Trust welcomes salmon recommendations

We warmly welcome the report of the REC Committee that we believe addresses most of the problems associated with the salmon farming industry, and we look forward to action being made to implement the 65 recommendations.

Recommendation 2[i] is the key to further action as it recognises that the status quo isn’t acceptable and that meaningful action has to be taken to address regulatory deficiencies and environmental issues before any expansion in the industry can take place.

The report highlights the impact that sealice from farms has on wild salmon and sea trout using the sea in the vicinity of fish farms, and that this is a major gap in the current regulation of the industry [ii].

Recommendations 45–47[iii] go on to urge that fish farms should not be sited in the vicinity of migratory routes for wild salmon and that a precautionary approach must be applied in a meaningful manner to curb the development of new fish farms.

Sea trout are more susceptible than salmon to the impacts of fish farming because they spend more time in coastal waters. Research conducted on sea trout has shown that sealice are found at elevated levels on wild sea trout within 30km of fish farms. This level of infestation raised the risk of these fish dying by 12–90% [iv]. This suggests that a precautionary approach to siting fish farms should be applied to zones within 30km of the farm.

A number of rivers (see map above) in the west of Scotland have been designated as Sites of Special Scientific Interest (SSSI) for Atlantic salmon or for freshwater pearl mussels. Mussels in their juvenile larval stages attach themselves to the gills of salmon, which then swim upstream. The larvae then fall off and attach to the river bed. An analysis of where these rivers enter the sea shows that there are already a large number of fish farms that one should assume, on a precautionary approach, are potentially having a damaging impact.

NOTES

[i] RECOMMENDATION 2. The Committee strongly agrees with the view of the Environment, Climate Change and Land Reform Committee (ECCLR) Committee that if the industry is to grow, the “status quo” in terms of regulation and enforcement is not acceptable. It is of the view that urgent and meaningful action needs to be taken to address regulatory deficiencies as well as fish health and environmental issues before the industry can expand.

[ii] RECOMMENDATION 42. The Committee notes concerns expressed in evidence that none of the existing regulatory bodies currently has responsibility for the impact of salmon farms on wild salmon stocks. The Committee believes that clarity must be provided by the Scottish Government as to how this apparent regulatory gap will be filled and which agency will assume responsibility for its management.

[iii] RECOMMENDATION 45. The Committee shares the view of the ECCLR Committee that the siting of farms in the vicinity of known migratory routes for wild salmon must be avoided. The Committee understands that there is at present only limited empirical scientific evidence to suggest that wild salmon are infected by sea lice as they pass salmon farms. However, it is noted that the Norwegian Government has taken the decision to act decisively on this matter. It applies a strict precautionary approach and does not issue licences for salmon farms in the vicinity of wild salmon routes.

RECOMMENDATION 46. The Committee is of the view that a similar precautionary approach must be taken in Scotland to assist in mitigating any potential impact of sea lice infestation on wild salmon. It therefore recommends that there should be an immediate and proactive shift towards siting new farms in more suitable areas away from migratory routes and that this should be highlighted in the strategic guidance on the siting of salmon farms

RECOMMENDATION 47. The Committee recognises that it will take time for the range of current activity by the Scottish Government (e.g. Fish Health Framework initiatives, consenting review) and regulatory bodies (e.g. SEPA finfish sector review) and action on the Committee’s recommendations to be completed, with outcomes known, agreed and implemented. Therefore, until this work is completed and the enhanced regulatory and enforcement regime is in place, the precautionary principle should be applied in a meaningful and effective manner in relation to applications for new sites and expansion of existing site

[iv] Eva B Thorstad, Christopher D Todd, Ingebrigt Uglem, Pål Arne Bjørn, Patrick G Gargan, Knut Wiik Vollset, Elina Halttunen, Steinar Kålås, Marius Berg, Bengt Finstad. (2015). Effects of salmon lice Lepeophtheirus salmonis on wild sea trout Salmo trutta—a literature review. Aquaculture Environment Interactions, Vol. 7: 91–113