Para 358: With the publication of the REC Committee report, the press has focused on the question of whether there should be a moratorium on salmon farming in Scotland or not. This has meant that they have missed the most critical conclusion of the entire inquiry. This is paragraph 358, which states:

“The Committee acknowledges that there are likely to be a range of factors that have contributed to the decline in wild salmon stocks over recent decades, and considers that it is possible sea lice attracted by the presence of salmon farms could be one. However, it also recognises that there is a lack of definitive scientific evidence on the issue.”

Clearly, no-one, including Salmon & Trout Conservation, submitted any definitive proof to the inquiry that sea lice from salmon farms are responsible for declines in wild salmonid fish on Scotland’s west coast. Any evidence is largely hearsay or circumstantial. There is an assumption that any declines are due to the presence of salmon farms, but as the Committee have indicated, there is a lack of definitive scientific evidence. It is now forty years since the collapse of the Loch Maree sea trout fishery was first blamed on salmon farming and yet after all this time, no-one has provided any evidence that salmon farms are to blame.

Why is this important?

In paragraph 318, the report states:

One of the key concerns expressed was that the presence of large numbers of salmon in farms attracted sea lice which in turn could increase infestation levels in wild salmon passing farms on their migratory routes. Indeed, it was concerns about the impact of sea lice on wild salmon raised in petition PE1598 which contributed to the Committee’s decision to undertake an aquaculture inquiry.”

In fact, it was only petition 1598 that triggered the decision to launch an inquiry into the salmon farming industry in Scotland. The petition, as submitted by Salmon & Trout Conservation, stated that it is increasingly ‘clear that sea lice produced on fish farms harm wild salmonids,’ yet the REC Committee have concluded that there is a lack of proof to support their claim. It could be argued that as the clams made in the petition are not proven, there shouldn’t have been the need for this inquiry.

Whilst it has yet to be definitively proven that sea lice are responsible for harming wild salmonids populations paragraph 333 states that as recently as “October 2018, Marine Scotland published a list of 12 high level pressures which impact on wild Atlantic salmon.” The first of these 12 high level pressures listed is exploitation.

An example of such exploitation is that anglers fishing the Delfur Fishery on the River Spey have caught and killed 2,025 wild salmon and sea trout in the seventeen years from 2000. These are all fish which had returned to freshwater to breed so the killing of the fish not only meant that the stock was reduced, but the potential for future stocks was also harmed. All these fish could have been caught and released to ensure the survival of the stock or not even fished at all.

The number of fish caught and killed at Delfur does not include the catch for 2018. Catch data for rod and line during 2018 will not be published until well into 2019 and even then, data of catches from individual fisheries are withheld. Despite being hundreds of miles from the nearest salmon farm, catches on the River Spey are in a downward spiral. According to the Sunday Post, no catches have been reported for the Upper Arndilly beat of the River Spey this year. Upper Arndilly is only a couple of miles up the river from the Delfur fishery.

Delfur is an interesting salmon fishery. According to FishPal, the fishing website, Delfur offers “approximately 2.5 miles of prime double bank fishing on the Lower Spey. The beat is well-known as one of the most productive, yet under-fished beats of the river with 11 named pools being fished by five rods.”

“Four full time ghillies are provided to assist rods where required and although in most instances’ anglers will find wading easy, each pool has a traditional cobble boat to allow fishing parties to cross over the pool or indeed fish them. There are also three fishing huts and a WC.  The beat has consistently proved to be one of the top beats on the Spey and annually produces about 10% of the catch of the entire river.”

According to the Herald newspaper in an article in September, Delfur Fishings has a market value of around £8.3 million and yields a gross annual income of up to £240,000. The Herald also reports that Sir Edward Mountain holds a 50% share of the Delfur Fishings. Sir Edward Mountain is also the convenor of the REC Committee.

As convenor of the REC Committee, Sir Edward not only oversaw the passage of the petition through the Committee but was instrumental in taking it to an inquiry. On June 21st, 2017, the Committee’s regular meeting included consideration of the petition. (http://www.parliament.scot/parliamentarybusiness/report.aspx?r=11034&i=100788#ScotParlOR)

The official record states:

The Convenor: “Item 2 is consideration of Petition PE1598 on protecting wild salmonids from sea lice from salmon farms”

” Would any members like to comment on the petition before I move on to make a suggestion about further action on it.”

After three comments’ the Convenor continued:

“I need to chastise myself for being remiss and not declaring an interest at the outset of the discussion as I have a wild fishery interest in my entry in the register of interests which members can look at.”

“I take the points that have been raised. I suggest that the committee might like to consider allowing the petition to continue and ….to look to carry out an inquiry into aquaculture probably early in 2018.”

“I seek the committee’s approval to carry that out. Are we agreed on that?”

The members indicated agreement.

The Convenor continued: “There is one other to bring to the committee’s attention. An opportunity has arisen to have some research carried out by SPICe in advance of our inquiry. I make it clear that I have been in conversation with the convenor of the ECCLR Committee to discuss how we can consider the issue together to ensure that we have the best possible impact.”

The best possible impact???

The best possible impact on the salmon farming industry? In our opinion, that is certainly how it seems to appear. If the convenor hoped to be portrayed as open-minded and impartial in relation to this inquiry, then perhaps it wasn’t the best choice of words. It is difficult to know, especially considering his strong links to the angling sector.

What we do know is that at the REC Committee’s previous meeting to discuss the petition on 14th December 2016 (http://www.parliament.scot/parliamentarybusiness/report.aspx?r=10695) the convenor had stated:

“Before we discuss the petition, I declare that I have an interest in a wild salmon fishery and have views on sea lice.”

We also know that the convenor had previously attended a meeting at Holyrood organised by the petitioners. On the 21st March 2017, Salmon & Trout Conservation launched their campaign to try to reinstate the Loch Maree sea trout fishery. Those MSP’s that attended the meeting were shown the premiere of a video – ‘The Demise of Loch Maree, once the world’s finest sea trout fishery.’  S&TC say that the video is a powerful and graphic illustration of how a poorly sited salmon farm can have a devastating impact on what was a previously prolific and entirely sustainable wild fishery.

Except, the catch data doesn’t show that at all and we should remember that the REC Committee have said that there is “a lack of definitive scientific evidence on this issue.”

Andrew Graham Stewart said at the time ‘It is surely no coincidence that catches in Loch Maree collapsed within a year of the start of salmon farming in the loch’. Actually, catches were already in decline before the farm was established but Mr Graham Stewart refuses to engage in discussion over this point.

S&TC have helpfully published a photo of some of those attending the meeting showing the convenor as well as another member of the REC Committee. Of all the MSPs in the photo only the convenor appears to have an interest in wild fisheries. This begs the question whether there is a closer link between the convenor and S&TC than just his attendance at this meeting might imply.  We recently wrote to the convenor to enquire whether he is a member of Salmon & Trout Conservation, given that, despite its name, it does actually represent angler’s interests. He responded saying that he has declared his interests as required to do in relation to relevant parliamentary business.

However, six months ago, the Daily Record reported that the ‘multi-millionaire landowner had agreed to lead the REC inquiry but had been accused of a massive conflict of interest. A spokesman for the SNP said that regardless of whether his interest in the angling sector is declared or not, people will rightly have doubts as to whether an MSP with a multi-million-pound stake in a salmon fishery on the Spey can objectively chair an inquiry into salmon farming in Scotland.’

The paper also reports that the River Spey Fishery Board, which represents the convenor’s interests as a proprietor on the Spey has submitted evidence to the inquiry ‘in which they expressly oppose development of fish farms.’

This year, whilst both the convenor and the River Spey Salmon Fishery Board have been immersing themselves in concerns about west coast salmon farms, their own river is in crisis.

The Press and Journal has just reported that catches of wild salmon from the River Spey have plummeted to an all time low. Just 3,100 fish were caught this season which is more than 1,000 fewer than the previous record low in 2014. The Spey Salmon Fishery Board has blamed a combination of fewer salmon returning to the river and the exceptionally hot summer this year. The Times newspaper has quoted the number of fish caught to illustrate the recent decline. This year, the number of rod-caught salmon was 3,178 down from 5,295 last year. In 2016, the number of fish caught was 7,632 whilst a decade ago the number was 11,545. Anglers believe that without an upturn in the coming seasons, the decline could result in the ‘death’ of the river.

However, we understand that this challenging situation for anglers does not extend to the west coast’s River Carron. Early reports suggest that catches of salmon, sea trout and finnock have all been good and although the river is located near one of the west coast’s largest aquaculture hubs, sea lice have been few and far between.

Based on this limited evidence, it could be suggested that the REC Committee should have been investigating the wild fish sector rather than aquaculture. The Press and Journal say that Ian Gordon, a ghillie, who has been fishing the Spey for over forty years, blamed ‘years of inaction’ for the decline. It could be suggested that actually, it is years of blaming the salmon farming industry rather than addressing the issues of the wild salmon sector as a whole. One of the complaints levelled at the salmon farming industry during the inquiry was that in recent years some mortality levels have increased to 20-25% and that action should be taken to reduce this to a more acceptable level. By comparison, 95% of wild salmon die before they can return to Scotland’s rivers. This applies to all Scottish rivers, not just those on the west coast. Back in the 1980’s, twenty percent of fish returned. and during this time, little was done to even consider the problem.

Meanwhile, the convenor has come up with suggestions as to what should be done about the salmon farming industry. According to the Herald, the convenor ‘ambushed’ his fellow committee members with a list of suggestions that should be included in the finished report. The paper claimed that the convenor ‘pushed’ for the precautionary principle to be applied until a new enforcement regime comes into place.

By coincidence, the committee recommended (recommendation no 40) 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 where-ever possible.”

It seems to us, at Callander McDowell that if there is sufficient concern about minimising the potential risk to wild salmon stocks (where-ever possible) then perhaps the precautionary approach should be extended to the wild fisheries sector. It seems complete madness that farms must significantly invest in a new regulatory regime to protect wild salmon, when the angling sector has been given the green light to kill what they want. A third of the rivers and fishery districts within the aquaculture zone have been classified for 2019 as Grade 1, which means that exploitation is considered sustainable, so no additional management action is required.

At the same, anglers who fish rivers on the east coast such as the Spey, are demanding action. This too should mean that a precautionary approach should apply to them too.

For wild fish angling, the precautionary approach is simple. There should be a mandatory catch and release policy across all Scottish rivers. Ideally, there should be a ban on recreational angling in line with the ban on netting, but this will never be agreed. Clearly, if the precautionary approach is considered necessary for salmon farming, then given the current situation, it should be applied to angling too, and as a matter of urgency.

Yet, it does seem that whilst the angling sector are keen to see more stringent controls placed on the salmon farming industry, they are somewhat reluctant for measures to be imposed on themselves. For example, the committee has recommended that compliance and reporting of sea lice data should be mandatory. By comparison, information of wild fish catches from both rivers and beats/fisheries is a bit spartan. It can take up to eighteen months for some data to be available and that only tends to be overall figures for the fishery district. We only know that the River Spey has suffered a decline in catches of wild salmon this year because the Fishery Board released the information to the press. Otherwise we would have to wait until well into 2019 before the data is officially published. This is typical of the disparity between what is required of the aquaculture industry and of the wild fish sector.

The SSPO told the Daily Record back in June that they expected the inquiry would be carried out impartially. It may have been so, but with a convenor who has direct interests in the angling sector, there will always be some uncertainty, especially as he had previously said that he has ‘views on sea lice’. It is our opinion that given his interests in the wild fishery sector, the convenor should have stepped aside from the outset and let the deputy convenor oversee any decision about the fate of the petition. That way, there would be no element of doubt.

Yet what is clearly not in doubt, is that the REC Committee have concluded that there is a lack of definitive evidence that salmon farming is responsible for the decline of wild fish along Scotland’s west coast.