The upcoming public consultation

The public consultation was announced in a government press release on 28 May 2024. It will run from April to June 2025.

The consultation is expected to cost FIG £200,000, according to the Financial Management Report of the Standing Finance Committee.

During November 2024, FIG ran a scoping exercise to establish what additional information and evidence the public and stakeholder groups wanted to see included for consideration in the public consultation.

Salmon Free Falkland’s response included concerns about apparent information bias in favour of industry. SFF also expressed concerns that the scoping exercise document lacked clarity regarding what the consultation is about: is it salmon farming, aquaculture or fish farming?

How will a decision be reached?

In response to an enquiry from SFF regarding how FIG would decide whether or not salmon farming should go ahead, Mr James Wilson (Deputy Director of Natural Resources) replied: “the key point to stress is that a public consultation is not a vote, but a way of seeking public feedback on proposals.”

“Consultations are not referendums where the outcome is determined by how many people respond with a particular viewpoint. What matters are (a) the strength of arguments – for example, if a large number of people submit comments backing a particular position, but they have misunderstood something or relied on faulty evidence, their views would not be given the same weight as a smaller number of people who had produced rigorous evidence to support their position, and ultimately (b) the views of politicians. While officers can make a recommendation as a result of the representations made during a consultation exercise, ExCo members may take a different view, although according to the Gunning Principles, they should evidence that consultation responses were taken into account when making their decision."

The Consent Order stipulates that there be a “public consultation on whether and if so how a large-scale fish-farming industry should be developed in the Falkland Islands” based on the four options set out in the MEP Report. These four options are as follows:

Option 1: No salmon farming in the Falkland Islands

Option 2: Commercial salmon farming takes place and is limited only by the carrying capacity of the environment.

Option 3: Commercial salmon farming takes place but is limited well below the carrying capacity of the environment.

Option 4: Commercial salmon farming is allowed but through niche methods such as “organic production”

The premise of options 2 & 3 is based on the concept of “carrying capacity of the environment”.

But neither the MEP report nor the scoping exercise document provide a definition of the “carrying capacity of the environment”, and according to the latter, no assessment will be done of the carrying capacity of Falklands waters.

Without an assessment or definition of the “carrying capacity of the environment”, it is impossible to evaluate options 2 & 3.

According to the Norwegian Institute of Marine Research’s Fish Farming Risk Report, 2023: “The amount of organic emissions from fish farming is high, but how much this affects the bottom systems will vary with the local conditions. The production of farmed fish varies significantly both within and between production areas, and the impact of particulate organic emissions varies from location to location.

“The locality's carrying capacity is a combination of the natural conditions such as current, topography, bottom type and faunal community and the amount of fish that is farmed, that is, the relationship between the sensitivity of the locality and the production pressure.

“A good current at all depths is, however, desirable and low sinking rates of the discharge, which will be able to ensure good dispersion of the particles and lead to limited sedimentation under the aquaculture facilities. Fjord locations are more exposed to local influences than coastal locations, even though the facilities on the coast are often much larger.

“Greater depth is also desirable, but is not enough to reduce the impact, if there is not a good current at the same time. Habitats such as coral reefs, coral forests, loose calcareous algae and sponge areas can be negatively affected by emissions of organic particles from food fish farms because they either tolerate less impact or take a very long time to re-establish themselves.

“There is still a lack of knowledge about how much organic load from fish farming these habitats can withstand.”

“Organic” salmon farming using “niche methods” is presented as one of the four options.

The several hurdles this option would entail (according to the MEP report) include distance from market, sourcing organic feed and using non-native fish (salmon).

According to the charity WildFish, “So-called ‘organic’ Scottish salmon is a misnomer.”

“Organic’ salmon farms are permitted to still use highly toxic chemicals, which can kill surrounding wildlife; they still use wild-caught fish to produce feed and for parasite control (typically, wrasse used as cleaner fish), with unknown environmental impacts; and they still allow for the build-up of sea lice parasites, which can spread to, and prove fatal for, wild Atlantic salmon and sea trout.” - Rachel Mulrenan, Scottish Director at WildFish.

The open letter associated with this article specifies that so-called ‘organic’ salmon farms use the chemical pesticides deltamethrin and formaldehyde.

It is perhaps then no surprise that the introduction of the Soil Association’s scheme in 2006 prompted a former chairman of the Association’s Standards Committee to state that “salmon farming in cages has nothing at all to do with organic principles”.

This article in The Guardian describes the greenwashing around so-called “organic” Scottish salmon farms.

According to the psychology of choice: by giving four choices, only one of which is against salmon farming, the framing of the consultation is intrinsically biased towards some kind of salmon farming. It presupposes that some kind of salmon farming might be acceptable.

A public consultation free from presupposition would ask: do you want salmon farming, yes or no?