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reLAKSation no 1068

Blame game: Last week, Fisheries Management Scotland launched a series of films about the pressures facing wild salmon in Scotland. There is one long film of about 40 minutes and five shorts of between 11 and 17 minutes in length.

At the very end of the long film, FMS CEO Dr Alan Wells sums up the plight of wild salmon with the following words:

“We find ourselves at a crucial tipping point where we need to act urgently to save our wild salmon for future generations. Fisheries managers, fishery owners and anglers are doing their part and we are building real momentum for change working with our partners in the Missing Salmon Alliance. The Scottish Government has recognised the need to support this vital work. We now need urgent coordinated action from government and regulators, and we need industry and developers to step up to the plate and do more to ensure their activities do not harm our precious wild salmon.”

Dr Wells stresses the part that fisheries managers and owner as well as anglers are doing to save wild salmon and it is only necessary to look at social media to get a real flavour of their actions. Typical is a weekly report put out by the River Tay Salmon Fishery Board recently, rebranded as Tay Rivers ( For those readers who don’t have the time to click on this link, I have included the following screenshot.

It’s clearly business as usual with anglers out catching fish for their sport. Currently, the target is the threatened spring run and whilst it is illegal to kill these fish, some will undoubtedly die from poor handling. Even now, the fishery boards are happy to post photos of anglers who have failed to follow the advice on safe handling whilst taking a photo.

Having mentioned the River Tay Salmon Fishery Board, I would like to digress for a few lines. I recently attended the Tay Boards AGM which was advertised as open to all. There was much I could now discuss but I would like to mention just one thing. Seemingly, a member of the board has been suspended. No reason was given although there was discussion about the need to acquire the services of a forensic accountant. What caught my attention is that the board are applying to Marine Scotland for funds to pay for this work. I am not sure why the Scottish taxpayer should foot this bill. Surely it is bad enough that the Scottish taxpayer is helping pay to safeguard the future of wild salmon whilst the fisheries sector continues to kill what Dr Wells calls ‘our precious salmon’. The wild fish sector will tell you about the high level of catch and release now practiced in Scotland but yet in 2020 (the 2021 data is still not available and that includes salmon caught in January 2021) anglers caught and killed 3,018 wild salmon and 1,565 sea trout. These figures are probably low due to reduced angling effort resulting from Covid.

One of the shorter films is entitled: Enforcement: Crimes against salmon. The opening commentary states that salmon “are now on a path towards extinction, unless we take decisive action on several fronts. Fish poaching is a nationally recognised wildlife crime that poses a serious threat to our wild salmon. With wild salmon numbers at crisis point, the illegal removal of even a small number of fish can have a big impact.” This begs the question that if the illegal removal of even a small number of fish can have a big impact, then surely the legal removal of even the same number of fish would have an equally big impact. Putting aside the issue of legality, removal of any fish is surely going to impact on the future viability of stocks. Given that about 90% of fish are returned, why is there now any need to kill any fish for sport. None of those who claim to be interested in the conservation of wild salmon have yet to demand a total ban on killing any wild salmon. I suspect that this has more to do with protecting salmon fisheries than protecting wild salmon.

I would imagine that what Dr Wells means when he says that anglers are doing their bit to protect wild salmon is by engaging in catch and release. Yet, twenty years of catch and release on the River Dee has so far failed to halt the declines. Catch and release does not seem to be the answer, however, it does not seem to be a subject that FMS is keen to discuss.

The introduction of the longer film states that “Now in a little as a few decades, salmon have dwindled in numbers to near extinction because of human activity.” Dr Wells then follows stating that “Fisheries Management Scotland exists to help take care of our rivers and the fish and the fisheries that depend on them. Our members are the Scottish district salmon fishery boards and the fisheries trusts. Together with fishery owners and anglers, our members work to understand, protect and conserve our wild salmon”.

Yet, the fishery boards, trusts and owners as well as anglers have overseen fisheries management for many years and clearly they have failed to either understand, protect or conserve wild salmon because as the FMS film states salmon have dwindled in numbers to near extinction because of human activity. The film highlights the various pressures that wild salmon are exposed to but rather oddly fails to mention one aspect of human activity that has had a significant impact on numbers and that is legal exploitation such as angling. The film could conceivably be renamed ‘Lets blame everyone and anyone but ourselves’. It is easy to forget that since official records began in 1952 through to 2020, anglers have caught and killed 5.9 million wild fish, (5.936,183 to be exact) all having returned to Scottish rivers to breed and produce the next generation but were prevented from doing so. I am not suggesting that this is the only reason why salmon are in crisis, but FMS fail to acknowledge their impact too. Equally, they focus on impacts of human activity but ignore key factors at sea that have had the greatest impacts of all. Dr Wells simply dismisses these as being out with their control, yet surely killing wild fish is within their control and still every year wild salmon are being killed for sport.

The long film considers eleven different impacts including fish farming, predation, hatcheries, water quality, hydro. enforcement, marine developments, invasive species, barriers and habitats. If anyone would have asked me which would be featured first, I would have said salmon farming and of course it does. This is not unexpected since despite the fact that west coast salmon fisheries have typically accounted for 10% of total Scottish production, and that some wild fish organisations grudgingly acknowledge that other factors may be at play, salmon farming is still the wild fish sector’s bête noire. After all, they have been pursuing this narrative for thirty years, so why would they change now even if the evidence does not support their view.

In addition to the primary slot in the longer video, salmon farming and sea lice also feature in the shorter film: Monitoring – The Appliance of Science. Unfortunately, the film fails to address the science and falls back on the same tired view that finding sea lice on wild fish together with the awareness that there fewer fish returning to Scottish rivers must mean that the two are connected. Yet, the science tells us otherwise.

The film introduces us to Charlotte Middleton, Aquaculture Interactions Manager for FMS who tells us that sea lice from salmon farms can damage wild salmon and sea trout populations. Sadly, despite her job title, Charlotte has been unwilling to interact to discuss the issues whilst FMS, as an organisation, aren’t interested in hearing any other view of the science. In the film Charlotte continues that “west coast fisheries trusts have been monitoring sea lice on wild fish for many years. Sea lice on wild fish are not always a cause for concern however there are situations when things go badly wrong, and the resulting impacts can be devastating for our wild salmon and sea trout”. The film then features Lucy Ballantyne of Lochaber Fisheries Trust, whose views I have written about recently. I won’t repeat here what she says in the film except to say that the film includes a caption that states:

In June and July 2021, 79.1% of fish sampled at this site (N=341) had lice burdens that would be expected to result in mortality.

There are two fundamental flaws with this statement. The first is that the sample size is not representative of the population. As I have written previously, the data collected by Lucy and her fellow west coast trust biologists has been made available following an FOI request. The sample size is 64,884 fish and what is apparent from this data is that sea lice follow an aggregated distribution with most hosts carrying no lice and a few hosts carrying many. Lucy’s 341 fish are likely to be the few hosts with many lice and these are easier to catch than lice free healthy fish. Her sample is not representative. The accumulated data shows that 72% of fish sampled were totally free of lice. This is data that has been recorded by Lucy and her colleagues. Unfortunately, this data runs only up to 2019. More recent data has not been published.

The second flaw is that the risk of mortality is calculated from Taranger, which is known to be over-estimated. I have challenged Dr Taranger as to his estimation of risk compared to actual data showing aggregated distributions and not for the first time, he has not responded.

Knowledge of aggregated distributions is basic parasite biology, yet it seems that FMS isn’t willing to apply this science to their narrative.

There are many other aspects of these films that are worthy of discussion, and I may return to these in a future reLAKSation. However, there is one of the films that has left me puzzled and that is the one about the use of hatcheries.  The impression given is that hatcheries are not a good idea except where restocking is used in rivers where there is no or little natural reproduction. Yet, the hatcheries that do operate are all run by the salmon fishery boards, who are members of FMS! Clearly, it must be the fishery boards themselves who have actively damaged the integrity of wild fish stocks over many years.

Perhaps after all, FMS should look at the impacts of angling and of restocking the rivers, with what they consider to be inferior fish before they start to blame others for the decline of wild fish in Scottish rivers.

The FMS films are available to watch at:


FMS and SEPA: Fisheries Management Scotland have published their response to the SEPA consultation on sea lice. It is available on their website. It contains nothing other than the usual FMS aquaculture narrative that the framework should be strict as possible to ensure that every migrating wild salmon is protected from the impact of salmon farming, so anglers can then catch them for sport. However, there are three points which merit comment.

Firstly, FMS highlight that as well as migrating post smolts, SEPA should consider the risk to returning adult salmon upon the return to coastal waters. (This is distinct from the risk to the fish from being caught by rod and line and dragged around by the mouth, then landed and displayed out of the water for the obligatory photo.) FMS cite the example of the fish that they say were heavily impacted by sea lice in Loch Roag in 2018.  However, this is a classic example of seeing sea lice on a dead fish and then blaming the local farm. The reality was very different. A lack of freshwater meant that a large number of salmon were caught in the shallow sea pools at the entrance of the Blackwater. This also occurred in 2012 when the fishery landed a record catch as reported by the Herald newspaper. As in 2012, the local fishery exploited these fish and only stopped when the fish were in distress and started to die. The fish health directorate were called in but could not find a reason for the deaths but some of the fish were carrying numerous sea lice and of course the angling sector laid the blame with the lice. These returning fish were carrying a natural infestation of lice, so loved by anglers. Unfortunately, the high temperature meant that these lice bred whilst the fish were caught in the pool, but the presence of these lice was incidental, and the stress of low oxygen and high temperatures caused these deaths. It didn’t help that anglers were actively trying to catch the fish during these poor conditions.

FMS say that NatureScot have recognised the issue and instigated a Loch Roag Emergency Action Plan. This has not been publicised, but its primary objective should be to ban angling when fish are trapped in these sea pools. There could even be a case that the water should be artificially oxygenated in these conditions.

The second point is that FMS refer to some Special Areas of Conservation relating to freshwater pearl mussels. They say that mussels in some of these areas are totally dependent on sea trout and thus sea trout should be afforded the same protection as salmon because the framework will not protect freshwater pearl mussels in these rivers. The framework is not designed to protect freshwater pearl mussels but more importantly, FMS don’t seem to understand that the presence of fish is irrelevant to the SAC. Special Areas of Conservation were designated under the Habitats Directive and it’s the habitat and the habitat alone that is protected not the fish or the mussels. This is why anglers can continue to catch and kill salmon in all the SAC’s designated to protect salmon. Of course, it is ludicrous that it is possible to kill the species whose habitat is protected but FMS can’t have it both ways.

Finally, FMS refer to the time that smolts take to swim through salmon farming areas. They say that the times quoted are often minimum passage times and that the results from the west coast tracking project show that some fish can take much longer than the quoted times. One example they give is for the River Lochy which has a minimum passage time of 1,26 days with the slowest taking 18.87 days.

The West Coast Tracking Project is yet another example of the way science is misused. The project was intended to show migration routes of fish through the salmon farming areas. Using the results to demonstrate passage times is a totally different proposition. This is because the fish being monitored were not the fittest post smolts. This is because in order to be recognised by the acoustic receivers at sea, the signal the fish tag has to send out has to be quite powerful. This means that the tag has to be quite large. In fact, the tags are surgically inserted inside the fish. They then are expected to swim at speed for long distances with this large tag inside them, assuming that the incision is healed.

To illustrate the point, I compare the fish tag to a Watney’s Party Seven. This was a can of beer produced during the 1970s that contained seven pints (or about 4 litres) of beer. If a can of Party Seven was inserted in his chest, Dr Wells might have some difficultly swimming from the River Lochy to the open sea. Perhaps, if the intention was to measure speed of migration, then a different tag should be used, and different approach should be adopted.

Rather than this continued focus on salmon farming, FMS should examine their own impacts on wild fish and sort these out first.


Thorstad: One of my readers sent me a copy of a tweet posted by Dr Eva Thorstad of NINA. I am blocked by Dr Thorstad on Twitter and the only reason I can think why is because I have asked her questions she can’t answer.

The thread of her latest tweet begins when she posts details of a new paper that examined the stomach contents of young salmon and concluded that fish larvae are an important part of their diet. They also found that the numbers of consumed fish larvae declined from the period 1995-2004 to 2008 -2015.

Someone commented that the fish were starving in both in freshwater and at sea and commented that the number of hatching flies seen on Scottish rivers had declined over the last 40 years due to chemical pollution from agriculture and asked Dr Thorstad if similar observation had been made in Norway.

Her reply was that the biggest threat to Norwegian salmon comes from salmon farming not agriculture.

In addition, to this new paper, Dr Thorstad has recently co-authored a paper I have previously discussed that showed growth of salmon slowed after changes in Arctic water in 2005. She has also co-authored papers on the impacts of seismic guns.  She has been the lead author on a paper about reduced marine survival and climate change amongst many others.

When is Dr Thorstad going to start considering the possibility that salmon farming may not be the greatest threat to wild fish? I recently wrote to her about work that might suggest otherwise. Of course, she has not replied. I would argue that if Dr Thorstad as well as other Norwegian researchers are unwilling to defend their views, then perhaps they are not worth our consideration.

Both in Norway and Scotland, there is now a suggestion that the panel of those who judge the impacts of salmon farming should not rely on a small group of scientists, but should include a wide variety of expertise. This cannot come soon enough.