9 Additional comments
Additional comments summary:
- A key concern was that care must be taken not to over-exploit resources in general.
- Several respondents considered that seaweed cultivation, including IMTA, should be subject to an Environmental Impact Assessment ( EIA).
- Respondents felt that all marine users should be taken into account when determining planning applications for all types of aquaculture, not just seaweed cultivation.
- One respondent requested financial support for the seaweed cultivation industry from the Scottish Government.
- Several respondents, particularly from the fishing industry, raised the issue of spatial pressures in the marine/coastal environment, and the effects these were having on their industry. They were of the view that consenting does not give due consideration to the displacement of fishing activities by marine/coastal development, or to the cumulative environmental pressures from e.g. Marine Protected Areas ( MPAs), renewable energy, and/or existing aquaculture developments, which may result in fisheries displacement. They drew particular attention to the Orkney fishery and called for a moratorium on further aquaculture developments, including seaweed, in Orkney.
- One respondent opposed to seaweed cultivation in the marine/coastal environment suggested that such cultivation would be acceptable if it were undertaken in tanks on land.
9.1.1 Some responses to the consultation document covered wider issues than those covered by the consultation questions. This section summarises these additional comments.
9.1.2 A key concern was that care must be taken not to over-exploit resources in general.
9.1.3 A few respondents from a range of sectors (including public bodies, the academic sector and the fishing industry, amongst others) suggested that Environmental Impact Assessment ( EIA) should be required for seaweed cultivation. It was felt that EIA would provide a structured means of providing environmental information alongside an application for consent, e.g. potential environmental and social impacts, including those on the benthos and water column; interactions with other marine organisms; implications for fisheries and other marine/coastal activities; visual/other coastal impacts; and evidence of mitigation measures. Another respondent felt that these requirements should also apply to shellfish farms. It was also proposed that the SPS should require that IMTA-scale cultivation undergo EIA, including the consideration of cumulative impacts.
9.1.4 Supporters of policy 5 (other marine users and activities should be considered in the siting of farms) requested guidance to assist in the assessment of potential impacts of seaweed cultivation on other marine and/or coastal users. However, they also considered that such users should also be taken into account when determining planning applications for other types of aquaculture.
9.1.5 One respondent welcomed the Scottish Government's support for seaweed cultivation, and noted that financial support would also be welcomed, stating that this would be greatly beneficial for small businesses trying not only to exist in this industry, but to grow the seaweed industry in Scotland. In addition, they felt that the funding of research would fill a large gap in the knowledge of seaweeds, their lifecycle, nutritional benefits and seasonal variability.
9.1.6 Several respondents, particularly from the fishing industry, raised the issue of spatial pressures in the marine/coastal environment, and the effects these were having on their industry. They were of the view that consenting does not give due consideration to the displacement of fishing activities by marine/coastal development, or to the cumulative environmental pressures from e.g. Marine Protected Areas, renewable energy, and/or existing aquaculture developments, all of which may result in fisheries displacement.
9.1.7 They considered that the Orkney fishery is now highly vulnerable to erosion of the critical mass of harvesting needed to sustain dependent industries, as well as the fishing skill and practitioner base. They called for an evaluation of all the impacts on the Orkney fishery and felt that Orkney should be exempted, at a national level, from any further threat to its low impact and sustainable fishery.
9.1.8 One respondent opposed to seaweed cultivation in the marine/coastal environment suggested that such cultivation would be acceptable if it were undertaken in tanks on land.
9.1.9 Policy 9 builds on existing Scottish Government policy on the spatial location of aquaculture development, which comprises a presumption against finfish farming on the north and east coasts, to safeguard migratory fish species. One respondent considered that Policy 9 would push seaweed farms onto the west coast, with attendant environmental problems, and felt that the policy was not equitable.
9.1.10 In contrast, one respondent felt that the existing policy should be widened to include Orkney and amended as follows: "There should be a presumption against further finfish and IMTA developments in Orkney due to the fact that Orkney is now at full capacity in terms of aquaculture sites". This respondent considered that Orkney waters are fully exploited by a sustainable and low impact wild inshore fishery, that Orkney is under greater pressure than any other area of the UK to accept large-scale renewable developments as it lies within the north region, and that the inshore fishery therefore requires special protection. One respondent called for a moratorium on further aquaculture developments, including seaweed, in Orkney, to support the existing inshore fishing industry.
9.1.11 One public sector body noted that, if this policy is to use area-based restrictions, it should apply to all sectors of the aquaculture industry. They cited examples of non-native species having been introduced as an aquaculture product and having become naturalised ( e.g. rainbow trout in Scottish freshwater lochs), and raised concerns about escapes of non-native strains of salmon.
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