Consultation: The Scottish Environment Protection Agency’s monumental 2nd consultation on the sea lice risk framework has finally come to a close. Like many others I have spent the summer months putting together a response to the consultation document which was finally submitted a few days ago. I was very conscious of comments made by SEPA’s head of ecology, Peter Pollard whilst writing my response. Peter told the West Highland Free Press that ‘As Scotland’s environmental watchdog, SEPA’s new responsibilities on managing the risk to wild salmon and sea trout from sea lice offer an opportunity for a fresh, proportionate and evidence-based approach to working together on the shared challenge’.
Since the consultation was launched, SEPA’s partner, Marine Scotland has become the Marine Directorate and Marine Scotland Science has been renamed ‘Science, Evidence, Data and Digital’ changing the emphasis away from just science to science and evidence. This stresses the need for evidence rather than just pure science.
Whilst Scottish Ministers have determined that there is an impact from sea lice on wild fish. However, they may not have reached such a verdict if the Salmon Interactions Working Group had been willing to hear the evidence. Unfortunately, they refused to do so. This means that SEPA now have to decide whether it wants to hear the evidence instead or whether like SIWG choses to ignore what many years of data actually shows.
My response focuses just on the small section of the consultation document that looks at collecting and interpreting evidence. The salmon farming industry has now been operating along Scotland’s west coast for over forty years and analysis of the wild salmon populations over that time only leads to one conclusion, which is that salmon farming is not responsible for the decline of wild fish numbers. This is exactly what Peter Pollard told the Scottish Parliamentary REC Committee in 2020.
SEPA will say that wild fish stocks are now at such a low level that even if the risk framework saves a handful of fish, then that will help safeguard wild fish for the future. However, imposing this massive costly framework to safeguard a handful of salmon will be a rather pointless exercise if anglers can continue to catch and kill wild salmon for sport in adjacent rivers. I would suggest that if wild salmon are so threatened, then Scotland should follow Norway and Ireland’s example and close threatened rivers to fishing altogether.
There is absolute evidence of the harm to wild fish from angling as published by the Marine Directorate annually, but this evidence is totally ignored. It will be interesting to see what conclusions are drawn at the end of the 2023 fishing season because I understand catches might be at an all-time low, especially in areas where there is no salmon farming.
I very much suspect that the evidence showing salmon farming is not the problem for wild fish will continue to be ignored simply because it doesn’t fit into the narrative that the Marine Directorate together with wild fish interests have pursued for many years.
Countryfile: The news that BBC TV programme Countryfile was to broadcast another feature on salmon farming was met by some with a certain amount of trepidation. In the past, such programmes have been given over to extensive coverage of complaints from the wild fish sector that salmon farming is killing all the wild fish. Such claims were never supported by any evidence except images taken illicitly in salmon pens of one or two dead or dying fish. The salmon farming industry was given the opportunity to reply but this was usually highly edited to exclude any proper explanation.
The Xsphere (twitter) was certainly excited at the prospect of this programme but following its broadcast, there was an air of despondency. Far from promoting their cause, Countryfile presented an extremely balanced view of the challenges faced by salmon farming today. The response given by Matt Palmer of Wild Fish seems to have been edited down to something just over a soundbite. Wild Fish later complained on X that there had been no mention of the impacts of sea lice.
Clearly, Wild Fish had thought that the programme would focus on their claims of the impact of sea lice on wild fish because the following day they took out a full-page advert questioning the potential effectiveness of SEPA’s planned sea lice risk framework on saving Scotland’s wild salmon. The advert is such a mishmash that even those who are knowledgeable about the framework will have a hard time understanding its point, so I have no idea what the public will make of it. I suspect that their advert will just end up as tomorrow’s fish and chip wrapping. At the bottom of the advert, Wild Fish call on those in power to take robust action to protect wild fish before its too late. Perhaps those in power should start by banning fishing in Grade 3 rivers.
Interestingly, the advert includes a number of logos. These include James Merryweather’s Salmon Think Tank, Corin Smith’s Inside Salmon Feedlots, and a couple of members of the Coastal Communities Network, but not the network itself. Clearly, such alliances demonstrate how much on the fringe of the debate Wild Fish really are. None of this group, including Wild Fish, are willing to listen or debate the issues. They are simply out of touch.
Wild Fish followed this advert with an open letter to the Scottish Government published on their website repeating the same points. This included a comment from Corin Smith of Inside Scottish Salmon Feedlots claiming that the Scottish environment is being trashed but yet again providing no evidence. The letter ends by saying that the Fisheries Boards and Trusts were approached for support but declined. Seemingly, the wild fish sector is not in total agreement about their views of salmon farming.
In a news email, Wild Fish claim that it has been a busy week. They say that they now have published a report claiming the public are being misled by certification bodies and supermarkets. Of course, Wild Fish know much about misleading the public having renamed their organisation twice in recent years to make it sound more conservation based than the activities of their members would suggest which is sports fishing for threatened species. However, they are now trying to appeal to a younger age group in the hope of increasing membership and hence revenue. However, as their charity auction clearly illustrates, they are firmly entrenched within the angling sector.
The organisation has been busy recruiting younger staff, and their activity reflects the fact that they must be spending all their time at their desks, unlike their predecessors who spent all their time out fishing. Sadly, the new younger staff seem unable to move away from the policies of old although I am sure that in won’t be that long before they see that the organisation is flogging a dead horse, at least where salmon farming is concerned, and they will move on to seek a more fulfilling job elsewhere.
Escaped funding: Last week, the Cabinet Secretary for Rural Affairs announced that over £500,000 of funding would be provided by the Scottish Government to support the protection and recovery of wild salmon populations. This will be used to monitor adult wild salmon numbers; to sample juveniles and to assess any interbreeding between wild and farmed salmon.
Sadly, I hold out no hope that this funding will contribute in any way to the safeguarding of wild salmon populations. If this is how it is planned to safeguard wild salmon, then we might as well wave goodbye now.
The news of this funding was announced on a Marine Directorate blog posting. The blog makes no mention of how adult salmon are to be sampled except that it will provide information on numbers, size, sex and age of salmon returning to Scottish rivers. Previously, the Marine Directorate has stated that the only method of assessing stocks in many Scottish rivers is through the rod catch. Presumably anglers are now to be asked to obtain the required data from any fish they now catch. Is this now to be justification for the need to pursue salmon angling of even the most threatened stocks of salmon in Scotland?
Monitoring juveniles already takes place in Scotland, so this offers nothing new to what is already in progress.
Finally, the funding is to be used to assess any so-called genetic introgression that might occur in Scottish rivers. The fact that Scotch Government funding aimed at the protection and restoration of wild salmon is to be used to assess alleged genetic introgression illustrates the dire state of fisheries management in Scotland today. The wild fish sector is much more interested in deflecting attention towards salmon farming than examining the real reasons why salmon are in decline and considering realistic ways to reverse the declines.
The wild fish sector often misguidedly point to Norway in terms of alleged impacts of sea lice and escaped salmon. The Scientific Council for Salmon Management (VRL) place sea lice and escapes as the biggest threats to wild fish. They are so convinced about sea lice and escaped fish that they are not interested in hearing any evidence to the contrary.
Last month, the Managing Director at Seafood Norway wrote a commentary about genetic introgression for IntraFish in which he said that VRL still consider escapes to be the biggest threat to wild salmon despite the fact that fewer and fewer farmed salmon now escape and despite the fact that there are fewer and fewer escaped salmon in Norwegian rivers. Geir Ove Ystmark said that VRL’s wrong assessment of the threat to wild salmon means that important measures that could help safeguard the fish are being ignored. This is also true of salmon in Scotland.
Mr Ystmark makes that point I have also made that the presence of genetic markers do not mean that there is any change in the genetics of the fish. Genetic tests that the public can buy show historical markers, but which have no influence at all. Mr Ystmark says that his own genetic makeup includes some Greek origin despite his Nordic roots. The presence now of genetic markers from farmed salmon may mean that some interbreeding took place in the past or even more likely that the farmed salmon were used to restock the river. This certainly occurred in Scotland.
Mr Ystmark writes that whilst wanting to maintain genetic integrity of wild salmon (whatever that means), VRL is unable to answer the question as to whether escaped farmed salmon will reduce or compromise stocks of wild salmon in Norwegian rivers. As VRL have not answered this central question, Seafood Norway commissioned NOFIMA to make an assessment. Their findings are presented in NOFIMA report 5/2023 and suggest that even if 20% of the salmon in a river were farmed, there would be no reduction in the population size.
The question is why VRL considers escapes to be a high risk whilst NORFIMA do not. The reason is that VRL use a points system that is arbitrary and not robust. The points are distributed amongst eight criteria that do not reflect the real issues. As Mr Ystmark rightly points out, the problems for wild salmon occur at sea and this is where the emphasis should be placed. I suspect that the high seas are outside the experience of VRL which is why they continue to place the focus on salmon farming.
SIWG: It’s hard to believe that it is now over three years since the Salmon Interactions Working Group report was published. The wild salmon sector often refer to this report as a reminder that they expect measures to be taken against the salmon farming in order to protect wild salmon. What is not so often mentioned is that there was a commitment by the wild salmon sector to also take some actions. Three years on, it would seem that there has been little attempt on their part to address any of these commitments.
For example, the SIWG recommended that the system for collection and reporting of catch data should be reviewed. Perhaps, someone in some form of authority has reviewed this system but if they have there has been no report nor has anything changed. If anything, it has got worse since I have previously discussed Fisheries Management Scotland no longer publish data in their annual report, presumably because I pointed out the massive discrepancies between their catch data and that published by the Scottish Government.
The SIWG also recommended that Scottish Ministers invest in the appropriate infrastructure to collect, and report catch data in as close to real time as possible. The idea was that catch data should be published continuously in real time. I understand that the Marine Directorate did commission a company to look at such reporting but seemingly nothing happened. Certainly, there is no mention now of this process and it would appear that we are just as far from having real time reporting as we were at the time of SIWG with no prospect of such for next season. It seems that we must continue to wait for several months for any data to be published.
Finally, SIWG recommended that wild fish monitoring including lice count data should be published. Currently, the annual counts are published by FMS as a PDF which does not allow for easy analysis of the data. In addition, if sea lice counts on wild fish are so critical then why are they not published as soon as possible after they are collected? Publishing the counts for a full year renders it relatively meaningless.
Compared to the commitment made by the salmon farming sector, it seems like the wild sector had little to do but three years on, it appears no progress has been made.
Back in January 2022, the Scottish Government published their Wild Salmon Strategy, which was followed up earlier this year with its implementation plan. The plan recommended that an annual report on the status of salmon in Scotland be published annually. Such a report was published in 2013 and 2014 but really failed to provide any incisive insight into the state of salmon stocks.
The implementation plan also said that the wild sector should maintain regular monitoring using rod catches, fish counters, adult salmon sampling programme, sampling of juvenile salmon through the National Electrofishing Programme for Scotland (NEPS) and assessment of interbreeding of wild and escaped farmed salmon through the National Introgression Programme for Scotland (NIPS).
This is exactly the part of the plan that has been allocated £500,000 by the Scottish Government yet there is no mention of providing any real time data.
Perhaps, it is time for SIWG to be revisited, but this time to try to achieve what it really should have been – a proper discussion about the threats to wild salmon from salmon farming, rather than the hatchet job it was.