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| Seaweed cutting in Loch Erisort - picture credit The Herald |
In the last few years, however, there has been renewed interest in re-starting alginates production in Scotland using seaweed mechanically harvested here. But before saying another word on the subject we need to deal with a very important terminological point: the two separate but rather unhelpfully overlapping meanings of the word "kelp". The first (original, historical) meaning is the mineral rich ash of seaweed of various species when it's burnt. The second (more recent, contemporary) meaning of kelp is a type of seaweed itself - i.e. the living plant before you cut it and put a match to it. Kelp in the first, original sense (ash of burnt weed) was made from kelp in the second sense but also from other seaweeds which are not kelp in the second sense. In the first two episodes of this saga, I reserved the word kelp for the first sense (ash). But in this episode I'm going to use the word in the second sense (a type of actual seaweed) because that's how it's generally understood in contemporary contexts. OK?
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| Kelp appearing at low tide - picture credit Colin Alston |
The two most important species of kelp in Scottish waters are Laminaria hyperborea and Laminaria digitata: these are the types that used to be called "stem" in the alginates industry and are known as "tangle" in common parlance. They look very similar but L. hyperborea is a bit bigger and has a rigid stem whereas L. digitata's is floppy. Most importantly for present purposes, though, both types of kelp form extensive submarine "kelp forests". Growing from the low water line down as far as about 30 metres depth, these have been described in one report as
... of high ecological significance. They are complex three-dimensional structures providing habitat, food and shelter for various species and are characterised by high productivity and a high diversity of associated flora and fauna. They also form important reproduction and nursery grounds for fish.
Kelp forests are to marine biodiversity what the Amazon rain forests are to terrestrial: you can go on a virtual dive in one covering 160 square kilometres (40,000 acres) in the Sound of Barra in this Youtube video by Scottish Natural Heritage.
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| Laminaria hyperborea in a kelp forest in Loch Laxford - picture credit Scottish Natural Heritage |
Laminaria hyperborea is the kelp proposed to be mechanically harvested by Ayr based company Marine Biopolymers Ltd (MBL) in a revival of the Scottish alginates industry. The company's name prompts another terminological point: alginates are a sub-set of a range of chemicals called hydrocolloids (in other words, all alginates are hydrocolloids but not all hyrocolloids are alginates) and hydrocolloids, in turn, are a subset of polymers. Biopolymers are simply naturally occurring polymers as opposed to synthetic ones. In the 21st century alginates industry, use of the word "alginates" tends to be downplayed in favour of hydrocolloids and biopolymers. That's just marketing: you can sell anything these days if you stick "bio-" or "hydro-" in front of it whereas "-ates" sounds a bit Erin Brockovich.
MBL have been on the go since 2009 and in 2014 were in discussions with the community landlord of South Uist Storas Uibhist about siting their alginates production factory beside SU's new harbour at Lochboisdale. One of MBL's directors and shareholders, Angus MacMillan, is also the chairman of SU (although he demitted during the MBL negotiations). Anyhow, MBL eventually opted instead to acquire none other than AIL/Kelco's old alginates factory at Barcaldine (see here) except nothing ultimately came of this either and Barcaldine has since been sold and demolished. It seems MBL's plans were not as far advanced five years ago as they thought because not much was happening with them (publicly, anyway) until 2018 when they began to progress their plans to harvest Laminaria hyperborea mechanically.
MBL's plan is to harvest kelp with a sort of cross between a rake and giant comb towed along the seabed behind a boat as pictured above. They've been doing this in Norway since the mid 1970s. It's commonly known as "kelp dredging" although that's something of a misnomer because kelp grows on rocky surfaces and you can't "dredge" rock, only sand, gravel and mud etc. Anyway, MBL intend by year six to have two harvesting vessels working year round to deliver (on separate transport boats) about 34,000 tonnes of wet kelp a year to a processing plant to be built at Mallaig. I'm not sure if the actual finished product algin ... sorry, biopolymers will be made at Mallaig or whether this will just be a facility where the wet kelp is dried and milled before being sent off for the final product to be made elsewhere. Anyway, they hope to create 32 jobs at the Mallaig plant and 10 on the harvesting and transport boats.
To use a vessel to remove anything from the seabed, you need a licence under Part 4 of the Marine (Scotland) Act 2010 from Marine Scotland (MS). An application for a licence to harvest seaweed does not legally require an Environmental Impact Assessment (for anyone interested in the legal detail, that's because seaweed harvesting is not included in Schedule 1 or 2 of the The Marine Works (Environmental Impact Assessment) (Scotland) Regulations 2017) but MBL decided it would be best practice to undertake one anyway. The first step in an EIA is a "scoping report" to enable MS, after consultation with the likes of Scottish Natural Heritage, to decide precisely what environmental issues require to be addressed in the EIA. You can read here MBL's scoping report submitted in July 2018 to MS preparatory to an application for a licence to harvest laminaria hyperborea within the area outlined red on the map below:-
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| MBL's "area of search" |
Meanwhile, a petition against MBL's plans was started by Ailsa McLellan who lives in Ullapool and, according to the BBC, "harvests kelp by hand using a pair of scissors and a bucket" (see here and note that, in the pictures there, that is not kelp she is cutting). The petition caught the attention of Green MSP Mark Ruskell and it was all very timely because there happened to be a bill before the Scottish Parliament concerning the management of the Scottish Crown Estate (SCE) and Ruskell happened to be a member of the lead committee on the bill, the Environment, Climate Change and Land Reform (ECCLR) Committee. The relevance of the Crown Estate is that it owns kelp (and all other seaweeds) growing below the low water mark and thus, as well as obtaining a regulatory licence from Marine Scotland, MBL will also need a commercial licence from SCE and pay them a royalty.
At a meeting of the ECCLR Committee on 18 September 2018 to consider Stage 2 of the Scottish Crown Estate Bill, when Ailsa's petition stood at 14,000 signatures, Mark Ruskell tabled an amendment to the bill to prevent the SCE (or anyone to whom its management might be delegated under the Bill) from permitting harvesting of kelp where that would "inhibit the regrowth of the individual plant." That would block MBL's plans because their harvesting method involves pulling up the entire plant: there is nothing left to regrow.
The usual procedure in the Scottish Parliament is that the lead committee on a bill hears evidence from stakeholders and experts on its principal provisions at Stage 1 and recommends any amendments which are dealt with at Stage 2. But there had been nothing in the original draft of the bill about kelp dredging and hence there had been no evidence on it at Stage 1. That's why six of the nine members of the ECCLR Committee were opposed to the Ruskell amendment - it wasn't because they were particularly in favour of kelp dredging but rather that they didn't have enough information to make an informed decision on the matter, particularly when the status quo was subject to a procedure under legislation passed as recently as 2010. But instead of voting against the Ruskell amendment, the six abstained and thus the amendment was passed by three votes for with none against. Six MSPs apparently inexplicably overlooked that votes in parliamentary committees are carried by a majority of the votes cast, not a majority of the members of the committee! (You can read the verbatim report of the Stage 2 meeting here and you can watch it here - the Ruskell amendment starts at 10:49:10.)
The next stage of a Scottish bill is Stage 3 where the bill as amended in committee at Stage 2 is reported to the full Parliament for approval (or otherwise) of the amendments. New amendments can be lodged at Stage 3 and the Scottish Government tabled one to remove the Ruskell amendment. But at the last minute, the Minister, Roseanna Cunningham, bottled it and withdrew the Scotgov's amendment when Parliament met for Stage 3 of the bill on 21 November 2018. Instead she announced that inevitable resort of timid politicians anxious not to upset anyone: a review. In saying to Parliament "I plan to keep the situation under review and do not wish unreasonably to block the future development of forms of harvesting that we might in time establish through a proper assembling of the evidence is sustainable", Cunningham appears to have left the door ajar to kelp dredging in the future but for now the Ruskell amendment prohibiting any method of harvesting which inhibits regrowth of the individual harvested plant stands and MBL's ball is well and truly on the roof. (You can read the verbatim report of Stage 3 here and watch it here - kelp starts at 15:37:40.)
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| Roseanna Cunningham - picture credit BBC |
I want to devote the rest of this post to fact checking some of the claims made against kelp dredging. Take for example Mark Ruskell's speech (here) at Stage 2 of the Crown Estate Bill in support of his amendment:-
If we were to consider forests on land, these days we would not be clear-felling ancient woodland. ... [Once] an area is clear-felled of kelp through dredging, it will take many years for the exposed rock to regrow the kelp; in some cases, due to the changing ecological conditions, it might be impossible for the kelp forests to re-establish themselves in areas that have been stripped. Therefore, in many cases, once the kelp forests are gone from a particular area, they may be gone forever or for a very long time
By the time of his speech (here) at Stage 3 of the Bill in defence of his amendment the threat had escalated to:-
We know that, if kelp is removed in its entirety from the sea bed, it may never grow back. Once it has gone, its benefits may be lost for ever.
The 34,000 tonnes of kelp MBL wants to harvest each year sounds a lot until you realise that the estimated total biomass of the stuff around Scottish shores is 19.7 million tonnes [Footnote (F/N) 1] In other words, MBL's annual take would be less than a fifth of one per cent of the total!
OK, so, at that rate, the kelp would all be gone in 500 years and we have a responsibility not to inflict that on future generations, don't we? Well, the even better news is that kelp grows back in about 5 years - even on bare rock entire plants have been torn off by the giant comb shaped harvesting tool because spores drift in and settle from adjacent undisturbed plants. For this reason, MBL's proposal is to harvest discrete strips of kelp which will be left surrounded by undisturbed plants. These strips will not then be harvested again for at least five years while the kelp re-generates on them. Moreover, the prongs on the harvesting rake are set as to catch only mature plants and leave juvenile ones undisturbed. Thus, talk by Mark Ruskell of "clear felling" kelp forests is grotesquely misleading.
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| Young kelp which has recolonised an area one year after harvesting - untouched plants on the left. |
The fact that kelp regenerates relatively quickly also puts into context the claim made in the petition and emphasised by Mark Ruskell in Parliament (at Stage 2) that, in newly harvested areas of kelp forest, the number of juvenile gadid (cod, pollock, saith etc) fish was 92% lower than in un-harvested areas. That's no doubt true but, if I were an MSP sitting on a Parliamentary committee taking evidence from stakeholders, I would be asking whether it's not the case that this is merely a temporary (c. 5 years) state of affairs in a tiny (less than 1%) proportion of the kelp forest while it grows back? [F/N 2] After all, if we could agree that felling a single tree in the rain forest was sustainable, it would presumably be the case that there would be a 100% reduction in the populations of tree living birds and monkeys etc. within its footprint.
Roseanna Cunningham's speeches to Parliament give the impression she was consenting to the Ruskell amendment as an emergency response to something the Scottish Government had been taken by surprise by. But in fact the SG has known for some time that applications for licences for mechanical harvesting of kelp were in the offing because, in 2016, Marine Scotland (MS), the SG's agency responsible for maritime development and protection, conducted a statutory Strategic Environmental Assessment (SEA) under the Environmental Assessment (Scotland) Act 2005 to:-
assess the potential environmental effects of wild harvesting of seaweeds and seagrasses and in turn inform future regulation.
You can read the SEA here. Interestingly, MS had "technical support" to the SEA from ABP Marine Environmental Research Ltd which is the firm which prepared MBL's scoping report. Anyway, its conclusions include (page 134):-
Although not straightforward, sustainable commercial scale harvesting of certain species is possible and is taking place in other countries, such as Norway and Chile where annual live extractions of
kelp by trawlers reaches 200,000 tonnes (Vasquez, 2008; Vea & Ask, 2011; Smale et al., 2013; Burrows et al., 2014a). The ability to sustainably remove such quantities at these locations has been attributed to the rapid recruitment and growth of kelps, the species associated with the kelp beds, and the implementation of appropriate and functional management of the resource.
Also of significance is a passage on page 125 of the SEA but first we need to do a quick bit of kelp biology. In the photo of a detached laminaria hyperborea plant below, from left to right is the holdfast by which the plant attaches itself to the substrate (it looks like a tree root but it's not a root because it doesn't penetrate the substrate which is rock); then the stipe which is the stalk; and finally the lamina or fronds. The junction between the stipe (stalk) and lamina (fronds) is called the meristem. The plant grows from the meristem - in other words, if you cut the stipe (stalk) below the meristem, it won't regrow and the plant will die but if you cut the lamina (fronds) above the meristem, the plant will survive and the lamina will grow again:-
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| Picture credit - Wikipedia |
Anyway, back to page 125 of the SEA:-
* Cutting heights should generally be as high as possible and well above the point of growth (e.g. the meristem for kelps) and the holdfast left attached. The only case where this may not be feasible is in the case of Laminaria hyperborea where the stipes (which are below the meristem) are targeted for commercial use, and where the most sustainable mechanical methods involve removing the entire mature plant and leaving smaller immature plants to continue to grow.;
* Where possible and relevant, less than one third (i.e. 33%) of an individual plant should
be harvested to allow for regrowth; and
*Avoid the entire removal of any plants apart from the case of L. hyperborea as
explained above. [Emphasis added]
In proposing his amendment to the effect that kelp could not be harvested except by a method which permitted the regrowth of the affected plants, Mark Ruskell said (Stage 2) that it:-
attempts to enshrine a golden rule that has applied to the harvesting of kelp for many years, if not generations.
Apart from the fact that that's contradicted by the Strategic Environmental Assessment, it overlooks the fact that living kelp has never been harvested in Scotland (except within the last 5-10 years by hand at an artisanal scale by businesses like Mara Seaweed and New Wave Foods). During the kelp [sense 1: mineral rich ashes of seaweed] industry which ended in the early 1930s and then the alginates industry which ended (so far as Scottish weed was concerned) in 1998, the kelp [sense 2: a type of seaweed including the laminarias] used was beachcast, that is plants torn from the seabed naturally by storms and washed up on the shore. Non-kelp weeds which are harvested (known as "asco" in the industry) are cut, both by hand and mechanically, so as to leave enough of the plants left to re-grow. But due to the differences between their biologies and the environments asco and kelp respectively grow in, the mechanical harvesting methods used for asco wouldn't work for kelp. That's because asco floats to the surface and, irrespective of where on the plant it's cut, what's left will regrow. It's thus amenable to being mechanically cut by a process known as "hedge cutting" in the industry using a sort of cross between a pedalo and a ride-on lawnmower:-
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| Asco harvesters at Loch Marvig, Lewis - photo credit John MacLennan |
These things work fine in the sheltered sea lochs where asco grows but you can't use them along the exposed rocky coasts preferred by kelp. Plus, kelp doesn't conveniently float to the surface and the plants have to be cut in a certain place (above the meristem) if what's left is to regrow: get it wrong and it will die. Thus, there is no technology for mechanically harvesting living kelp such that the affected plants can regrow: the only way to do it is to remove whole mature plants with the giant comb and leave juvenile plants and new ones seeded from surrounding undisturbed areas to grow.
So there is no "golden rule that has applied to the harvesting of kelp for many years, if not generations" and if Mark Ruskell was attempting thereby to imply that he wasn't trying to legislate some new ban that isn't already enforced another way, then, assuming he wasn't being disingenuous, he seems to have been misinformed. Perhaps he's just muddled about the different meanings of the word "kelp" and thinks it applies to all seaweeds of commercial interest. Roseanna Cunningham certainly betrayed some confusion about this when she told Parliament [Stage 3] that "there are five different ways in which kelp can be harvested commercially—it is not simply hand versus mechanical harvesting." That's a reference to the SEA (page 40) but of the five harvesting methods listed there, only four apply to kelp. The fifth ("hedge cutting") applies only to asco - the different uses of the word kelp really are a trap for the unwary!
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| Kelp (laminaria hyperborea) visible at low tide - picture credit Robin Cox |
None of this is to say that kelp dredging is totally without environmental impacts, of course, as the SEA makes clear. Concerns include, amongst others, the following:-
1. Although the kelp itself regrows in about 5 years, it's possible its associated biodiversity takes a few years more to re-establish itself. In Norway, it's been suggested this be addressed by extending the fallow period between harvests to 7-10 years [F/N 3] and could this not be applied to Scotland as well?
2. Conflict between kelp dredging and creel fishing for crab and lobster because kelp forests are the habitat for crab and lobster (but not prawns or scallops because they live in muddy seabeds where kelp doesn't grow). There's also potential for conflict with other marine users such as nature tours etc. In this regard, though, MBL's scoping report said that they estimated the annual footprint of their operations to be the equivalent of that of a single large scallop dredger in a month so surely there must be enough room for everybody, no?
3. "Urchin barrens" - areas of kelp forest grazed bare by plagues of sea urchins. Such barrens exist in Norway and the suggestion is that kelp dredging threatens the habitat of urchins' predators leading to an explosion in their population. "Avoid harvesting kelp in areas with high abundance of grazing sea urchins" is the mitigation measure recommended in the SEA (page 127) suggesting that this problem is not insurmountable.
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| Urchins attacking kelp in California - picture credit Monterrey Bay Aquarium |
4. Coastal erosion - kelp forests dampen waves rolling in from the ocean: in Norway, they've been found to reduce wave height by as much as 60% resulting in wave energy loss of up to 80% [F/N 4] So the concern is that removal of kelp could threaten "soft" coastlines (those fronted by beaches as opposed to rocks) such as the west coast of Tiree. It's significant that coastal protection is the only area where the SEA's "risk matrix" (page 120) says the environmental risk from kelp dredging is higher ("medium" as opposed to "low") than mechanical harvesting ("hedge cutting") of asco as currently practiced and assumed by everyone to be eminently sustainable. It's also worth noting that no aspect of kelp dredging is assessed as "high" risk in the matrix and the prescription for the threat to soft coastlines is "Limit/avoid harvesting in wave exposed and erosion prone coastal areas (e.g dunes) where kelps dissipate wave energy". [F/N 5]
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| Waves on the west coast of Tiree - picture credit David Baker |
Generally, it seems to me that, once the tiny percentage of the total biomass of kelp growing round the coast which MBL propose to harvest is understood - and that there's no question of clearfelling entire kelp forests - the threats assume a more rational proportion. They could and should have been dealt with under the marine licensing process which operates under existing, relatively recently (10-15 years) passed legislation rather than a knee-jerk ban passed in contravention of the Scottish Parliament's usual protocols. You do have to wonder what the point of statutory Strategic Environmental Assessments is if, come the thing the SEA is supposed to inform the Scottish Government's response to, the SG instead legislates to ban that thing and announce a further review?
The contra argument to that may be that the Ruskell amendment is merely a temporary stop while the review ascertains whether the licensing process is robust enough to deal with the environmental risks. And that, once it's either been determined that it is and/or any improvements have made (for example making project specific Environmental Impact Assessments compulsory for seaweed harvesting proposals as opposed to merely good practice), then the SG will legislate again to remove the Ruskell amendment so that kelp dredging can proceed subject the necessary monitoring and threat mitigation measures. But are they brave enough to take such a step? Ah hae ma doots!
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| Wouldn't that be rather courageous, Humphrey? |
Footnotes
[1] - Burrows et al. (2018) Wild Seaweed Harvesting as a Diversification Opportunity for Fishermen page 19, Table 4
[2] - the 92% reduction in juvenile fish stocks claim is made in an article (Multi-trophic Consequences of Kelp Harvest by Lorentsen at al (2010)) the full text of which is not available without a subscription but its abstract is here. Note the reference to the reduction being "persistent for at least 1 year following harvest" suggesting that it declines in a relatively short number of years.
[3] - Strategic Environmental Assessment, para 6.4.3, page 80
[4] - Strategic Environmental Assessment, para. 7.2.7, page 101.
[5] - Strategic Environmental Assessment, page 127.
