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.”

https://digitalpublications.parliament.scot/Committees/Report/REC/2018/11/27/Salmon-farming-in-Scotland#Summary-of-conclusions-and-recommendations

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

PROBLEMS ARE NATIONWIDE

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.”

Ends

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.

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

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

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.

Nick Measham, CEO, Salmon & Trout Conservation,

I am proud to take on the responsibility for leading Salmon & Trout Conservation. Though I am a relatively recent recruit – I joined S&TC part time five years ago to help manage a project on the Upper Itchen and developed the Riverfly Census – I have had a life-long love of rivers and am fascinated about every aspect of them.

I come from West Bromwich, born at a time when my local river, the Tame, was one of the most polluted in Europe. My earliest memories are of playing in small streams, catching bullheads, loach, sticklebacks and crayfish. I came to angling through this love of water – no one else in the family fished – and have always believed that fishing is a dividend, albeit a big one, of our stewardship of wild fish and their habitats. You can’t fish too happily without catching fish (though I often seem to…).

My central objective for S&TC may seem prosaic but it is to continue to grow the work we do as the only independent voice campaigning for wild fish and their habitats. We will continue to take no Government money which too often leads to solutions which do not appear to put the environment first and which would conflict with our need to hold Government and its agencies to account.

We have been and will remain a small team with a reputation for getting things done.

We achieve what we do at a national scale by: being ruthlessly focused on a small range of critical issues and; working in close partnership/collaboration with many others.

This focus and partnership working will continue to form the framework for all we do in the short run and over the longer term too.

My immediate priority in this difficult year is to find the resources to increase the impact of our projects across our three current work streams (and protect our wonderful dedicated talented team). The Covid-19 impact is placing huge stress on funding, but the environmental demand has never been greater.

Our current projects are:

SmartRivers which builds on the Riverfly census to train volunteers to use invert samples to nail the water quality threats (pesticides, phosphate, sediment and sewage) threatening wild fish populationsWe are growing a SmartRivers “franchise” network across England, Wales and Scotland which will provide our water quality database with evidence of the pollutants stressing our rivers, their dependent wild fish and water life.
Salmon Farm Reform to prevent open-net salmon farming harming salmon and sea trout. In-shore open-net salmon farming kills wild salmon, sea trout, other fish and crustaceans. Lethality results from sea lice infestation, escaped farmed fish breeding with wild ones, and coastal waters being seriously polluted by fish waste; and also, ironically, by the quantity of chemicals needed to try to keep cage-farmed fish parasite and disease free. We champion effective regulation to control sea-lice parasites and eliminate escapes; we also seek relocation of open cage farms away from sensitive salmon and sea trout migration routes.
Water Action using evidence from the Riverfly Census and other science to drive policy reform on water quality (we are leading the charge on forcing action on pesticides in water and general agricultural abuse of water) and on abstraction for example.

Longer-term, the main challenges are to put in place effective regulation of agriculture and aquaculture to protect our wild fish and their habitats.

Our river fly evidence from the Riverfly Census and SmartRivers shows agricultural pollution rather than the industrial pollution of my childhood, to be the main threat to wild fish. We must ensure that farming practices stop damaging our rivers. We already have the regulation in place to do this, regulation which has been accepted by the NFU and other farmers’ bodies. This requires the Environment Agency and its sisters in Wales and Scotland to be given the resources and the will to stop bad farming practice through education and enforcement. It seems so straight forward but, somehow or other the UK’s Governments fail to deliver.

The second main challenge is aquaculture: simply put open-cage salmon farming in inshore marine locations is incompatible with wild fish. We are fighting hard to get the Scottish Government to regulate salmon farming to protect wild fish from the lethal plumes of sea lice from farmed fish and from genetically devastating escapes.

Underlying these threats to our rivers and coastal waters, is the whole more food/cheaper ethos which has dominated food production for decades. Countering this will require more than anglers, and this raises campaigning issues which we are only now beginning to understand and resource. We are an organisation of some 6000 members. We must retain and expand this base - numbers count politically - and add sources of support both people and funds.

I cannot promise you immediate success, but I can offer you the commitment to try to counter the damage being done to our wild fish and their waters. I hope I can count on your support in the years ahead.

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.

Why a strict ceiling on sea lice must be applied to all Scotland’s salmon farms

Wild salmon and sea trout populations in Scotland are dangerously low. For wild salmon and sea trout in the west Highlands and Islands to be properly protected from the negative impact of salmon farming, the effective control of sea lice on farms is a vital first step.

A precautionary approach is essential

S&TCS believes that a genuinely precautionary approach must be applied to the licensing and permitting of any new salmon farms or expansion of existing farms. Such a precautionary approach was also recommended by both the REC and ECCLR Committees in the 2018 Parliamentary Inquiry.

In March 2018, Graeme Dey MSP, Convener of the ECCLR Committee, emphasised the need to apply the precautionary principle to fish farming - “there appears to have been too little focus on the application of the precautionary principle in the development and expansion of the sector…Scotland’s public bodies have a duty to protect biodiversity and this must be to the fore when considering the expansion of the sector. We need to progress on the basis of the precautionary principle …”.

REC Committee (Recommendation 40) was that “although there is a lack of definitive scientific evidence of the various factors that are contributing to the decline of wild salmon stocks, the Committee is nevertheless of the view that a precautionary approach should be taken which will seek to minimise the potential risk to wild salmon stocks wherever possible”.

Put simply, applying the precautionary approach means not using lack of scientific certainty to justify delay in taking action to prevent environmental damage. Where a threat of serious damage has been identified action should be taken to prevent damage occurring. The threat of serious damage to wild salmonids caused by salmon farms has been identified by numerous fisheries scientists, and applying the precautionary principle means putting in place now measures that will prevent salmon farms causing harm to wild salmonids. Waiting to take action until after it has been demonstrated that a particular salmon farm has harmed wild fish is not in accord with the precautionary approach.

In the context of the contested scientific understanding of the negative interactions between farmed and wild fish, fish farm regulation must be underpinned by a robust and strict precautionary approach to protect wild salmonids. Wild salmonid monitoring, particularly in the marine environment, is an imprecise science and is highly unlikely to produce clear and unambiguous results that are not open to multiple different interpretations of what might be occurring.

A strict sea lice ceiling must be applied to all fish farms

Therefore, the precautionary principle demands that adaptive management can only take place under a strict, robust and universally applied sea lice ceiling, in other words an absolute upper limit to the permitted average number of adult female sea lice per farm fish.

Without this ceiling, the burden of proof is effectively reversed, with proof that there is damage being caused to wild salmonids becoming a pre-requisite to any action being taken to address fish farm performance in respect of sea-lice and diseases^[1].

There is already domestic, international and industry support for a strict sea lice ceiling

In November 2018, the Scottish Parliament’s Rural Economy and Connectivity Committee, in its report following its investigations as part of the Inquiry into Salmon Farming, concluded (Recommendation 15) that sea lice triggers should be “challenging” and urged Government to “set a threshold that is comparable with the international industry standards”.

The inter-governmental North Atlantic Salmon Conservation Organization (NASCO) advocates 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”.

In most North Atlantic salmon farming countries statutory on-farm average adult female sea lice limits are set at no more than 0.5 per fish during the critical main wild smolt outward migration period in the spring.

So, why should Scotland’s wild salmon and sea trout be accorded any lesser levels of protection than fish elsewhere?

The Aquaculture Stewardship Council (ASC) certification programme for salmon farming sets global standards for salmon farming (https://www.asc-aqua.org/wp-content/uploads/2019/12/ASC-Salmon-Standard_v1.3_Final.pdf) including for sea lice (Requirement 3.1.7) that “farms seeking certification to maintain on-farm lice levels at 0.1 mature female lice during and immediately prior to sensitive periods, particularly outmigration of wild juvenile salmon”. Mowi (formerly Marine Harvest) claims to be working towards “100 % ASC certification” (https://mowi.com/sustainability/aquaculture-stewardship-council/asc-dashboard/).

So, why should Scotland’s wild salmon and sea trout be accorded aless protection than that recommended by the ASC?

Domestically too, there is support for a strict sea lice ceiling. Scottish Natural Heritage (SNH) has recommended that a strict ceiling for on-farm sea lice levels should be set to protect wild salmonids in the Langavat Special Area for Conservation. In its response to the Screening and Scoping Exercise for the Taranaish fish farm on Loch Roag, SNH required that sea lice control should be based on

“a) The ability of the applicant to maintain average sea lice levels in line with our position paper Marine Aquaculture and Wild Salmonids, see Appendix 1:

0.1 adult female lice per fish between February and June inclusive

0.5 adult female lice per fish between July and January inclusive”.

So, why should Scotland’s wild salmon and sea trout now be accorded less protection than that already recommended by Scotland’s statutory nature conservation body?

Adaptive management, by itself, is not enough…

The Salmon Interactions Working Group’s recently published report proposes a system of adaptive management, but without any precautionary underpinning by a strict universally-applied sea lice ceiling.

Under the SIWG proposals, in effect, wild fish interests would have to prove conclusively that damage is being caused to wild salmon and sea trout before sea lice controls on nearby fish farms were tightened.

Adaptive management will be subject to disagreement between fish farmers and regulators over why wild fish had experienced sea lice infestations and it is likely (in the last resort) that there could be legal challenges from the industry.

Experts within Marine Scotland Science and the Crown Estate agree 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 established, and even then it will likely be the subject of dispute between fish farmers and regulators over the science.

Therefore, 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 for the foreseeable future. At best, adaptive management alone would, at least for several years, be no more potent in protecting wild fish than the current system. At worst, it will become mired in disputes over what wild fish monitoring is showing and why, leading to no effective control of fish farm production of sea lice.

Why should Scotland’s wild salmon and sea trout be accorded no more effective protection than is currently the case?

Current Scottish Government sea lice reporting levels are not enough

In a letter to S&TCS (June 2020), Cabinet Secretary Fergus Ewing signalled the Scottish Government’s woeful lack of ambition regarding the control of sea lice on farms. Referring to the current sea policy (which only relates to the health and welfare of the farmed fish), he stated that the intention is to enhance “the sea lice reporting process by reducing intervention levels” (currently 2 and 6 average adult female lice per fish – see Marine Scotland Topic Sheet Number 71 V3) “to 2 and 4 in 2021 – unless there is evidence to the contrary”, forgetting that the industry’s current Code of Good Practice already has nominal lice treatment advisory thresholds of 0.5 adult lice per fish (February to June) and 1.0 per fish (July to January).

In other words, farms will not even be required to notify the Fish Health Inspectorate (FHI) of sea lice numbers until the average number of female lice per fish reaches 2 at which point, theoretically, FHI is committed to “increased monitoring/surveillance”, although no other sanction is applied. That is a level fully 20 times the ASC limit during wild smolt runs.

Fergus Ewing’s stated objective amounts to confirmation that Scottish Government does not envisage currently that the future system of adaptive management being proposed will be underpinned by a strict universally-applied and precautionary sea lice ceiling.

S&TCS believes that it is imperative that any new regime includes a strict adult female sea lice ceiling applied to all fish farms, which must be 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, below which ceiling any adaptive management, based on wild fish monitoring, is then applied.

[1] See, for example, Friends of the Earth Limited, Re Judicial Review [2017] NICA 41

“37. Given the repeated finding that the operations are likely to have significant impact on the environment the decision maker cannot simply put in the balance the absence of evidence of harm…What has been disregarded … is that these operations are considered likely to have significant impact, that the nature and extent of that impact has not been established, that prior to the grant of permission is the requirement to establish that there will be no significant impact and that it is imperative that the precautionary principle be applied. What must be put in the balance is the absence of evidence that there is no harm. To approach the matter with a requirement for evidence of harm is the negation of the precautionary principle”.

Paul Knight reports on the 37^th 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.

Corin Smith writes,

"Contrary to what you may believe salmon farmers go to great lengths to protect Atlantic salmon smolts from the harm caused by sea lice. The problem is they only protect the smolts inside the salmon farms, not the wild ones on the outside."

Analysis combining multiple industry and government datasets reveals the low levels at which salmon farmers can, and do, successfully maintain sea lice to protect farmed salmon smolts.

The insight that follows comes with the following explanations and caveats.

Datasets from SEPA, Marine Scotland, Fish Health Inspectorate, Crown Estate Scotland and the Scottish Salmon Producers Organisation were all combined into a single proprietary database. The data covered the period 2018 and 2019. However, it is the case that all of the data is collected and reported by the salmon farming industry itself. There is no independent body which collects, verifies or audits any of the data. There is a lack of transparency with regard to operational methodologies, and therefore consistency of, sea lice count data. Where averages are used by the industry there is no transparency as to how these are derived. There is no information as to how any of these processes may have varied over time. The view we have of the industry is the one it currently permits us to see.

Sea lice counts are recorded by salmon farmers as often as daily and often at the individual pen level. This data is retained within the salmon farming corporations and extends back a period of perhaps decades in some cases.

Where average weekly sea lice numbers on salmon farms in Scotland breach thresholds outlined in The Regulation of Sea Lice in Scotland policy document, (currently 2.0 and 6.0 per farmed salmon and which refers only to a single life stage, gravid females, of a single species “Lepeophtheirus salmonis”) sea lice counts are reported to Marine Scotland. These reports are therefore sporadic, short lived and of little use for any form of regression analysis.

The Scottish Salmon Producers Organisation also receives sea lice count information from salmon farmers and publishes monthly sea lice averages for each salmon farm in Scotland. The mathematical basis for how the SSPO derives its averages is not published. The SSPO has been publishing this individual farm data since Jan 2018. The effect of using “averages of averages” is to remove a lot of potential volatility in the data.

By way of example Vacasay salmon farm in Loch Roag, reported to Marine Scotland the following weekly sea lice count data:

Week 23: 0, Week 24: “no data”, Week 25: 7.28, Week 26: 24.22

The SSPO monthly average recorded this as: 4.69

There are reasonable explanations for this seemingly implausible mathematical outcome, which reflect the possible use of weighted averages. Analysis of averages alone can be useful for deriving insight, but caution should be noted that they do not, apparently, account for any changes in scale. For example, two salmon farms may have the same average sea lice count, but one may be twice the size of the other. Analysis of absolute emissions is fundamental in assessing risk to wild fish populations. Absolute production/emission of sea lice from salmon farms is a function of an average sea lice number per fish and numbers of fish. Numbers of fish on salmon farms is not a figure which is recorded or reported in any publicly accessible dataset. The resulting abundance and location of salmon farm derived sea lice external to the farm is further dependent on a number of other factors including temperature, salinity, weather conditions and geography.

Clearly there are pros and cons to using a monthly “average of averages” approach, which depend on the intended purpose of the data. However, some useful insight can be derived, especially given the continuity of the dataset in comparison to anything else available. Hence, SSPO data forms the basis of the following insight.

The original proposition was that salmon farms do, in fact, maintain sea lice numbers at low levels, but only when farmed salmon smolts are present. It should be noted that a farmed salmon smolt may be 100gms or considerably larger. Wild salmon smolts are more likely to be between 50-80gms.

Even at lower levels, sea lice on smolts will result in lethal, and perhaps more significantly, sub lethal effects which impact the fish throughout the remainder of its life. In the case of farmed salmon, the effects of sea lice infestations may reduce growth rates and feed conversion, resulting in smaller more expensive to produce salmon. In wild smolts it may reduce the ability of the fish to survive migration, grow at the rate required to catch prey and/or impact fecundity. The immediate lethal effects of sea lice infestation on a smolt varies directly with its size.

The chart below (sea_lice_vs_length_production_cycle) plots the average sea lice count for all farms, for all months in 2018/19, against the stage of the production cycle the count was recorded. A straight average is used.

The simplest interpretation of this data is that sea lice levels are, in fact, effectively maintained at much lower levels in the early stages of a farmed salmon’s life in sea water than in later stages. Further, that there is a strong correlation between rising sea lice levels on salmon farms and the length of time fish have been in the sea water. It is of course the case that the longer a fish spends in sea water, the larger it will get. Length of production cycle is in effect a proxy for fish weight, a data point which is not publicly available.

For reference, seasonality of sea lice numbers on salmon farms was also examined. This showed a slight seasonal effect where sea lice levels were higher in September and October. Seasonal effects may be the result of environmental factors; sea temperatures are at their highest in these months and so sea lice reproduce more rapidly. However, it could also be influenced by operational reasons such as larger numbers of farms reaching maturity at this time, relative to other months, in preparation for seasonal trends associated with smoked salmon and Christmas. It is, however, clear that from a statistical perspective that correlation with stage of production cycle is by far and away the dominant factor in sea lice abundance on salmon farms.

The table below, shows us that the vast majority of salmon farms managed to maintain monthly average sea lice levels below 0.5 sea lice per farmed salmon for the first twelve months of the production cycle.

Out of a total of 2351 published counts for farms reporting their sea lice levels in the first twelve months of production, 1751 (74%) were at or below 0.5 sea lice per farmed salmon.

The outliers, particularly the figure of 16.68 reflect the fact that from time to time salmon farmers will transfer mature salmon from one farm, to an empty farm elsewhere, for fish health reasons. In the data this is recorded as being Month 1 of the production cycle. This issue occurs in a tiny number of cases.

It would clearly be helpful if salmon farming data indicated information such as fish numbers, fish weight and stage of production/lifecycle.

The chart below shows the same information.

Growth rates and stocking size of farmed salmon smolts in seawater varies according to different strategies used by the operator. However, assuming a smolt is stocked at 100gms, roughly six to nine months later it will weigh around 1kg. The same size as a small wild grilse on the west coast of Scotland.

On average, we see that salmon farmers maintain sea lice levels at 0.2 sea lice per farmed salmon for the first two months of the sea water phase, when the farmed smolt will grow on from 100gms. This rises to 0.4 in month 4 and by month 10, once the smolt has grown on to approximately 1kg, the average sea lice level has been allowed to more than triple, to 0.7 sea lice per farmed salmon.

When one examines the raw data for the first twelve months of the sea water phase it is the case that there is low degree of volatility in the counts from month to month on individual farms, and also when compared to farms across all operators. This would indicate a relatively high degree of control is being exerted on sea lice numbers by salmon farm operators.

When one introduces data from SEPA’s databases relating to the use of the two main chemicals used to prevent sea lice on salmon farms, a striking picture emerges.

Prima facie it could be said that where salmon farmers use chemicals to prevent sea lice occurring, they do so predominantly in the first twelve months of the production cycle. One could argue this is when smolts would be most adversely affected by sea lice and therefore have the greatest commercial impact on a salmon farm. Every sea louse on a farmed smolt reduces the profit that will be made from it as an adult, as a result of reduced health and growth performance for the rest of its life. As the fish increase in size the sea lice carrying capacity steadily increases. The apparent need for preventative chemical measures declines. As farmed salmon increase in size and age, so the financial impact of higher sea lice numbers declines. To the point where at the end of the production cycle the impacts of very high numbers of salmon farm sea lice on the commercial value of a farmed salmon are negligible, and likely far outweighed by the cost of maintaining them at the low levels present in the early stages of production.

That is of course a simple interpretation. The apparent lack of chemical use in later stages may reflect a transition to well-boat based sea lice strategies (physical and chemical) which can begin to be deployed once the farmed salmon are larger. Well-boat chemical use is not recorded in SEPA’s data set. However, it remains the case that any treatment strategies deployed demonstrably do not maintain sea lice numbers at the low levels that were achieved in the early stages of production.

One issue worth noting is an emerging trend toward stocking farmed smolts at much larger sizes, having been grown on in land-based facilities, which for obvious reasons have no sea lice issues. The rationale for the operator is clear. Doing so effectively eliminates the first year in sea water, a period that clearly requires expensive early stage chemical prophylactics. This strategy, however, presents a new and serious long-term risk for wild salmonids. Much of the discourse about sea lice impacts from salmon farms relates to shocking peak sea lice counts. While damaging and troubling these are relatively isolated.

The table below shows the frequency of monthly sea lice counts for all salmon farms, for all months in 2018 and 2019, aggregated by ranges. One can clearly see the vast majority of sea lice occurrence takes place in the lower ranges.

It is the ever-present background level of sea lice being emitted from salmon farms that should be of most concern in terms of wild fish conservation.

By effectively removing the first twelve months of the production cycle, all salmon farm production in Scotland would be late cycle all of the time, where much higher levels of sea lice are historically present on salmon farms. If 1kg smolts were stocked on salmon farms and salmon farmers adopted the same tolerable sea lice level strategy shown in the first chart, this would raise the average sea lice floor levels on salmon farms from 0.5 usually seen in the first twelve months, where wild fish have some hope of respite, to a new minimum average of 1.1. This could in effect more than double the minimum background sea lice levels present on salmon farms and being emitted into the environment.

Of course, the farmed fish would be in the water for less time, but this in no way changes the dynamics of sea lice ingress, incubation, proliferation and emission from open cage salmon farms in the late stages of production. Sea lice levels are, after all, a business decision. There’s no indication that salmon farmers would willingly commit additional capital and operational expenditure to reduce late cycle sea lice levels on salmon farms, below that which occurs now. While a shorter seawater phase would potentially benefit the salmon farming business model, it simply means the next batch of bigger farmed salmon arrive earlier in the sea, resulting in a greater constant intensity of salmon farm production.

On this basis shorter production cycles may be dramatically worse for wild salmon, and sea trout in particular, whose lifecycle is often entirely contained in a single location. This is an area which merits considerable investigation to quantify the risks to wild salmonids that a super-size smolt stocking policy on salmon farms could represent.

The Norwegian, Canadian and Faroese corporations that own 99% of salmon farms in Scotland see their potential profit in every farmed smolt. They recognise the harm that salmon farm sea lice will inflict on farmed smolts, and their profits, and so they go to great lengths and expense to protect their investment. It is unconscionable that salmon farmers do not accept an obligation to offer the same protection to Scotland’s wild Atlantic salmon smolts, from the same harm caused by the very same salmon farm sea lice, simply because they are on the other side of a net a few millimetres wide.

Corin Smith was previously commercial operations director at betfair.com with responsibility for insight and optimisation. Latterly establishing a data analysis consultancy serving FTSE and NASDAQ listed clients. He now consults for S&TC on communications and strategy.

Executive summary

Download full review here: HERE

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.

Scotland

Category: Scotland