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:

https://salmonbusiness.com/salmon-farmers-assemble-crack-force-team-of-lawyers-to-file-giant-lawsuit-against-state/

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.

https://salmon-trout.org/2020/06/24/why-a-strict-ceiling-on-sea-lice-must-be-applied-to-all-scotlands-salmon-farms/

Salmon and Trout Conservation Scotland

October 2020

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

https://www.bbc.co.uk/news/uk-scotland-glasgow-west-53913708

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.

ENDS

Notes

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 

Not just another escape

As a moderate late summer storm abated, rumours that one of Mowi’s salmon farms between the Mull of Kintyre and Arran was in trouble were confirmed by a statement from the company:

“On August 20, 2020, Mowi’s salmon farm at Carradale North, consisting of 10 circular net pens containing 550,000 salmon (at 4.2kgs), shifted position after its seabed anchors became dislodged during Storm Ellen that has hit the UK and Ireland. The company’s priority at this time is to secure the fish cages in place until Storm Ellen subsides, and to safeguard staff, contractors and fish stock”.

Soon thereafter dramatic aerial pictures, showing that one of the farm’s circular cages was severely buckled, dominated both broadcast and print media coverage. The images made a mockery of the claim advanced in an ingratiating article about the Carradale farm in the local Campbeltown newspaper two months earlier that new “robust anchoring” renders “the pens more stable and better suited to withstand the most extreme weather”.

The damage to the farm allowed some 48,000 large salmon to escape. When it comes to escapes, the Carradale farm has form, having “lost” 16,000 immature fish in 2015. Mowi’s recent record elsewhere in the region is suspect; 73,000 salmon escaped from its farm off Colonsay in January this year. What differentiates this latest escape is the fact that the fish were mature and they entered the wider marine environment just at the time of year when they are predisposed to run into rivers alongside wild salmon

Sure enough, within days large numbers of flabby farmed salmon were showing up in west Scotland rivers, notably in the Firth of Clyde (the Leven) and Ayrshire. These fish dominated rod catches, an indication that they will likely greatly outnumber wild fish on the spawning redds. Mowi’s position statement that it “continues to engage with local and national wild fisheries groups to monitor and assess the presence or absence of salmonid genetic introgression” is essentially meaningless. The genie is well and truly out of the bottle, with farmed salmon of Norwegian origin (alien fish to Scottish rivers) seriously threatening the vital genetic integrity of our already depleted native wild salmon strains. Imagine, if you will, wild wolves interbreeding with poodles and consequently the fitness of the offspring.

It is not currently illegal for a salmon farming company to have an escape in Scotland, so Scottish Government will not intervene. Contrast this with Chile where Mowi has just been fined $6.7 million following a major escape there in 2018.

Indeed, Mowi Scotland is somewhat blasé and on record as recognising that escapes are inevitable (and viewed as just another business expense). In response to the Carradale escape, Ian Roberts, a director at Mowi Scotland, responded thus: "To lose 48,000 fish is extremely disappointing and obviously hits you financially as well... But in the history of salmon farming and... moving into locations that are very high in energy and difficult to farm unfortunately, we have these incidents… it has happened before and it will happen in the future again…."

In these circumstances the only remedy likely to cause Mowi to redouble efforts to retain its stocks within their cages is legal action for damages by District Salmon Fishery Boards and/or their representative body Fisheries Management Scotland (FMS). To date the response by the latter has been muted with no outright condemnation of the escape; they have simply issued advice that the farmed fish should be killed and scale samples taken. Some Boards in the affected area are now looking for FMS to take the lead with robust action.

Considerable numbers of farmed salmon are now also showing up in the rivers of north-west England. There is a growing clamour on the ground for the relevant authorities to instigate appropriate legal action against those responsible. Obviously, no-one can bring a case without the necessary evidence – in this case sample fish. Initially anglers were given the bonkers instruction to release any farmed fish back into the water! Fortunately, this has now been rescinded, at least on the Cumbrian rivers, with the Environment Agency advising that “farmed salmon may be taken and killed” and reported accordingly.

 

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.

NASCO 2020

Paul Knight reports on the 37th Annual Meeting of NASCO

The North Atlantic Salmon Conservation Organisation (NASCO) met for its Annual Meeting in the first week of June, although this year, uniquely, all the meetings were held virtually by video link, with those not directly involved being able to listen in by phone.  Despite concerns that such a large international conference would be difficult to organise and run – it involved a Council and three separate Commissions – it actually went very smoothly, albeit with some of the more important issues, particularly from an NGO viewpoint, being postponed until Council is able to meet face-to-face, hopefully this autumn.

The main objective for the NGOs was to influence support for a full day Theme-based Special Session (TBSS) on salmon farming at next year’s Annual meeting.  This follows increasing concern right across the north Atlantic – and also the Pacific – that open-net salmon farming is the most damaging issue for wild salmon and sea trout that NASCO parties and jurisdictions actually have the power to do something about.  The NGOs were therefore delighted to receive unanimous support from all the Heads of Delegation for the TBSS in June next year, even agreeing to extending the meeting by a day if that is needed to accommodate the event.

The main concern driving the NGOs is that, despite NASCO resolutions going back at least 17 years, and a Council direction that open-net salmon farming should receive particular attention from relevant countries, the Implementation Plan process – the 5-year plans for salmon conservation put forward by each party and jurisdiction – clearly show a failure to protect wild fish from the adverse impacts of sea lice infestations killing migrating smolts, and escaped farmed fish interbreeding with natural salmon populations.  Two countries with significant salmon farming industries openly admit that they have no action to regulate sea lice emanating from open pen farms, while another has a national policy allowing 30% of wild salmon smolts to be killed before any serious regulation is considered.

So, the TBSS is a small but significant step along a very long road needed to turn around the juggernaut of political commitment so that appropriately effective regulations are introduced (in those jurisdictions where they are still absent) and are enforced rigorously to protect wild fish.  It is a sad admission that no country with both a salmon farming industry and wild salmon populations presently protect their natural fish stocks adequately enough.

Another pleasing aspect of this meeting was that, following several incidents last year when the NGOs felt they were being kept at arms’ length from important Council decisions, there were signs that our complaints had been taken onboard.  However, there are still serious issues to address for the NGOs at the autumn intersessional Council meeting, including:

  • The process for completing and reviewing the Implementation Plans – we want to see far more genuine commitment in these plans to protecting wild salmon, particularly from the harmful effects of salmon farming
  • An opportunity for NGOs to input fully to the upcoming external performance review, which will be an independent audit of NASCO’s performance since the previous review in 2012 in achieving its primary objective of protecting wild salmon.
  • Confirmation that NASCO is committed to a fully transparent process in all its work, including NGO access to and involvement in all Council and Commission decisions
  • Through our representation on the Implementation Plan and Annual Progress Report Review Group, NGO involvement in developing TBSSs for upcoming annual meetings
  • Following on the success of this virtual meeting, how much of NASCO’s work could be delivered in this way in future, so cutting down time and money resources in attending meetings, particularly those outside of the main annual event, which we agree should remain face-to-face under normal circumstances

In summary, therefore, a useful meeting where the NGOs achieved our main goal of a TBSS on salmon farming next year.  Much still to do and agree, and we now look forward to the face-to-face intersessional Council meeting in the autumn – provided we are able to travel again by then, of course.

S&TCS writes to Scottish Ministers: MSA position on salmon farming regulation

Salmon & Trout Conservation Scotland (S&TCS) writes to Scottish Ministers to outline Missing Salmon Alliance's formally agreed position on salmon farming regulation.

Roseanna Cunningham MSP

Cabinet Secretary for Environment, Climate Change and Land Reform

Fergus Ewing MSP

Cabinet Secretary for the Rural Economy

2 April 2020

 

Dear Ministers

Regulation of salmon farming with particular reference to impacts on wild salmon and sea trout

In their 2018 reports into salmon farming, both the Environment, Climate Change and Land Reform Committee and the Rural Economy and Connectivity Committee concluded that the regulation of salmon farming was inadequate and not fit for purpose, particularly in terms of protecting wild fish from negative impacts.

There is considerable concern that the recommendations to the Cabinet Secretary on salmon farming regulation that will emerge from the Salmon Interactions Working Group (SIWG) may fall far short of what is required and thus will fail to give urgently required protection to wild fish. You will be aware that none of the members of the Missing Salmon Alliance (MSA), which includes the Atlantic Salmon Trust, Salmon and Trout Conservation Scotland, the Angling Trust and the Game and Wildlife Conservation Trust, were represented within SIWG. Indeed, wild fish representation on SIWG was restricted to those with a somewhat limited mandate.

The four members of the MSA carry between them a very substantial mandate. 

They have recently adopted a joint formal position on salmon farming regulation:

Regulation must include: 

  1. The clear identification of a Scottish public authority with the statutory function of protecting wild fish from the negative interactions of salmon farming. 
  1. The introduction of an effective, robust and enforceable regulatory system for all salmon farms, to protect wild migratory fish and proactively address all and any negative impacts associated with salmon aquaculture, including much stricter ‘backstop’ limits for on-farm sea lice numbers, coupled with independent monitoring and strict enforcement in the event of breaches, to curtail the damage being caused to wild salmon and sea trout by salmon farming. The ‘backstop’ limits should be set at an average of 0.5 adult female lice per farmed fish on any particular farm,  with the limit dropping to  0.1 during wild smolt emigration between February and June, but this would not prevent adaptive management requiring lower lice levels on particular farms if that was required.  
  1. A genuinely precautionary approach to the licensing and permitting of any new salmon farms or expansion of existing farms. 
  1. A review of the permitted biomass and location of all existing salmon farms as against their environmental impact, with a mechanism to compel reductions in biomass and relocation where appropriate. 
  1. Full transparency on the environmental impact of fish farming, including the ‘real time’ publication of on- farm sea-lice, escapes of farmed fish, use of all treatment chemicals (whether on-farm or in well boats), farmed fish mortalities and disease information. 
  1. A requirement that no salmon farming development be permitted without the prior completion of a rigorous independent cost benefit analysis of the potential impact on coastal communities, including the impact on existing local businesses and ecosystem services.
  1. Any adaptive management of fish farms, to be based on monitoring of wild fish, must be robust, independent, transparent and open to public scrutiny, with clear thresholds and deadlines for rapid action on-farm where problems are identified or suspected, and an appropriate regulator charged with enforcement of such management measures. 

MSA members have now individually published the above position:

https://anglingtrustcampaigns.net/blog/missing-salmon-alliance-update

https://atlanticsalmontrust.org/aquaculture/ 

https://www.gwct.org.uk/fishing/msa/position-statement-on-the-tighter-regulation-of-salmon-farming/ 

https://salmon-trout.org/2020/03/25/missing-salmon-alliance-urgent-implementation-of-new-system-of-regulation-for-fish-farms/ 

Members of the MSA therefore request that Scottish Government also adopts the same position as MSA, as you consider how to proceed with salmon farming regulation. 

Given the perilous state of wild salmonid populations, members of the MSA believe robust Government action, in line with this position, is urgently required and anything weaker will not protect wild fish sufficiently.

Yours sincerely

Andrew Graham-Stewart

Director – Salmon and Trout Conservation Scotland

Cc Graham Black, Director, Marine Scotland

Alastair Mitchell, Marine Scotland

Edward Mountain MSP, Convener REC Committee

Gillian Martin MSP, Convener ECCLR Committee

John Goodlad, Chairman, Salmon Interactions Working Group

Mike Montague, Terry A’Hearn, Peter Pollard, SEPA

Cathy Tilbrook, Nick Halfhide, SNH

Alan Wells, Fisheries Management Scotland

Sam Collin, Scottish Wildlife Trust

Issued by Corin Smith, 2 April 2020. comms@salmon-trout.org (07463576892)

Missing Salmon Alliance: Urgent Implementation of new system of regulation for fish farms

The Missing Salmon Alliance members today published updated guidance on the need for the urgent implementation of a new system of regulation for fish farms in Scotland.

25 March 2020

Regulation must include:

1.            The clear identification of a Scottish public authority with the statutory function of protecting wild fish from the negative interactions of salmon farming.

2.            The introduction of an effective, robust and enforceable regulatory system for all salmon farms, to protect wild migratory fish and proactively address all and any negative impacts associated with salmon aquaculture, including much stricter ‘backstop’ limits for on-farm sea lice numbers, coupled with independent monitoring and strict enforcement in the event of breaches, to curtail the damage being caused to wild salmon and sea trout by salmon farming. The ‘backstop’ limits should be set at an average of 0.5 adult female lice per farmed fish on any particular farm,  with the limit dropping to  0.1 during wild smolt emigration between February and June, but this would not prevent adaptive management requiring lower lice levels on particular farms if that was required.

3.            A genuinely precautionary approach to the licensing and permitting of any new salmon farms or expansion of existing farms.

4.            A review of the permitted biomass and location of all existing salmon farms as against their environmental impact, with a mechanism to compel reductions in biomass and relocation where appropriate.

5.            Full transparency on the environmental impact of fish farming, including the ‘real time’ publication of on- farm sea-lice, escapes of farmed fish, use of all treatment chemicals (whether on-farm or in well boats), farmed fish mortalities and disease information.

6.            A requirement that no salmon farming development be permitted without the prior completion of a rigorous independent cost benefit analysis of the potential impact on coastal communities, including the impact on existing local businesses and ecosystem services.

7.            Any adaptive management of fish farms, to be based on monitoring of wild fish, must be robust, independent, transparent and open to public scrutiny, with clear thresholds and deadlines for rapid action on-farm where problems are identified or suspected, and an appropriate regulator charged with enforcement of such management measures.

NOTES

The Missing Salmon Alliance (MSA) is fighting to reverse the devastating collapse in wild salmon around the UK. By combining expertise, coordinating activities and advocating effective management solutions we can help the wild Atlantic salmon survive and thrive in our rivers and seas for the next generation.

The MSA is comprised of the following members:

Salmon & Trout Conservation, Game & Wildlife Conservation Trust, Atlantic Salmon Trust, and the Angling Trust with Fish Legal

https://www.missingsalmonalliance.org

Scottish Ministers’ lamentable failure to regulate salmon farming

Scottish Ministers’ lamentable failure to regulate salmon farming to protect wild fish continues, while industry’s relentless expansion gathers pace

 Almost two years after first Parliamentary report said  “the status quo is not an option”, S&TCS, other NGOs and Scottish community groups warn that their next step is to call and campaign for a boycott of Scottish farmed salmon

ISSUED: 20 Feb 2020

As the comprehensive Scottish Parliamentary inquiry reports on salmon farming from 2018 continue to languish on the shelves without Scottish Ministers taking any meaningful action on the reports’ recommendations, Salmon and Trout Conservation Scotland (S&TCS), other NGOs and Scottish community groups are saying “enough is enough” and issuing an ultimatum.

Almost two years after the Environment, Climate Change and Land Reform (ECCLR) Committee issued its report in March 2018 and 15 months after the Rural Economy and Connectivity (REC) Committee reported in November 2018, that the “status quo” in terms of the regulation of the salmon farming industry was not an option, the old regulatory system remains in place  and is still failing wild salmon and sea trout.

ECCLR: http://bit.ly/ECCLR_salmon_farming

REC: http://bit.ly/REC_salmon_farming

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

“In January 2019 Cabinet Secretary Fergus Ewing committed to making ‘tangible early progress’ on the findings of the inquiry. He has not honoured that commitment. He set up two working groups to address the impacts of salmon farming on wild fish. Over a year later, these groups are way behind schedule, are still deliberating and there is no timeline for them to reach any conclusions.

“We no longer have any confidence that introducing effective regulation of salmon farming is a Scottish Government priority. We have been as patient and as trusting of Scottish Government as we can be, but the time for prevarication and procrastination is over and we are now left with no option but to issue a simple ultimatum.

“Unless Scottish Ministers have confirmed by Easter that they are putting in place appropriate statutory and/or regulatory measures to protect wild salmon and sea trout and that these measures will be in place and in force by the end of 2020, then S&TCS, together with many other organisations supporting this statement, will call and campaign for a full and complete boycott of all Scottish farmed salmon products.

If we have to go ahead with this, it will be the fault of Scottish Government.”

Relentless growth of the industry has continued

Despite the REC Committee being “of the view that 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), between March 2018 (when the ECCLR Committee’s Report was published) and December 2019, salmon farm planning permissions for an additional 76,000 tonnes of biomass have either been granted or are in the planning process; this breaks down into 28,754 tonnes planning permission granted, 14,370 tonnes planning permission applied for or pending and 33,105 tonnes screening and scoping applied for. 76,000 tonnes equate to almost 50% of the actual tonnage of farmed fish harvested in 2018.

Guy Linley-Adams, solicitor to S&TCS, said: 

“Scottish Ministers need to call a halt to any more expansion of the industry until appropriate regulatory measures are in place to protect the environment and nature. The REC Committee called for a moratorium in all but name, but there were some silly games in the use of that word. 

“Most importantly, rather than simply waiting and hoping for the fish farming industry to agree to controls, when that industry clearly feels any regulation is contrary to its commercial ambitions and priorities, the Scottish Government must do what it was elected to do - it must actually govern - in this case to protect Scottish wildlife.

“If Scottish Ministers fail to deliver the required protections, at very best, they will be guilty of presiding over the managed decline of wild salmon and sea trout in the west Highlands and Islands”. 

For the avoidance of doubt, vital statutory or regulatory measures must now include:

  • The clear identification of a Scottish public authority with the statutory function of protecting wild fish from the negative interactions of salmon farming
  • The introduction of an effective and robust regulatory system for all salmon farms, including much stricter limits on-farm sea lice numbers, to curtail the damage being caused to wild salmon and sea trout by open cage salmon farming
  • A genuinely precautionary approach to the licensing and permitting of any new salmon farms or expansion of existing farms
  • A review of the permitted biomass and location of all existing salmon farms as against their environmental impact, with a mechanism to compel reductions in biomass and relocation where appropriate
  • Full transparency on the environmental impact of fish farming, including the ‘real time’ publication of on- farm sea-lice, escapes of farmed fish use of all treatment chemicals (whether on-farm or in well boats), farmed fish mortalities and disease information; and
  • A requirement that no salmon farming development be permitted without the prior completion of a rigorous independent cost benefit analysis of the potential impact on coastal communities including the impact on existing local businesses.

A 4 page brief explaining in detail the context and background to the decision to issue an ultimatum can be found: HERE

The ultimatum and potential boycott are endorsed and supported by the following organisations so far:

Angling Trust

Community of Arran Seabed Trust (COAST)

Craignish Restoration of Marine & Coastal Habitat (CROMACH)

Fairlie Coastal Trust

Friends of Loch Etive

Friends of the Sound of Jura

Loch Visions

North and West District Salmon Fishery Board

Open Seas

Orkney Trout Fishing Association

Save Seil Sound

Scottish Creel Fishermen’s Federation (SCFF)

Scottish Salmon Think-Tank

Sea Change Wester Ross

Sealife Adventures

Skye Communities for Natural Heritage

South Skye Seas Initiative

Tay Ghillies Association

Added since news release:

Coastal Communities Network Aquaculture Sub-Group

Eigg Environmental Action Group

Friends of Loch Creran

Salmon Aquaculture Reform Network Scotland (SARNS)

The Meikleour Arms

Tay Salmon Fisheries

North Atlantic Salmon Fund US (NASF US)

North Atlantic Salmon Fund Iceland (NASF Iceland)

Atlantic Salmon Federation (ASF)

Ulster Angling Federation

Salmon Watch Ireland (SWIRL)

If your organisation wishes to join the coalition calling for regulation please contact comms@salmon-trout.org

VISUAL ASSETS

Can a “feed the world” mantra justify trashing our marine environment?

"The suggestion that salmon farming is somehow justifiable in order to feed the world simply will not wash."

Andrew Graham-Stewart, Salmon & Trout Conservation Scotland

I have been cursing Fergus Ewing MSP, Cabinet Secretary in Scotland for the Rural Economy, of late. Of course, it is nothing personal. I will explain.

On November 6 I was watching – on Parliament TV – Ewing and his senior civil servants giving evidence before the Scottish Parliament’s Rural Economy Committee. Following close questioning about the salmon farming industry’s dismal environmental record, Ewing sought to justify the industry’s “serious problems” thus:  “If we have to feed twice as big a population in the world, we must, as no new farmland is going to be created any time soon, find a way of using the marine environment……to feed the planet.”

As soon as the Cabinet Secretary uttered the words “feed the planet”, the refrain from what is perhaps the most annoying and sanctimonious pop ditty in history entered my head. In 1984 the assorted stars of Band Aid raised millions towards famine relief in Ethiopia, a thoroughly creditable initiative, through sales of the single Do they know it’s Christmas? The words of the chorus, Feed the world, are repeated endlessly in shrill tones. Ever since its release, this song and its inane refrain have become a staple of the excruciating muzak that pollutes public spaces throughout December. This year, thanks to Fergus Ewing’s utterance, I have been struggling to expurge the inane Feed the world refrain from my consciousness since early November.

Of far greater import is the fact that farmed salmon is never going to be a sustainable answer to feeding the world. Growing farmed salmon is dependent on the extraction by foreign-flagged factory ships of vast amounts of other fish, mainly from the coastal seas off poor countries in West Africa and South America (depriving local communities of sustenance and the opportunity of making a sustainable living), and shipping the catch thousands of miles to be converted into fishmeal.

Farmed salmon is simply not an efficient use of fish protein. It requires a considerably greater weight of bait or other fish to produce a kilo of farmed salmon – and the oft-quoted and dubiously optimistic conversion ratios never take into account those farmed salmon that die, because of disease and parasites, before they are harvested; this mortality rate of salmon (for which in effect the feed has been entirely wasted) in Scotland is some 25%.

As I write, supermarket fresh salmon is retailing for around £15 per kilo, generally more than the price of cod or haddock and far more than the likes of mackerel or herring. In fact, salmon is often a luxury purchase; recently the Daily Mirror reported that one Tesco London store is “hiding smoked salmon following a string of thefts in the run-up to Christmas”. Farmed salmon is not cheap protein that is going to be a solution for world hunger. It is simply fatuous for any politician or indeed industry spin-doctor to suggest that is the case.

Hardly a week goes by without further damning evidence of what an environmental disaster open-cage salmon farming is. Scottish Ministers and industry spokespersons are increasingly desperate in their search for valid reasons to vindicate the trashing of our coastal marine environment and the catastrophic decline in those species that depend upon clean, chemical-free and parasite-free waters. The suggestion that salmon farming is somehow justifiable in order to feed the world simply will not wash.

S&TC and Patagonia deliver 170,000 strong petition to Scottish Parliament

Our partnership with Patagonia in this campaign has been extremely effective.

Salmon & Trout Conservation Scotland (S&TCS) are pleased to have been able to orchestrate the delivery of Patagonia Inc's "Artifishal" petition against open-net salmon farming, which we supported, to Gillian Martin MSP, Convener of the Environment, Climate Change and Land Reform (ECCLR) Committee at the Scottish Parliament.

Patagonia's credibility on environmental issues and the public's overwhelming empathy with the issues raised by the 'Artifishal' film and petition has been reflected in support from hundreds of thousands across Europe.

The recent collaboration with Patagonia has reinforced Salmon & Trout Conservation Scotland's (S&TCS) determination to ensure that the Scottish Government takes meaningful action to deliver on the clear recommendations of the ECCLR and REC committees which were the outcome of last year's Scottish Parliament Inquiry into salmon farming.

Andrew Graham-StewartDirector - S&TCS said:

"We will continue to press for an immediate moratorium on the expansion of open cage salmon farming and to insist that the Scottish Government accepts that the future for salmon farming in Scotland must be in closed containment systems. We are unwavering in our determination to protect wild salmon and trout populations in Scotland, and the ecosystems on which they rely, from the devastating impacts of open cage salmon farms."