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reLAKSation no 998

Still NO: In the last issue of reLAKSation, I highlighted a reply to a question posed by a member of the Scottish Parliamentary REC Committee to a group of representatives’ agencies involved in the regulation of the Scottish salmon farming industry.

The answer provided by Peter Pollard of SEPA as taken from the official record was:

“I will start with the big picture. Do we think that sea lice from farmed fish are responsible for the declines that we have seen over the decades in wild fish? No. There is a complex range of reasons, some of which are probably to do with high seas changes.”

Am I the only person to wonder that the meaning of such a small word can be so easily misinterpreted? The reply to the REC Committee seems reasonably clear to me – sea lice from salmon farms are not responsible for the declines of wild salmon and sea trout over several decades. No surely means no, salmon farming is not to blame.

I must also wonder when this realisation that sea lice from salmon farming is not to blame became apparent, because no such statement was made during the original REC Committee inquiry into salmon farming, but then it doesn’t seem that the specific question was even asked, which must be considered to be a major deficiency.

The petition that initiated the REC Committee inquiry, the subsequent Salmon Interactions Working Group; the Technical working group and many other investigations and meetings was titled: ‘Protecting wild salmonids from sea lice from Scottish salmon farms’ so I presume that the Committee just accepted what the petitioners had said that wild salmonids needed protecting from sea lice without asking if the petitioners’ claims were valid

However, if sea lice from salmon farms are not damaging wild salmon stocks, then this petition should have been thrown out. Unfortunately, although evidence to show that the petition was flawed was provided at the time, it was never taken into consideration.

The petition eventually ended up with the REC Committee. The Committee’s website stated that:

“The Committee agreed that the inquiry will focus solely on the farmed salmon sector.


To consider the current state of salmon industry in Scotland, identify opportunities for its future development and explore how the various fish health and environmental challenges it currently faces can be addressed.”

Although this petition highlighted concerns (which were flawed) about protecting wild salmonids from sea lice, which were flawed, the REC Committee extended the resulting inquiry to cover every aspect of the salmon farming industry rather than just address the concerns of the petition.

The Scottish Parliament’s Information Centre (SPICE) commissioned SAMS to undertake a full review of the environmental impacts of salmon farming in Scotland. Interestingly, the 196- page report contained less than a page about the impacts of sea lice on wild salmonids. Besides placing Loch Laxford outside of Scotland, the report stated that the consequences of increased sea lice levels for wild salmon populations is unclear. This is not unexpected given that this sector of the report was written by a fish geneticist rather than an expert on sea lice. SAMS clearly were unable to identify anyone with the necessary qualification to express a view on the issue.

Given that the brief was no longer about the impacts of sea lice on wild salmon but about the salmon farming industry as a whole, this shortcoming might be considered less relevant now. Yet, it should have been the most relevant issue to the REC Committee and thus the minimal coverage given was extremely disappointing.

When the REC Committee published its report, the recommendations about wild fish interactions appeared in the section about regulatory responsibility. The section concerned with interactions and the impacts of sea lice did not include any recommendations at all.

Recommendation number 40 states:

Although there is a lack of definitive scientific evidence of the various factors that are contributing to the decline of wild salmon stocks, the Committee is nevertheless of the view that a precautionary approach should be taken which will seek to minimise the potential risk to wild salmon stocks wherever possible

So despite an extensive inquiry involving many witnesses, there was no definitive evidence to support S&TC’s petition that salmon needed to be protected from sea lice and no definitive evidence that the threatened state of salmon on the west coast was due to salmon farming.

Regardless of the lack of such definitive evidence, the committee expressed a view that a precautionary approach should be taken wherever possible to minimise the potential risk to wild salmon stocks.

Nowhere in this statement does it suggest that this precautionary approach to wild salmon should only apply to salmon farming.  However, as the recommendation states wherever possible, surely the precautionary approach should apply to wild salmon (and sea trout) fisheries too.

At the beginning of 2020, Fisheries Management Scotland held a meeting at the Scottish Parliament that was attended by MSPs and others with the intention of making salmon a national priority. FMS stated that:

“Salmon and sea trout catches in 2018 were the lowest since records began. Environmental change, and a range of human impacts across the Northern Hemisphere are placing salmon at risk across their natural range. Figures for 2018, taken together with those of recent years, confirm this iconic species is now approaching crisis point.”

if this iconic fish is, as FMS suggest, approaching crisis point then such a precautionary principle might be applied. Any right-minded person would suggest that if environmental impacts cannot be addressed, then those human impacts that can be tackled must be addressed as a priority.

This week the REC Committee met with the Fisheries Minister Fergus Ewing and during the exchanges, the issue of the precautionary principle was discussed. The convenor explained his understanding of what the precautionary principle means. He said:

My understanding of the precautionary principle is that you don’t do something unless you know that there will be no adverse effects as a result.”

The dictionary definition of adverse is ‘causing harm’ and I would suggest that catching and killing a wild salmon does cause harm. The REC Committee report was clear in that the precautionary principle should be taken wherever possible to minimise the potential risk to wild stocks. Unfortunately, the wild fish sector doesn’t seem to think that this approach should apply to them.

As I have previously indicated, if wild salmon stocks are approaching crisis point, then surely every returning salmon must be allowed to breed without any human intervention. This is what the precautionary principle clearly means.

The precautionary principle is regularly cited by the angling sector as a way of safeguarding wild fish. Thus, fishing for salmon in the high seas by Greenland has been either banned or severely restricted. Inshore fishing for salmon by nets has also been banned following a campaign by S&TC and others because the fish might have come from a threatened stock.

The precautionary principle has also been cited against the salmon farming industry because of claims that migrating salmon might pick up sea lice (which happens naturally anyway – regardless of the presence or absence of a salmon farm).

The latest issue of one of the angling magazines highlights concerns about a new windfarm that might impact salmon stocks in local rivers.

Marine Scotland Science are trying to introduce a stocking policy that will prevent rivers from being restocked because the precautionary principle argues that the local stock, might be further compromised

It seems that the precautionary approach has been suggested for every sector that might impact on wild salmon except the one sector where we know it does, and that is angling.

According to the angling sector, rod fishing for wild salmon has no impact on threatened stocks. Yet since the start of the inquiry, anglers have killed 6,306 salmon and 4,256 sea trout. These are figures for the 2018 and 2019 seasons. Data for this year is not yet available even though the season has closed.

These are all fish that could have bred and added to the stock. Instead, they are gone forever. Why is the loss of these 10,562 fish not considered by the angling sector a threat to wild fish stocks and why shouldn’t a precautionary principle apply, especially as they are so keen that it be applied to others?

Perhaps, the way to safeguard wild salmon in Scotland is to stop the killing of all wild fish as well as committing to a three-year firebreak where all fishing is banned so stocks can recover.

In addition to recommendation 40, the Committee’s final report acknowledged that the Scottish Government had formed the Salmon Interactions Working Group. The report noted that the group would examine and provide advice on the interactions between wild and farmed salmon.

Unfortunately, the group does not seem to have examined the interactions between wild and farmed salmon at all. It seems that there was a blanket acceptance that any interaction would have a negative outcome.

SIWG’s final report, which was only published in April stated that:

At an early meeting the SIWG acknowledged the potential hazard that farmed salmonid aquaculture presents to wild salmonids (Atlantic salmon and sea trout)”

I appreciate that there are other issues besides sea lice that might impact on wild fish but given the background that led to the formation of the group, consideration of sea lice should be the primary focus.

What is surprising is that Peter Pollard, who told the Committee that sea lice from salmon farms was not to blame for the declines of wild fish also represented SEPA on the group for the majority of the meetings.

Perhaps, he wasn’t asked the same question as he was asked at the recent meeting of the REC Committee but I would hope that anyone with any awareness that salmon farming was not impacting on wild salmon because of sea lice might speak out. However, the final report does not suggest that anyone did.

Equally, the group decided that they did not want to hear from anyone from outside the group who might want to express a view, so I would imagine that the question was never asked.

Perhaps, if the question had been asked before now, there would have been little need to form the Salmon Interaction Working Group and instead of just consideration of this one pressure on wild salmon, the working group could have spent more constructive time considering some of the other high level pressures that have been identified by Marine Scotland Science.

In all, there are 12 high level pressures of which two relate to salmon farming. The idea that salmon farming has an impact on wild fish comes from Marine Scotland Sciences, ‘Summary of the Science’, which highlights two scientific papers as proof of these impacts. Regular readers of reLAKSation will be aware that I have questioned the validity of these papers on more than one occasion, but MSS have so far refused to respond.

These papers suggest that salmon farming has an impact on wild fish yet, if Peter Pollard’s statement to the REC Committee is correct, then the findings of these papers are wrong.

Sadly, the Salmon Interactions Working Group was a missed opportunity. Their report states:

“The SIWG recognises that there are a number of gaps in our understanding relating to wild-farmed interactions. However, the SIWG is firmly of the view that filling these knowledge gaps is not a pre-requisite for taking forward regulatory reform.”

Yet, the REC Committee report stated in recommendation 38 that:

The Committee supports the proposal from the ECCLR committee for more research into the interactions between farmed and wild salmon, as a matter of priority

Regular readers will know that earlier this year, I had a per-reviewed scientific paper published showing that the decline of wild fish around the west coast collapsed during the late 1980s as a consequence of the introduction of the three mile limit. A request to present this research to the SIWG was refused.

In my opinion, SIWG were not concerned whether salmon farming impacts on wild salmon and sea trout or not; their focus was on implementing regulatory reform. If salmon farming is not responsible for the declines of wild fish, then strengthening regulatory reform relating to wild fish would appear unnecessary.

SIWG was intended to be the first part of a long-term plan to investigate all the high-level pressures impacting wild fish. Even before COVID, there didn’t seem any plans to take this further.

The wild fish sector had got their wish to implement tighter controls on the salmon farming industry and thus any further cross sector discussions were of no interest.

Meanwhile, Marine Scotland has formed a new group to investigate a strategy for wild fish. Unlike SIWG, this group has not been subject to public scrutiny. I have requested details of who is participating in the group but am still waiting for an answer. Of course, the group will consist of the same people offering the same solutions with no prospect of any real innovation.

My understanding is that the wild fish people have already objected to the possible presence of sector outsiders like myself. They are always ready to express a view about other sectors, but they certainly don’t like it when others express an opinion about them.

I can still only wonder when the message will finally get through. Certainly, it hasn’t yet got through to Salmon & Trout Conservation. They simply do not accept that salmon farming is not responsible for the declines of wild fish. The time has come for them to look elsewhere and to stop blaming salmon farming.