Closed Containment development: EIR release

Information requested

You asked for the following information since the REC report was published in November 2018:
1. Incentives offered by the Scottish Government on closed containment development
2. Academia and other agencies’endeavours, incentives made, and initiatives taken
3. Scottish Aquaculture Innovation Centre (SAIC) work done on closed containment
4. Which parties officials have met to discuss closed containment
5. Who is currently showing an interest in developing such technology in Scotland
6. Examples of companies currently looking at alternative approaches in Scotland

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.

While our aim is to provide information where ever possible, in this instance we are unable to provide some of the information you have requested because exceptions under Regulations 6(1) (b) and 10 (4) (a) of the EIRs apply to that information. The reasons why those exceptions apply are explained in Annex A.

1. The Scottish Government is technology neutral. However we are very supportive of innovation which will improve fish health. Such technological innovations include construction of stronger and more durable cages for high impact environments, allowing farms to move offshore into deeper and more flushed waters, or could include the exploration of closed and semi enclosed systems. In 2019 we funded a project to look at technical considerations of closed containment sea production in Scotland through the Scottish Aquaculture Research Forum.
Project report: http://www.sarf.org.uk/SARFSP011.pdf

2. We recommend that you contact specific academia and agencies to obtain this information.
However, you may find the following publicly available documents and websites of interest:
· SAIC (https://www.scottishaquaculture.com/projects/
· Scottish Aquaculture Research Forum http://www.sarf.org.uk/SARFSP011.pdf
· Stirling University http://www.susaquastirling.net/blog/2019/5/30/study-on-closed-containmentsystems-for-nursery-rearing-in-scotland-published
· Highlands and Islands Enterprise: https://www.hie.co.uk/media/6167/ras-study-2018-update.pdf
· Nordic Network on Recirculating Aquaculture Systems https://www.nordicras.net/about 
https://www.nordicras.net/Workshops/Workshop-2019

3. The Scottish Government does not hold this information – this can be obtained from SAIC by contacting it by phone on 01786 278318, or email at info@scottishaquaculture.com.

4. The Scottish Government does not hold this information.

5 & 6. Marine Scotland Science (MSS) is aware of several initiatives which are either exploring or employing closed containment measures across the range of sectors within Scottish aquaculture. We do not hold definitive records as such, but where such initiatives have been implemented or are proposed then our knowledge has been obtained through either the inspection activity conducted in accordance with Marine Scotland’s aquatic animal health surveillance programme, or the authorisation and planning processes under which Marine Scotland’s Fish Health Inspectorate performs important roles.

Some specific examples where this practice has been implemented include a number of Recirculating Aquaculture Systems (RAS):
· Whiteleg shrimp production by Great British Prawns Ltd using land based facilities with artificial seawater
· Freshwater Atlantic salmon production by a number of companies including, but not limited to, Mowi Scotland Ltd, Scottish Sea Farms Ltd, The Scottish Salmon Company and Cooke Aquaculture (Freshwater) Ltd
· Tilapia production by Forth Foods Ltd, Rainbow trout production by The Aquaponics Garden Ltd, and African catfish production by Saheliya in freshwater land based aquaponics facilities
· European lobster production by Todd Fisheries Technology and Orkney Shellfish Hatchery Ltd and Native oyster production by Orkney Shellfish Hatchery Ltd in land based facilities with pump ashore seawater
· Marine Atlantic salmon production in land based facilities using artificial seawater. Facilities in Machrihanish were previously operated by Niri Scotland Ltd but are now under ownership of EFC Scotland Ltd, although at present this facility is not producing salmon 

Marine Scotland is also aware of a number of potential plans for closed containment aquaculture facilities within Scotland. We have been made aware of these either through the authorisation process undertaken in accordance with the requirements of The Aquatic Animal Health (Scotland) Regulations 2009 and/or the planning process under the Town and County Planning (Scotland) Act 1997 (as amended), for which Marine Scotland Science acts as a statutory consultee. Examples include · Freshwater and marine Atlantic salmon production - FishFrom Ltd using RAS technology
· Marine Atlantic salmon production - Simply Blue Aquaculture Ltd
· Freshwater Scottish caviar production - Fynest Caviar Company Ltd
The websites of these companies have further information.

A number of initiatives are taking place in relation to closed containment within the marine production phase of Atlantic salmon. Much of this work is being conducted outwith Scotland, but often by companies who also farm within Scotland.

It is perceived that, should those initiatives prove to be technically and financially viable, delivering a reduction in environmental impact, then such systems may become more widely implemented within the marine Atlantic salmon farming sector. Development will of course be subject to appropriate planning permission prior to operation.
Presently, the major investment in Scotland relates to the freshwater phase of Atlantic salmon production. Other ‘alternative approaches’ include changes within the production cycle – producing larger fish within freshwater facilities to reduce the length of time farmed fish are present within the marine environment.

ANNEX A
REASONS FOR NOT PROVIDING INFORMATION

Regulation 10(4) (a)
Under the terms of the exception at regulation 10(4) (a) of the EIRs (information not held), the Scottish Government is not required to provide information which it does not have. The Scottish Government does not have the information you have requested at question 3 above because the Scottish Government is not responsible for the subject, and SAIC holds the information you are looking for.  The Scottish Government does not have the information you have requested at question 4 above because it is not recorded or stored in any form.

This exception 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 exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about parties meeting to discuss closed containment, or SAIC work done on closed containment, clearly we cannot provide information which we do not hold.

Regulation 6(1) (b)
Under the terms of the exception at regulation 6(1) (b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format. If you do not have internet access to obtain this information from the links to websites listed above, please contact me again and I will send you a paper copy. 
This exception 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 exception. We have found that, on balance, the public interest lies in favour of upholding the exception, as the information is already publicly available.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.