Alresford Salads threaten a struggling English chalkstream

Currently many of our rivers across the UK are impacted by a variety of undesirable inputs.  Influencing the future health of these important waterways is one of our key objectives. We continue to be extremely concerned about a worrying example of pollution by Alresford Salads on the Upper Itchen in Hampshire.

Alresford Salads, who process and package watercress and other salads into bags for supermarkets have applied for a change to its license to discharge chemicals directly into the river.  In the past, they have used chlorine to wash salads, and still use chlorine-based chemicals to clean down the processing plant at the end of the day’s production.

These chemicals are lethal to fish and aquatic insects.

Nick Measham from Salmon & Trout Conservation said:

“It is extraordinary that chlorine was ever allowed to be discharged into any UK river, but the fact that it was allowed into the Itchen, a Special Area of Conservation under the EU Habitats Directive, is staggering. And, if the proposed license variation goes through, the plant will still be discharging lethal chemicals.”

The Itchen is protected by the highest possible environmental legal status under EU law – the Habitats Directive and is classified as a Special Area of Conservation.  However, monitoring of the river by S&TC since 2013 for phosphates as well as water invertebrates since 2015 through its Riverfly Census, identifies that this once highly-prized river is critically degraded with the consequential loss of vital insects and other water invertebrates such as Gammarus Pulex – a freshwater shrimp – which is a core component of the food chain.

The Environment Agency is currently reviewing this new discharge variation licence for Alresford Salads through the National Permitting process for licencing discharges into watercourses.

Nick Measham, adds:

“This processing plant was first licensed by the Environment Agency in 2002. This was a mistake and it is hardly surprising that this once pristine chalkstream is now recording such dismal results.”

Recent monitoring on the Itchen by S&TC researchers measured Gammarus in depressingly low numbers. For example, under 100 Gammarus were recorded in many kick samples. 500 is the minimum benchmark we have agreed with the local Environment Agency, which represents a functioning, healthy system. In addition, riverfly richness was also below the figure expected of a river of this nature. This poor water insect outturn has a knock-on effect for all aquatic wildlife.

Nick Measham continues:

“We have always been opposed to the discharge of any effluent directly into the Itchen or any other river on precautionary grounds, but until now have not had the evidence to build a persuasive case to challenge the Environment Agency. Our monitoring over such a long period of time has certainly built a very strong case.”

The salad washing plant will continue to discharge cleaning chemicals that contain sufficient toxic materials to cause serious population crashes of Gammarus for some distance downstream of the discharge point.  The discharged chemicals react to form chloramines which are highly toxic even in very low concentrations in water.

Nick Measham explains:

“We are dismayed that there appears to be no understanding of the well documented combined toxicity of surfactants and chlorinated compounds found in the current and proposed cleaning chemicals used at Alresford Salads. Combined effects of chemical mixtures should be taken into account for sound ecological risk assessments.  Risk assessments made by both the chemical manufacturers and the product distributors of products containing those chemicals are unequivocal when they stipulate that such materials should not be allowed in waterways.”

In order to protect the Itchen from further destruction, we are keen to find solutions.

Nick Measham said:

“If this permit is granted it will have long-lasting implications for all aquatic life on the Itchen.

But in a stroke this issue could be resolved.

Alresford Salads could connect its operation to the main sewer, which is about 500 yards away.  Indeed, its nearby competitor, Vitacress has done just this on the Bourne Rivulet and pays Southern Water for the privilege.  This would mean further investment by this wealthy company,  but in the long term it would protect this once-famous river from potential chemical pollution from the salad washing plant.

This surely must be a priority for a Government environmental regulator and a company keen to bolster its environmental credentials.”

In addition, the charity is requesting that the Environment Agency’s National Permitting process is reviewed in light of the lessons learnt from this process on the Itchen.

Nick Measham concludes:

“We believe the public should be aware of these questionable decisions by our regulators who seem to put short-term business interests above environmental protection.

Chemical discharge should not be allowed into any watercourse, especially a highly protected chalkstream.

Alresford Salads who are owned by Bakkavor – a multi-national company, claim to be green but they are showing scant regard for protecting this important chalkstream in southern England.”

Will the Environment Agency’s proposals to protect wild salmon work?

Can the EA Protect Wild Salmon?

We warmly receive the Environment Agency’s proposed new measures to protect wild salmon stocks, but we emphasise that they need to be implemented rapidly to save this threatened species.

The 2015 national salmon stock assessment indicated that wild salmon stocks in many rivers across England had failed to meet their minimum conservation targets. Further monitoring since then has shown that this trend has continued downwards.

Paul Knight, our CEO says:

“We are delighted that the campaigning and responses of S&TC and other organisations to the Environment Agency’s consultation on salmon stocks has resulted in these new proposals to protect wild salmon and sea trout.

The proposed closure of net fisheries on the North East coast of England by 2019 is a promising start but we believe the case is extremely pressing and action should be taken this year and not delayed for yet another season.”

Mixed stock coastal netting stations indiscriminately catch any salmon passing by, regardless of where they are heading or the strength of the population in their home rivers.

They are completely non-selective, making the management of individual river stocks almost impossible. In addition, many rivers that should see returning fish are designated as “At Risk”. The random nature of mixed stock fisheries therefore makes it extremely difficult to determine the impact of such fisheries on these vulnerable river sites.

Under pressure from S&TC and other organisations, the Scottish Government finally announced the closure of all Scottish netting fisheries in 2016.  However, coastal mixed stock netting stations still occur along the North East coast of England. While this is not under Scottish jurisdiction, between 30-70% (depending on area fished) of wild salmon caught are from Scottish stocks.

Paul Knight continues:

“We agree that the reason for the dramatic decline in wild salmon is complex.  Atlantic salmon are wild migratory fish with a unique life cycle. Leaving its distant marine feeding areas, this iconic fish returns to the river where it was born to lay eggs, but to do this they face immense challenges.  Many of these are caused by direct human impact – so it is in our gift to save this fascinating species for future generations, but time is running short.”

S&TC has long battled with the Scottish Government on fish farming and the impact that this is having on wild stocks of salmon because of the dramatic rise in sea lice populations.  The charity is also helping to protect wild salmon ‘s fresh water habitats through its Riverfly Census, which has identified that pollution from sediment and phosphate is having a direct effect on water quality to the detriment of all aquatic wildlife including wild salmon.

Paul Knight concludes:

“Pollution has reached an alarming level in many of our rivers and much more work needs to be done to protect these spawning grounds for salmon as well as other wild fish.

This will involve a major re-think in the way our water is managed through improved regulations, stricter penalties for polluters and more in-depth monitoring of water quality.”

In addition, S&TC is concerned that these new proposals do not address the conservation status of sea trout. Although considerable effort has gone into identifying the conservation status of Atlantic salmon and its complex lifecycle, we know far less about how sea trout are faring, although they share very similar characteristics and habitats to salmon.  More detailed research on the status of sea-trout populations is urgently needed to protect this species too.

The Environment Agency will advertise the proposed byelaws to protect salmon in late February 2018 and is inviting responses to the proposals either online or via letter. We welcome this new opportunity to protect wild salmon, provided it can be effectively activated.

Chlorinated chemicals in our areas of conservation? Just say no!

Chlorinated Chemicals

One of our main objectives is to influence the clean-up of rivers across the UK, where many waterways are impacted by a variety of undesirable inputs. We use local issues to bring attention to problems at national level, and one such case is very topical on the Upper Itchen right now.

Alresford Salads, who process and package watercress and other salads into bags for supermarkets, has applied for a new licence to discharge chemicals directly into the river.  In the past, they have used chlorine to wash salads, and still use chlorine-based chemicals to clean down the processing plant at the end of the day’s production. These chemicals are lethal to fish and aquatic insects. It is extraordinary that chlorine was ever allowed to be discharged into any UK river, but the fact that it was allowed into the Itchen, a Special Area of Conservation under the EU Habitats Directive, is staggering.

Without going into huge detail, these licenses are controlled by a central Environment Agency (EA) National Permitting department.  Alresford Salads has applied for a licence to use new chemicals and, although we suspect that local EA people are unhappy with any such discharge into the river, their advice seems to have been ignored by EA National Permitting who appear instead to have given way to commercial interests rather than do their job to protect the river environment.  True, they have followed a box-ticking exercise which includes an Environmental Impact Assessment of the new chemicals that Alresford Salads now intend to use, but they are still prepared for chemicals to be poured directly into the river daily – and what would happen if there was an accidental spillage of, say, concentrated chemical?

The solution would have been simple – the EA could have forced Alresford Salads to connect to the mains sewer as its competitor, Vitacress, does on the Bourne Rivulet (a stream with no SAC or SSSI protection).  It would have cost money, of course, but it would have protected this once-famous river from potential chemical pollution from the salad washing plant, and that, surely, is the priority for an environmental regulator?

Vitacress, a competitor of Alresford Salads is connected to the mains sewer on the Bourne Rivulet
Vitacress, a competitor of Alresford Salads is connected to the mains sewer on the Bourne Rivulet

This decision is astounding in 21st century UK.  It shouldn’t matter that the Itchen is one of our high profile chalkstreams – chemical discharge should not be allowed into any watercourse – but it is especially concerning that we cannot even protect these SAC rivers properly.

Our Riverfly Census, which reports in a few months’ time on 3-years of invertebrate data analysis across 20 English and Welsh rivers, will show that sediment and phosphate are the biggest culprits of poor water quality.  Our recently published peer-reviewed scientific paper (link below) shows that sediment and phosphate are both lethal to blue winged olive eggs, and almost certainly to many other water insect species as well.  In Wales, slurry pollutes rivers on a seemingly weekly basis, and nothing is done about it.

We must stop this pollution, and make sure that our regulators face up to their responsibilities to protect the environment, rather than cave in to commercial interest.

See Blue Winged Olive Egg Study by Nick Everall et al.

For more information on the Riverfly Census email or click the button below:

Access here

Riverfly Census

Sea Trout Science and Management

Sea Trout Science and Management is a book containing the proceedings of the 2nd International Sea Trout Symposium, held in Ireland in 2016.

The Proceedings are edited by Graeme Harris, an eminent authority on sea trout and long-term member and scientific adviser to S&TC.

S&TC was one of the Symposium’s sponsors and these proceedings prove what an excellent insight was given by specialists across many fields into sea trout science and management – as well as what we know and what gaps are still there in our knowledge.

The Symposium provided several challenges to sea trout scientists and managers, as well as a full update on sea trout work and issues from different countries, and these proceedings are therefore essential reading for all those with an interest in this magnificent fish.

This important new volume updates developments in the sea trout science and management in the Northwest Atlantic since the 1st International Symposium on ‘Sea Trout: Biology, Conservation & Management’ in Cardiff, Wales in July 2004.

It includes 30 peer-reviewed papers by acknowledged experts under the broad themes of:

  • Understanding Anadromy
  • Populations & Management
  • Movement & Migration
  • Monitoring & Surveillance
  • Ecology & Behaviour
  • Threat Assessment

To see full contents list click HERE

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Learn more about the book and how to access it using the link below

Click Here to learn more about Sea Trout Science and Management

Mayfly research emphasises serious need for river regulation re-think

For the first time a new research study, co-authored and financed by S&TC and published in the science journal Environmental Pollution, shows how even modest levels of sediment and phosphate are threatening the very life-blood in our rivers and streams.

This research matters as our Riverfly Census shows rivers are suffering from phosphate and sediment. Phosphate is the single largest cause of water bodies not achieving ‘good ecological status’ in the UK under the EU Water Framework Directive (WFD) and 83% of our rivers are failing to meet this standard.  According to the Environment Agency, phosphorus concentrations have increased in many regions, often linked to human and animal waste. 

The study carried out by Dr Nick Everall from Aquascience Consultancy Ltd in collaboration with us, shows that elevated levels of fine sediment and phosphate are having a devastating impact on the survival of the eggs of the Blue-Winged Olive (Serratella ignita) one of the most common mayfly species in the British Isles and present across most of Europe. 

Once a mainstay species for fish and anglers alike and synonymous with summer evenings on rivers from the Eden to the Test, the Blue-Winged Olive (BWO), is now in rapid decline in many waters across the UK.

The Blue Winged Olive (Serratella ignita) with an egg ball
The Blue Winged Olive (Serratella ignita) with an egg ball

Dr Nick Everall, who conducted this study with S&TC said:

“Mayflies such as the Blue-Winged Olive are a crucial component in the aquatic food chain but numbers have declined substantially in many UK rivers over the past 30 years, particularly in chalkstreams. Their continuing loss can affect the survival of other important species such as wild fish, bird life and mammals.  This research showed that even modest levels of sediment and phosphate below current national thresholds have a significant impact on egg survival to hatching.”

Although knowledge on environmental stresses affecting adult and larval life stages of mayfly such as BWOs has increased, until now there has been very limited research on the survival of their eggs. Their life cycle typically includes a long overwintering period of up to eight months in the vulnerable egg stage before nymphs emerge in the spring with adults hatching from June to September.   

Paul Knight, Chief Executive of S&TC said:

“The results of this ground-breaking study, which add further weight to the findings of our Riverfly Census are irrefutable.  For the first time, we have identified the serious impact that fine sediment and phosphate are having on the vulnerable early egg stages of mayflies.  We believe this is just the tip of the iceberg.  Lose your invertebrates and other species will follow.” 

Nick Everall explains:

“Our study showed that even low levels of both suspended sediment and orthophosphate (phosphate in solution) negatively affect invertebrate egg development.  It would seem that important information is being missed by focusing on the larval and adult stage of invertebrate development rather than their eggs, in what is potentially their most vulnerable development stage.”

Previous research on the larval and adult stages of invertebrates indicates that elevated levels of suspended sediment and orthophosphate are pervasive issues in river management, due to agricultural intensification and population increases coupled with direct discharge of untreated human waste.

Significantly, the sediment and orthophosphate levels used in laboratory conditions in this study, represented relatively modest concentrations for many English rivers and typically below current Water Framework specified thresholds.  These current findings support the growing concern that the annual mean suspended sediment guideline standard of 25mg 1-¹ in the UK is not sufficient.

This new study is in conjunction with our 3-year Riverfly Census, which has been monitoring the health of rivers across England and Wales by measuring water insect abundance and diversity.  The Census, which ends in 2018 has so far shown that many of our rivers (including those with Special Area of Conservation status) are suffering from pollution because of human pressure to the detriment of all water life including insects, wild fish, birds and mammals. 

Using the unique results of the Riverfly Census S&TC has been working with local Environment Agency teams to devise appropriate targets for river invertebrates such as mayfly species but, as Paul Knight, explains:

“These targets need to be agreed on a national basis before we will be able to see any positive progress.” 

Paul Knight adds:

“Current regulations under the Water Framework Directive are simply not rigorous enough to detect the extent of the problem. This latest study supports growing concern about current guidelines relating to suspended sediment and associated organic contaminants and the need for more stringent regulation, more defined targeting and better monitoring to protect all aquatic wildlife is paramount.”

The study published in Environmental Pollution (2017) by Everall N.C. et al is titled: Sensitivity of the early life stages of a mayfly to fine sediment and orthophosphate levels. 

For more information on the Riverfly Census email or click the button below:

Impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout

Impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout

Scottish Government called upon to review its position and act now to protect wild fish.

An exhaustive new report, Impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout, commissioned by S&TC Scotland, examines all the available and up to date research on the impact of sea lice from salmon farms. The report concluded unambiguously that…

“The combined knowledge from scientific studies provides evidence of a general and pervasive negative effect of salmon lice on salmonid populations in intensively farmed areas of Ireland, Norway and Scotland.”

The report, Impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout, is published by the Norwegian Institute for Nature Research (NINA), Norway’s leading institution for applied ecological research.

It is authored by Prof Eva B. Thorstad and Dr Bengt Finstad, both internationally acknowledged for their expertise in sea lice biology and the interactions between salmon farming and wild fish.

Impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout

The report is published today and can be accessed below through our site or the NINA site

View through NINA

View through S&TC

Andrew Graham-Stewart, Director of S&TC Scotland, said:

“For many years we have maintained that the Scottish Government’s position – that there is ‘no evidence’ in Scotland that sea lice from salmon farming damage wild salmon and sea trout ‘populations’ – is untenable.

The Impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout report substantiates our view that it would be very odd indeed if the Scottish situation was markedly different to elsewhere.

We do after all have the same sea lice, which all too often Scottish salmon farm operators are incapable of keeping under control, and the same wild fish.”

Mr Graham-Stewart added:

“The forthcoming Parliamentary Inquiry provides a timely opportunity to redress the balance between the drive for growth of the salmon farming industry, at all costs, and the need to protect wild fish. We trust that the Committees conducting the Inquiry will pay close heed to the conclusions of this important report.”

Impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout
Photo: Steinar Kålås. Heavily lice-infested sea trout, causing loss of skin and thus brain to be exposed.

Paul Knight, CEO of S&TC and co-Chair of the NGOs at the North Atlantic Salmon Conservation Organisation (NASCO), said:

“At NASCO’s annual meetings Scotland has been repeatedly challenged for its systematic denial of any significant negative impacts caused by salmon farming in the west Highlands and Islands on wild salmon and sea trout.

The ‘impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout’ report vindicates the NGO stance that sea lice emanating from salmon farms are harmful to populations of wild fish, often devastatingly so. Scotland is no exception.”

In June, the Scottish Parliament’s Rural Economy and Connectivity Committee, in response to a formal Petition lodged in the Scottish Parliament in February 2016 by S&TC Scotland seeking protection for wild salmonids from sea lice from Scottish salmon farms, agreed to launch an Inquiry (scheduled this year) into salmon farming in Scotland and the issues we have raised.

Issued by Andrew Graham-Stewart (telephone 01863 766767 or 07812 981531) on behalf of Salmon & Trout Conservation Scotland

Hardy Fishing tackle donates proceeds of limited edition reel project to support our ongoing and vital Atlantic Salmon conservation work

Hardy has donated £22,500 to Salmon & Trout Conservation (S&TC) towards their salmon conservation campaigns in both Scotland and England!

The donation comes from sales of the 148 Hotspur Cascapedia limited edition reels released earlier in the year to celebrate 950 years of the Percy family – the present Head of the family, the 12th Duke of Northumberland, is S&TC’s President.

The funds will primarily be used to fund S&TC’s Scottish team giving evidence to the Scottish Parliamentary Committee Inquiry into salmon farming and its impact on wild salmon and sea trout, and also on the continuing work to limit exploitation of salmon in English coastal netting fisheries.

Paul Knight, Salmon & Trout Conservation’s CEO, said:

“This donation from Hardy is a fantastic contribution towards our salmon conservation work, and will particularly help us to collect a full evidence dossier to present to the Scottish Parliamentary Committee’s Inquiry into salmon farming and its impact on wild salmon and sea trout. 

It was a great idea to produce a limited-edition reel to celebrate 900 years of the Percy family, and extremely generous of Hardy to distribute the profits from the sale in this way.”

Paul Knight added:

It is particularly pleasing that Hardy is investing in wild fish conservation like this.  Healthy fish stocks, rivers and lakes are the foundation of good fisheries, but their protection and conservation are expensive. 

Hardy recognises this and is taking responsibility by donating towards the cost, for which we are extremely grateful.  We look to other manufacturers and retailers to follow Hardy excellent example.”    

Grant Harris, Managing Director of Pure Fishing, owners of Hardy, said during the presentation:

“This has been a really exciting project and one of multiple success for all concerned.  The team here at Hardy, Alnwick had to pull out all the stops to make sure this was a success for the trust whilst matching the high specification requirement and functionality of all of our products.

We are also delighted that our customers are actually using the reels on the river which is exactly what they were intended for whilst knowing they have supported this initiative.”

 He added:

“We are seeing more evidence than ever before that suggests the future of the Atlantic Salmon is in serious jeopardy, for this we felt that it was important to rally our resources to support such an important cause.”

Argyll salmon run crisis in the River Awe

Argyll salmon run in crisis

Catastrophic failure of salmon run in Argylls largest and most closely monitored river confirmed. Annual count is by far the lowest on record. 

Plea for Scottish Government to intervene now to halt precipitous decline of wild salmon in main intensive aquaculture production areas

 This year’s Argyll salmon run in the most closely monitored and biggest river, the Awe, is by far the lowest since records began in 1964. The annual salmon count on the River Awe has now been confirmed as only 480. The figure compares to 807 in 2016 and a five-year average of 1400. The previous lowest total was 781 in 1998.

Argyll salmon run
Rive Awe Salmon Count

The Awe is a short river, draining Scotland’s longest loch (Loch Awe), with a hydro-electric dam at its head. There is a fish lift and a counter in the dam. The flow regime is such that fish can run the river any day of the year; almost all the fish are destined for the headwaters and thus there is a full river count which is almost unaffected by the weather. The Argyll salmon run count runs from April 1 to November 30.

Roger Brook, Chairman of the Argyll District Salmon Fishery Board, said:

“This year’s salmon count on the River Awe is incontrovertible evidence that the decline in wild fish in salmon farming’s southern heartland has become critical. We call upon the Scottish Government to take action on all issues within its regulatory control.

Specifically, we ask for a review of the policy to facilitate the continued expansion of the salmon aquaculture industry without first addressing the negative impacts. Expansion of aquaculture without greater regulatory control is sounding the death knell for viable wild salmon populations in most of the West Highlands and Islands.”

Mr Brook continued:

“We plead with the Scottish Government to take this issue seriously and act decisively to protect and improve our iconic west Highland salmon and the important west coast tourist industry associated with recreational fishing. Scotland has the opportunity to create a world-leading regulatory and planning system which protects wild migratory fish and proactively seeks to address any local negative impacts.”

Andrew Graham-Stewart, Director of Salmon and Trout Conservation Scotland (S&TC Scotland), said:

“If the crisis in wild salmon numbers in the West Highlands and Islands is to be halted, Scottish Ministers must now be given a duty, and granted the necessary powers, to intervene to protect wild fish and to implement measures to prevent further damage and provide the conditions to reverse the decline in wild salmon and sea trout populations.

This means ensuring proper control on the siting of farms and the levels of sea lice on the farms. We call upon Scottish Government and its agencies to insist that future farms are sited away from the probable migration routes. Most importantly, the worst-performing existing farms, both in terms of location and lice control, should now be closed.”

Mr Graham-Stewart added:

“When in August we highlighted the low Awe salmon count, the Scottish Salmon Producers Organisation claimed the announcement had been ‘premature and over simplistic’, as ‘the majority of grilse don’t return to the Awe until the autumn’. There has never been a significant autumn grilse run on the Awe and our forewarning has proven to be entirely accurate.”

Juvenile salmon migrating from rivers in the South-West Highlands, such as the River Awe, must pass close to lice-producing salmon farms (and rainbow trout farms), not only in the immediate area but also the whole way up the west coast, before they reach open ocean, free of aquaculture. Throughout this coastal migration they are vulnerable to infestation by deadly sea lice. It is logical that, the more sea lice-producing farms that outgoing juvenile salmon have to negotiate their way past on their migration to the North Atlantic feeding grounds, the less likely they are to survive.

In June, the Scottish Parliament’s Rural Economy and Connectivity Committee, in response to a formal Petition lodged in the Scottish Parliament in February 2016 by S&TC Scotland seeking protection for wild salmonids from sea lice from Scottish salmon farms, agreed to launch an Inquiry (scheduled for early 2018) into salmon farming in Scotland and the issues raised by S&TC Scotland.

Issued by Andrew Graham-Stewart (telephone 01863 766767 or 07812 981531) on behalf of Salmon & Trout Conservation Scotland. Salmon image © David Miller

FOI Number Five – getting you the information they don’t want you to see!

As the Scottish Government continues to try to downplay the harm being caused by open-cage salmon farming, S&TC Scotland has just secured its fifth favourable decision in a row this year from the Scottish Information Commissioner. Putting information about salmon farming and its impacts - information that the Scottish Government and its agencies would rather you didn’t see - into the public domain.

In November 2017, we secured a Decision from the Commissioner, who found that SEPA was not entitled to withhold a report that had been provided to SEPA, regarding a future study into the use of emamectin benzoate (Slice) for the treatment of sea lice, to be carried out for the Scottish aquaculture industry. This future study appears to be a very clear attempt to undermine the proposed  SEPA phasing-out of the use of Slice. SEPA tried to argue that the information was subject to the exception in regulation 10(5)(f) of the Environmental Information (Scotland) Regulations 2004, that:

“...its disclosure would, or would be likely to, prejudice substantially the interests of the person who provided the information...” namely the salmon farming industry.

However, the Commissioner agreed with legal arguments put forward by S&TC Scotland, that the information about this future study related to emissions to the wider marine environment, with the result that the exception that SEPA had tried to invoke, could not apply. The Commissioner has required SEPA to disclose the information. If SEPA wishes to  appeal, it has 42 days to do so. The Decision is expected to be published very shortly – keep an eye on it HERE

Earlier in November 2017, we secured another Decision from the Commissioner who decided that Scottish Ministers had unlawfully tried to withhold information concerning  a Scottish Aquaculture Research Forum-commissioned report on the environmental impact of the sea lice medicine, emamectin benzoate (Slice). Ministers had  tried to conceal the fact that the report was peer-reviewed by six scientists, five or whom were linked to or worked for the multinational corporation that produces emamectin, Merck. Learn More

In September 2017, we secured another Decision from the Commissioner,  that Scottish Ministers unlawfully tried to withhold information naming fish farms that had breached Scottish Government trigger levels for the numbers of adult female sea lice on the farmed salmon Read More Here. In 2016 and 2016, we had made a number of requests for information for details of those farms that had notified Marine Scotland that the new Scottish trigger levels, announced to the North Atlantic Salmon Conservation Organization in 2016, had been exceeded, but Scottish Ministers had declined to provide the information, on the basis that to do so would cause “substantial prejudice” to the interests of the fish farmers which had provided the information. Scottish Ministers argued that the salmon farmers feared that information on the performance of individual fish farm sites could be used to undermine commercial contracts through undue media pressure, or to call for local authorities and other regulators to revoke consent for sites reporting higher sea lice levels. Scottish Ministers supported the industry in those fears. After two separate and detailed referrals, the Scottish Information Commissioner ruled that arguments put forward by S&TC Scotland for full disclosure of the names of the most lice-affected fish farms in Scotland were correct and that the Scottish Ministers had unlawfully tried to prevent public scrutiny.

Two earlier 2017 Decisions had also shown that Scottish  Ministers were not complying with freedom of information law by failing to respond in time and within statutory deadlines to requests made by S&TC Scotland. See Decision 038/2017:  Salmon & Trout Conservation Scotland and the Scottish Ministers  -Whether a request was complied with as soon as possible - See Here and Decision 063/2017:  Salmon & Trout Conservation Scotland and Scottish Ministers - Control of sea lice on fish farms: failure to respond within statutory timescales - See Here.

Guy Linley-Adams, Solicitor for S&TC Scotland said:

“The right to environmental information is enshrined not just in Scottish law, but in European law and in an international convention, the Aarhus Convention, to which the UK is signatory.

Scottish Ministers and SEPA cannot keep ignoring the law, just because the information S&TC Scotland requests from them might be embarrassing or show that they lean too far towards protecting the fish-farmers from proper public scrutiny.

It must never be forgotten that the impact of fish-farms outside the cages - on wild fish, on benthic species and on the wider sea loch environment -  is of very real, substantial and legitimate public interest.”

Scotland’s worst sea lice offenders: Full Farm List

In our previous article we shared how our campaigning had lead to full disclosure of which Scottish salmon farms were not keeping their lice under control (read here). We highlighted the worst offenders, but today we bring you the full list of farms breaching the sea lice trigger levels set by the Scottish Government.*

To date, no meaningful enforcement action, such as the ordering of culls or immediate reductions in fish-farm biomass, has been taken against serial offenders.

Scottish Government’s new trigger levels of 3 adult female lice per farmed salmon (at which point a “site-specific escalation plan” to reduce lice numbers is required) and 8 adult female lice per farmed salmon (at which point, enforcement action may be ordered to harvest early, reduce biomass or cull-out a farm) are already very considerably more generous to the fish-farmers than the industry’s own longstanding Code of Good Practice (CoGP) sea lice treatment levels of 0.5 or 1 lice per fish, depending on the time of year.

The Scottish Government has a legal duty to protect and conserve wild salmon and sea trout, but this data shows it is failing to rein in the biggest threat to wild salmonids.

BE SALMON SAVVY! Use the list to check your supermarket isn't selling Scottish farmed salmon from these farms. If you spot supermarkets selling from these farms, please snap a photo of the packaging and send it in via email ( or social media (Facebook or Twitter @SalmonTroutCons).

*Note: The list covers the period extending from week 43 in 2016 (November) to week 35 in 2017 (end August) inclusive.