LOCATION AND RELOCATION WORKING GROUP
NOTE OF FIFTH MEETING OF LOCATION AND RELOCATION WORKING GROUP, PITLOCHRY, 15 November 2004
Present:
Laura Bateson, SE LINK
Gordon Brown, SEERAD, Chair
Dr Jean Balfour, Scottish Quality Salmon (SQS)
Dr Malcolm Beveridge, Fisheries Research Service (FRS)
Dr Kenny Black, Scottish Association for Marine Science (SAMS)
Stuart Cannon, British Marine Finfish Association (BMFA)
Dr Trevor Hastings, Fisheries Research Service (FRS)
David Hay, Fisheries Research Service (FRS)
Ian Pritchard, The Crown Estate
Professor Randolph Richards, University of Stirling
Andrew Wallace, Association of Salmon Fishery Boards (ASFB)
Colin Wishart, CoSLA
Dominic Counsell, Scottish Natural Heritage (SNH)
Graeme Dear, Scottish Quality Salmon (SQS)
Secretariat:
Phil Gilmour, SEERAD
Alistair Prior, SEERAD
Andy Rosie, Scottish Environment Protection Agency (SEPA)
1. The Chair welcomed everyone to the meeting and introduced Laura Bateson of Scottish Environment Link. The chair informed the group about the change in Minister and indicated that Executive is about to announce the secondment of two individuals from Industry for a period of 12 months to deal with regulatory issues and the PA commitment on streamlining regulation. The Chair reassured the group that the secondees will be SE employees and so will be expected to take an objective and even-handed approach to the task.
2. Apologies for absence were received from; Doug Macleod, ASSG; Ian Sutherland, HIE; Mark Bilsby, AWCFT; David Ferguson, SEDD; Steve Dowell, SEDD; Hansen Black, SFF; Douglas Sinclair SEPA; Dr Amanda Currie, SEERAD; Alan Youngston, FRS
3. The group were asked to note that the minute of the last meeting had been agreed by correspondence in July and placed on the Executive's website after August 2004.
4. The group then discussed matters arising from the previous meeting.
AZE's/Farm sizes
SEPA updated the group on progress with the new AZE Model and related consultation paper - hopefully to be published late Nov/early December. A 6-week consultation period is proposed. By late February the new model should be finalised.
Industry representatives asked about the SEPA paper on site consolidation. The group was invited to note industry was concerned about certain elements of the paper, particularly where medicine EQSs may restrict biomass even if the scope for larger biomass is increased using the new model. Univ. of Stirling - asked if efficacy of treating Sealice had been taken into account in the proposed limiting factor approach bearing in mind possible benefits of consolidating production at one large site. SEPA explained that a limiting factor approach will identify the most sensitive environmental driver and the consent will be aligned to take account of this, however, the paper was prepared to stimulate debate on these issues, and SEPA would be happy to receive constructive comments on its proposals. (Action: All)
Farm Sizes
Industry representatives informed the group that farms must be more competitive if the industry is to survive. FRS informed the group that farm sizes was to be discussed at the next Aquaculture Health Joint Working Group (AHJWG) meeting on 7 December 2004 and agreed to produce a paper of that groups conclusions in advance of the next LRWG meeting. (Action: FRS)
SNH/CoSLA presented its paper, which went wider than visual impacts and included locational issues. SNH felt that it could feed into moves towards a criteria based approach to location/relocation and the group agreed that comments should be made to CoSLA by 30 November. (Action: All) CoSLA agreed to revise the paper in advance of the next meeting. (Action: CoSLA)
Industry Code of Practice
SQS explained that an advanced draft has been prepared and was back with Industry for final comments. The draft would then be issued for consultation, which would include the opportunity for bilateral presentations/discussions with industry.
Regulatory Burden
The Chair invited the group to note the SEERAD paper which summarised the main points arising from a recent meeting of regulators to discuss reducing the regulatory burden of aquaculture.
The group were also informed that two industry secondees to the Scottish Executive (See Para 1) would be working on this issue over the next 12 months. This will take forward the Ministerial commitment to reduce the number of bodies involved in regulating and controlling the aquaculture industry.
5. The Sub-group, drawn from the industry and wild fish interests, updated the group about relocation "sites of interest". Association of Salmon Fisheries Boards outlined the recommendations of the subgroup's paper, which were;
• Recommendation 1 - the relocation pilot should be progressed by the Executive;
• Recommendation 2 - advice from SEPA on AZEs should made available as soon as possible;
• Recommendation 3 - any relocation, where single class management exists must comply with existing management practice in the area;
• Recommendation 4 - a mechanism should be adopted to test relocation processes to establish what for potential there is for progress and what constraints might limit the process;
• Recommendation 5 - FRS modelling on sea-lice dispersion should be developed into a useable and cost effective technique to develop criteria for relocation of fish farms where there are wild fish issues;
• Recommendation 6 - The work of the subgroup should be cross-referenced with other lists of sites which may be being developed;
• Recommendation 7 - the work of the subgroup should be considered as now largely completed, other than as a reference point and advice in further discussions.
It was agreed that the identity of the sites of interest should, for the meantime, remain confidential due to the commercial and employment sensitivities involved. The group was invited to think further about how it deals with such sites in the future. The list of sites of interest was left with SEERAD to consider the next steps and further advice would be offered at the next LRWG meeting.
6. The group discussed the first recommendation of the subgroup, the relocation pilot and considered how the pilot might be taken forward. SEERAD agreed to arrange a meeting between the company and statutory regulators, before the end of the year. SEERAD will report again to the LRWG as things progress. Action: SEERAD
7. SNH outlined its paper on relocation. SNH has a list of sites over which natural heritage sensitivities have been tentatively identified (in the absence of much information) and has had some dialogue with members of the industry/wild fish subgroup. However, SNH did not identify any sites that it feels, on the basis of current knowledge, urgently need to be relocated from a natural heritage perspective. It was pointed out by industry that local SNH staff had attended meetings with the subgroup.
8. The group then went through the rest of the recommendations outlined in the subgroup's paper:
• Recommendation 2 -SEPA had outlined the AZE issue earlier.
• Recommendation 3 - The group agreed.
• Recommendation 4 - The group agreed that the mechanism for wider relocation should be based on the outcome of the pilot exercise.
• Recommendation 5 - SEERAD outlined the work that they consider could be done to underpin relocation, i.e. benefits of relocation. SQS suggested that sealice dispersion is a management issue for industry. FRS suggested that that this recommendation was looking for FRS to work on a criteria based approach to sea lice dispersal. ASFB said that the subgroup should give the FRS a better steer. FRS will respond to this recommendation alongside SEERAD and report back to the LRWG. Action: FRS, SEERAD.
• Recommendation 6 - the group agreed, and suggested that this should be linked to actions stemming from recommendation 4. CE suggested that the list should be prioritised. Confidentially issues are outstanding.
• Recommendation 7 - The group agreed.
9. The discussion then moved to confidentiality issues, particularly in relation to the status of sub group paper, and others. It was agreed that due to commercial sensitivities the list of "sites of interest" would not be made publicly available at this time. The sites cited in the text as confidential could be made available to the LRWG subject to the agreement of the companies concerned, the sub group agreed to pursue this. Action: Subgroup SNH was also invited to consider whether any part of its existing list could be made available to LRWG. Action: SNH
10. The CE suggested that the sub-group should identify sites of interest in Orkney and Shetland. The subgroup agreed. Action: Subgroup
11. SEERAD outlined how Strategic Environmental Assessment (SEA) might be applied to any relocation 'framework'. SEA will facilitate public consultation, and identify pros and cons of relocation. SEERAD reiterated that SEA will apply to the principles of the relocation 'plan' rather than to individual sites. SEERAD also updated the group on SARF outputs relating to location/relocation.
12. The group agreed to postpone a further discussion about locational criteria, as the meeting was running late, until the next meeting. ASFB suggested that a sub group look at this issue. SNH were invited to lead, and agreed to action. Action SNH, SE LINK and others
13. The group provisionally agreed to hold the next meeting, at the FRS Freshwater Laboratory at 11am on 17 March. SEERAD agreed to canvass members for agreement. Action: SEERAD