RAIC: I believe that I have watched every session of the REC/RAIC inquiries into salmon farming either in person or through the video link since the first session in 2018. I also believe that this latest session was the most attended by observers, the majority of who were anglers who had been exhorted to attend by various angling groups to protest at the impact of salmon farming on wild fish stocks.
It is easy to forget that the first session was instigated because of a petition organised by the angling sector complaining about the impact of salmon farming on wild fish. It therefore seems that eight years of inquiries have not resolved the complaints of the angling sector. This is not surprising because despite holding many session both REC and RAIC have avoidied asking the fundamental question as to whether salmon farming and specifically sea lice associated with salmon farming is the reason why wild salmon stocks are in such a perilous state and if salmon farming is the cause of the decline, then what can be done about it.
In this last session, the convenor stated
‘We continually hear from stakeholders [i.e. angling lobby] that the risk to wild salmon remains largely unchanged in practice, on the ground. Given these concerns, can you give us any evidence that there has been a meaningful reduction in the impact of farmed to wild salmon, where that evidence is, if it doesn’t exist, why is it after a decade almost [since the RECC inquiry] of these concerns being raised we are still not seeing measurable improvements in safeguarding wild salmon?’
As I said, the committee have never really asked the question and more importantly, wanted to know the answer, primarily I suspect because it doesn’t fit in with the claims made against the industry. I know that my name has been put forward as a witness more than once. I believe even one of the members of the original committee requested that I should be called. Certainly, my name was mentioned in one of the sessions as the written transcript can confirm. Yet those organising the witness list have always rejected my inclusion, preferring in some cases, witnesses who have no knowledge of the subject.
Instead, the various committees have spent time and money delving into the minutiae of issues such as mortality which only became an issue because the same organisation that launched the petition believed that by focusing on mortality rather than the plight of wild fish, they could persuade consumers to stop eating farmed salmon. That is not to say that salmon farming companies take mortality lightly, because everyone I know cares deeply about the fish under their protection.
Unfortunately, whether it is the REC/RAIC committee or the wild fish sector, there is this unwillingness to discuss whether salmon farming is an important factor or not in why wild fish stocks are now in crisis. This is why Salmon Scotland has backed calls for a Scottish Parliamentary inquiry into the long-term decline of wild salmon. However, I would argue that the wild salmon sector cannot afford to wait for a Scottish Parliamentary inquiry to take place. I would still argue that there needs to be a mini-conference or similar where different viewpoints can be expressed and discussed. It is always a puzzle as to why the wild fish sector are so reluctant to engage in such discussions. You might think that they would want to pursue any discussion that might lead to helping wild salmon stocks recover.
I will go through the full RAIC session when the transcript is published, and I may discuss this further.
Finally, the press reported that the wild salmon decline had triggered a rally outside the Parliament as the last session of the RAIC inquiry took place. According to the Scottish Daily Express the demonstration would bring together representatives of Scotland’s angling community, which they estimate to be around 32,000 anglers, to protest at the Parliament building. The images broadcast of the protest would suggest that only a few heeded the call to protest. Of course all their demands relate to the salmon farming industry but what caught my interest were the comments of the organiser Ken Reid who said – anglers are typically conservation volunteers, not protestors and when people who quietly restore rivers and fund vital science feel compelled to stand outside the Parliament, it reflects the seriousness of the situation and that something has gone badly wrong. Ignoring the obvious contradiction, I am not sure what vital science has emerged from this quiet funding and clearly if it has, it hasn’t helped. The newspaper article ends with reference to the Atlantic Salmon Trust’s West Coast Tracking Project which the paper says had highlighted significant mortality of migrating smolts in aquaculture intensive regions. This is news. Certainly, the two papers that are linked to the project do not highlight mortality and although the work finished in 2023, the Atlantic Salmon Trust have yet to publish their final report and as far as I can gather, they have no plans to do so.
Lice quotas: We know that the Norwegian Traffic Light System doesn’t work. This is evident from the continued poor state of wild fish populations in Norway that the Traffic Light System is supposed to protect. Whilst the catch data for 2025 showed a little improvement, it is clear that the overall numbers of wild fish are headed in one direction only.
The discussion about what Norway should do about the Traffic Lights seems to imply that the reason for the failure is down to the actions of farmers, a view that has been reinforced recently by the news that production has risen in areas where it is supposed to be controlled. What there doesn’t seem to be is any discussion as to whether it is the science underpinning the Traffic Light System that is wrong. Certainly, this is something that the scientific community refuse to consider and thus the obvious option of going right back to basics and reconsidering whether sea lice associated with salmon farming is actually what is causing the decline of wild salmon simply is not on the agenda.
Instead, one of the main pieces of work taking place to consider the options ahead is HAVREG -the implications of regulatory models for the Norwegian aquaculture industry and society as a cost of NOK 13,589.000 or just over £1 million. The project runs for 18 months until March 2027.
According to FHF who are funding the project the main objective is to analyses how different regulatory models for aquaculture affect environmental and social sustainability, fish health, biosecurity, production, competitiveness and value creation in the Norwegian aquaculture industry and provide recommendations on a regulatory model together with an assessment of knowledge of uncertainty and risk elements.
It is only when you come to number 3 of the 8 sub-objectives that there is any mention of wild fish, which is surely the whole purpose of this regulation. Sub-objective 3 states to assess how regulation of lice induced impacts on wild salmonids can be designed and evaluated including lice quotas as well the consequences of fee models and sanctions.
It is the three words in the middle of this objective which are at the heart of the matter -lice induced impacts. The close-knit scientific community in Norway are certain that there are lice induced impacts but have very little real-life evidence to demonstrate the impacts. In contrast, there are a handful of scientists, such as me, who hold a different view and have evidence to support their claims. It seems absolute madness that huge sums of money are still being directed at projects such as HAVREG and the Hidden Toll of sea lice and yet there is such a reluctance to have the discussion as to whether the impacts exist and or whether they merit regulation at all.
In my own case, I continue to make the arguments simply because both the scientific community and wild fish sector appear to prefer to attack the messenger than be willing to discuss the message.
HAVREG is now being discussed because the well-funded research team have recently published two articles in Kyst.no. Lice quotas – opportunities and pitfalls in design and Technological change in aquaculture – what is needed to meet the lice quotas.
It is a short section of the first article that is of most interest – regulation of lice induced mortality. In this the researchers say that the starting point for future lice quotas regulation is the Traffic Light System where researchers estimate the proportion of wild salmon smolt that die from sea lice during the migration period between April and June. This is of course an estimate, and researchers cannot say whether their estimates bear any relation to how many fish actually died or if any died at all. The estimated mortality of 10% gives a green light and over 30% gets the red light for which farmers must reduce the company maximum allowable biomass by 6%.
The researchers say that the current system does not calculate what the estimated mortality corresponds to in terms of number of lice in fish farms and in theory there is a relationship between the number of lice in farms and the mortality of wild salmon however, as yet it seems that no-one has worked this out. My own research would indicate that levels of lice on farms have little bearing as to what is happening in the wild population, but more work is required.
Meanwhile the Government have said that the lice quotas will be set based on the number of lice that corresponds to 10% mortality in wild salmon. However, we already know that the science that leads to the estimation of 10% mortality as used in the Traffic Light System is flawed, so transferring to the lice quotas will ensure any new system is equally flawed.
This is why rather than invest in extensive research programmes, there needs to be a proper forum for scientific debate on sea lice impacts. The Sea Lice Group are holding a one-day meeting in April, but this will only consider new research not the older research that is relevant but that the sea lice group have chosen to ignore because it doesn’t fit their narrative.
AI and Algorithms: A three-part series featuring mathematician Hannah Fry has just finished its run on BBC 2 TV. She is Professor of Public Understanding of Mathematics at Cambridge University. In the series she took a deep dive into some of the most extraordinary human stories emerging from the world of AI. Th first programme asks who is responsible when a teenager fell in love with a chatbot, which then encouraged him to try to kill the late Queen Elizabeth. The second programme asked who is responsible when a self-driving car hits a pedestrian and kills them and the final instalment looked at how health insurance companies in the US are using AI to determine when patients’ hospital care should end.
The programmes were fascinating and at the same time horrifying as Hannah asks what impact the increasing use of AI will have on us humans.
I mention these programmes because in the middle of the three-week run I received a document, the contents of which I cannot discuss at this time, except to mention that it is of course about sea lice science. What I can say is the final three lines say:
As a final comment, to quote Professor Hannah Fry (2018) ‘The choice isn’t between a flawed algorithm and some imaginary perfect system. The only fair comparison to make is between the algorithm and what we ‘d be left with in its absence.’
Whoever wrote this document was referring to the modelling of the Scottish Sea Lice Risk Framework and Norwegian Traffic Light System. My understanding of what is being said is that my desire to see a proper validation of the model i.e. That we show that sea lice larvae actually exist in numbers and approximate locations where the models predict, is an unrealistic view of an ideal world. Instead, the view seems to suggest that it is better to have an imperfect model than no model at all and this is exactly what we have and yet in the case of sea lice I would argue that we would in fact be better off with no model at all.
What concerns me is the use of Hannah Fry’s quote which is taken totally out of context. The quote comes from one of the chapters covering subjects as diverse as Art and Medicine, Cars and Justice. The quote was taken from the chapter on Justice looks at the use of algorithms in court rooms to predict such things as the likelihood of reoffending. The chapter also considers whether judges may be prejudiced and whether algorithms can help remove this. This is very different from the use of models to predict the presence, densities and locations of sea lice.
The reality is simple. If regulation is to be imposed on salmon farmers, then the regulations must be sound and as we know neither the Traffic Light system nor the Sea Lice Risk Framework can be described as such.