S&TCS briefing as Scottish Government debate the future of salmon farming

TODAY: Scottish parliament to debate the Rural Economy and Connectivity (REC) committee report on salmon farming

Legislative impact is expected to follow on from today's debate, Wednesday 6th February 2019, for which S&TCS have contributed the following briefing:

S&TCS briefing for MSPs for salmon farming debate Feb 2019

STCS Briefing Addendum - SG's response to REC Report Feb 2019

S&TCS salmon farming debate briefing

S&TCS concerns concentrate on the proven negative effects of salmon and rainbow trout farming at sea on wild salmonids - both Atlantic salmon and sea trout. It has been clear for many years that Scotland’s performance, particularly on sea lice, falls very far short of the internationally agreed NASCO goals.

As a bare minimum S&TCS wishes to see the following five changes in Scotland, all of which were supported by both REC and ECCLR Committees:

  1. The development and introduction of full closed containment farming.
  2. The clear identification of a Scottish public authority charged with the statutory function to protect wild fish from the negative interactions of fish farming.
  3. No expansion of the industry while wild fish interactions remain uncontrolled.
  4. Relocation of existing sensitive sites.
  5. Full transparency and publication of sea lice, escapes, mortalities and disease information.

The Scottish Government response is in danger of allowing the “status quo”, in terms of the regulation and legislation of salmon farms (and transparency in the way that the industry operates), to persist for the foreseeable future.

This would be in stark contrast to what the ECCLR and REC Committees have both advocated after exhaustive examination and consideration. Both Committees identified major shortcomings in the way that the industry is permitted to operate. Action to remedy matters, rather than further prolonged discussion, must now be the priority.

Read the S&TCS briefing in full:

S&TCS briefing for MSPs for salmon farming debate Feb 2019

STCS Briefing Addendum - SG's response to REC Report Feb 2019

Background: 2018 Rec Committee report

The REC committee report was published in November 2018, following the Environment, Climate Change and Land Reform (ECCLR) committee report.

Read more: S&TCS warmly welcomes the Rural Economy and Connectivity (REC) Committee’s report on salmon farming

Read more: S&TCS applauds Environment Committee report into environmental impacts of salmon farming

Both 2018 Parliamentary inquires into salmon farming, as conducted by the ECCLR and REC Committees, were triggered by S&TCS’ formal Petition to the Scottish Parliament’s Petitions Committee in 2016.

The 148-page REC report found that urgent action was needed to improve the regulation of the Scottish salmon farming industry and to address fish health and environmental challenges. Commenting on the REC report in November, Andrew Graham-Stewart, Director of S&TCS, said:

We applaud the REC Committee’s report, which cuts through many years of Scottish Government and industry spin and prevarication.

The onus is now on Scottish Government to act without delay to implement the Report’s recommendations, giving wild fish much needed protection from sea lice and diseases emanating from salmon farms”.

S&TCS look to the Scottish Government to take action today.

2018: A year in review

What have we achieved this year?

2018 has been our biggest year yet! So where has your support got us, and what have we done for wild fish protection and conservation? Our CEO's Year In Review summaries our influence, accomplishments and campaigns over the past 12 months. 

With the help of our many donors, members and grant-making Trusts, S&TC has had a successful year in influencing a number of wins for wild salmon and trout. The below is a quick summary; however you can download the full review here.

Accomplishments:

  • Salmon farming - we were the major catalyst in achieving TWO game-changing Scottish inquiries into salmon farming impacts on wild fish and environment:
    • ECCLR – they conducted the first Inquiry and their Report included the one-liner: the status quo is no longer an option.
    • REC - their Autumn Report was highly critical of the way salmon farming is operated and regulated and presented 65 recommendations for improvement, including most of our main asks.
  • NASCO - we work internationally on wild salmon issues through NASCO, our CEO being co-chair of the accredited NGOs which gives us unprecedented influence. Amongst other issues, we have used NASCO to influence netting closures and pressurise Scottish salmon farming.
  • Riverfly Census - 3 years and 20 rivers later, we have professional and actionable evidence of various pollutants impacting river health, nationally and locally.
    • Census results have shown up the alarmingly poor condition of some of our most high-profile rivers, particularly from sediment and phosphate, and we co-authored a peer-reviewed paper showing the lethal impact of those two stressors on mayflies.
    • The full Riverfly Census report is currently being compiled but has already influenced new invertebrate species and abundance targets for chalkstreams. The Test and Itchen report is now available.
  • Living Rivers - we've been sampling daily phosphate and chemical levels on local chalkstreams, highlighting and challenging some appalling ecological conditions, specifically:
    • Using a case study on the Upper Itchen at Alresford Salad’s washing plant to fight for the elimination of toxic chemical discharges into SAC rivers.
  • Other S&TC policy work - There has been plenty of other work this year, including but definitely not limited to:
    • Water abstraction reform.
    • Agricultural post-Brexit policy.
    • Our seat on the EA’s Water Leaders’ Group, which covers all environmental water issues.
    • Our seat on the National Drought Group, where we have represented wild fisheries since 2011.

Next Steps:

  • Salmon farming - drive the REC Committee’s recommendations through Government so that they are acted upon rather than ignored.  In particular:
    • Scottish Government to adopt legal responsibility to protect wild salmon and sea trout from the impacts of salmon farming.
    • An independent agency to regulate salmon farming against sea lice trigger levels that protect wild fish, with the sanction of forced harvest on persistent offenders.
    • A moratorium on establishing/expanding farms in sensitive locations and movement of existing farms away from migration routes.
    • Incentives for companies to move into closed containment production.
  • Netting - we are concerned that sea trout will still be exploited in some of the north east coastal nets and we will be seeking more action in 2019 to protect sea trout.
  • SMARTrivers - Our new project, based on training and utilising high resolution citizen science to understand and improve wild fish water quality.
  • Living Rivers - We will continue to fight for the protection of the Upper Itchen and have major chemical sampling plans for other rivers in 2019.
  • Much more - stay tuned for our 2019 plans, in January.

Why you should go salmon-free this Christmas

A Christmas favourite it may be; but there is nothing festive nor joyous about farmed salmon.

Salmon is considered by many to be a Christmas staple, its murky journey from net-pen to plate concealed behind tinsel-clad wrapping and slick marketing.

Two parliamentary inquiries have this year confirmed the need for rapid change in salmon farming, which is causing widespread environmental destruction and the devastation of wild fish. We have campaigned for these changes for years; but what can be done until this happens...?

And for the uninitiated, what are the issues with farmed salmon? Our CEO, Paul Knight, explains why farmed salmon is best avoided - at Christmas, and until the industry changes...

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Why you should go salmon-free this Christmas

This year’s reports from two Scottish Parliamentary Committees - Environment, Climate Change and Land Reform (ECCLR), and Rural Economy and Connectivity (REC) – following their inquiries into salmon farming, are both unequivocal; we have to adopt a far more precautionary approach to salmon farming to stop it damaging wild salmon and sea trout populations.

Quite apart from the many millions of farmed salmon dying in their cages every year through disease, parasites and the negative effects of both physical and chemical treatments for sea lice, the stark fact is that politicians from all Scottish political parties agree that Scotland’s already beleaguered wild migratory fish stocks need to be protected from the impacts of open-net salmon farming on Scotland’s west coast and Islands.

These reports vindicate Salmon & Trout Conservation’s strong campaigning over many years – the ECCLR and REC inquiries only came about because of our official Petition to Scottish Parliament in 2016 – and confirm what most of us have known for years. The challenge for us now is to drive through the Committees’ recommendations so that Scottish Government introduces, as a matter of urgency, far stronger regulation of the salmon farming industry.

This includes more sensitive siting of farms, well away from wild salmon and sea trout migration routes. One of S&TC’s key objectives received prominence in the REC Committee report - the incentivisation of companies to invest in closed containment units that physically and biologically separate farmed salmon from the natural environment and wild fish.

However, that all takes time. So what can we do?

Take a stand for wild fish

What we, as consumers, can do right now is to drive home the message to salmon producers by refusing to buy any farmed salmon products this Christmas (or indeed at any time until the industry becomes environmentally sustainable).

Forget ‘organic’ salmon (here's why), or any other marketing gimmick that tries to tell you these fish are farmed responsibly.

Read more: Organic Farmed Salmon - Let's Get Real

As it stands today, all open-net salmon farming can cause problems. None are truly environmentally sustainable.

❌ There is always the very real risk that any farm can suffer from too many sea lice parasites, which then release huge numbers of sea lice larvae into sea lochs, where they attack wild fish.

❌ Any farm can also suffer human error or storm damage that allows large numbers of farmed salmon to escape and breed with wild salmon and dilute natural gene pools.

❌ And then there is the fouling of the sea bed around cages...

❌ And those millions of dead salmon that never make it to the market because disease or chemical treatment, or just plain bad husbandry, kill them first.

❌ And more...

Urgent action now required

As the Scottish Parliamentary Committees have now identified, the Scottish Government has to act fast and decisively to save the worst parts of the industry from itself and, in doing so, save wild fish. Action now help ensure that wild salmon and sea trout are genuinely protected in Scotland.

Until then, we can send a clear message to salmon producers, just as Scottish Parliamentary Committee members have this year - current salmon farming practices are just not acceptable anymore, and the industry must evolve quickly if it is to win back the public’s confidence to buy its products again.

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So, this Christmas (and until standards improve) take a stand for wild fish by taking a hard pass on any farmed salmon. Use the power you have - the power of the mighty Pound.

S&TCS warmly welcomes the Rural Economy Committee’s report on salmon farming

S&TCS warmly welcomes the Rural Economy Committee’s report on salmon farming

Scottish Government must now act quickly to put in place greater protection for wild salmon and sea trout.

Salmon and Trout Conservation Scotland (S&TCS) has warmly welcomed the Rural Economy and Connectivity (REC) Committee’s report on salmon farming, published today.

The report builds on the Environment, Climate Change and Land Reform (ECCLR) Committee’s report published in March.

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

“This Report is a strong vindication of the campaign S&TCS has spearheaded for some years now, and the arguments we have been putting forward, often in the face of sharp criticism from both the industry and Scottish Government alike.

We are pleased to see that the REC Committee has recognised that the law is currently insufficient to protect wild salmon and sea trout from the damaging impacts of salmon farming.

We now look to Scottish Government to grasp the nettle and move quickly to legislate to improve markedly the protection of wild salmon and sea trout from the negative impacts of salmon farming.”

Key conclusions and recommendations in the REC Committee’s report include:
  • “….if the industry is to grow, the Committee considers it to be essential that it addresses and identifies solutions to the environmental and fish health challenges it faces as a priority” (Recommendation 1)
  • “….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)
  • Sea lice triggers to be “…challenging” and Government urged to “set a threshold that is comparable with the highest international industry standards” (Recommendation 15)
  • “…a move away from a voluntary approach to compliance and reporting with regard to sea lice infestation” (Recommendation 16)
  • In relation to breaches of sea lice levels, “enforcement action… has not been sufficiently robust to date. It is therefore of the view that if the revised compliance policy is to be effective it must be robust, enforceable and include appropriate penalties” (Recommendation 17)
  • Sea lice data in real time to be published in real-time, made mandatory and “the data provided should be that which is required to inform the regulatory and enforcement regimes, as opposed to that which the industry itself takes it upon itself to produce” (Recommendations 19 to 21).
  • “the Committee is….of the view that a precautionary approach should be taken which will seek to minimise the potential risk to wild salmon stocks wherever possible” (Recommendation 40)
  • “the Committee suggests that the siting of salmon farms is key to managing any potential risk to wild salmon stocks and ensuring that the sector is managed responsibly” (Recommendation 41)
  • on the issue that none of the existing regulatory bodies currently has responsibility for the impact of salmon farms on wild salmon stocks, “the Committee believes that clarity must be provided by the Scottish Government as to how this apparent regulatory gap will be filled and which agency will assume responsibility for its management”. (Recommendation 44)
  • “The Committee shares the view of the ECCLR Committee that the siting of farms in the vicinity of known migratory routes for wild salmon must be avoided” (Recommendation 45)
  • “The Committee is of the view that a…precautionary approach must be taken in Scotland to assist in mitigating any potential impact of sea lice infestation on wild salmon. It therefore recommends that there should be an immediate and proactive shift towards siting new farms in more suitable areas away from migratory routes and that this should be highlighted in the strategic guidance on the siting of salmon farms”. (Recommendation 46)
Andrew Graham-Stewart, Director of S&TCS, said:

“Scottish Government has a clear duty to safeguard the coastal environment and those species, including wild salmon and sea trout, that depend upon healthy coastal ecosystems.

We applaud the REC Committee’s report, which cuts through many years of Scottish Government and industry spin and prevarication. The onus is now on Scottish Government to act without delay to implement the Report’s recommendations, giving wild fish much needed protection from sea lice and diseases emanating from salmon farms”.

This year’s Parliamentary inquiry into salmon farming, as conducted by the ECCLR and REC Committees, was triggered by S&TCS’ formal Petition to the Scottish Parliament’s Petitions Committee in 2016.

“Organic” farmed salmon – let’s get real

“Organic” farmed salmon

Similar scenarios play out at dinner tables up and down the UK, particularly during the festive season.

Salmon, either smoked or “fresh”, is served and the host, feigning environmental awareness, announces along the lines of:

“Don’t worry, we are always very responsible – we only ever buy ‘organic’ salmon.”

But is eating “organic” farmed salmon really environmentally responsible?

The blunt and unequivocal answer is, no!

“Organic” salmon is a con. It is simply a marketing ploy‎, aimed at the naive and ignorant well-heeled, especially those who frequent the more prestigious supermarkets and food emporiums, to persuade them to pay a premium price for something that is almost the same as bog standard farmed salmon.

The only real difference is that “organic” salmon is stocked in open net cages at a lower density. There is no separation between the farmed fish and the wider environment; fish faeces, in vast quantities, still pollutes and destroys the integrity of the seabed.

“Organic” salmon farmers still use all the same chemicals, including lice treatments, thus killing other crustaceans in the vicinity.

The problems with lice and escapes are just as prevalent in “organic” salmon - hence the impacts on wild fish are identical.

The Soil Association’s indefensible endorsement of any farmed salmon undermines the credibility of, and indeed is an indelible stain on, the organisation’s reputation.

So, the next time you hear a smug announcement from your host that the salmon being served is so-called “organic” and therefore by implication “is ok to eat”, I suggest giving it a wide berth.

At the same time, you should tactfully explain that he or she is being duped and, if they give a damn about the environmental damage all salmon farming, including that purporting to be “organic”, causes (especially to wild salmon and sea trout in the west Highlands and Islands), they should not allow such dross of sham pedigree to besmirch and contaminate their table.

 

Views of our Scottish Director, AGS

Salmon farming industry blames wild fish for sea lice infestations

Sea lice on farmed salmon – the ultimate solution

In September, following months of media exposes of salmon farming’s dire environmental failures, the Scottish Salmon Producers’ Organisation (SSPO) announced the appointment of a leading political journalist to the newly created role of “Director of Strategic Engagement”.

In the SSPO’s news release, the appointee is quoted as “looking forward to playing my part in helping the industry cement its already excellent reputation for sustainability...”. One wonders just where he has been to reach such a view of the industry’s record!

Now it seems that his first strategic initiative is coalescing. The strategy, designed to deflect criticism when sea lice numbers on farms spiral out of control, is to shift the blame.

Salmon farming industry blames wild fish

Recently S&TCS have been forwarded emails from two industry luminaries, addressed to Scottish Ministers and other influential MSPs. They both make similar points:

Julie Hesketh-Laird, CEO SSPO:

"With respect to lice, our members operating in sea lochs can observe an increased sea lice challenge in an environment in which they coexist with returning lice burdened mature wild salmon."

Ben Hadfield, MD Marine Harvest Scotland:

"We associate returning (wild) adult salmon with a period of enhanced infection rates of farmed stock, which are placed in the sea without a sea lice challenge."

In essence the salmon farming industry blames wild fish. They are saying that wild mature or adult salmon are to blame, indeed that they are the cause of the industry’s sea lice woes.

They clearly imply that we should forget about poor management and/or husbandry on farms and the fact that hundreds of thousands of fish crammed into a confined netted area are a perfect breeding reservoir for sea lice, because wild fish are the problem.

The logical extension to Ms Hesketh-Laird’s and Mr Hadfield’s ludicrous statements is that, in order to eliminate sea lice issues on farms, all wild salmon in the salmon farming areas of the west Highlands and Islands should be exterminated; indeed, do away with wild fish and at a stroke you remove much of the opposition to salmon farming and its expansion.

Salmon farming PR machine

To the industry, sustainability is just a vague PR concept to which cynical lip-service has to be paid.

And, as for the fate of wild fish, on the evidence of recent events, they really do not give a flying fig.

Incidentally, Ms Hesketh-Laird and Mr Hadfield are the industry’s two representatives on Scottish Government’s new Salmon Interactions Working Group, yet another talking shop initiative designed to kick the real issues for wild fish deep into the long grass.

If their input is consistent with their quotes above, then it should be a very short-lived affair.

What next?

We await the report from the current Parliamentary Inquiry into the industry, and wonder what the committee members might think of this seemingly desperate attempt by salmon farmers to lay the blame for their lice issues at the door of wild migrating salmon, a species that has been returning to Scottish west Highland and Island rivers since the Ice Age.

Meanwhile, be assured that S&TC Scotland will continue to fight to protect these fish, and their sea trout relatives, from the ravages of Scottish open-net salmon farming – an industry with an appalling environmental record and an increasingly desperate list of lamentable excuses.

- AGS

Loch Roag Sea Lice: SSPO Defence Falls Flat

Mea culpa……mea what?

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

Wild Adult Salmon Run Decimated By Sea Lice

 

The tip of the iceberg

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

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

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

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

 

Loch Roag sea lice

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

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

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

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

 

Salmon industry reaction

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

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

But no, not a chance.

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

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

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

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

 

SSPO and The One Show

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

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

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

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

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

-AGS

Wild Adult Salmon Run Decimated By Sea Lice

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

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

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

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

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

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

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

All badly damaged fish will eventually die.

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

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

 

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

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

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

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

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

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

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

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

 

Devastating consequences for wild fish populations

Mr Graham-Stewart added:

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

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

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

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

 

The law is insufficient to protect wild fish

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

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

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

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

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

 

Notes for editors

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

Salmon Escapes Removed From Database

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

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

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

 Mr Linley-Adams continued:

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

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

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

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

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

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

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

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

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

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

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

 

Salmon Escapes a 'Cause For Concern'

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

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

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

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

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

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

 Guy Linley-Adams commented:

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

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

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

 

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

 

Notes for editors

 

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

2) The Scadabay “escape”

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

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

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

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

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

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

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

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

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

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

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

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

43/2018 Salmon and Trout Conservation Scotland Scottish Environment Protection Agency Information relating to the use of sea lice medicine For applicant 26 Mar 2018
013/2018 Salmon and Trout Conservation Scotland Scottish Environment Protection Agency Correspondence with Marine Scotland For applicant 31 Jan 2018
010/2018: Salmon and Trout Conservation Scottish Environment Protection Agency Report on the environmental impact of sea lice medicine For applicant 29 Jan 2018
199/2017 Salmon and Trout Conservation Scotland Scottish Environment Protection Agency Information concerning sea lice medicine For applicant 30 Nov 2017
191/2017 Salmon and Trout Conservation Scotland Scottish Ministers Report on the environmental impact of sea lice medicine For applicant 20 Nov 2017
142/2017 Salmon and Trout Conservation Scotland Scottish Ministers Control and reduction of sea lice on fish farms For applicant 04 Sep 2017
063/2017 Salmon and Trout Conservation Scotland Scottish Ministers Control of sea lice on fish farms: failure to respond within statutory timescales For applicant 02 May 2017

4) The NASCO Williamsburg Resolution

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

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

S&TCS FOI Requests

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

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

 

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

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

Guy Linley-Adams said:

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

 But this is not the first time.

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

 

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

 

43/2018 Salmon and Trout Conservation Scotland Scottish Environment Protection Agency Information relating to the use of sea lice medicine For applicant 26 Mar 2018

 

013/2018 Salmon and Trout Conservation Scotland Scottish Environment Protection Agency Correspondence with Marine Scotland For applicant 31 Jan 2018

 

010/2018: Salmon and Trout Conservation Scottish Environment Protection Agency Report on the environmental impact of sea lice medicine For applicant 29 Jan 2018

 

199/2017 Salmon and Trout Conservation Scotland Scottish Environment Protection Agency Information concerning sea lice medicine For applicant 30 Nov 2017

 

191/2017 Salmon and Trout Conservation Scotland Scottish Ministers Report on the environmental impact of sea lice medicine For applicant 20 Nov 2017

 

142/2017 Salmon and Trout Conservation Scotland Scottish Ministers Control and reduction of sea lice on fish farms For applicant 04 Sep 2017

 

063/2017 Salmon and Trout Conservation Scotland Scottish Ministers Control of sea lice on fish farms: failure to respond within statutory timescales For applicant 02 May 2017

 

 

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

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