The Need for a Sustainable Strategy for Scottish Aquaculture.

A response to the Scottish Executive Consultation on the Aquaculture and Fisheries Bill. 24 February 2006.

The full referenced, version of this submission is available to download - click here. The Executive Summary (this document) is also available as a pdf - click here.

Overview

There is the potential for a sustainable and economically viable fish farming industry in Scotland. The independent sector in Scotland which is characterised by good social, economic and environmental practices is showing the way forward.

Unfortunately, the independent sector currently makes up only a small part of the Scottish industry which is largely characterised by a low-cost high-volume approach to fish farming that is:

• Socially unsustainable as it has already cost hundreds of jobs in remote rural communities in the last five years.
• Economically unsustainable for Scotland as it is driven by foreign multinational companies whose primary allegiance is to international investors rather than to the needs of the communities and countries in which their operations are located.
• Environmentally unsustainable as the systematic overfishing of wild stocks for fish feed is causing eco-system collapse and harming commercial and artisanal fisheries in the North Sea and throughout the world.
• Scientifically unsound as it relies on insufficient scientific evidence of the safety and effectiveness of artificial feed substitutes and pays no regard to the precautionary principle.
  

The low-cost high-volume approach is being driven, not by Scottish interests, but by Norwegian political and business leaders. If successful, their strategy will benefit Norway exclusively at the expense of other countries’ aquaculture industries. The Scottish Executive should not support policies or spend resources which benefit the economy of another country to the detriment of Scotland and our own coastal communities.

As it stands the proposed Aquaculture and Fisheries Bill will do nothing to check the social, economic and environmental disbenefits outlined above. The regulatory issues of fish health and farm relocations that this Bill sets out to tackle – while noble causes in themselves – amount to fiddling while the opportunity for a sustainable aquaculture industry sinks.

We call on the Executive to fundamentally revise this Bill to promote the development and implementation of a strategy for Scottish aquaculture that builds on the Executive’s commitments set out in Choosing our Future: Scotland’s Sustainable Development Strategy, to establish a successful aquaculture industry based on the local and global dimensions of sustainability.

Executive Summary

1) Scotland needs a strategy for aquaculture that is based on sustainable principles, recognising both the local and global dimensions of sustainability.

In December 2004 the Scottish Parliament passed a motion welcoming the Scottish Executive’s commitments “to support a sustainable aquaculture industry” and “to protect and improve employment and investment opportunities in…many parts of our most remote rural and island communities”.

The Executive, in its sustainable development strategy, has identified the following among its key principles:

• “promoting personal well-being, social cohesion and inclusion, and creating equal opportunities for all”
• building an economy “which provides prosperity and opportunities for all”
• “respecting the limits of the planet’s environment, resources and biodiversity”
• ensuring policy is developed “taking into account scientific uncertainty (through the Precautionary Principle) as well as public attitudes and values”.

2) There is the potential for a sustainable and economically viable fish farming industry in Scotland. The independent sector in Scotland which is characterised by good social, economic and environmental practices is showing the way forward.

Much of the independent fish farming sector in Scotland is moving towards the implementation of Soil Association organic standards which bring multiple benefits. The growing process is labour intensive because various environmentally damaging chemicals are prohibited. As well as providing more jobs it also means an end product recognised for its quality by consumers which therefore commands a higher market price.

3) Unfortunately, the independent sector currently makes up only a small part of the Scottish industry which is largely characterised by a low-cost high-volume approach to fish farming that is unsustainable socially, economically and environmentally.

Eighty five per cent the Scottish industry is owned by foreign multinationals. The move from indigenous to foreign control of the industry has been pronounced over the last ten years and is likely to continue.

4) The low-cost high-volume approach is socially unsustainable as it has already cost hundreds of jobs in remote rural communities in the last five years. These losses are likely to continue.

The merger in 2005 of two multinationals, Marine Harvest and Stolt Sea Farms, immediately led to the loss of more than 50 jobs at a recently opened processing factory on the small island of Scalpay in the Western Isles with dramatic social and economic consequences. The company say that more cuts are on the way.

In 2002 the multinational, Pan Fish, took over Wester Ross based Highland Fish Farmers. Staff at the company report that since then the number of jobs has fallen from over 60 to around a dozen. The cuts were specifically criticised by the sheriff of a Fatal Accident Inquiry into the death of a Pan Fish employee on one of their farms in 2003.

5) The low-cost high-volume approach is economically unsustainable for Scotland as it is driven by foreign multinational companies whose primary allegiance is to international investors rather than to the needs of the countries and communities that their operations are located in.

Over the last five years several of the Norwegian multinational fish farm companies have lost millions of pounds as the price of salmon plummeted due to overproduction. These companies have only been kept in business by the conversion of massive amounts of debt to shareholdings by banks. Rather than cut production to return to profit – which was the method suggested by banking regulators and advisors – Norwegian fish farmers instead increased production. This led to further financial losses.

6) The low-cost high-volume approach is environmentally unsustainable as it is a major cause of wild stock depletion. Each year the industry uses millions of tonnes of fish feed which is manufactured from industrial fishing stocks. The systematic overfishing of these industrial stocks is causing eco-system collapse and thus harming commercial and artisanal fisheries both in the North Sea and throughout the world.

By 2009 it is predicted that aquaculture will require almost the entire global output of fish oil which is used to produce feed. This demand is already placing increased pressure on the fish stocks used to produce the oil.

In 2003 the industrial sand eel fishery in the North Sea collapsed. Scientists at the International Council for the Exploration of the Seas believe the blue whiting is also on the verge of collapse. European politicians have ignored their advice and are allowing 2 million tonnes of blue whiting to be taken from the sea in 2006, mainly by Norwegian boats.

Meanwhile, buyers of fish meal and fish oil in South America are reporting unprecedented demand.

7) The low-cost high-volume approach is scientifically unsound as it relies on insufficient scientific evidence of the safety and effectiveness of artificial feed substitutes and pays no regard to the precautionary principle.

Studies from industry sponsored scientists claim that much if not all of the fish oil used to feed farmed salmon can be replaced with vegetable oils.

However, another industry sponsored study has shown that a vegetable oil diet, even over a relatively short period, can have detrimental effects for the fish and lessen the benefits for human consumers. This study has not been promoted.

8) The low-cost high-volume approach is not being driven by Scottish interests. In fact it is being vigorously pursued by Norwegian political and business leaders who see intensive aquaculture as the economic solution to the depletion of Norway’s oil resources.

In 1999 Norway’s premiere research institute predicted that the country’s fisheries industry could be worth £21 billion a year by 2030, highlighting aquaculture as a major growth area. Aquaculture is now regarded as the mainstay of Norway’s economic future.

However, in order for them to reach this end it is necessary for them to achieve monopoly control over the global industry.

Financial assistance provided by partially state run banks has played a vital role in this bid for global control. It has allowed Norwegian multinational companies to survive and actually expand their interests – including taking over companies in Scotland – at a time when the Norwegian industry was losing hundreds of millions of pounds as a result of overproduction. This may have breached state-aid rules.

9) If successful, the strategy will benefit Norway exclusively at the expense of other countries’ aquaculture industries. The low-cost high-volume approach is economically unsustainable for Scotland. The Executive should not support policies or spend resources which benefit the economy of another country to the detriment of Scotland and our own coastal communities.

This submission provides compelling evidence that the current financial crisis in the fish farming industry has been manufactured by the Norwegian elite as they try to ensure that country’s continued financial security. However, the consequences of this crisis have been most intensely felt in Scotland, in “many parts of our most remote rural and island communities”. There is an overwhelming case for the Scottish Executive to deal with this social, economic and environmental exploitation as a matter of urgency.

As it stands the proposed Aquaculture and Fisheries Bill will do nothing to check the social, economic and environmental disbenefits outlined above. The regulatory issues of fish health and farm relocations that this Bill sets out to tackle – while noble causes in themselves – amount to fiddling while the opportunity for a sustainable aquaculture industry sinks.

10) We call on the Executive to fundamentally revise this Bill to promote the development and implementation of a strategy for Scottish aquaculture that builds on the Executive’s commitments set out in ‘Choosing our Future: Scotland’s Sustainable Development Strategy, to establish a successful aquaculture based on local and global dimensions of sustainability.

Elements of a sensible, sustainable and economically viable aquaculture are already in place. Mindful of the highly unsustainable nature of the low-cost high-volume approach, the Executive should undertake consultation with Scottish independent producers, and the social and environmental certification bodies, with a view to maximising the industry’s potential for truly sustainable growth. This may take the form of financial support for research, marketing and promotion, while at the same time implementing a strong regulatory regime which supports the needs of these producers at the expense of the needs of low-cost high volume producers.