MoRPh: a tool for assessing river habitats at biological monitoring sites

As you probably already know, SmartRivers is proud to be part of the Riverfly Partnership's 'Riverfly Plus' toolkit, alongside other exciting citizen science projects like MoRPh - the modular river survey

River organisms respond to their environment and so it is important to monitor any environmental changes. Often the environment is characterised through water chemistry and temperature, but the physical and hydraulic habitat structure of the river and its margins are also very important.

The MoRPh survey was developed to inventory habitats within a river channel and along its margins at a scale appropriate for characterising the physical environment at biological monitoring sites. Originally the biological monitoring was envisaged to be kick sampling of macroinvertebrate communities, and so MoRPh was designed to capture habitat within a rectangular area extending back 10 m across both river bank tops and along a length of river roughly equivalent to twice the river width. By conducting 10 adjacent MoRPh surveys along a river, a river length of approximately 20 channel widths is inventoried, which should be sufficient to capture the larger range of habitats available to more mobile species such as fish. I expect that both these scales are of interest to readers because invertebrates are food for fish!

The MoRPh survey records flow velocity patterns; sediments, including areas of siltation of the river bed; physical features such as pools, riffles, bars, bank profiles, ponds; the structure and extent of the river bed, edge and bank top vegetation; and the types of human interventions (pipes, weirs, bank reinforcement) and pressures from adjacent land use. These observations are recorded by not only ticking the type of feature that is present on a list but also by estimating the feature’s abundance through either a count (pools, riffles) or a category of percentage cover (gravel, vegetation structural type). There are three feature lists to complete, one for the bank tops, one for the bank faces and one for the river bed. In addition, the surveyor records details of where the survey is located, so that it can be shown on a map, and also the approximate size of the river channel, because river channel properties are strongly affected by river size.

MoRPh surveyors are allocated a log-in to an information system that stores and maps their data, calculates some useful indicators from their survey data, and allows raw data and indicators to be downloaded. The indicators include the degree of siltation, the average and largest sizes of the bed material, and the physical and vegetation complexity of the river bed. These bed-indicators are extremely useful for monitoring short-term (monthly, seasonal, annual) changes in the river bed that may impact on the invertebrate community. Broader changes in the river channel and its margins also have important impacts on river organisms but these changes usually occur more slowly, making monitoring most effective at an annual or longer timescale.

If you are interested in the MoRPh survey and would like to find out more, have a look at the Modular River Survey website: www.modularriversurvey.org.

- Prof. Angela Gurnell, Queen Mary University of London

Persistence pays off in the pursuit of a pesticide problem

This is a terrific outcome for the river, wild fish, the wider environment and the local community.

Nick Measham, CEO S&TC writes,

Bakkavör is closing its salad washing plant at Alresford on the Upper Itchen. In simple terms this should result in an end to significant chemical pollution and provide much needed respite for all biodiversity associated with the river.

It is difficult to celebrate this terrific result for the environment while at the same time local employees of Bakkavör face job losses. But, we should. In our experience it is rarely the case that it comes down to” jobs or the environment”, more often than not there are technical and operational solutions to pollution problems which require only modest investment. It really is the responsibility of Boards to balance their need for every penny of profit, over livelihoods and the environment of local people. Certainly, it is S&TC’s view that consumers and communities are increasingly demanding a “jobs and the environment” approach from business. The environment does not need to be sacrificed for economic growth. We wanted Bakkavor to discharge its environmental obligations to stop polluting the river. We were not seeking closure.

On purely environmental grounds the end to pollution from salad washing is an outcome which we are delighted with. We hope that the local people and community groups long associated with the river will reap the benefits of its increasing health. From our own perspective the closure is a reassuring vindication of S&TC’s unique, and demonstrably effective, strategy to drive change and improve river health to directly benefit wild salmon and trout. A combination of outcome focused scientific study, robust legal posture and patient but forceful campaigning.

Some years ago, following concerns raised by local residents, anglers and conservationists, S&TC lent its weight to efforts to end the environmental damage that Bakkavör was suspected of causing. It was as a direct result of S&TC’s model of producing scientifically analysed invertebrate data on the Itchen (which we popularised under the River Fly Census banner) that we were able to force the Environment Agency to undertake further research into potential pollution coming from the salad washing plant. In June 2018 S&TC made a formal notification of environmental damage to the Environment Agency (EA), pursuant to the Environmental Liability Directive. The EA investigation exposed a number of issues with the site, some of which were resolved promptly, but a pesticide threat was highlighted, which, until the recently announced closure of the plant, remained unresolved and subject to continuous pressure. At the time of the closure, the EA was in the process of imposing a monitoring regime on Bakkavor and Vitacress, its neighbour on a tributary of the River Test, with highly precautionary pesticide discharge limits. It remains to be seen how Vitacress will respond to the challenge of cleaning up its discharge.

S&TC’s role in leading a scientifically evidenced approach to highlight the environmental damage attributable to the operation allowed us to engage significant local and national media interest, including a feature on the BBC’s Countryfile.

Not only did S&TC’s investigations reveal problems with Bakkavör’s operations, it also shone a light on the serious inadequacies of regulation and enforcement options for the EA. Exploration of these issues has led to further revelations which are of national significance. The likelihood of the same issues at Bakkavör Alresford Salads and Vitacress being replicated in other settings, in terms of pollution and inadequate regulation, appear to be high.

A successful outcome in one location will provide a compelling case study, a proven model for eradicating chemical pollution and potentially significant reform of the EA licensing regime across the country.

The chemical problem is national in scale and, if it is to be addressed, it requires a robust, fit for purpose, regime around licensing, monitoring and enforcement.  Both locally and nationally S&TC is using its scientifically based evidence to effect change. S&TC will continue to campaign and create energy and enthusiasm for change, but as with Bakkavör, patience will be required to accommodate the hurdles the EA faces.

Data collection, analysis, legal fees and staff time has come at a significant financial cost, and it is without doubt that our members and donors are owed a debt of gratitude. Being truly financially independent has its challenges, but it allows S&TC to campaign, free of conflicts of interest, more powerfully and effectively.

This is a terrific outcome for the river, wild fish, the wider environment and the local community.

Media Coverage:

Countryfile: https://www.salmon-trout.org/2019/06/17/bakkavor-alresford-salads-impacting-upper-itchen/

https://www.hampshirechronicle.co.uk/news/18602214.updated-salmon-trout-conservation-argue-alresford-salads-pollution-river-itchen/

https://www.endsreport.com/article/1690492/salad-washing-plant-pumped-harmful-levels-neonicotinoid-chalk-stream

https://www.hampshirechronicle.co.uk/news/18630704.bakkavor-close-alresford-salad-branch-loss-100-jobs/

https://www.hampshirechronicle.co.uk/news/18651943.mixed-reaction-bakkavor-factory-closing-doors/

S&TC Recent Press Releases:

Levels of Acetamiprid, a pesticide discharged by Bakkavor into the upper Itchen catchment, have regularly exceeded acceptable concentrations by a factor of up to four times.

https://www.salmon-trout.org/2020/06/23/toxic-neonicotinoid-washed-off-salad-leaves-into-protected-chalkstream/

Identification of 36 other chemicals from Bakkavor Alresford salad washing activities which could be causing environmental damage.  The company declared they were permitted although the EA believed they “present a real or present danger to the environment”.

https://www.salmon-trout.org/2020/07/23/thirty-six-toxic-pesticides-washed-into-headwaters-of-sac-chalkstream/

Reporting with a purpose

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

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

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

Phosphorus, Chickens and the River Wye

S&TC’s agricultural policy is simple; incentivise farmers to invest in their infrastructure and spread the word about modern soil management, but always be prepared to use the current legislation to regulate persistent offenders...

Paul Knight, S&TC Fisheries Consultant

George Monbiot writing in the Guardian recently highlighted the dreadful state of Welsh rivers.  He focussed on the Wye, where intensive chicken farming discharges phosphate (P) at far greater levels than the safe carrying capacity of the river, leading to awful water quality and subsequent impact on its wildlife.  The NFU hang on the coattails of Natural Resources Wales, who state that P has improved in the river over recent years, but rather than crow that excess nutrient is no longer a problem, it is important to understand the way P acts in a river, and why no-one should be complacent about the state of the Wye or its sister Welsh rivers.

The easiest way to explain P’s impact on a river is to think of a cliff gently sloping down until it reaches an edge, which then drops vertically into the sea – let’s give the cliff-edge a value of 30 and the top of the gentle slope as 100.  P at 40 has broadly the same impact on water quality as it does at 100 – too much nutrient leading to excess algae growth, discoloured water and the ‘dirty’ riverbed to which George Monbiot  alludes, but once it drops back to 30, the improvement is dramatic, and the symptoms fall away, you might say, over the cliff edge and into the sea.

This rather simplistic explanation has an important message, cutting P back from 100 to, say, 50, is a huge improvement, to which government agencies and the likes of the NFU will crow about the great job being done.  However, in terms of water quality improvement that actually supports more resilient and healthy life in the river, it is virtually useless.  More work needs to be done to reach 30 at the cliff edge, and then the river really starts a rapid improvement.

So why is excess P a problem to water life, apart from making the river environment murky and the bed gravels covered in algae?  S&TC’s Riverfly Census showed that P, along with sediment and toxic chemicals, are the biggest river polluters across the UK, and that agriculture is their main source. Our further research proved that high P levels, particularly in conjunction with sediment, kills water insects, the vital basis of a river’s food chain.  So, P, especially in conjunction with sediment, is actually toxic to water life unless kept down to natural values, 30 in our scenario.

S&TC is now using this evidence to press Welsh government and Natural Resources Wales, and Defra/Environment Agency (EA) in England, to take river pollution seriously and tighten agricultural regulation to ensure that the wildlife of rivers such as the Wye have a much more natural environment in which to thrive.  We can never return our watercourses to their truly natural state, there will always be human impact in such a closely managed countryside as we have in the UK, but there are issues we can do something about if we have the political commitment to address them, and cutting back agricultural impact on our rivers is definitely one of those.

Strong regulation is a must, but we do not just advocate the stick approach.  If you read the executive summary of the Axe Report, you will see that financial incentives for farmers to improve their infrastructure can produce dramatic results, albeit that they were threatened with heavy regulation if they didn’t comply.  Persuading farmers to adopt better soil management techniques is also critical, so that P is kept where it belongs, on fields, rather than being allowed to leach into rivers.

However, the most important aspect of the Axe example is that sufficient resources were made available to the EA to properly address the poor ecological state of the river, and they did that by visiting farms and advising farmers, many of whom had no idea they were polluting the river.  The result was nearly £4m of inward investment into updated infrastructure, and that is the sort of funding we need replicated across the whole of Wales and England if we are to protect our rivers into the future.

So, S&TC’s agricultural policy is simple; incentivise farmers to invest in their infrastructure and spread the word about modern soil management, but always be prepared to use the current legislation to regulate persistent offenders so that it becomes uneconomic for farmers to pollute watercourses such as the Wye.  If we can achieve that, then our wild fish and all other water wildlife will have the best possible chance to thrive, even in our micro-managed environment.

Thirty-six toxic pesticides washed into headwaters of SAC chalkstream

Bakkavör washing unknown quantities of thirty-six toxic pesticides, which present real danger to aquatic life, into headwaters of SAC chalkstream

Following on from our recent release about dangerous quantities of toxic neonicotinoid Acetamiprid being washed off salad leaves into the headwaters of a protected chalkstream, a further freedom of Information (FOI) request proves this is just the tip of the iceberg.

Information obtained by Salmon & Trout Conservation (S&TC), confirms thirty-six other chemicals, (Appendix 1) from Bakkavör’s Alresford salad washing activities, which could be causing environmental damage. The list of chemicals, which Bakkavör declare are permitted for use on the produce they wash at the site, highlights thirty-six chemicals of great concern where the Environment Agency believe they “present a real or present danger to the environment”. Current laboratory tests for these chemicals cannot detect the presence in the discharge low enough to ensure they are not causing environmental damage.

The problem is national in scale. Alongside neighbouring Vitacress on the Bourne Rivulet, a tributary of the River Test, there are several hundred similar factories across England which could also be discharging lethal quantities of pesticides.

The Environment Agency has produced, using the best available science on the ecological impact, a minimum reporting value (MRV) for each chemical, at which they believe they can be confident no damage to the surrounding environment, to its fish, bugs, kingfishers, otters and water voles, will occur. However, unfortunately for thirty-six of the pesticides listed current laboratories Limit of Quantification (LOQ), the lowest analyte concentration that can be quantitatively detected with a stated accuracy and precision, is in the worst case 3500 times higher than these “safe” concentrations.

S&TC believes the only safe and responsible solution is for Bakkavör to stop washing salads and discharging its lethal cocktail immediately while a means to measure and remove harmful pesticides is introduced. And the EA needs to demand Bakkavör meets the environmentally safe levels come what may.

Nick Measham, S&TC CEO states,

”Pesticides are, of course, by their very nature designed to kill unwanted animals, unlike industrial chemicals or pharmaceuticals whose toxic impact is an unfortunate side-effect. Is it really acceptable that any pesticides are allowed to be discharged into our natural environment whatever the concentrations? Surely as a responsible business Bakkavör must stop discharging all knowingly toxic pesticides into this river which in so importance to the local community and has international ecological importance, before it’s too late”.

The River Alre, which receives Bakkavör’s toxic discharge, is a tributary to the River Itchen, a Special Area of Conservation- the highest environmental protection a site can get, and a world important chalkstream, as 85% of global chalkstreams are in England. Yet, because of historical discharge permits, once small, but now industrial level salad washing activity is able to pollute this invaluable natural resource.

Janina Gray, Head of Science and Policy at S&TC added,

“Chemical pollution is arguably the biggest single threat to our wildlife and us. In truth, we know very little about most of the chemicals we are pumping into the environment, so governments have put it in the too difficult to deal with box for too long. With wild fish populations like salmon endangered, bugs both in the water and on land showing catastrophic populations collapses and 85% of our rivers considered unhealthy, we cannot ignore this problem any longer. Pesticides are the obvious place to start, and in particular point discharges like Bakkavör. I for one will not be buying any washed bagged salad until I know it isn’t silently killing our rivers with its washed-off pesticides”.

S&TC is calling on Bakkavör to stop their discharge immediately until they can be certain they are not discharging pesticides at toxic levels in the surrounding environment.

NOTES FOR EDITORS

(1) Salmon and Trout Conservation

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

www.salmon-trout.org

2) Case History

Fears about pesticides and other chemicals in the discharges from this salad washing plant have been long standing and culminated in June 2018 when S&TC issued the EA with a formal notification of environmental damage pursuant to the Environmental Liability Directive. This followed the results of S&TC’s invertebrate sampling at a site immediately downstream of Bakkavör’s outflows which indicated that chemicals were impacting the invertebrate communities.

The resulting EA investigation confirmed S&TC’s findings; that there were pesticides present, which were on the salad leaves imported by Bakkavör and which were being subsequently washed off and into the Upper Itchen. It appears that Bakkavör had not self-notified the EA of the presence of these chemicals. Once made aware of the pesticide threat the EA began a monitoring and sampling regime. This testing revealed the presence of dozens of chemicals, pesticides and herbicides being washed off the fresh produce at Bakkavör

Appendix 1:

Pesticide Minimum Reporting Value (MRV) and Limit of Quantification (LOQ), where pesticides highlighted in red indicate Environment Agency concerns current monitoring cannot prove they are not impacting the environment.

 

New CEO at Salmon & Trout Conservation

Nick Measham, CEO, Salmon & Trout Conservation,

I am proud to take on the responsibility for leading Salmon & Trout Conservation. Though I am a relatively recent recruit – I joined S&TC part time five years ago to help manage a project on the Upper Itchen and developed the Riverfly Census – I have had a life-long love of rivers and am fascinated about every aspect of them.

I come from West Bromwich, born at a time when my local river, the Tame, was one of the most polluted in Europe.  My earliest memories are of playing in small streams, catching bullheads, loach, sticklebacks and crayfish. I came to angling through this love of water – no one else in the family fished – and have always believed that fishing is a dividend, albeit a big one, of our stewardship of wild fish and their habitats. You can’t fish too happily without catching fish (though I often seem to…).

My central objective for S&TC may seem prosaic but it is to continue to grow the work we do as the only independent voice campaigning for wild fish and their habitats.  We will continue to take no Government money which too often leads to solutions which do not appear to put the environment first and which would conflict with our need to hold Government and its agencies to account.

We have been and will remain a small team with a reputation for getting things done.

We achieve what we do at a national scale by: being ruthlessly focused on a small range of critical issues and; working in close partnership/collaboration with many others.

This focus and partnership working will continue to form the framework for all we do in the short run and over the longer term too.

My immediate priority in this difficult year is to find the resources to increase the impact of our projects across our three current work streams (and protect our wonderful dedicated talented team). The Covid-19 impact is placing huge stress on funding, but the environmental demand has never been greater.

Our current projects are:

  • SmartRivers which builds on the Riverfly census to train volunteers to use invert samples to nail the water quality threats (pesticides, phosphate, sediment and sewage) threatening wild fish populationsWe are growing a SmartRivers “franchise” network across England, Wales and Scotland which will provide our water quality database with evidence of the pollutants stressing our rivers, their dependent wild fish and water life.
  • Salmon Farm Reform to prevent open-net salmon farming harming salmon and sea trout. In-shore open-net salmon farming kills wild salmon, sea trout, other fish and crustaceans. Lethality results from sea lice infestation, escaped farmed fish breeding with wild ones, and coastal waters being seriously polluted by fish waste; and also, ironically, by the quantity of chemicals needed to try to keep cage-farmed fish parasite and disease free. We champion effective regulation to control sea-lice parasites and eliminate escapes; we also seek relocation of open cage farms away from sensitive salmon and sea trout migration routes.
  • Water Action using evidence from the Riverfly Census and other science to drive policy reform on water quality (we are leading the charge on forcing action on pesticides in water and general agricultural abuse of water) and on abstraction for example.

Longer-term, the main challenges are to put in place effective regulation of agriculture and aquaculture to protect our wild fish and their habitats.

Our river fly evidence from the Riverfly Census and SmartRivers shows agricultural pollution rather than the industrial pollution of my childhood, to be the main threat to wild fish. We must ensure that farming practices stop damaging our rivers. We already have the regulation in place to do this, regulation which has been accepted by the NFU and other farmers’ bodies. This requires the Environment Agency and its sisters in Wales and Scotland to be given the resources and the will to stop bad farming practice through education and enforcement. It seems so straight forward but, somehow or other the UK’s Governments fail to deliver.

The second main challenge is aquaculture: simply put open-cage salmon farming in inshore marine locations is incompatible with wild fish. We are fighting hard to get the Scottish Government to regulate salmon farming to protect wild fish from the lethal plumes of sea lice from farmed fish and from genetically devastating escapes.

Underlying these threats to our rivers and coastal waters, is the whole more food/cheaper ethos which has dominated food production for decades. Countering this will require more than anglers, and this raises campaigning issues which we are only now beginning to understand and resource. We are an organisation of some 6000 members. We must retain and expand this base - numbers count politically - and add sources of support both people and funds.

I cannot promise you immediate success, but I can offer you the commitment to try to counter the damage being done to our wild fish and their waters. I hope I can count on your support in the years ahead.

 

S&TC leaves the Missing Salmon Alliance

After discussion and detailed consideration of the tactical approach, the Missing Salmon Alliance has decided to pursue an advocacy course by engaging with the Scottish government with respect to future regulation of the aquaculture sector. Salmon and Trout Conservation (S&TC) has decided to withdraw from the Alliance to pursue an alternative approach.

The Missing Salmon Alliance was formed to bring a greater focus on the plight of wild Atlantic salmon and to reverse the devastating collapse that has seen this magnificent fish disappear from our rivers.  By coming together, the organisations who make up the Missing Salmon Alliance can pool their skills and expertise.  Through research, evidence and by advocating for a greater understanding of the dire situation Atlantic salmon face, and the need for greater protection and management throughout its lifecycle, the Missing Salmon Alliance is working to reverse the devastating decline in numbers.

The members of the Missing Salmon Alliance share its vision and objectives and are clear on the need for further actions to be taken by governments, business sectors and fisheries managers who impact, directly and indirectly, on wild Atlantic salmon to ensure of their conservation and protection in the future.  The members share the view that the status quo is not acceptable.

After discussion and detailed consideration of the tactical approach, the Missing Salmon Alliance has decided to pursue an advocacy course by engaging with the Scottish government with respect to future regulation of the aquaculture sector. The Angling Trust, Game Wildlife Conservation Trust, and the Atlantic Salmon Trust support this approach.  Salmon and Trout Conservation (S&TC) has decided to withdraw from the Alliance to pursue an alternative approach.

S&TC will therefore now campaign, outside the Alliance, for effective regulation of salmon farming to be introduced in accordance with the recommendations of the two Parliamentary Committees, and to include the key principles that S&TC has identified.

S&TC shares the aims of the Alliance and will continue to cooperate with the other members, and to support and provide inputs to the Likely Suspects Framework research programme.

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”.

Toxic neonicotinoid washed off salad leaves into protected chalkstream

Toxic neonicotinoid washed off salad leaves into protected chalkstream exceeds acceptable concentrations by up to 400%.

NEWS RELEASE 23 June 2020

Data from a recent Freedom of Information request by Salmon & Trout Conservation shows that levels of Acetamiprid, a pesticide discharged by Bakkavör plc into the Upper Itchen catchment[1], have regularly exceeded acceptable concentrations. This toxic pesticide and many more are washed off leaves in preparing bags of salad.

Bakkavör plc supplies leading retailers, including M&S, Sainsbury's and Waitrose, with fresh produce such as watercress, baby leaf and organic salads and herbs.[2]

Acetamiprid regularly exceeded, by a factor of up to four times, the lethal dose (chronic and acute Regulatory Acceptable Concentration (RAC))[3]. Acetamiprid is in the neonicotinoid family, many of which were recently banned for use in Europe due to their acute toxic impact on bees. While Acetamiprid is considered less harmful to pollinators than its banned relatives, research shows that it is significantly more toxic to aquatic insects.[4]

Nick Measham, CEO Salmon & Trout Conservation said,

“Enough is enough. Bakkavör’s Alresford Salads factory has a long history of polluting the Upper Itchen. This latest revelation is the most troubling yet. Quite simply this pesticide pollution has to stop, and now. These chemicals will be killing aquatic insects, destroying the primary food source of wild salmon and trout. Bakkavör must end emissions of these and all other toxins which occur as a by-product of their processes. If they continue to refuse to do so, the EA must take decisive action.”

S&TC fears this is not the only insecticide discharging from the plant at quantities dangerous to aquatic life, and that, nationally, Bakkavör is not alone in this activity.  Until S&TC raised concerns over potential chemical inputs from the factory affecting the river, no-one was aware or monitoring what was actually being discharged. Current discharge permits require the operators to disclose to the EA any toxic substances which may be present in their discharge, and then monitoring procedures are established accordingly. Clearly, in this case, that did not happen. There are fundamental failures in the regulatory approach applied here, which must be addressed by the EA.

Additional Freedom of Information data obtained by S&TC suggests up to five hundred other sites throughout England of a similar nature could be operating under the same or similar inadequate permits with no pesticide monitoring requirements, but with pesticide residues being discharged.

Dr. Janina Gray, Head of Policy and Science, Salmon & Trout Conservation,

“Bakkavör is surely the tip of the iceberg. These issues appear to be widespread and will be causing ongoing environmental damage. The existing permitting regime wholly fails to protect the environment from the damaging effects of a range of toxic chemicals. What is even more worrying is the emerging science suggesting that a “cocktail effect” may increase the toxicity of many different chemicals beyond the sum of their parts. The EA has failed to keep pace with what is actually polluting our rivers.”

S&TC is calling on Bakkavör plc to stop their discharge immediately until they can be certain they are not discharging pesticides above regulatory standards and until they can demonstrate they are not impacting the river.

Bakkavör plc urgently needs to outline: 

  1. what action it is taking to remove Acetamiprid and other pesticides from its discharge;
  2. why it is taking so long to put proper protections in place for the Itchen;
  3. why as a responsible business, it should be discharging any pesticides into the headwaters of a highly protected chalkstream; and
  4. why, given the growing body of scientific evidence showing synergistic impacts of chemical cocktails, it routinely discharges a cocktail of 40 plus chemicals into the Itchen.

S&TC is calling on the Environment Agency to:

  1. accept no more delays and to vary Bakkavör’s discharge permit immediately, to give the EA the ability to regulate all chemical discharges made by Bakkavör;
  2. enforce permit variations at any other similar activities in England to require monitoring at any sites where pesticides are identified and, given the risk of synergistic effects, limit these discharges to well below safe levels.

NOTES FOR EDITORS

(1) Salmon and Trout Conservation

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

https://www.salmon-trout.org

2) Case History 

Fears about pesticides and other chemicals in the discharges from this salad washing plant have been long standing[5] and culminated in June 2018 when S&TC issued the EA with a formal notification of environmental damage pursuant to the Environmental Liability Directive. This followed the results of S&TC’s invertebrate sampling[6] at a site immediately downstream of Bakkavör’s outflows which indicated that chemicals were impacting the invertebrate communities.

The resulting EA investigation confirmed S&TC’s findings; that there were pesticides present, which were on the salad leaves imported by Bakkavör and which were being subsequently washed off and into the Upper Itchen. It appears that Bakkavör had not self-notified the EA of the presence of these chemicals. Once made aware of the pesticide threat the EA began a monitoring and sampling regime. This testing revealed the presence of dozens of chemicals, pesticides and herbicides being washed off the fresh produce at Bakkavör Alresford Salads.

References

[1] The salad washing plant is situated on the River Aire a tributary of the protected River Itchen, a Special Area of Conservation (SAC)

[2] https://www.bakkavor.com/investors/

[3] The long-term chronic Regulatory Acceptable Concentration (RAC) for Acetamiprid is 0.0235mg/l, and the short- term acute RAC is 0.085mg/l.

[4] https://sitem.herts.ac.uk/aeru/ppdb/en/Reports/11.htm

[5] https://www.salmon-trout.org/2019/06/17/bakkavor-alresford-salads-impacting-upper-itchen/ [6] http://bit.ly/2RhzimT

Appendices (3):

Graph 1: Presence of Acetamiprid in the overnight wash discharge of Bakkavör Alresford Salads. The Lowest Limit of Analytical Determination (LOD) refers to the lowest concentration of the analyte that can be reliably detected and quantified. [It is believed that salad leaves associated with Acetamiprid, and its use, are more commonly associated with Spring seasonal produce, hence the absence of data during other months].

Table 1: Results of the sampling of the water leaving the factory during the overnight wash of salads and other fresh produce. [Only certain laboratories have the ability to test for Acetamiprid at the levels at which it is found to cause harm].

Table 2: Monthly Bakkavor - April 2020 - Sampling Data Summary April 2020. Released as part of Environment Agency FOI: 200605 SSD171346 - Bakkavor Data

 

S&TC Cymru Update June 2020

Richard Garner Williams, S&TC National Office for Wales writes:

In a spirited demonstration of enthusiastic collaboration S&TC Cymru, the Wild Trout Trust, the Grayling Society and the Game and Wildlife Trust recently joined forces in writing to Lesley Griffiths, Welsh Government Minister for Environment, Energy and Rural Affairs offering broad support for Natural Resources Wales’ Salmon and Sea Trout Plan of Action. The Plan was launched at the Minister’s request in response to the outcome of the Local Inquiry on Natural Resources Wales’ proposed All Wales Salmon and Sea Trout Byelaws earlier this year. We understand the Plan of Action will be underlain by a detailed Forward Delivery Plan which all four organisations look forward to examining and discussing upon publication. The letter also urged the Minister to ensure that the implementation of the Plan be adequately funded to ensure that Wales meets its national and international obligations towards these two keystone species.

Agricultural pollution continues to wreak havoc on the fragile populations of the wild fish of Wales with a recent slurry containment failure killing fish along at least 4km of the Afon Peris, near Llanon on the Cardigan Bay coast. It must be presumed the invertebrate population within the affected reaches fared little better than the fish, further compounding the effects of the spill on the river’s biodiversity. Although diminutive in size, S&TC Cymru is becoming increasingly convinced that rivers such as the Peris play an important role in sewin stock recruitment, with emerging smolts supplementing returning numbers of mature fish in larger, neighbouring rivers. With the Teifi to the south and the Rheidol, Dyfi and Mawddach to the north, we can only begin to wonder what the long term, more distant impacts of the spill might be. Regrettably, the incident was only brought to the attention of the authorities when members of the public noticed dead fish floating in the polluted water. It would appear that the farmer was unaware of the incident until alerted to it by NRW. Equipment or storage failures such as this are a far too frequent an event and suggest widespread negligence and lack of investment in the infrastructure required for today’s more intensive methods of dairy production. S&TC Cymru have repeatedly called on Welsh Government to address these issues and while the recently announced Draft Water Resources Regulations give some hope for improvement in the control of agricultural pollution, we have yet to see evidence of the commitment to the extra resources required for their enforcement.

Originally planned for introduction in January of this year, the new agricultural regulations designed to tackle the scourge of agricultural pollution remain in limbo as Welsh Government addresses the issues posed by Covid-19. S&TC Cymru wrote to congratulate the Minister on her original forthright announcement of the need to take action but have since become increasingly concerned at hints of mission creep. During the latter months of last year, at the behest of the Minister, Natural Resources Wales and NFU Cymru collaborated on a project to explore potential voluntary options, suggesting a more flexible approach based on “earned autonomy” which would release individuals from strict regulatory control. Unlike Scotland and England, where the impact of agriculture on water is regulated by statutory basic rules, Wales has no such general binding measures, relying instead on voluntary compliance with guidelines laid put in the Code of Good Agricultural Practice (CoGAP). Patently, this has failed, as the regular reports of both acute and chronic incidents of pollution make clear. We therefore conclude there can be no further place for the provision of voluntary measures with regard to the impact of agriculture on the freshwater environment if Welsh Government is serious in its intent to conclusively address the matter. With that in mind and again in the spirit of collaboration and cooperation, the Grayling Society and the Wild Trout Trust recently joined with S&TC Cymru as co-signatories to a letter to the Minister calling for the introduction of a suite of basic rules for water for all land users across the whole of Wales, in advance of the currently proposed regulations, whatever their final form. I look forward to reporting, hopefully, a positive outcome to this and thank the WTT and the GS for their ready participation in our collaborative approach.

Finally, I’m sure you were all as disappointed as was I that we had to postpone our spring seminar. This has become an extremely popular event and this year’s bookings were already close to capacity when we suddenly found ourselves overtaken by events. With so much uncertainty continuing to surround the resumption of normal social interactions we have decided to formally cancel our 2020 seminar and start instead to prepare for the 2021 event. Until then, thank you for your valued support and please feel free to get in touch at any time should you wish to discuss matters in greater detail.

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.

SmartRivers launched in Wales

S&TC Cymru launches its first SmartRivers hub in partnership with the South East Wales Rivers Trust

S&TC Cymru is delighted to announce that South East Wales Rivers Trust (SEWRT) is to host the first SmartRivers hub in Wales. The hub is certain to play a valuable role in assisting SEWRT restore the natural beauty and biodiversity of the postindustrial Cynon.

SmartRivers, 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.

Quick and easy to deploy, but also producing robust and powerful information, polluters of rivers and streams have already been forced to take action. "SmartRivers Delivering Results"

Richard Garner Williams, S&TC National Office for Wales

"I'm delighted SEWRT has chosen to engage with S&TC's SmartRivers programme and look forward to seeing the positive contribution the hub will make towards the Trust's ambitions. It is heartwarming to see the rivers of the south Wales valleys returning to life and I wish the all those associated with the Trust great success in their endeavours." 

river cynon smartrivers

SmartRivers provides valuable 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.

The South East Wales Rivers Trust (SEWRT) was formed in 2007 to recover river habitats in the former industrial valleys of South Wales. The valley environment suffered a great deal in the industrial era, but is slowly recovering, although weirs, contemporary industrial pollution and waste water issues continue to present problems for fish habitats and migration. Thanks to European funding, SEWRT has spent in excess of£190,0000 over recent years on twenty fish easements and three habitat improvement schemes opening up an additional one hundred and thirteen kilometres of river to migrating fish. Regrettably, due to pressure of work, the Cynon did not feature heavily in the programme, benefitting from only five minor easements.  Historically, the Cynon valley was a major area of coal production and heavy industry, the consequences of which had a devastating impact on the ecology of the river. However, the very upper reaches were not so badly affected and over the years these have proved to be the areas from which life has returned to repopulate this bruised and battered river. Local interest in the recovery and importance of the Cynon has generated an enthusiastic band of volunteers, ready and willing to carry out much of the work. The driving force within SEWRT is working with the local community to value the river, carry out community river surveys and run river restoration and fly monitoring courses.

Tony Rees, Chairperson of the SEWRT said:

“As Chairman of the SEWRT I have been heavily involved in several fly monitoring programmes.  Reading about the SmartRivers project made me realise how well this would fit into a new project that SEWRT is running on a truly urban river, the Cynon. I already have funding for two fly monitoring courses locally as well as to run a river restoration course. Using SmartRivers will raise the standard of the work we will be doing to a higher level and is a perfect fit for the “River for All” project on the Cynon. It will ultimately help us to understand in greater depth the problems in our valley rivers. It will also be an excellent way to show those who join in with us the unseen life in the river that is so important to all our wellbeing, but that the public has little knowledge of.  We are grateful to Welsh Water, Pen Y Cymoedd wind farm community fund, Natural Resources Wales and Post Code Lottery for supporting the project.”

SmartRivers includes 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. This 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

We are delighted to be continuing our water quality work in Wales through SmartRivers. The Cynon is unlike any river we have enrolled in the programme to date, so the information we will obtain through the monitoring will be fascinating. It is astounding that tiny invertebrates can give us such vast insight into the subtle, and often invisible, pressures our young fish are being exposed to. We are very excited to educate the Cynon volunteers on these pressures. SmartRivers will give them the scientific power to understand what improvements are needed and measure the biological impact of any actions they may take.”

 Nick Measham, S&TC CEO said:

“The rivers of Wales rivers suffered so much in the industrial era and sadly continue to face a lot of pressure. We are always pleased to hear about the positive work being done and some good news stories about river restoration. SEWRT have achieved so much good for the rivers under their care. We hope our SmartRivers programme will help SEWRT turn high quality citizen science into meaningful real-world action that here and now improves outcomes for wild fish and the wider habitat.”

Dennis Baynham, Secretary of the SEWRT

“The Cynon starts above Hirwaun and runs down the valley through the middle of Aberdare and Mountain Ash joining the Taff in Abercynon. It is a truly urban river in need of some TLC. It suffered years of pollution from colliery waste and the Phurnacite plant in Abercwmboi, but in the years since they stopped production water quality has improved tremendously. It now suffers with water quality problems from sewerage over flows and poor connections. I welcome this initiative as a step in the direction of identifying all the problems the Cynon. The local angling fraternity are behind this.”

 Afon Cynon, A River for all: Gareth Edge Project officer

“My project aims to improve the biodiversity of the Cynon through meaningful education, community engagement and small-scale environmental improvements. Volunteers are encouraged to undertake a Level 1 accredited qualification in River Restoration. Partner Schools look after critically endangered European eels for release on the catchment, as part of a Europe wide restocking project. River clean-ups are undertaken in partnership with Keep Wales Tidy. Invasive species will also be managed with the aid of local authority. Partnering S&TC and the SmartRivers programme will enable me to take my work to a wider audience of volunteers.”

 Natural Resources Wales issued the following statement,

“NRW is keen to support initiatives like SmartRivers, that involve communities in citizen science, and engender a wider and increased understanding of river ecosystems. SmartRivers monitoring aims to pick up issues, and working together, we can better protect and improve our river environments.”

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

 For more information on the work of S&TC Cymru, please email our National Officer for Wales, Richard Garner Williams: wales@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

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.