Response to CAR Licence application CAR/L/1010433 Marine Cage Farm – Loch Duich

20th March 2017

Summary: The proposed expansion of this fish farm will greatly increase the levels of pollutants entering the Lochs Duich, Long and Alsh SAC and MPA. These are likely to have direct effects on the designated features- reefs in the case of the SAC and burrowed mud in the MPA. The existing farm has already breached Environmental Quality Standards for residues of Emamectin Benzoate and increasing the permitted size will exacerbate this problem. Furthermore, recent research suggests that this chemical has profound effects on invertebrate populations at considerable distances from fish farms and at levels below those measured by the EQS. It is therefore almost inevitable that the existing farm will have had adverse impacts on features of the SAC but this has not been detected because Site Condition Monitoring has not been carried out on reef features in Loch Duich.

It will also affect the burrowed mud feature on the floor of Loch Duich. The deposition model used to predict the impact of pollutants from fish farms is not suitable for use on steep underwater topography of the type found at this site and the monitoring carried out by the applicant fails to take account of the potential for pollutants to travel down this slope. Increasing the numbers of fish in this site, coupled with the decreasing ability of Marine Harvest and other farming companies to control sea lice infestations, will inevitably lead to heightened loads of sea lice larvae in Loch Duich which will have detrimental effects on wild runs of salmon and sea trout in local rivers.

Permission to expand this site should be refused and consideration should be given to rescinding the existing licence.

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