SmartRivers is delivering results

The hot dry summer has exposed the stress our rivers are under

Nick Measham, Deputy CEO, S&TC

To view the full interview click HERE

The hot dry summer has exposed the stress our rivers are under – particularly in Southern chalkstreams where algal growth and sediment is choking life to a seemingly unprecedented extent. Once clean gravels are covered in thick mats of algae and river weeds are festooned with tresses of filamentous algae. Elsewhere in England and Wales, lethal fish-killing slurry spills are occurring with distressing frequency.

S&TC’s Riverfly Census and our SmartRivers’ initiative, using volunteers to collect species-level data to Environment Agency (EA) standards, demonstrates the destructive impact agriculture is having on water quality through sediment, phosphate and chemicals leaching into rivers. Sewage works remain a problem – albeit possibly a reducing one if their own monitoring is to be believed which, as a result of the case of Southern Water, we need to remain sceptical about.

Great news then that SmartRivers is spreading rapidly across the country thanks to support from Esmée Fairbairn, Patagonia and others. This volunteer data collection is providing evidence of the good, the bad and the ugly in our rivers.

Lauren Mattingley, S&TC Science Officer said: 

"Since launch in spring this year, the ‘SmartRivers’ effect has begun to spread across the UK. With five hubs established and a further six in the process of enrolment, in just a short period of time SmartRivers has already started to grow."

Autumn 2019 has seen the completion of Wiltshire Fisheries Association's training, the enrolment of Stour Fishery Association in Kent and the first round of volunteer species identification from Bowland Game Fishing Association . Meanwhile back at HQ we are hard at work preparing new species to be added to our app, filling gaps identified by our hubs.

Another focus is the development of our linked database. This will communicate with the Environment Agency’s data and other citizen science data platforms. By ensuring our data speaks to other data, we have the best chance of understanding and alleviating the subtle, often invisible pressures threatening nature’s nursery of wild salmon and trout

The power of this species-level invertebrate data is that it enables the local SmartRivers’ hubs, supported by S&TC, to produce robust and tangible results. The EA’s action to force Bakkavör to stop discharging deadly pesticides washed off imported salads into the headwaters of the Itchen is just one case in point.

Nick Measham, S&TC’s Deputy CEO (Project Manager for the Riverfly Census and SmartRivers) said,

"The work to get Bakkavor to remove pesticides from its discharge is setting national precedents and changing policy. The local EA has already asked another salad-washer, Vitacress, to take out pesticides from its discharge. We will keep up the pressure until all salad and vegetable processing clean up their act."

On that note, we are hopeful that Bakkavor will be able to employ sophisticated technology to clean its discharge to an acceptable level. We will be keeping up the pressure to ensure this happens as we told the EA in a meeting this week. Other potential actions on the back of SmartRivers’ data are well-advanced in the Hampshire Avon catchment, another SAC river in a poor condition in many places.

Our fundamental aim is to make sure agricultural regulations are observed and enforced if need be. This will not be easy. The resources currently available to the EA to inspect farms are insufficient. A farm is inspected on average once every 200 years. We need all the SmartRivers’ evidence we can muster.

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.

Discharges from salad washing – Update

Salad washing on the Upper Itchen: A local problem with national significance…

Nick Measham , Deputy CEO, S&TC writes…….

S&TC’s battle to stop Bakkavör discharging pesticides and chlorinated plant-cleaning chemicals from its salad washing activities is achieving increased environmental protection, and not just for the Upper Itchen. [Previously covered by BBC Countryfile]

As a result of an Environment Agency investigation, in response to S&TC’s Environmental Damage challenge, both Bakkavör and The Watercress Company will be subject to individual pesticide discharge limits and required to carry out monitoring for a wide range of toxins.

The outcome so far is an improvement but much more remains to be done both on the Itchen and nationally to provide protection against pesticides in combination. Our fight to change national policy to require consideration of the impact of a mixture of pesticides continues.

Results so far:

  • On the Upper Itchen, the Environment Agency (EA) is seeking to revise the discharge permits of both Bakkavör and The Watercress Company’s to limit pesticide concentrations. Bakkavör discharges its overnight factory cleaning waste water directly into the river, but the daily water used to wash the salad leaves goes to The Watercress Company cress beds. TWC does not use pesticides in its growing activities and has therefore not been monitored up to now.
  • We understand Bakkavör is already trialling equipment to remove the pesticides from its discharges to enable it to meet the limits the EA imposes. The company has already stopped using chlorinated chemicals in its plant cleaning waste water.
  • It looks like the EA will require Vitacress’ salad washing plant on the Bourne Rivulet, a tributary of the Test, to meet the same pesticide discharge standards as Bakkavör.

What’s next?

  • The immediate next step is to ensure any revised discharge permits protect the river from the salad washing activities. While the EA has accepted the need for pesticide limits and associated monitoring, S&TC will scrutinise proposed permit changes, when they are published, to ensure the pesticide limits deliver the highest standards of protection currently available.
  • These current standards only consider pesticides individually not in the cocktail which is discharging into the Upper Itchen. There is an urgent need for the Government to investigate the impact of chronic, often low-level pesticide impacts in combination. We are extremely concerned about the impact of multiple different pesticides in combination. The EA’s investigation report following the Environmental Damage challenge in respect of the Upper Itchen refers to the risks on page 36:

“this poses a potential risk of exposure to invertebrates downstream of the discharge and being exposed to multiple different pesticide compounds intermittently at low concentrations (which may be above the Probable No Effect Concentration on infrequent occasions). 

 Current UK policy is to look at the effect of individual pesticides, not the effective exposure to a mixture. A change to policy is being considered at a European Union level, but we are a long way (temporally) from this policy being revised.”

This delay in acting on potentially lethal cocktails of pesticides is just plain wrong and, like so much government policy, completely ignores the precautionary principle. S&TC has written to Dr. Thérèse Coffey to ask what Defra intends to do about this on the Itchen, other SAC rivers and, indeed, any river.

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.

Chalk streams debated in parliament

We always intended the Riverfly Census to be a lobbying document as well as reporting on the science, and this has been an excellent first political outing for it.

Paul Knight, CEO, S&TC

In a speech during a House of Commons debate on "Degraded chalk stream environments", Richard Benyon MP cited evidence from S&TC’s ground breaking Riverfly Census Report. Further, he referenced our investigative work into previously unknown pesticide issues associated with a salad washing plant owned by multinational food group, Bakkavör. [recently covered by BBC Countryfile]

By way of response, Department for Environment, Food and Rural Affairs minister, Dr Thérèse Coffee, rather worryingly pointed to the EA’s permitting system for discharges into rivers as giving them adequate protection. S&TC does not agree.

Nick Measham, S&TC’s Deputy CEO (Project Manager for the Riverfly Census and SmartRivers) said,

“Richard Benyon used S&TC’s professionally sampled and analysed data to show that our rivers are far from being protected at the moment, especially our chalk streams, which we have shown are badly impacted not only by toxic chemicals, but excess phosphate and sediment as well.  We suspect that one of the outcomes of our Bakkavör work may well have national implications for discharges directly into watercourses, so Dr Coffee might not be quite so confident in her agency’s permitting performance in the near future.”

S&TC’s Head of Science, Dr Janina Gray, added,

“Our Riverfly Census results show the power of good science to establish the ecological health status of our rivers and at the same time encourage the Environment Agency to actually take action when problems are highlighted.  It also shows that by producing sound science such as the Riverfly Census results, we can support Richard Benyon and his Parliamentary colleagues with solid evidence to help them influence change at the highest level.”

S&TC’s CEO, Paul Knight, said,

“Richard Benyon’s speech was a welcome public endorsement of our approach to protecting wild water and all that relies on it. He outlined that our data had shown a pesticide discharge from Bakkavor’s plant into the River Itchen that had gone unnoticed, until the arrival of the S&TC team to analyse the invertebrates. This precipitated the Environment Agency conducting their own analysis, which confirmed our results. It is clear none of this would have happened without our intervention, data gathering and subsequent lobbying.”

Follow the full debate in Hansard

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.

Salmon stock exploitation: Wales delays, while England acts

Salmon stock exploitation: Wales delays, while England acts

On the 14th June 2019, in response to troubling results from their own analysis of Severn salmon stocks, the Environment Agency (EA) implemented an emergency bylaw prohibiting the use of certain nets in the estuary and imposed compulsory catch and release on all other nets and rod and line fisheries on the whole of the river for the remainder of the season.

Richard Garner Williams, S&TC Cymru said:

“S&TC Cymru congratulate the EA on this decisive move and trust that the bylaw will be observed by all.” 

Somewhat worryingly however, until the Welsh Minister for the Environment, Energy and Rural Affairs decides to approve similar bylaws for Wales, proposed eighteen months ago by Natural Resources Wales (NRW), this EA bylaw cannot be enforced on the Welsh reaches of the Severn, nor its tributaries. Further, despite the stock assessment for 2018 showing every salmon river in Wales to be "at risk, or probably at risk, of failing to meet its conservation limits," NRW remain unable to extend the enforcement of compulsory catch and release of salmon to all Welsh rivers.[1] Solely the result of political feet dragging.­­

NRW have previously conducted three comprehensive regional consultations on proposed changes to rod and net bylaws with regard to salmon and sea trout in Wales. The first and most extensive, in terms of geographical coverage, concerned every river in Wales but for the Dee, Wye and Severn. Two further, more specific, consultations then followed. One concerning the Dee and the Wye, both of which rise in Wales but bless England with their presence for part of their journey to the sea, and another for the Severn, which while it rises in Wales, flows for the greater part of its length through England.

By reciprocal arrangement the regulations relating to the exploitation of the salmon populations of the Dee and the Wye are governed by NRW, while management of the Severn salmon stocks falls to the EA.

With salmon stock assessments in Wales showing a continued decline, NRW contends it is imperative to implement a policy of compulsory catch and release on all Welsh waters to protect remaining salmon populations from further exploitation. As a result of the NRW consultations, bylaws were proposed placing restrictions on method, such as banning the use of treble hooks and all forms of bait. Further restrictions to those stipulated in the current bylaws relating to sewin (sea trout) were also put forward for consultation.

2018 Salmon Stock Assessment: http://bit.ly/2wtMlrK

In early 2018 these bylaw proposals were endorsed by the board of NRW and submitted to Welsh Government for confirmation. Six months later, in the autumn of 2018, in a wholly unexpected turn of events, Lesley Griffiths, the then Cabinet Secretary for Energy, Planning and Rural Affairs and more recently Minister for the Environment, Energy and Rural Affairs announced her conclusion that given “the level of response to the consultation, the number of outstanding objections to the byelaw proposals and the nature of the correspondence” it is “the most appropriate course of action to conduct a local Inquiry which will allow independent scrutiny of NRW’s proposals.”[2]

Richard Garner Williams commented:

“Proposals to protect salmon stocks in Wales have been put on hold while a protracted enquiry runs its course. The Inspector has now delivered his report but we remain none the wiser about the future intentions of the Welsh Government towards regulating the exploitation of a rapidly declining species. Meanwhile NRW have published their stock assessment for 2018 showing every salmon river in Wales to be at risk, or probably at risk, of failing to meet its conservation limits. Time is not a luxury we have in the fight to save wild Welsh Atlantic salmon for future generations.”

  1. Compulsory catch and release of salmon is already force on the Wye, Taff and Rhymni under the demands of an existing bylaw.
  2. https://naturalresourceswales.gov.uk/guidance-and-advice/business-sectors/fisheries/local-inquiry-into-nrw-s-proposals-for-new-rod-and-net-fishing-byelaws/?lang=en

For more information please contact: wales@salmon-trout.org

 

ARTIFISHAL & Patagonia Inc

"The thing that has struck us at the screenings we have attended is that the audience is far from being just anglers – it has been great seeing so many younger folk there and hearing their reaction to the issues"

Paul Knight, CEO Salmon & Trout Conservation

In 2019 one of Patagonia's core global campaigns has been highlighting the need for the protection of wild salmon populations around the world from the damaging impacts of commercial hatcheries and open cage salmon farming.

The campaign has centred around a feature length film "Artifishal"  which has been supported by a large public relations effort.

Patagonia Inc said: 

"Artifishal is a film about people, rivers, and the fight for the future of wild fish and the environment that supports them. It explores wild salmon’s slide toward extinction, threats posed by fish hatcheries and fish farms, and our continued loss of faith in nature."

The film has been toured around major European capitals and is now being shown by local activist groups in smaller towns and villages.

Accompanying the film has been a petition which is to be delivered to the governments of Scotland, Norway, Ireland and Iceland later in the year.

https://you.wemove.eu/campaigns/stop-europe-s-dirty-fish-farms

Salmon & Trout Conservation has supported the campaign throughout and participated as the lead NGO in the UK. Each film screening is book-ended with a hosted panel discussion of experts and a Q&A with the audience. S&TC staffers, Paul, Nick, Andrew and Corin have attended dozens of events between them throughout the UK and Europe. Largely speaking to issues around the impacts of open cage salmon farming in Scotland, but often ranging into areas of consumer activism, protecting wild waters and the process of forcing change from reluctant governments.

The audience members at screenings reflect Patagonia's demographic and have been overwhelmingly younger, environmentally active, consumer conscious and non fishing. The discussions, engagement and vocal consensus about the concerns being raised demonstrate that S&TC's campaigns do have very broad appeal and resonate strongly with consumers. This tells us a lot about how to build public support for the issues we are concerned with. Patagonia's global reach (over 1.5m followers on facebook and instagram) combined with their deeply held convictions on protecting wild places, activism and making change, has taken S&TC's message to people and places we would have struggled to reach ourselves, and at a scale that is internationally significant.

S&TC's credibility on the issues combined with Patagonia's credibility with consumers is proving to be a potent symbiotic relationship.

Corin Smith, Communications Consultant for S&TC said:

"Working with Patagonia Inc has been a significant coup for S&TC. Our highly visible collaboration to end open cage salmon farming has both government and industry deeply concerned. Touring with "Artifishal" has taught us a huge amount. Not least it has clearly demonstrated that our wider environmental attitude to campaigning, highlighted through consumer issues, has the potential for broad public appeal and engagement over the longterm."

Artifishal (Europe) By Numbers (up to June 2019)

Nearly 140,000 signatures! https://you.wemove.eu/campaigns/stop-europe-s-dirty-fish-farms

12 million -- Total reach for all film and campaign related content on social media through Patagonia sponsored ads

192 -- Number of PR pieces so far

> 197.5 million -- Total PR readership for these pieces

Meanwhile…

Salmon & Trout Conservation Scotland have secured a date to deliver the "Stop Europe's dirty fish farms" petition to the Scottish Government with Patagonia Inc

Patagonia's short film about salmon farming in Iceland went online: https://www.youtube.com/watch?v=5vgmpdwOgvs

Media highlights

'We're the bad guy': inside the shocking new film about wild fish (The Guardian – review of the film at the Tribeca film festival).

Patagonia founder Yvon Chouinard: ‘Denying climate change is evil’ (The Guardian – interview also features the film Artifishal)

Outdoor gear, food retailer Patagonia harshly criticizes aquaculture, hatcheries in "Artifishal" (SeafoodSource – great interview with Artifishal producer Dylan Tomine)

Salmon Farming Exposed – BBC Panorama program on salmon farming in Scotland and subsequent articles like this one. Some of the best recent coverage of the issue and features Corin Smith from Salmon & Trout Conservation Scotland.

We still have a few more months of "Artifishal" to go with a number of screenings in Scotland and the UK between now and September.

For dates near you check out: https://eu.patagonia.com/eu/artifishal-screenings.html

Thanks to Becky, Lisa Rose, Lisa D, Mihela and the rest of the team at Patagonia Inc. And of course Yvon, his vision, passion and conviction are game changing.

We continue!!!

Dear Phil, Thank you so much!

What can we say other than a huge THANK YOU!!

Phil Chessum took on the challenge of running the Race to The King ultramarathon to raise money for S&TC. An exhausting 52.4 mile slog across the South Downs.

Completing the course in a very respectable 10 hours 26 minutes and finishing 71st out of 750 competitors, Phil's feet seemed to take the brunt of the effort.

Phil said:

"It was a bit gruelling - glad to get it over with. Feeling quite positive about it all at the moment - although having to work from home, as I can't get my shoes on!" 

Phil raised just short of £3,500 for S&TC and is still receiving donations.

The funds will be used to fund the benchmarking of a river of Phil's choice through our SmartRivers initiative, a lasting legacy worthy of such incredible efforts.

SmartRivers plays a crucial role in ensuring the longterm protection of wild waters by establishing a solid science led reference point of biodiversity, against which any future impacts can be measured and evidenced.

SmartRivers enables volunteers, supported by a training scheme, training videos, an invertebrate-identification App and support programmes, to monitor the water quality in their rivers to a near-professional standard.

Phil celebrated his achievement with a pint. And yes, his eldest son is correct. It was TWO full marathons!!

Well done Phil, and thank you so much. It's appreciated.

From all of us at Salmon & Trout Conservation

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.

Response to Southern Water Fine

Ofwat has imposed the biggest fine ever on a water company for "significant breaches of its licence conditions and its statutory duties." Southern Water has been fined £37.7m, but this has been reduced to £3m because the company has undertaken to pay customers some £123m over the next five years.

Ofwat states in its report:

We have concluded that Southern Water has deliberately misreported data to us about the performance of its wastewater treatment works. We have also concluded that it has failed: to have adequate systems of planning, governance and internal controls in place to be able to manage its wastewater treatment works; to accurately report information about the performance of these works; and to properly carry out its general statutory duties as a sewerage undertaker, to make provision for effectually dealing with and treating wastewater.”

It is extremely frustrating that this financial penalty will only compensate Southern Water’s customers and does not include any funding to clean up the environmental damage that the company has quite obviously caused in both rivers and along the coastline.

Ofwat is only concerned about regulatory obligations over which it has authority, and this does not include scrutiny of Southern Water’s environmental permit failures or, indeed, whether its employees behaved criminally in covering up its woeful operating performance.

These issues are currently being dealt with by the Environment Agency, although the Ofwat report suggests that appalling practices were endemic throughout Southern Water’s structure  “…including at senior management levels” including some designed “to prevent samples of wastewater from being taken at treatment works to check compliance with environmental permit conditions”.

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

“S&TC has been pursuing this matter, including through the Information Commissioner’s Office for some time now. Given what we now know, it is inconceivable that the Environment Agency will not prosecute Southern Water, and for multiple offences. We expect nothing less. 

There must be no ‘deal’ made with Southern Water. Quite simply, the company set out to cheat the system, knowing that would harm the environment, and it must both pay for the environmental damage it has caused and be punished for what it has done. 
The entire green lobby - and its lawyers - will be watching what happens now”. 

S&TC has reported on Southern Water’s appalling environmental record before.  Although we have no evidence of similar operating practices in other water companies, it is fanciful to think that they are all lily-white in their performance since privatisation.  Some £55 billion has been paid to shareholders since privatisation, which would suggest the greatest driver for these companies is profit-sharing among investors rather than any serious sense of responsibility for environmental protection. The damage the water companies cause  either from inadequately-treated sewage polluting our rivers or the impacts of excessive water abstraction from rivers and aquifers, is immense.

As we cannot trust water companies any more, the time has arrived to require independent monitoring of all water company’s sewage works and abstractions.

S&TC’s Head of Science and Policy, Dr Janina Gray, said:

S&TC’s recently published Riverfly Census Report highlighted the parlous state of our Southern chalkstreams, which is the freshwater habitat most vulnerable to Southern Water’s operations.  S&TC is now calling for full independent environmental monitoring of all water company operations in England.  It is not an excuse to cite lack of resources for failing to comply with adequate monitoring – it should be a legal requirement for these companies to pay for independent monitoring; they can surely afford it!”

Paul Knight CEO of S&TC UK said:

No-one can be so naïve as to think it is only Southern Water cheating like this at the expense of the environment. This is the direct result of years of cutting the regulator to the bone and relying instead on self-monitoring by polluters. It is time to reverse that trend and require independent monitoring of all large companies that can have such massive impact on the environment”.

William Hix, Chairman, Salmon & Trout Conservation commented:

“These are shocking revelations which make it difficult for the public to trust Southern Water’s treatment of the environment. It is the environment that has suffered as a result of this appalling behaviour, and if the fine is to be dramatically reduced because of undertakings given by Southern Water, then those undertakings should relate primarily to the environment rather than customers. OFWAT’s statutory duties and strategic priorities and objectives include the environment. The way in which this compromise arrangement with Southern Water essentially compensates customers (rather than the environment) for damage to the environment, reinforces the impression that OFWAT places little weight on the environment. If there is to be a massive reduction in the fine levied in response to undertakings, then those undertakings should relate to expenditure on protecting the environment. If trust in the environmental protection activity of Southern Water is to be restored, then an effective system of independent monitoring of Southern Water’s emissions to the environment must be put in place as a matter of urgency. Financing such a system, rather than refunding customers, would be the appropriate course to take in accordance with OFWAT’s and Southern Water’s duties to the environment and the nature of the failures.”

ENDS

Issued by comms@salmon-trout.org (07463 576892) on behalf of Salmon and Trout Conservation. For more information please contact janina@salmon-trout.org and paul@salmon-trout.org on 01425 652461

For more information and resources please visit: www.salmon-trout.org/

Notes to Editors

(1) Salmon and Trout Conservation

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 England, Wales and 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 Riverfly Census

THE CENSUS PROCESS

The Riverfly Census utilises the invertebrate assemblage: presence, absence and abundance of certain invertebrates and the specific set of conditions they need to thrive, to indicate the types of stress our rivers are experiencing. This species-level resolution shows pressures which family-based Water Framework Directive (WFD) methods fail to capture.

The Riverfly Census has spanned three years, across 12 rivers in England. Multiple sample sites were carefully selected on each.

Kick-sweep sampling was completed in spring and autumn to EA-accepted guidelines, at all sample sites. Sampling and species-level identification were carried out by professional entomologists at Aquascience Consultancy Ltd.

Species data were inputted to Aquascience’s biometric calculator to obtain scores against key stress types: chemical, nutrient, sediment and flow. The data was then evaluated in a whole catchment context to pinpoint the likely suspects contributing to the river’s deterioration.

The data was compiled for, and is being reported to, local stakeholders and policy makers to improve management and conservation of our rivers.

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.

Salmon farming being supported by hands-off regulation and taxpayers’ money

FOI reveals hands-off regulation of salmon farming’s environmental impactand the lavish use of taxpayers’ money to support the industry

 Freedom of Information requests made by Salmon & Trout Conservation Scotland (S&TCS) to the Scottish Environment Protection Agency, Marine Scotland, the Fish Health Inspectorate and Highlands and Islands Enterprise have shown the extent of Scottish Government use of taxpayers’ money to fund the salmon farming industry and the very light touch regulation of its environmental impact.

Weak regulation - SEPA

Information supplied by the Scottish Environment Protection Agency (note 2) shows that only two applications for marine fish farm licences, issued under the Controlled Activities Regulations (CAR), have been refused in the last five years and, over the same period, there have been no enforcement notices served for any failure to comply with the CAR licence and no prosecutions.

SEPA’s own annual compliance assessments show that Scotland’s aquaculture sector saw overall compliance levels drop during 2017 to 81.14%, against 85.75% in 2016 – meaning almost 20% of farms breached their CAR licences in 2017 (note 3) with 56 of the country's 297 licensed fish farms rated "poor", "very poor" or "at risk".

Over the last five years, 147 benthic surveys under salmon farms have been rated as ‘unsatisfactory’ which SEPA itself categorises as “an indication that the emissions arising from the site in question are of a scale that is beyond the assimilative capacity of the local environment. This classification may relate to impacts on benthic fauna or sediment chemistry, unacceptable infeed medicine residue concentrations, or a combination of these parameters”.

This is completely at odds with the assurance of Terry A’Hearn, SEPA’s Chief Executive, who said last year that compliance is“non-negotiable”for fish farms (note 4).

Weak regulation – Fish Health Inspectorate and Marine Scotland

Information provided by the Scottish Government’s Fish Health Inspectorate(note 5), that polices farms for parasites and diseases, and investigates escapes of farmed fish, shows that, in the last five years, the FHI has served only two enforcement notices under the Aquaculture and Fisheries (Scotland) Act 2007, relating to the failure to control sea lice on fish farms - at the Ardmaddy farm in 2015 and at Score Holms in 2017.

There have been no prosecutions of fish farms or fish-farm well-boat operators in the last five years for failure to have adequate measures in place to control sea lice to protect wild fish – this despite a huge number of fish farms breaching the Scottish Government’s 3 and 8 average lice trigger levels since their inception in 2017.

Calling time on weak regulation?

No wonder that the recent Scottish Parliament’s Rural Economy and Connectivity (REC) Committee Inquiry into Salmon Farming in Scotland (note 6) concluded this year, per Recommendation 2, that “The Committee strongly agrees with the view of the Environment, Climate Change and Land Reform Committee (ECCLR) Committee that… the “status quo” in terms of regulation and enforcement is not acceptable” and, per Recommendation 60, that the Committee, “considers that there is a need to raise the bar in Scotland by setting enhanced and effective regulatory standards to ensure that that fish health issues are properly managed and the impact on the environment is kept to an absolute minimum”.

 The Committee also recommended that, “a comprehensively updated package of regulation should be developed by Marine Scotland and other regulatory bodies…”

 Importantly, the vital wild fish protection part of that package is expected to be announced by Scottish Government in June.

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

“The almost incredibly soft touch regulation that has been applied by the Scottish Environment Protection Agency and the Fish Health Inspectorate, and the closeness of the relationship between Marine Scotland and the industry, paints an unhealthy and unsustainable picture that the REC Committee of the Scottish Parliament decided could and should not continue.

 We look forward to the Scottish Government announcing very shortly robust measures to protect wild salmon and sea trout from the damage that has been, and is still being, caused by salmon farms”

The use of taxpayers’ money to support salmon farming in Scotland

At the same time as applying the softest of soft touch regulation, the Scottish Government has also been using significant sums of taxpayers’ money to fund the industry.

Over the last 10 years, the Scottish Government has provided £2 million to the Scottish Aquaculture Research Forum (SARF) by way of annual grants (note 7).  It was the withholding of information about one SARF project - that had showed unexpected negative impacts from the use of the sea lice treatment, Slice, in salmon farms, on wild lobster and prawns - that led to five formal decisions of the Scottish Information Commissioner in favour of S&TCS and against SEPA and Scottish Government (note 8).

The Scottish Aquaculture Innovation Centre was awarded further grants during 2016 and 2018 from the European Fisheries Fund, totalling £3.9 million (note 7).

Further grants totalling £1.5 million were given by Scottish Enterprise to the salmon farming industry between 2011 and 2018 to a range of fish farming companies, including two of the bigger companies active in Scotland, The Scottish Salmon Company, and Scottish Sea Farms (note 7), both of which are highly profitable and thus entirely capable of absorbing the cost of such routine expenses as “website development” and “international market development”. Grants for “international market development” are said by Scottish Government to consist of assistance to companies (travel, accommodation etc) to attend international trade events, trade missions etc.

The Highlands and Islands Enterprise also awarded grants to the salmon farming industry totalling £3.9 million between 2010 and 2018 (note 10) for anything from the redevelopment of fish-processing facilities to attendance at Asian trade fairs.

Of particular note is Scottish Enterprise providing £1,075,000 of Scottish Investment Bank investments to Loch Duart Limited over the period 2012 to 2016, to support the company’s sustainable farming practices” (note 7). Despite this investment, in 2019, Loch Duart Limited agreed with the Advertising Standards Authority to stop using claims of sustainability, having described itself as “the sustainable salmon company,” which prompted complaints (note 9). Overall, the relatively small firm of Loch Duart Limited has received, from various government and official sources, a total of £3.25 million over the last 10 years. According to its accounts to year end March 2018, Loch Duart made a profit of £2.6 million and paid £555,981 to its directors.

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

“Given the amount of taxpayers’ money that has been poured into this industry over the last decade, the public has a right to expect the Scottish Government to put into effect all the recommendations of the REC Committee Report, and quickly. If the Report is allowed to gather dust, the Scottish environment and wildlife will continue to suffer.

 We call on the Cabinet Secretary to make it crystal clear to the fish farmers to expect tough regulation and not to rely on the old cosy relationship with government and regulators to protect it from proper scrutiny”. 

Supporting images available here: http://bit.ly/2x34mNH (Credit: Corin Smith)

Ends

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

Notes for editors

1) Salmon & Trout Conservation UK (S&TC UK) 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 UK has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC UK has charitable status in both England and Scotland (as S&TCS) 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. www.salmon-trout.org www.salmon-troutscotland.org

 

2) FOI response to S&TCS from SEPA 15thMarch 2019

 

3) See http://media.sepa.org.uk/media-releases/2018/environmental-compliance-of-scottish-business-exceeds-90-for-third-year-in-a-row.aspx

 

4) See https://www.bbc.co.uk/news/uk-scotland-45752796

 

5) FOI response to S&TCS from FHI 11thMarch 2019

 

6) Rural Economy and Connectivity Committee Report into Salmon farming in Scotland, 9th Report (Session 5), 2019

 

7) FOI response to S&TCS from Marine Scotland 7thMarch 2019

 

8) Scottish Information Commissioner’ decisions – at https://www.itspublicknowledge.info/ApplicationsandDecisions/Decisions/Decision_Listing.aspx

 

Decision 043/2018

Salmon and Trout Conservation Scotland

Scottish Environment Protection Agency

Information relating to the use of sea lice medicine

For applicant             26 Mar 2018

 

Decision 013/2018

Salmon and Trout Conservation Scotland

Scottish Environment Protection Agency

Correspondence with Marine Scotland

For applicant             31 Jan 2018

 

Decision 010/2018

Salmon and Trout Conservation

Scottish Environment Protection Agency

Report on the environmental impact of sea lice medicine

For applicant             29 Jan 2018

 

Decision 199/2017

Salmon and Trout Conservation Scotland

Scottish Environment Protection Agency

Information concerning sea lice medicine

For applicant             30 Nov 2017

 

Decision 191/2017

Salmon and Trout Conservation Scotland

Scottish Ministers

Report on the environmental impact of sea lice medicine

For applicant            20 Nov 2017

 

9) See https://www.asa.org.uk/codes-and-rulings/rulings.html?q=Duart#informally-resolved

 

10) FOI response to S&TCS from HIE 8thMarch 2019

 

Bakkavör Alresford Salads Impacting Upper Itchen

Sewage and pesticides from a salad washing factory owned by Bakkavör Group Plc may present a serious threat to aquatic invertebrate life on a highly protected English chalkstream.

 The Environment Agency’s response to a formal notification of environmental damage made by S&TC in June 2018, pursuant to the Environmental Liability Directive, confirms the wild fish conservation charity’s fears: discharges from Bakkavör’s site at Alresford are threatening the fragile Upper Itchen and Alresford Pond.

Bakkavör www.bakkavor.com is a leading supplier of fresh food and salads to UK supermarkets.

The EA’s wide-ranging investigation was prompted by the results of S&TC’s invertebrate sampling at a site immediately downstream of Bakkavör’s outflows.

A copy of the sampling report (produced by Aquascience Consultancy Ltd) is available here: http://bit.ly/2RhzimT

The threat from these activities was highlighted by Joe Crowley on the BBC’s Countryfile Chalkstream Special.

www.bbc.co.uk/iplayer/episode/m0005xlv/countryfile-chalk-streams

The EA investigation firstly exposed a failing in the factory’s own sewage works. The sewage is now being tankered away and S&TC says discharges should not restart. The headwaters of a chalkstream is not the right place to dump sewage.

The EA investigations also exposed a potential pesticide threat. The EA has not been able to rule out damage caused by traces of pesticides present on the salad leaves used by Bakkavör and which are being subsequently washed into the Upper Itchen. The EA is now undertaking more monitoring work. S&TC will follow the results of this work closely.

The S&TC notification has highlighted a wider national issue, that of the EA being unable to look at the impact on wildlife from chronic, low level and cumulative exposure to combinations of different pesticides.  This is directly relevant, not just to salad washing but to agriculture in general. S&TC will continue to raise its scientific evidence at the highest levels within UK Government and the European Commission to influence the changes required to provide our chalkstreams and all rivers with proper protection.

The EA also recognised specific damage to Alresford Pond from nitrates, which now requires remediation plans to be drawn up, as well as a severe sediment issue in the pond that threatens its long-term value to wildlife. Alresford Pond is a Site of Special Scientific Interest.

Nick Measham, S&TC’s Deputy CEO comments:

“The EA’s response to S&TC’s species-level monitoring shows the necessity to go beyond the technical confines of the Water Framework Directive to tackle the worrying declines in aquatic invertebrate life in the Upper Itchen. The EA’s “family-level measure” shows invertebrates to be fine at its chosen sample point well downstream of the factory, but our sample point, and the EA’s own work at Alresford, indicate real threats. The only sensible way to protect the river is for Bakkavör to be required to put the water it uses back into the river at the same quality at which it abstracts. If it can’t do that, it must cease discharging altogether.”

S&TC is delighted that the EA has persuaded Bakkavör Group Plc to consider its whole operation at Alresford to protect the Itchen. S&TC’s fierce lobbying has already stopped the company using chlorinated chemicals in its overnight wash.

S&TC is happy to work with Bakkavör Group Plc if its management begins to show a genuine willingness to undertake efforts to remedy the impacts of its operations and contribute towards restoration efforts, but S&TC will pursue the company relentlessly if it does not fulfill its obligations to protect the Upper Itchen in the future.

Dr. Janina Gray, S&TC’s Head of Science & Environmental Policy added:

“The EA cannot continue to put chemicals, especially pesticides, in the too difficult to deal with box. The Upper Itchen highlights urgent action is required to monitor and regulate the synergistic and/or additive effects of chemicals. This cocktail of chemicals is having an environmental impact now and can no longer be ignored. S&TC see the formal notification to the EA as a first step in better understanding the pressures impacting the Upper Itchen, now we will be seeking action to address these. Business as usual is no longer an option.”

ENDS

Issued by Corin Smith comms@salmon-trout.org (07463 576892) on behalf of Salmon and Trout Conservation. For more information please contact janina@salmon-trout.org and nick@salmon-trout.org on 01425 652461

 

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.

Troubling news from Wales

Troubling news from Wales as the recently published 2018 assessments of salmon and sea trout populations point towards a continued decline.

Stocks in twelve of the twenty-three principle salmon rivers were deemed to be “at risk” of failing to reach their conservation limits for sustainable recruitment and those in the remaining eleven rivers to be “probably at risk”.

Sewin stocks were found to be in an equally worrying situation with populations in sixteen of the thirty-three principle rivers revealed to be “at risk” and all but two of the remainder “probably at risk”. The need for urgent action to halt these declines grows by the day, not least in remedying the deterioration in water quality of several rivers brought about by intensive agriculture.

We eagerly await an announcement from Lesley Griffiths, Minister for Environment, Energy and Rural Affairs, on the details of the new regulations to tackle agricultural pollution to be implemented in January 2020 in the hope that they will be sufficiently robust to bring an end to the current unacceptable practices of a small number of irresponsible operators. While they will not be sufficient in themselves to bring about a complete recovery of stocks, they will nevertheless be warmly welcomed as an important first step in addressing the plight of our precious sewin and salmon.

 

Unlike Scotland and England, where the potential impact of everyday farming practices on water are regulated under a suite of legally enforced rules and measures, farmers in Wales have until recently only been expected to follow the voluntary Code of Good Agricultural Practice (CoGAP). There is a lot to be said for minimising regulatory control and respecting an individual’s right to use their own land as they please; but with rights come responsibilities which, when shouldered in a conscientious manner, naturally result in equitable outcomes. Sadly, that has not been the case with CoGAP and in recent years we have seen a startling increase in incidents of agricultural pollution, particularly so within the dairy sector, as producers have expanded their herds and effectively abandoned all notion of voluntary restraint in the spreading of slurry.

For more information please contact: wales@salmon-trout.org

2018 Sea Trout Stock Assessment: http://bit.ly/2XapNIa

2018 Salmon Stock Assessment: http://bit.ly/2wtMlrK

Header Image Credit: Steffan Jones