Selected Excerpts from the Salmon Farm Protest Group’s formal response to the Scottish Executive’s draft ‘Strategic Framework for Scottish Aquaculture’ (or, download the full response in word format)

“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)