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reLAKSation no 849

Sincere apologies: The plan for this latest issue of reLAKSation was to comment on a report in about a major summit in London this week hosted by the Norwegian Seafood Council during which would include a discussion about fish and seafood consumption. We also had seen that Intrafish reported on the next ‘new’ salmon market (it’s the US) and felt this was worthy of a comment. Finally, we were planning to continue our review of the issues likely to be discussed at the forthcoming Scottish Parliamentary enquiry into salmon farming. We were to focus on closed containment.

However, on Thursday, the Environment, Climate Change and Land Reform Committee announced its plans for a review of the environmental impacts of salmon farming with the publication of the commissioned research. This is such an important development that in our opinion it requires our sole attention, if for no other reason than to ensure our view is not diluted by other issues.

We will hopefully get back on track by the beginning of February. Aquaculture is such a key part of fish and seafood supply, that it should not be disrupted by a blinkered minority view.

The following is a commentary by Dr Martin Jaffa.


Not so fair: On the evening of January 24th I watched the BBC Alba programme Turas a’ Bhradain in which presenter Need MacKay explores the world of salmon and fly fishing in Scotland. The week’s programme (Series 4 episode 3) examines the effect of Hydro schemes on salmon rivers – (not available outside the UK). The programme begins with Neen MacKay stating that Hydro -electric schemes ‘have had some of the biggest impacts on wild salmon in Scotland and some believe they make the impact of aquaculture look small by comparison.’ It does make one wonder that if this is true then the forthcoming Parliamentary Enquiry is investigating the wrong industry. Of course, the enquiry is the result of the activities of a very vocal minority. As we mentioned last week, the Norwegian Institute of Nature Research’s estimate of wild fish deaths due to salmon farming is about 7,500 fish whereas the last reported angling kill was 9,096 fish. Maybe, someone should be asking why if wild salmon stocks are in such a perilous state, then they are still being killed for sport. The Scottish Government have already stopped commercial netting so is it not time for a ban on the killing of wild salmon for sport too?

The following day, I received the latest copy of Fish Farmer magazine and found inside a four-page article written by Scott Landsburgh of the Scottish Salmon Producers Organisation (SSPO), in which he looks forward to the forthcoming Parliamentary enquiry. He writes that this is the opportunity to set the record straight rather than allow the voices of the militant part of the wild fish lobby to set the agenda. He is sure that the salmon industry can make a convincing case of its merits if the industry is given a fair hearing.

Mr Landsburgh’s view certainly reflects my own but since learning of the intention to hold an enquiry, my worry has always been that it will be conducted in a fair and even-handed manner. In my opinion, my concern is not without foundation. I remember watching the evidence session during the passage of the Aquaculture Bill in which one representative of the salmon industry had to share a platform with several representatives from anti-farming groups. The ensuing debate was neither fair or even-handed.

However, it was not just the evidence session that was of concern. The various Parliamentary committees are provided with research briefings for any subject being discussed. Thus when the Aquaculture Bill was in process in 2012, SPICe, the Scottish Parliament Information Centre produced a briefing document for Members of the Scottish Parliament (MSP’s) – . At the time, I did not think that this briefing document fairly reflected the industry then. This was inevitable since most research is geared towards identifying perceived negative impacts of salmon farming, rather than demonstrating that the industry is not as environmentally damaging as small number of vocal critic’s claim. In research, it is very easy to keep repeating the same messages time over time so that eventually, their validity is never questioned. For example, the 2012 SPICe briefing document includes the following statement: ‘While Atlantic salmon declines are due to a number of reasons, there have been suggests (sic) that higher declines on the West coast of Scotland might be linked to the concentration of aquaculture production there (Vøllestad et al. 2009)’. I would argue that this specific paper does not demonstrate at all that there is a link between salmon farming and declines of wild fish. In fact, the subject of the paper is about something completely different and is not concerned with the impacts of salmon farming.  However, for me, the real problem is that there is no opposing view in the briefing document and yet, there is an opposing view.

It is this lack of balance that I find disturbing as it feeds into the attempts by critics to undermine the salmon industry. I had hoped that this enquiry would be different but then I started to hear rumours that it was going to be different. Instead of writing the briefing document themselves, SPICe was to commission an outside agency to produce a review for them. I also heard that this outside agency was then subcontracting some of the work to others. The names bandied about did not fill me with confidence.

I had been travelling on Thursday so only learnt that evening that the ECCLR had announced their intentions of producing a report which they would later submit to the Rural Economy and Connectivity Committee in preparation for the full Parliamentary enquiry. The ECCLR confirmed that SPICe had commissioned a review of the environmental impacts of salmon farming and the contract had been awarded to the Scottish Association of Marine Science (SAMS). Their review can be accessed  from:

I had already heard that SAMS were engaged in preparing the review and had recruited outside help. I therefore wrote to express my concerns and received the following reply:

‘SAMS is an independent scientific institute of long standing with an international reputation for the quality and impartiality of marine research work. Where we involve scientists from outside of our organisation in any aspect of our work, we do so recognising their particular competency and its relevance to the work. Literature review and reporting carried out by SAMS references all relevant evidence and is based on science carried out at the limits of current knowledge and practice, with interpretations made by expert scientists, based on best endeavour, fact and total impartiality.’

However, now I have seen the final review document, I believe that my concerns are fully justified. In my opinion, the review is not impartial, and I will explain why.

The review consists of six different issues presented in a document that is 196 pages long. Those, such as myself who wish to comment about the document are allowed just four pages and about two weeks to respond. Clearly, it is impossible to evaluate the whole document in either the space or the time. I therefore would restrict my comments to the issue of sea lice since this is the issue as raised by Salmon & Trout Conservation Scotland (S&TCS) that has promoted the enquiry in the first place.

Sea lice are considered in Section 2 of the document from page 10 to 16 a total of six and a half pages. Given that sea lice are considered such a major issue that they have prompted this enquiry, they account for not even 5% of the total review. Seemingly, those writing the report did not have that much to say.

The review document begins with information about the various contributors to the commissioned work. The documents states:

‘The work within this review has been the effort of several researchers, who contributed on areas of their scientific expertise’.

‘An outline of the contributors for each section of the review is included below:

Section 2

Prof. Eric Verspoor (UHI; Rivers and Lochs Institute)

Dr Donna-Claire Hunter (UHI; Rivers and Lochs Institute)

Dr Mark Coulson (UHI; Rivers and Lochs Institute)

The document is quite clear, the three members of the University of Highlands & Islands who have contributed to Section 2; an area of their scientific expertise.

Just to be sure that there is no confusion, section 2 concerns the issue of sea lice, the contents lists sea lice as section 2.


2.1 Sea Lice Impacts …………………………………………………………………………………………………. 10

2.2 Diseases and Other Parasites………………………………………………………………………………… 16

Since SAMS have recruited the various contributors based on their expertise, I must assume that Professor Verspoor, Dr Mark Coulson and Dr Donna-Claire Hunter are all experts in the issue of sea lice. The problem is that I cannot find any reference to any of the three in either of the review documents commissioned by S&TCS. These are the review of the collapse of Loch Maree by Dr Andy Walker or the review of sea lice paper by the Norwegian Institute of Nature Research.

In the case of Professor Verspoor, the reason why he does not appear in either of these reviews of sea lice becomes clear with reference to the UHI website Professor Verspoor’s stated academic expertise is in ecological and population genetics and its application in sustainable resource management and conservation. There is no mention of sea lice.

Dr Mark Coulson also has a dedicated page on the UHI website. He states that ‘My background is in molecular ecology and population genetics’. As with Professor Verspoor, there is no mention of expertise in sea lice research –

I would also like to include Dr Donna-Claire Hunter’s expertise in my commentary, but she is not listed on the UHI website or the pages of the Rivers and Lochs Institute. In fact, the only recent references to her appear in the news items relating to last year’s Scottish Salmon Festival hosted by UHI in Inverness.  The BBC News website states that Beauly based angler Donna-Claire Hunter competed in the festival’s Speycasting competition.

In the Past, Dr Hunter has worked on the Managing Interactions Aquaculture Project (MIAP) (Genetics) for the Rivers and Fisheries Trusts of Scotland (RAFTS). She does not appear to have been involved in sea lice research.

The SAMS document begins by restating its purpose of specifically reviewing the environmental impacts of salmon farming by conducting a comprehensive review to assess and summarise the six different areas of impacts in Scotland as prepared by a group of subject experts from throughout Scotland. The report leaves me in no doubt that it was put together by experts in their subject area.

Whilst I am certainly knowledgeable of the impacts of sea lice on wild fish stocks, I would not claim to be an expert. However, if I had written section 2 of this report it would look very different to that which has been published. Clearly, the length of the report means that it is impossible to discuss every point raised. When I first scanned through the document, a couple of points jumped out at me and these are worth mentioning.

On page 12 of the document, there is a short paragraph titled – Salmon farming increases sea lice abundance and infect wild salmon.

The first sentence states: ‘A clear relationship between the increased abundance of sea lice due to salmon farming and presence on wild hosts has been demonstrated outwith Scotland (Marshall 2003, Morton et al 2004, Serra-Llinares et al 2016)’.

Although, this statement doesn’t look contentious, it does make me wonder whether the authors have actually read the papers or whether they are just requoting something stated in a different review. Firstly, they say that the quoted studies are outwith Scotland, yet Marshall (2003) clearly states that the work was conducted in Laxford Bay in Sutherland. This paper also states that

‘From this study, there appears to be a weak relationship between lice abundance on the wild salmonids within Laxford Bay and the stage of production on the neighbouring fish farm’.

Further in the paragraph, the document states: ‘The only reported scientific study relates to wild sea trout monitored over five successive farm cycles (Middlemas et al, 2010, 2013), which found that lice burdens …were significantly higher in the second year of the production cycle’. Middlemas et al 2013, does restate this in their introduction, but the intention of the paper was to identify the risk of infestation of wild sea trout in relation to their proximity to local salmon farms. Other work in Canada and Ireland had identified a critical distance of 30km where wild fish could be prone to infestation and Middlemas et al 2013, subsequently identified a critical distance of 31 km in Scotland.

However, recently, I used data collected by RAFTS in Scotland over a period of five years up to 2015 to look for a similar relationship. I was unable to identify any such relation and would be interested to see if Middlemas and his colleagues can do so using the newer data. It is important to point out that similar infestation levels have also been found on the east coast of Scotland where there are no salmon farms, but such information is not included in this review document.

From this one paragraph, any concerns I had about the validity, accuracy or impartiality of this review now appear justified and can only hope that the two Parliamentary Committees will address these concerns as part of their enquiry. The fundamental problem is that scientific papers, even those which have been peer reviewed, do not necessarily reflect what is happening out in the sea lochs. It is possible to argue the science ad infinitum, but it won’t necessarily change views. I am reminded of the major study undertaken by the Marine Institute in Ireland that found just 1% of released salmon smolts die due to the impact of sea lice. Critics have taken the same data and conclude the scale of mortality is up to 40%. Its just a matter of how the data is presented.

I am sceptical of any of these science reviews when applied to a working functioning industry. Instead, the Committee should be asking for evidence of real examples where the salmon industry has actually damaged the Scottish environment. After all, the salmon industry has now been operating for around 40 years, there must be real evidence of its impacts rather than relying on the theoretical evidence provided by some researcher working in a laboratory remote from any working salmon farm.