The Scottish Executive’s (SE) consultation document ‘A Strategic Framework for Scottish Aquaculture’ (9th January 2003) demonstrates with frightening clarity the regulatory failure that allows factory salmon farming to create havoc in the West Highland and Islands marine and freshwater environment. It unashamedly pretends to be unique and vigorous but, in reality, it is designed solely to address issues that should have been addressed three decades ago, prior to the expansion of fish farming, not now.

But the document seems to serve another, less savory purpose: it attempts to justify this regulatory failure and to exonerate those responsible for allowing it to happen; the succession of Scottish Office and now Scottish Executive civil servants and fisheries scientists who have consistently protected aquaculture from public scrutiny, allowing salmon farming to expand far beyond the carrying capacity of the waters into which the industry dumps its untreated waste.

The SE’s most famous success in protecting the fish farmers from public scrutiny was in 2000:  they rejected a request from two Parliamentary committees for an independent public inquiry into the damage caused by fish farming, based upon a petition presented by Mr Allan Berry (PE 96) and backed by 500 pages of scientific evidence. Berry’s petition was also supported by more than 100 organisations from UK and from around the world. The Scottish Executive dismissed the petition and the call for a public inquiry as being “irrelevant”. They claimed that they were already investigating these matters.

If this was indeed true, then why are so many of the new research projects announced in today’s  ‘Strategic Framework’ document exactly the same as the ones that the executive claimed to be investigating two years ago? And now, as then, why are no costs or even estimated costs attributed to these projects?  Surely the executive must have prepared and approved a financial budget for the work they propose to carry out?

The list of members on the ‘Ministerial Working Group’ that produced the framework further exposes the fallacious nature of this 86-page document: of twenty-nine participants, including the Secretariat, twenty-six represented either government or industry interests and two came from Scottish Environment Link, an over-arching body of environmental organsiations. Only one member, Andrew Wallace representing the Association of Salmon Fishery Boards (ASB), had any direct involvement with wild salmonids.

When Allan Wilson, SE deputy rural affairs minister, announced the formation of this Group, he boasted that it embraced the views of all “stakeholders”, from both industry and wild fish interests. But the ASB represents only the interests of fishery owners, and not the interests of Scotland’s 250,000-strong rod and line sport anglers. Their representative bodies, The Scottish Anglers’ National Association and the Salmon & Trout Association (Scotland), who have complained bitterly for years about the despoliation of wild salmon and sea-trout by fish farm disease and pollution, were not invited to be members.

The SE strategy makes it abundantly clear that, come what may, they intend to continue to give full support to fish farming, regardless of the impact it has on wild fish, the environment, employment in tourism, or on shellfish fishing: “a streamlined application process [for permission to use new chemicals]” (page 10); “to encourage more people to benefit from Scotland’s healthy, nutritious aquaculture products” (page 23); “the application of genetic techniques may be expected to play some role in the future” (page 30); “a campaign designed to improve the public’s understanding of the industry… will  be mounted” (page 34); “assist the industry… including the provision of new piers and jetties” (page 52); “lighter regulatory standards” (page 60).

In direct contradiction of the above, the document notes: “To develop further, aquaculture will need suitable additional capacity [more fish farm sites], but this will be subject to carrying capacity limits still to be determined” (page 15); “The industry will identify means of increasing production within the constraints of carrying capacity (still to be determined)” (page 27); “Without an in-depth understanding of the limits of environmental capacities, the precautionary principal which would have to be applied would constrain aquaculture development below its full potential” (page 37); “In several parts of the Highlands and Islands wild stocks are already depleted or even extinct” (page 39); “Better information is needed on the causes of escapes” (page 47).

The sad truth is that this ‘Strategic Framework’ is nothing other than a rehash of the many similar Scottish Office and SE documents issued over the years, their only purpose being to allay concern about the spread of fish farm disease and pollution and to imply to the public that the industry was being effectively regulated; late and unlamented talking shops, such as the Scottish Secretary’s salmon advisory group, the West Highland Sea Trout & Salmon Group, Michael Forsyth’s Scottish Salmon Strategy Task Force, and the present Tripartite Working Group and Highlands and Islands Aquaculture Forum, et al.. Nothing in the framework document will have any impact on current fish farm practice, because that is exactly what the SE intend. For the fish farmers it will mean ‘business as usual’. For Scotland’s wild salmon and sea-trout, it will mean death.