Manifestly Unreasonable: Last week, the Scottish Environment Protection Agency (SEPA) circulated an email advising key stakeholders that they are finalising documents for a second consultation on how their proposed spatially based risk assessment framework for sea lice would be implemented. They hope to launch the consultation before the end of May.
My own research of the science of sea lice infestation of wild fish clearly shows that sea lice from salmon farms are not responsible for the decline in wild salmon and sea trout stocks. As I have repeatedly highlighted, SEPA even agree on this point, which makes the implementation of this risk framework even more puzzling. The framework is not going to save many fish and certainly will not help stocks of wild fish recover. The framework is just an exercise to help deflect attention away from the inability of the Scottish Government to safeguard wild fish stocks for the future.
Its important to highlight that this framework is based on a model not on evidence. Just because it predicts that larval sea lice will be present in certain areas does not mean that they are there. The recent SPILLS project was supposed to demonstrate that larval sea lice were present in the water body. It did not. The SPILLS report concluded that just because they didn’t find larval sea lice, does not mean that they are not there. I would disagree. The SPILLS project didn’t find sea lice because they are not there.
Wild Fish Conservation recently published a report about sea lice in which they said that they estimate that two billion sea lice emanate from a single farm in a single week. There are at least two hundred farming sites in Scotland so worse case, there are 400 billion sea lice entering the seas around Scotland every week. SEPA and Marine Scotland Science (MSS) have developed models that predict exactly how these sea lice disperse from salmon farms, especially in the test areas around Loch Linnhe, Shuna.
There are five farms operating in the area around Shuna. That equates to ten billion lice entering the local waterbody every week and yet the SPILLS team struggled to find any. MSS have produced an animation of where the lice are expected to be dispersed that runs from 1st April to October 30th, 2021. This can be seen at: https://www.youtube.com/watch?v=MD_cRMySYow . If the larval lice cannot be found where they are predicted to be then surely the model is wrong. If that is the case, then how can the salmon farming industry trust that the models that form the basis of the risk assessed framework?
There is a lot riding on these models, but as I have pointed out previously, they are just models. I prefer to look at the actual evidence and see whether or not the presence of salmon farms have had a negative impact on wild fish stocks over many years.
MSS have also used observational data in their assessment of the impacts of sea lice on wild fish. Two papers they cite use rod catch data to determine whether salmon farming have impacted wild fish even though MSS have contradicted themselves in another document by saying that rod catch data cannot be used in this way.
The first paper argues that catches of wild salmon declined on the west coast relative to elsewhere after the late 1980s, however, the authors stressed that this did not prove a causative link with aquaculture (so why is the paper even cited). The second paper offers one graph of rod catch data comparing east (black) and west coasts (blue) with the growth of the salmon farming industry (red). Yet, no matter how I look at this graph, I cannot see how salmon farming can be implicated in the declines. Perhaps someone from MSS might like to explain this graph to me.
However, there is a problem with looking at catch data across the whole region and this is the inability to link the arrival of named farms with changes in local stock abundance. Until now, I have analysed the rod catch data from the 60 individual fishery districts that cover the west coast. This provides a much better picture of the interaction, or lack of interaction of salmon farming and wild fish than across the whole region. The trouble with using fishery district data is that in some cases, there are multiple farms and multiple rivers in a district. However, there are other districts, such as the Ewe, where the salmon farm interacted with just one river. As I have pointed out previously, salmon catches from the River Ewe continued to increase after the arrival of salmon farming to Loch Ewe. This somewhat contradicts MSS’s view that there is a risk that sea lice from salmon farms negatively affect wild fish stocks on the west coast.
Of course, rather than use fishery district catch data, it would be more preferable to use catch data from named rivers, but such data has never been made available. This is to protect the privacy of river proprietors. However, since 2016, MSS have been publishing river catch data for some rivers as part of the process of grading rivers for salmon conservation purposes. This has set a precedent for making such information available and consequently, I have since requested catch data for some rivers.
Yet, the availability of river catch data has been a subject of dispute between MSS and me. Data prior to 1986 has never been digitalised and MSS claim that it involves too much work to supply it now. I have suggested that this could easily be undertaken by a student, but MSS do not seem interested. I would argue that this historic catch data is a valuable resource which can be used to assess the changing stock status of many west coast rivers, but the reality is that as MSS have subsequently admitted, they have never analysed such data.
To date, I have managed to obtain historic catch data from four small rivers located around the SPILLS project area. However, with the prospect of the SEPA consultation ahead, I requested the data from the 29 rivers around the two key areas analysed by both MSS (Loch Linnhe) and SEPA (Loch Fyne). I want to see whether there is any link between the arrival of named farms and local rivers.
In response, MSS have said that I am being ‘Manifestly Unreasonable’ by requesting so much data, but I would argue that it is MSS who are being ‘Manifestly Unreasonable’ because they are preventing me from providing a full response to the SEPA consultation. It might also be suggested that as MSS have formulated the policy for this framework, they are placing obstacles in my way to this consultation.
MSS have since reviewed my request and have concluded that the data I have requested is beyond their remit, so I have referred the matter to the Scottish Information Commissioner.
I would have thought that it should not be left to me to want to analyse this data. MSS collect this data on an annual basis, surely, they should be looking at this data in detail, not just in relation to salmon farming but to understand what is happening to stocks of wild salmon and sea trout. However, as the reply from the MSS investigation clearly states: “Marine Scotland Science does not use individual river catch data for any research or monitoring purpose.”
Science review: The Scottish Science Advisory Council (SSAC) recently published their report into the use of science and evidence in the sustainable development of Scottish Aquaculture. The SSAC had been invited by the Cabinet Secretary to examine the current use and communication of science and scientific advice relating to the aquaculture industry. This followed major concerns expressed in the Griggs report that trust and transparency was being harmed due to differing interpretations of science and evidence.
I am not convinced that this new report will help address these concerns. After all, how can differing interpretations of the science and evidence be addressed when one side refuses to discuss them. I don’t see how the report’s recommendations will help. The report suggests that there should be an annual Scotland wide multistakeholder discussion but clearly any discussion should take place more regularly than once a year.
The major area of concern currently is the planned sea lice risk framework. In my view, it is not enough that SEPA run a consultation. Equally, SEPA’s workshops are too narrow and restrictive. What is needed is a much wider discussion and this should begin with a mini- conference in which all interested parties are able to present their views on the science, not just from those whose science forms the basis for the framework. This would be followed by a major discussion on the proposals and whether or not further science is required before any of these proposals are implemented.
Selfish: Dr Keith Williams, director of Kyle of Sutherland Fisheries recently wrote a column for the Northern Times in which he stated that anglers concern over dwindling fish stocks is sincere and not for selfish reasons. He wrote that he had been kindly invited to fish the River Naver, a river that he had been on his wish list for a long time. The weather was not so kind to him, and he failed to make any contact with a fish. He said that this was not a problem as people go fishing for a whole host of reasons beyond the obvious desire to catch and land a fish.
He points out that anglers are one group of several who now highlight the poor water quality of many rivers and lakes and how this could affect the state of local fish stocks. He mentions a recent article in the Times newspaper which discussed the decline of Arctic charr in Lake Windermere in England’s Lake District. He says that a number of the comments made by readers of the article decried that anglers were still allowed to fish for the species in the lake. The implication was that anglers only wanted measures to be taken against polluters so stocks would improve so that they could catch and eat more.
Dr Williams writes that everyone is entitled to their own views but in his opinion many of the responses were highly simplistic and failed to understand that the concerns expressed by the fisheries were sincere. He added that he suspected many traditional charr fisheries would wish to see stocks improve irrespective of whether they continue to fish for them or not.
I have read all 86 comments written in response to this article and I didn’t get the same message as Dr Williams. Most comments were about the pollution entering the lake from both human and agricultural sources. There were a few comments from anglers bemoaning the lack of fish, mainly salmon in Scotland and these focused on the lack of predator control and the uncontrolled expansion of foreign owned salmon farms. There seemed to be little concern about the state of the Arctic charr stock in Lake Windermere at all. It was all about angling. This can be summed up by one comment: A salmon caught at sea or in a poacher’s net is only worth the face value (let’s say 10 quid a pound). A salmon caught by an angler is worth thousands to the local economy.
Angling appears more important than anything else including the fish especially as a salmon left in the river has no commercial value at all.