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Archived: 01 November 2017 15:54:22 From: orkneyfisheries Sent: 30 October 2017 09:14:32 To: Registry Dingwall Subject: CAR/ L/1157275 Importance: Normal

Dear Ms Eastwood, CAR/ L/ 1157275

I received your letter of 13 October in relation to a marine cage fish farm at St Margaret’ s hope Orkney and Hunda North Orkney. As an Association we have been very concerned over the expansion of fish farming and human inputs over the last 10 years in particular within the enclosed water body of Scapa Flow.

We are concerned in particular that the licensing of chematheraputants ignore the effects on the developmental stages of commercial crustacean . In essence we believe that the licensing legislation is not robust enough to prevent detrimental effects on the larval, moulting, spawning and spatting stages of commercial species. Please see attached. Although the attached refers to West Glimps Holm we believe the concerns equally apply to any proposed farm in this area of Scapa Flow and would wish the contents to be considered in relation to CAR/ L/ 1157275.

Rgs

Fiona Matheson SEcretary Orkney Fisheries Association.

2017file:///C:/Users/ karen. eastwood/ AppData/ Local/ Temp/ Low/ ss_ 333d_ pdf_html/ ss_ 333... 01/11/ 4 Ferry Terminal Buildings, Kirkwall Pier, Kirkwall KW15 1HU Tel 01856871818 email orkneyfisheries@btconnect. com mobile 0772 503 9183 / 01856871818

30.8.17

17/ 343/ MAR West Glimps holm

OFA note that currently 8 salmon aquaculture fish farms are licensed for operation within Scapa Flow.

23 Salmon fish farms are in operation throughout Scapa Flow and the North Isles of Orkney.

Two fish farm companies operate within Orkney Scottish Seafarms Ltd (subsidiary of Leroy Salmar Norway) and Cooke Aquaculture ( New Brunswick Canada).

The eight salmon fish-farms currently licensed within Scapa Flow equates to a licensed salmon biomass total for Scapa Flow of 10270. 1 tones.

OFA have highlighted in the past and do so again in relation to this application and with reference to Brown Crab ( Cancer pagurus) Brown crab, European Lobster ( Homarus gammarus), Velvet Crab necora puber), green crab (cancer maenas), buckies ( ), King ( pectin maximus) and queen scallop ( opercularis) the following:

the lack of any research or evidence that biologically, the commercial shellfish industry at the point of moulting, spawning, as spat, in planktonic state, throughout the juvenile development process of all species and below minimum landing size or adult mature size for is not harme by any of the following deposits from salmon aquaculture farming including: salmon faeces and salmon urine, uneaten salmon foodstuffs containing chemical additives

for the preventions of sea- lice, copper, teflubenzuron, cypermethrin, emmamectin benzoate, hydrogen peroxide as a compound and at its active point separating from a compaound.

OFA view Scapa Flow as an enclosed body of water with areas of poor flushing and benthic areas where harmful deposits as described above can remain trapped or embedded to be ingested by shellfish which make up the commercial species listed above and for which there is no evidence that they will not be significantly damaged, compromised in terms of reproduction and survival to the stage of commercial harvesting at their legal minimum size. OFA note that OIC has no policy for the biological safety and integrity of Scapa Flow to protect all its flora and fauna including commercial fishing species.

OFA further notes that OIC has not to date employed the ‘ precautionary principal’ in relation to the uncertainties and risks posed to the developmental stages of the commercial species within Scapa Flow and on which the commercial wild fishery depends.

OFA note that OIC have not sought to establish a safe biological carrying capacity for the inputs relating to aquaculture within Scapa Flow not withstanding that other human input may contribute to cumulative harmful effects on other species not currently protected by EU or UK legislation.

OFA notes that it is Scottish Government Policy to grow salmon farming within Scotland without any cumulative biological safe limits in place.

The precautionary principal should be invoked with regard to the lack of knowledge on the harmful consequences of the siting of a new salmon fish farm on the commercial shellfish stocks listed above.

OFA requests the following in relation to this application and any future application within Scapa Flow.

1. Deferral of this application pending an appraisal of a holistic plan to create a biological policy for Scapa Flow. 2. Application of the precautionary principal in relation to the uncertainty surrounding the licensed aquaculture depositions on non- adult points of the biological development of species comprising the commercial shellfish fishery which are Brown Crab ( Cancer pagurus) Brown crab, European Lobster ( Homarus gammarus), Velvet Crab ( necora puber), green crab cancer maenas), buckies ( buccinum undatum), King Scallop ( pectin maximus) and queen ( Aequipecten opercularis).

Signed

Fiona Matheson

Secretary to OFA