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reLAKSation no 1137

Question? The Marine Directorate has just launched a consultation on the proposed river gradings for 2024. These are changed little from the gradings that are currently imposed. The detailed changes according to the consultation paper are that seven river systems have risen rise one grade from 2023 year including four that will no longer require mandatory catch and release. These include:

Laxdale and Blackwater (Lewis)

Laxford and Gleann Dubh

Lussa River (Jura)

Soval Estate

My question is that all these river systems fall within the Aquaculture Zone and four are closely associated with salmon farms. The other three river systems have salmon farms located within 10km.

My question is how can this be? How can rivers show such improvement in stock when they are in close vicinity to active salmon farms which according to the wild fish lobby spew out billions of sea lice killing all the wild fish they encounter? Seemingly, the sea lice narrative promoted by the wild fish lobby could well be flawed, however I don’t expect to hear any explanation any time soon from the wild fish sector, as to why these river systems have shown improvement?

In addition, four river systems fall one grade including three rivers which will become mandatory catch and release. These are:

Laggan and Sorn

Urr Water

Varragill River

Three of these river systems fall within the Aquaculture Zone, but analysis of the information provided suggests that these changes have little to do with the presence of aquaculture.

I had initially written that I would look at these proposed changes in more detail in a future reLAKSation but then I took a closer look at the table provided to illustrate the net effect of the various changes.

The proposed changes mean that the number of grade one rivers increases from 29 to 31. Grade two rivers change from 31 to 30 and the grade three rivers from 113 to 112. This would men that grade one rivers have increased by 2 in number whilst the other two grades lose one each. These changes don’t seem to marry up with the claim that seven rivers have increased their grade, whilst four have fallen a grade.

I have had to go through the whole list of 173 rivers/districts to confirm that the seven of the river systems have improved from grade 3 to a grade 2, whilst four have fallen from a grade 2 to a grade 3.

What the consultation paper has ignored is that the River Beauly near Inverness has also been downgraded from a grade 1 to a grade 2 river, whilst another three river systems have had their grading increased from a grade 2 to a grade 1. These are the Helmsdale on the northeast coast and the River Blackwater, part of the Loch Roag system and the River Leven near Fort William. The last two river systems are both to be found in the heart of the Aquaculture Zone.

The River Blackwater is particularly of interest because back in 2018, salmon farms in Loch Roag were being accused of causing significant mortality of returning salmon to the Blackwater that year through infestations of sea lice. (

It seems that despite the continued presence of these farms, the River Blackwater has elevated it grading to grade 1 status, which allows anglers to kill any fish they catch, subject to local regulations.  Five years on there has not been any further problem reported in the river even though the farms are all still active. This might be due to the fact that the real problem was that the fish had been caught in warm sea pools, where they became stressed and susceptible to the secondary issues that caused their deaths. Unfortunately, the wild fish lobby are all to quick to blame salmon farms for any problems as happened in 2018.

It’s a puzzle why these new proposed grade one rivers are not mentioned in the consultation document. Could it be that this news is not compatible with the forthcoming proposed sea lice risk framework?

It’s worth pointing out that 11 out of the 31 grade one rivers are located within the Aquaculture Zone despite the area only producing less than 10% of the national catch.

Finally, the consultation states that 112 out of 173 stocks (65%) have been assessed to be in poor conservation status. This is just nonsense. How can the Marine Directorate compare Mhor a’ Ghlinne Ruaidh and Geisiadar in the Outer Hebrides with an area of 17,000 m2 to the Tweed of size 16,187,000 m2 and say that they count the same. These 173 stocks are simply not comparable. A few years ago, I calculated the contribution of grade 3 rivers in terms of conservation, and it was if I remember correctly less than 20%, not 65%. The reality is that Scottish rivers are healthier than these conservation measures imply. That’s not to say that salmon stocks are threatened because they are. It is just the emphasis is being put totally in the wrong place.


Hiding behind celebrity: The Daily Record has said that the ‘Undertones’ frontman, Feargal Sharkey has hit out at the £600 million salmon farming sector as a ‘treacherous industry’ claiming it has contributed to falling wild fish stocks.

He told the newspaper that it is a complete fallacy to suggest that farmed salmon does not impact, and has not impacted, on populations of wild salmon in Scotland or Ireland. He said that “it clearly, blatantly, has – and actually, the farming industry is beginning to sound awfully like tobacco companies back in the 1960s saying ‘nothing to see here, we’re not doing any damage’.”

Sadly, whilst Mr Sharkey is keen to make these accusations, he hides behind his celebrity ensuring that those who he accuses have no way of discussing the issues with him. In my opinion, Mr Sharkey knows nothing about salmon farming or whether it impacts on wild fish or not. Instead, he relies on those in the organisation of which he is vice-president to provide him with a narrative, that they are just as unwilling to discuss.

If Mr Sharkey, or in fact those at Wild Fish formerly Salmon & Trout Association, believe that salmon farming impacts on wild fish perhaps, they might like to provide some evidence of their claims.  Instead, as the article in the Daily Record shows, they simply highlight salmon mortalities of farmed salmon. However, Mr Sharkey or Wild Fish are equally unable to demonstrate a link between mortalities on farm and declining wild salmon numbers, which is why Mr Sharkey is happy to talk to the press but will not make these claims direct to the industry he accuses. I know that in the past the salmon farming sector has invited the Salmon & Trout Association, or whatever other name they care to use, to meet but they have refused to do so. Surely, if they really cared about safeguarding the future of wild salmon and sea trout, they would be willing to talk to everyone and anyone to help stop these declines, but they won’t. I suspect that it is because they are reluctant to talk to people who actually might know more about the issues that they do.

Mr Sharkey accuses the industry of being like the tobacco industry of old trying to suggest that they don’t do any harm. He will say this regardless of whatever evidence the salmon industry can put forward. He is simply not interested in hearing the other side of the story. As I have said, if Mr Sharkey believe that wild salmon declines are due to the impacts of salmon farming then perhaps, he would like to provide the evidence to support his claims. I have seen nothing from Mr Sharkey or Wild Fish to help their case.

The first step in safeguarding wild salmon is to talk and I challenge Mr Sharkey to do so. Stop hiding behind your celebrity to make accusations and why not become the catalyst to actually help protect wild salmon.


Ireland: Mr Sharkey has alluded to the fact that the salmon farming sector in Ireland is also responsible for the decline of wild salmon there. The Irish Times has reported that the Wild Salmon and Sea Trout Statistics Report for 2022 “clearly shows anglers and the authorised commercial sector are making efforts to restore Atlantic salmon back to a sustainable plateau. Last year anglers released 54 per cent of their catch”.

That means that 46% of the catch were caught and killed. In total, the number of salmon caught by all methods (commercial and angling including catch and release) stood at 26,715 salmon and 2,082 sea trout. This means that 12,289 salmon were killed in Ireland in 2022. This compares with 1,936 salmon killed by anglers and netsmen in Scottish waters.

However, whilst killing of salmon in Irish waters is much greater than from Scottish rivers, their approach to conservation is more targeted than in Scotland. Of the 147 salmon rivers in Ireland, 48 are deemed to be fully open to fishing with 33 open for catch and release only, while 66 continue to be closed to fishing because stocks are considered to be too low to be exploited. While 48 rivers are fully open, only five rivers in four counties accounted for 53 per cent of the salmon in 2022. 18% on the Moy, 16.1% on Blackwater (Lismore) 7.3% on the River Laune, 5.89% on the Corrib and 5.4% on the Lower Lee.

The Head of Operations at Inland Fisheries Ireland said that wild salmon and sea trout continue to face numerous risks including climate change, water pollution and illegal fishing. Seemingly, IFI don’t agree with Mr Sharkey that salmon farming is a major cause of the problems for wild salmon.


Anglers speak: Fisheries Management Scotland have Tweeted that their film series on the plight of wild salmon have accumulated 36,000 views to date since they were posted about a year ago. These are available to watch on the FMS You Tube channel ( Not all the six videos have received equal viewing which makes an interesting reflection of what is of interest to the angling community. Five of the videos focus on one aspect of the pressures affecting wild salmon. The sixth is a summary of the others.

The specialist subject video with the most views is the one titled – ‘Enforcement: Crimes Against Salmon’ with 13,000 views. This is about illegal fishing and how the wild fish sector deal with the problem.

The second most popular is ‘Breaching Barriers’ with 5,100 views concerning the removal of barriers and the building of fish passes to mitigate against those that cannot be removed.

The next most popular concerns hatcheries and restocking with 2,500 views.

The fourth most popular video is titled ‘Habitat: Providing a good home to return to’. This concerns ensuring the local habitat is the best it can be. This video has had 2,400 views.

Finally, the last specialised video is titled ‘The Appliance of Science’ and has had just 1,300 views. The first half of this 14-minute video concerns the alleged impacts from salmon farming and is fronted by FMS’s Aquaculture Interaction Manager – Charlotte Middleton.

In total, there has been 24,300 views of these five specialist videos, which means that just 5.3% of those that have viewed these videos have been interested in the one about aquaculture interactions. This clearly demonstrates that salmon farming is not the issue that the leaders of the wild fish sector make out it to be. The real problem for wild salmon is that there has been far too much emphasis on salmon farming meaning that the other pressures have not been really addressed.

Until a couple of months ago, FMS have effectively had three members of staff, a CEO, a Director of Communications and Administration and an Aquaculture Interactions Manager, who is paid for by Marine Scotland. Why do they employ an Aquaculture Interactions Manager and not an Enforcement Manager or a Barriers Manager, roles which would better reflect the interest of the angling community. The answer is simple. They are too focused on aquaculture to see that aquaculture is not the problem they claim it to be for wild salmon.

In the science video, Dr Keith Williams of the Kyle of Sutherland Fisheries Board says that the emphasis has been on them to prove that there is a problem rather than for the aquaculture industry to demonstrate that there isn’t one. He was referring to the concept of genetic introgression, but it applies just as much to sea lice.

In the case of sea lice, I would be happy to demonstrate to FMS that they should focus their attention on the other pressures as sea lice are not the problem, Unfortunately, their CEO will only speak to official representatives of the salmon industry and their interactions manager appears unable to acknowledge any attempt at contact. It seems FMS are more interested in maintaining their narrative against salmon farming than trying to protect wild salmon.

Finally, the last video which provides an overview of all the pressures has managed to accumulate just 12,000 views, which is less than the one on dealing with illegal fishing.  Clearly it is time FMS took a hard look at themselves and what they do.