The law protecting porpoises, dolphins and whales from injury and disturbance will be of little worth if civil servants licence the use of Acoustic Deterrent Devices (ADDs) by salmon farms on March 1st.
 
Marine Scotland may well circumvent the law by granting European Protected Species Licences which would legalise the currently illegal use of ADDs. They can only legally grant the licences if 3 tests can all be passed.
 
One test is that there must be no ‘satisfactory alternatives’ to ADDs. The problem Marine Scotland civil servants have is that there are ‘satisfactory alternatives’ currently in use in Scotland and abroad.

Here is some of the evidence: this article Cooke farm manager David Brown said the company was in the process of investing a total of £4.7 million into anti-predator nets designed and developed by the Indian company Garware-Wall Ropes. The Seal Pro netting is much tougher and has a more rigid surface than traditional nylon nets. Grant Cumming, managing director at Grieg Seafood Shetland said the company was using different solutions to suit different sites. “We have sites with dedicated predator nets. These can be made of HDPE [high-density polyethylene] netting or of semi-rigid non-fibre plastic. We would then hang a traditional nylon net within the predator net to contain the salmon,” he said. “On other sites which are too tidal for predator nets we have a single net made of monofilament nylon which has a much higher breaking strain that the traditional nylon nets.  They are also more rigid than traditional nets.

 The Minister’s reply to this Parliamentary Question is that Cooke Aquaculture have 35 farms and none of them use ADDs. Greig have 20 farms of which 18 are fitted with the better nets and do not use ADDs.
 
By contrast the Scottish Salmon Company use ADDs on every one of their 45 salmon farms.  Freedom of Information evidence reveals that  none of their farms use anti-predator nets.
 
The difference between Cooke and Greig farms which do not use ADDs and Scottish Salmon company who do is that the former use the best nets and the latter use the cheapest nets. Marine Scotland have conceded that extra cost or inconvenience is not a valid reason to claim that an alternative to the use of ADDs is not ‘satisfactory’.
 
Marine Scotland are breaking the rules: they are 'accountable to the public', but they have not published the EPS licence applications for public scrutiny despite a formal complaint lodged December 14th. They must 'take decisions fairly, impartially and without bias using the best evidence' but they refuse to reply to questions challenging their science, lodged 31 days ago until 15 days after their stated date to complete the licensing process. 
 
If you want to help whales, dolphins and porpoises please copy the text above (or write your own letter) to all your MSPs, just click on this link, copy and paste this update or write your own letter.
 
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