Aquaculture and Fisheries Consultation Analysis - Summary Report

10 Other Comments and Issues Raised

10.1 Many respondents provided additional comments on wider issues relating to aquaculture and freshwater fisheries in their responses. In summary, these included:

• Disagreement with information in and/or conclusions of the SEA.
• Support for the recommendations of the Mixed Stock Salmon Fisheries Working Group.
• Support for changes in farming practices (i.e. closed containment and production innovations).
• Suggestions for further action on escapes (i.e. requirement for remedial action by operators, genetic sterilisation, stopping movement of cages into open waters).
• Support for presumption against or powers to limit fish farm developments in areas of importance to wild salmonids.
• Suggestion for the provision of additional scope for DSFBs (i.e. include all species of trout, notification of developments impacting on river systems, include as a consultee for planning permission applications).
• Suggestion for the adoption of an ecosystem approach for fisheries management.
• Suggesting further consultation and collaboration on the operation of MAs, particularly regarding salmon farming practices and sea-lice treatments.
• Several suggestions for reviewing or changing weekly close times for net fishing and correcting the current imbalance in financial contributions from net fisheries to fishery management.
• Concern that the proposals in the Consultation Document may adversely impact the coarse angling and aquaculture industries.
• Support for changing the use of Protection Orders ( POs) where risk to native species or the environment can be demonstrated.
• Recommendation for a review of the Scottish Aquaculture CoGP.
• Support for inclusion on a range of additional provisions (i.e. pollution, seal shooting, acoustic deterrent devices, locational planning issues amongst others).