reLAKSation no 1065

My view: This week Marine Scotland tweeted that the SEPA consultation on proposals for a new spatially-risk based assessment framework for regulating the interaction between sea lice from marine fish farms and wild Atlantic salmon has now closed. They also retweeted the original posting from SEPA from December last year. This includes the following statements about the consultation:

Protecting Scotland’s wild salmon ‘a national priority’ as protection zones and sea lice thresholds proposed by SEPA

Nearly 60% of salmon rivers across Scotland are in poor conservation status

The causes of poor conservation status are complex and believed to be due to a range of different factors other than a single cause

Sea lice from open pen salmon farms can pose a significant risk to wild salmon populations

Although it is only just over three months since SEPA posted these statements, I look at them now and can only wonder what were SEPA thinking? Don’t they recognise that even if the science they used to establish protection zones was absolutely correct, which it isn’t, the benefit to Scotland would be to protect approximately one percent of the total Scottish stock. If Scotland’s salmon are a national priority, then what is needed are measures that will protect the other 99% of Scotland’s salmon. Yet, the wild salmon strategy has shown that there isn’t a will to protect these fish because the key stakeholders are more interested in protecting their fisheries. At the moment, the only national recommendation to safeguard wild salmon seems to be to plant trees to prevent warming river temperatures. However, by the time these trees will be of a sufficient size to produce shade, the salmon stock will already be near extinction. There are also other concerns about this approach, which I will discuss in a future issue of reLAKSation.

Of course, SEPA did not develop this proposal for protecting wild salmon as it came from elsewhere and they are only acting on advice, but like everything connected with the conservation of wild salmon, all efforts are continually directed towards the control of aquaculture, whilst very little is being done about the complex range of factors that actually do affect the conservation of wild salmon.

I appreciate that the biggest risk to wild salmon comes from what happens to them at sea, but after fifty years of diminishing returns, we surely should have some idea as to what might be done to stop this decline. Unfortunately, many dismiss what happens at sea as being outside their abilities and so they focus on the factors that they may be able to influence. Unfortunately, it is not easy to simply knock down dams and other barriers, shoot predators or influence the weather which only leaves exploitation and salmon farming as factors that might be changed.

Exploitation is at the heart of the wild fish sector, so it is not for consideration by most stakeholders, which leaves salmon farming despite its minimal impacts. Focussing on salmon farming also deflects attention away from exploitation by rod and line. In the last issue of reLAKSation, I discussed the only bit of work commissioned to look at the impacts of rod and line fishing on wild stocks. This was a 3-year PhD study funded by Marine Scotland. The pressures document describes this as a project to look at “rod and line catch and release mortality”.

I have now seen the full PhD thesis rather than just the paper published from part of it. The one thing that jumped out at me was that all the fish used during the study were caught in a permanent fish trap on the River Blackwater in the Cromarty Firth during November and December 2018.

The Blackwater River feeds into the River Conon which has a fishing season running from 11th February to 30th September. This means that all the fish caught for this work on catch and release were caught outside the fishing season at a time when they were near spawning. Clearly the impacts on these fish could be very different compared to a fish caught in April. Surely, the work should have been focussed on the impacts, both short and long term, to fish caught during the fishing season, not after it.

The problem, as I have pointed out previously, is that that every fishery has a different fishing season and that nothing is standardised. The earliest the fishing season opens is January 11th and the last closure is the 30th of November. The fishing season on the Tweed, for example, lasts for a whole ten months leaving little time for the fish to undisturbed to spawn.

Unfortunately, the fish do get disturbed for while it is not possible to fish for salmon during December and January, fishing for Grayling is allowed. According to Alba Game fishing, their season runs from June 16th to 28th February with the prime season being November to mid-March.

The Tweed was in the news this week with both the BBC and the Border Telegraph reporting that the total catch of salmon from the Tweed was 5,862 fish which was well down on the 9,614 fish caught in 2020 but better than the 5,644 salmon caught in 2018.

The reasons for the decline this year have been cited as coronavirus restrictions and low water levels, however, it is unclear from the reports whether the low number of fish caught is simply due to there being less fish in the river. Certainly, restrictions on movement due to coronavirus were more stringent in 2020 so it might be expected that catches in 2021 should be higher than in 2020. What isn’t mentioned is that the Scottish Government have somewhat belatedly (compared to England and Wales) been recording angling effort. It should be therefore possible to compare the effort for both years to see whether Covid had an effect or not.

At the same time, when water is low, the fish tend to remain in the lower river, and it is the upper reaches that may not see them until the water conditions improve. It should be possible to identify whether any parts of the river had specifically low catches at times when the weather was good. Alternatively, could it simply be that returning salmon numbers in 2021 were insufficient to sustain a large catch?

The possibility that rivers such as the Tweed may see catches and thus breeding stock to fall to such levels that they are reclassified from a Grade One river to a Grade Two or even Grade Three is unlikely to have even been considered by the angling fraternity, but as SEPA claim that 60% of Scottish salmon rivers are now in a poor conservation status, the likelihood that the Tweed could lose its Grade One status is no longer unthinkable. As nothing much seems to have been done to reverse the declines, there is an increased chance that the number of rivers with a poor conservation status could easily increase. It is also worth remembering that the River Dee has imposed catch and release for the late twenty years and yet the stock has not improved.

In terms of salmon habitat less than 6% of rivers in the salmon farming area are in poor conservation status. Clearly, this is not down to salmon farming but as yet, SEPA do not appear to have recognised the lack of any connection.

SEPA are also wrong in suggesting that sea lice can pose a significant risk to wild salmon. I don’t know whether anyone from SEPA has actually read the scientific evidence cited in their consultation because it does not support the need for this proposed framework.

For example, the consultation states that a Scottish study has identified that a 12.5 cm salmon post smolt will travel through an 11 km protection zone in 24 hours. The consultation also states that the proposed exposure threshold is derived from a Norwegian study using sentinel cages. The fish were held in these cages for a total of 21 days. In addition, as the fish were held closely together there was added risk that if one fish became infested, the infestation could spread to the other fish rather than from the environment. How can the risk of infestation of fish held for 21 days realistically be used to determine the risk to a fish that probably spends less than a day swimming through areas that might, but more likely not, be a risk to being infested?

I will take a deeper look at some of the deficiencies in the SEPA proposal in future issues of reLAKSation


Traffic Lights: SEPA will now be busily reading the responses they received to their consultation. They will clearly have to differentiate between those, who like myself, question the validity of the science used to justify the proposals and the emotive claims from the angling side. At the end of their eleven-page submission, Salmon & Trout Conservation state that ‘opposition to open-net fish farming is a legitimate view held by an increasing number of what SEPA call its stakeholders and it’s a view that SEPA needs to take into account’. I would very much hope that SEPA bases any decision on real science, rather than the fact that S&TC don’t like salmon farming because their science is certainly questionable. For example, the only illustrations in the S&TC submission show the decline in sea tout catches from Loch Maree and the Ewe System, which they say were down to the local salmon farm. They then show the graph of sea trout catches from across all of Scotland which shows a similar decline but from areas that are completely free of salmon farming. Could it be that the decline of sea trout from Loch Maree is due to the same factors that have caused the decline across all of Scotland and salmon farms have had no role to play in this? Sadly, S&TC refuse to discuss the possibility.

I would also hope that SEPA look beyond Scotland and across the North Sea. The idea of protection zones was prompted by the introduction of the Norwegian Traffic Light System. SEPA should note that before they try to introduce a system in Scotland, the Traffic Light System has not gone well in Norway. The debate continues to rage on with Seafood Norway suggesting that what might have looked good on paper has proven to provide significant uncertainties in practice. They also say that there are weaknesses in all three pillars of the TLS. These are the database, the model and the expert assessment. Effectively, the whole system is flawed.

Seafood Norway have also expressed concern that having commissioned an international scientific review of the TLS, the Norwegian Government might consider the recommendations too complicated to implement. There is added concern that the inability to resolve the problems of the TLS might compromise Norway’s position as a leading seafood nation.

The commentary from Seafood Norway has prompted a response from industry players with suggestions as to how the TLS can be modified in terms of its assessment. I hold a different view. I believe that the only way that the TLS might be able to be made to work is if the groups who assess the risk are opened up to include a wide range of other experiences. The International Group made a similar suggestion, but I believe that it didn’t go far enough. The salmon farming industry needs a place at the table. They need to understand the rationale of any decision and have the ability to question and challenge without having to resort to taking the Government to court.

In addition, it must be a concern that most of the scientists who sit on these groups have also engaged in research that has been subsequently used in the development of the TLS. They clearly have a vested interest and cannot take an impartial view as to whether any restrictions are necessary or not.

The wild salmon debate in Scotland suffers exactly the same problem as in Norway. Anyone with scientific research or even just a view about the impacts or not of salmon farming on wild salmon should be prepared to stand up and argue or defend their case. The fact that many, including representatives of the wild fish sector, refuse to do so simply says to me that they are not confident of their position. As we know from the experience of social media, it is every easy to say anything from behind a screen or a closed door but how many have been willing to get out from behind that screen or open that door?


Experiment: It looks like British Columbia are heading towards the great salmon experiment. Most salmon farm licences are up for renewal and the industry is hoping that they be renewed for the next six years.  Opponents want the licences withdrawn and the farms scrapped. They blame salmon farming for the decline of wild salmon in the Fraser River. They argue that wild salmon have the best chance if they don’t have to navigate past open pen farms.

What opponents seem to ignore are wild salmon are in decline across the world, regardless of salmon farms are not. I personally do not believe that the Fraser River salmon stock will recover simply based on the presence or absence of salmon farms. However, British Columba have already removed some farms creating salmon free corridors. Surely, it makes sense for the Minister to evaluate what happens in these areas before making any major decisions about the future of salmon farming in BC. The likelihood is that BC may end up with no salmon, whether wild or farmed.