Agricultural Pollution – Educate, Encourage, Enforce

"Up to 2016, a staggering 95% of farms did not comply with storage regulations and 49% were polluting the river Axe. Environmental law breaking, albeit mostly through lack of knowledge, on a massive scale."

Paul Knight, Outgoing CEO Salmon & Trout Conservation writes,

S&TC’s Census Report, published in May 2019, provided evidence that the main damage done to our rivers in rural areas was a result of poor land management – especially excess fine sediment and phosphates, and pesticides.  Intensive farming, including livestock, dairy and arable, often on an industrial scale, is the main culprit.

However, farmers provide a significant proportion of our food in the UK and so we have to find a way of protecting our rivers – and the whole environment – while allowing farmers to operate efficiently.   Impossible, you may say. Actually, we don’t believe it is – there are solutions which actually benefit farmers at the same time as stopping soil, pesticides, too much phosphate etc falling into our rivers and damaging wild fish and the water ecology.   

First, though, we need to understand how rivers operate, and why every landowner has to cooperate, otherwise none of this will work.  Put simply, rivers connect headwaters to the sea, and everything in between. This connectivity means that it only takes a few non-compliant farmers to undo all the good work done by their neighbours.  There are plenty of examples – slurry run-off, pesticide and fuel spills, sediment smothering riverbeds – affecting a waterway well downstream of where the pollution actually occurred.

There is a fundamental problem we recently unearthed.  During a meeting with NFU representatives and local farmers in Wiltshire, it became clear that few farmers were aware of the Reduction and Prevention of Agricultural Diffuse Pollution Regulations 2018, designed to protect the environment and under which all farmers should be operating. The EA staffer present described it as the softest regulation launch he had ever known. Education on a massive scale is therefore required to ensure all landowners are aware of their legal responsibilities.

We have left the EU and, shortly, our farmers will be bound by a new agricultural policy to replace Europe’s Common Agricultural Policy (CAP).  This means that we have the opportunity to influence government thinking about how farmers can be rewarded for protecting fragile environments such as river corridors, but under a much more effective programme than CAP.  As stated above, all farmers in a catchment have to cooperate, otherwise the plan will fail.  

A classic example of how things could work better in future comes from the recently published Environment Agency (EA) River Axe N2K Catchment Regulatory Project Report 2019.  After years of advice to farmers on Devon’s River Axe, and the very occasional farm inspection, the river was in a terrible ecological state, as confirmed by S&TC’s Axe Riverfly Census data.  Up to 2016, a staggering 95% of farms did not comply with storage regulations and 49% were polluting the river Axe. Environmental law breaking, albeit mostly through lack of knowledge, on a massive scale.

The EA then intervened and, with £120,000 of resource, carried out 86 farm audits (well above national average) and encouraged farmers to invest in 33 slurry stores, 3 silage clamps, 10 fuel stores and undertake 21 infrastructure repairs – all costing nearly £4m, so not a bad return on a £120K enforcement budget.  

However, an important message from the Axe Report is that tough regulation was threatened but was not required, at least up until the Report publication date, although time will tell as to whether behavioural change will result in long-term adherence to regulations.  Agricultural regulation had been flouted for many years because of a lack of regulation – no political commitment coupled to a lack of funding – but when the EA cracked down with some meaningful resources behind them, improvements were swift and, as a result, we hope the river will begin improving over the coming years.  The Axe example clearly shows that a combination of advice and financial incentives, supported by the threat of tough regulation, was sufficient to encourage farmers to act in the short term, but S&TC remains adamant that more resources are required for monitoring and enforcement so that land managers know they will get caught if they have the urge again to cut corners.  We completely support the continuation of subsidies for farmers, but we must have public benefit in return, rather than the old system of cross compliance under CAP, which was never properly monitored and, as a result, completely failed to protect our rivers. 

The question is, of course, will this action be sufficient to result in a lasting improvement to the river? S&TC will be re-running its Riverfly census next year to look for improvements, but we believe that the EA will need resources to make visits over the long-term to ensure improvements in water quality endure

From the evidence of our Riverfly Census, S&TC believes that a new government agricultural policy can encourage farmers to utilise methods which benefit them as well as protect the environment.  For instance, we believe that, if farmers were incentivised to embrace good soil management such as zero tillage (where appropriate), there would be benefits all round - farmers would keep their natural resource in place (soil); a more natural soil function would be encouraged (earthworms rather than ploughs), lower inputs in terms of fuel and size of equipment required and, medium-long term, increased yields – so, a bottom line benefit for farmers and better protection for rivers from sediment, chemicals and phosphate seepage.  A classic win/win scenario.

So, S&TC’s message to government is that the River Axe example gives a view of how things might happen in the future.  It needs government commitment to roll out across the country, and the Treasury to allow Defra to fund the new agricultural policy properly to allow long-term changes in the EA farm inspection regime, but if that happens, our rivers, wild fish and water ecology could receive a massive boost and we could start to reverse the degradation of the past decades – and farmers will benefit too.

As the Axe Report states,

"This evaluation clearly demonstrates the power of advice (to farmers), backed up by regulation and supported by financial incentives to create positive benefits for water quality. Neither advice, incentives nor regulation delivered in isolation of the others will generate the desired environmental improvements in water quality."

Reporting with a purpose

S&TC are a national organisation and we use evidence from local case studies to help instigate policy changes that will benefit UK wild fish populations. But, this is just part of the value - we are making all our Riverfly Census findings available so they can be used to inform local management and drive action.

Each individual river report is based on three years of surveying data. Where possible, we have linked up our findings with other existing literature and data. Using the available information we suggest where local conservation groups can focus their management efforts to achieve the best health outcomes for each of the rivers.

S&TCS writes to Scottish Ministers: MSA position on salmon farming regulation

Salmon & Trout Conservation Scotland (S&TCS) writes to Scottish Ministers to outline Missing Salmon Alliance's formally agreed position on salmon farming regulation.

Roseanna Cunningham MSP

Cabinet Secretary for Environment, Climate Change and Land Reform

Fergus Ewing MSP

Cabinet Secretary for the Rural Economy

2 April 2020

 

Dear Ministers

Regulation of salmon farming with particular reference to impacts on wild salmon and sea trout

In their 2018 reports into salmon farming, both the Environment, Climate Change and Land Reform Committee and the Rural Economy and Connectivity Committee concluded that the regulation of salmon farming was inadequate and not fit for purpose, particularly in terms of protecting wild fish from negative impacts.

There is considerable concern that the recommendations to the Cabinet Secretary on salmon farming regulation that will emerge from the Salmon Interactions Working Group (SIWG) may fall far short of what is required and thus will fail to give urgently required protection to wild fish. You will be aware that none of the members of the Missing Salmon Alliance (MSA), which includes the Atlantic Salmon Trust, Salmon and Trout Conservation Scotland, the Angling Trust and the Game and Wildlife Conservation Trust, were represented within SIWG. Indeed, wild fish representation on SIWG was restricted to those with a somewhat limited mandate.

The four members of the MSA carry between them a very substantial mandate. 

They have recently adopted a joint formal position on salmon farming regulation:

Regulation must include: 

  1. The clear identification of a Scottish public authority with the statutory function of protecting wild fish from the negative interactions of salmon farming. 
  1. The introduction of an effective, robust and enforceable regulatory system for all salmon farms, to protect wild migratory fish and proactively address all and any negative impacts associated with salmon aquaculture, including much stricter ‘backstop’ limits for on-farm sea lice numbers, coupled with independent monitoring and strict enforcement in the event of breaches, to curtail the damage being caused to wild salmon and sea trout by salmon farming. The ‘backstop’ limits should be set at an average of 0.5 adult female lice per farmed fish on any particular farm,  with the limit dropping to  0.1 during wild smolt emigration between February and June, but this would not prevent adaptive management requiring lower lice levels on particular farms if that was required.  
  1. A genuinely precautionary approach to the licensing and permitting of any new salmon farms or expansion of existing farms. 
  1. A review of the permitted biomass and location of all existing salmon farms as against their environmental impact, with a mechanism to compel reductions in biomass and relocation where appropriate. 
  1. Full transparency on the environmental impact of fish farming, including the ‘real time’ publication of on- farm sea-lice, escapes of farmed fish, use of all treatment chemicals (whether on-farm or in well boats), farmed fish mortalities and disease information. 
  1. A requirement that no salmon farming development be permitted without the prior completion of a rigorous independent cost benefit analysis of the potential impact on coastal communities, including the impact on existing local businesses and ecosystem services.
  1. Any adaptive management of fish farms, to be based on monitoring of wild fish, must be robust, independent, transparent and open to public scrutiny, with clear thresholds and deadlines for rapid action on-farm where problems are identified or suspected, and an appropriate regulator charged with enforcement of such management measures. 

MSA members have now individually published the above position:

https://anglingtrustcampaigns.net/blog/missing-salmon-alliance-update

https://atlanticsalmontrust.org/aquaculture/ 

https://www.gwct.org.uk/fishing/msa/position-statement-on-the-tighter-regulation-of-salmon-farming/ 

https://www.salmon-trout.org/2020/03/25/missing-salmon-alliance-urgent-implementation-of-new-system-of-regulation-for-fish-farms/ 

Members of the MSA therefore request that Scottish Government also adopts the same position as MSA, as you consider how to proceed with salmon farming regulation. 

Given the perilous state of wild salmonid populations, members of the MSA believe robust Government action, in line with this position, is urgently required and anything weaker will not protect wild fish sufficiently.

Yours sincerely

Andrew Graham-Stewart

Director – Salmon and Trout Conservation Scotland

Cc Graham Black, Director, Marine Scotland

Alastair Mitchell, Marine Scotland

Edward Mountain MSP, Convener REC Committee

Gillian Martin MSP, Convener ECCLR Committee

John Goodlad, Chairman, Salmon Interactions Working Group

Mike Montague, Terry A’Hearn, Peter Pollard, SEPA

Cathy Tilbrook, Nick Halfhide, SNH

Alan Wells, Fisheries Management Scotland

Sam Collin, Scottish Wildlife Trust

Issued by Corin Smith, 2 April 2020. comms@salmon-trout.org (07463576892)

Missing Salmon Alliance: Urgent Implementation of new system of regulation for fish farms

The Missing Salmon Alliance members today published updated guidance on the need for the urgent implementation of a new system of regulation for fish farms in Scotland.

Regulation must include:

1.            The clear identification of a Scottish public authority with the statutory function of protecting wild fish from the negative interactions of salmon farming.

2.            The introduction of an effective, robust and enforceable regulatory system for all salmon farms, to protect wild migratory fish and proactively address all and any negative impacts associated with salmon aquaculture, including much stricter ‘backstop’ limits for on-farm sea lice numbers, coupled with independent monitoring and strict enforcement in the event of breaches, to curtail the damage being caused to wild salmon and sea trout by salmon farming. The ‘backstop’ limits should be set at an average of 0.5 adult female lice per farmed fish on any particular farm,  with the limit dropping to  0.1 during wild smolt emigration between February and June, but this would not prevent adaptive management requiring lower lice levels on particular farms if that was required.

3.            A genuinely precautionary approach to the licensing and permitting of any new salmon farms or expansion of existing farms.

4.            A review of the permitted biomass and location of all existing salmon farms as against their environmental impact, with a mechanism to compel reductions in biomass and relocation where appropriate.

5.            Full transparency on the environmental impact of fish farming, including the ‘real time’ publication of on- farm sea-lice, escapes of farmed fish, use of all treatment chemicals (whether on-farm or in well boats), farmed fish mortalities and disease information.

6.            A requirement that no salmon farming development be permitted without the prior completion of a rigorous independent cost benefit analysis of the potential impact on coastal communities, including the impact on existing local businesses and ecosystem services.

7.            Any adaptive management of fish farms, to be based on monitoring of wild fish, must be robust, independent, transparent and open to public scrutiny, with clear thresholds and deadlines for rapid action on-farm where problems are identified or suspected, and an appropriate regulator charged with enforcement of such management measures.

NOTES

The Missing Salmon Alliance (MSA) is fighting to reverse the devastating collapse in wild salmon around the UK. By combining expertise, coordinating activities and advocating effective management solutions we can help the wild Atlantic salmon survive and thrive in our rivers and seas for the next generation.

The MSA is comprised of the following members:

Salmon & Trout Conservation, Game & Wildlife Conservation Trust, Atlantic Salmon Trust, and the Angling Trust with Fish Legal

https://www.missingsalmonalliance.org

Issued by Corin Smith, 25 March 2020. comms@salmon-trout.org (07463576892)

Environmental Land Management Scheme 2020

Environmental Land Management Scheme

Consultation 2020

Make your voice heard:

http://bit.ly/ELMS_2020

CLOSING DATE FOR COMMENTS 5th May 2020

Overview of Salmon & Trout Conservation (S&TC) Response

• The main requirement is for political commitment to finally tackle the issue of pollution by inappropriate land use - particularly relevant to our rivers and aquatic life (EA River Axe N2K Catchment Regulatory Project Report 2019)

• The continual cuts in the EA’s budget and resourcing needs urgently addressing, otherwise this ELM will fail through lack of effective monitoring and, where necessary, enforcement

• Whether it be breaches of diffuse pollution rules by farmers, deliberate release of slurry, or just ‘bad practice,’ we already have sufficient legislation in place to deal with these issues. What we need is independent monitoring, inspection and robust enforcement of ELM (See River Axe Report below on the use of the Red Tractor assurance scheme) that shows persistent offenders they are far more likely to be identified and potentially prosecuted than at present – ie a 1 in 200 chance each year of having a farm inspection

• We refence our evidence to EFRA on diffuse pollution and farming rules (attached) that shows that Codes of Practice for farmers going back to the 1980s have been saying roughly the same thing and yet we still suffer huge damage from poor land use, because there has been no enforcement ( see River Axe Report, page 17, para 11, Despite significant amounts of advice and grant aid in the last 10-15 years, there has been an absence of basic regulation).

S&TC ELMS Response 2020

6. Do you have any comments on the design principles on page 14? Are they the right ones? Are there any missing?

Salmon & Trout Conservation (S&TC) does have some concerns over the design principles. We fully support the overall objective in (a) of focusing on achieving environmental outcomes and helping to deliver Defra’s 25 Year Environment Plan and net zero target. However, there are some aspects of the design principles which require tighter definition if the proposed environmental outcomes are to be achieved:

Under (e), the proposal is that farmers, foresters and other land managers have greater flexibility over how they deliver environmental outcomes. While this might be acceptable as a general rule, there are current impacts of poor land management on rivers and watercourses that require targeted remedial action as a matter of urgency, and much closer protection in the future, if aquatic ecosystems are to be healthy and support abundant biodiversity. S&TC’s Riverfly Census data shows that pesticides, excess phosphates and sediment, much of it sourced from poor land management, impact many English watercourses, and these require specific remedial measures to restore and protect our river systems. For instance, we believe that improved soil management will solve many stressors impacting watercourses, but this requires incentives for land managers to concentrate on the specific outcome of their actions, rather than allowing flexibility which might not deliver the required result.

Under (f), you state that you wish to ensure minimal complexity and administrative burden for participants and administrators, considering lessons learned from similar past initiatives. This is a worrying objective, because S&TC believes that one of the strongest lessons learned from past initiatives is that, without sufficient monitoring and, where necessary, enforcement, environmental damage to rivers will continue. We go into more detail below under question 15, but there has to be much tighter control over land managers so that they achieve genuinely effective outcomes in terms of river protection, before they receive public subsidies. We therefore see Flexibility as a potential barrier to this new scheme achieving its environmental objectives.

Under (g), we fully support the harnessing of new technology and digital solutions if they can be shown to add value and improve the scheme design and operation. Again, we go into more detail below under 15, but if self-monitoring is to continue to be a significant part of this scheme, then participants will have to provide far better evidence that their actions have achieved the required environmental outcomes, and we believe that modern technology could have a major role to play in that scenario.

Under (i), S&TC is not in favour of re-using / improving existing systems and data. We believe that the existing system has frequently failed to protect watercourses, wild fish stocks and aquatic wildlife and that a completely fresh look is required as to how environmental objectives can be genuinely achieved. We of course appreciate that land management produces an important proportion of our food supply, but we can no longer use that as an excuse for allowing environmental damage on the scale of the past few decades, especially when we believe that solutions are available that benefit farmers at the same time as protecting river corridors – i.e. zero tillage arable farming where appropriate, which allows natural processes to improve soil quality and water permeability while keeping soil on the field rather than allowing it to run-off into watercourses during storm events, taking with it residues of chemical toxins and excess nutrients.

7. Do you think that the ELM scheme as currently proposed will deliver each of the objectives on page 8?

The objectives are:

"To secure a range of positive environmental benefits, prioritising between environmental outcomes where necessary" – as stated above, S&TC’s data has shown the significant current impact on our rivers from farming activities over recent decades. At the very least, environmental objectives that must be achieved under the new scheme include the restoration of watercourses and their future protection. We believe that this is a major priority and anything less than minimising future agricultural impact on rivers and their ecosystems must be regarded as a failure. We are well aware of the stressors on our river systems and the solutions required to address their impact, and so the proposed ELM scheme has to incentivise land managers to undertake the necessary measures or be prepared to enforce legislation and withhold payments until relevant measures are undertaken. Anything less than this will signal a failure of the system and our rivers will continue to be impacted by poor land management activities.

"To help tackle some of the environmental challenges associated with agriculture, focusing on how to address these in the shorter term" – this is exactly what S&TC means, but we are disappointed by the weak language.

As above, we know what needs to be done, and the current impacts on our watercourses need urgent remedial action under a comprehensive plan, rather than under a system where just some of the environmental challenges are addressed, which is far too ambiguous for what is required to achieve environmental objectives under the 25 Year Plan. Measures must be put in place under ELM that genuinely minimise the danger of either point of diffuse pollution entering watercourses – measures such as improved soil management, livestock exclusion from streams, effective slurry storage and disposal etc.

In summary, S&TC believes that these objectives go some way towards greater environmental protection, but that Defra needs to tighten them if the environmental objectives contained within the 25 Year Plan are to be achieved for watercourses and aquatic biodiversity.

8. What is the best way to encourage participation in ELM? What are the key barriers to participation, and how do we tackle them?

S&TC believes that the scheme should lead with sufficient incentives to encourage land managers to participate, but that participation should be compulsory, at least for those managers who have the potential to adversely impact sensitive habitats, especially river corridors. Protecting rivers on a catchment basis is essential due to their connectivity, where just a few polluters can negate all the good work done by neighbours who take their responsibilities toward river protection seriously. In these instances, the carrot of incentives must be supported by effective enforcement of those who continue to pollute rivers.

We do not wish to denigrate those land managers who have protected the particular environments within their land holdings under past schemes, and much good environmental protection work has undoubtedly been undertaken by many land managers. However, our evidence, alongside many other datasets, prove that rivers in particular continue to be adversely impacted by poor land management, and so past subsidies/cross compliance schemes have obviously been insufficient to protect rivers and aquatic biodiversity. This has to change under ELM.

S&TC believes that one of the main reasons for participation in the past has been the ease with which subsidies have been distributed with very little monitoring or enforcement of, for example, cross compliance – i.e. the widespread perception that the public should not expect environmental benefits in return for subsidies. Many land managers appear to have thought that they had little chance of being prosecuted for failing to achieve cross-compliance – a reputed 1 in 263 chance of having a farm inspected in any one year – and so took the risk. With the tightening of environmental objectives that must be included within ELM, there is the potential for land managers to shy away from the initiative because they see the monitoring/enforcement issue as making their responsibilities under the scheme too onerous.

We believe that a fair distribution of incentives to encourage the adoption of actions to achieve environmental objectives, supported by strong, well-resourced monitoring and enforcement, is essential for this scheme to be successful – it has to be financially attractive enough for widespread uptake, but sufficiently monitored/enforced to ensure compliance. It will also require education for some land managers that they can no longer expect subsidies without providing a return in terms of public benefit.

However, if voluntary participation still does not protect our watercourses effectively, S&TC believes that mandatory inclusion in the scheme, supported by strong, well-resourced enforcement for any persistent offenders, is the only way to reverse the decline in ecosystem health across many of our river systems. A voluntary approach has not worked under previous schemes and we have deep reservations that it will work under ELM unless the conditions are strong enough in terms of achieving environmental outcomes and strictly adhered to through effective monitoring.

S&TC is beginning to work with farm clusters in river catchments to monitor the success of measures designed to protect rivers, and farm clusters have been very successful in coordinating terrestrial environmental improvements in recent years. Individual land managers working within clusters are far more likely to be encouraged to adopt ELM actions and so this form of cooperation should be further encouraged throughout the country.

9. For each tier we have given a broad indication of what types of activities could be paid for. Are we focussing on the right types of activity in each tier?

Tier 1 – S&TC believes these are exactly the issues which need to be included in Tier 1 to make the scheme successful. As discussed above, data from our Riverfly Census, which used species-level invertebrate analysis to produce water quality biometrics, provided evidence that the greatest stressors on English rivers are chemicals including pesticides, sediment and excess phosphate, much of which is derived from poor land management. If the measures in Tier 1 were adopted by all farmers with watercourses running through their land, then riverine water quality and ecosystem health would undoubtedly benefit and we could begin to reverse the degradation of recent years.

However, S&TC is adamant that subsidies should be paid against outcomes, not against proposed actions. The latter will, in effect, only perpetuate the cross-compliance element of previous schemes which have been shown to be ineffective at protecting river corridors. There has to be a level of monitoring to ensure that actions have been taken and outcomes delivered before funds are received, otherwise we cannot see how environmental objectives will be achieved in anything other than a piecemeal fashion which, as already stated, is insufficient for river protection because of the connectivity issue within watercourses.

While flexibility might be a preferred option in attracting land managers to participate in ELM, we do not believe that allowing a choice of actions from a menu is sufficient to protect the water environment. We strongly believe that there should be basic standards set for all land managers, especially those with watercourses flowing through their land, to which their actions must be targeted. Those that adopt those actions responsibly and provide the required public benefit should receive subsidies, whereas those that do not should have to improve the quality of their outcomes before subsidies are paid – with strong enforcement for persistent offenders.

S&TC is pleased that the Payment by Results trial run for Defra by Natural England and the Yorkshire Dales National Park, is showing encouraging results and we believe this is the way forward to best deliver public benefit in return for subsidies to land managers.

While we would far prefer well-resourced monitoring and enforcement from the government regulator, we fully appreciate that lack of funding could make official monitoring ineffective. We could therefore support the idea of Smart self-monitoring if the evidence produced by land managers was strong enough to show proof of required environmental outcomes under the scheme – and then subsidies paid in arrears on receipt of that evidence (see response to question 15 below). Any self-monitoring must be robust with both the methods used and the results obtained being routinely published and made accessible to the wider public.

Tier 2 – S&TC supports the types of activities included under Tier 2. Our concerns for monitoring and payments are similar to Tier 1 above, but we are more encouraged that, Defra is suggesting that tier 2 payments could initially be based on actions, offering top-up payments for delivery of additional results (where output result indicators can be tested and proven to be feasible). Over the longer term, where land manager experience and confidence has been established and our methods for monitoring outcomes have advanced, we could move towards pure results-based payments for certain outputs where tested and proven to be feasible.

Again, though, monitoring is an issue and we would urge that more resources are made available by Defra/The Treasury for monitoring, both in terms of researching the effectiveness of actions under Tier 2 and compliance that environmental protection is delivered and continues over time.

As an example of our concerns, S&TC understands that the overall EA agricultural budget is £650,000 pa, but that covers more than just monitoring/enforcing the Reduction and Prevention of Agricultural Diffuse Pollution Regulations 2018 ie it includes groundwater inspections for sheep dip and pesticides, running advisory events, making planning visits and dealing with planning and grant applications. Therefore, only a fraction is for compliance visits and enforcement action.

Assuming, say, a probably optimistic half of this agricultural budget is aimed at monitoring the 2018 Regulations, that would equate to £325,000pa. DEFRA (2016 farm survey) states that there are some 106,000 farm businesses in England, so this budget would equate to just £3 per farm business in terms of monitoring and enforcement of diffuse pollution impact. While we appreciate that farm visits are evidence led, this is still a tiny fraction of the budget required to ensure minimising environmental impact on rivers and aquatic ecosystems from poor land management.

The EA states that, for 2018/2019, they made 403 farm visits, (as against the 106,000 farm businesses), since the 2018 Regulations came into force – which equates to approximately 0.4% of farms having received a visit. Even following an evidence-led campaign, this is quite obviously a totally inappropriate level of monitoring to ensure effective environmental protection and the delivery of public benefit outcomes – a 1 in 263 chance of a farm being inspected in any one year.

Tier 3 – S&TC agrees with the overall thinking around Tier 3, which is looking at landscape-scale environmental objectives. S&TC, alongside other environmental organisations relevant to watercourse and aquatic ecosystem protection, believes that management at the catchment scale is the only way to be truly effective in restoring ecosystem health within rivers and protecting them for the future. With this in mind, cooperation between the three Tiers would be essential in ensuring that, for instance, actions in Tier 1 and Tier 2, as well as contributing to local environmental protection, are planned as part of an overall catchment plan for individual river systems.

We believe this is the best way of ensuring maximum return for subsidies and grants and has the potential to provide multiple public benefits. For example, adopting natural flood defences by reversing upland drainage and restoring wetlands on marginal agricultural land, will result in storm-event run-off decreasing as more water is stored in headwaters and flood plains, resulting in more even river flow regimes to better control downstream flooding, with added benefits to biodiversity, especially within aquatic ecosystems.

10. Delivering environmental outcomes across multiple land holdings will in some places be critical. For example, for establishing wildlife corridors or improving water quality in a catchment. What support do land managers need to work together within ELM, especially in Tiers 2 & 3?

As in our response to question 8 above, farm clusters are a proven way of coordinating environmental protection actions across a catchment/landscape and should be further encouraged. However, land managers are not necessarily specialists at environmental planning and will require advice to maximise the benefit of landscape-scale measures. This should be coordinated by the government regulator but must be sufficiently funded to make the process effective.

The Catchment Based Approach (CaBA) is an inclusive, civil society-led initiative that works in partnership with Government, Local Authorities, Water Companies, businesses and more, to maximise the natural value of our river environments, and coordinating ELM with existing CaBA groups and farm clusters would be an advantage in delivering maximum public benefit, especially at Tier 2 & 3 scales. Again, though, increased resources are required to make the catchment-based planning and delivery approach truly effective.

11. While contributing to national environmental targets (such as climate change mitigation) is important, ELM should also help to deliver local environmental priorities, such as in relation to flooding or public access. How should local priorities be determined.

We have covered this issue above in terms of the part ELM could play in natural flood defence, and the knock-on benefits that would have to aquatic biodiversity. Local priorities must be determined at catchment level and, again as above, the CaBA approach has a role to play in bringing together local stakeholders to agree priorities. Once agreements have been reached, one organisation needs to take ownership of delivering actions and achieving outcomes and S&TC believes this should be the national regulator answerable to DEFRA.

12. What is the best method for calculating payments rates for each tier, taking into account the need to balance delivering value for money, providing a fair payment to managers, and maximising environmental benefit.

S&TC is not qualified to comment on this question

13. To what extent might there be opportunities to blend public with private finance for each of the 3 tiers?

S&TC is not qualified to comment on this question

14. As we talk to land managers and look back on what has worked from previous schemes, it is clear that access to an adviser is highly important to successful environmental schemes. Is advice always needed? When is advice most likely to be needed by a scheme participant?

We believe that, to make an environmental scheme successful, specialist advice is required at both the planning stage – especially for Tier 2 & 3 initiatives – and prior to, and probably during, delivery of actions. As stated above, land managers are not necessarily specialist environmentalists and so they will require guidance if their actions are to be effective in achieving objectives.

However, the Environment Agency Report on the impact of agriculture, especially dairy farming and maize growing, on the River Axe Special Area of Conservation, is highly relevant:

Despite over a decade of advisory visits in the period up to 2016, the catchment continued to decline and there were no significant improvements in farming practices. 95% of farms did not comply with storage regulations and 49% of farms were polluting the river Axe. (EA River Axe N2K Catchment Regulatory Project Report 2019)

Clearly, as the River Axe case study shows, advice alone is insufficient in protecting the environment. There must be suitable incentives to encourage farmers to participate in environmental schemes, and effective enforcement for those who persist in ignoring advice or incentives and continue to pollute rivers. The Axe report states:

"The Environment Agency secured £120,000 in local funding for a three-year regulatory farm visit campaign during the winter periods 2016 to 2019, during which time we carried out 86 farm audits. As a result of these advice-led but regulatory visits farmers in the catchment have either constructed or are in the process of constructing 33 slurry stores, 3 silage clamps, 10 fuel stores and have carried out 21 infrastructure repairs.
These infrastructure investments are estimated to total nearly 4 million pounds and were sourced by both farmers and from grant aid incentives. Or put another way, every pound spent by the Environment Agency in regulatory visits has resulted in investment of £33 for infrastructure improvements."

This case study clearly shows that the combination of the right incentives, but supported by effective regulation, can have multiple benefits for the environment and, therefore, for the public. The River Axe Report also states:

"All the improvements have been achieved without recourse to prosecutions or formal cautions, although we made it clear these would be the sanctions should compliance not be reached. A minimal number of notices were served to secure compliance and a number of warning letters were sent in response to actual pollution incidents observed during the visits.

This evaluation clearly demonstrates the power of advice, backed up by regulation and supported by financial incentives to create positive benefits for water quality. Neither advice, incentives nor regulation delivered in isolation of the others will generate the desired environmental improvements in water quality."

Apart from this excellent and ground-breaking work on the River Axe, elsewhere the EA has recorded just 14 breaches of the Reduction and Prevention of Agricultural Diffuse Pollution Regulations since April 2018 – equating to just 3.5% of the 403 visits discussed under Question 9 above (Tier 2), even though these visits were, apparently, evidence led. There has been no hard enforcement of those 14 breaches, merely the sending of 7 warning letters.

S&TC therefore believes that Defra and the EA have much to learn – and urgently replicate – from the River Axe case study.

15. We do not want the monitoring of ELM agreements to feel burdensome to land managers but we will need some information that shows what’s being done in fulfilling the ELM agreement. This would build on any remote sensing, satellite imagery and site visits we deploy. How might self-assessment work? What methods or tools, for example photographs, might be used to enable an agreement holder to be able to demonstrate that they’re doing what they signed up to do?

As already discussed, monitoring of outcomes is essential if ELM is to be more effective at achieving environmental objectives than previous schemes have been. We fundamentally disagree with the statements made on page 9 (h) that, under previous schemes, the compliance requirements placed on land managers were overly complex and demanding, or that, In the past, where land managers have been found to be in breach of their agreements, the approach to enforcement has been overly-punitive and harsh. We believe that one of the major problems with past schemes has been the failure to monitor and, where necessary, enforce compliance. The EA River Axe N2K Catchment Regulatory Project Report 2019 has shown the reality of what happens within a river catchment when land managers are not properly regulated, and frankly gives a lie to the notion that farmers have been over-burdened by legislation and enforcement in the past. The Report also clearly shows that, to be effective, the ELM scheme will require, "The power of advice, backed up by regulation and supported by financial incentives to create positive benefits for water quality…."

S&TC recently undertook an audit of agricultural codes of good practiced published by DEFRA and its forerunner departments over the past four decades. The most telling issue was that we already have all the codes and written advice we require to protect watercourses from agricultural impact. Fundamentally, what is missing is the commitment to enforce these Codes via legislation, as witnessed by the fact that a land manager has approximately a one in two hundred chance each year of being inspected by the regulator. The very soft touch regulation so far being applied in the case of the Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018 merely continues this failure. This smacks of a lack of political commitment to challenge land managers, especially the agriculture sector.

S&TC fully supports initiatives that incentivise land managers to protect the environment, but anything like cross-compliance has already been proven to be totally inadequate in achieving environmental objectives. It is S&TC’s firm belief that Defra, supported by the Treasury, has to commit far greater funds to ensure that ELM achieves its public benefit targets, otherwise the scheme is doomed to failure.

For ELM to work, it must be properly incentivised, monitored, the rules enforced and any breaches sufficiently penalised to discourage non-compliance.

However, S&TC also believes that modern digital technology could be utilised to allow a level of self-assessment for Tier 1 initiatives, but this must not be an excuse for a lack of official monitoring. The self-assessment evidence must be compulsory, submitted to the regulator within strict timelines and properly scrutinised before compliance is confirmed.

16. Do you agree with the proposed approach to the National Pilot? What are the key elements of ELM that you think we should test during the Pilot?

With the plan to run two large Pilots for Tier 1, we suggest that one is conducted with payment of subsidies up-front for actions, on a par with existing schemes, while the other has subsidies paid in arrears subject to environmental outcomes.

For Tier 2 & 3, the planning will be critical, together with the actions required to achieve the agreed target outcomes, who should deliver the actions and what advice is required to assist delivery.

However, S&TC is concerned at the lack of ambition in relying on Pilots until 2024, with the roll-out to the whole industry coming after that date. Under the Water Framework Directive, at least 75% of rivers must be in good ecological status by 2027 if the main objective is to be met. Currently, just 14% of rivers achieve GES, with poor land management one of the major reasons for lack of achievement. Leaving just three years to reverse the ecological declines due to agricultural stressors is totally unrealistic. However, as previously stated, we already have the legislative powers to enforce regulation on poor land management, and so the national regulator must be given increased resources, supported by strong political commitment, to tackle offenders now.

17. Do you have any other comments on the proposals set out in this document?

S&TC leaves the final word to the EA River Axe N2K Catchment Regulatory Project Report 2019:

"All the farms visited are Red Tractor Assured. The findings of this campaign demonstrate that Red Tractor is not effective at assuring farms are meeting environmental regulations

To maintain these improvements (gained under a three-year regulatory farm visit campaign during the winter periods 2016 to 2019), dedicated EA officers, with the skills to engage farmers will be needed. Having secured investment in basic infrastructure, further regulatory improvements could be gained by focusing on wider land management in the catchment."

The approach taken in this catchment could clearly be transferred to other priority catchments in the country to generate similar improvements for relatively small regulatory investment.

Reporting with a purpose

S&TC are a national organisation and we use evidence from local case studies to help instigate policy changes that will benefit UK wild fish populations. But, this is just part of the value - we are making all our Riverfly Census findings available so they can be used to inform local management and drive action.

Each individual river report is based on three years of surveying data. Where possible, we have linked up our findings with other existing literature and data. Using the available information we suggest where local fishing and/or conservation groups can focus their management efforts to achieve the best health outcomes for each of the 12 original Census rivers.

Some of our local reports can be found on the slider below. Alternatively, visit the Riverfly Census page and scroll down to the map.

Anne Voss-Bark Memorial Award 2020

The Anne Voss-Bark Memorial Award 2020 is now open to students.

See below for details on this exciting award, and please share with any suitable students you may know.

What is the Anne Voss-Bark Memorial Award?

Set up by Salmon & Trout Conservation in collaboration with the Arundel Arms, the Anne Voss-Bark Memorial Award 2020 offers students:

  • One week work experience with the West Country Rivers Trust; learning catchment management and water science from the Trusts eminent scientists
  • Two day fly fishing course
  • Complimentary stay at the Arundell Arms hotel during the work experience
  • £250

The work experience for the winning student will be organised for this autumn.

Who is the Anne Voss-Bark Award open to?

The award is open to young fisheries or aquatic students and offers an unbeatable opportunity to study the practical elements of river restoration and management.

What does a previous winner say?

Mark Fordham, winner of the 2019 award said:

"…..the placement has been a fantastic experience – and has allowed me to apply the information I have learned from my course to real life scenarios and project work. I have learned a massive amount during the placement, and cannot thank the team at West Country Rivers Trust enough. I’d also extend my thanks and gratitude to Adam, David, Alex and the rest of the team from The Arundell Arms. I would highly recommend the opportunity to anybody interested in this area of work – it will deepen your understanding of the subject, and inspire you to learn and achieve more!"

Who was Ann Voss-Bark?

Anne Voss-Bark was a dedicated conservationist and prominent hotelier. Her love of fly fishing made her aware of changes in the countryside detrimental to our rivers and fish. She worked tirelessly to see this demise reversed.

Anne was a strong supporter of the S&TC (then S&TA), the only UK fisheries campaigning charity. She was a Council Member, Vice Chairman and finally Vice President of the charity.

Anne, with others, also founded the West Country Rivers Trust, embracing the concept of total river management.

Anne will also always be well-remembered as the perfect hostess at the Arundell Arms in Lifton, Devon, which was rather run down on acquisition but developed by her over nearly 50 years into today’s eminent fishing and country sports hotel.

How can students apply for the Anne Voss-Bark Award 2020?

Wild fish and their habitats were of great importance to Anne, and we look for the same level of  passion in our applicants.

To apply, in no more than 500 words explain what this work experience opportunity means to you, why you should get this opportunity, and how it would benefit you.

Applicants will need to be available to undertake the placement between the 22nd - 28th August 2020

The Closing date for applications is 31st May 2020.

To submit an entry or for further information on the Award, please contact Dr Janina Gray, Head of Science at S&TC by email on: janina@salmon-trout.org

S&TC launches first SmartRivers hub in Scotland

S&TC launches first SmartRivers hub in Scotland in partnership with Flow Country Rivers Trust.

The River Halladale is set to become the first river in Scotland to join SmartRivers, as Salmon and Trout Conservation continue trials of the innovative scheme.

The scheme, born out of the Riverfly Census, uses aquatic invertebrates as a diagnostic test to tell us about the health of rivers and possible pollutants affecting wild fish populations.

Nick Measham, S&TC Deputy CEO said:

 “We’re delighted to be able to support Flow Country Rivers Trust with our SmartRivers programme. SmartRivers is what S&TC is all about, turning science into meaningful real-world action, that here and now improves outcomes for wild fish and the wider habitat.  We are very much looking forward to working with FCRT over the coming years.”

image1

Quick and easy to deploy, but also producing powerful information. Polluters of rivers and streams in England have already been forced to take action.

"SmartRivers Delivering Results"

SmartRivers provides both information to assist with catchment management decisions, as well as establishing an insurance policy for rivers in the form of a benchmark of their health. Real world empirical evidence about the diversity of invertebrate species which form the foundation of the food web in rivers will support the indicative monitoring of conductivity, pH levels and fry numbers.

Reuben Sweeting, Head Ghillie on the River Halladale said:

“SmartRivers is the final piece of the puzzle.  It complements the range of monitoring already being carried out, helping to develop a fuller picture of the health of our rivers and, crucially, allowing us to better understand the potential they hold.

 Being part of the team to bring SmartRivers north to Scotland for the first time is very exciting.  With the opportunity to attain professional level benchmarking, combined with sampling and identification training, the benefits will be felt by all involved.”

A comprehensive online and field based training scheme, 1-2-1 support and good use of information technology, including a dedicated S&TC Invert ID App, ensures that local community groups themselves are able to monitor the water quality in their rivers to a near-professional standard.

Lauren Mattingley, SmartRivers Project Manager S&TC said:

 “We are overjoyed to be extending our water quality work into Scottish rivers. Ensuring young salmon and trout are as fit and healthy as possible before they migrate to sea is crucial for them to successfully complete their life cycles.

 It is astounding that tiny invertebrates can give us such vast insight into the quality of the water our young fish are being exposed to. Working with the FCRT volunteers on the Halladale is going to be fascinating.”

Benchmark monitoring on the River Halladale will be carried out in spring and autumn 2020. The first independent monitoring by the volunteers, under the auspices of the Flow Country Rivers Trust, will occur in spring 2021.

Alan Youngson, Scientific advisor, FCRT

"Over the last few years the FCRT and the local Fishery Boards have worked hard to build a better picture of the northern rivers and the salmon populations that they support. However, we still know very little about the invertebrate populations that the fish depend on for food. We look forward to learning much more from the professionals driving the Smart Rivers project."

John Mackay, Chairperson, Flow Country Rivers Trust said:

 “Currently the North of Scotland rivers are in very good health, but we are mindful of the deteriorating situation across the UK. We have a database of the juvenile numbers, biomass density and the water conductivity for all the 10 rivers in the FCRT area. The Smart Rivers project to measure the insect food supply will add to this database and provide a benchmark, which will hopefully give us advance warning of a change in our environment.”

 For more information about SmartRivers and how it could support your river management activities, please email: smartrivers@salmon-trout.org

 Please note: We can only run courses with groups of around 10 volunteers and not for individuals. However, if you are struggling to establish a 'hub' group your local Rivers Trust or Wildlife Trust may be able to help.

ENDS

Issued by Corin Smith comms@salmon-trout.org (T: 07463 576892)

Reporting with a purpose

S&TC is a national organisation and we use evidence from local case studies to help instigate policy changes that will benefit UK wild fish populations. But, this is just part of the value - we are making all our Riverfly Census findings available so they can be used to inform local management and drive action.

Each individual river report is based on three years of surveying data. Where possible, we have linked up our findings with other existing literature and data. Using the available information we suggest where local fishing and/or conservation groups can focus their management efforts to achieve the best health outcomes for each of the 12 original Census rivers.

Some of our local reports can be found on the slider below. Alternatively, visit the Riverfly Census page and scroll down to the map.

Change of Chief Executive at Salmon & Trout Conservation

S&TC’s CEO, Paul Knight, is to retire at the end of June and Nick Measham, currently Deputy Chief Executive, will take over the reins of the UK’s premier wild fish charity.

Paul Knight stands down on June 30th after 26 years with the organisation, 18 of which have been as CEO, although he will continue for a further year with some part-time consultancy work, mainly connected to his Co-chairmanship of the NGOs at the North Atlantic Salmon Conservation Organistion (NASCO).

Paul Knight and Nick Measham, third and fourth from right respectively.

During Paul Knight’s tenure, the organisation evolved from being the governing body for game angling into a fisheries charity (2008), changed its name from Salmon & Trout Association (S&TA) to Salmon & Trout Conservation (S&TC) in 2016, and had two office moves from Fishmongers’ Hall, culminating in its first ever dedicated HQ, which is now located in Wiltshire.

Above all, the charity has gradually developed the focus of its work from being an angling interest group to a fisheries conservation organisation with policies built on sound scientific evidence.  S&TC now sees angling as being a dividend of its work to create healthy wild fish stocks, water quality and freshwater and marine habitats, and its membership base is still mainly anglers, albeit those with a vision of their place within the wider water environment and their critical role in its future protection

Paul Knight had this to say about his time at S&TC, 

“I have been extremely proud to work for this organisation for a quarter of a century, during which we made some substantial changes to the way in which we operate.  I am very grateful to the six Chairs, all the Trustees and, before them, Council and Committee members, and of course the many volunteers at branch and national levels, all of whom have helped make my job so enjoyable.  I am handing over to a very able successor in Nick Measham, with whom I have worked for five years and so continuity is assured.  Despite our hard-won achievements over the years, there is still much to do to protect wild salmon and trout and the water environments on which they depend, and I wish S&TC, Nick and our tremendous staff the very best for the future.”  

Nick Measham has a background in investment management and a near life-long fascination with rivers and fish. He joined S&TA, as it then was, in 2015.  He project-managed S&TC’s highly successful Riverfly Census initiative and oversaw the expansion of freshwater campaigns to improve water quality and riverine habitat, and still found time to be an extremely effective fundraiser.

Nick Measham said,

“I am excited to take on the challenge to build on our achievements under Paul Knight to protect wild salmon and trout from the harm wreaked by over-exploitation, fish farming, poor water quality, land management issues and over abstraction. I inherit a talented and committed team and together we will strive to carry forwards our evidence-based advocacy for wild fish and their habitats.”   

High-frequency phosphorus monitoring for water quality management

Using high-frequency phosphorus monitoring for water quality management: a case study of the upper River Itchen, UK

Gary R. Fones & Adil Bakir & Janina Gray & Lauren Mattingley & Nick Measham & Paul Knight & Michael J. Bowes & Richard Greenwood & Graham A. Mills

Abstract Increased concentrations of phosphorus (P) in riverine systems lead to eutrophication and can contribute to other environmental effects. Chalk rivers are known to be particularly sensitive to elevated P levels. We used high-frequency (daily) automatic water sampling at five distinct locations in the upper River Itchen (Hampshire, UK) between May 2016 and June 2017 to identify the main P species……..

Read the full paper HERE

Dr Janina Gray, Head of Science & Environmental Policy at S&TC said: 

"This peer-reviewed article has come from our phosphate (p) monitoring work on the Itchen. It highlights the spiky nature of P, which is typically missed in the EA’s current monthly monitoring regime, and the need to better understand the impact these spikes could be having on river ecology. As a next step, S&TC, alongside EA and HIWWT, have joint funded a PhD at Nottingham University, which started in Sept 2019, to investigate the ecological impact of the P spikes."

Nick Measham, S&TC Deputy CEO said:

"We have already taken this science and turned it into action. The work underpinned changes to watercress companies’ discharge permits on the Itchen and contributed to a massive reduction of this pollutant in the river. 

The spiky nature of the discharge implies that the EA’s monthly sampling, combined with permit limits set in terms of annual averages, does not provide the protection our rivers need. Permit reform and the use of monitoring technology is urgently required. The current regime makes no sense.

Much more remains to be done but this is a start."

 

S&TC Response: Sea trout netting season. Yorkshire and the North East

S&TC Response: Length of the netting season for sea trout in Yorkshire and the North East

Salmon & Trout Conservation (S&TC) does not believe that any coastal mixed stock fishery (MSF) netting for sea trout should take place.  We consider that the Environment Agency (EA) made the correct decision in closing the MSF for salmon on the north east coast, based on salmon stock assessments which, although in need of review for the way in which they are calculated, at least give a broad indication as to the health or otherwise of regional salmon populations.  We do not believe that the same work has been carried out to accurately identify the status of English sea trout stocks, and certainly insufficient scientifically robust information is available on which to base a decision as to whether an MSF should be operated for sea trout in the north east coastal region.  This is particularly important as the EA acknowledges that sea trout catches were heavy during the trial season in 2019, suggesting that at least some individual river stocks will have been significantly impacted by the fishery, and would be even more so in an extended season.

Both the North Atlantic Salmon Conservation Organisation (NASCO) and International Council for the Exploration of the Seas (ICES) consider MSFs for salmon to be poor management practice, principally because they make it extremely difficult to manage individual river stocks effectively.  Having taken the correct decision to close the MSF for salmon on the north east coast, we fail to see why a different decision should be acceptable for sea trout, especially when there is less stock information available for the species - though the strong likelihood is that the fishery is indeed indiscriminately exploiting sea trout populations from the eastern English and Scottish rivers.  Even so, we note that the EA states in its supporting paper:

“The majority of the salmon populations in England exposed to the beach net fishery are assessed as ‘probably at risk’. Also seen to be ‘probably at risk’ is a number of sea trout stocks contributing to the coastal net fishery - indicating a precautionary management approach should be adopted."

S&TC therefore asks, if these same classifications for salmon stocks were deemed sufficient grounds to close the MSF for that species, why is it considered acceptable to continue killing sea trout under similar circumstances?  Also, If NASCO and ICES consider coastal MSFs for salmon to be poor management practice, why are MSFs not considered the same under sea trout management?

S&TC therefore believes that the coastal beach net fishery for sea trout should be completely suspended - with appropriate compensation paid to netsmen for relinquishing their licences - at least until more work is undertaken to better assess the status of sea trout stocks in England, and in particular for those rivers impacted by the fishery.  What is good for salmon is equally valid for sea trout and we believe that to continue the fishery, let alone extend its season, should be considered poor management practice, quite apart from any conservation measures which should be imposed on individual river sea trout stocks pending better assessment of their status.  As the EA’s supporting paper states, management decisions should be taken under the Precautionary Principle – in the present circumstances, that should indicate the need to close the fishery.

S&TC therefore strongly advocates that there should be no extension to the sea trout netting season and that consideration should be given to closing the fishery altogether, pending further assessments of individual river stocks so that future management and conservation decisions are taken in the light of the most up to date scientific evidence available to managers.

Scottish Ministers’ lamentable failure to regulate salmon farming

Scottish Ministers’ lamentable failure to regulate salmon farming to protect wild fish continues, while industry’s relentless expansion gathers pace

 Almost two years after first Parliamentary report said  “the status quo is not an option”, S&TCS, other NGOs and Scottish community groups warn that their next step is to call and campaign for a boycott of Scottish farmed salmon

ISSUED: 20 Feb 2020

As the comprehensive Scottish Parliamentary inquiry reports on salmon farming from 2018 continue to languish on the shelves without Scottish Ministers taking any meaningful action on the reports’ recommendations, Salmon and Trout Conservation Scotland (S&TCS), other NGOs and Scottish community groups are saying “enough is enough” and issuing an ultimatum.

Almost two years after the Environment, Climate Change and Land Reform (ECCLR) Committee issued its report in March 2018 and 15 months after the Rural Economy and Connectivity (REC) Committee reported in November 2018, that the “status quo” in terms of the regulation of the salmon farming industry was not an option, the old regulatory system remains in place  and is still failing wild salmon and sea trout.

ECCLR: http://bit.ly/ECCLR_salmon_farming

REC: http://bit.ly/REC_salmon_farming

Andrew Graham-Stewart, Director of S&TCS, said:

“In January 2019 Cabinet Secretary Fergus Ewing committed to making ‘tangible early progress’ on the findings of the inquiry. He has not honoured that commitment. He set up two working groups to address the impacts of salmon farming on wild fish. Over a year later, these groups are way behind schedule, are still deliberating and there is no timeline for them to reach any conclusions.

“We no longer have any confidence that introducing effective regulation of salmon farming is a Scottish Government priority. We have been as patient and as trusting of Scottish Government as we can be, but the time for prevarication and procrastination is over and we are now left with no option but to issue a simple ultimatum.

“Unless Scottish Ministers have confirmed by Easter that they are putting in place appropriate statutory and/or regulatory measures to protect wild salmon and sea trout and that these measures will be in place and in force by the end of 2020, then S&TCS, together with many other organisations supporting this statement, will call and campaign for a full and complete boycott of all Scottish farmed salmon products.

If we have to go ahead with this, it will be the fault of Scottish Government.”

Relentless growth of the industry has continued

Despite the REC Committee being “of the view that urgent and meaningful action needs to be taken to address regulatory deficiencies as well as fish health and environmental issues before the industry can expand” (Recommendation 2), between March 2018 (when the ECCLR Committee’s Report was published) and December 2019, salmon farm planning permissions for an additional 76,000 tonnes of biomass have either been granted or are in the planning process; this breaks down into 28,754 tonnes planning permission granted, 14,370 tonnes planning permission applied for or pending and 33,105 tonnes screening and scoping applied for. 76,000 tonnes equate to almost 50% of the actual tonnage of farmed fish harvested in 2018.

Guy Linley-Adams, solicitor to S&TCS, said: 

“Scottish Ministers need to call a halt to any more expansion of the industry until appropriate regulatory measures are in place to protect the environment and nature. The REC Committee called for a moratorium in all but name, but there were some silly games in the use of that word. 

“Most importantly, rather than simply waiting and hoping for the fish farming industry to agree to controls, when that industry clearly feels any regulation is contrary to its commercial ambitions and priorities, the Scottish Government must do what it was elected to do - it must actually govern - in this case to protect Scottish wildlife.

“If Scottish Ministers fail to deliver the required protections, at very best, they will be guilty of presiding over the managed decline of wild salmon and sea trout in the west Highlands and Islands”. 

For the avoidance of doubt, vital statutory or regulatory measures must now include:

  • The clear identification of a Scottish public authority with the statutory function of protecting wild fish from the negative interactions of salmon farming
  • The introduction of an effective and robust regulatory system for all salmon farms, including much stricter limits on-farm sea lice numbers, to curtail the damage being caused to wild salmon and sea trout by open cage salmon farming
  • A genuinely precautionary approach to the licensing and permitting of any new salmon farms or expansion of existing farms
  • A review of the permitted biomass and location of all existing salmon farms as against their environmental impact, with a mechanism to compel reductions in biomass and relocation where appropriate
  • Full transparency on the environmental impact of fish farming, including the ‘real time’ publication of on- farm sea-lice, escapes of farmed fish use of all treatment chemicals (whether on-farm or in well boats), farmed fish mortalities and disease information; and
  • A requirement that no salmon farming development be permitted without the prior completion of a rigorous independent cost benefit analysis of the potential impact on coastal communities including the impact on existing local businesses.

A 4 page brief explaining in detail the context and background to the decision to issue an ultimatum can be found: HERE

The ultimatum and potential boycott are endorsed and supported by the following organisations so far:

Angling Trust

Community of Arran Seabed Trust (COAST)

Craignish Restoration of Marine & Coastal Habitat (CROMACH)

Fairlie Coastal Trust

Friends of Loch Etive

Friends of the Sound of Jura

Loch Visions

North and West District Salmon Fishery Board

Open Seas

Orkney Trout Fishing Association

Save Seil Sound

Scottish Creel Fishermen’s Federation (SCFF)

Scottish Salmon Think-Tank

Sea Change Wester Ross

Sealife Adventures

Skye Communities for Natural Heritage

South Skye Seas Initiative

Tay Ghillies Association

Added since news release:

Coastal Communities Network Aquaculture Sub-Group

Eigg Environmental Action Group

Friends of Loch Creran

Salmon Aquaculture Reform Network Scotland (SARNS)

The Meikleour Arms

Tay Salmon Fisheries

North Atlantic Salmon Fund US (NASF US)

North Atlantic Salmon Fund Iceland (NASF Iceland)

Atlantic Salmon Federation (ASF)

Ulster Angling Federation

Salmon Watch Ireland (SWIRL)

If your organisation wishes to join the coalition calling for regulation please contact comms@salmon-trout.org

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