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reLAKSation no 874

Two fingers & a thumb: Salmon & Trout Conservation Scotland seems to be fixated with their hands. Their solicitor Guy Linley Adams has said that the fish farming industry has decided to ‘thumb its nose’ at the Scottish Parliament, whereas their director Andrew Graham Stewart said that the salmon farmers have essentially given ‘two fingers’ to the Scottish Parliament.

According to Salmon & Trout Conservation, the salmon farming industry has reneged on transparency promises made to the Scottish Parliament’s ECCLR Committee and delivered them an extraordinary snub. This is because S&TC say that the salmon industry has ignored unanimous demands for more comprehensive publication of sea lice data. They say that in a comprehensive and detailed report the ECCLR Committee addressed the issue of sea lice data.

S&TC now say that the SSPO has spectacularly failed to live up to its commitment and this has prompted the committee convenor Graeme Dey MSP to write to the SSPO to ask their intentions.

We, at Callander McDowell, would argue that it is the S&TC that are the real problem not the SSPO. It is the S&TC’s petition that prompted the Scottish Parliamentary Committee enquiries and neither committee actually bothered to investigate the first petition to see whether it had any validity.

The S&TC provide links to the correspondence from Mr Dey to the SSPO and the SSPO’s reply. In response, we, at Callander McDowell would make the following observations, which we hope Mr Dey and the ECCLR Committee will note:

The S&TC Petition provided no evidence that salmon farming is to blame for declines of wild fish on Scotland’s west coast. Their main argument was that all fishery districts had been classified as Grade 3 conservation limit and this meant that they were all considered to be in poor health. However, the following year, 23% of rivers were classed as Grade 1 and 35% as Grade 2 allowing anglers to kill wild salmon for sport in 58% of aquaculture zone rivers. This does not support a view that salmon farming is responsible for problems with west coast salmon.

The Petition also quotes a mortality figure of between 12-29% for wild salmon killed by sea lice. These figures have been determined by various Norwegian scientists using mathematical models and statistical analyses. This accounts for the wide variation in the estimated impact. A report from Norway, commissioned by S&TC, actually concludes that the impact was 10%, which is lower than the figures quoted in the Petition. By comparison, experimental studies from Norway and Ireland that actually measured the mortality in fish, found the impact to be just 1%. The big question is why are the ECCLR Committee bothering to focus on sea lice when the mortality on wild fish is so low, yet wild salmon are suffering a 95% mortality, even in areas where there is no salmon farming? Perhaps the fact that nearly half the committee were subsequently willing to scrap conservation limits on wild fish to appease their angling constituents is an indication of their position?

S&TC state that the report issued by the ECCLR Committee was detailed and comprehensive. We would disagree. Firstly, the £42,000 report commissioned for the ECCLR Committee which was the foundation on which their enquiry was based was flawed. The section on sea lice was written by an expert in fish genetics and not sea lice. It was not comprehensive in its assessment of the impacts of lice in any way. Secondly, the ECCLR report was extremely selective in the way it used the submissions it received. For example, it ignored the submission from Professor Randolph Richards who clearly stated the impacts of sea lice were minimal. It also failed to answer the question of the graph we posted showing the decline in sea trout catches from rivers in the aquaculture zone since 1952 including the thirty years prior to the arrival of salmon farming to the west coast.

We, at Callander McDowell would mention that to date we have yet to receive a single response from anyone connected to the wild fish sector, whether anglers or scientists. to explain to us what is happening in this graph.

Unfortunately, by writing to the SSPO, the ECCLR Committee convenor has ignored much of the evidence showing that sea lice are not the problem for wild fish as the S&TC maintain. As we regularly point out, the S&TC are always keen to implicate the salmon farming industry through their regular press statements, but they are completely unwilling to meet those that they accuse face to face to discuss the issue. We have recently tried again to invite Andrew Graham Stewart and Guy Linley Adams to meet us, but they won’t even acknowledge our requests. If they are so convinced that salmon farming is the problem, then they should be willing to argue their case in person rather than getting the ECCLR Committee to do the job for them.


Scraping the barrel: At the end of last month, salmon farming critic and director of the Global Alliance Against Industrial Aquaculture and Scottish Salmon Watch, Don Staniford, released a large number of pictures of individual salmon which had been collected during routine monitoring of salmon farms by the Scottish Government’s Fish Health Inspectorate. The photos had been acquired, at Scottish taxpayer’s expense, through yet another blanket coverage Freedom of Information request. The photos came with a warning that they should be viewed in context. Many of the photos were taken as part of a health-risk surveillance programme where 5 fish were removed from a cage holding up to over one million fish. The photos were not representative of the total fish population. The Fish Health Inspectorate also told Mr Staniford that some fish will always experience a challenge to good health.

We would imagine that the point of obtaining these photos would be to shock any members of the public. Mr Staniford describes the photos as gruesome, eye popping, jaw-dropping and stomach churning and no doubt this is the effect he hoped to create. Unfortunately for Mr Staniford, the mainstream press ignored his coverage and only the on-line Ferret investigative journalism platform posted the photos.

We, at Callander McDowell, wonder whether by requesting these photo’s Mr Staniford is scraping the bottom of the ‘Freedom of Information’ barrel. Has he run out of ideas of whose correspondence he can request that he has moved on to photograph? Perhaps, this is the end of this way of attacking the salmon industry?

However, Mr Staniford has one last roll of the die to pursue and even that seems to be something of a last gasp. The Daily Mail reported that Scottish Salmon Watch will file a legal challenge against all of Scotland’s salmon farms for systematic breaches of the animal welfare laws. We aren’t lawyers or legally trained, but we understood a legal challenge to be something that could be lodged to challenge a decision made by Government. The Daily Mail report was published a day after Mr Staniford had received correspondence from the Scottish Government. In response to a letter to Government Ministers and a Cross Party Group on Animal Welfare, Mr Staniford was informed:

‘Fish Health Inspectors will report any significant case of poor welfare to Animal & Plant Health Agency (APHA veterinarians, responsible for overseeing the requirements of the Animal Health & Welfare (Scotland) Act 2006. If APHA suspect that an offence may have been committed under the ACT, there are various enforcement options including issuing advice, warning letters and care notices, and the option of passing evidence for a potential prosecution to the Procurator Fiscal to consider’.

Mr Staniford’s response to this information is to send his dossier of photos to APHA’s office in Surrey, even though their website says complaints about issues in Scotland should be directed to the relevant Scottish Field Office.

Mr Staniford has also copied his complaint to the Wildlife Crime Unit at Police Scotland. He writes that he understands that the Wildlife Crime Unit has the authority to investigate his complaint with any evidence being passed onto the Procurator Fiscal for prosecution.

We, at Callander McDowell believe that Mr Staniford is simply ‘grasping at straws’.

Firstly, Mr Staniford’s so-called legal challenge is better described as a complaint and as a complaint, it is something of a damp squib. He says that the Wildlife Crime Unit has the authority to investigate his complaint, but their website highlights that wildlife crime covers a huge spectrum of criminal activity from damage of sites of scientific interest to disturbance of cetaceans; from illegal use of traps and snares to illegal taxidermy; and from illegal cockle picking to removal of bird’s nests. The nearest their interest gets to salmon is in prosecuting salmon poachers.

His complaint to APHA is also flawed. As the Scottish Government point out, Fish Health Inspectors already have the powers to report salmon farms to APHA but haven’t done so yet. Why should APHA therefore consider Mr Staniford’s complaint based on photos that have been taken out of context. In addition, APHA would no doubt consider that the salmon industry is largely covered by RSPCA Freedom Food accreditation and that most salmon companies employ dedicated fish veterinarians. It is unlikely that farming would therefore be considered to have ignored key welfare issues.

Mr Staniford’s complaint is that salmon farming companies have systematically breached the Animal & Welfare (Scotland) Act 2006 in particular in relation to Unnecessary Suffering (Section 19), Cruel Operations (Section 21) and Ensuring Welfare of Animals (Section 24) and in totals runs to 108 pages. In all these pages, which contains countless links to other documents, we are unable to find any reference to the Farm Animal Welfare Committee, an expert committee set up by the DEFRA. FAWC have produced an ‘Opinion on the Welfare of Farmed Fish’ which is posted on the APHA website and which details what is and what isn’t of concern with regard to the welfare of fish farmed commercially in the UK. We don’t see that, using this opinion as a guide, APHA would consider Mr Staniford to have a valid complaint.

We shall have to wait and see.


Highly selective: For many years, salmon farm activist, Alexandra Morton blamed declining returns of Pacific salmon to BC rivers on the presence of salmon farms. Together with researcher Martin Krkosek, they warned that some populations of wild salmon would die out within four generations. This never happened. Their warnings failed to materialise with some stocks returning in increasing numbers.

Having failed to convince Canadians that sea lice were a real threat, Ms Morton turned her attention to viruses and especially the Piscine Reovirus (PRV). Her constant focus on PRV led a group of researchers including scientists from Fisheries & Oceans Canada to conduct a study that linked PRV and Jaundice in Chinook salmon, much to Ms Morton’s delight.

Now ‘Vancouver Business’ reports that a scientific review requested by the BC Government and conducted by the independent BC Centre for Aquatic Health Sciences and the University of British Columbia has found no evidence that PRV causes disease in the Pacific as it might appear to do in Norway. The report concludes that rather than being introduced by fish farming, PRV might be endemic to the province and may have been present long before the arrival of fish farming. The PRV virus has been found to be benign. When the PRV virus was injected into healthy fish, even at high levels, the fish failed to develop any disease.

Hugh Mitchell, a US fish veterinarian told ‘Vancouver Business’ that PRV is really an innocuous virus which rarely causes disease and when it does it is usually in association with something else. It is complex and that is why statements and conclusions of untrained activists or pigeon-holed researchers do an incredible disservice.

By coincidence, Alexandra Morton has posted a five minute video on her website – In this, she expresses her views about PRV, as in the following extract:

“But in Chinook salmon which did not co-evolve with this Norwegian virus the cells just fill up and they explode. 80% of farmed salmon in British Columbia are infected with PRV, the industry is telling us this and its causing the blood cells of Chinook salmon to burst en-mass. This is causing a toxic response in their organs. It is making it harder for them to breathe because they’ve lost a whole bunch of their red blood cells and ultimately, she (Dr Kersti Miller) says it is causing death. So, is this why Chinook salmon are vanishing in Clayoquot Sound? Is this why 69% of southern resident orca pregnancies are aborted because those mothers are starving due to a lack of Chinook salmon?”

We can only wonder that having failed in her attempts to attack the BC salmon farming industry with claims about sea lice and now PRV virus, what will Ms Morton turn to next?