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reLAKSation no 1181

Week 3:  The main question arising from the third session of the Rural Affairs & Islands Committee is whether SEPA are wasting theirs and the industry’s time pursuing their sea lice framework. The answer must be yes. During the inquiry, MSP Elena Whitham MSP asked SEPA if they had identified any significant harm to wild salmon from farmed salmon sites. In response Lin Bruton from SEPA said that they are not aware that they have a direct link between farmed salmon and wild salmon per se. However, the Interactions Working Group have identified that sea lice are a potential impact and that’s why we have brought the framework in from the beginning of February.

So clearly, SEPA are not aware of any link between significant harm to wild salmon from salmon farms, which reinforces the point made by SEPA’s Head of Ecology to the previous committee inquiry in 2020 that salmon farms are not responsible for the decline in wild salmon numbers. It therefore seems that the question of an impact from salmon farms on wild salmon comes from the Salmon Interaction Working Group. I question whether the SIWG were even qualified to suggest that sea lice from salmon farms do have an impact on wild fish.

The attendance at the first meeting of SIWG that took place on Wednesday 31 October 2018 included the Chairman, two members of the salmon farming industry (one MD and the Chief Executive) two members of the salmon fishing sector (one from a salmon fishing board and a member of their aquaculture group and their Chief Executive) one representative of the environmental NGOs sector. An executive (chemist) from SEPA (although subsequently replaced by Peter Pollard), one member from Scottish Natural Heritage, one representative of Orkney Council planning, two members of the Scottish Government administration (including the SIWG’s secretary) and one Scottish Government scientist. I would therefore ask who of this group are the qualified experts who are able to determine whether sea lice associated with salmon farms have an impact on wild salmon. The chairman of the group told me that the group never discussed the science because it was too contentious and certainly, they refused offers from those with evidence to present such evidence to them.

It should also be borne in mind that whilst the salmon industry was represented on the group, the presence of two members of the wild fish sector, as well as one from the environmental NGOs meant that the salmon industry would always be in the minority.

I suspect that it will be argued that there was expertise on the group in the form of the Scottish Government scientist. Dr John Armstrong. However, I would very much challenge his expertise on sea lice. Although, he has co-authored papers and reports on the subject everyone I have seen is flawed. The latest, as I have written previously, analysed just a few selected years of many years of sea lice counts from wild fish to arrive at its conclusion. Analysis of the full dataset tells a very different story.

I first tried to speak to Dr Armstrong about sea lice about ten years ago and he responded by telling me that he would only speak to me if I had a published paper. I now have published two papers, and he still won’t speak to me.

I will be writing a review of the Scottish Government’s ‘science’ on sea lice as part of my evidence to the Rural Affairs salmon inquiry.

Meanwhile I will again argue that before SEPA pursue the implementation of their framework, there needs to be a scientific discussion between the salmon industry, SEPA and the Marine Directorate to ensure that the science concludes that this framework is needed.

It should be remembered that Peter Pollard took an active role in SIWG yet in 2020 he told the Parliamentary Committee that sea lice from salmon farming were not responsible for the decline of wild fish. This is why it is critical that the science of sea lice needs to be revisited.

Events elsewhere in the world show what happens when uninformed views are allowed to dominate the debate. It is likely that Canada has just signed away the possibility that BC will not only have no farmed salmon but also will have no wild salmon either. I will be writing about events in Canada in a future reLAKSation.


I would mention a couple of points made by REC Committee convenor Sir Edward Mountain who asked questions during the meeting. He was particularly keen to press home the point about precautionary principle yet, I see that despite wild salmon being endangered, the Spey Fishery Board continues to post pictures of anglers catching and then mishandling their catch. It seems that anglers must have a photo of their catch regardless of the damage to the fish. I don’t see any precautionary principle being applied in this situation. In addition, anglers fishing the Spey killed 109 salmon and 113 sea trout for sport. As the  catch data is restricted to fishery districts, protecting the interests of proprietors rather than the salmon, it is unknown if any of these fish were caught from Sir Edward’s fishery.

Sir Edward also mentioned farms that have been moved and referred specifically to the farm at Loch Ewe. Despite its closure, MD data shows that sea trout fishing has not improved since the farm was removed but crucially, the salmon fishing which was good throughout the presence of the farm, has deteriorated since.


Credibility. iLAKS has published an opinion piece which claims that the credibility of Norwegian researchers is now at stake in relation to the aquaculture industry. This follows the publication of a report commissioned by the Ministry of Trade and Fisheries – Report on jhow the Traffic Light System affects the work to achieve the goals set out in the Quality Standard for wild salmon.

Although the Norwegian Government commissioned this report, it seems that they did not write the mandate but instead it was written by the Steering Group for the Traffic Light System. The Steering Group consists of three employees from the Institute of Marine Research (HI), The Veterinary Institute (VI) and the Norwegian Institute for Nature Research (NINA). The Steering Group also appointed a Working Group to consider the questions posed by the Government. The Working Group consists of nine members, 2 of whom are from HI, 2 from NINA and one from VI, all of whom are well known names involved in ‘researching’ impacts of sea lice on wild fish. These include Torbjørn Forseth, Geir Lasse Taranger, Peder Fiske and Susie Dalvin. The Working Group also consists of a representative from the Directorate of Fisheries, one from the Environment Agency and one from the Food Safety Authority, as well as the Working Group leader from the University of Bergen. Thus, the Steering Group have appointed mainly people from their own research institutions.

The introduction to the Working Group’s report states that the Quality Standard for Wild Salmon was adopted in 2013 to ensure that wild salmon populations are safeguarded and rebuilt to a size and composition that allows harvesting opportunities. Around 80% of Norwegian salmon stocks do not reach the target of good quality or better. The Quality Standard is an overall assessment of spawning stock targets, harvest potential and genetic integrity. The Working Group consider that spawning stock and harvest potential are most relevant as in their opinion it is these that sea lice affect. According to the Scientific Council for Wild Salmon Management (VRL), sea lice are the greatest threat to wild salmon and account for over a third of the total negative impact.

The two members of the Working Group from NINA are members, not just VRL, but also VRL’s secretariat and they claim that sea lice are the greatest threat to wild salmon. It is therefore unlikely that the Working Group would offer any other opinion despite evidence to the contrary. In 2019, VRL forecasted that an estimated 39,000 salmon smolts would die from sea lice infestation. In the same year, 96,147 salmon, in near breeding condition had been killed that year by anglers and netsmen. I would suggest that the loss of 96,147 breeding salmon represents a greater threat to wild salmon’s future than an estimated and unverified 39,000 smolts alleged to have been killed by sea lice. Since 2019, VRL have not bothered to update these estimates.

The main problem with the Working Group is that it comprises of such a narrow view on sea lice that their deliberations will be a forgone conclusion. It remains a major puzzle given that the Traffic Light System impacts on one specific industry, yet not one representative from that industry is included in any of the Steering Group, Expert Group or Working Group. The other issue as raised in iLAKS is that all three research institutions have a clear vested interest in the research. It is unclear how these institutions can undertake research, then make assessments based on their own research and finally contribute to the regulation. It’s not surprising that the researchers and their institutions are unwilling to engage in any discussion that may offer a different perspective.

According to iLAKS, a guide to the appointment of committees by the Ministry of Local Government states that if the aim of the committee is to agree on common goals and values, it is important the composition reflects different interests, experiences and points of view. The opinion piece in iLAKS continues that there is considerable professional disagreement about the questions relating to the connection between sea lice and salmon farms together with mortality in migrating wild salmon smolts and population development of wild salmon stocks. This disagreement is well known to both the Ministry of Trade & Fisheries and the Steering Group for the Traffic Light System as both have received extensive professional input about differing views, yet the makeup of the Working Group remains focused on one single viewpoint – that which is the result of their own research.

What I find really interesting about this report is the fact that I see exactly the same experience repeated in Scotland. It is the same Government scientists who are directing the narrative based on their own research and this is then being used to formulate Government policy.

There seems to be no consideration by these scientists, both in Norway and Scotland, that they might have been misled by their own observations and have simply got the story wrong.  The fact that they all seem reluctant to sit round the table with a wider audience appears to endorse this view.


Closed: Intrafish reports that the salmon fishing in Norwegian rivers has collapsed. Catches that are so low have never been experienced before. Whilst the number of salmon returning to Norwegian rivers last year was at a record low, the numbers so far this year appear to be even worse. For example, the Mandaselav is down 79%, Bjerkreim/Tengs is down 65% and Surna is down by 90% on last year. Increasingly strict restrictions on fishing in recent years do not seem to have had any effect.

Senior Advisor at the Norwegian Environment Agency, Helge Axel Dyrendal follows event closely. He said that there will be an evaluation after the first week of July and if it turns out that catches are down by 50% compared to previous average catches then restrictions will be introduced. However, if the numbers are catastrophic then even more drastic measures must be taken, which in the worst case would be an early end to the fishing season.

Torbjorn Forseth senior researcher at the Norwegian Institute for Nature Research and also the head of the Scientific Council for Salmon Management (VRL) said that it is likely to be the weakest salmon season ever and this has occurred despite good conditions in most rivers. He added that the only explanation must be poor survival at sea and in that case, it will be even more important to get control of what we can do something about. For example, over 30% of the wild salmon smolt die due to sea lice in parts of Western Norway. When asked if there would be further restrictions on fishing this year, he said that he would not be surprised. If the number of salmon returning is lower than the past couple of years, the harvestable surplus would approach zero. When asked whether the returning salmon could just be late this year, Dr Forseth said that seeing more fish returning later in the year was something in which he has not a lot of faith.

Whilst Dr Forseth has little faith in seeing more salmon return, I have very little faith in Dr Forseth and his colleagues at VRL. Last Monday, VRL published the latest annual status report for salmon in Norway and yet again sea lice are cited as the greatest threat to wild salmon. Actually, the greatest threat to wild salmon in Norway are the scientists at VRL who just trail out the same story every year without understanding the implications for wild salmon.

I know that ICES began analysing returns of Norwegian salmon later than those from Scotland, but the trend has been clear since the 1970s and that is now 50 years ago. In that time, what have the scientists and the wild fish mangers done about this decline? The answer is absolutely nothing except attack salmon farming. I have written more than once about the 50th Anniversary dinner of the Atlantic Salmon Trust attended by our future King Charles and King Harald V of Norway. King Charles could not have been clearer when he said we don’t know why our salmon are failing to return to our rivers. He said that on 25th May 2017, which is now seven years ago and yet all Dr Forseth can offer is that the survival of salmon must have been very poor.  VRL are so focused on sea lice that they cannot see that the real problems lie elsewhere.

The VRL report offers the following evidence of sea lice impacts. It states that “For the period 2010-2014, we calculated an annual loss of salmon to Norway due to salmon lice of approx. 50,000 salmon (VRL 2017). Equivalent calculations for later years indicate a reduced insight of approx. 29,000 salmon in 2018 and approx. 39,000 salmon in 2019 (VRL 2020b).”

It is worth considering that whilst both the Norwegian Environment Agency and VRL have said that 2023 was a bad year, anglers still managed to kill 51,741 wild salmon returning to Norwegian rivers to breed. Commercial nets caught and killed a further 7.656 salmon. It is still a complete mystery how Dr Forseth and his colleagues consider sea lice to be a greater threat when in 2019 they estimated 39,000 smolts might die – although they could not prove this actually happened, but the deaths of nearly 60,000 salmon are not even considered a threat.

NRK also covered the collapse of salmon in an article. They mention that the Norwegian Environment Agency have stated that fishing is well regulated and poses little threat to salmon populations, yet at the same time, they now propose measures that might lead to the early end to all fishing in Norway this year. It is clear that they have little idea as to what is happening to wild salmon because they rely on poor information from VRL who appear incapable of researching anything to do with wild salmon unless it involves a salmon farm.

As far as I can gather nine out of the thirteen members of VRL have at some time worked on some aspect of farmed fish wild fish interactions. It is not surprising that this features so highly in their assessment. VRL should consider changing their name to the Scientific Council for Salmon Mismanagement.