DAWNFRESH’S RECORD ON LOCH ETIVE AND LOCH AWE
Dawnfresh Holdings Ltd is controlled by Alistair Salvesen. He is the majority shareholder.
In the three years ended 31 March 2014 the company made a losses of £15.6 million:
£4.5 million loss
£5.2 million loss
£5.9 million loss
- Increased numbers of farmed fish
- Escapee fish
- Sea lice
- Seabed pollution
Since January 2010, the biomass of fish held on Dawnfresh Loch Etive farms has increased by nearly 500%.
In that time, there have been numerous problems with Dawnfresh farms.
This year saw a huge escape of farmed fish from Etive 4, with Dawnfresh confirming that it had lost over 2,000 fish in April this year.
Dawnfresh’s Loch Awe and Loch Etive farms have a very poor record of losing rainbow trout and this has, over many years, caused great disruption to the wild salmon fishing on the River Awe. There have been just under 24,000 reported rainbow trout escapes into Loch Awe and Loch Etive since the start of 2008, the year Dawnfresh bought the farms.
Marine Scotland Science says that rainbow trout can pose a threat to wild fish through direct competition for resources and transfer of disease.
Despite the oft-repeated mantra that ‘Etive has no sea lice’, Etive 3, Etive 4, Etive 6 and Etive 5 (Ardchattan) were all treated for sea-lice by Dawnfresh last autumn using emamectin (Slice) and a further treatment has become necessary again this summer.
In October 2014, both Etive 4 and Etive 6 farms had sea lice record levels above the suggested criteria for treatment in the industry’s Code of Good Practice. At the time, there were 274,000 fish in Etive 6 and 229,000 held in Etive 4 – over half a million fish. Even if just a single adult female lice was present on each fish, this constituted an enormous production of juvenile sea lice and a huge risk to wild salmon and sea-trout in Loch Etive. Information from Marine Scotland Science and from the west coast of Scotland suggests lice from fish farming can cause a risk to local salmon and sea trout.
Most salmon farmers attempt to deal with sea lice by loch-wide fallowing, a method supported by Marine Scotland Science. This lets sea lice levels within a loch to drop back to levels that do not cause problems either for farmed fish or for wild fish, but as Dawnfresh confines all its seawater production to a single loch, Loch Etive and operates continuous production, this presents a significant risk that sea lice numbers could build up over time in Loch Etive.
All Scottish fish farms have to self-report the level of benthic pollution (uneaten fish feed, faeces and general detritus) and any change in the species found living on the loch-bed under and around fish-farms. SEPA states that a ‘borderline’ benthic survey classification “indicate(s) that a site is close to having an unsustainable impact on the environment” and that an ‘unsatisfactory’ report is “an indication that the emissions arising from the site in question are of a scale that is beyond the assimilative capacity of the local environment”.
Loch Etive contains sea-bed habitats and species which Scottish Natural Heritage considers to be marine nature conservation priorities in Scottish waters. The Nature Conservation (Scotland) Act 2004 places a general biodiversity duty on all Scottish public bodies, including the Argyll and Bute Council, to protect biodiversity in Loch Etive.
But the Dawnfresh record of benthic pollution on Loch Etive is not good. Since 2009, on Loch Etive, 7 out of 12 surveys have been less than satisfactory, according to SEPA:
- Etive 1/2 (Inverawe East and West) – 1 out of 3 less than satisfactory (1 unsatisfactory)
- Etive 3 (Port na Mine) – 2 out of 3 less than satisfactory (1 unsatisfactory, 1 borderline)
- Etive 4 (Airds Bay) – 2 out of 3 less than satisfactory (1 unsatisfactory, 1 borderline)
- Etive 5 (Ardchattan) – 2 out of 3 less than satisfactory (2 borderline)
The fish-farming industry generally regards seals as a potential predator and nuisance species, but this is not a view shared by the vast majority of tourist visitors to and residents of Loch Etive.
Dawnfresh has an existing licence to shoot seals. According to figures released under freedom of information by the Scottish Government, in 2011 Dawnfresh reported that it had shot six common seals in total on Loch Etive (one shot from Inverawe East, one from Port na Mine (Etive 3), one from Airds Point (Etive 4) and one from Inverawe West). In 2012 (first three quarters only), the figures were 3 common seals – one at Airds Point (Etive 4) and two others (sites not given).
The more fish are held on Dawnfresh farms on Loch Etive, the more likely it is that seals will be attracted to the cages and may end up being shot.
The last assessment of the ‘ecological status’ of Loch Awe, carried out by SEPA under the European Water Framework Directive, concluded that Loch Awe was only at moderate status, at least in part due to phosphate pollution coming from the Dawnfresh fish farms.
The Directive requires that Loch Awe should reach good ecological status by 2015, subject to various exemptions. Instead, Dawnfresh has applied to increase its biomass at its two Loch Awe farms by 20% at each site.
In 2013, the Council’s attention was drawn to a significant breach of planning at Etive 4 which showed that Etive 4 was being operated at the same time as Etive 3 and not being fallowed for a sufficient period, both contrary to planning conditions. Regrettably, the Council decided this was just a ‘technical breach’.
In 2014 and 2015, Etive 6 has in breach of its planning permission’s associated section 75 agreement, because the fish farm equipment at Etive 1 has not been fully removed as it should have been before Etive 6 was first stocked with farmed fish.
Following a variation of its pollution control licence, Etive 4 is currently in a position where its planning permission and pollution control licence from SEPA are incompatible. Either one or other will be breached if the farm is restocked.
At Etive 3, Dawnfresh has been using 70 metre cages where its permission is only for 60 metre cages – this represents a significant 36% increase in the footprint of the farm, without any new planning permission being granted.
FoLE has also drawn the Council’s attention to what appears to be significant changes in the cages and equipment on Dawnfresh’s two Loch Awe farms. The Council has since served formal Planning Contravention Notices under the Town and Country Planning (Scotland) Act 1997 on Dawnfresh in relation to Etive 3 and the Loch Awe farms and has also had to require Dawnfresh to remove disused old fish farm cages pulled up and moored near the shoreline near the Etive 1 site.
The equipment at Etive 5 does not currently match the equipment listed in the planning permission for that farm, granted centrally by Scottish Ministers, but the Council has decided to take no action as that farm must be removed completely in 2017.
At Etive 2, Dawnfresh appears also to have breached its planning permission by keeping fish in the cages beyond June 2015, as its pollution control licence did not permit it to treat those fish for sea lice in the event of an outbreak or infestation. The condition that Dawnfresh needed a pollution control licence to control sea lice was imposed by Scottish Ministers last year, but still there are fish in Etive 2. FoLE has asked the Council has been asked to enforce planning permission here too.