reLAKSation no 1080

Clouds: Last week, Professor Russel Griggs went before the Scottish Parliament’s Rural Affairs, Islands and Natural Environment Committee to discuss his review of aquaculture regulation. In reporting the meeting, Fish Farming Expert, highlighted that Professor Griggs told the committee that the anti-voice is very well funded and resourced and their message out-shouts those with a different view on rural life.

In my opinion, this is the foundation as to why there is such mistrust and vitriol between some stakeholders. They have their narrative, and they are not interested in hearing anything else but their narrative, but more significantly, they don’t want others to hear anything but their narrative, which eventually comes to dominate any discussions. This was clearly apparent from some of the questions from the committee that were asked of Professor Griggs.

However, it is not just the antis that hold such a position. Professor Griggs also highlighted breakdowns between others. including parts of Government. In response to a question about communication or miscommunication, Professor Griggs used the example of SEPA (although I suspect that this was just a random choice) and said that SEPA might have a scientific view on part of the process whilst a farming company may have a different scientific view. He therefore suggested that what is needed is to take the two scientific views together and to find out which is right, and this is where we need a ‘party’ to do that. In the case of science Professor Griggs means an independent scientific body. But he also said that it is simply a matter of people just talking to each other and this is what in my view is missing. I can only speak for myself, but I have tried to engage in discussion with all those, like me, who are interested in safeguarding wild fish but instead I have met a total wall of silence.  I do understand why this is. They, especially the angling sector, have their long-established narrative that salmon farming has destroyed wild fish stocks and they are not interested in hearing anything that may undermine that view. Even though, as Professor Griggs pointed out, that there are reams of scientific papers, the reality is that there are no papers providing hard evidence to support their claims against salmon farming. It is all circumstantial or conjecture. I accept that others don’t think so, but that is exactly why people should be willing to sit down and discuss the science. Instead, those with opposing views use their ‘science’ to dominate the narrative both in the media and the communities, and from this, such mistrust develops.

Professor Griggs used the random example of SEPA in his response to the committee and I repeated it because this week I attended three 90 minutes workshops organised by SEPA to discuss aspects of the proposed risk framework about which SEPA held a consultation. I was surprised that SEPA had planned to run these workshops, because I would have hoped that prior to any discussion about how the framework might be instigated, the consultation response would have been published. From my perspective and the response, I gave to the consultation, there is no scientific justification for this framework. At the risk of repeating myself yet again, Peter Pollard, SEPA’s Head of Ecology told the November 2020 meeting of the Rural Economy Committee that:

“I will start with the big picture. Do we think that sea lice from farmed fish are responsible for the declines that we have seen over the decades in wild fish? No. There is a complex range of reasons, some of which are probably to do with high seas changes. The issue is whether the state of the populations at the moment can be affected by the added pressure of further sea lice as they migrate to sea. That is not to suggest that the declines over the past few decades are due to fish farming. The concern is whether the additional pressure of sea lice is now significant, as wild stocks are at such low levels.”

Given that salmon farms have been operating along the west coast for over forty years and that sea lice from these farms had not until 2020 been responsible for the declines of wild fish, it seems unlikely that the risk would increase after then. However, I appreciate that my feelings about such concerns are not sufficient, and that scientific evidence is required. I therefore turn to Jackson et al. 2013, who showed that the impact from sea lice on migrating wild salmon post smolts amounted to a mortality of around 1-2%. Although this was an enormously significant paper from Irish Government scientists involving over 352,000 smolts at eight locations in Ireland over nine years, the paper is not included in the Summary of Sea Lice Science as posted on the Scottish Government website. It appears it is not deemed relevant to this discussion. Seemingly it doesn’t fit into the accepted narrative yet, I shouldn’t be surprised. The Summary of the Science has, in my opinion, always summarised just selected parts of the science, whilst ignoring others. This would not be an issue if it were just the science, but as it is posted on the Scottish Government website it must be considered in terms of Government policy especially as its message is very clear. The summary states that:

‘The body of scientific information indicates that there is a risk that sea lice from aquaculture facilities negatively affect populations of salmon and sea trout on the west coast of Scotland.’

Regular readers of reLAKSation will know that I have contested this point ever since the first version of the summary appeared about seven or eight years ago. Unfortunately, MSS have never been willing to discuss this science at all. My last attempt in February this year prompted the response that ‘the summary lists peer-reviewed papers that comprise the specific literature referring to potential impacts of sea lice on wild salmonids. Inclusion of studies does not necessarily imply that they form part of Scottish Government’s policy position, but they are available for interested parties to consider any deliberations that they wish to make.’

Clearly, if these studies, as posted on the Scottish Government website are not being used to form Scottish Government policy, then what science is? The answer is apparently that from the Salmon Interactions Working Group. Yet, I already know that discussion of the science was avoided during the group meetings because it was considered too contentious. Which leaves the question begging as what to science promoted the recommendation of the spatial risk framework. This is a question that remains unanswered.

There is a secondary issue which I would highlight simply because it has been said to me that the peer-review system is of paramount importance and that if my work is to be discussed then it should be published as a peer reviewed paper. Having recently had two papers published, I can attest, that publication is no guarantee that the work will be discussed, especially if it doesn’t fit in the established narrative. However, the point I wanted to make is that whilst the summary of science states

‘Here, a summary of evidence from peer-reviewed literature is presented to inform assessment of the risk and effect of lice arising from salmon farms on Scottish wild salmonids.’

Actually, three of references provided are not peer-reviewed papers. Two are published as part of the Scottish Marine & Freshwater Science series, which clearly state that the contents have not been peer-reviewed.

The summary of science featured in the SEPA consultation document, and as their response has yet to be published it is still unknown how SEPA have reacted to the science. My response to the consultation focused on the lack of scientific evidence to justify the implementation of this framework. The fact that SEPA have progressed four and half hours of development meetings about monitoring, modelling, and regulation, would suggest that a lack of any real scientific evidence is not a barrier to taking the framework forward. They wouldn’t have held these meetings and outlined future meetings if they believed, like me (and others) that there is no scientific justification for this framework.

During the meetings, I offered a comment twice both of which I would like to repeat here. The first concerned the model that SEPA have already developed to predict the movement of sea lice larvae from farms. It is a really impressive model but there must be concern as to whether the model actually reflects what happens in the sea. Another participant referred to fish swimming through ‘clouds’ of larval lice. After the meeting, I asked what scientific evidence is there to prove that such clouds of lice exist. The answer was that if there are ‘x’ number of fish in the farm and each has ‘x’ lice and they breed and produce ‘x’ larvae, then cumulatively, billions of lice are being released into the sea. If this is the case, then they should be easy to measure. My question to SEPA asked about validation of the model in relation to what is actually happening in the sea. As yet, they have to work out how they are going to do this, but they must. There is no point having a model unless it reflects what is actually happening in the sea, not what everybody thinks is happening.

Much of the basis of the modelling comes from a paper by Murray and Moriaty (2021) yet even this model seemingly lacks any supporting data as to what is happening in the sea. One paper cited in this study, dated from 2004, found high concentrations of larval lice around a river mouth, which is of no surprise. However, they found low levels of lice elsewhere. Professor Griggs told the Parliamentary Committee that if there are gaps in the science, then work should be commissioned to fill in the gaps. Clearly, this is a very big gap in the data.

However, there is some science that can help fill the hole. A paper by Nelson et al. (2017) from Canada, measured the larval lice concentrations around the pens and from increasing distances away from the pens. They found that lice concentrations were low within 100 metres of the pens. Most larval lice were retained in the salmon pens because that’s where the potential hosts were. They concluded that sea lice originating from the salmon pens, remain close to them, forming a self-sustaining population. Unfortunately, Nelson et al. doesn’t seem to have been considered sufficiently relevant to be included in the summary of science, even though it clearly is. I am guessing that if MSS haven’t considered the work of Nelson and her colleagues, then SEPA haven’t either.

Finally, I would like to refer to how sea lice are monitored which formed the basis of my second comment. SEPA are considering a range of options to monitoring, but whether they will be effective is unclear. However, I have been further analysing the sea trout data that I received earlier this year. The data set runs from 1997 to 2019 and totals 21,629 fish. These fish were recorded after being sampled by the various west coast fisheries trusts. The work is commissioned by Marine Scotland Science via Fisheries Management Scotland. In 2008, the protocol for this sampling research was reviewed confirming that sampling should be carried out during May and June and that a minimum of 30 fish should be sampled. I have yet to find out how the number of 30 fish was actually decided, because in Norway, Taranger recommends at least 100 fish, and these should be caught well away from the shore.

During the twenty-three years of sampling by the fishery trusts, a total of 1,649 sample nettings were made (averaging 63 a year). Of these just 16% of the nettings caught a minimum of 30 fish as recommended by the protocol.  The average number of fish caught per netting was only 14 fish. Clearly this falls well short not only of the protocol but more importantly of providing any true representation of what is happening in the wider population. It’s not surprising with such unrepresentative sampling, that claims such as that made in the Sunday Times at the end of last year by Lucy Ballantyne of Lochaber Fisheries Trust that wild fish are suffering 85% mortality during migration. I believe that Lucy has now changed jobs and has gone to work for SEPA!

It should also be considered that some of this data has been used in various scientific papers which have helped conclude that salmon farming has a negative impact on wild fish, but as it is not used to help form Government policy, it must be OK then.