Scottish Government inertia marks anniversary of Scottish Parliament’s Environment Committee’s report into salmon farming

Scottish Government inertia marks anniversary of Scottish Parliament's Environment Committee's report into salmon farming

Industry allowed to persist with business as usual a year after Government was told 'the status quo is not an option'

One year on from the Environment, Climate Change and Land Reform (ECCLR) Committee’s report on the Environmental Impacts of Salmon Farming, the first part of the 2018 Scottish Parliament Inquiry into the industry, Salmon and Trout Conservation Scotland (S&TCS) is concerned that the report is being allowed to gather dust by both Scottish Government and the industry.

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

“A year ago, the ECCLR Committee, could not have been clearer that any expansion of the industry ‘must be on the basis of a precautionary approach and must be based on resolving the environmental problems’ and that ‘the status quo is not an option’. It is obvious that almost nothing has changed and we fear that the Scottish Government’s game-plan is yet more of the prevarication that has allowed the industry to develop without meaningful regulation and at the expense of the coastal environment and those species, including migratory fish, which rely on healthy coastal ecosystems. Consequently, environmental damage is continuing and indeed increasing unchecked. Scottish Government’s completely unconditional support for the salmon farming industry must end.”

The 2018 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.

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

“The ECCLR Committee’s comprehensive report underlined why urgent action was required to protect wild salmon and sea trout. However, Scottish Government has not yet grasped the nettle and moved to legislate in order to improve markedly the protection of wild salmon and sea trout from the negative impacts of salmon farming.”

 

SSPO still failing to publish farm by farm sea lice data in as close to real time as possible

On transparency, the ECCLR Committee’s report was adamant that the industry should publish weekly data on sea lice figures on a farm by farm basis in as close to real time as possible, together with all historic data “from the time records are available”, this to be done
by the end of April 2018.

The Scottish Salmon Producers’ Organisation has not honoured this deadline, nor is it publishing current farm by farm sea lice data in as close as possible to real time, as the Committee required. In contrast it is only publishing monthly sea lice averages per farm more than three months in arrears and it is to the Scottish Government’s shame that they have not amended secondary legislation to force transparency on this most important of issues.

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.

S&TC welcomes England’s NE salmon net closure

NE salmon net closure

S&TC welcomes the new Environment Agency byelaws which will close down the killing of Atlantic salmon in drift nets and coastal T&J nets on the north east coast of England, which follows lobbying from several fisheries NGOs over many years.

S&TC believe this is the correct decision in the interests of protecting and conserving salmon stocks and brings England into line with international salmon management obligations.

S&TC Campaigning

S&TC was closely involved in the closure of the Scottish coastal nets in 2016, via complaint to Europe under the EU Habitats Directive that Scotland was not managing its wild salmon stocks responsibly. The Scottish action left England in some embarrassment, in that these north east English nets exploited salmon bound for Scottish rivers anywhere between 30% (Yorkshire coast) and 70% (drift nets).

S&TC has also been heavily involved internationally as Co-Chair of the NGOs at the North Atlantic Salmon Conservation Organisation (NASCO), pressurising all countries still allowing exploitation of salmon stocks from more than one river system (Mixed Stock Fisheries) to close them down on management and conservation grounds.

Paul Knight, S&TC CEO, said,

“We are delighted with this decision to close the north east mixed stock fisheries for salmon, and congratulate the EA for taking this decisive action, which will allow thousands of wild salmon to run their natal rivers without fear of exploitation so that they can spawn future generations.
However, we must not forget that netsmen are having to give up some or all of their livelihoods under these new byelaws, which is never a welcome outcome, and so it is up to all anglers to show the highest possible restraint when salmon fishing so that they too play their part in conserving wild stocks.”
Knight added,
“We are concerned that sea trout will still be exploited in some of the north east coastal nets and we will be seeking more evidence in the near future as to the true status of English sea trout stocks.
With the fisheries management doubts over climate change and the evidence emerging of salmon and sea trout smolts being smaller because of it, and therefore having less chance of survival at sea, we need to take a precautionary approach now on all migratory salmon stocks, not wait until things get worse.”

The NE salmon net closure byelaws

The new byelaws will come into force on 1 January 2019, an important step in tackling the international decline in migratory salmon stocks. Salmon numbers are currently among the lowest on record and are below sustainable levels in many rivers.

S&TC welcome the new laws, which include:

  • Closing all commercial net fisheries for ‘At Risk’ and ‘Probably At Risk’ rivers (some fishing for sea trout will still be allowed). This will include all drift net fisheries;
  • Mandatory catch and release by anglers on the rivers that are classed as ‘At Risk’ to be introduced in June 2019. These are the Cumbrian Calder, Dorset Stour and Yealm;
  • Mandatory catch and release by anglers on the rivers that are listed as ‘Recovering Rivers’. These are rivers where salmon were effectively wiped out and small populations have re-established in recent years with improvements in water quality on mostly heavily polluted post-industrial catchments. Examples of these are the Mersey, Yorkshire Ouse;
  • Renewal of the 1998 Spring Salmon Byelaws. These protect the larger, early running salmon, and do not involve any new measures.

Latest data on River Test and River Itchen reveals concerning issues

Test and Itchen are no exception to national decline in water quality and flylife

The S&TC Riverfly Census continues to reveal worrying declines in flylife and water quality in rivers across England and Wales, as confirmed by our latest report on the River Test and the River Itchen (the king and queen of our precious chalkstreams).

In our comprehensive Test and Itchen report published today, the results from three years of independent species-level invertebrate data reveal:

  • Significant loss of mayfly species.
  • Low gammarus counts.
  • Worrying impacts from sediment, phosphate and, occasionally, pesticides.

Mayfly and gammarus declines

Comparing historic data with our findings has revealed that both the Test and Itchen have four less mayfly species, on average, than their historical averages. This decline in mayfly species richness, and the worrying low numbers of gammarus, are powerful indicators of an ecosystem in distress.

The flylife in both rivers is far poorer than we would expect for chalkstreams in good condition  - let alone these SSSI (Sites of special scientific Interest) and SAC (Special Area of Conservation) rivers.

Mayfly species have declined from an average of 12 to 8 (33.3%) on the Itchen and 11 to 7 (36.36%) on the Test, over the period from the late 1970s/early 1980s to today.

The current levels are also well below local targets of 10 mayfly species - targets agreed with the Environment Agency for what would be expected in a healthy river.

Gammarus, a key staple of the aquatic food chain, is also well below our 500-target level at most sites (historically, gammarus counts went into the thousands).

Excess sediment and phosphorus

Our report reveals the extent that chemical, phosphorus and sediment pollution are impacting the invertebrate community in both the Test & Itchen.

It is clear that a reduction of sediment and phosphate inputs (from point and diffuse sources, including septic tanks, agriculture, sewage treatment works, industry, etc) are essential to conserve these rivers.

Importance of the S&TC Riverfly Census

Lauren Mattingley, S&TC’s Science Officer, explains why data like this is so important:

“We frequently hear stories and concerns about missing flylife and lack of fish compared to the 'good old days', but anecdotal evidence has little weight in environmental decision making.

The Riverfly Census was launched as a ‘myth-busting’ tool to collect much needed high-resolution, scientifically robust data about the real state of water quality in our rivers.

Switching from opinion to fact-based evidence gives us real power to drive national and local improvements to our waterways.

“The Test & Itchen report is a fantastic example of why we need to break away from data ‘silos’.

The Riverfly Census data tells a story on its own, but when linked up with additional local invertebrate and phosphorus monitoring data, we can really start to grasp the pressures on these rivers.

The environment is complex, and stressors rarely work in isolation, so why would we conduct monitoring this way?”

Turning science into action

The Census is no mere academic exercise. We are using this powerful data to inform and build effective strategies which improve wild fish habitat:

  • We are acting on the Census results to improve water quality in these rivers, working with stakeholders in the area.
  • We are tackling known sources of pollution; such as the Bakkavor salad washing plant on the Itchen headwaters, and intensive watercress farming on both the Test and the Itchen.
  • Our findings on the Itchen impelled us to challenge the EA under the Environmental Damage Regulations. We are awaiting the EA’s response.
  • To share the Riverfly Census results from the Test and Itchen and drive further improvements to these rivers, we will be holding a workshop on 12th February 2019. A key aim of the workshop will be to highlight knowledge gaps and develop next steps with a range of stakeholders, regulators and scientists. Please contact Lauren (lauren@salmon-trout.org) if you or your organisation would like to book a place at the workshop.

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.

#ProtectWater campaign success: brilliant news for our waters and fish

First success for #ProtectWater campaign

Thanks to an extensive collaborative effort from over 100 NGO's across Europe, including S&TC, an important first milestone has been achieved in the defence of our water's environmental protection laws.

A paper drafted by a group of government officials, seeking to weaken the laws which currently protect our waters, has NOT been endorsed at the recent Water Directors' meeting.

Government officials from Member States prepared a paper for last week’s meeting of Water Directors - who represent their national governments on all decisions related to water management. The paper included a series of proposed changes to the WFD which, if ever put into effect, would constitute a significant weakening of the legislation.

Collaborative effort from NGO's

However, thanks to a joint and sustained policy and communications effort from NGO's across Europe, the paper was not endorsed by Water Directors. Prior to the meeting, Water Directors were sent numerous letters and communications urging they maintain the environment and protect the WFD - as explicitly recognised in the discussion and in the final report of the meeting, which stated:

"Water Directors reiterated their conviction that the WFD is a center-piece of EU water legislation and has been highly instrumental for progress achieved in protecting and improving the status of European waters so far.

They emphasized that the level of ambition of the WFD and its objectives should be maintained. They also stressed the need to focus efforts on achieving the WFD objectives, and highlighted that water using sectors responsible for the pressures leading to a failure in achieving the objectives should contribute to these efforts."

These succesfull communications and documents were borne of, and sent on behalf of, the Living Rivers Europe coalition; as well as a multitude of individuals, NGO's and other government officials. Water Directors were receptive, indeed;

"They thanked the consultation group for its work and the document prepared. They took full note of the concerns raised by NGOs and stakeholders".

This could not have been achieved without such a co-ordinated effort, and this result is a testament to the power of the #ProtectWater movement of 100+ organisations, of which S&TC are proud to be a part of.

Next steps

The paper will now be discussed at the meeting of the Strategic Coordination Group (SCG) early next year; the issues it contains to be addressed by the Water Directors of the Member States only after various European Commission assessments, i.e. the end of 2019.

So there is still a long way to go, and we still need many more submissions to the European Commission's consultation...

Help us Protect Water and wild fish in the UK

Despite this strong start, the battle is far from over and we still need your help to keep our water laws strong, especially on the eve of Brexit.

Please click here to find out more about the campaign and to have your say with the European Commission, using our simple consultation form. Please, for the sake of our wild fish and their habitats, ACT NOW and help us #PotectWater.

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.

Suffering salmon: A temperature-gauge for our worryingly low water-flow

By our Head of Science and Policy, Dr Janina Gray. The original article was written for Countryside and Wildlife Link.

What would a third dry winter mean for wildlife and habitats?

Worryingly low water flows are of major concern to much wildlife, particularly salmon which rely on flowing rivers to travel to estuaries to spawn.

As our minds start focusing in on Christmas after a warm summer and mild autumn, the elephant in the room not receiving much attention at the moment, is the continued dry weather which could drive us into a 3rd dry winter. Whilst we are all enjoying a November that doesn’t involve the typical 3 inches of mud to contend with, what does this mean for the environment?

Environment Agency (EA) data shows river flows, as of 30 October, are below normal or notably low for most of the south and west of England and all but 4 EA areas are classified as in prolonged dry weather. Reservoirs in the Pennines and south west are still at risk from lower than normal levels going into winter. And the continuing dry autumn and consequent high soil moisture deficits, look set to result in a continued delay of winter groundwater recharge in southern and eastern counties.

Figure 1a) river flow (relative to time of year) 30 October 2018

1b) EA areas in relation to dry weather

For fish and our chalk streams the impacts of low flow will start being felt now. Reduced groundwater will severely impact the resilience of our chalk streams, and the low flows will increase siltation and die off of water crowfoot, which is a crucial part of the ecosystem.

Reports around the country suggest this year is looking catastrophic for salmon. Salmon spawning should be occurring between now and end of January, but low flows in the summer and up to now, have meant salmon arriving in our estuaries are delayed or just never entering freshwater. They need sufficient flow to encourage them to run, and many in-river obstacles (even fish passes) only allow access above certain water heights.

If the fish do manage to make it upstream, past all the predators (from which they have less cover to hide), the loss of wetted area will severely impact the whole year classes of juveniles, forcing them to lay eggs in sub-optimal locations.

If the low flows continue to May 2019, this will also impact downstream salmon and sea trouts molt migration, as well as coarse fish and lamprey spawning for the same reasons.

These are of course not the only impacts of low flows; others include:

  • Salinity incursions to rivers will kill freshwater organisms.
  • Pollution incidents in rivers will have a greater impact due to lack of dilution
  • Dried heathlands, grasslands, peat lands and forestry will have increased risk of fires.
  • Decreased wetted areas in ponds, lakes and in rivers combined with low flows will adversely impact on aquatic insects and amphibians.
  • Decreased wetted areas will impact breeding bird populations.

Low flows and, indeed, droughts are natural events and healthy habitats and species populations tend to be resilient to them. However, with only 14% of our rivers currently classified as healthy and salmon populations in a dire state, the potential impact of these weather events this winter is very worrying. We can do little about changing weather patterns, except to address man-made impacts, but we can collectively lobby government to take excessive water abstraction – and its solutions – more seriously, especially the need for water companies to find new sources of water that have less impact on the environment.

That means solutions which will include increasing demand management, improved natural and man-made water retention in catchments and, where necessary, reservoirs or desalination plants. Above all, we have to make sure that government departments, Ofwat etc fully appreciate that ground waters and many of our rivers just cannot take existing levels of abstraction, let alone the increases expected in areas of massive new housing and infrastructure construction. We must continue to press ever harder for government commitment to protecting the water environment, and a new, enlightened approach to abstraction policy seems a great place to start.

Follow @drjaninagray and @SalmonTroutCons

SIFCA Consultation: Help us ban inshore netting which threatens salmon & trout

Join S&TC in seeking to ban inshore netting in Dorset, Hampshire and the Isle of Wight to help protect genetically-unique chalkstream salmon and sea trout.

Salmon & Trout Conservation has responded to an important consultation on the future of net fishing in the harbours and estuarine waters of the South Coast.

We want a cessation of netting in these areas out to one mile off-shore.

Anything less is not sufficiently protective of our vulnerable migratory fish, and many other species such as bass and mullet:

  • Recent research has shown that Southern Chalkstream salmon are genetically distinct from all other European populations and we therefore have an extra responsibility to protect them.
  • These waters form an important migratory route for salmon and sea trout throughout the year as they enter and leave rivers.
  • They also provide nursery and refuge areas for a wide range of fish species such as bass and mullet. These species also need protection.

The consulting body, the Southern Inshore Fisheries and Conservation Authority (Southern IFCA for short), is proposing a change in netting rules to ban drift and fixed nets but to allow the use of ring nets in the Southern IFCA district.

We consider the threat from ring netting to salmon and sea trout (let alone bass and mullet) to still be too high for these nets to be allowed. We recommend a ban on all inshore netting to one mile offshore in the Southern IFCA district.

How can you help?

Please respond to the Southern IFCA consultation by the closing date of 7 December 2018.

The official documents are available on the SIFCA website. Please follow these steps to submit your input to the consultation:

  1. Click on this link to take you to the overview page on the Southern IFCA website.
  2. Download the 'Southern IFCA Consultation Document' - available directly here in Word Doc (the SIFCA website, unhelpfully, contains only a PDF - we have provided a Word Doc for easy editing).
  3. Complete your answers from page 18 onwards - please feel free to use our responses. You can view our full PDF submission here, OR simply use our word doc of answers only (for ease of copying).
  4. Responses must be submitted by 7 th December 2018. You can respond in writing by email to: enquiries@southern-ifca.gov.uk. Or by post to: Southern IFCA, 64 Ashley Road, Parkstone, Poole, Dorset BH14 9BN.

Your responses truly count – numbers matter!

Important Links

S&TC Cymru welcomes new agricultural pollution regulations

Welcome news from Wales: New regulatory measures to tackle agricultural pollution

Following an extensive lobbying exercise, S&TC Cymru are greatly encouraged by the recent announcement by Lesley Griffiths, Welsh Government Cabinet Secretary for Energy, Planning and Rural Affairs, to introduce regulatory measures to combat the growing threat to the freshwater environment from agricultural pollution.

The regulations will come into force in January 2020 with transitional periods for some elements to allow farmers time to adapt and ensure compliance. The regulations, to be confirmed next spring, will include the following measures:

  • Nutrient management planning
  • Sustainable fertiliser applications linked to the requirement of the crop
  • Protection of water from pollution related to when, where and how fertilisers are spread
  • Manure storage standards

A statement by Lesley Griffiths explained the the need for stricter regulations:

"...poor practice is leaving many stretches of rivers devoid of fish.

...In the long-term, we will develop a regulatory baseline, informed by responses to the Brexit and our Land consultation.  But in the short term, we must take action now to deal with these unacceptable levels of agricultural pollution.

...The regulations will replicate good practice which many farms are already implementing routinely - this must become the norm.

...The regulations will enable firm and consistent enforcement to be taken. The regulations will also ensure there are no barriers to trade of agricultural produce with the European Union following Brexit and help us meet national and international obligations on water quality.

This is the right thing to do – for the environment, for the economy and for the reputation of farming in Wales.”

View: Agricultural Incidents to Water in Wales (from 1st Jan 2010 to 28th Feb 2018 ) [Source: NRW]

S&TC Cymru's observations

S&TC Cymru welcome this news; indeed our rivers and fish have told us for some time that stricter rules, and more stringent enforcement of such rules, is urgently needed to protect against bad agricultural practice.

Our National Officer for Wales, Richard Garner Williams, summarises our thoughts on the announcement below; following consultations with our environmental lawyer, who provides the legal analysis which supports our demands for revision of the law; and based upon professionally-analysed scientific evidence of direct impact on invertebrates and the freshwater ecosystem.

agricultural pollution regulations

Above: Slurry spreading in wet weather, violating voluntary CoGAP.

Voluntary code is not enough

Unlike in Scotland and England, where basic measures or general binding rules place statutory constraints on the dispersal of, among other materials, farmyard slurry, the only guidance currently relating to such practices in Wales is the voluntary Code of Good Agricultural Practice (CoGAP).

A review by S&TC Cymru of this, and earlier codes, showed that little has changed since 1991 and, in some cases, since 1985, in the advice given to Welsh farmers on methods of practice that would avoid polluting our streams and rivers.

Read More: Our response to EFRA regarding the Agriculture Bill in England

welsh agricultural pollution regulations

Above: Dead fish following a pollution incident in the Clywedog in September.

A minority of farmers

Regrettably, a minority of farmers have consistently chosen to disregard these codes, resulting in increased incidents of acute pollution and a rise in the pervasive effects of widespread diffuse pollution.

S&TC Cymru appreciates that the majority of farmers operate to commendable levels of stewardship, but there exists a minority who have ignored voluntary codes of practice and will probably ignore new basic measures as well. This results in reputational damage; not only to the Welsh agricultural sector, but also the wider rural economy and the international standing of Welsh produce.

welsh agricultural pollution regulations

Above:River water polluted with slurry following spreading on nearby fields.

Rigorous enforcement needed

The success or otherwise of new basic measures in addressing the persistent and pernicious effects of agricultural pollution will require more rigorous and regular inspection of farmed premises than at present, if we wish to see a change in the behaviour of this recidivist minority.

It is therefore essential that an undertaking is given to provide the necessary financial provision for Natural Resources Wales to fully exercise their authority as statutory environmental regulator from the outset, in order that the new measures can be enforced without delay.

Welsh agricultural pollution regulations

Above: Highly poluuted water from the Cywyn in September, following a slurry pollution incident.

S&TC & agricultural pollution: next steps

Over recent years S&TC Cymru has committed a large proportion of its limited resources towards highlighting the impact of agricultural pollution on the wild fish of Wales, and we are relieved that Government has finally chosen to act.

We look forward to hearing the details of the Cabinet Secretary’s intentions in due course, and trust that they will fulfil our hopes for a reversal in the current troubling decline in numbers of our precious salmon and sewin.

In the meantime, you can learn more and help us tackle agricultural pollution by visiting our campaign page and following the instruction to report any incidents to us.


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