Why a strict ceiling on sea lice must be applied to all Scotland’s salmon farms

Why a strict ceiling on sea lice must be applied to all Scotland’s salmon farms

Wild salmon and sea trout populations in Scotland are dangerously low. For wild salmon and sea trout in the west Highlands and Islands to be properly protected from the negative impact of salmon farming, the effective control of sea lice on farms is a vital first step.

A precautionary approach is essential

S&TCS believes that a genuinely precautionary approach must be applied to the licensing and permitting of any new salmon farms or expansion of existing farms. Such a precautionary approach was also recommended by both the REC and ECCLR Committees in the 2018 Parliamentary Inquiry.

In March 2018, Graeme Dey MSP, Convener of the ECCLR Committee, emphasised the need to apply the precautionary principle to fish farming - “there appears to have been too little focus on the application of the precautionary principle in the development and expansion of the sector…Scotland’s public bodies have a duty to protect biodiversity and this must be to the fore when considering the expansion of the sector. We need to progress on the basis of the precautionary principle …”.

REC Committee (Recommendation 40) was that “although there is a lack of definitive scientific evidence of the various factors that are contributing to the decline of wild salmon stocks, the Committee is nevertheless of the view that a precautionary approach should be taken which will seek to minimise the potential risk to wild salmon stocks wherever possible”.

Put simply, applying the precautionary approach means not using lack of scientific certainty to justify delay in taking action to prevent environmental damage. Where a threat of serious damage has been identified action should be taken to prevent damage occurring. The threat of serious damage to wild salmonids caused by salmon farms has been identified by numerous fisheries scientists, and applying the precautionary principle means putting in place now measures that will prevent salmon farms causing harm to wild salmonids. Waiting to take action until after it has been demonstrated that a particular salmon farm has harmed wild fish is not in accord with the precautionary approach.

In the context of the contested scientific understanding of the negative interactions between farmed and wild fish, fish farm regulation must be underpinned by a robust and strict precautionary approach to protect wild salmonids. Wild salmonid monitoring, particularly in the marine environment, is an imprecise science and is highly unlikely to produce clear and unambiguous results that are not open to multiple different interpretations of what might be occurring.

A strict sea lice ceiling must be applied to all fish farms

Therefore, the precautionary principle demands that adaptive management can only take place under a strict, robust and universally applied sea lice ceiling, in other words an absolute upper limit to the permitted average number of adult female sea lice per farm fish.

Without this ceiling, the burden of proof is effectively reversed, with proof that there is damage being caused to wild salmonids becoming a pre-requisite to any action being taken to address fish farm performance in respect of sea-lice and diseases[1].

 There is already domestic, international and industry support for a strict sea lice ceiling

In November 2018, the Scottish Parliament’s Rural Economy and Connectivity Committee, in its report following its investigations as part of the Inquiry into Salmon Farming, concluded (Recommendation 15) that sea lice triggers should be “challenging” and urged Government to “set a threshold that is comparable with the international industry standards”.

The inter-governmental North Atlantic Salmon Conservation Organization (NASCO) advocates that “100% of farms to have effective sea lice management such that there is no increase in sea lice loads or lice-induced mortality of wild salmonids attributable to the farms”.

In most North Atlantic salmon farming countries statutory on-farm average adult female sea lice limits are set at no more than 0.5 per fish during the critical main wild smolt outward migration period in the spring.

So, why should Scotland’s wild salmon and sea trout be accorded any lesser levels of protection than fish elsewhere?

The Aquaculture Stewardship Council (ASC) certification programme for salmon farming  sets global  standards for salmon farming (https://www.asc-aqua.org/wp-content/uploads/2019/12/ASC-Salmon-Standard_v1.3_Final.pdf) including for sea lice (Requirement 3.1.7) that “farms seeking certification to maintain on-farm lice levels at 0.1 mature female lice during and immediately prior to sensitive periods, particularly outmigration of wild juvenile salmon”. Mowi (formerly Marine Harvest) claims to be working towards “100 % ASC certification” (https://mowi.com/sustainability/aquaculture-stewardship-council/asc-dashboard/).

So, why should Scotland’s wild salmon and sea trout be accorded aless protection than that recommended by the ASC?

Domestically too, there is support for a strict sea lice ceiling. Scottish Natural Heritage (SNH) has recommended that a strict ceiling for on-farm sea lice levels should be set to protect wild salmonids in the Langavat Special Area for Conservation. In its response to the Screening and Scoping Exercise for the Taranaish fish farm on Loch Roag, SNH required that sea lice control should be based on

a) The ability of the applicant to maintain average sea lice levels in line with our position paper Marine Aquaculture and Wild Salmonids, see Appendix 1:

0.1 adult female lice per fish between February and June inclusive

0.5 adult female lice per fish between July and January inclusive”.

So, why should Scotland’s wild salmon and sea trout now be accorded less protection than that already recommended by Scotland’s statutory nature conservation body?

Adaptive management, by itself, is not enough…

The Salmon Interactions Working Group’s recently published report proposes a system of adaptive management, but without any precautionary underpinning by a strict universally-applied sea lice ceiling.

Under the SIWG proposals, in effect, wild fish interests would have to prove conclusively that damage is being caused to wild salmon and sea trout before sea lice controls on nearby fish farms were tightened.

Adaptive management will be subject to disagreement between fish farmers and regulators over why wild fish had experienced sea lice infestations and it is likely (in the last resort) that there could be legal challenges from the industry.

Experts within Marine Scotland Science and the Crown Estate agree that it would probably take intense monitoring of wild fish for at least three farm production cycles (up to six years) for any pattern of damage to wild fish caused by fish farms to be established, and even then it will likely be the subject of dispute between fish farmers and regulators over the  science.

Therefore, without a strict sea lice ceiling applied to all fish farms from the outset, wild fish would have no more protection from farm-origin sea lice infestation for the foreseeable future. At best, adaptive management alone would, at least for several years, be no more potent in protecting wild fish than the current system. At worst, it will become mired in disputes over what wild fish monitoring is showing and why, leading to no effective control of fish farm production of sea lice.

Why should Scotland’s wild salmon and sea trout be accorded no more effective protection than is currently the case?

 Current Scottish Government sea lice reporting levels are not enough

In a letter to S&TCS (June 2020), Cabinet Secretary Fergus Ewing signalled the Scottish Government’s woeful lack of ambition regarding the control of sea lice on farms. Referring to the current sea policy (which only relates to the health and welfare of the farmed fish), he stated that the intention is to enhance “the sea lice reporting process by reducing intervention levels” (currently 2 and 6 average adult female lice per fish – see Marine Scotland Topic Sheet Number 71 V3) “to 2 and 4 in 2021 – unless there is evidence to the contrary”, forgetting that the industry’s current Code of Good Practice already  has nominal lice treatment advisory thresholds of 0.5 adult lice per fish (February to June) and 1.0 per fish (July to January).

In other words, farms will not even be required to notify the Fish Health Inspectorate (FHI) of sea lice numbers until the average number of female lice per fish reaches 2 at which point, theoretically, FHI is committed to “increased monitoring/surveillance”, although no other sanction is applied. That is a level fully 20 times the ASC limit during wild smolt runs.

Fergus Ewing’s stated objective amounts to confirmation that Scottish Government does not envisage currently that the future system of adaptive management being proposed will be underpinned by a strict universally-applied and precautionary sea lice ceiling.

S&TCS believes that it is imperative that any new regime includes a strict adult female sea lice ceiling applied to all fish farms, which must be rigorously enforced by tough and prompt action, set at 0.5 per farmed fish, dropping to 0.1 during the period of wild smolt emigration, below which ceiling  any adaptive management, based on wild fish monitoring, is then applied.

[1] See, for example, Friends of the Earth Limited, Re Judicial Review [2017] NICA 41

“37. Given the repeated finding that the operations are likely to have significant impact on the environment the decision maker cannot simply put in the balance the absence of evidence of harm…What has been disregarded … is that these operations are considered likely to have significant impact, that the nature and extent of that impact has not been established, that prior to the grant of permission is the requirement to establish that there will be no significant impact and that it is imperative that the precautionary principle be applied.  What must be put in the balance is the absence of evidence that there is no harm. To approach the matter with a requirement for evidence of harm is the negation of the precautionary principle”.

NASCO 2020

Paul Knight reports on the 37th Annual Meeting of NASCO

The North Atlantic Salmon Conservation Organisation (NASCO) met for its Annual Meeting in the first week of June, although this year, uniquely, all the meetings were held virtually by video link, with those not directly involved being able to listen in by phone.  Despite concerns that such a large international conference would be difficult to organise and run – it involved a Council and three separate Commissions – it actually went very smoothly, albeit with some of the more important issues, particularly from an NGO viewpoint, being postponed until Council is able to meet face-to-face, hopefully this autumn.

The main objective for the NGOs was to influence support for a full day Theme-based Special Session (TBSS) on salmon farming at next year’s Annual meeting.  This follows increasing concern right across the north Atlantic – and also the Pacific – that open-net salmon farming is the most damaging issue for wild salmon and sea trout that NASCO parties and jurisdictions actually have the power to do something about.  The NGOs were therefore delighted to receive unanimous support from all the Heads of Delegation for the TBSS in June next year, even agreeing to extending the meeting by a day if that is needed to accommodate the event.

The main concern driving the NGOs is that, despite NASCO resolutions going back at least 17 years, and a Council direction that open-net salmon farming should receive particular attention from relevant countries, the Implementation Plan process – the 5-year plans for salmon conservation put forward by each party and jurisdiction – clearly show a failure to protect wild fish from the adverse impacts of sea lice infestations killing migrating smolts, and escaped farmed fish interbreeding with natural salmon populations.  Two countries with significant salmon farming industries openly admit that they have no action to regulate sea lice emanating from open pen farms, while another has a national policy allowing 30% of wild salmon smolts to be killed before any serious regulation is considered.

So, the TBSS is a small but significant step along a very long road needed to turn around the juggernaut of political commitment so that appropriately effective regulations are introduced (in those jurisdictions where they are still absent) and are enforced rigorously to protect wild fish.  It is a sad admission that no country with both a salmon farming industry and wild salmon populations presently protect their natural fish stocks adequately enough.

Another pleasing aspect of this meeting was that, following several incidents last year when the NGOs felt they were being kept at arms’ length from important Council decisions, there were signs that our complaints had been taken onboard.  However, there are still serious issues to address for the NGOs at the autumn intersessional Council meeting, including:

  • The process for completing and reviewing the Implementation Plans – we want to see far more genuine commitment in these plans to protecting wild salmon, particularly from the harmful effects of salmon farming
  • An opportunity for NGOs to input fully to the upcoming external performance review, which will be an independent audit of NASCO’s performance since the previous review in 2012 in achieving its primary objective of protecting wild salmon.
  • Confirmation that NASCO is committed to a fully transparent process in all its work, including NGO access to and involvement in all Council and Commission decisions
  • Through our representation on the Implementation Plan and Annual Progress Report Review Group, NGO involvement in developing TBSSs for upcoming annual meetings
  • Following on the success of this virtual meeting, how much of NASCO’s work could be delivered in this way in future, so cutting down time and money resources in attending meetings, particularly those outside of the main annual event, which we agree should remain face-to-face under normal circumstances

In summary, therefore, a useful meeting where the NGOs achieved our main goal of a TBSS on salmon farming next year.  Much still to do and agree, and we now look forward to the face-to-face intersessional Council meeting in the autumn – provided we are able to travel again by then, of course.

Salmon farmers own data makes the case for much lower sea lice limits

Corin Smith writes,

"Contrary to what you may believe salmon farmers go to great lengths to protect Atlantic salmon smolts from the harm caused by sea lice. The problem is they only protect the smolts inside the salmon farms, not the wild ones on the outside."

 Analysis combining multiple industry and government datasets reveals the low levels at which salmon farmers can, and do, successfully maintain sea lice to protect farmed salmon smolts.

The insight that follows comes with the following explanations and caveats.

Datasets from SEPA, Marine Scotland, Fish Health Inspectorate, Crown Estate Scotland and the Scottish Salmon Producers Organisation were all combined into a single proprietary database. The data covered the period 2018 and 2019. However, it is the case that all of the data is collected and reported by the salmon farming industry itself. There is no independent body which collects, verifies or audits any of the data. There is a lack of transparency with regard to operational methodologies, and therefore consistency of, sea lice count data. Where averages are used by the industry there is no transparency as to how these are derived. There is no information as to how any of these processes may have varied over time. The view we have of the industry is the one it currently permits us to see.

Sea lice counts are recorded by salmon farmers as often as daily and often at the individual pen level. This data is retained within the salmon farming corporations and extends back a period of perhaps decades in some cases.

Where average weekly sea lice numbers on salmon farms in Scotland breach thresholds outlined in The Regulation of Sea Lice in Scotland policy document, (currently 2.0 and 6.0 per farmed salmon and which refers only to a single life stage, gravid females, of a single species “Lepeophtheirus salmonis”)  sea lice counts are reported to Marine Scotland. These reports are therefore sporadic, short lived and of little use for any form of regression analysis.

The Scottish Salmon Producers Organisation also receives sea lice count information from salmon farmers and publishes monthly sea lice averages for each salmon farm in Scotland. The mathematical basis for how the SSPO derives its averages is not published. The SSPO has been publishing this individual farm data since Jan 2018. The effect of using “averages of averages” is to remove a lot of potential volatility in the data.

By way of example Vacasay salmon farm in Loch Roag, reported to Marine Scotland the following weekly sea lice count data:

Week 23: 0, Week 24: “no data”, Week 25: 7.28, Week 26: 24.22

The SSPO monthly average recorded this as: 4.69

There are reasonable explanations for this seemingly implausible mathematical outcome, which reflect the possible use of weighted averages. Analysis of averages alone can be useful for deriving insight, but caution should be noted that they do not, apparently, account for any changes in scale. For example, two salmon farms may have the same average sea lice count, but one may be twice the size of the other. Analysis of absolute emissions is fundamental in assessing risk to wild fish populations. Absolute production/emission of sea lice from salmon farms is a function of an average sea lice number per fish and numbers of fish. Numbers of fish on salmon farms is not a figure which is recorded or reported in any publicly accessible dataset. The resulting abundance and location of salmon farm derived sea lice external to the farm is further dependent on a number of other factors including temperature, salinity, weather conditions and geography.

Clearly there are pros and cons to using a monthly “average of averages” approach, which depend on the intended purpose of the data. However, some useful insight can be derived, especially given the continuity of the dataset in comparison to anything else available. Hence, SSPO data forms the basis of the following insight.

The original proposition was that salmon farms do, in fact, maintain sea lice numbers at low levels, but only when farmed salmon smolts are present. It should be noted that a farmed salmon smolt may be 100gms or considerably larger. Wild salmon smolts are more likely to be between 50-80gms.

Even at lower levels, sea lice on smolts will result in lethal, and perhaps more significantly, sub lethal effects which impact the fish throughout the remainder of its life. In the case of farmed salmon, the effects of sea lice infestations may reduce growth rates and feed conversion, resulting in smaller more expensive to produce salmon. In wild smolts it may reduce the ability of the fish to survive migration, grow at the rate required to catch prey and/or impact fecundity. The immediate lethal effects of sea lice infestation on a smolt varies directly with its size.

The chart below (sea_lice_vs_length_production_cycle) plots the average sea lice count for all farms, for all months in 2018/19, against the stage of the production cycle the count was recorded. A straight average is used.

The simplest interpretation of this data is that sea lice levels are, in fact, effectively maintained at much lower levels in the early stages of a farmed salmon’s life in sea water than in later stages. Further, that there is a strong correlation between rising sea lice levels on salmon farms and the length of time fish have been in the sea water. It is of course the case that the longer a fish spends in sea water, the larger it will get. Length of production cycle is in effect a proxy for fish weight, a data point which is not publicly available.

sea_lice_time

For reference, seasonality of sea lice numbers on salmon farms was also examined. This showed a slight seasonal effect where sea lice levels were higher in September and October. Seasonal effects may be the result of environmental factors; sea temperatures are at their highest in these months and so sea lice reproduce more rapidly. However, it could also be influenced by operational reasons such as larger numbers of farms reaching maturity at this time, relative to other months, in preparation for seasonal trends associated with smoked salmon and Christmas. It is, however, clear that from a statistical perspective that correlation with stage of production cycle is by far and away the dominant factor in sea lice abundance on salmon farms.

sea_lice_month

The table below, shows us that the vast majority of salmon farms managed to maintain monthly average sea lice levels below 0.5 sea lice per farmed salmon for the first twelve months of the production cycle.

Less than 13

Out of a total of 2351 published counts for farms reporting their sea lice levels in the first twelve months of production, 1751 (74%) were at or below 0.5 sea lice per farmed salmon.

The outliers, particularly the figure of 16.68 reflect the fact that from time to time salmon farmers will transfer mature salmon from one farm, to an empty farm elsewhere, for fish health reasons. In the data this is recorded as being Month 1 of the production cycle. This issue occurs in a tiny number of cases.

It would clearly be helpful if salmon farming data indicated information such as fish numbers, fish weight and stage of production/lifecycle.

The chart below shows the same information.

lessthan13months

Growth rates and stocking size of farmed salmon smolts in seawater varies according to different strategies used by the operator. However, assuming a smolt is stocked at 100gms, roughly six to nine months later it will weigh around 1kg. The same size as a small wild grilse on the west coast of Scotland.

On average, we see that salmon farmers maintain sea lice levels at 0.2 sea lice per farmed salmon for the first two months of the sea water phase, when the farmed smolt will grow on from 100gms. This rises to 0.4 in month 4 and by month 10, once the smolt has grown on to approximately 1kg, the average sea lice level has been allowed to more than triple, to 0.7 sea lice per farmed salmon.

When one examines the raw data for the first twelve months of the sea water phase it is the case that there is low degree of volatility in the counts from month to month on individual farms, and also when compared to farms across all operators. This would indicate a relatively high degree of control is being exerted on sea lice numbers by salmon farm operators.

When one introduces data from SEPA’s databases relating to the use of the two main chemicals used to prevent sea lice on salmon farms, a striking picture emerges.

chem_vs_sea_lice

Prima facie it could be said that where salmon farmers use chemicals to prevent sea lice occurring, they do so predominantly in the first twelve months of the production cycle. One could argue this is when smolts would be most adversely affected by sea lice and therefore have the greatest commercial impact on a salmon farm. Every sea louse on a farmed smolt reduces the profit that will be made from it as an adult, as a result of reduced health and growth performance for the rest of its life. As the fish increase in size the sea lice carrying capacity steadily increases. The apparent need for preventative chemical measures declines. As farmed salmon increase in size and age, so the financial impact of higher sea lice numbers declines. To the point where at the end of the production cycle the impacts of very high numbers of salmon farm sea lice on the commercial value of a farmed salmon are negligible, and likely far outweighed by the cost of maintaining them at the low levels present in the early stages of production.

That is of course a simple interpretation. The apparent lack of chemical use in later stages may reflect a transition to well-boat based sea lice strategies (physical and chemical) which can begin to be deployed once the farmed salmon are larger. Well-boat chemical use is not recorded in SEPA’s data set. However, it remains the case that any treatment strategies deployed demonstrably do not maintain sea lice numbers at the low levels that were achieved in the early stages of production.

One issue worth noting is an emerging trend toward stocking farmed smolts at much larger sizes, having been grown on in land-based facilities, which for obvious reasons have no sea lice issues. The rationale for the operator is clear. Doing so effectively eliminates the first year in sea water, a period that clearly requires expensive early stage chemical prophylactics. This strategy, however, presents a new and serious long-term risk for wild salmonids. Much of the discourse about sea lice impacts from salmon farms relates to shocking peak sea lice counts. While damaging and troubling these are relatively isolated.

The table below shows the frequency of monthly sea lice counts for all salmon farms, for all months in 2018 and 2019, aggregated by ranges. One can clearly see the vast majority of sea lice occurrence takes place in the lower ranges.

sea_lice_freq_all_months

It is the ever-present background level of sea lice being emitted from salmon farms that should be of most concern in terms of wild fish conservation.

By effectively removing the first twelve months of the production cycle, all salmon farm production in Scotland would be late cycle all of the time, where much higher levels of sea lice are historically present on salmon farms. If 1kg smolts were stocked on salmon farms and salmon farmers adopted the same tolerable sea lice level strategy shown in the first chart, this would raise the average sea lice floor levels on salmon farms from 0.5 usually seen in the first twelve months, where wild fish have some hope of respite, to a new minimum average of 1.1. This could in effect more than double the minimum background sea lice levels present on salmon farms and being emitted into the environment.

Of course, the farmed fish would be in the water for less time, but this in no way changes the dynamics of sea lice ingress, incubation, proliferation and emission from open cage salmon farms in the late stages of production. Sea lice levels are, after all, a business decision. There’s no indication that salmon farmers would willingly commit additional capital and operational expenditure to reduce late cycle sea lice levels on salmon farms, below that which occurs now. While a shorter seawater phase would potentially benefit the salmon farming business model, it simply means the next batch of bigger farmed salmon arrive earlier in the sea, resulting in a greater constant intensity of salmon farm production.

On this basis shorter production cycles may be dramatically worse for wild salmon, and sea trout in particular, whose lifecycle is often entirely contained in a single location. This is an area which merits considerable investigation to quantify the risks to wild salmonids that a super-size smolt stocking policy on salmon farms could represent.

The Norwegian, Canadian and Faroese corporations that own 99% of salmon farms in Scotland see their potential profit in every farmed smolt. They recognise the harm that salmon farm sea lice will inflict on farmed smolts, and their profits, and so they go to great lengths and expense to protect their investment. It is unconscionable that salmon farmers do not accept an obligation to offer the same protection to Scotland’s wild Atlantic salmon smolts, from the same harm caused by the very same salmon farm sea lice, simply because they are on the other side of a net a few millimetres wide.

Corin Smith was previously commercial operations director at betfair.com with responsibility for insight and optimisation. Latterly establishing a data analysis consultancy serving FTSE and NASDAQ listed clients. He now consults for S&TC on communications and strategy.

Review of the Report of the Salmon Interactions Working Group

Executive summary

Download full review here: HERE

Salmon and Trout Conservation Scotland’s 2016 Petition to the Scottish Parliament led to the 2018 ECCLR and REC Committee inquiries into salmon farming. The REC Committee identified that “the ‘status quo’ in terms of regulation and enforcement of the fish farming industry is not acceptable”.

In response, the Scottish Government tasked the SIWG to look at the conclusions of the Committees, evaluate current policy and advice governing interactions and make recommendations. However, the requirement that the SIWG must reach consensus has prevented the SIWG from bringing forward recommendations that fully address the damage being caused to wild salmonids (salmon and sea trout) by fish farming.

The SIWG has also moved beyond the remit of wild/farmed salmon interactions, considering the wider conservation of wild salmonids and has adopted the ‘narrative’, pushed by Scottish Government and the fish farming industry since 2018, that the impact of fish farms is only one of a large number of pressures upon wild salmonids.

Linkages made by SIWG between reforming the regulation of fish farming and the wider funding of conservation and research into wild salmonids, and the resourcing of DSFBs and Fishery Trusts, are concerning.

Although the proposed move to licensing, and away from planning, as a means to control the impacts of fish farms on wild salmonids is welcome, overall, the recommendations made by SIWG do not amount to a licensing system that would yet be capable of being “robust, transparent, enforceable and enforced” (SIWG, 1.2).

The SIWG makes no reference to the precautionary approach recommended by both the REC and ECCLR Committees. The SIWG’s proposed system of adaptive management, without precautionary underpinning, will fail to protect wild salmonids.

The SIWG’s proposed system would mean that unless there is strong proof that damage is being caused to wild fish, no action needs be taken to improve fish farm performance in respect of sea- lice and diseases (SIWG, 2.2). The same principle would apply when considering closing poorly- sited existing farms (SIWG, 1.14).

There is no requirement for independent monitoring of sea lice number on farms, nor of wild fish.

The SIWG fails to recommend or set any precautionary ‘backstop’ limits for on-farm sea lice, to be set in line with best international standards.

The SIWG fails also to recognise the wider public interest in wild salmonid conservation beyond the interests of fishery proprietors as represented by the DSFBs.

The SIWG recommendations do not meet the rights of the public, guaranteed under the Aarhus Convention, to access to information and to participate in decision-making in environmental matters, in relation to the control of impacts of fish farms on wild fish.

In order to provide a proper basis on which the reform of fish farming regulation can proceed, S&TCS recommends that:

1. A strongly precautionary approach must be applied from the outset to the licensing of both new and existing farms, in line with the recommendations of both REC and ECCLR Committees.

2. There must be a back-stop adult female sea lice maximum on all fish farms, rigorously enforced by tough and prompt action, set at 0.5 per farmed fish, dropping to 0.1 during the period of wild smolt emigration, to set a precautionary ceiling on sea lice numbers , below which adaptive management can then be applied.

3. There must be full publication of all relevant data and information and, specifically, individual farm sea-lice numbers and treatment data must be published in as close to real time as possible.

4. There must be strong independence in both the monitoring of sea lice counts on-farm and of wild fish monitoring, and in the assessment of that data.

5. There must be provision for full and proper public participation in the licensing system and adaptive management processes envisaged by the SIWG.

Salmon Farm Regulation: S&TC initial response to SIWG report

Report fails to advocate the simple regulatory system urgently required to protect wild fish including adherence to the precautionary principle

Initial response to the Salmon Interactions Working Group (SIWG) Report

 Salmon and Trout Conservation Scotland                                                               5 May 2020

On May 1st, the Scottish Government released the “Report of the Salmon Interactions Working Group”. The Group’s terms of reference relate specifically and only to the interactions between farmed salmon and farmed trout and wild salmon and sea trout.

The Report contains 42 recommendations. It concludes that there should be a single body responsible for operating a regulatory system to protect wild salmonids from the effects of fish farms, and it concludes that the regulatory system should be robust, transparent, enforceable and enforced. Unfortunately, the regulatory system outlined by the Report would not achieve that aim.

Burden of proof reversed:

In particular the regulatory system proposed by SIWG lacks any adherence to a precautionary approach to wild salmon and sea trout protection, i.e. that the absence of absolute scientific evidence should not stand in the way of effective management or regulation when damage to wild fish is suspected.

The report recommends that those seeking to protect wild salmon and sea trout will have to prove damage is being caused before any action is taken to regulate poor performance at fish farms. This is quite contrary to the precautionary approach.  It is completely at odds with the Scottish Government’s existing and long-term commitment to the precautionary principle[1] and its legal duty to further nature conservation (including both wild salmon and sea trout)[2]. It also fails to follow the recommendations of both Parliamentary Committees who reported in 2018 that the precautionary approach should be adopted.

A robust and strict precautionary approach is vital to underpin an effective regulatory system. The SIWG envisages the burden of proof being reversed, so that establishing proof that there is damage being caused to wild fish, particularly by sea lice, is to be a pre-requisite to any action being taken by the salmon farm(s). The object should be to act promptly to prevent damage. Monitoring of wild fish in the marine environment is far from an exact science. Reversing the burden of proof will inevitably lead to delay, disputes and legal challenges by salmon farmers determined to maintain or increase production.

Financial support no substitute:

We are concerned that The SIWG report does not just deal with the interactions between farms and wild salmonids. Financial support for research and other conservation work is urgently required but it cannot be considered a substitute for an effective system of regulation.

Omissions:

There are a number of serious omissions from the recommendations, for example:

  • There are no robust maximum on-farm sea lice levels proposed or even envisaged by SIWG that would apply to all farms as a ceiling above which sea lice levels on-farm must not be allowed to rise. This omission is completely at odd with international norms.
  • There is no requirement for the publication in near real time of individual farm sea lice data.
  • There is no requirement for independent monitoring.
  • There are no proposals for effective public scrutiny and monitoring of farm management.

SIWG REPORT:  https://bit.ly/SIWG_report

We will soon be publishing a detailed response to the SIWG Report.

[1] The environmental principles by which the Scottish Government must abide are enshrined in Article 191(2) of Treaty on the Functioning of the European Union FEU, originally the Treaty of Rome. The principles include the precautionary principle, which states that where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing cost-effective measures to prevent environmental degradation.

[2] Section 1, Nature Conservation (Scotland) Act 2004

ENDS

Salmon Farming: New study shows economic costs never assessed by government

An independent economic report [1], commissioned by two leading Scottish charities [2], has revealed that the Scottish Government has failed to assess the costs the salmon farming industry causes to other economic sectors and has only considered those benefits the industry brings.

As a result, the report proposes the Scottish Government’s policy of supporting the substantial expansion of the salmon farming industry should be put on hold until further economic evidence has been obtained including a comprehensive Cost Benefit Analysis.

Report co-author Dr Geoffrey Riddington noted that

"The Scottish Government’s support for salmon farming industry expansion relies exclusively on estimates about income and employment creation. The reality is that the industry’s damage to Scotland’s inshore waters must result in many other stakeholder groups being worse off. At no time has the Scottish Government even identified these stakeholder groups, let alone calculated the extent of their costs."

The report estimates that the salmon farming industry’s "Gross Value Added", which has been extensively quoted and relied on by Highlands and Islands Enterprise and Marine Scotland, is possibly exaggerated by 124%, whilst employment could be overestimated by a massive 251%’ and that, given an "evidence base that is partial, incomplete, unreliable and even irrelevant, it is difficult to understand how the Scottish Government can sensibly address the question of whether further damage to Scotland’s marine environment is a price worth paying."

The report also questions the way the salmon farming industry’s economic contribution is reported, noting how a widely reported £2bn turnover figure for aquaculture companies and their trading partners has been conflated with overall economic impact. [3, 4] The report notes that such turnover figures "do not relate to any coherent economic performance indicator and should not influence public policy."

Andrew Graham-Stewart of Salmon and Trout Conservation Scotland, which co-commissioned the report, said

"This study lays bare the basic deficiencies in the evidence which underpins Scottish Ministers’ unstinting support for the salmon farming industry. It is fundamentally flawed for official policy to ignore the considerable damage inflicted on the coastal environment and the consequential losses which other interests suffer due to the presence of salmon farms. Given the value of our marine environment to the public and local communities, policy should be based upon Cost Benefit Analysis, not upon Benefit Analysis. Only assessing half the impacts of an activity is not good enough."

Charles Millar of Sustainable Inshore Fisheries Trust, co-commissioner of the report, said

"By considering only the benefits and ignoring the costs, Ministers are skewing the debate about how Scotland’s inshore waters should be managed. If Scotland is to look after the long-term prospects of our marine dependent communities, it's time to take proper account of the economic activity lost as a consequence of aquaculture, whether that's inshore fishing, recreational sea angling or tourism. It is vital that the Scottish Government commissions an independent assessment of the economic contribution of salmon aquaculture that considers the industry in the round."

The report has been subjected to an independent peer review [5].

ENDS

Further information available from Charles Millar of SIFT (07775 914996) and Andrew Graham-Stewart of S&TCS (07812 981531).

 

NOTES TO EDITORS

1. The Economic Contribution of Open Cage Salmon Aquaculture to Scotland: A Review of the Available Economic Evidence by Geoff Riddington, Alan Radford and Hervey Gibson, January 2020.

Full Report: https://bit.ly/Contribution_Salmon_Aqua_Scotland_full_report

Executive Summary: https://bit.ly/Contribution_Salmon_Aqau_Scotland_exec_summ

2. Salmon and Trout Conservation Scotland (www.salmon-trout.org/countries/scotland/) and Sustainable Inshore Fisheries Trust (www.sift-uk.org).

3. ‘An overall economic impact of more than £2bn represents a major benefit to the Scottish economy’ - SSPO, quoted in Salmon Business Website, accessed 15/09/2019.

4. ‘Aquaculture is one of our real economic success stories of recent years, with the industry on track to grow to a value of well over £2bn annually to the Scottish economy by 2020’ – Fergus Ewing, Cabinet Secretary for Rural Economy (www.bbc.co.uk/news/uk-scotland-scotland-business-37781081).

5. The commissioning charities also commissioned an independent peer review of the report. Peer Review of the Economic Contribution of Salmon Aquaculture to Scotland by Bridge Economics, April 2020.

Full report: https://bit.ly/pr_full_contribution_salmon_aqua

Executive Summary: https://bit.ly/pr_exec_contribution_salmon_aqau

The peer review concludes that the evidence on which Scottish Government relies for expanding salmon farming is "partial, incomplete and inappropriate for use in assisting public sector decision making’ and that ‘if the Scottish Government does propose to support expansion of the Scottish aquaculture sector then a proper assessment needs to be made."

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.