Registry Department
SEPA
Graesser House
Fodderty Way
Dingwall IV15 9XB
4 June 2019
CAR Application – Dawnfresh Farming Limited CAR/L/1178003
Ardentinny Community Council wishes to express its opposition to this proposal.
We do so in the belief that the Dawnfresh proposal is ill-judged as to its location and design, failing to reflect current scientific evidence concerning sustainable aquaculture as recognised by SEPA.
We note, in particular, that SEPA has recently completed a period of research and consultation that has lead it to conclude that the existing regulatory approach is outdated and does not “adequately protect marine life” and that accordingly SEPA will be introducing
“a revised regulatory regime that will strengthen the protection of the marine environment for the people of Scotland” in June 2019[1].
It seems particularly unfortunate that the Dawnfresh proposal has been submitted shortly before these new regulations come into force.
We welcome the fact that the SEPA statement continues:
“In practice, we anticipate this [new regulatory framework] will lead to fewer fish farms in shallower, slow-flowing waters and more fish farms in deeper and faster-flowing waters. We also anticipate it will encourage the adoption of new technologies such as partial and full containment to capture organic waste and any remaining medical residues. SEPA has seen some industry operators successfully developing new approaches such as non-chemical ways of managing fish health. Our new regime will support these encouraging developments.”
However, the Dawnfresh proposal meets none of these criteria, being in shallower, slower-flowing waters, far from the open sea and located in a fragile and already damaged environment. Furthermore it does not address the issues raised in the new Regulatory Framework[2] : it does not mention any of the new approaches that SEPA has recommended, such as non-medicinal farming using wrasse, full or partial containment or enhanced fallowing[3].
It relies, therefore, purely on older, outdated methods.
It is to be welcomed that the Dawnfresh Non-Technical Summary explicitly states that in-food medicine is not being proposed, given the recent evidence concerning Emamectin benzoate[4].
However, this approach means that Sea Lice control will rely entirely on the use of bath treatments, using Cypermethrin, Deltamethrin and Azamethiphos, all of which pose a serious risk to the marine environment if used in excessive dose.
For instance the European Agency for the Evaluation of Medicinal Products states that Azamethiphos has a “low therapeutic margin of safety”[5] and SEPA has stated that “ it is possible that all uses will eventually be phased out through European legislation”[6].
With regard to Deltamethrin, we are concerned that there is evidence that the effects may be felt well away from Fish Farm itself, as Ernst et al (2014) found mortality and paralysis effects on amphipods up to 350m from cages. This is the approximate distance from the Fish Farm to the beach at Ardenfield in Ardentinny Beach, a popular recreational area.[7]
We note that Cypermethrin is a priority substance for action under the Water Framework Directive.[8]
Recent studies have confirmed that Sea Lice are increasingly developing resistance to such treatments[9]. This problem is exacerbated by the limited number of treament chemicals available and so is likely to become more pronounced given that in-feed treatment is not proposed by Dawnfresh.
If resistance does develop (or develops further, if Sea Lice in Loch Long have already been exposed to these treatments in other facilities) then it is possible that maximum dosage will be insufficient to contain Sea Lice infestation. This will result not only in high mortality to dawnfresh stock, but also to wild Salmonids in the Loch.
Further, we are concerned about the possibility of excessive doses being given, in that SEPA reports that a significant proportion of the 19% of non-compliance reported in 2017 involved “quantities of medicines used exceeding that permitted”[10].
The Community Council is also concerned that this proposal has not considered the treatment for other diseases that Rainbow Trout may be prone to, given that these include those “caused by bacteria (bacterial gill disease, furunculosis, bacterial kidney disease, fin rot), parasites (Gyrodactylus, Chilodonella, Trichodina, Epistylis, Trichophrya, Ichthyopthirius, Ichtyobodo, proliferative kidney disease, amoebic gill infestation, Coleps), fungi (Saprolegnia), and viruses (infectious pancreatic necrosis, viral hemorrhagic septicemia, and infectious hematopoietic necrosis)”(Noble and Summerfelt 1996)[11]. No mention is made in this proposal on how such infections would be dealt with and what treatments might be used. In particular, the proposal fails to mention what antiobiotics are intended to be used. However, the Farm Antibiotics report for 2017 stated that usage data for 70% of the trout sector showed mean antibiotic usage levels of 19mg/kg for trout[12].
The Community Council is also concerned about the apparently casual approach of this proposal (for instance the error in Form C Section 2, 2.1) and the absence of any thorough study into the ecology and local conditions pertaining to this site.
The Community Council’s objection to the proposal is reflected in the community’s overwhelming opposition. A survey of residents, carried out by the Community Council and which had a 90% response rate, found that 73% opposed the Dawnfresh application.
The Community Council believes that this proposal falls far short of SEPA criteria. We request, therefore, that SEPA rejects this application or, at the very least, delays approval until it can be considered fully under the new, improved regulations that have been designed to enhance environmental protection, reflecting improved technology and scientific understanding.
Yours sincerely
Rob Bray Ph.D.
Neil Robinson, Convenor
on behalf of Ardentinny Community Council
[1] SEPA https://www.sepa.org.uk/regulations/water/aquaculture/bbc-panorama-response/ accessed 26/5/2019
[2] SEPA 2018 Fish Aquaculture Sector Plan Annexe 1
[3] SEPA 2018 Fish Aquaculture Sector Plan p 19
[4] WAT-PS-17-03: INTERIM POSITION STATEMENT FOR PROTECTING THE WATER ENVIRONMENT UNTIL SUCH TIME AS A DIRECTION IS ISSUED ON AN EQS IN RELATION TO EMAMECTIN BENZOATE IN FINFISH FARM REGULATION
[5] European Agency for the Evaluation of Medicinal Products 1999 EMEA/MRL/527/98-Final
[6] http://apps.sepa.org.uk/spripa/Pages/SubstanceInformation.aspx?pid=169 Accessed 30 May 2019
[7] Ernst, W., Doe, K., Cook, A., Burridge, L., Lalonde, B., Jackman, P., … & Page, F. (2014). Dispersion and toxicity to non-target crustaceans of azamethiphos and deltamethrin after sea lice treatments on farmed salmon, Salmo salar. Aquaculture, 424, 104-112.
[8] SEPA Scottish Pollutant Release Inventory Cypermethrin http://apps.sepa.org.uk/spripa/Pages/SubstanceInformation.aspx?pid=135 Accessed 30 May 2019
[9] For instance: Kaur, K., Jansen, P. A., Aspehaug, V. T., & Horsberg, T. E. (2016). Phe362Tyr in AChE: A major factor responsible for azamethiphos resistance in Lepeophtheirus salmonis in Norway. PloS one, 11(2), e0149264.
[10] SEPA 2018 Fish Aquaculture Sector Plan p 19
[11] Noble, A. C., & Summerfelt, S. T. (1996). Diseases encountered in rainbow trout cultured in recirculating systems. Annual Review of Fish Diseases, 6, 65-92.
[12] Farm Antibiotics https://www.farmantibiotics.org/media-news-updates/progress-by-sector/fish-production/ Accessed. 30 May 2019