River Lugg: EA issued with EDR

Salmon & Trout Conservation issues formal request to the Environment Agency under the Environmental Damage (Prevention and Remediation) (England) Regulations 2015 over horrendous damage caused to the River Lugg in Herefordshire.

Salmon & Trout Conservation (S&TC) has today issued a formal request for action under Regulation 29 of the Environmental Damage (Prevention and Remediation) (England) Regulations 2015 over damage caused to the River Lugg Site of Special Scientific Interest.

The formal request requires the Environment Agency to consider whether damage, as defined by the Regulations, has occurred and if so, to inform S&TC of the action it will take. The Regulations also indicate that the cost of addressing the damage caused and preventing further damage, and any mitigation or remediation as may be required, should be met by the person who has caused the damage.

Nick Measham, Chief Executive of S&TC UK said:
“Following their inspections, the Environment Agency and Natural England will be very well aware of the extent of the damage caused by the in-river dredging, tree-felling and bank profiling work conducted last week on the river Lugg at Kingsland
The release of sediment into the river and the loss of habitat on the bed and banks of the river is shocking. The damage caused to protected species, including, but not limited to otters, dippers, bats and Atlantic salmon, is also, patently, very extensive.
There is a threat of further damage being caused downstream, due to the condition that the river upstream of Lugg Bridge has been left in, with exposed profiled mud banks liable to erosion during winter flows, increasing silt and sediment transfer downstream.
We trust that the Environment Agency will now be prosecuting the person or persons responsible for these terrible events. They will, no doubt, require some time to assemble their case, but we will be watching events very closely”. 
Nick Measham, Chief Executive of S&TC UK added:

“There has been discussion about the need to address flooding at the bridge in Kingsland. Of course this is a legitimate concern for those who have been flooded. But what has been done here, the extent of the works, and how it was done, goes way beyond what would be considered to be reasonable in all the circumstances. It is for the Agency now to decide if it was also unlawful.”


Further information is available from Janina Gray (janina@salmon-trout.org) or Nick Measham (nick@salmon-trout.org)

Notes for editors

1) Salmon & Trout Conservation UK (S&TC UK) 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 UK has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC UK has charitable status in both England and Scotland (as S&TCS) 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 wild salmonid fish stocks and the aquatic environment upon which they depend. www.salmon-troutscotland.org

Severn Trent to adopt SmartRivers

SmartRivers welcomes its first water company hosted volunteer hub

We are pleased to announce that Severn Trent is the first water company to enrol into the SmartRivers programme. SmartRivers is the volunteer arm of the Riverfly Census, where invertebrates are sampled and analysed to species-level. The species lists are then used to calculate biometrics that indicate what water quality pressures a river is experiencing. This information enables us to understand more about the subtle pollutants 'stressing out' our fish, and drive real improvements to the quality of water flowing through our rivers.

The monitoring will be taking place at Linacre, situated on the outskirts of Chesterfield. The landscape around the site is diverse, ranging from broadleaf and conifer plantation, to pasture and grassland. In regards to freshwater habitat, there are three de-commissioned reservoirs and the Linacre brook. Over the years, a variety of practical conservation projects have taken place to improve habitat on the brook for the wild trout that live there. However, the effectiveness of this work in regards to the health of the trout population is missing. 

 Lloyd Ross, Ranger for Severn Trent describes how SmartRivers will benefit Linacre:

“I am really keen to carry out work to improve the quality of the aquatic habitat for the trout and other fish and invertebrate species. Aside from the huge ecological benefit, I believe the healthy trout population could become one of a few “flagship” species for Linacre – we could design and install interpretation and education boards around site and plan engagement events centred around about aquatic habitats, species identification and water quality. 

Having a monitoring scheme like SmartRivers in place would allow us to pick up and act on any risks to the aquatic habitat before damage may be caused. The scheme would also help with developing natural flood management in the area as I would have an up-to-date set of data to inform my decisions and planning. Involvement in SmartRivers would be a pro-active, positive contribution to our company pledge to commit to improving the natural environment on our sites”.

Lauren Mattingley, SmartRivers Project Manager says:

“We are really pleased to have a water company on board, and hope others will follow in the footsteps of Severn Trent. As water companies have a huge role to play in keeping our waters pollution-free we welcome engaging with them through SmartRivers”.

Benchmark samping has already begun in the Linacre Brook, with the volunteers due to receive their training in spring 2021, pending Government advice at the time.

Sea lice rampant on salmon farms

Shocking photos show sea lice rampant on salmon farms in Scotland

Shocking footage passed to Salmon & Trout Conservation Scotland reveals horrendous sea lice parasite problems currently occurring on salmon farms in Argyll & Bute, Skye and the Outer Hebrides.

The appalling conditions documented on Vacasay salmon farm on the Isle of Lewis in September 2018 (https://theferret.scot/sick-salmon-scottish-fish-farm-film/) are now being repeated at numerous locations.

Loch Creran, Oct 2020

In its damning report on the salmon farming industry in November 2018, the Scottish Parliament’s Rural Economy and Connectivity Committee was adamant that “the ‘status quo’ in terms of regulation and enforcement is not acceptable.”

Andrew Graham-Stewart, Director of Salmon and Trout Conservation Scotland (S&TCS), said:

“The images and footage passed to us are truly shocking. It seems that little, if anything, has changed, since the 2018 Parliamentary Inquiry, in the way that salmon farms are managed to address escalating sea lice parasite issues. The Scottish Government has failed to introduce a proper regime of regulation and enforcement on salmon farms and consequently parasite and disease issues are being allowed to run riot.”

One of the most severely affected salmon farms, in Loch Creran, is owned by Scottish Sea Farms Ltd. The company is the exclusive supplier of farmed salmon to Marks & Spencer. Recent treatments at the farm, including Thermolicing (passing the farmed salmon through heated water to shock the sea lice off the salmon) and bathing the fish in Hydrogen Peroxide, appear to have had minimal effect. Indeed, large numbers of mature sea lice are clearly visible in the footage which was shot on 22 October, shortly after these treatments.

View sample footage: HERE


Investigators who passed the footage to S&TC have documented severe sea lice eruptions concurrently at salmon farms near Oban, Lochgilphead, Dunvegan, Broadford, Loch Maddy and Loch Boisdale. No investigations were conducted on Orkney or Shetland.

These images from a salmon farm on Skye captured on 26 October, show the horrific injuries sea lice parasites may cause when they are left for weeks to eat the skin of the farmed salmon and expose large areas of flesh.

Skye, Oct 2020


While S&TCS’ focus is the health of populations of wild salmonid fish, it is clear that sea lice inflicting such damage to farmed salmon means that farms are simply not being managed properly and that is bound to have knock-on effects on wild fish.


Nick Measham, CEO of Salmon and Trout Conservation UK, said:

“Badly managed fish farms have severe implications for wild fish, especially when salmon farmers allow sea lice numbers to run out of control.

Anyone with a shred of decency should be sickened by the condition and suffering of these farmed fish. Will the UK really be able to claim it has higher animal welfare standards than other countries such as the US when the Scottish Government allows this to happen?  How does this type of image sit with claims being made over farmed animal welfare in advance of UK-US trade talks?"

Independent monitoring of sea lice on salmon farms is desperately needed.

The monitoring and publication of sea lice numbers on salmon farms is entirely reliant on self-reporting by the salmon farmers themselves.

Andrew Graham-Stewart added: 

"We have no doubt that the appalling lack of control over sea lice on salmon farms will continue until such time as Scottish Government introduces a rigorous regime of independent monitoring and verification. Without such a regime, farms will continue to be run ‘out of sight and out of mind’ of the regulators, with devastating consequences for Scotland’s wild salmon and sea trout.” 


Issued by comms@salmon-trout.org (T: 07463 576892).

Notes for editors

1) Salmon & Trout Conservation UK (S&TC UK) 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 UK has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC UK has charitable status in both England and Scotland (as S&TCS) 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 wild salmonid fish stocks and the aquatic environment upon which they depend. www.salmon-troutscotland.org

2) What is the problem with sea lice? (https://salmon-trout.org/projects/salmon-farming/Background levels of these parasites occur naturally in the sea. However, the advent of salmon farming, particularly in fjordic or largely enclosed sea lochs, has led to a fundamental change in the density and occurrence of sea lice in parts of the coastal waters of the west Highlands and Islands. Even one or two mature female sea lice per fish within a set of cages housing hundreds of thousands of farmed salmon amounts to a very large breeding reservoir producing huge numbers of mobile juvenile sea lice that move out into the local marine environment. The consequences for wild salmon and sea trout smolts, the metamorphosing fragile skin of which is not adapted to cope with more than a few lice, as they migrate from local rivers to sea can be devastating. Lice feed by grazing on the surface of the fish and eating the mucous and skin. Large numbers of lice soon cause the loss of fins, severe scarring, secondary infections and, in time, death. Badly infested wild salmon smolts disappear out to sea, never to be seen again. In contrast afflicted sea trout smolts remain within the locality and they, together with the impact of the deadly burdens they carry, are more easily monitored.

Don’t just take our word for it

The Salmon Interactions Working Group proposals to protect wild salmon and sea trout will not work.

But don’t just take our word for it…..

The Salmon Interactions Working Group (SIWG), which includes Fisheries Management Scotland (FMS), has proposed a system of adaptive management, through the sampling of sea trout in sea lochs by netting, “to monitor lice levels in the environment and assess impacts on wild salmonids”. In the event that such monitoring shows elevated numbers of sea lice, then possible changes to the management of lice levels on the local salmon farms would be discussed.

1) Such adaptive management cannot be a realistic substitute for proper regulation including a strict and universally applied ceiling on farm sea lice numbers (an absolute upper limit to the permitted average number of adult female sea lice per farm fish). But don’t just take our word for it.

In a letter to Highland Council in February 2018, the Chairman of the Wester Ross Area Salmon Fishery Board (also a Board member of Fisheries Management Scotland and an employee of Atlantic Salmon Trust) said:

"If sea trout or wild salmon were to completely disappear at monitoring locations (as may happen), there would be no way to demonstrate cause and effect……Monitoring of wild fish to inform the management of salmon farms for the benefit of wild fish populations in nearby waters is no substitute for appropriate regulation of open cage farms to safeguard wild fish."

2) The monitoring of lice levels on sea trout by netting to inform the management of salmon farms is indeed fraught with difficulties. But don’t just take our word for it.

FMS, which represents Boards and Trusts, published a paper in January 2018 on sea trout post smolt monitoring. It concluded:

“Attempting to link sea lice levels on wild sea trout to the nearest fish farm may not be appropriate, as prevailing wind direction and sea currents may transport fish farm derived sea lice away from salmonid rivers (Adams et al. 2012), and sea trout in the marine environment are mobile and can interact with more than one fish farm” and  “…..in order to better manage the interactions….will require a greater understanding of the lice populations, their build up within the cages and wider environment and the impacts on the wild salmonids. Until these issues are better understood local management will remain difficult”. See http://fms.scot/wp-content/uploads/2018/05/180222-Aqua-Sweep-Netting-Report-2017.pdf

3) Under the SIWG proposals, in a rejection of the standard precautionary approach, it is envisaged that the burden of proof that there is damage being caused to wild fish by salmon farms (before there is any possibility of remedial action in terms of fish farm performance) is the sole responsibility of wild fish interests. This is contrary to the basic principles of natural justice. But don’t just take our word for it.

In a letter dated December 2018 to Highland Council, regarding a proposed increase in biomass at the Loch Hourn salmon farm, the Wester Ross Area Salmon Fishery Board had the burden of proof the right way around…

“We therefore request that the applicant is able to demonstrate, contrary to the information presented above, that the previous increase in on-farm biomass in 2016 was not associated with further declines in wild fish stocks in the area, and that, contrary to the information presented above, that the high sea lice figures reported in SSPO fish health reports for 2016 and 2017 were not associated with high emissions of larval lice into surrounding waters….The applicant should demonstrate that the reported declines in catches of wild sea trout and salmon in the area from 2016 to 2017 were not associated with sea lice infestation associated with the Loch Hourn salmon farm”.

 4) Under adaptive management, establishing a pattern or trend in sea lice numbers through wild fish monitoring is not an exact science, nor can it be achieved quickly. It will take several years and, in the meantime, 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 than is currently the case. Indeed, as a consequence of significant ongoing industry expansion, the sea lice burden and challenge for wild fish continues to rise and will inevitably rise still further in the first decade under an adaptive management regime. But don’t just take our word for it.

In a video conference call in July 2020 a senior executive from the Crown Estate Scotland (responsible for awarding and managing leases for fish farms) did not disagree 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 discernible.

 Even then the results are likely be challenged (including the use of the courts) by the fish farmers. See what is happening in Norway:


There are considerable doubts regarding the extent to which monitoring of wild sea trout is relevant to wild salmon. Even if there were abundant smolts of both species to sample, it would require tens of thousands of samples to be taken nationally, over many years and in many conditions, in order to produce a statistically robust dataset.

Previous studies in Loch Shieldaig by Marine Scotland Science, which sampled over 3,000 smolts (in sentinel cages) relating to just one system and salmon farm area, showed strong correlation with salmon farm lice numbers but crucially still did not meet a sufficient threshold of evidence to ensure control of sea lice on salmon farms. But it is now suggested that sampling less fish of another species by non-research professionals will going to produce enough evidence. What has changed? https://www.researchgate.net/publication/263776267_Using_sentinel_cages_to_estimate_infestation_pressure_on_salmonids_from_sea_lice_in_Loch_Shieldaig_Scotland

5) We have serious concerns that local fishery interests (who will be contracted and paid by the salmon farmers to monitor sea lice on wild fish) will be reluctant to argue robustly for changes to local salmon farming practices when wild fish monitoring shows high levels of sea lice – he who pays the piper calls the tune.

Before the SIWG process Fisheries Management Scotland’s (FMS) position was that adaptive management on its own would not provide the basis for effective regulation, and that a robust sea lice ceiling should be applied to all farms.  Through the SIWG process, which required recommendations which were agreed by the Industry, FMS has aligned themselves with recommendations which do not achieve this. There may well be elements of the recommendations (particularly financial ones) which are beneficial for FMS and the Trusts. However, the compromise in relation to regulation will mean that it is not effective.

We believe that it is imperative that any new regulatory regime includes a strict adult female sea lice ceiling, to be applied to all fish farms. Sea lice must be independently monitored and where levels rise there must be rigorous and very prompt  enforcement to drive lice levels back down. , This ceiling should be set at 0.5 adult female lice 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. This position is based on best available science and in line with recommendations already made by SNH, the industry’s own Code of Good Practice and the Aquaculture Stewardship Council amongst others.


Salmon and Trout Conservation Scotland

October 2020

Sewage (Inland Waters) Bill

Philip Dunne MP launches new Bill to tackle river pollution

Salmon & Trout Conservation warmly welcomes the introduction of the Sewage (Inland Waters) Bill, aimed at tackling the unacceptable levels of raw sewage being discharged into our rivers and streams.

Rt. Hon Philip Dunne MP for Ludlow has published his Private Member’s Bill designed to tackle river pollution from untreated sewage and improve water quality.

In 2019, raw sewage was discharged into rivers across England and Wales for over 1.5 million hours, compromising these vital habitats for wildlife and endangering the health of people who use our rivers for recreation.

Philip Dunne MP, who is also chairman of the Environmental Audit Committee, said:

“Our rivers are a vital part of our natural heritage. It is right the Government has committed to restoring at least three quarters of our waters to their natural state.

But it is clear from last week’s latest assessment from the Environment Agency that we are a long way from achieving that, with fewer than one in six of our rivers in good health. This threatens the aquatic life and iconic species that rely on these precious habitats, such as freshwater fish, kingfishers, otters and dippers.

The discharge of untreated sewage is a major part of the problem. It poses a significant health risk to those who wish to enjoy our rivers for leisure and recreation.

The River Severn and its tributaries the Clun, Corve, Kemp, Onny, Rea, Teme and Worfe all flow through my constituency. They are nothing like as healthy as when I was a child, but they should be.

That is why I have brought forward this Bill, which aims to cut discharges of raw sewage into our rivers - protecting our precious habitats for wildlife and people to enjoy.”

The Sewage (Inland Waters) Bill places a duty on water companies to ensure that untreated sewage is not discharged into rivers and other inland waters. The Bill will require water companies to set out plans progressively to reduce their reliance on combined sewer overflows (CSOs). It proposes increasing levels of transparency, as firms will be mandated to report publicly not just on the frequency and extent of sewage discharges from CSOs and any other sewer catchment assets, but also on the impact on water quality as this is enabled by advances in technology.

Nick Measham, CEO S&TC said,

“I am delighted to see this vital Bill introduced and have been pleased that S&TC was able to make use good use of the donations we receive from members, and elsewhere, to allow S&TC’s lawyer to play a significant role in drafting the Bill and the Explanatory Notes.”

Sewage (Inland Waters) Bill 

Sewage Bill (Explanatory Notes)

The Bill also proposes measures to upgrade drainage infrastructure to separate household sewage from surface water drainage, helping reduce the risk of overspills. It includes measures to reduce harmful products such as non-biodegradable wet wipes, commercial fats and oils from being disposed down the drains. It also proposes measures to expand the number of inland bathing waters and establish targets to increase those classified as “good” or “excellent”.

Guy Linley-Adams, solicitor with Salmon and Trout Conservation said,

“The Bill is a welcome and necessary correction to the post-privatisation legislation for controlling sewage pollution of rivers, streams and lakes. As we leave the EU, we need to increase the level of ambition and this Bill does that. All sides in this debate, including water companies, recognise that we need to build back better post-Covid, including in our water infrastructure, so this Bill deserves, and I’m sure will get, very strong cross-party support.”

The Bill has additional support from environmental charities and NGOs including,

The Rivers Trust, Surfers Against Sewage, The Wildlife Trusts, The Angling Trust, Chalk Aquifer Alliance.

We encourage you to share the Bill with your local MP and lobby them to support it.

Who is my MP? https://www.writetothem.com


  1. The Rt Hon Philip Dunne MP has been Member of Parliament for Ludlow since May 2005. In February 2020 he was elected Chairman of the Environmental Audit Committee. He is also a member of the Conservative Environment Network Parliamentary Caucus.
  1. Untreated sewage is discharged directly into rivers from licensed Combined Sewer Overflows (CSOs) managed by the 9 water and sewerage companies in England, which are permitted by the Environment Agency (EA) to exceed consented concentrations during periods of heavy rainfall. Recent data obtained by the Guardian established 6,508 inland CSOs discharged untreated sewage into rivers over 200,000 times across England for over 1.5 million hours in 2019, meaning that they likely occurred far more regularly than just during periods of intense rainfall.
  1. The government set an ambition in the 25 Year Environment Plan to improve at least three quarters of UK waters and return them to their natural state. However, the latest assessment by the Environment Agency showed that just 16% of England’s rivers meet the criteria for ‘good ecological status’, unchanged from 2016.

It’s the perfume that you notice first.

"If we can’t conserve the most protected, how can we ever conserve the rest?"

Feargal Sharkey, recently appointed a Salmon & Trout Conservation Vice President writes,

It’s the perfume that you notice first.

Not in that pleasingly attractive CHANEL N° 5 kind of a way but more in that acrid, back of the throat, ammonia filled reflux-inducing kind of a way.

It’s when you notice the used condoms, the sanitary products and the dead rat all trapped in a spiralling embrace, circulating anticlockwise in a backwater eddy that you really begin to notice that things just aren’t right. What one observer pithily described as “Dead rat and sanitary towel soup”.

Is this fiction? No. In 2019 raw sewage was discharged for more than 1,000 hours into an environmental wetland situated at the heart of Olympic Park, Hackney Marshes created as part of the London Olympics legacy.

feargal sharkey 2

Yes as part of an event designed to highlight to the world the greatest achievements of British athletes; an event who’s ambition was to build a legacy that would impact upon the lives of millions of Londoners and generations to come: to build a wetland in one of London’s most deprived boroughs. And yet, and yet in 2019 we allowed the local water company to spend more than 1,000 hours dumping sewage into that newly created wetland.

It was not an isolated event. According to recent reports in the Guardian during 2019 water companies across England spent more than 1,500,000 hours dumping sewage into our rivers.

Take for example the case of the River Avon in Hampshire. Just over 1,000 sq miles of catchment, some of the rarest, most precious rivers systems on earth: the River Avon and is tributaries. All chalks streams. All designated part of a Special Area of Conservation.

Yet in 2019, by my counting, Wessex Water spent 14,642 hours ejecting sewage into the River Avon and its catchment.

That’s 5 chalk streams, some of the rarest river ecosystems on earth, afforded one of the highest form of legal protection this country has to offer and we allowed the water company to do WHAT?

Or the Rive Kennett, given birth to in the lush rolling hills of Wiltshire but even by the time it reaches Marlborough just 10 miles later it is already polluted Thames Water having spent 1,636 hours dumping sewage into its once pristine waters.

46 miles later as it reaches Reading parts of the river have been designated a SSSI. And yet, and yet, in 2019 Thames Water spent a total of 12,734 hours dumping sewage into the Rive Kennett.

And the Environment Agency does what exactly?

Well it transpires at least in the eyes of th3e European Court of Justice (ECJ) not a lot that would bring the UK government into line with the Urban Waste Water Treatment Directive (UWWTD).

You see in 2012 the UK Government was taken to the EJC by the European Commission for been noncompliant with the Directive. My reading, the court agreed, the UK was breaking the law. Not only that the court ruled, again my reading that this should only ever happen, only ever happen in “Exception circumstances”.

Well all of that was in 2012. So here we are, 8 years later and in 2019 water companies spent over 1,500,000 hours worth of sewage dumped into England’s rivers. Would that be “Exception circumstances”?

Or the14,642 hours of sewage dumped into the River Avon catchment during 2019. Would that be “Exception circumstances”? Or the 12,734 hours worth of sewage dumped into the River Kennett. Would that be “Exception circumstances”?

As a nation it speaks volumes about the platitudes we allow government and others to heap upon the environment, the empty, meaningless words devoid of intent, the 25 year plans that simply perpetuate the obscenity and the complicity.

If we can’t conserve the most protected, how can we ever conserve the rest?

SNH and EA formally notified of threat of environmental damage from escaped farmed salmon

Salmon & Trout Conservation (S&TC) formally notifies NatureScot (formerly SNH) and the Environment Agency of threat of environmental damage to protected wild salmon SACs following the recent major escape of farmed salmon off the Mull of Kintyre


Following the major escape from a salmon farm off the east side of the Mull of Kintyre in August and the subsequent presence of large numbers of farmed salmon in Scottish and English rivers, Salmon and Trout Conservation has now formally notified the relevant authorities in Scotland and England of  environmental damage to affected Special Areas of Conservation (SACs) for wild Atlantic salmon that either has or may about to be caused to wild stocks.

This process, set down in European law, requires both the Environment Agency and NatureScot to undertake formal examinations of what has occurred and do what they can to prevent further damage occurring to the wild salmon populations in the SACs affected.

Almost 50,000 large farmed salmon were able to escape from Mowi (Scotland) Limited’s farm at Carradale North near Campbeltown on August 20. Since then farmed salmon have been caught in considerable numbers in rivers from the Firth of Clyde to Cumbria, prompting concerns that interbreeding with wild salmon will occur with implications for the vital genetic integrity and thus long-term viability of already depleted wild populations.

The affected rivers include three SACs for wild salmon – the River Endrick SAC in Scotland and the River Derwent and Bassenthwaite SAC and the River Eden SAC in England – which are subject to enhanced protection under the law in the respective jurisdictions.

Guy Linley-Adams, solicitor to Salmon and Trout Conservation, said:

“These notifications put  NatureScot in Scotland and the Environment Agency  in England, the competent enforcing authorities charged with ensuring that the integrity of SACs is maintained, on formal notice that damage to these SACs is either now occurring and/or that there is an imminent threat and that accordingly they should now take any necessary remedial action.”

The notification letter to NatureScot is supported by the Loch Lomond Angling Improvement Association (LLAIA), whose responsibilities include much of the River Endrick.

The notification letter to the Environment Agency is supported by North West Angling Trust Fisheries Consultative Council (NWATFCC) which represents the west coast game fisheries of Cumbria and Lancashire.

If either competent authority finds, following notification, that damage is occurring, then it is obliged to require Mowi to avoid further damage to the conservation status of the habitat and/or species and remedy damage already done.



1) The Environmental Liability Directive (ELD), which enshrines the “polluter pays” principle, was adopted in 2004. In Scotland, it takes effect through the Environmental Liability (Scotland) Regulations 2009.  In England it is covered under the Environmental Damage (Prevention and Remediation) (England) Regulations 2015

2) Scottish Government confirms that “escaped fish…… have the potential to interbreed with wild fish, leading to dilution of genetic integrity”. http://www.gov.scot/Topics/archive/18364/18692 Research indicates that interbreeding of farmed with wild salmon results in lowered fitness, with repeated escapes causing cumulative fitness depression and potentially an extinction vortex in vulnerable populations. See, for example, McGinnity et al (2003) https://pure.qub.ac.uk/en/publications/fitness-reduction-and-potential-extinction-of-wild-populations-of 

Time for bespoke regulatory targets for all chalkstreams

Chalkstreams are as internationally rare and ecologically important as coral reefs or rainforests, and 85% of the world’s chalkstreams are found in England.

With this comes a responsibility to protect them, something at the moment we are failing to deliver, with evidence of many stretches running dry, whilst others are clogged with nuisance algae and huge declines in flylife, the base of the food web.

Our Riverfly Census work has shown chalkstreams are under huge pressure from excess phosphates, fine sediments and chemicals, all exacerbated by vast over-abstraction. Chalkstreams are groundwater fed- when rain falls it sinks into the chalk ground through fissures and cracks, turning into underground oceans of trapped rainwater. Natural refilling of this underground water is essential to ensure our chalkstreams stay flowing. Yet, because this water is cool and stable and therefore ‘cheap’ to use, it is heavily relied upon and much is removed by water companies to become the water we use in our homes.

We, at Salmon & Trout Conservation, are calling for: New ambitious, bespoke regulatory
targets for all chalkstreams which recognise and manage them as the unique habitats they are.

Currently all our rivers are managed under the Water Framework Directive (WFD). Within
this all rivers are classified the same, working towards common ecological targets. Yet, our
data confirms invertebrate communities in chalkstreams are biologically distinct from other
rivers. So, this generic, one size fits all approach cannot adequately protect them. ‘Good’
according to WFD is not good enough for chalkstreams. By developing new chalkstream
specific ecological targets for all chalkstreams it will identify the elements which make
chalkstreams so special and protect and restore them.

To ensure all our chalkstreams are healthy and sustainable into the future requires radical
action now and a step change in the way we manage our water environment. It will require
new bespoke regulatory targets alongside a properly resourced Environment Agency to
deliver and enforce regulations, and an ambitious timeframe to stop all water company’s
reliance on ‘cheap’ chalk aquifer water and drive investment into alternative water supply

We cannot afford to tinker around the edges any longer. The more degraded our
chalkstreams become, the more similar they are to other rivers. We are losing the things
which make them special. We have an international duty and moral obligation to raise the
bar and sustainably protect these precious habitats into the future.

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





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.


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”.


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.