‘Secret’ Strategy Exposed – Scottish Executive mislead both Parliament and public over aquaculture consultation

The Scottish Executive is conducting a private and exclusive debate on the future of aquaculture despite claiming in the Scottish Parliament that “the debate must be public and wholly inclusive” [1].  Time is running out for the public to respond to the ‘secret’ consultation on ‘A Strategic Framework for Scottish Aquaculture’ (the deadline is believed to be 3^rd February).  The draft ‘Consultation Document’ claims in the text that it will be finalised “following public consultation” but a civil servant told a member of the Salmon Farm Protest Group that the Government intends publishing the final strategy document before the Parliament rose in March without a statutory public consultation process [2].  The SFPG are now writing to the Standards Commission, the Scottish Executive’s Ombudsman and to the Scottish Parliament complaining about the manner in which the so-called “public consultation” has been conducted.

The Salmon Farm Protest Group reveal on their web-site – The Salmon Farm Monitor (www.salmonfarmmonitor.org) that the Scottish Executive’s “Aquaculture Strategy - Consultation Document” (http://www.scotland.gov.uk/about/ERADRA/FFAME/00015953/Strategy.aspx) was:

o             Slipped out over Christmas on 23^rd December to avoid public scrutiny

o             Rushed out as only a 6 week consultation (deadline of 3^rd February) rather than the 12-13 week consultation period required for public consultations

o             Issued privately and exclusively to a select number of pro-aquaculture groups

o             Not publicised via a press release

o             Never issued as a public consultation document as promised in Parliament

o             Not listed under ‘consultations’ on the Executive’s web-site (http://www.scotland.gov.uk) despite being referred to as a “Consultation Document”

o             Re-drafted at least five times before being issued

o             Already a year behind it’s Spring 2002 schedule for completion

o             Never discussed in a public conference as promised in Parliament

Since the Scottish Executive appear reluctant to advertise it publicly, The Salmon Farm Protest Group are urging members of the public to respond to the draft strategy and have posted a detailed response on their web-site [3].  Criticisms include:  

o             The failure to regulate and legislate for sea cage fish farming

o             Government support for a PR campaign for farmed salmon

o             Proposals to compensate farmers for relocation

o             A failure to ban salmon farms at the mouths of rivers

o             No consideration of land-based containment

SFPG Chairman Bruce Sandison said:

“The Scottish Executive’s consultation document demonstrates with frightening clarity the regulatory failure that allows factory salmon farming to create havoc in the West Highlands and Islands.  The strategy makes it abundantly clear that, come what may, the Government intends to continue to give full support to sea cage fish farming, regardless of the impact it has on wild fish, the environment, employment in tourism, or on shellfish fishing.  The sad truth is that this ‘Strategic Framework’ is nothing other than a re-hash of the many similar Scottish Office and Executive 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.  Nothing in this framework document will have any impact on the polluting practices of salmon farmers, because that is exactly what the Executive intend.  For the sea cage fish farmers it will mean ‘business as usual’.  For Scotland’s wild salmon and sea trout it will mean death”

Please visit The Salmon Farm Monitor for more information on the aquaculture strategy and further news on salmon farming: www.salmonfarmmonitor.org

For further information please contact Don Staniford on 07880 716082

Notes to Editors:

[1]  In the Scottish Parliament on 26^th June 2001, Fisheries Minister Rhona Brankin  claimed that the strategy debate would be inclusive, public, involve a conference and issue a consultation document:

“The debate must be public and wholly inclusive. I have no difficulty with that approach; indeed, I would welcome it. I mean to involve all interested organisations and groups that are willing to participate….There will be widespread consultation with people who have an interest in aquaculture. The consultation will be followed by a consultation document….work will be followed by a major conference - possibly in early 2002”

“I am keen to seek an end to that polarisation and to get some dialogue going openly and inclusively, in order to try to establish consensus on a sustainable future for aquaculture. I repeat that no attempt has been made to dampen down debate - the opposite is the case. I want to encourage and engender a genuinely public debate about the future of aquaculture in Scotland”

“I was at pains to rebut the accusation that I had a closed mind on the subject in general. I have a very open mind on the subject….We are keen to develop a sustainable strategy for aquaculture.  We want to do that in an inclusive way, by consulting all the stakeholders and by listening to what the Parliament has to say about aquaculture” http://www.scottish.parliament.uk/official_report/cttee/trans-01/tr01-1902.htm#Col1944

The Scottish Executive also claimed in a press release – “Brankin announces consultation on aquaculture strategy to balance environmental and economic concerns” - on 26^th June 2001 that: “The debate must be public – and it must be completely inclusive.  And I want to involve all interested organisations and groups which are willing to participate…The Executive aims to complete the development of the strategy by spring 2002”: http://www.scotland.gov.uk/news/2001/06/se1543.asp

In October 2001 the Scottish Executive issued “an invitation to the fish farming industry to help to develop a long-term strategy” claiming once again that “we must have a wide-ranging and inclusive debate”: http://www.scotland.gov.uk/pages/news/2001/10/SE4244.aspx

In December 2001 the Scottish Executive’s Fisheries Minister Allan Wilson again claimed that: “I am pleased that everyone involved in the consultation is approaching the process in a serious, open and inclusive way.  The intention behind this process is not to create the Executive’s strategy – rather it should be Scotland’s strategy, informed by everyone with an interest”: http://www.scotland.gov.uk/pages/news/2001/12/SE4982.aspx

A press release in June 2002 announced the appointment of an “Aquaculture Strategy Working Group” (http://www.scotland.gov.uk/pages/news/2002/06/SEEN054.aspx).   However, membership of the Ministerial Working Group of Aquaculture was by private invitation only, was composed predominantly by representatives of the sea cage fish farming industries and agencies with a vested interest in the promotion of sea cage fish farming, meetings were closed to the public and no minutes were made publicly available.  Despite claiming that “reports of the stakeholder bilaterals which have been held as the first stage of strategy development and notes outlining decisions taken by the Group after each plenary meeting can be found at: http://www.scotland.gov.uk/publications/issue.asp?id=1&issue=12”, the lack of public information presented here certainly does not constitute a “public and wholly inclusive” debate (indeed the link for the 3^rd meeting on 29^th August 2002 does not work and there is no link at all to a 6^th meeting on 29 November 2002). 

For example, the “Note of Fourth Plenary Meeting” (7^th October 2002) stressed that “the development of a long term strategic framework for the Aquaculture Industry must be subject to an open, transparent and, above all, inclusive process” and referred to a “4^th draft of the consultation document by the end of October” but at no stage have the Executive issued a public consultation document on the aquaculture strategy and a major public conference on the strategy has never taken place.  The only reference to the consultation is cryptically contained at the end of a press release issued on 16^th January 2003 on “Location Guidelines for Fish Farms”:

“On 23 December the Executive published a draft Strategic Framework for Aquaculture, based on the work of a range of stakeholders under the direction of the Ministerial Working Group on Aquaculture, chaired by the Deputy Minister for Environment and Rural Development”: http://www.scotland.gov.uk/pages/news/2003/01/SEen295.aspx

[2]  The Salmon Farm Protest Group’s formal consultation response includes details of a phone conversation last Friday with Gordon Hart (Tel: 0131 244 6172; 0131 244 6253), part of the secretariat of the ‘Ministerial Working Group on Aquaculture’ of the Scottish Executive:  “Suspicions over the approach being adopted by the Scottish Executive were confirmed by remarks made on 17^th January 2003 by a senior Scottish Executive civil servant and Working Group spokesman that the Executive had little intention of changing the draft after the consultation process, except for a “tweak” here and there, justifying this on the grounds that the preparation of the report had constituted a de facto public consultation process. Such an approach ignores the massive weighting of the Working Group in favour of industry representatives and interests. Whatever the composition of the Working Group, the Scottish Executive’s administrative requirements for public consultation cannot simply be side-stepped by arbitrary fiat in such a blatantly undemocratic manner” (p3) 

[3] The 29-page response by the Salmon Farm Protest Group to the “Consultation Document” on ‘A Strategic Framework for Scottish Aquaculture’ is available in full on The Salmon Farm Monitor (http://www.salmonfarmmonitor.org) but includes:

“The overwhelming conclusion of the Salmon Farm Protest Group is that this document is a sham to both strategy and sustainability” (p1)

“In our detailed response below to the draft Framework, we raise 13 key flaws in the draft ‘Strategic Framework’:

1) Repeated delays envisaged for any action in the draft Framework

2) Failure of the draft Framework to propose effective regulation

3) Proposed abuse of public money for PR purposes

4) Failure of the draft Framework to adequately address the food safety issues associated with factory farmed fish

5) Failure of the draft Framework to adequately assess the environmental and public health impact of toxic and carcinogenic chemicals

6) Failure of the draft Framework to adequately assess land-based containment as a solution to escapes, wastes, mortalities and sea lice

7) Fudging of the issue of relocation of salmon farms

8) Failure to recommend a ban on salmon farms at the mouths of salmon rivers

9) The proposed compensation for pollution

10) Failure of the draft Framework to adequately assess the problem of depleted and contaminated fish feed

11) Proposed government support for GM

12) Failure to acknowledge that restocking harms wild fish

13) Failure to incorporate recent EU recommendations on aquaculture” (p1)

“While the irreplaceable natural environment of Scotland is being irreparably destroyed, along with the jobs and livelihoods that depend upon that environment, the draft Framework offers little but muddled delay and the promise of business as usual for the Scottish aquaculture industry. Instead of grasping and redressing the fundamental regulatory failure that has permitted the current sorry state of affairs, the draft Framework proposes only further studies, delays, guidelines and voluntary codes. This is an unacceptable abrogation of the responsibilities of the Scottish Executive to the people and environment of Scotland, both now and for future generations” (p1)

“The lack of public transparency surrounding the current consultation process is totally unacceptable, and renders any conclusions drawn from this consultation, and any strategy document emerging from it, fatally flawed” (p2)

“The publication of the draft strategy on 23^rd December can only serve to exacerbate the suspicion that the current process has been designed to actively discourage rather than facilitate public input” (p2)

“The production of the strategy has been anything other than open and inclusive, culminating in the disgraceful refusal to undergo a formal statutory consultation process for the draft strategy” (p4)

“Membership of the Ministerial Working Group of Aquaculture was by private invitation only, was composed predominantly of representatives of the sea cage fish farming industries and agencies with a vested interest in the promotion of sea cage fish farming, and meetings were closed to the public and no minutes were made publicly available” (p4)

“If the primary function of the draft Framework is to introduce a modern and appropriate regulatory regime for Scotland’s aquaculture industry, the document is a shambolic failure” (p7)

“The Scottish Executive still insist on procrastinating and prevaricating on the irksome issue of regulation” (p8)

“The Scottish Executive’s predilection for deregulation and its reluctance to legislate undermines the whole aquaculture strategy.  This is particularly alarming considering it freely admits that current controls “were designed for other purposes and are not wholly apt” (p9)

“Public money should not be abused by “rewarding” those salmon farmers who actually manage to comply with Codes of Practice.  Instead, penalties for those farmers guilty of non-compliance of Codes of Practice ought to be introduced” (p10)

“The draft Framework proposes to use public money to bankroll a PR campaign “designed to improve the public’s understanding of the industry” (p11)

“As well as educating the general public in how healthy dioxin contaminated and artificially coloured farmed salmon is, it seems children will not be immune from state-sponsored propaganda.  Children from the age of 5 will be indoctrinated via a ‘learning programme’ which “will promote the industry’s crucial significance to communities in fish farming areas” and at a higher level the Government will help to train the next generation of salmon farmers” (p12)

“That the Scottish Executive are loathe to criticise the quality and safety of farmed salmon is not altogether surprising given their conflict of interest: in the wake of the BBC documentary exposing dioxin contamination in farmed salmon in 2001 the Scottish Executive awarded Scottish Quality Salmon £210,000 for “communications and PR activity to raise awareness of Scottish farmed salmon in both the UK and France”. That more money is to be pumped into promoting dioxin-contaminated Scottish farmed salmon flies in the face of common sense and consumer safety” (p14)

“Allowing salmon farmers to produce more at new sites and paying compensation for relocation is the equivalent of the “polluter gets paid” principal. To consider providing financial assistance to salmon farmers who have fouled their own nest is akin to money in the back pocket and a pat on the back as a reward for polluting Scotland’s pristine coastline. Should not salmon farmers instead be paying compensation to river owners, creel fishermen, scallop farmers and other businesses that have been seriously affected by the polluting presence of such noxious neighbours? ” (p23)

“The painfully obvious conclusion that Scotland must stop farming carnivores such as salmon, trout, cod and halibut and start supporting sustainable forms of aquaculture such as shellfish farming is dismissed completely in favour of appeasing the industry with soothing rhetoric” (p24)

“If Scotland is going to have a “sustainable” aquaculture industry the Scottish Executive must promote extensive shellfish farming at the expense of the intensive farming of salmon, cod and halibut” (p26)

“The future of aquaculture in Scotland must no longer be seen to be synonymous with sea cage fish farming” (p26)

“The salmo-centric strategy document is woefully inadequate when it comes to dealing with shellfish farming. For example, that statement that “Environmentally sensitive aquaculture, particularly shellfish farming, should be encouraged” (p18) is not followed up with any recommendations or concrete commitments.  Once again, the reader is left in no doubt whatsoever that salmon farming (and now cod, halibut and haddock farming) will take precedence over sustainable and environmentally sensitive shellfish farming.  How shellfish farmers are “very much part of the Executive's strategy for the aquaculture industry”, as suggested by the Fisheries Minister in November 2001, is left to the reader’s imagination” (p27)

“The assumption that “if local planning officers ensure that zoning decisions and framework plans emerge out of a truly inclusive process, much of the dissatisfaction of local communities may disappear” is hopelessly optimistic.  Community liaison is certainly not a panacea for public protests against sea cage fish farming.  The plain truth of the matter is that many communities across Scotland do not want their pristine coastline, unpolluted bays or lochs littered by sea cages discharging untreated effluent and spreading sea lice and infectious diseases to wild fish.  No amount of public consultation, state-sponsored indoctrination in schools or industry propaganda will stop legitimate and informed public dissent” (p29)