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

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

Roseanna Cunningham MSP

Cabinet Secretary for Environment, Climate Change and Land Reform

Fergus Ewing MSP

Cabinet Secretary for the Rural Economy

2 April 2020

 

Dear Ministers

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

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

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

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

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

Regulation must include: 

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

MSA members have now individually published the above position:

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

https://atlanticsalmontrust.org/aquaculture/ 

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

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

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

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

Yours sincerely

Andrew Graham-Stewart

Director – Salmon and Trout Conservation Scotland

Cc Graham Black, Director, Marine Scotland

Alastair Mitchell, Marine Scotland

Edward Mountain MSP, Convener REC Committee

Gillian Martin MSP, Convener ECCLR Committee

John Goodlad, Chairman, Salmon Interactions Working Group

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

Cathy Tilbrook, Nick Halfhide, SNH

Alan Wells, Fisheries Management Scotland

Sam Collin, Scottish Wildlife Trust

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

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

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

Regulation must include:

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

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

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

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

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

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

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

NOTES

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

The MSA is comprised of the following members:

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

https://www.missingsalmonalliance.org

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

Scottish Ministers’ lamentable failure to regulate salmon farming

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

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

ISSUED: 20 Feb 2020

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

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

ECCLR: http://bit.ly/ECCLR_salmon_farming

REC: http://bit.ly/REC_salmon_farming

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

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

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

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

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

Relentless growth of the industry has continued

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

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

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

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

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

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

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

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

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

Angling Trust

Community of Arran Seabed Trust (COAST)

Craignish Restoration of Marine & Coastal Habitat (CROMACH)

Fairlie Coastal Trust

Friends of Loch Etive

Friends of the Sound of Jura

Loch Visions

North and West District Salmon Fishery Board

Open Seas

Orkney Trout Fishing Association

Save Seil Sound

Scottish Creel Fishermen’s Federation (SCFF)

Scottish Salmon Think-Tank

Sea Change Wester Ross

Sealife Adventures

Skye Communities for Natural Heritage

South Skye Seas Initiative

Tay Ghillies Association

Added since news release:

Coastal Communities Network Aquaculture Sub-Group

Eigg Environmental Action Group

Friends of Loch Creran

Salmon Aquaculture Reform Network Scotland (SARNS)

The Meikleour Arms

Tay Salmon Fisheries

North Atlantic Salmon Fund US (NASF US)

North Atlantic Salmon Fund Iceland (NASF Iceland)

Atlantic Salmon Federation (ASF)

Ulster Angling Federation

Salmon Watch Ireland (SWIRL)

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

VISUAL ASSETS

Can a “feed the world” mantra justify trashing our marine environment?

"The suggestion that salmon farming is somehow justifiable in order to feed the world simply will not wash."

Andrew Graham-Stewart, Salmon & Trout Conservation Scotland

I have been cursing Fergus Ewing MSP, Cabinet Secretary in Scotland for the Rural Economy, of late. Of course, it is nothing personal. I will explain.

On November 6 I was watching – on Parliament TV – Ewing and his senior civil servants giving evidence before the Scottish Parliament’s Rural Economy Committee. Following close questioning about the salmon farming industry’s dismal environmental record, Ewing sought to justify the industry’s “serious problems” thus:  “If we have to feed twice as big a population in the world, we must, as no new farmland is going to be created any time soon, find a way of using the marine environment……to feed the planet.”

As soon as the Cabinet Secretary uttered the words “feed the planet”, the refrain from what is perhaps the most annoying and sanctimonious pop ditty in history entered my head. In 1984 the assorted stars of Band Aid raised millions towards famine relief in Ethiopia, a thoroughly creditable initiative, through sales of the single Do they know it’s Christmas? The words of the chorus, Feed the world, are repeated endlessly in shrill tones. Ever since its release, this song and its inane refrain have become a staple of the excruciating muzak that pollutes public spaces throughout December. This year, thanks to Fergus Ewing’s utterance, I have been struggling to expurge the inane Feed the world refrain from my consciousness since early November.

Of far greater import is the fact that farmed salmon is never going to be a sustainable answer to feeding the world. Growing farmed salmon is dependent on the extraction by foreign-flagged factory ships of vast amounts of other fish, mainly from the coastal seas off poor countries in West Africa and South America (depriving local communities of sustenance and the opportunity of making a sustainable living), and shipping the catch thousands of miles to be converted into fishmeal.

Farmed salmon is simply not an efficient use of fish protein. It requires a considerably greater weight of bait or other fish to produce a kilo of farmed salmon – and the oft-quoted and dubiously optimistic conversion ratios never take into account those farmed salmon that die, because of disease and parasites, before they are harvested; this mortality rate of salmon (for which in effect the feed has been entirely wasted) in Scotland is some 25%.

As I write, supermarket fresh salmon is retailing for around £15 per kilo, generally more than the price of cod or haddock and far more than the likes of mackerel or herring. In fact, salmon is often a luxury purchase; recently the Daily Mirror reported that one Tesco London store is “hiding smoked salmon following a string of thefts in the run-up to Christmas”. Farmed salmon is not cheap protein that is going to be a solution for world hunger. It is simply fatuous for any politician or indeed industry spin-doctor to suggest that is the case.

Hardly a week goes by without further damning evidence of what an environmental disaster open-cage salmon farming is. Scottish Ministers and industry spokespersons are increasingly desperate in their search for valid reasons to vindicate the trashing of our coastal marine environment and the catastrophic decline in those species that depend upon clean, chemical-free and parasite-free waters. The suggestion that salmon farming is somehow justifiable in order to feed the world simply will not wash.

“Responsibly Sourced” Are supermarkets facing a crisis of credibility?

"Supermarkets face a crisis of credibility unless they take immediate action to address systemic failings in their own farmed salmon buying policies."

With the launch of a report into the state of farmed salmon being sold on supermarket shelves, Scottish conservation and welfare charities, Salmon & Trout Conservation Scotland (S&TCS) and OneKind, are jointly calling on supermarkets to sort out farmed Scottish salmon.

Surveying of supermarket shelves (samples below) over the course of twelve months reveals that consumers are being sold, and unwittingly consuming, products from Scottish salmon farms meeting one, or a combination, of the following criteria:

1. Raised levels of sea lice parasites and disease

2. Significant premature mortalities

3. Unsatisfactory levels of marine pollution

This places at risk Scotland’s wild fish and marine ecosystems, impacts local community well-being and pays scant regard to improving the poor lives led by many farmed salmon.

Full Report HERE

Sample Products with

Sea Lice, Mortality and Environmental Survey Information

Ends
Issued by Corin Smith, comms@salmon-trout.org

Notes for Editors

Salmon & Trout Conservation UK (S&TC UK) was established 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 wild 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
Media Contact: Corin Smith, comms@salmon-trout.org (+44 74636576892)

OneKind is Scotland’s leading campaigning animal welfare charity, working to end cruelty to Scotland’s animals. OneKind is an evidence-based organisation, using scientific evidence, investigations and research to address the welfare issues of Scotland's wildlife, farmed animals, pets and lab animals. They have done extensive work on the issue of salmon welfare in Scotland's salmon farms and have produced three reports exploring the suffering of Scotland's farmed salmon.

www.onekind.scot
Media Contact: Eve Massie, eve.massie@onekind.org

S&TC and Patagonia deliver 170,000 strong petition to Scottish Parliament

Our partnership with Patagonia in this campaign has been extremely effective.

Salmon & Trout Conservation Scotland (S&TCS) are pleased to have been able to orchestrate the delivery of Patagonia Inc's "Artifishal" petition against open-net salmon farming, which we supported, to Gillian Martin MSP, Convener of the Environment, Climate Change and Land Reform (ECCLR) Committee at the Scottish Parliament.

Patagonia's credibility on environmental issues and the public's overwhelming empathy with the issues raised by the 'Artifishal' film and petition has been reflected in support from hundreds of thousands across Europe.

The recent collaboration with Patagonia has reinforced Salmon & Trout Conservation Scotland's (S&TCS) determination to ensure that the Scottish Government takes meaningful action to deliver on the clear recommendations of the ECCLR and REC committees which were the outcome of last year's Scottish Parliament Inquiry into salmon farming.

Andrew Graham-StewartDirector - S&TCS said:

"We will continue to press for an immediate moratorium on the expansion of open cage salmon farming and to insist that the Scottish Government accepts that the future for salmon farming in Scotland must be in closed containment systems. We are unwavering in our determination to protect wild salmon and trout populations in Scotland, and the ecosystems on which they rely, from the devastating impacts of open cage salmon farms."

Sea lice numbers on salmon farms double in a single year

Total sea lice numbers on salmon farms double in a single year.

Industry and official SEPA data underline how the rush to expand salmon farm production is massively increasing the risks to wild salmon and sea trout.

“A moratorium on salmon farm expansion is now more essential than ever”

Andrew Graham-Stewart, Director of Salmon and Trout Conservation Scotland (S&TCS).

Data recently published by the Scottish Salmon Producers Organisation (SSPO) shows that the average adult female sea lice count per fish on salmon farms increased from 0.25 in April 2018 to 0.49 in April 2019 – an increase of 96%.

Over the same period the total amount of salmon in Scotland’s farms rose by almost 25%, from 97,000 tonnes to 122,000 tonnes, according to data published by the Scottish Environmental Protection Agency (SEPA). The 122,000 tonnes figure is the highest on record.

By combining the above data sets and with the fair assumption that the average size of the fish across all farms is unchanged year-on-year, it is evident that total adult female sea lice numbers in April were more than double the total for a year earlier.

Multiplying (total biomass in 2019 / total biomass in 2018) by (average lice per farmed fish in 2019 /average lice per farmed fish in 2018) shows that, in April 2019, the production of juvenile sea lice by fish farms is likely to have been between two and three times higher than that in April 2018.

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

“The absolute number of adult female sea lice on farms is of far greater relevance as regards the impact on wild salmon and sea trout than the average number of lice per farmed fish.It is these adult female lice on the farms that produce the lice larvae that then infest wild fish in the sea lochs.There can be no doubt that there has been a dramatic year-on-year increase in total adult female sea lice numbers on Scotland’s salmon farms. The available data indicates there was a huge escalation in the production of sea lice larvae, at the most critical time in the spring when juvenile salmon migrate from their rivers to sea and are most vulnerable to fatal sea lice infestations.”

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

“The massive increase in sea lice numbers is a major concern. The situation is now far worse than it was during last year’s Scottish Parliamentary Inquiry. In the circumstances, a moratorium on salmon farm expansion is now more essential than ever, if further damage to wild fish survival is to be avoided. Scottish Ministers need to act now and stop kicking the necessary decisions into the long grass”.

Permissions for new salmon farms or salmon farm expansions are continuing on a regular basis. For example, in Argyll and Bute alone there have been ten planning decisions in favour of salmon farming expansion since the publication of the ECCLR Committee report in March 2018. Another three applications are awaiting decisions.

Following a warmer than average winter, salmon farming industry sources are predicting severe problems with sea lice on fish farms in Scotland this autumn. They report that sea lice levels have been highly challenging this summer with no end in sight.

They also report that some companies are choosing not to treat their fish for sea lice because of high levels of other disease and gill health problems, which weaken farmed salmon and reduce their ability to survive the chemical and physical treatments for sea lice.  This will almost certainly inflict even more damage on wild salmon and sea trout.

FULL MEDIA ASSETS (WITH VIDEO): http://bit.ly/SeaLiceDoubleAssets

ENDS

Issued by Corin Smith. 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) Just what is the problem with sea lice?

Adult wild salmon are well 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 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. Even one or two mature female sea lice per fish within a set of cages housing hundreds of thousands of farmed salmon amounts to a rampant breeding reservoir pumping huge numbers of mobile juvenile sea lice out into the local marine environment. The consequences when wild salmon and sea trout smolts, the metamorphosing fragile skin of which is not adapted to cope with more than the odd louse, migrate from local rivers into this “sea lice soup” can be devastating.

Carrying an unnaturally high burden of sea lice is known to compromise severely the survival of juvenile wild migratory salmonids; research has shown that an infestation of ten to 12 lice 10 is likely to have fatal consequences. 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. Quite literally, the fish are eaten alive. Badly infested salmon smolts disappear out to sea, never to be seen again. In contrast afflicted sea trout smolts remain within the locality and they, together with the impact of the deadly burdens they carry, are more easily monitored through sweep net operations.

3) Research indicates that a 1,000 tonnes salmon farm with an indicative adult female sea lice count of 5.0 per fish could be producing as many as three billion sea lice larvae per month. Open cage salmon farming allows unhindered free flow of sea lice into the wider marine environment.

Response to MOWI decision to close Loch Ewe salmon farm

Mowi (previously Marine Harvest) has announced that it is to close its highly contentious salmon farm in Loch Ewe, Wester Ross.

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

“We welcome Mowi’s decision to close the Loch Ewe farm. There can be no doubt that the decision is a vindication of S&TCS’ long campaign to end salmon farming in this enclosed sea loch, which has devastated sea trout stocks in iconic Loch Maree, previously the best sea trout fishery in western Scotland. Our film, ‘Eaten Alive – End of an Era’ on the demise of the Loch Maree sea trout fishery was pivotal in this campaign. (http://bit.ly/30ojQIU)

The other factor in Mowi’s decision is clearly the farm’s failure to reduce its benthic impact. As a consequence, SEPA has cut the farm’s permitted biomass very substantially, thus diminishing its commercial viability. 
Mowi has signalled its intention to move the biomass elsewhere. If Mowi wishes to apply for a biomass increase at another location, then that should be judged on its own merits. Indeed, it would be disingenuous to try and link it to the closure of Loch Ewe. Furthermore it is vital that any biomass increase elsewhere avoids migration routes for wild salmonids.

The closure of the Loch Ewe farm will give Loch Maree’s sea trout the opportunity, for the first time in three decades, to thrive and grow in Loch Ewe without being infested with parasitic sea lice originating from the Loch Ewe farm”. 

For more information on S&TC's salmon farm reform campaigns: www.salmon-trout.org/campaigns/salmon-farming/

Andrew Graham-Stewart, Scottish Director 

For Scottish Enquiries contact: director@salmon-troutscotland.org

Recent Press Coverage:

STV News: http://bit.ly/STCLochEwe

https://www.independent.co.uk/../mowi-close-loch-ewe-sea-lice

https://www.pressandjournal.co.uk/…/fish-farm-giant-to-clo…/

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!!!

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