Is organic salmon farming a real operation, other than bearing a label to show it is sanctioned by the Soil Association whose standards we find questionable? N.B. Incredibly, the RSPCA has awarded caged ‘battery’ salmon ‘Freedom Food’ status, so anything is possible.

May we have any confidence that this farm will not first fail to maintain its organic status (as allowed for in this application) and then transfer its business to a larger operator?

The people in North Skye have been encouraged to support this fish farm project because it has been advertised as: ‘organic’. They will not be pleased if, after a while, the farm converts to non-organic, but that is the published contingency plan. The more one investigates, the more likely that looks.

In the context of this application, what does ‘organic’ mean? Since the applicant intends to use net-cages, the word seems to have little to do with the mitigation of pollution, other than fish stocking density is less than in conventional net-cage farms, so waste outputs will be marginally reduced. In order to make fair comment, I would like to determine how much less waste will be released into the sea untreated by this proposed farm. However, I cannot find the Autodepomod Modelling Report among the submitted documents, only allusion to that exercise in the Environment Statement (mostly part 1b).

From what I have read about organic farmed salmon it seems to be little different in production from conventional mass-production salmon farming. Since the salmon are kept in nets in both systems, the same pollution outputs and the same pest and disease threats apply to either and both. How does this applicant intend to control sea lice, amoebic gill disease, the various forms of salmon leukaemia etc.? For most of these problems, chemical treatments would seem to be unavoidable, yet one would expect organic salmon production to eschew such methodologies.

Recently revised Soil Association aquaculture standards (2016) include:

"A prohibition on the use of organophosphate or avermectin-based [e.g. emamectin benzoate] veterinary medicines due to their detrimental effect on the aquatic environment, including sediment-dwelling organisms."[1]

One might express one’s amazement that the SA would ever have permitted the use of organophosphate or avermectin-based pesticides[2] and become suspicious that SA regulations for organic salmon are not as demanding as those with which we have become familiar in terrestrial food production. How does the applicant intend to control sea lice, invasion by which is inevitable? Will they be applying chemical treatments? Are ‘organic’ chemical treatments available? If so, do they work? I doubt it, or the rest of the industry would be eagerly using them.

The applicant could claim that biological sea louse control will be employed instead of chemical treatment. That would mean cleaner fish (wrasse and/or lumpsucker), which are not available from farmed supplies, but are being harvested live in vast numbers from the wild all around the UK coast. That fishery has simply emerged recently in response to demand. Its impacts remain unresearched, and therefore unknown, and wrasse trapping continues without regulation.

Disastrous ecological consequences of intensive wrasse trapping have already been reported: e.g. increased numbers of adult octopus, the eggs of which are part of the wrasse diet, appearing on beaches and stealing the catch from langoustine fishermen’s creels. Until they can be farmed, cleaner fish cannot be a valid replacement for chemical sea louse control, which in itself is highly undesirable. Sea lice generate a monumental dilemma for salmon aquaculture, conventional or organic.

I note, from the Environmental Statement part 1b:

“OSH [Organic Sea Harvest Ltd.] intends to apply to SEPA [Scottish Environment Protection Agency] for CAR [Controlled Activities Regulations] licences for the use sea lice medicines on the site, these treatments and the methods of application are described in more detail in Section 6.2. It is intended that treatments be limited in accordance with Organic Standards but that licences are in place to allow for additional treatments if required to switch to conventional farming. Modelling has been carried out for the infeed treatment, Slice, with the active ingredient Emmamectin [sic] Benzoate (EMBZ), using the AutoDepomod model.”

“SEPA model BathAuto was used to model the inputs of the bath treatments Azamethiphos, Cypermethrin and Deltamethrin in accordance with the methodologies required by SEPA.”

Although the stocking density is to be 8 kg/m3,[3] less than the SA maximum of 10 kg/m3, the maximum claimed stocked biomass is given as 2,500 tonnes. That is the maximum for a conventional farm of the same size.

So, it would seem preparation has already been made for conversion from organic to conventional methods of sea louse control. Invasion of the farm by sea lice are not just possible, but highly probable. There are no organic sea louse treatments, so the use of chemicals or bad-practice biological control will be essential if the farm is to succeed at all. In the long (or shorter) run, this farm I most unlikely to maintain its organic status.

It is surely noteworthy that, even if the applicant intends initially to farm salmon according to organic standards: “It is recognised that if the farm breaches the Organic Standard there may be the need to farm under conventional farming methods.”[4] That is a significant let-out cause, likely to be overlooked by the public, impressed as they are by the consistently publicised promise of an ‘organic’ fish farm throughout the preparation of this planning application.

Should we, for ‘if’ in the above quotation read ‘when’?

It has become a quite common strategy for a small aquaculture company to set up a fish farm before it is taken over by one of the big corporations, e.g. Loch Ainort, Skye: Ferguson Transport to Marine Harvest. May we have any confidence that OSH farms will not first fail to maintain its organic status and later transfer to a larger operator? Read on ... ...

Seattle Times, 7 Dec. 2017 “Cooke [Aquaculture] purchased its operation from Icicle Seafoods last year. The company’s business model is to grow by expansion, and Cooke, one of the largest aquaculture companies in the world, based in New Brunswick, Canada, has stated it would like to improve its farms here, and expand them.”

James Merryweather
Extract from his comment letters

[1] https://www.soilassociation.org/certification/certification-updates/2016/january/21/new-aquaculture-standards-to-be-launched/
Also in full:  https://www.soilassociation.org/what-we-do/organic-standards/soil-association-organic-standards/farming-growing-standards/ click on 'aquaculture'
[2] ‘veterinary medicines’ is a mendaciously euphemistic descriptor for two groups of severely toxic chemical compounds.
[3] Application Form of these applications p. 4.
[4] ENVIRONMENTAL STATEMENT PART 1B of these applications.

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