Dear Supporters,
Friends of the Sound of Jura is one of more than sixty organisations that have joined the Our Seas Coalition.
Our Seas believes that Scotland’s coastal waters are among the country’s most precious assets, and worth protecting. Our waters are extremely productive, rich in biodiversity and they can support many jobs in coastal communities if they are managed sustainably.
​
Some fishing methods damage life on the seabed, destroying nurseries for commercial fish, such as maerl beds, and harming rare seabed animals. The Scottish Government has identified 11 of these Priority Marine Features (PMF) species and habitats that are most at risk from bottom-contacting fishing (scallop dredging and prawn trawling).
In 2017, a scallop dredger devastated a bed of rare flameshells in Loch Carron.
​
Despite this being one of the best examples of this PMF, the flameshell bed was not legally protected. After a public outcry, the Scottish Cabinet Secretary for the Environment set up an emergency Marine Protected Area, within which it is hoped that the flameshells will gradually recover. She also promised to review the protection given to PMFs from scallop dredging and prawn trawling. This review was launched in 2018 but nothing has come of it so far and the Government’s ambition to protect these PMFs seems to have dwindled almost to nothing. The only tangible action is that trials have started of tracking devices on the smaller scallop dredgers, which would show where the boats are, without being admissible as evidence in court, if the boats are fishing illegally in protected areas.
​
We fear that these devices will be used to claim that PMFs can now be avoided very precisely, so the few areas where this type of fishing is not allowed, such as parts of the Loch Sunart to the Sound of Jura Marine Protected Area, might be opened up to dredging, with just small exclusions around the known PMF locations. Records of PMFs are far from complete and the unknown ones will be at risk.
Although the Government has designated 20% of our seas as Marine Protected Areas, boats using bottom-contacting methods are allowed to continued scraping 95% of Scotland’s seabed, and some boats illegally fish the remaining 5%, where they are banned. Marine Scotland Compliance seems unable to enforce the law.
​
The Scottish Government has control over the management of our inshore area within 12 nautical miles. Its agency, Marine Scotland, is obliged to follow Scotland’s National Marine Plan (NMP) and the Marine (Scotland) Act 2010, which require it to put fisheries on a sustainable footing. The National Performance Framework also commits the Scottish Government,
​
“by 2020 [to] effectively regulate harvesting and end over-fishing … and unregulated fishing and destructive fishing practices and implement science-based plans, in order to restore fish stocks in the shortest time feasible, at least to levels that can produce sustainable yield as determined by their biological characteristics”.
​
The Government has also committed to promote local, small-scale and sustainable fisheries, robust measures to protect vulnerable stocks, and “mechanisms for managing conflicts between fishermen” (Policy FISHERIES 1), so as to manage fisheries in the long-term public interest. Its marine planners must also identify marine carbon sinks and seek to avoid the “Colocaton of damaging activity”. Dredging disturbs the ability of seabed sediments to store carbon.
​
None of these obligations are being met by our Government. In fact, the Scottish Government has failed to meet 11 of the 15 indicators it uses to measure Good Environmental Status, allowing our marine environment to decline.
​
The longer Ministers stall, the more seabed habitats we lose and the harder it becomes for them and the species that rely on them to recover.
​
Our seas are a public asset and potential resource; they must be managed in a way that restores lost marine life and degraded fish stocks, and recovers the marine environment, so it can provide for us all into the future. To restore public confidence, Ministers must be guided by science and policy. We need urgent action to stop further destruction and improve the resilience of our seas.
​
So, what can be done to preserve what’s left and allow recovery?
​
The degradation can still be reversed. If we protect the seabed it will recover. If we take action, environmental and economic benefits will flow.
​
This European Environment Agency report, Marine Messages, states it clearly:
​
"Solutions for halting the loss of marine biodiversity and starting to restore ecosystem resilience, while allowing for the sustainable use of Europe's seas, are obvious and available. They just need to be implemented.”
​
But that is not happening in Scotland.
​
In the absence of any progress to protect and restore Scotland’s seabed habitats and animals, and with the laws on illegal fishing going unenforced, Our Seas calls on First Minister Nicola Sturgeon and the Scottish Government to implement their own policies and stop the chronic destruction of our seabed.
​
Reinstating a coastal limit on bottom-trawl and dredge fishing seems to be the only way for this to be enforceable, so Our Seas calls for the Scottish Government to act urgently on this.
​
Our Seas is campaigning to Bring Back the Fish - Bring Back Scotland's #InshoreLimit
Please help this to happen by signing and sharing the Our Seas petition here
Please join us in supporting this petition:-
https://ourseasscotland.eaction.org.uk/bring-back-the-fish
Friends of the Sound of Jura have recently added their name to support a Global Call for the United Nations Human Rights Council to recognise without delay the human right to a safe, clean, healthy and sustainable environment.
In this time of climate emergency and COVID-19 crisis, we have come together as civil society organizations, social movements, local communities, and Indigenous Peoples to address the attached letter, calling on the United Nations Human Rights Council to recognize without delay the human right to a safe, clean, healthy, and sustainable environment. We respectfully ask you to join with us, support this call, and share it with other organizations that might be interested in joining this call.
Details can be found on the following link:
bit.ly/Right2Environment_SignOn
Friends of the Sound of Jura
www.friendsofthesoundofjura.org.uk
Community Group Member of
The Coastal Communities Network, Scotland
Friends of the Sound of Jura is a Scottish Charitable Incorporated Organisation: SC049740
​
​
Dear Supporters,
Friends of the Sound of Jura is one of more than sixty organisations that have joined the Our Seas Coalition.
Our Seas believes that Scotland’s coastal waters are among the country’s most precious assets, and worth protecting. Our waters are extremely productive, rich in biodiversity and they can support many jobs in coastal communities if they are managed sustainably.
​
Some fishing methods damage life on the seabed, destroying nurseries for commercial fish, such as maerl beds, and harming rare seabed animals. The Scottish Government has identified 11 of these Priority Marine Features (PMF) species and habitats that are most at risk from bottom-contacting fishing (scallop dredging and prawn trawling).
In 2017, a scallop dredger devastated a bed of rare flameshells in Loch Carron.
​
Despite this being one of the best examples of this PMF, the flameshell bed was not legally protected. After a public outcry, the Scottish Cabinet Secretary for the Environment set up an emergency Marine Protected Area, within which it is hoped that the flameshells will gradually recover. She also promised to review the protection given to PMFs from scallop dredging and prawn trawling. This review was launched in 2018 but nothing has come of it so far and the Government’s ambition to protect these PMFs seems to have dwindled almost to nothing. The only tangible action is that trials have started of tracking devices on the smaller scallop dredgers, which would show where the boats are, without being admissible as evidence in court, if the boats are fishing illegally in protected areas.
​
We fear that these devices will be used to claim that PMFs can now be avoided very precisely, so the few areas where this type of fishing is not allowed, such as parts of the Loch Sunart to the Sound of Jura Marine Protected Area, might be opened up to dredging, with just small exclusions around the known PMF locations. Records of PMFs are far from complete and the unknown ones will be at risk.
Although the Government has designated 20% of our seas as Marine Protected Areas, boats using bottom-contacting methods are allowed to continued scraping 95% of Scotland’s seabed, and some boats illegally fish the remaining 5%, where they are banned. Marine Scotland Compliance seems unable to enforce the law.
​
The Scottish Government has control over the management of our inshore area within 12 nautical miles. Its agency, Marine Scotland, is obliged to follow Scotland’s National Marine Plan (NMP) and the Marine (Scotland) Act 2010, which require it to put fisheries on a sustainable footing. The National Performance Framework also commits the Scottish Government,
​
“by 2020 [to] effectively regulate harvesting and end over-fishing … and unregulated fishing and destructive fishing practices and implement science-based plans, in order to restore fish stocks in the shortest time feasible, at least to levels that can produce sustainable yield as determined by their biological characteristics”.
​
The Government has also committed to promote local, small-scale and sustainable fisheries, robust measures to protect vulnerable stocks, and “mechanisms for managing conflicts between fishermen” (Policy FISHERIES 1), so as to manage fisheries in the long-term public interest. Its marine planners must also identify marine carbon sinks and seek to avoid the “Colocaton of damaging activity”. Dredging disturbs the ability of seabed sediments to store carbon.
​
None of these obligations are being met by our Government. In fact, the Scottish Government has failed to meet 11 of the 15 indicators it uses to measure Good Environmental Status, allowing our marine environment to decline.
​
The longer Ministers stall, the more seabed habitats we lose and the harder it becomes for them and the species that rely on them to recover.
​
Our seas are a public asset and potential resource; they must be managed in a way that restores lost marine life and degraded fish stocks, and recovers the marine environment, so it can provide for us all into the future. To restore public confidence, Ministers must be guided by science and policy. We need urgent action to stop further destruction and improve the resilience of our seas.
​
So, what can be done to preserve what’s left and allow recovery?
​
The degradation can still be reversed. If we protect the seabed it will recover. If we take action, environmental and economic benefits will flow.
​
This European Environment Agency report, Marine Messages, states it clearly:
​
"Solutions for halting the loss of marine biodiversity and starting to restore ecosystem resilience, while allowing for the sustainable use of Europe's seas, are obvious and available. They just need to be implemented.”
​
But that is not happening in Scotland.
​
In the absence of any progress to protect and restore Scotland’s seabed habitats and animals, and with the laws on illegal fishing going unenforced, Our Seas calls on First Minister Nicola Sturgeon and the Scottish Government to implement their own policies and stop the chronic destruction of our seabed.
​
Reinstating a coastal limit on bottom-trawl and dredge fishing seems to be the only way for this to be enforceable, so Our Seas calls for the Scottish Government to act urgently on this.
​
Our Seas is campaigning to Bring Back the Fish - Bring Back Scotland's #InshoreLimit
Please help this to happen by signing and sharing the Our Seas petition here
Please join us in supporting this petition:-
https://ourseasscotland.eaction.org.uk/bring-back-the-fish
Friends of the Sound of Jura have recently added their name to support a Global Call for the United Nations Human Rights Council to recognise without delay the human right to a safe, clean, healthy and sustainable environment.
In this time of climate emergency and COVID-19 crisis, we have come together as civil society organizations, social movements, local communities, and Indigenous Peoples to address the attached letter, calling on the United Nations Human Rights Council to recognize without delay the human right to a safe, clean, healthy, and sustainable environment. We respectfully ask you to join with us, support this call, and share it with other organizations that might be interested in joining this call.
Details can be found on the following link:
bit.ly/Right2Environment_SignOn
Friends of the Sound of Jura
www.friendsofthesoundofjura.org.uk
Community Group Member of
The Coastal Communities Network, Scotland
Friends of the Sound of Jura is a Scottish Charitable Incorporated Organisation: SC049740
​
​
![](https://static.wixstatic.com/media/2aea85_c1f9888c739844239b560c77179aac13~mv2.jpg/v1/fill/w_227,h_107,al_c,q_80,enc_auto/2aea85_c1f9888c739844239b560c77179aac13~mv2.jpg)
Email to the Scottish Ministers 16 Nov 2019
From: Friends of the Sound of Jura <info@friendsofthesoundofjura.org.uk>
Subject: Request to call in SEPA PROPOSED DETERMINATION OF APPLICATION FOR VARIATION OF AUTHORISATION. REFERENCE NUMBER: CAR/L/1004226 BAGH DAIL NAN CEANN MARINE PEN FISH FARM, LOCH SHUNA
Date: 16 November 2019 at 15:11:27 GMT
To: EQCAT@gov.scot
Cc: registrydingwall@sepa.org.uk
Scottish Ministers,
The Scottish Government,
Environment and Forestry Directorate,
Environmental Quality Division,
Area 1-D (North),
Victoria Quay,
Edinburgh
EH6 6QQ
Re WATER ENVIRONMENT (CONTROLLED ACTIVITIES) (SCOTLAND) REGULATIONS 2011,
SEPA NOTIFICATION OF PROPOSED DETERMINATION OF APPLICATION FOR VARIATION OF AUTHORISATION
REFERENCE NUMBER: CAR/L/1004226
LOCATION OF ACTIVITY: BAGH DAIL NAN CEANN MARINE PEN FISH FARM, LOCH SHUNA
Dear Ms Cunningham,
The Friends of the Sound of Jura coastal community group objects to SEPA’s decision to grant a variation of authorisation under CAR, for the expansion of biomass at the Bagh Dail Nan Ceann fish farm in Loch Shuna by 20% to 3000 tonnes.
The expansion of this farm represents a direct threat to jobs in our community that depend on the health of the sea.
As shown by the graph on the right side of the screen grab from the Scotland’s Environment website below, the degree of seabed pollution around this farm has already caused it to fail multiple environmental monitoring surveys, when its biomass was substantially lower than it would be after the proposed expansion.
​
![Screengrab from Scotland's Environment w](https://static.wixstatic.com/media/2aea85_50cba2f85a5b4719b602f3ea1530f4f5~mv2.png/v1/fill/w_933,h_622,al_c,q_90,usm_0.66_1.00_0.01,enc_auto/Screengrab%20from%20Scotland's%20Environment%20w.png)
The most recent of these seabed surveys (report attached below) was conducted by MOWI staff in December 2017 and judged ‘borderline’ by SEPA. In fact the text of the survey report shows that the seabed quality failed on several counts.
Despite this, MOWI has applied to SEPA for permission to increase the biomass at the BDNC Loch Shuna farm by 40% to 3500t.
SEPA has decided that its pollution modelling software supports a 20% biomass increase at the site (500 tonnes more fish), and that this increase would reduce the amount of organic waste falling on each square metre of seabed. SEPA’s decision does not make it clear enough that this reduction in grammes per square metre of waste deposition is only possible because the agency is allowing a large increase in the area of seabed that would be severely polluted.
Under SEPA’s new regulations, a farm’s ‘pollution mixing zone’ depends on the surface area of the farm. MOWI already has planning permission to expand this farm from 10 to 12 cages and to moor the cages further apart. This increases its surface area and enables SEPA to calculate a larger pollution mixing zone. The overall amount of organic pollution will of course increase by 20%, in line with biomass. Any chemical bath treatments discharged into the water will also increase by 20%, as will the number of sea lice larvae released into the sea through the farm’s open nets.
SEPA and the industry both acknowledge that the agency’s computer modelling of the dispersion of fish farm bath treatments is inadequate, and that their impact beyond the immediate area of the farm is unknown. One of these chemicals, hydrogen peroxide, is not even regulated by SEPA, yet 5000 tonnes are discharged into Scotland’s sea each year, including at BDNC Loch Shuna. The ongoing Norwegian ‘PestPuls’ study shows that hydrogen peroxide can kill commercially fished crustaceans 1-2km from farms and up to three days after treatments, at doses typical of use on fish farms.
At its existing size, BDNC Loch Shuna has had catastrophic levels of mortalities this year, with around a quarter of the fish dying of disease and algal blooms. The rest have been killed early, to prevent them succumbing in the same way, and the farm is now empty. The same thing has happened at most of MOWI’s farms in Argyll, and as far afield as Rum. According to MOWI’s Director of Communication; ‘These 12 sites lost a combined total of 737,000 fish over the three month period, or 2,600 tonnes in weight’ between July and September. This was twice the usual death rate and cost the company £7.6 million. The company says this was exacerbated by warmer water temperatures, which will become more likely as the climate warms.
The Fish Health Inspectorate visited the site on 26th June, reporting that lumpfish had suffered ‘issues with mortality increasing with the warmer weather’….’This was visible when inspecting the pens as some fish looked very lean, and others with a clear fungal challenge'. MOWI was also censored in September 2019 by the Animal and Plant Health Agency for failing to look after the welfare of its lumpfish, saying that ‘Not taking effective decision at earlier date has prolonged the period while the lumpfish still at the site have been in need to be protected from suffering and disease’.
The Scottish animal campaigns charity, OneKind, ranked BDNC as one of the worst for animal welfare in Scotland. That was based on an analysis of death rates, overcrowding, lice infestations and other factors in 2017.
The BDNC Loch Shuna farm is clearly already stocked beyond its capacity to sustain so many salmon, yet MOWI has already started the process of applying for planning permission to add another two cages to BDNC Loch Shuna. Once it has 14 cages in place, the farm’s area will have increased again, allowing SEPA to recalculate a yet larger mixing zone, and to give permission for a further variation of authorisation of the CAR licence, to the 3500 tonne biomass that MOWI wanted in the first place, making this the largest single salmon farm in Scotland.
SEPA will be able to use the same illogical justification that it has this time, that the quantity of waste falling on each square metre of seabed has not increased, while failing to point out that the area of seabed so affected has grown enormously.
There is no end to this step-wise increase of seabed pollution, as neither SEPA nor aquaculture’s other regulators impose a maximum size on the area that fish farms can occupy, so their pollution mixing zones and the area of seabed around each farm that can be severely polluted can continue to grow indefinitely.
The assumption that seabed pollution does no harm is based on the out-dated and unsustainable assertion that the marine environment can assimilate large amounts of organic waste, providing only that two species of burrowing worm survive to aerate the sediment, and that this would allow the seabed to recover in the medium to long term, in the unlikely event that the farms were removed. Hardly any fish farms have ever been removed - instead the industry and Scottish Government are intent on doubling their capacity - so the area of severely polluted seabed continues to grow.
SEPA confirms that fish farms are the largest polluter of Scotland’s seas. They are allowed to dump their waste in the water for free, with the cost borne instead by coastal communities. This is not consistent with the polluter pays principle or with tackling pollution at source.
Despite the recommendations of the ECCLR and REC Committees more than a year ago that the status quo is not an option, there has still been no thorough assessment of the cumulative environmental impact of waste from multiple farms, or of the capacity of the marine environment at the waterbody scale or larger to assimilate the organic and chemical waste discharges from fish farms.
Besides the harm to other marine life and to local jobs, the ongoing pollution, welfare and disease disasters are doing tremendous harm to the reputation of brand Scotland, especially the food and drink sectors. Scotland’s farmed fish are falling very far from being demonstrably the best in the world.
Please call in this decision and do not allow this farm to expand.
Yours Sincerely
Friends of the Sound of Jura
Community Group Member of
The Coastal Communities Network, Scotland
Response from Scottish Ministers 26 Nov 2019
The following response was received from the Scottish Ministers:
![Scottish Ministers to FOSOJ 26 Nov 2019.](https://static.wixstatic.com/media/2aea85_f794c76127d947168f0a533dcdfd8341~mv2.png/v1/fill/w_863,h_738,al_c,q_90,usm_0.66_1.00_0.01,enc_auto/Scottish%20Ministers%20to%20FOSOJ%2026%20Nov%202019_.png)