Freshwater Lochs: Caged fish farming: EIR release

Information request and response under the Environmental Information (Scotland) Regulations 2004.


Information requested

The Scottish Salmon Strategy Task Force recommended that there should be a presumption against the siting of fish farm cages on freshwater lochs (1997 Report, Recommendation 61).

The Task Force was concerned that 'the release of nutrients from food and faeces, and the use of chemicals including antibiotics to treat disease, may pose particular problems in poorly flushed and nutrient-poor waters. The spread of disease, and escape of fish may also generate special difficulties.'

How many freshwater lochs in Scotland have fish cages?

How many individual cages exist?

What is the permitted biomass for these sites, distinguishing between trout and salmon?

What research has the Government, or its agencies, undertaken to assess the impact of the operation of these cages on the ecosystems of freshwater lochs?

Response

Your questions are answered separately below in the order above.

  • How many freshwater lochs in Scotland have fish cages?

Thirty freshwater lochs in Scotland currently have fish cages.

A spreadsheet is enclosed that provides a response to your question. See “Item 1”.
Tab 1: a list of all active freshwater aquaculture sites (April 2024). See columns A to D for the details of all sites in the thirty freshwater lochs.
Tab 2: provides a list of fisheries that have freshwater cages within the waters of the fishery.

  • How many individual cages exist?

While our aim is to provide information whenever possible, in this instance the Scottish Government does not have the information you have requested. Therefore we are refusing this part of your request under the exception at regulation 10(4)(a) of the EIRs. The reasons why that exception applies are explained below. 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 because it is not possible for the Marine Directorate to provide the exact numbers of cages per site. Whilst we hold some information relating to the number of cages on site, including details of the number of cages present at the point of inspection and authorisation (see detail below), we recognise that the number of fish farm cages is variable and can be subject regular change over time. 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 how many individual
cages exist, clearly we cannot provide information which we do not hold.

Additional information provided out with the EIRs
Under regulation 9 of the EIRs (our duty to provide advice and assistance) we can advise that, although it is not possible to provide the exact number of cages per site, we can provide the maximum authorised number of cages per each site – see Tab 1 of “Item 1” enclosed. The data in column E of tab 1 provides the number of authorised cages (420) in freshwater lochs at the time these data were extracted from the Marine Directorates aquaculture database. Information relating to the inspection of fish farm sites associated with aquatic animal disease surveillance is routinely published as part of a proactive publication plan. This will include the details of the number of cages present and the number of cages stocked at the point of the inspection - https://www.gov.scot/collections/publication-of-fish-health-inspectorate-information/. As acknowledged above, this number can be subject to regular change.

  • What is the permitted biomass for these sites, distinguishing between trout and salmon?

While our aim is to provide information whenever possible, in this instance the Scottish Government does not have this information that you have requested. Therefore, we are refusing this part of your request under the exception at regulation 10(4)(a) of the EIRs. The reasons why that exception applies are explained below. 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 hold. 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 the permitted biomass of trout and salmon farms, clearly we cannot provide information which we do not hold.

However, biomass permissions are detailed on the Controlled Activities Regulations (CAR) consents granted by the Scottish Environment Protection Agency (SEPA), which can be contacted directly at: Access to information | Beta | SEPA | Scottish Environment Protection Agency . The following website has a map of all active aquaculture sites, which may also be of interest to you: Scotland's Aquaculture | Map.

  • What research has the government, or its agencies, undertaken to assess the impact of the operation of these cages on the ecosystems of freshwater lochs?

The Scottish Government has commissioned the Scottish Association for Marine Science (SAMS) on a research project relating to NewDepomod, an updated computer programme looking at impacts of fish farms on the sea bed, which was released in 2018. Details of this project can be found at: DEPOMOD — Scottish Association for Marine Science, Oban UK (sams.ac.uk).

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.

FOI 202400406319 - Information Released - Annex

Contact

Please quote the FOI reference
Central Enquiry Unit
Email: ceu@gov.scot
Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road
Edinburgh
EH1 3DG

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