Scottish Natural Heritage has released the text of a letter after being consulted on a Marine Harvest licence application to shoot seals in the Sound of Barra.  SNH has been trying to explain how it fulfils its advisory role.

Dear xxxxxx

Application for a licence to shoot 3 harbour and 6 grey seals at 1 fish farm in the Western Isles Management Region from Marine Harvest Ltd

Thank you for consulting us on this licence application, we appreciate the opportunity to comment.

Our view is that the assessment of seal damage at fish farms should be based on stock loss and not on the number of seals present in the area. Our opinion is that seal shooting should only be carried out in close proximity to the fish farm affected by seal predation and only when salmon cages are stocked. Finally it is our belief that shooting should only be used as a last resort where all appropriate methods of non-destructive seal deterrent have been exhausted.

We note from the results of the Scottish Oceans Institute survey that the applicant employs Acoustic Deterrent Devices (ADDs) “all of the time” at this site. We would like the applicant to note that where ADDs are employed it is our view that they should be used only when there is evidence of seal presence or attack rather than as a panacea.

We advise that Marine Scotland take account of the following when considering whether to grant this licence application:

• The Potential Biological Removal (PBR) figures of 54 for harbour seals and 408 for grey seals calculated for the Western Isles Management Region for 2012 by the Sea Mammal Research Unit (SMRU);
• The potential cumulative impact on the harbour and grey seal populations of the Western Isles Management Region of all anthropogenic impacts such as those covered by licences granted at other fish farms, rivers and netting stations and any other unnatural seal deaths caused by accidents such as entanglement in ropes and nets and collisions with boat propellers;
• The fact that the application is for shooting seals within the Western Isles harbour seal conservation area; 
• The fact that not all marksmen will have received training for seal shooting until after the licence period has started therefore there could be some cases of misidentification of species and, for example, harbour seals could be shot by accident in areas where only grey seals are licensed.

Position
We advise that if this licence were granted there could be a significant effect on the Sound of Barra possible Special Area of Conservation (pSAC) designated for harbour seals Phoca vitulina. We recommend that conditions are added to the licence to limit the number of seals shot at fish farms within 50Km of the Sound of Barra pSAC in order to prevent a significant effect on the site.

Appraisal of the impacts of the proposal and advice in relation to the SAC
The fish farm listed in the application lies within the Sound of Barra pSAC proposed for harbour seals (Phoca vitulina).

The site’s status means that the requirements of the Conservation (Natural Habitats, &c.) Regulations 1994 as amended, (the “Habitats Regulations”) apply as a matter of Government policy as set out in revised Circular 6/95. Further information is available at: http://www.snh.gov.uk/docs/A423286.pdf.

In our view, from the information available, it appears that in this case the proposal is not connected with or necessary for the conservation management of the site. Hence, further consideration is required.

In our opinion this proposal is likely to have a significant effect on the harbour seals of the Sound of Barra pSAC.  If a licence was granted with no restriction placed on shooting at individual fish farms in the vicinity of the pSAC there is the possibility that all the seals could be shot at one or a small number of the fish farms within or close to the Sound of Barra pSAC. Therefore the population of seals within the pSAC could potentially be reduced.  As a consequence, Marine Scotland is required to undertake an appropriate assessment in view of the site’s conservation objectives for harbour seals (see Annex).  It is important that this assessment considers other licence applications under consideration that may impact this SAC.

On the basis of information currently available we consider that it is probable that it cannot be ascertained that the proposal will not adversely affect the integrity of the site. This is due to the decline in the number of harbour seals in the Sound of Barra pSAC in recent years.

If you would like to discuss our comments please contact me at the above address.

Yours sincerely,