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A consultancy firm which took part in a government pilot for fast-tracking salmon farm applications did an “independent” evaluation of that same pilot — prompting critics to call it a “sham” and claim a conflict of interest could threaten the marine environment.
Orkney-based Aquatera concluded that the pilot — which involved four salmon farm applications across Shetland and Highland council areas — was ultimately not quick enough.
Yet one of these applications – for Norwegian-owned Scottish Sea Farms, which will be the UK’s largest salmon farm if approved – was lodged with the help of Aquatera.
The government will now consider whether to roll the fast-track application scheme out across the rest of Scotland’s coastal areas.
Environmental campaigners – who raised alarms when the pilot began – said it threatens to “sideline environmental oversight”, and that Aquatera stands to gain business with developers from the success of the pilot.
Aquatera said it is “confident there is no conflict of interest”. The Scottish Government said Aquatera’s contract was subject to “strict” consideration of any conflicts of interest and that it had no concerns about the impartiality of the report.
It’s done by the same people who put in the application. Clearly this process is a sham.
Andrew Graham-Stewart, Wildfish.
The pilot was designed after a 2022 review said the current application process for fish farms is “ineffective” and demonstrates “no real coordinated approach” between councils and the national bodies which consider applications.
At present, fish farm developers must file as many as a dozen forms with five different local and national regulators for a single application. The pilot saw companies file one application to a council, with the local authority charged with consulting other regulators on the applicant’s behalf.
The pilot began early last year. Plans were submitted at Loch Snizort off the Isle of Skye, Hyskier in the Inner Hebrides, Strome Mor in Wester Ross and Fish Holm in Shetland.
Fish Holm, if approved, would rear 6,000 tonnes of fish a year, making it the UK’s largest fish farm to date.
Wildfish objected to Fish Holm this spring, on the grounds that lice from the farm would endanger Shetland’s wild trout. Its interim Scotland director, Andrew Graham-Stewart, said that the campaign group should have asked for Wildfish’s views as part of Aquatera’s survey, but was not approached.
“The respondents were clearly cherry picked, presumably to confirm the narrative of the consultants,” added Graham-Stewart. “It’s really got no credibility; it’s done by the same people who put in the application. Clearly this process is a sham.”
For its review, Aquatera approached both participating councils, community councils, four developers, government regulators, Salmon Scotland and the British Trout Association, which both represent the fish farming industry.
Of those, most said the pilot did not speed up the consenting process enough.
With such financial entanglements and a clear conflict of interest, how can Aquatera’s evaluation be seen as credible?
Abigail Penny, Animal Equality
Animal Equality also objected to Fish Holm, and said Aquatera’s review represented the fish farming industry marking its own homework.
“When the aim of the pilot is to essentially fast-track fish farm development by sidelining environmental oversight, then tasking a consultancy with direct industry ties to lead that review is deeply problematic,” said Abigail Penny, Animal Equality’s executive director.
She added: “It’s hard to argue full independence when the company evaluating policy changes stands to gain future business from those very changes. With such financial entanglements and a clear conflict of interest, how can Aquatera’s evaluation be seen as credible?”
Aquatera chief executive Gareth Davies said the firm has 25 years’ experience “providing impartial, evidence-based advice to government, industry, and communities”.
He added: “This evaluation set out to capture and present a balanced record of experiences from those directly involved in the consenting pilots, including developers, regulators, local authorities, and statutory consultees and non-statutory consultees.
“Our role was not to advocate for any party, but to document findings and identify areas for improvement, reflected in a series of recommendations to support the continued development of the pre-application process.
“Our work for aquaculture companies is entirely separate, and as with all of Aquatera’s work, our approach was guided by independence, transparency, and professional integrity.”
A spokesperson for the Scottish government said Aquatera’s contract “was subject to strict public procurement processes, including consideration of any conflicts of interest”.
“We do not have any concerns with the impartiality of the report and its conclusions,” they added. “The evaluation involved gathering quantitative and qualitative information from developers, regulators and statutory consultees involved in the first fish farm consenting pilots and their perceptions of effectiveness and areas for improvement.”
At the time of the 2022 review, Wildfish said the pilot risked prioritising the agenda of individual councils over concerns from the government’s environmental watchdogs.
One of Aquatera’s recommendations was to consolidate applications further through an individual “process champion” for each submission.
In its report the consultancy acknowledged: “as with all self-reported data, there is the possibility of response bias”, a statistics term used to describe dishonest or false responses to a survey.
“However, the study design encouraged open, anonymous input, and the findings are strengthened by the consistency of themes emerging across multiple sources and stakeholder groups”.
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Main image: starpik/iStock
This article was updated at 08.34 on 22 August 2025 to correct the spelling of Andrew Graham-Stewart.
Mohammed was 17 years old when he was shot by an Israeli sniper in Bethlehem. Two years on, his family say there is no accountability for his death. Their story is one of dozens from across the West Bank, it is claimed, with human rights organisations calling for child rights to be upheld.
Airbnb’s business practices in the West Bank have long been in the spotlight, prompting criticism from human rights campaigners. We can now reveal that the firm has lobbied the Scottish Government 52 times since 2018.
The residents of Umm al-Khair in the West Bank were already reeling from the loss of community leader and English teacher Awdah Hathaleen. Now they are fighting a mass demolition order on their homes. Human rights organisations say it’s become a symbol of the struggles of life under occupation.
The Aquaculture Stewardship Council monitors standards at Scottish fish farms to help consumers choose “environmentally and socially responsible” farmed seafood. But it showcased a farm that had breached its rules on sea lice 11 times.