Our director in Scotland, Andrew Graham-Stewart responds to SEPA's proposals for managing interactions between sea lice from salmon farms and wild salmon.
We are shocked and dismayed at what is being proposed by the Scottish Environment Protection Agency (SEPA). The proposals set out fall far short of what is required to protect wild salmon from the impacts of sea lice because they:
- ignore the damage already caused by fish farming to wild salmon populations in Scotland;
- fail to recognise the urgency of the situation faced, that populations of wild salmonids are at critically low levels (as per the SIWG), and that “urgent” (per the REC and ECCLR Committees) and “swift” (per SIWG) action to provide enhanced and effective regulation is needed, adopting the precautionary approach (per REC and ECCLR Committees);
- fail to recognise or apply the principles laid down in the UK Withdrawal from the European Union (Continuity) (Scotland) Act 2021, in particular, the precautionary principle as it relates to the environment and the principle that preventative action should be taken to avert environmental damage;
- fail completely to deal with impacts on sea trout, a UK Biodiversity Action Plan priority fish species;
- fail to address the continued impacts of existing farms, instead being politically focussed on facilitating the expansion of fish farming;
- fail to deal with impacts on wild salmon beyond a very short time window (April/May);
- fail even to attempt to meet the NASCO objective 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” to which Scotland is signed up;
- are vague in delivery, built on largely untested models and numerous assumptions on the interactions between farmed-derived lice and wild fish;
- rely excessively on self-monitoring, self-assessment and indeed, self-design of both the regulatory tools and models by the fish farmers themselves;
- are very far from the “robust, transparent, enforceable and enforced” regulatory system that the SIWG sought; and
- in any event, would take years to develop and implement properly, with outcomes remaining extremely uncertain, therefore not providing any prospect of effective regulation in the foreseeable future.
We urge you to respond to the consultation (which closes on Monday 14th March 2022) and make it clear to SEPA and Scottish Government that what is proposed is nowhere near acceptable.