reLAKSation no 1087

One rule for one: In the last issue of reLAKSation, I mentioned that the Scottish Government had issued the proposed river conservation gradings for 2023 and that I had noticed that the River Ewe had been downgraded from a Grade One to a Grade Two river. This means that the river had a reduced likelihood of achieving the desired level of conservation. Yet, this downgrading had occurred after the farm in Loch Ewe had shut down. I was subsequently contacted by one reader who suggested that my claim was misleading because the fish caught in 2021, and used in the assessment, would have out-migrated whilst the farm was in operation. This is true but the rivers are not assessed by catch data alone. The farm might have been in operation, but it was being run down prior to closure. In addition, the lice counts were extremely low. Actually, I was being ironic because the reality is that the last four assessments, prior to the most recent one, assessed the river as being Grade One, even though the farm was fully productive.

The summary of the proposed changes for 2023 lists 29 rivers as Grade One, 31 as Grade Two and 113 as Grade Three. Yet, despite recent catches being the lowest on record, these latest grading are not the most stringent imposed. In 2018, there were 122 rivers classified as Grade Three, nine more that this year. That year, there were just 28 Grade one rivers and 21 rivers classified as Grade Two. Clearly, low catches and strict conservation limits do not go hand in hand.

The Scottish Government says that for the 2023 season, 113 out of 173 stocks have bene assessed to be in poor conservation status. They say this equates to 65% but this is extremely misleading. This suggests that the River Tay is the same as the smallest west coast river when they are not. In fact, the area of river catchment taken up by Grade Three rivers is a much smaller percentage of the total than the Scottish Government imply. I shall be calculating the actual percentages for the consultation and present them in a future issue of reLAKSation.

The detailed changes are that twenty river systems fall one grade including thirteen which now become mandatory catch and release (Grade Three). One river system in the Outer Hebrides rises a Grade from a Grade Three to a Grade Two. However, this summary from the Scottish Government does not tell the whole story.

Of the thirteen rivers that are now Grade Three, six are located outside the salmon farming area and seven within, although two are part of the same system. This means that effectively the areas with no salmon farms are suffering equally to that with salmon farms. More significantly, the summary fails to mention that one of the rivers has fallen two grades from a Grade One to a Grade Three. This river is located on the north coast in an area well away from salmon farms. It has regularly been suggested that north coast rivers have bucked the national trend, but clearly this is not the case.

This can be seen from some of the other changes, which have not been highlighted by the Scottish Government. In addition to the thirteen that have been reclassified as catch and release, another seven rivers have been downgraded from Grade One to Grade Two. Three of these are in the salmon farming area including the River Ewe whilst four are north-east coast rivers. The most notable of these is the River Helmsdale. This has been a Grade One river from the early days of river classification. The manager of the local fishery board is Sir Michael Wigan, who is known for his book ‘The Salmon – The extraordinary story of the King of fish’. In this he devotes many pages to the scourge of salmon farming. The book was published in 2013 and he wrote that wild salmon on the west coast are probably permanently compromised. It’s likely that he could never imagine that ten years later, his own river was also compromised, but clearly not by salmon farming. In the same way, the rivers on the west coast have not been compromised by the presence of salmon farms. Meanwhile, the only river in Scotland to see an improvement in its conservation grading is located in the heart of the salmon farming area.

Despite the implementation of these conservation measures, wild fish continue to be caught and killed from rivers within the Aquaculture Zone. In 2019, it was 703 fish, 560 fish in 2020 and 634 fish last year. Using available data, I estimate that had the 2023 proposals being implemented last year, just four fewer fish would have been caught and killed. It is very difficult to reconcile the fact that last year was the lowest catch on record and that some angling ‘conservation’ organisations have issued a call for action to safeguard the future of wild fish. It remains a puzzle the sector has not called for the imposition of mandatory catch and release across all of Scotland. Even more surprising, is that Scottish Government scientists have not issued a similar call. Instead, they have announced a consultation to request views on how voluntary catch and release can be increased.

The consultation states that due to the current state of Atlantic salmon populations, the Scottish Government is considering options with a view to improving salmon stocks including whether voluntary catch and release should be more widely encouraged throughout Scotland. This would mean that all rivers would be recommended to practice catch and release regardless of their conservation grading. The Scottish Government also hope to improve the survivability of fish caught and released by following best practice. Given the photos posted on fishery boards social media even this week, it seems that best practice is regularly ignored and the fact that the photos are published or endorsed by various fishery boards would suggest that there is a long way to go before best practice on catch and release is regularly followed. The following image was posted this week – note the blood on the fish:

The Scottish Government are also asking for views on mandatory catch and release if voluntary measures are unsuccessful. This would suggest that it could be a couple of years before mandatory catch and release would be imposed although this could require a change in legislation.

By comparison, measures to help protect wild fish from a perceived threat from salmon farming are to be introduced simply because Scottish Ministers have requested it. This is despite a clear message from the regulator, SEPA, who told the Scottish Parliament REC Committee that sea lice were not to blame for declines of wild fish. They also said that the concern is whether any additional pressure of sea lice on wild fish is now significant given that the wild stocks are at such low levels.

Yet, this concern about the low level of stocks is clearly not sufficiently significant to stop anglers killing an average 630 fish a year for sport at a time when salmon farmers are to be subjected to more stringent controls to protect the same fish. It seems very much that there is one rule for one sector and different one for another, even though the arbitrators of these decisions are the same Scottish Government department.

The problem for me is that the science supporting these decisions is in my opinion extremely selective and yet there seems a total unwillingness to instigate a wider discussion of the scientific evidence. I recently read an article in the Guardian newspaper concerning the badger cull taking place in England to prevent the spread of bovine TB. New research has shown that the cull is totally unnecessary, ‘yet because the English Government have painted themselves into a corner they now refuse to enter into any discussions.’ I believe that this exact description can be ascribed to the Scottish Government about the impacts of sea lice.

The big question is whether either measure, increased catch and release or the introduction of the sea lice risk framework will actually do anything to safeguard the future of wild salmon and sea trout. In my opinion, the answer is no.

Firstly, irrespective of what the mathematical models suggest, there is no clear link between salmon farming and the decline of wild fish. It is simply conjecture. In addition, the models have not been validated and thus there is no proof that what the models show actually happens in the real world. For example, the claims that there is a soup or clouds of sea lice larvae in the sea that spreads for many kilometres is simply unproven. By comparison, there is scientific evidence that such claims don’t happen, but such science has been ignored because it doesn’t fit the accepted narrative.

Currently, I am waiting for SEPA’s response to last year’s consultation to be published before I expand on this in detail. I have been assured that the SEPA document is to be published imminently and thus this will feature in a future issue of reLAKSation. However, as SEPA themselves accept, sea lice from salmon farms are not responsible for the declines so how can the imposition of more stringent controls make any difference?

More importantly, how many fish is the framework aiming to save. Will the framework be considered a success if one extra fish is able to return to breed? Or will it be two or three, or ten or twenty? However, whilst anglers are able to continue to kill over 600 wild fish a year from the rivers around salmon farms, saving one or twenty or even hundred fish would appear to defeat the purpose.

The real problem is that this risk assessment is simply deflecting attention away from the real causes of the declines.

Secondly, it is impossible to see how 100% catch and release, whether voluntary or mandatory will safeguard the future of wild fish stocks. I have previously discussed that the River Dee has been mandatory catch and release for over twenty years and yet catches have continued to decline as can be seen from this graph published in the FMS Annual Review.

Even more puzzling, the River Dee is still classified as a Grade One river. It makes no sense that a river with declining catches over so many years can still be of the highest conservation status. I appreciate that catches are not the only measure but when catches have declined over such a long period, common sense must suggest that the grading must be wrong. However, downgrading the river to even to the lowest Grade Three would make no difference because the river is already fully catch and release. How is imposing voluntary or mandatory catch and release going to change the fortunes of the River Dee?

The answer is should this consultation really be about catch and release or something more stringent such as found in Ireland and Norway. Perhaps when stocks are under significant threat, the only remedial measure that should be considered is to close the river to fishing completely. The problem in Scotland is that this is never going to happen until the Scottish Government decide whether it is salmon they want to safeguard or salmon fisheries. Currently, it seems that it is the fisheries that are winning out.

By coincidence, the consultation has prompted a strong response from former Spey Gillie Ian Gordon. Writing in his blog Speyonline. (

He is dismayed by the fact that we have reached the point where 100% catch and release is being considered. He too asks the question of the experts at Marine Scotland Science and Fisheries Management Scotland, why previous changes in legislation together with a move towards 90% catch and release over the past twenty years have done nothing to halt the decline so why would the introduction of 100% catch and release now make any difference? More significantly he suggests that such measures might have bought some time but crucially, what have the experts done with that time? Mr Gordon implies nothing.

I can understand his frustration. I have written previously that data from ICES and NASCO have shown that the number of salmon returning to Scottish rivers has been in decline since the early 1970s. That is over a period of fifty years. Do we know why these fish have not returned? According to Prince Charles, speaking at an Atlantic Salmon Trust dinner in 2017, the answer is no.

Ian Gordon suggests the problem is that for the last forty years, the time of worst decline, the sector has been run by experts who have consistently shunned any advice from those with any experience of the fish or the fisheries.  Instead, these experts have been spending lots of taxpayer’s money on ‘total nonsense’ rather than things that would make a difference. Alternatively, Mr Gordon asks whether this is just politics; creating jobs that produce nothing but more questions.

I am reminded of a £600,000 project to investigate sea lice impacts in Scotland. There are two papers from Norway and Ireland that show mortality of wild fish from sea lice to be about 1%. However, researchers in Scotland argue that the impact in Scotland could be different and thus embarked on a project which was effectively a copy of the previous two. The one big difference was to use wild smolts instead of hatchery rise done. Of course, their problem was collecting sufficient wild smolts from west coast rivers. It could have been argued that these smolts were so valuable that they should not have been used experimentally. The three-year project eventually failed because the size of sample sizes was so small that it proved impossible to obtain enough returning fish to make any assessment. Now Norway and Ireland are cited as examples of the sea lice experience, although interestingly, the Scottish Government’s summary of science does not include any reference to the iconic 2013 Irish study and the finding of just 1% mortality is masked by other work more favourable to the sea lice narrative.

Even Andrew Graham Stewart of Wild Fish Conservation has taken time out from his anti-salmon farming rants to question how funding is used. In a WFC blog, he asks whether there is a wild salmon crisis or not ( He highlights that the latest Scottish Government initiative to bring wild salmon back from crisis point involves a National Adult Sampling Plan which he says is simply counting fish and the development of a standardised fisheries management plan template. He suggests that these £500,000 funded projects will not result in even one more single smolt for years to come. Instead, Mr Graham Stewart wants to see more barriers removed, an end to water catchment transfers and more large-scale riparian tree planting effort.

My view is that these are simply sticking plasters over the problem. We really need to understand why fish are not returning to Scottish rivers because until we do, we will not know what remedial action is needed. Unfortunately, Mr Graham Stewart is partly to blame. His, and other organisations, have always placed the focus on salmon farming, claiming that this was an issue that could be addressed whilst issues at sea were beyond their capability. They have all failed to realise that they have all focussed attention on an issue which has had little impact on wild salmon numbers, whilst the real issues have gone ignored.

It’s not so surprising that none of them want to openly talk about the actual impacts of salmon farming on wild fish because it will show that the whole wild fish sector is culpable in the decline of wild fish.


BC Morton: This week BC Salmon Farmers issued a press release to rebut claims from anti-salmon farming campaigners that the current wild salmon returns are linked to the removal of salon farms –

This press release was met by a response from leading salmon farming critic Alexandra Morton that stated ‘OMG this is hilarious. Good Grief, do they hear themselves? Ridiculous.’

Well, I heard them and at the same time, I was dismayed by her response. I certainly don’t find such a serious subject to be hilarious and I certainly don’t appreciate that this is her response to any claims that do not agree with her very blinkered narrative.

In previous weeks I have presented her Salmon Coast Field Station data in various ways that show her own data does not support her claims. This time, I have presented the lice data that her Field Station reported in terms of the three main sample sites on the Broughton Archipelago. These are Burdwood, Glacier and Wicklow. I have combined all three data sets onto one graph.

I am not sure how much clearer this can be. There is a slight variation between sites since 2001 but essentially all are the same with the majority of fish sampled being either free of lice or carrying one or two – and these are not the mature adult stages that Ms Morton publishes pictures of to support her narrative. In fact, none of the fish sampled carry the lice burden portrayed in her images leaving some doubt as to how or where these infested fish originated.

Perhaps, if Ms Morton didn’t find any claims that don’t meet her narrative to be hilarious, then there could be a proper and open debate about the science. However, it seems that she prefers to only talk to people who wholeheartedly agree with her or are not sufficiently knowledgeable to challenge her claims. Perhaps she should revisit her data and publish the relevant information that demonstrate the link between salmon farming and wild fish declines.