Evidence(ly) not: In their consultation response, SEPA state that ‘we require suitably robust evidence that reduction in sea lice concentrations are required before we act. We expect it to take around five years to carry out modelling and monitoring work necessary to generate this evidence. If we obtain suitable evidence sooner, we will act on it without delay.’
Unfortunately, their claim about acting on suitable evidence has already been shown to be untrue. My own response to the consultation contained at least 55 pages of direct evidence concerning the interactions of salmon farms and wild fish catches and SEPA have shown absolutely no interest in this evidence. I can only assume that this is because it doesn’t support their perceived approach to sea lice regulation.
SEPA did however take a comment from my submission which states that ‘There is already seventy years of data available from Marine Scotland plus other sources of information to help assess the impacts of salmon farming on the wild fish populations in prioritised protection zones.’ Clearly SEPA don’t pay any attention to the detail because they classified Callander McDowell with the comments from environmental /wild fisheries group. It’s interesting that having made various submissions, participated in workshops and engaged in one-to-one sessions, that this is how I am perceived to the SEPA team.
Some of the evidence in my consultation response could have been more comprehensive, but any lack of detail is down to SEPA’s partner, the Marine Directorate, who refuse to publish more detailed catch data because it might invade the privacy of the fishery proprietors. Given that the proprietor’s representative organisation, Fisheries Management Scotland, is so keen to work alongside SEPA, I might have thought that the issue of privacy would take second place to safeguarding the future of wild salmon and they would happily allow the provision of such information. However, this would be extremely unlikely since FMS are still so fixated on blaming the salmon farming sector for any impacts on wild fish. Sadly, the wild fish sector is extremely protective of their data. Consequently, I have had to return to the Information Commissioner for a second time to question the Marine Directorate’s reluctance to provide more detailed information about catches of wild salmon over their claims of needing to protect the wild sector’s privacy.
Interestingly, both SEPA and FMS refer to the Salmon Interactions Working Group report which clearly states that the wild fish sector should publish any relevant catch assessment data from local rivers. The reality is that far from publishing more data, the wild fish sector has published less and has failed miserably to introduce real time or even weekly catch reports. It is worth remembering that in Report 01/15, Marine Scotland Science state: ‘Rod catches are the most comprehensive indicator of stock status in terms of temporal and geographic coverage and in many areas are the only information available.’ Nothing has changed since this was written so this statement is just as applicable today as it was when it was first written.
As part of the framework, SEPA want to establish a series of Wild Salmon Protection Zones along the whole length of the west coast down to the Scottish borders. I would argue that there is a legal case to be made that Wild Salmon Protection Zones should be exactly that and protect wild salmon from immediate entry into the zone right up to the riverbeds where they lay their eggs. Wild salmon should not be put at risk from any human activity that can be proved to have a negative impact. The most damaging of these is the impact from angling either directly or indirectly. The wild fish sector will no doubt claim that catch and release angling has minimal impact on wild fish, but Marine Scotland Science commissioned a PhD project to assess the mortality of fish caught and release that began in October 2018. The results have yet to be published. The project was listed in the Marien Scotland Science document on high level pressures affecting wild salmon. Clearly it makes no sense to have a Wild Salmon Protection Zone that affects one sector whilst allowing another sector continues to wreak havoc amongst the wild fish that enter it. It makes sense to restrict all activity, especially without the relevant evidence to allow any activities to continue.
I would argue that not only has SEPA’s representative, Peter Pollard made it clear that salmon farming is not responsible for the declines of wild fish, but the science shows the same too. In addition, historic evidence shows that the arrival of salmon farms is not linked to any wild fish declines. It is just the wild fish sector, SEPA, The Marine Directorate and Scottish Government simply seem unwilling to consider that the long-term narrative against salmon farming cannot be substantiated.
The SEPA consultation document highlighted eight Wild Salmon Protection Zones that have been prioritised. Two of them are extremely interesting – Loch a Siar in Harris and Loch Braccadale on Skye. This is because both zones contain just one salmon farm. These are Soay Sound on Harris and Portnalong on Skye. With just one farm within the WFPZ and both being distant from other farms, the impacts of the farm on wild fish stocks should be easier to identify.
According to SEPA, these farms, along with 16/17 others, have been identified as of the highest risk based on the initial screening assessment. This means that the level of exposure of wild salmon smolts to infective stage sea lice is expected to be more sensitive to increases of sea lice than on other farms in other relative risk categories. SEPA also say that these farms will use more of the capacity of the WSPZ to accommodate sea lice in any other relative risk category.
I have written previously about Model Land, as highlighted in the book Escape from Model Land by Erica Thompson. The book s subtitled ‘How mathematical models can lead us astray and what we can do about it’. I certainly believe that SEPA have been led astray by their models and I know that what I can do is simply keep demonstrating that the models do not reflect what is actually happening in the real world.
Portnalong
The Scotland Aquaculture map identifies the farm near Portnalong as Loch Harport which was established on the 7th August 1979 yet the CAR licence names the farm as Portnalong with the same code as SEPA uses.
Whilst this is the only farm in the area, there have been others which have since closed down. These include West Loch Braccadale which was established in August 1998, Tamer Island established in February 1992 and Portnalong Bay Loch Harport which was established in April 2002. Clearly by 2002, there were four farms potentially operating in the area and thus the pressure from sea lice must have been much greater then than now.
The key question is not that which SEPA might pose, such as asking about the sea lice counts on the existing farm but rather what has happened to wild salmon and sea trout in the area since the farms were first established. After all the main intention is to protect wild fish not to be a sea lice counter. Whilst the Marine Directorate and Fisheries Management Scotland could provide details of the numbers of salmon caught over this period, sadly, I am deprived of such data. Instead, I must rely on contemporary accounts from different commentators.
The first source is the book ‘The Salmon Rivers of Scotland’ by Mills & Graesser. Derek Mills was at one time considered to be one of the eminent experts on wild salmon in Scotland. The book was published in 1981 so after the establishment of the farm in Loch Harport in 1979. Mills & Graesser write that the Drynoch river is one of the most important rivers on Skye along with Kilmartin, Snizort and Varagill. However, they say that as the fish, which tend to be mainly grilse, do not appear until the end of July or early August, angling is not one of Skye’s main attractions. The Drynoch is not even available for public fishing as it is held in private hands.
The point about the Drynoch is that the rivers enter the sea at the head of Loch Harport and thus since 1979, migrating smolts have had to swim past the farm to reach the open sea. Interestingly, Mills & Graesser report that the biggest threat to wild salmon is from poaching, which is widespread.
The second source is that book Rivers and Lochs of Scotland – an angler’s complete guide written by the late Bruce Sandison and updated in 2014. Mr Sandison was an active campaigner against salmon farming writing columns about the impacts of salmon farming in the angling press and Private Eye. His guide is awash with references to the poor quality of the fishing due to salmon farming. The entry about the River Drynoch is therefore interesting because he does not refer to salmon farming at all in relation to the river. Instead he refers to the spate nature of the stream and hence requires rain to produce the best catch. Salmon are mostly grilse and average 5lb whilst sea trout average 1lb. The fishing is apparently owned by the Scottish Government and is leased to the Drynoch and Borline angling club.
There are a number of other rivers entering the sea in close proximity to the farm. These include the Sumardale, the Amar, the Caroy, the Roskhill and the Ose. Only the Ose is mentioned by Bruce Sandison and none of the others are mentioned in the Skye Fisheries Management Plan. Clearly these rivers, other than the Ose have any numbers of wild salmon or sea trout.
Bruce Sandison describes the Ose as a pleasant little spate stream which is eminently fishable after heavy rains. Salmon average 7lb and fish can be over 10lb whilst sea trout average 2lb. Permits available from the local bike shop.
However, what needs to be highlighted is that whist the Drynoch is classified as a Grade three river, the Ose is a Grade two and therefore can be exploited by anglers subject to local regulations. Certainly, three salmon were killed in the Snizort district in July 2019 but there is no information as from which river they were taken. The calculation made by the Marine Directorate estimating the abundance of juvenile salmon usually provides an indication of catches from specific rivers, but both the Drynoch and the Ose are linked to other rivers and thus it is impossible to tell whether any salmon were caught from these rivers over the past five years. How SEPA will be able to estimate whether there is an impact on wild salmon in the vicinity is unclear.
Whilst Mr Sandison does not provide any indication of the catches from these rivers and Marine Directorate are hanging onto the river specific data the only measure of catches currently available is the catch from the whole fishery district. The farm sits within the Snizort fishery district area that covers most of western and northwestern Skye.
The overall trend has been upwards to 2011 when national catches peaked. There is a dip from the early 1990s to early 2000s, but this is the same as occurred in many of the districts and whilst critics blame salmon farming the truth that anglers stopped visiting the area after the wild fish sector claimed that salmon was almost extinct in the west coast. After the early 2000s catches improved despite an expanding farming industry and continued claims by the wild fish sector of the impacts of sea lice.
For SEPA to suggest that Portnalong is a high-risk farm is clearly not supported by the historic data. Its not the farm that is proving risky, but the screening process adopted by SEPA. They clearly place far too much importance on their model which as yet has not even been validated. Why should the owners of Portnalong be penalised simply because SEPA are in too much of a rush to launch a framework which is not yet fit for purpose.
Soay Sound
According to the Scotland Aquaculture website, of which SEPA is part, Soay Sound was established on the 10th of May 1991.
There have previously been three farms in the area which are now closed. These are Ardhasaig I and II which were both established in January 1987. The third farm was West Loch Tarbert which was established in January 1989. The Soay Sound farm arrived slightly later in May 1991.
The farm is sited within the Fincastle fishery district of which the North Harris SAC is part. The fact that the farm is near a Special Area of Conservation is irrelevant because under the Habitats Directive, it is the Habitat that is the Special Area of Conservation not necessarily the salmon.
The whole area is managed as the North Harris Fishery, although some streams belonging to the fishery do not enter into the sea by the farm.
According to Mills & Graesser, there are three key rivers/streams that are in the proximity of the farm. These are the Scourst river. It has a reputation for large sea trout and on good days can produce salmon. The Halladale and the River Eaval both enter the sea at Amhuinnsuide Castle but it is the Eaval that is the largest river system on the estate. The river enters the sea after a steep fall. Although fish collect in the bay, the river is relatively unproductive which may because many fish damage themselves trying to get up the falls. It is also possible that the construction of a power station at the head of the river has disturbed the water flow. The Halladale can produce some salmon and sea trout depending on conditions.
Bruce Sandison refers to the Scourst river as being noted for sea trout rather than salmon, but water is needed to bring fish into the river. He describes the Eaval to be of limited interest because of the power station, whilst the Halladale may have the occasional sea trout. He makes no mention of the local salmon farm.
The Amhuinnsuidhe is also mentioned in the book – The Salmon Rivers of the North Highlands and the Outer Hebrides by Andrew Graham Stewart. Mr Graham Stewart is the leading critic of salmon farming, so it is inevitable that he mentions the sector. However, he first refers to the fact that salmon do congregate around the Eaval river mouth as did Mills & Graesser but they often fail to enter the river due to the height of the falls. Mr Graham Stewart charts the history of the estate back to the 1800s referring to a good day on the Scourst with four salmon and averaging 7lb and 20lb of sea trout, but this was in 1881.
More recently Mr Graham Stewart says that catches on the Voshimid and Ulladale systems which have had little exposure to the hazards of marine aquaculture with a catch of 222 salmon and 836 sea trout in 2003. By comparison he says that there is little doubt that numbers have declined since the mid-1980s due to the presence of farms in West Loch Tarbert. He cites changes in salmon catches as follows:
1983-85 255 salmon
1986 -90 244 salmon
1991-95 96 salmon
1996 -2000 105 salmon
2001-3 187 salmon
However, this appears to follow the pattern elsewhere with a dip in the 1990s as anglers chose to fish elsewhere after dire warnings of no fish from salmon farming critics such as Bruce Sandison and Andrew Graham Stewart. Unfortunately, I don’t have the access to catch data that Mr Graham Stewart was party to except the official data. However, according to the conservation grading data no salmon have been caught in the North Harris SAC fishery in the five years from 2018 to 2022.
Interestingly, catches for the fishery district which is not much more than the area covered by the North Harris Fishery shows healthy catches that have increased over the period that farming has been present in the area. In more recent years, the numbers caught have dropped in line with the collapse of catches across all of Scotland so the decline cannot be attributed to salmon farming.
There is no evidence to suggest that these two farms, Portnalong and Soay should be classified as high risk as clearly there is no link between their activities and the declines of wild fish. SEPA need to validate their model against real life fish before they use it as a regulatory tool.
Perhaps if SEPA were not so intent on launching the framework and actually took the time to listen to why it is not the way forward, they might find a form of regulation to which all parties agree rather than this car-crash of a framework. They need to remember that the point of the framework is to protect wild salmon, not to regulate sea lice.