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Salmon and Trout Conservation Scotland’s 2016 Petition to the Scottish Parliament led to the 2018 ECCLR and REC Committee inquiries into salmon farming. The REC Committee identified that “the ‘status quo’ in terms of regulation and enforcement of the fish farming industry is not acceptable”.
In response, the Scottish Government tasked the SIWG to look at the conclusions of the Committees, evaluate current policy and advice governing interactions and make recommendations. However, the requirement that the SIWG must reach consensus has prevented the SIWG from bringing forward recommendations that fully address the damage being caused to wild salmonids (salmon and sea trout) by fish farming.
The SIWG has also moved beyond the remit of wild/farmed salmon interactions, considering the wider conservation of wild salmonids and has adopted the ‘narrative’, pushed by Scottish Government and the fish farming industry since 2018, that the impact of fish farms is only one of a large number of pressures upon wild salmonids.
Linkages made by SIWG between reforming the regulation of fish farming and the wider funding of conservation and research into wild salmonids, and the resourcing of DSFBs and Fishery Trusts, are concerning.
Although the proposed move to licensing, and away from planning, as a means to control the impacts of fish farms on wild salmonids is welcome, overall, the recommendations made by SIWG do not amount to a licensing system that would yet be capable of being “robust, transparent, enforceable and enforced” (SIWG, 1.2).
The SIWG makes no reference to the precautionary approach recommended by both the REC and ECCLR Committees. The SIWG’s proposed system of adaptive management, without precautionary underpinning, will fail to protect wild salmonids.
The SIWG’s proposed system would mean that unless there is strong proof that damage is being caused to wild fish, no action needs be taken to improve fish farm performance in respect of sea- lice and diseases (SIWG, 2.2). The same principle would apply when considering closing poorly- sited existing farms (SIWG, 1.14).
There is no requirement for independent monitoring of sea lice number on farms, nor of wild fish.
The SIWG fails to recommend or set any precautionary ‘backstop’ limits for on-farm sea lice, to be set in line with best international standards.
The SIWG fails also to recognise the wider public interest in wild salmonid conservation beyond the interests of fishery proprietors as represented by the DSFBs.
The SIWG recommendations do not meet the rights of the public, guaranteed under the Aarhus Convention, to access to information and to participate in decision-making in environmental matters, in relation to the control of impacts of fish farms on wild fish.
In order to provide a proper basis on which the reform of fish farming regulation can proceed, S&TCS recommends that:
1. A strongly precautionary approach must be applied from the outset to the licensing of both new and existing farms, in line with the recommendations of both REC and ECCLR Committees.
2. There must be a back-stop adult female sea lice maximum on all fish farms, rigorously enforced by tough and prompt action, set at 0.5 per farmed fish, dropping to 0.1 during the period of wild smolt emigration, to set a precautionary ceiling on sea lice numbers , below which adaptive management can then be applied.
3. There must be full publication of all relevant data and information and, specifically, individual farm sea-lice numbers and treatment data must be published in as close to real time as possible.
4. There must be strong independence in both the monitoring of sea lice counts on-farm and of wild fish monitoring, and in the assessment of that data.
5. There must be provision for full and proper public participation in the licensing system and adaptive management processes envisaged by the SIWG.