being sought from the Veterinary Medicines Directorate ( VMD). It is important that the efficacy of medicines and potential of such new medicines is kept under review but at the same time the methods of treatment must be continuously improved. There may also be opportunities to share information on best practice with other countries, particularly Norway.

The Aquaculture and Fisheries (Scotland) Act 2007 makes provisions for the control of parasites (sea lice). A Record Keeping Order is being developed along with guidance for fish health Inspectors. The Order will be laid in the next session of the Scottish Parliament. Inspections for compliance with the Act will commence in Autumn 2008, once the Order is in place.

Tripartite Working Group

This group was set up to promote dialogue between the wild fish sector and finfish farmers for mutual benefit. It has been very successful, particularly with the signing of 18 Area Management Agreements on the west coast. We must build on this success.

Hatcheries

It is important that Scotland retains hatcheries for aquaculture in order to secure supplies of juveniles for the future development and diversification of the industry. This will also reduce the risk of introduction of disease through importing stocks from other countries.

Shellfish

It is essential to control the culture, harvesting and marketing of shellfish in order to protect public health. SEPA has a duty to maintain and improve the quality of shellfish waters and the Food Standards Agency is responsible for ensuring that shellfish are fit for human consumption. It is important that these duties are carried out in a co-ordinated fashion to promote efficiency to the benefit of both producers and consumers. In certain cases the powers provided by legislation may offer only a partial solution to water quality problems which may be more holistically addressed through a prudent approach to marine planning.

Waste Management

Arrangements and facilities for dealing with fish mortalities in Scotland are generally unsatisfactory leading to unsustainable approaches to mortality disposal. This is particularly important in respect of disease control and meeting the requirements of animal by-products legislation. SARF recently commissioned a study in this area and will make recommendations.

Aquatic Animal Health Directive ³

Application of this Directive should ensure that farms, transporters and processors operate to a high standard of biosecurity. Maintaining high fish health status in Scotland will help to protect the industry and wild fisheries stocks from the potential consequences of the introduction of disease through imports from countries and areas with a lesser health status.

Control of Disease

It is important to have a better understanding of the impacts of fish disease outbreaks. Strategies should also be developed to ensure high aquaculture animal health is maintained including regular site fallowing. Measures should also be in place to ensure the early identification of emerging and serious disease problems as well as an ability to introduce measures to control and prevent their spread, which is essential to reduce their impact.

PLANNING, CONSENTS AND SITES

Desired outcome: Development of the right sites, in the right places, by the right people through transparent, streamlined and proportionate regulation/processes to minimise impacts on other users of the marine and freshwater environment

Improved Availability of Sites

There is perceived lack of available sites for the expansion of aquaculture in Scotland. To help address this, the Expert Working Group on Aquaculture Siting has a remit to examine how sites are currently used (especially inactive sites) and make recommendations on a strategic approach to the siting of farms to help expand the aquaculture industry in a sustainable way. Any new approach will have to sit within the marine planning framework being developed as part of the Marine Bill.

Undeveloped Leases

There are many Crown Estate leases which are currently inactive. The reasons for this are varied and include companies keeping leases as an asset for the future, to act as a (disease) firebreak or for other operational reasons. Crown Estate income is related to production. If development has not progressed, Crown Estate will increase rents to discourage this. It is hoped that the Expert Working Group on Aquaculture Siting will establish the status of all leases. This information may also be useful for any brokerage system for making the best use of aquaculture sites.

Locational Guidelines

The Scottish Government has produced locational guidelines in respect of protecting water quality and natural heritage at a water body scale in an area of sea or a loch. SEPA is able to model the more localised likely impacts of potential individual developments on benthos and water quality.

Historically, development may have been allowed in sites which would now be considered to be unsuitable and a relocation grant scheme was set up under the previous Strategic Framework for Scottish Aquaculture.

The Planning Process

As a result of implementation of the Planning etc (Scotland) Act 2006,The Town and Country Planning (Scotland) Act 1997 was amended so that responsibility for determining permanent planning permission for marine aquaculture facilities was passed to the local authorities.

The planning system is plan-led, meaning that decisions on where development may or may not be permitted are generally made against the development plan for the local authority area. Scottish Planning Policy 22 provides a policy context for determining marine and freshwater farms, including the use of non-statutory guidance such as aquaculture framework plans. These plans can be used to supplement the local plan by providing further detail in guiding developments to appropriate locations. In Scotland, there are a number of such plans in place, although some of these plans have been in place for a number of years.

New or modified finfish farm developments are subject to Environmental Impact Assessment Regulations and an environmental impact assessment may be required. The requirements of the Regulations can be onerous and in order to streamline the process, a template approach to the production of environmental statements has been developed. In addition, to assist planners and developers, Scottish Natural Heritage has recently produced landscape guidance in respect of aquaculture development.

On expiry of their leases, existing marine farms will be subject to an audit or review process to ensure that requirements of European Directives are not compromised. Following this, permanent planning permission may be granted by Scottish Ministers.

Scottish Marine Bill

A consultation on a proposed Scottish Marine Bill is underway. It seeks to address the need for a system of marine planning and other improved marine management arrangements, to be championed and led by a new Scottish Marine Management Organisation ( SMMO) - Marine Scotland. The position and interests of aquaculture need to be considered alongside other issues in managing Scotland's marine areas and resources. This should be reflected, as appropriate, in the proposed Scottish marine legislation and the work of Marine Scotland. The Marine Bill consultation paper asks for views relating to where control for aquaculture should lie.

CONTAINMENT

Desired outcome: Fish farm escapes minimised by adopting best-practice to reduce stock loss, improve profitability and secure the future and credibility of the industry whilst minimising environmental impact and preventing conflict with others' interests

Escapes from Fish Farms

Effective containment is very important for fish farmers, as loss of stock can have a serious commercial impact. The release of farmed fish, particularly Salmonids, into the water environment is also of serious concern to wild fishery interests and other stakeholders. It brings risk of spread of disease to the wild population, dilution of the wild fish gene pool due to the potential for interbreeding and competition for space and food. In addition, farmed smolt have an appetite for smaller wild fish.

Wild Atlantic salmon is of european importance and is listed in Annex II of the EC Habitats Directive. Wild fishery representative bodies have particular concerns about some fish farms located in freshwater lochs where there are important wild Salmonid populations.

The Aquaculture and Fisheries (Scotland) Act 2007

This Act makes provision in relation to fish farms for containment and escapes. It gives inspectors powers to: inspect fish farms to ascertain the risk of escape, assess whether fish have escaped, and assess the measures in place to contain, prevent escape; assess (for example; condition of nets, anti-predator measures), and recover escaped fish. There is provision for issuing of enforcement notices and penalties. Inspections for compliance with the act will commence in Autumn 2008 once the necessary Record Keeping Order is in place.

Reporting of Fish Farm Escapes

Scottish Ministers must be notified as soon as possible when an escape has occurred or there is significant risk that an escape has occurred. Every suspected escape will be investigated and reported on by Fisheries Research Services on behalf of the Scottish Government. Confirmed fish farm escapes are published on the Scottish Government website.

Source of Escaped Fish

Fish farmers have a legal obligation to report escape incidents and it is essential that this is a fully-transparent process. There have been occasions where it has been difficult to identify the source of an escape and there may be a need to develop methods to improve traceability.

Utilisation of Best Practice

Best practice is set out in the Code of Good Practice for Scottish Finfish Aquaculture, which is subject to regular review and update. The farmed salmon industry has already held a number of containment workshops for its members. The trout industry intend to hold similar workshops. There may be opportunities for technology transfer with other countries.

Industry Demonstration Project

The farmed salmon industry is already carrying out trials on new net materials which are far stronger than those currently used. These are usually much more expensive but it is hoped that the research will improve containment and also highlight other benefits in terms of reduced operational costs, through net repair and replacement as well as increased profitability by reducing the amount of escapes. The rainbow trout sector will conduct similar trials.

Contingency Planning

It is essential that there are robust plans in place which reflect detailed risk assessments and scientific data.

MARKETS, MARKETING AND IMAGE

Desired outcome: Maximised profitability for commodity and niche market producers by promotion of a positive image of the industry and making best use of the Scottish quality brand to secure markets home and abroad

Image

Public perception of aquaculture can be negative and generally based on outdated and inaccurate information. There is a need to address this by positive promotion of the industry to improve its image through highlighting 'good news' stories, as well as being open if problems occur.

A Career in Aquaculture

It is important that the industry is able to attract, retain and develop able people who see a long-term rewarding career in aquaculture.

Structure of the Industry

There may be opportunities to improve co-operation between producers in various sectors to share processing facilities. Access to markets could also be improved with better planning.

Securing the Scottish Premium

The aquatic environment utilised by aquaculture producers in Scotland is different from that of some of its aquaculture competitors in that it cannot support such large-scale aquaculture developments. Some businesses are looking to rationalise operations into larger more efficient farms. There are also many opportunities for smaller-scale production to meet increasing consumer demand for niche products.

Trade Defence

The loss of the Minimum Import Price ( MIP) is an unwelcome change for the industry. The European Commission's monitoring mechanism will allow an ex-officio,

anti-dumping investigation, should there be sufficient prima facie evidence of injurious dumping. The industry needs to be able to operate in a market that does not have unfair competition from Norway. It will need support to ensure that it is prepared for potentially-difficult trading conditions.

Diversification

There are opportunities for diversification in Scottish aquaculture and experience has shown that success depends on the development of new markets so that diversification is effectively market led. The industry will need access to good advice underpinned by research and experience sharing. There should also be opportunities to explore potential benefits offered by the production of fish and shellfish to organic and higher welfare standards.

Feed Sustainability

This is a global issue which is not unique to Scotland or the aquaculture industry. International effort is required to ensure that fish feed is sourced sustainably. Wild feed fish stocks in many cases continue to be depleted and it is difficult to provide robust evidence of their sustainability. Alternative credible and appropriate raw material sources must be found. Some work has been commissioned in this area by SARF and the farmed salmon industry. There is a need for continued dialogue between key partners and stakeholders to advance this issue.

FINANCE

Desired outcome: An investment climate which supports and underpins the long-term future and competitiveness of the sector with investment in best practice and technologies to minimise impacts on the environment

Competitiveness of Scotland with other Aquaculture-producing Countries

Scotland is a major aquaculture-producing country and produces around 8% of the world's farmed Atlantic salmon. There are likely to be significant increases in salmon production by its major competitors, Norway and Chile, in the next few years and Scotland will need to protect its market share. The industry also needs to show that it is competitive in both mainstream production and to serve niche markets. The same challenges apply to the other sectors. The trout sector faces strong competition from France and Denmark and shellfish businesses face competition from the Netherlands, Spain and France.

Long-term Investor Confidence

Aquaculture is now a well-established industry, which is here to stay. Investor confidence is needed for the long-term development and expansion of Scottish aquaculture. Some view the industry as a short-term investment opportunity and remove support when there are difficulties. We need to encourage investors to take a longer term view of aquaculture, as is the case in Norway.

We need to change perceptions of the industry. This could be achieved by both Government and producers providing investors with better information about our industry and our plans for growth. We must also learn about long-term investment in aquaculture in other countries.

Lack of Private Sector Funding

The industry has commented that the private sector is unwilling to make significant investments in aquaculture. A greater number of private funders should be encouraged to engage with, and support, the sector.

EFF

The European Fisheries Fund ( EFF), the successor to FIFG (Financial Instrument for Fisheries Guidance) will provide one mechanism of support to Scotland's fisheries industry and fisheries communities. This is particularly important to smaller businesses - who have real difficulties in securing finance. The EFF will prioritise applications from micro and small enterprises. ⁴

Lack of Public Sector Finance

The aquaculture industry has commented that, apart from limited EFF, there are few opportunities for financial assistance from the public purse. Although there are a number of sources available, for example from HIE and local authorities, these must provide funding within State Aid Rules, and within the context of the wider strategies of those organisations and reducing resource allocations. There is, therefore, a need to make better use of the funding available.

Support for Innovation and New Technologies

Targeted research and development are key to a successful aquaculture industry. SARF has been very successful and there is a need to ensure that best use is made of all research carried out in Scotland. The salmon industry demonstration project is also a good example of industry looking at better, more efficient ways of working. Options should be explored for increased collaborations with Norway on research and development. There should also be continued support for knowledge transfer partnerships.

Better Use of Facilities

Competitiveness may be improved by encouraging producers to share facilities, such as processing units and shellfish depuration facilities.

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