Agricultural Bill: Is a ‘Green Brexit’ possible?

The first major Agriculture Bill for over 70 years has now been published, promising a cleaner, greener and healthier environment post Brexit

Currently farmers receive €4 billion in subsides each year, which is divided up related to the total amount of land farmed. For current subsidies farmers do not need to ‘do’ anything.

The new Bill proposes farmers are paid for delivering public goods; things we cannot buy in a shop, like clean water, flood attenuation, thriving wildlife and healthy soils.


Funding a 'Green Brexit'

The headlines are good. But as with everything, the devil will be in the detail.

This new approach will need substantial investment and coordination to ensure the right public goods happen in the right places for people and wildlife.

And the big elephant in the room is the funding. How do the Government plan to fund their ‘Green Brexit’? No details have been given on this so far.


Carrot vs Stick

The Government reiterated at the launch that they were committed to:

“maintaining a strong regulatory baseline, with enforcement mechanisms that are proportionate and effective”.

This is where we at S&TC have the greatest concern.

Current enforcement is just not fit for purpose. It is totally under-resourced.

We are all for having a big juicy carrot for farmers, but it must be accompanied by an equally proportionate stick where required.

The data from our own Riverfly Census indicates that many rivers in England and Wales are suffering from the impacts of excess phosphates and fine sediments from poor agricultural practices. This impacts wild fish populations, from smothering their spawning redds, to reducing the invertebrates they feed on.

For the small minority of farmers which do pollute, sometimes repetitively, strong action must be taken.


What happens next

The Bill proposes a long timetable, where the current system of payments under the Common Agricultural Policy will continue until 2021, then a seven-year transition period to the new system, where the old payments will gradually taper off.

Like most environmental charities, we have lobbied for years for this vision where farmers are rewarded for delivering for the environment- creating a sustainable future for farming and the environment alike.

We will see over the next few months, as the Agriculture Bill makes its way through Parliament, if that vision can survive.

However, in order to achieve a truly cleaner, greener and healthier environment post Brexit, enforcement, or the current lack of it, must be addressed too.

To help us take action against agricultural pollution visit our ‘see it, photograph it, report it’ campaign.


By Dr Janina Gray, Head of Science & Policy at S&TC

Loch Roag Sea Lice: SSPO Defence Falls Flat

Mea culpa……mea what?

On September 3 we issued a news release detailing the deaths, in the Blackwater River (Isle of Lewis), of a substantial proportion of this Hebridean system’s wild adult salmon run.

Wild Adult Salmon Run Decimated By Sea Lice


The tip of the iceberg

The corpses removed from the tidal Sea pool were likely just the tip of the iceberg with many more dying out in the sea loch.

The underwater video of a moribund wild salmon, infested with and being eaten alive by many hundreds of sea lice and gasping for oxygen, made for disturbing viewing.

A week later, on September 10, BBC TV One’s The One Show aired a short and graphic film linking the deaths in the Blackwater to very high numbers of lice and mortalities, again recorded on video, at the nearest salmon farm to the river in Loch Roag, the sea loch into which the river flows.

The BBC programme and our earlier news release triggered widespread media attention – and rightly so, as this was undeniable evidence of catastrophic sea lice infestations of both farmed fish and wild fish.


Loch Roag sea lice

The only reasonable explanation for the wild fish deaths is that the sea lice, numbering up to 700 on each wild fish, had reached such high levels in the loch because the huge number of lice-infested host fish on the salmon farms had released an epidemic of sea lice larvae into the loch.

The Fish Health Inspectorate, a Scottish Government agency, carried out tests on affected fish and concluded that no other factor was involved.

There can be absolutely no doubt that the source of the infestations was local salmon farms.

On the nearest farm, adult female lice numbers in August reached 13 times the industry’s Code of Good Practice. Incoming wild Blackwater salmon, held back by low water on the river, had been forced to wait in Loch Roag, close to the farms and exposed to sea lice larvae in numbers many orders of magnitude higher than any natural background. They never had a chance.


Salmon industry reaction

Two weeks after we broke this story it is perhaps opportune to consider the reaction from the salmon farming industry to this evidence of the devastating impact on wild fish when on-farm lice numbers explode.

One might imagine there would at least be a formal admission by the local farm’s operators (The Scottish Salmon Company, with its registered office in Jersey) that they were at fault, indeed something of a mea culpa.

But no, not a chance.

They and their industry’s spokespersons have shown not the slightest hint of contrition, rather they have fallen back on the usual response of denial and obfuscation.

The industry’s response was encapsulated in an SSPO press release on September 6, containing the following gem:

“Lice occur naturally in places like river mouths, where there is low water flow and a lot of returning wild fish”.

In other words, the SSPO was trying to suggest that the wild fish deaths were simply a natural phenomenon and nothing to do with them!


SSPO and The One Show

When the SSPO was formally challenged by a wild fish representative on Lewis for any evidence of similar sea lice infestations, past or present, on wild salmon in rivers, but outside the salmon farming areas, there was stony silence.

On The One Show on September 10 the SSPO’s CEO maintained that only “one or two” fish on the Loch Roag farm were badly diseased and lice-infested. At this point the drone footage of the farm, playing behind her bland assurances, showed a multitude of fish in the cages with white heads, the classic sign of massive sea lice damage!

Interestingly, the only industry voice showing any kind of recognition of the gravity of the situation has been a Norwegian online salmon farming news-site, which castigated The Scottish Salmon Company and the SSPO for their  failure to respond adequately to “proof of such appalling practice”, accusing them of ,

“Weak judgment at several levels, which should necessitate appropriate consequences for the perpetrators”.

It seems, however, that major parts of Scotland’s salmon farming industry still have fundamental issues with truth and integrity. Plus ca change.


River Itchen pollution: Alresford Salads trial chlorine-free cleaning products

Is the end of chlorine-based cleaning products at Alresford salad washing plant finally in sight?

Finally, it appears Alresford salad washing plant is planning to stop using chlorine-based cleaning products.

This would mean that there would no longer be any products used to wash the site’s equipment that could react to form chloramines, which are highly toxic to water life even in very low concentrations in water.


A small win for S&TC

At S&TC we have been campaigning for this for a long-time.

Our own Riverfly Census invertebrate data and phosphate monitoring on the Itchen in recent years indicate that the river is far from a pristine chalkstream.

We feel it is extraordinary that chlorine products are ever allowed to be discharged, insufficiently treated, into any UK river, let alone a Special Area of Conservation (SAC) such as Itchen, the most protected under EU legalisation.

This, however, would only be a small potential win. It is important to remember that any chemicals used to disinfect and clean are, by their nature, toxic.

We do not believe any of these chemicals should be discharged into an SAC river.


More sustainable solution still needed

Applying the precautionary principle, the solution is easy- connect the discharge to the main sewer, as nearby competitor, Vitacress, has already done on the Bourne Rivulet.

Yes, this would be at a cost, but should a multi-million pound industry really be allowed to use an SAC to dispose of chemical waste?


Next steps

On the 10th September, Alresford salad washing plant began a 6-week trial into the new chlorine-free cleaning products for its night-time washing; during which time the EA has requested monitoring of the discharges. Following this:

  • The EA envisage that the updated risk assessment will be submitted to them by the end of October
  • The EA will then undertake consultation with Natural England in mid-December
  • The EA plan to consult the public on their position in February 2019

As always, we will continue to provide updates via our website, social media and email.


Imported pesticides in our chalkstream?

It is worth noting that we have wider concerns beyond the nighttime washing effluent.

We also have concerns about whether pesticides, which may be washed off imported salad that is being processed and bagged at Alresford, could also be ending up in the Itchen.

We plan to do more monitoring to assess this risk and will be requesting to see the EA’s official policy on protecting our rivers from the risks of chemicals washed off imported goods and discharged directly into our watercourses.

In the meantime, I’ll be washing my own salad!


Words by our Head of Science & Policy, Dr Janina Gray

High resolution monitoring is essential for river conservation

This is a re-posting of an original article from Environmental Technology


High Resolution Monitoring on the Itchen

Working on behalf of Salmon & Trout Conservation (S&TC), researchers from the University of Portsmouth have been investigating nutrient concentrations in the Upper River Itchen, in Hampshire, UK, to better understand where phosphorus is coming from and how it is impacting river ecology.

The work has been underway for over three years and Lauren Mattingley, Science Officer for S&TC says:

“Continuous monitoring of phosphorus has improved our understanding of nutrient dynamics in the Itchen.

To date the results from this monitoring have influenced the lowering of discharge limits from watercress companies and trout breeding farms.

The behaviour of phosphorus in rivers is relatively poorly understood, and this is often reflected in water quality standards that, in our opinion, lack the scientific evidence to adequately protect the ecology of the UK’s diverse water resources.

Research such as that which we have commissioned on the Itchen is essential to set informed phosphorus permits to protect water life.”



The Itchen is a world famous chalk stream; renowned for its clear water and high quality fly fishing.

Designated a ‘Special Area of Conservation’ the river supports populations of water-crowfoot, Southern damselfly, Bullhead, Brook lamprey, White-clawed crayfish and otters. The upper river does not suffer from wastewater treatment works discharges, but does support two watercress farms, which have been the focus of initiatives to reduce phosphate concentrations.

S&TC is the only UK charity campaigning for wild fish and their habitats. The organisation’s goal is for UK waters to support abundant and sustainable populations of wild fish and all other water-dependent wildlife. Within its ‘Living Rivers’ campaign S&TC is seeking to tackle two of the major causes of poor water quality – fine sediment and phosphorus. The Itchen is therefore acting as a pilot river for their water quality monitoring initiatives.

Phosphorus in fresh water is a major concern globally; mainly because of its role in the formation of algal blooms and eutrophication, which have a harmful effect on water quality and habitats. Under certain conditions, raised phosphate concentrations contribute to the proliferation of nuisance phytoplankton as well as epiphytic and benthic algae.

Diffuse sources of phosphate include storm water and agricultural run-off from land, and point sources include septic tanks and wastewater discharges from industry and sewage treatment works. Soluble reactive phosphorus (SRP) is the main concern, because of its availability for aquatic organism growth, but other forms of phosphate such as particulate phosphate can contribute to nutrient enrichment.

The EU’s Water Framework Directive (WFD) required the UK to achieve ‘good status’ of all water bodies (including rivers, streams, lakes, estuaries, coastal waters and groundwater) by 2015, but in 2012 only 36% of water bodies were classified as ‘good’ or better.

The UK Technical Advisory Group (UKTAG) published recommendations in 2013 to revise the standards for phosphorus in rivers, because those set in 2009 were not sufficiently stringent - in 75% of rivers with clear ecological impacts of nutrient enrichment, the existing standards produced phosphorus classifications of good or even high status! DEFRA, therefore, revised the phosphorus standards to lower concentrations. However, the SRP concentration limits vary widely according to the location and alkalinity of the river.

Recognising a gap in the understanding of the relationship between phosphorus and aquatic ecology, S&TC has a unique agreement with the Environment Agency (EA) in Hampshire in which key environmental targets have been established for the Rivers Itchen and Test to help drive ecological improvements. The agreed targets are set around the number of key water insects that should be expected in a 3-minute kick-sweep sample. The targets are for the middle and lower reaches of the catchment to support at least 500 freshwater shrimps (Gammarus) and 10 separate mayfly species - all of which are susceptible to different forms of pollution, so their presence provides a measure of the river’s health.

S&TC has also conducted research investigating the effects of fine sediment and SRP on the hatching of the blue winged olive, Serratella ignita (Ephemerellidae: Ephemeroptera) a crucial component of the aquatic food chain. The results found that a cocktail of SRP and fine sediment at concentrations exceeding those found in many UK rivers (25 mg/L fine sediment and 0.07 mg/L phosphate) caused 80% of the eggs in the experiment to die. This unique research highlighted the environmental damage caused by phosphorus beyond eutrophication.


Water sampling and analysis

Five automatic samplers have been strategically located on the river, each collecting daily samples. This generates 120 samples per 24 day cycle, which are collected and transferred to the Portsmouth laboratory. The samples are split into three for the analysis of Total Phosphate, Soluble Reactive Phosphate (SRP) and Total Dissolved Phosphate (TDP).

To accommodate such a high volume of work, the lab in the University of Portsmouth’s School of Earth & Environmental Sciences employs a QuAAtro 5-channel segmented flow autoanalyzer, from SEAL Analytical.

“The QuAAtro has been in heavy use for over 9 years,”

says Senior Scientific Officer Dr Adil Bakir.

“It has been employed on a number of academic and commercial research projects, and is also used for teaching. As a 5-channel instrument, we are able to study phosphate, nitrate, nitrite, ammonia and silicate, but our work on the Itchen is focused on the different forms of phosphate.”

The University of Portsmouth’s Environmental Chemistry Analytical Laboratory provides analytical and consultancy services for businesses, universities and other organisations. Dr Bakir says: “With the QuaAAttro we are able to analyse diverse matrices including river water, sea water and wastewater, and with automatic dilution and high levels of sensitivity, we are able to measure a wide range of concentrations.”


Developing effective discharge consents

The analytical work undertaken by the laboratory at the University of Portsmouth has greatly improved the understanding of the ecology of the River Itchen and thereby informed the development of appropriate discharge consents for the watercress farms.

Effective 1st January 2016, new discharge permits were issued by the Environment Agency that set limits on phosphate discharges to the River Itchen system. For the Vitacress Pinglestone Farm these limits were set at 0.064 mg/L and measured as an annual mean increase compared to the inlet sample. S&TC now works closely with Vitacress, monitoring immediately downstream of the discharge so that the effects of the new discharge limit can be effectively assessed.

Looking forward, Lauren says:

“The lessons that we have learned on the Itchen are transferrable, and do not only apply to chalk streams. All rivers have their issues and inputs, so proper diagnosis and understanding of how these shape the biology is essential to the successful restoration of degraded systems.

In an ideal world, phosphorus targets would be established on a river by river basis, and determined by research and proper monitoring.

River ecology is impacted by a wide variety of factors and while nutrients represent a serious risk, it is important for us to understand all of the threats, and the relationships between them.

In summary, without high-resolution monitoring, river standards will be less reliable and river restoration efforts will be blind to their consequences.”

Riverfly Census uncovers rare mayfly species: Brown May Dun

The Brown May Dun (Heptagenia fuscorgrisea)

As a result of our species level monitoring of riverfly life as part of our groundbreaking Riverfly Census, the highly elusive brown may dun Heptagenia fuscogrisea has recently been discovered in both the Usk (at Great Hadwick) and the Ribble (at Long Pool).

brown may dun

Significant Discovery

The rare brown may dun has a conservation status of Nationally Notable and is incredibly elusive and localised.

It is occasionally found in Dumfries, Galloway, Thames Catchment and in Ireland; but this is the first reported sighting on both the Ribble and the Usk, and possibly in Wales.

The discovery is significant due to the rare and elusive status of the brown may dun, coupled with it's susceptibility to stressors in the water which make it an excellent indicator species.
The S&TC River Fly Census is as much about protecting the habitat for these rarities and the wild fish who rely on them, as it is about highlighting and then tackling the EA over declining water quality.


Below: Brown May Dun information
brown may dun


Riverfly Census: species level monitoring

We welcome the news and are proud of the discovery, made by our commissioned independent scientist, Dr Nick Everall.

The  elusive brown may dun represents something very positive among the largely damning findings of our Riverfly Census. Yes, much work is needed to secure and enforce better protection for our rivers; but amidst this we find that our bugs are resilient little critters who continue to surprise us.

Furthermore, our high-level monitoring is proving itself a worthy and necessary investment in the work to understand and thereby better protect our waters. Without species-level analysis, this discovery would not have been made.

Indeed, this discovery promotes the power and importance of species level benchmarking for effective and professional monitoring, which is the crux of our work. We cannot (and will not) proceed without robust and in-depth scientific evidence.


Brown may dun & our River Invertebrate App

The rare brown may dun has been added to our unique river invertebrate app, an important resource for anglers, scientists, nature lovers and anyone interested in the life and health of their local river.

Using high quality digital images (produced by Dr Cyril Bennett MBE), the river invertebrate app shows easily identifiable features for each species, plus its pollution fingerprint and conservation value.

Rather than forking out for an expensive identification key or field guide, carrying it on the river bank, and needing to re-purchase when it becomes out of date; or app is an easily accessible, simple to use, and constantly updated resource which does the job for you.

Find out more about the River Invertebrate App.

brown may dun

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and the places they live

By donating or joining as a member you will be making a huge contribution to the fight to protect the UK's waters and ensure a sustainable future for wild fish.

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Wild Adult Salmon Run Decimated By Sea Lice

Important Hebridean adult wild salmon run decimated by parasites as sea lice numbers on local salmon farms rise and dead farmed fish are taken ashore for burial

Underwater video and photos show graphic evidence of wild salmon covered in parasites

Above: A dead wild adult Blackwater salmon, fatally wounded after its skin has been stripped away by hundreds of parasitic sea lice

A substantial proportion of this year’s wild adult salmon run, into one of the Hebrides’ most renowned rivers, has been killed by a plague of parasitic sea lice

On reaching coastal waters on their route back from the Atlantic, the fish had to pass several salmon farms in Loch Roag. On-farm sea lice numbers have risen this summer and many dead farmed fish have been taken onshore for disposal.

The Blackwater River flows into Loch Roag on the west side of Lewis. At the end of July many dead, dying or distressed adult wild salmon were found in the tidal section of the lower part of the river.

These wild salmon were smothered with many hundreds of sea lice. There is extensive and graphic photographic and video evidence, showing the extent of the infestations and how the sea lice have eaten away the skin of the fish.

All badly damaged fish will eventually die.

This footage, filmed in July in the tidal section of the Blackwater River, shows a very heavily lice-infested and moribund wild adult salmon on the point of expiring:

Blackwater River wild salmon, on their return journey from the Atlantic, must pass through Loch Roag where there are seven salmon farms, all operated by The Scottish Salmon Company (TSSC).


There is strong evidence that sea lice numbers on farmed fish have been far too high in the farm cages this summer

Lice breeding on the hundreds of thousands of farmed fish in Loch Roag will have released unimaginable numbers of juvenile lice into the waters of Loch Roag to infest wild fish.

Clearly the fish farmers have had a serious problem this summer.

Numerous special waste skips full of dead fish have been leaving from Loch Roag over the last two months with tankers transporting fish carcasses to North Uist for disposal by burial in sand dunes.

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

“We believe that the explosion in lice numbers on the Loch Roag farms, spreading out into the wider sea loch environment, has had deadly implications for wild fish, as they were waiting to enter the Blackwater.

As the video shows, these fish were literally eaten alive and a large number of adults, that would have bred in the river, have been killed by the lice.

Laboratory tests have failed to find any other possibility. Adult salmon are well adapted to coping with a few lice but, when plastered with hundreds, they simply do not have a chance.”


Devastating consequences for wild fish populations

Mr Graham-Stewart added:

“This episode represents exceptionally strong evidence of how lice on fish farms, where many hundreds of thousands of fish are packed close together in cages, can increase rapidly in number and release vast numbers of juvenile lice into the surrounding waters. This can have absolutely devastating consequences for wild fish populations.

The loss of a very substantial proportion of the Blackwater River adult salmon run this year has severe implications for spawning and thus future salmon numbers.

Furthermore, if sea lice numbers were high during May and June, then migrating wild juvenile salmon are likely to have been badly infested, compromising their survival chances.

On top of that, local rural businesses that rely on wild salmon are under threat.”


The law is insufficient to protect wild fish

Guy Linley-Adams, Solicitor for S&TCS, commented:

“As the Scottish Parliament’s Environment and Rural Economy Committees have both heard this year, the law is insufficient to protect wild fish from this sort of event.

We desperately need MSPs to act quickly to plug this gap in Scottish law.

Currently, there is no regulatory body that is responsible for protecting wild salmon from the impacts of salmon farming and so one of Scotland’s most iconic species is under serious threat.

The Fish Health Inspectorate has been to the Roag farms, but the law means it is only able to involve itself in the health and welfare of the farmed fish, though the truckloads of mortalities that have been seen suggest that it has not been very successful.


Notes for editors

The Blackwater River, historically one of the most prolific salmon rivers in the Outer Hebrides, flows into Loch Roag on the west side of the Isle of Lewis, near the Callanish Standing Stones.

The Scottish Salmon Company (TSSC) operates all seven salmon farms in Loch Roag. The parent company is TSSC PLC, registered in Jersey. The largest shareholder (with 72%) is SIX SIS AG, a Swiss company.

Just what is the problem with sea lice? Adult wild salmon are perfectly adapted to coping with a few sea lice. Background levels of these parasites occur naturally in the sea. However, the advent of salmon farming, particularly in fjordic or largely enclosed sea lochs, has led to a fundamental change in the density and occurrence of sea lice in parts of the coastal waters of the west Highlands and Islands.

Carrying an unnaturally high burden of sea lice is known to compromise severely the survival of juvenile migratory salmonids. Lice feed by grazing on the surface of the fish and eating the mucous and skin. Large numbers of lice soon cause the loss of fins, severe scarring, secondary infections and, in time, death.

S&TCS’ formal petition to the Scottish Parliament in 2016 has led to first the Petitions Committee, then the Environment, Climate Change and Land Reform (ECCLR) Committee, and finally the Rural Economy and Connectivity (REC) Committee examining the problems that the salmon farming industry in Scotland is experiencing on-farm and causing to the wider marine environment, including wild fish. The ECCLR Committee report issued earlier this year agrees with S&TCS that there are significant concerns over impacts upon wild salmon and sea trout in the aquaculture zone of the west coast and in the western and northern isles of Scotland. S&TCS understands that the report of the REC Committee into salmon farming in Scotland will be published in the early autumn.

Some key findings of the ECCLR Report on the Environmental Impacts of Salmon Farming:

There appears to have been too little focus on the application of the precautionary principle in the development and expansion of the sector”. 

 “If the current issues are not addressed this expansion will be unsustainable and may cause irrecoverable damage to the environment”. 

 “The Committee is deeply concerned that the development and growth of the sector is taking place without a full understanding of the environmental impacts”. 

 “Scotland’s public bodies have a duty to protect biodiversity and this must be to the fore when considering the expansion of the sector.  We need to progress on the basis of the precautionary principle and agencies need to work together more effectively.”

 “…further development and expansion must be on the basis of a precautionary approach and must be based on resolving the environmental problems.  The status quo is not an option.”

 “The current consenting and regulatory framework, including the approach to sanctions and enforcement, is inadequate to address the environmental issues.  The Committee is not convinced that the sector is being regulated sufficiently, or regulated sufficiently effectively.  This needs to be addressed urgently, because further expansion must be on an environmentally sustainable basis.” 

We rely on your support to protect wild fish

and the places they live

By donating or joining as a member you will be making a huge contribution to the fight to protect the UK's waters and ensure a sustainable future for wild fish.

Plastic Rivers

Plastic Rivers: An overlooked but essential element of the global plastic problem

We are all familiar with the shocking plastic-related headlines and imagery that has filled our media channels over the past year: sea turtles with straws up their noses, the ‘Great Pacific Garbage Patch’ and fears about plastics in our seafood.

But our plastic problem begins upstream.

Plastic pollution is frequently described as an ‘ocean epidemic’. Although this is the truth, microplastics are much more than an ocean specific issue. Microplastics are everywhere; soil, air and our rivers - but for the most part these are overlooked.


80% of marine plastic comes from freshwater

Around 80% of marine microplastics come from freshwater run-off, meaning there is a whole period where microplastics persist in rivers before they are flushed into the ocean.

It is essential we stop seeing rivers simply as plastic ‘couriers’ and answer the big question: what impact are these plastic particles having on life in freshwater?


What impact is plastic having on freshwater life?

Evidence from the marine environment suggests microplastics may be considered contaminants of emerging concern in freshwater.

It is already known that there is an energetic cost associated with ingestion of microplastics by organisms. That is, plastic consumption effects the very survival of our freshwater wildlife because it changes their inate behaviour.

For example, when plastic particles are consumed, they mimic fullness, so animals stop eating and suffer from poor nutrition.

There is also potential for ecotoxicological harm, as plastics act like sponges, absorbing chemicals in the water. Once eaten, these chemicals can be released from the plastic into whatever has eaten it. And so forth, up the food chain.


How does river plastic affect wild fish?

For salmon and sea trout, we know chemicals in water have a directly negative effect on completion of their life cycles, particularly the phase where they transform to become ready for life at sea.

So it is logical to ask an important question: are these damaging chemicals becoming more available to these fish - and in higher doses - through the ingestion of plastic particles?

New research is being commissioned and investigations are being made into understanding and controlling the freshwater element of plastic pollution.

Wastewater treatment plants (a large input of microplastics that come from domestic and industrial sources) are currently not designed to remove microplastics effectively, but new filtration options are being discussed.


How can we plastic-proof our rivers?

There is huge scope for positive change, with people and businesses being more aware of their plastic footprints than ever before.

From paper straws to reusable cups, every change we make is a win for the water environment. We urge people to remember that this impact extends way beyond marine; in fact, most plastic pollution begins life in our rivers, where it will also be having an impact - one that often seems overlooked.

At S&TC HQ we have gone single-use-plastic free, and would urge others to do the same.

Moving forward, we would like to see action in the form of a monitoring protocol and standard for river microplastics, so watch this space!

Until we fully grasp and measure the problem, we will not be able to effectively control it.

Additionally, only by understanding the dynamics of microplastics in freshwater, will we be able to effectively measure and manage the contribution to our oceans, in turn protecting marine and freshwater life.

---> By Lauren Mattingley, S&TC's Science Office

The curious case of the great salmon escape that wasn’t…

Scottish Ministers again failing to comply with FOI law over mysterious 2016 salmon farm escape of 300,000 fish that company now says never happened….

The reporting of the disappearance of 300,000 farmed salmon in 2016, understood at the time to be the industry’s biggest escape in many years, raises serious questions about the oversight and regulation of salmon farming and Scottish Government’s dubious record on transparency.

In June 2016, The Scottish Salmon Company reported that it believed about 300,000 salmon, with an average weight of 623g, had escaped from its Scadabay farm on Harris.

Over the next 18 months the company’s financial reports, SEPA’s biomass records, Marine Scotland’s Annual Production Survey, Scotland’s Aquaculture website and various industry websites consistently maintained that this major escape had indeed occurred (2).


Salmon Escapes Removed From Database

However, in early 2018, just as the Scottish Parliament’s Environment Climate Change and Land Reform (ECCLR) Committee was beginning to investigate the Environmental Impact of Salmon Farming, the escapes database on the official Scotland’s Aquaculture website was amended to record an escape of zero fish at Scadabay in June 2016.

Guy Linley-Adams, for Salmon and Trout Conservation Scotland (S&TCS), said:

“Whatever the true facts as to what went on here, the removal of a 300,000 escape in 2016 from the datasets did have the effect of improving dramatically the industry’s official record on escapes.”

 Mr Linley-Adams continued:

“There have also been unexplained delays, over many months, by the Fish Health Inspectorate (FHI) and Scottish Government in providing paperwork under Freedom of Information law to help clarify what has occurred.”

S&TCS asked the FHI for copies of relevant inspections conducted in 2016 at the Scadabay farm, which unusually still remained unpublished on the FHI’s Case Information website, but these were not supplied by FHI until after a referral was made to the Scottish Information Commissioner.

Those reports have now been disclosed, in redacted form, to S&TCS. Other requested information – such as a letter from the company concerned to Scottish Government, sent in late 2017 – remains unpublished.

One of the FHI reports from June 2016 notes that the suspected loss of fish “is thought to have occurred during the storms at the beginning of 2016” and that “a new fish counter was used which could reported account for slight discrepancy in fish numbers, but not the 332,372 that are unaccounted for”.

However, an update to the FHI inspection reports records that a letter from The Scottish Salmon Company, sent to Marine Scotland in Edinburgh on 16th November 2017, a year and a half after the “escape”, states that the company had concluded that it had lost no fish and that the most likely reduction in biomass was caused by early mortality that was undetected due to adverse weather conditions.

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

“To say, 18 months after the event, that there was a mass mortality rather than an escape is stretching credulity to breaking point. There must be serious questions about the standards of husbandry when the deaths of 300,000 fish go unnoticed.”

Guy Linley-Adams, for S&TCS, added:

“Irrespective of whether 300,000 fish escaped in June 2016 or just died in the cages – and   whatever the reason for the apparent discrepancy in reported fish numbers and biomass at the Scadabay farm – taking almost two years to assess whether or not such a massive escape or mortality had actually occurred raises serious questions.

If these fish had either escaped or just died in June 2016, presumably 300,000 fewer fish eat a lot less feed as they grow?  Was this not noticed before the site started harvesting or the letter apparently reporting a ‘zero’ loss was finally sent in November 2017?

Whatever the facts or what has occurred here, what we can say is that this demonstrates that current regulation of fish farms is not fit for purpose.”


Salmon Escapes a 'Cause For Concern'

The Scottish Government has acknowledged for some time that “escapes from fish farms are a cause for concern….for conservation and wild fish interests, escaped fish may represent a disease hazard, occupy valuable habitat to the exclusion of wild fish and have the potential to interbreed with wild fish, leading to dilution of genetic integrity”.

The Convention for the Conservation of Salmon in the North Atlantic Ocean (NASCO) aims to minimise impacts from aquaculture on wild salmon stocks.

The NASCO Williamsburg Resolution (4) lays down measures to minimise the impact of aquaculture with respect to escapes. Each party, including the UK, is required to take measures to minimise escapes of farmed salmon to a level that is as close as practicable to zero.

The number of escapes of farmed Atlantic salmon in Scotland remains stubbornly high.

S&TCS’ information requests over the Scadabay “escape” had to be referred to the Scottish Information Commissioner who has just issued yet another Decision against Scottish Ministers in favour of S&TCS in relation to the failure by FHI to comply with the Environmental Information (Scotland) Regulations 2004.

This decision adds to another seven decisions from the Scottish Information Commissioner that S&TCS has obtained in just 15 months concerning requests about salmon farms that have not been answered by Scottish public authorities in compliance with the law (3).

 Guy Linley-Adams commented:

“While we welcome this latest decision, the Scottish Information Commissioner has required Scottish Ministers to consider whether it would be appropriate to apologise to S&TCS for their failure to comply with the statutory timescales for response. 

I would just note that this is not the first time.

In lay terms, Scottish Ministers simply being told to say sorry, and do what they should have done many weeks or months ago, does not yet appear to be having the desired effect of ensuring they comply with the law on freedom of information.” 


Issued by Andrew Graham-Stewart (telephone 01863 766767 or 07812 981531) on behalf of Salmon and Trout Conservation Scotland. For further information, call Guy Linley-Adams on 07837 881219.


Notes for editors


1) Salmon & Trout Conservation (S&TC) was established as the Salmon & Trout Association (S&TA) in 1903 to address the damage done to our rivers by the polluting effects of the Industrial Revolution. Since then, S&TC has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC has charitable status in both England and Scotland (where it operates as S&TC Scotland) and its charitable objectives empower it to address all issues affecting fish and the aquatic environment, supported by robust evidence from its scientific network, and to take the widest possible remit in protecting salmonid fish stocks and the aquatic environment upon which they depend.

2) The Scadabay “escape”

In June 2016, it was initially reported by The Scottish Salmon Company that about 300,000 fish, with an average weight of 623 g, had escaped from its Scadabay farm on Harris.

On 28th November 2016, The Scottish Salmon Company ‘Final Notification’ to the FHI indicated the numbers lost were still “unknown”, and noted “the inconclusive results from  investigation”, but biomass data for the Scadabay farm held by the Scottish Environment Protection Agency shows a drop in reported biomass at the farm of some 199 tonnes between April and May 2016, which would broadly match the loss reported to FHI.

The Scottish Salmon Company itself, in its own Quarter 2 and First Half Year Report for 2016, published on 24th August 2016, had reported on the escape:

“Operating costs for the quarter are £23.5m (Q2 2015: £26.80m) (a cost per kg of £3.68 compared to £3.27 in Q2 2015) and have been affected by losses at one site, in the Hebrides, which is currently under investigation. While the average fish size was around 600 grams, this together with smaller losses at other sites, represents a loss in harvest volumes of around 1800 tonnes which will impact Q4 2016 and the start of 2017. The site which is in a particularly remote location, was affected by unseasonably poor weather during the first part of the year. We have undertaken a review of infrastructure, processes and configuration to mitigate the risk”.

“We have adjusted our annual target for this financial year to around 26,000 tonnes. This is a combination of the lower than expected harvest volumes in the year to date due to biological issues and the impact of the losses at our site in the Hebrides. We are also reviewing our strategy in relation to 2017 in response to these losses”.

Biomass data for the Scadabay farm held by the Scottish Environment Protection shows that the site’s peak biomass, that occurred in November 2016, was still some 500 tonnes lower that the CAR licence issued by SEPA actually permits at Scadabay.

The site had completely harvested out by April 2017 and was fallow from May 2017 to at least March 2018 (the last month for which biomass data has yet been published).

Marine Scotland’s 2016 Production Survey, published in September 2017, was still reporting a total of 311,496 fish reported as escaped in 2016, which included the Scadabay loss.

In October 2017, the Scotland’s Aquaculture database was also still reporting 300,000 fish lost.

In December 2017, it was also still being reported by industry websites that “The Scottish Salmon Co.’s Scada Bay grow-out was pounded by bad May weather until it released 300,000 fish of 625 grams”.

3) In respect of the information on Scadabay, the Scottish Information Commissioner has now issued another decision* against Scottish Ministers for their failure to comply with freedom of information law. (Decision 120/2018: Salmon and Trout Conservation Scotland and the Scottish Ministers | Scadabay Inspections: failure to respond within statutory timescales | Reference No: 201801191 |Decision Date: 6 August 2018).

This is now added to seven other decisions obtained in the last 15 months by S&TCS concerning requests about salmon farms that have not be answered by Scottish public authorities in compliance with the law.

43/2018Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyInformation relating to the use of sea lice medicineFor applicant26 Mar 2018
013/2018Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyCorrespondence with Marine ScotlandFor applicant31 Jan 2018
010/2018:Salmon and Trout ConservationScottish Environment Protection AgencyReport on the environmental impact of sea lice medicineFor applicant29 Jan 2018
199/2017Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyInformation concerning sea lice medicineFor applicant30 Nov 2017
191/2017Salmon and Trout Conservation ScotlandScottish MinistersReport on the environmental impact of sea lice medicineFor applicant20 Nov 2017
142/2017Salmon and Trout Conservation ScotlandScottish MinistersControl and reduction of sea lice on fish farmsFor applicant04 Sep 2017
063/2017Salmon and Trout Conservation ScotlandScottish MinistersControl of sea lice on fish farms: failure to respond within statutory timescalesFor applicant02 May 2017

4) The NASCO Williamsburg Resolution

Resolution by the Parties to the Convention for the Conservation of Salmon in the North Atlantic Ocean to Minimise Impacts from Aquaculture, Introductions and Transfers, and Transgenics on the Wild Salmon Stocks - The Williamsburg Resolution (Adopted at the Twentieth Annual Meeting of NASCO in June 2003 and amended at the Twenty-First Annual Meeting of NASCO in June 2004 and at the Twenty-Third Annual Meeting of NASCO in June 2006.

S&TCS FOI Requests: Scottish Government still not responding lawfully

S&TCS FOI Requests

The Scottish Information Commissioner has issued yet another decision [1] against Scottish Ministers for their failure to comply with freedom of information law.

This is now added to seven other decisions obtained in the last 15 months by S&TCS to do with requests for information about salmon farms.


Eight decisions from the Scottish Information Commissioner on aquaculture in just fifteen months

The latest decision relates to information about an escape of 300,000 salmon reported in 2016 by The Scottish Salmon Company’s farm at its Scadabay on Harris [2].

Guy Linley-Adams said:

“While we welcome this latest decision, the Scottish Information Commissioner has required Scottish Ministers to consider whether it would be appropriate to apologise to S&TCS for their failure to comply with the statutory timescales for response. 

 But this is not the first time.

 In lay terms, Scottish Ministers simply being told to say sorry, and do what they should have done many weeks or months ago, does not yet appear to be having the desired effect of ensuring they comply with the law on freedom of information”. 


The Scottish Information Commissioner’s other decisions obtained by S&TCS in the last 15 months:


43/2018Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyInformation relating to the use of sea lice medicineFor applicant26 Mar 2018


013/2018Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyCorrespondence with Marine ScotlandFor applicant31 Jan 2018


010/2018:Salmon and Trout ConservationScottish Environment Protection AgencyReport on the environmental impact of sea lice medicineFor applicant29 Jan 2018


199/2017Salmon and Trout Conservation ScotlandScottish Environment Protection AgencyInformation concerning sea lice medicineFor applicant30 Nov 2017


191/2017Salmon and Trout Conservation ScotlandScottish MinistersReport on the environmental impact of sea lice medicineFor applicant20 Nov 2017


142/2017Salmon and Trout Conservation ScotlandScottish MinistersControl and reduction of sea lice on fish farmsFor applicant04 Sep 2017


063/2017Salmon and Trout Conservation ScotlandScottish MinistersControl of sea lice on fish farms: failure to respond within statutory timescalesFor applicant02 May 2017



[1] Decision 120/2018: Salmon and Trout Conservation Scotland and the Scottish Ministers

[2] Scadabay Inspections: failure to respond within statutory timescales - 6 August 2018

Scottish salmon farming seeks to expand as publication of Scottish Parliament’s Rural Economy Committee report approaches

Whilst the report of the Rural Economy and Connectivity (REC) Committee into salmon farming in Scotland is awaited (scheduled for “early autumn”), applications for new salmon farms, or expansion of existing farms, are continuing apace.

Applications to increase tonnage are in the pipeline from southern Argyll to the northern isles. These applications are generally not in the offshore locations that the fish farmers claim they want to develop to reduce the impact on wild fish.

Local council planning departments are attempting to secure some limited protection for wild fish and meet their statutory duty under the Nature Conservation (Scotland) Act 2004 to protect wild salmon and sea trout from significant harm from fish farms, by tightening up planning conditions.

Whilst councils are usually minded to grant planning permissions, on the basis of inconclusive advice from Marine Scotland, they are requiring Environmental Management Plans (EMPs) to be put in place during the operation of these fish farms.

EMPs are supposed to offer a degree of protection for wild fish, but S&TC Scotland believes, as do the councils themselves, that these EMPs are little more than ‘sticking plasters’ and will not be effective unless these plans have real ‘teeth’ and can be enforced.


While these new farms continue to get planning permission, S&TC Scotland is working behind the scenes to make sure that the EMPs are not just simply tick-box exercises.

S&TC Scotland has already taken Senior Counsel’s advice over one case in Argyll and secured an important understanding from both the local council and fish farmer, that an EMP must be approved and in place before any increase in biomass of farmed fish could be allowed at the site in question.

S&TC Scotland is also finalising a draft EMP planning condition - one with real teeth - that will be promoted to Councils, to be utilised in the interim period before, we anticipate, Scottish Government/Marine Scotland acts to tighten up the planning process, to provide proper protection for wild fish, following what we hope will be robust recommendations within the imminent REC Committee report.


The RECC report follows the S&TC Scotland’s petition to the Scottish Parliament in 2016, which prompted inquiries at Holyrood and has resulted in three committees examining the issue.

Concerns regarding sea lice impacts upon wild salmon and sea trout (in the aquaculture zone of the west coast, and in the western and northern isles of Scotland) are shared by the Petitions Committee, the Environment, Climate Change and Land Reform (ECCLR) Committee and the Rural Economy and Connectivity (REC) Committee.

The inquiries conducted by the various committees simply would not have happened without the help of S&TC; who  has provided extensive evidence, written and oral, to the committees.


The ECCLR Committee Report, published in March 2018, was clear on sea lice impacts, advising:

  • That fish farms should be located away from salmonid migration routes.
  • That there should be a mandatory requirement to keep sea lice levels within those identified in the industry’s Code of Good Practice.
  • That the efforts of the industry have proven to be largely insufficient to address lice issues.
  • That sea lice data should be published on a farm by farm basis in real time.

Despite a commitment made by the salmon farmers to the ECCLR Committee in oral evidence earlier this year, salmon farmers are still not publishing real-time data relating to sea lice numbers on their fish farms, nor any historic farm specific data.

After S&TC Scotland’s ground-breaking referral to the Scottish Information Commissioner last year, who then ordered Scottish Government to publish farm specific data on the worst performing farms, we are now getting farm-specific data, but only three months in arrears.

S&TC Scotland has written to the Conveners of both the ECCLR and REC committees, expressing exasperation at the failure of the industry to live up to its commitments made to MSPs, and asking Scottish Government to act.

S&TC Scotland now looks to the upcoming RECC report to back their demand that full disclosure of real-time farm specific sea lice data and historic trend data should be made a statutory requirement upon the fish farmers.