Salmon farming net washing: EIR release

Information requested

Information in relation to salmon farming net washing. I have responded to each of your questions in the section which follows.

1. What regulations cover “net washing”?

2. What is the environmental impact of “net washing”?

3. Are environmental impact assessments being carried out?

4. What preventions are in place to safeguard wild fish and the marine environment from discharges from “net washing”, including disease, lice, algae, pathogens, viruses, jellyfish etc?

5. I also wish to know what cost benefit analysis has been carried out with regards to the immediate benefit to the community and Scotland in general?

6. Specifically: How will the performance of these grants be measured?

Response

As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

In preparing our response we have considered net washing operations that take place both on fish farms and at net washing stations.

Net washing on farms generally involves the mechanical cleaning of the nets while they are still attached to the cages, in order to remove build-up of algae and other fouling organisms, such as hydroids and anemones.

Net washing stations are land-based facilities which receive nets from farms for cleaning and repair before they are reused at farms. Cleaning at these stations may involve use of detergents and disinfectants.

1. What regulations cover “net washing”?

There are no regulations that specifically govern all net washing operations, however the following may apply depending on where and how net washing takes place:

The Town and Country Planning (Scotland) Act 1997 if net washing facilities have required planning permission from a local authority the planning consent may include conditions relating to the operation of the facility.

The Water Environment (Controlled Activities) (Scotland) Regulations 2011 (CAR) regulate any net washing operations that involve discharges into the water environment.

The Waste Management (Scotland) Regulations 2011 which is dependant on the volumes, types of material, proposed treatment and storage relating to waste generated at the site.

Aquatic Animal Health (Scotland) Regulations 2009 would apply in any movement and handling/washing of fish farm nets in a situation where movement controls for a listed disease were in place at the fish farm site of origin.

This would ensure that the process of equipment transfer, and handling would be done in a bio-secure manner to minimise the risk of spread of the listed disease.

Any permission granted to the Aquaculture Production Business operating the farm site to allow the transfer and handling of the nets would be done under the supervision of the Fish Health Inspectorate (FHI), to ensure that the conditions of any permission granted were being met.

You may also be interested to note that the FHI produce a disinfection guide which sets out best practice at fish farms and related sites to minimise and prevent the spread of disease. The guide includes procedures for the cleaning and disinfection of equipment including cages and nets.

2. What is the environmental impact of “net washing”?

As is the case for any industrial activity, net washing facilities have the potential to have an impact on the environment, whether that is from a discharge of effluent (spent net washing liquid) or the keeping, storing, or processing of waste generated at the site.

The impact would be determined by the nature of the activity, the processes carried out as part of the activity and the location.

Any impact in terms of emissions to the environment would be assessed by the Scottish Environment Protection Agency (SEPA) upon receipt of an application (where appropriate). 

This assessment would take account of treatment processes, likely constituents of any discharge, maximum rate and total volume of effluent discharged, sensitive receptors, and the environmental capacity in the receiving environment. Where an authorisation is granted, any such authorisation would contain conditions appropriate to protect the environment.

3. Are environmental impact assessments being carried out?

Please see above for information on SEPA’s role in relation to environmental risk assessment.

Developments of a type listed in Schedule 2 to the 2017 EIA Regulations will require an Environmental Impact Assessment (EIA) if they are likely to have a significant effect on the environment, due to factors such as their size, nature or location. An EIA may be required for planning or marine licence applications, which certain net washing operations may require.

4. What preventions are in place to safeguard wild fish and the marine environment from discharges from “net washing”, including disease, lice, algae, pathogens, viruses, jellyfish etc?

The response to the above should not be limited to this new venture but should cover all “net washing” as currently practised in-situ or otherwise.

Fish diseases are controlled by the FHI under the Aquatic Animal Health (Scotland) Regulations 2009. Please see response to Question 1 above.

Any discharges to the water environment are required to be authorised under CAR by SEPA. As part of that determination a risk assessment is undertaken and where appropriate, site-specific conditions are included in a permit to ensure that the activity will pose no significant risk to the environment. Once a site is given an authorisation a risk-based audit programme is then established to ensure that the site continues to operate in line with the authorisation granted.

5. I also wish to know what cost benefit analysis has been carried out with regards to the immediate benefit to the community and Scotland in general?

Given the volume of Marine Fund Scotland applications received each year, we do not undertake a cost benefit analysis for each application. However, business accounts or a project’s profit and loss forecasts [for projects over £100,000 or larger projects] are assessed to establish a business’s rate of return and need for public assistance for the project to proceed.

Applicants must identify value for money in their applications, highlighting the benefits which the grant aid supporting the project will deliver against the Blue Economy outcomes.

Each application goes through an outcomes assessment process against five distinct outcomes. One of these outcomes aims to capture benefits to wider coastal communities, and includes the following criteria:

• deliver measurable social benefits for communities in Scotland in areas where commercial fish or aquaculture activities are carried out, in particular where people are experiencing poverty or disadvantage across different aspects of their lives, 
• and where relevant, support community-led local development for the purposes of the economic development or social improvement of areas where commercial fish or aquaculture activities are carried out. 

The assessment of the above and other outcomes is therefore used in conjunction with information from a business’s accounts or, profit and loss statements, and overall risk (e.g. grant rate) to determine whether a project may get funded.

More Information about eligibility, outcomes and the assessment process can be found in the Marine Fund guidance notes.

6. Specifically: How will the performance of these grants be measured?

All projects must provide progress reports when claiming grant instalments. After the applicant has made their final grant claim, they are required to submit annual post-project monitoring updates for up to a further five years.

This is to monitor any lasting impacts beyond the period of the grant. The timescale is set during the project assessment process, and usually larger projects will have longer post-project monitoring timescales.

Through these post-project monitoring reports, officials and analysts from Marine Directorate can assess the performance of the project and its ability to meet the stated outcomes.

We also monitor other variables which depend on the type of project. These are supplied by the applicant and could include fuel or energy use, output, revenue, profit, employment, and types of species or products produced.

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