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.

The SAMARCH Project International Salmonid Coastal and Marine Telemetry Workshop

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SAMARCHLogo

The "Blue Book"

Based on a workshop organised by Salmon & Trout Conservation and Game & Wildlife Conservation Trust on behalf of the SAMARCH Project and the Atlantic Salmon Trust in Southampton, UK, on the 5th and 6th November 2019.

SAMARCH is a five-year project with a grant of €5.8m from the EU’s France Channel England Interreg Channel programme.

Download HERE

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)

S&TC launches first SmartRivers hub in Scotland

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

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

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

Nick Measham, S&TC Deputy CEO said:

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

image1

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

"SmartRivers Delivering Results"

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

Reuben Sweeting, Head Ghillie on the River Halladale said:

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

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

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

Lauren Mattingley, SmartRivers Project Manager S&TC said:

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

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

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

Alan Youngson, Scientific advisor, FCRT

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

John Mackay, Chairperson, Flow Country Rivers Trust said:

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

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

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

ENDS

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

Reporting with a purpose

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

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

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

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

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

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

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

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

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

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

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

Scottish Ministers’ lamentable failure to regulate salmon farming

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

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

ISSUED: 20 Feb 2020

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

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

ECCLR: http://bit.ly/ECCLR_salmon_farming

REC: http://bit.ly/REC_salmon_farming

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

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

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

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

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

Relentless growth of the industry has continued

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

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

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

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

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

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

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

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

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

Angling Trust

Community of Arran Seabed Trust (COAST)

Craignish Restoration of Marine & Coastal Habitat (CROMACH)

Fairlie Coastal Trust

Friends of Loch Etive

Friends of the Sound of Jura

Loch Visions

North and West District Salmon Fishery Board

Open Seas

Orkney Trout Fishing Association

Save Seil Sound

Scottish Creel Fishermen’s Federation (SCFF)

Scottish Salmon Think-Tank

Sea Change Wester Ross

Sealife Adventures

Skye Communities for Natural Heritage

South Skye Seas Initiative

Tay Ghillies Association

Added since news release:

Coastal Communities Network Aquaculture Sub-Group

Eigg Environmental Action Group

Friends of Loch Creran

Salmon Aquaculture Reform Network Scotland (SARNS)

The Meikleour Arms

Tay Salmon Fisheries

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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.