The Marine Conservation Society needs to re-evaluate its position on farmed salmon

By James Merryweather – An e-mail sent to MCS 29 March 2018

Dear MCS,

As an MCS member, I am increasingly disheartened by your constantly feeble attitude to farmed salmon. Some while ago I wrote to Dawn Purchase on the matter without much success. If you don’t specifically recommend farmed salmon as food, you certainly make no attempt to condemn it. In the latest edition of the magazine, so-called ‘organic’ farmed salmon is given the green light of recommendation for eating. Although the Soil Association awards accreditation to organic salmon farms, ‘organic’ really doesn’t work for salmon farming (also see * below). To illustrate, here is a passage from a recent comment letter I submitted to consultations on two ‘organic’ fish farm proposals for north Skye:

Recently revised Soil Association (SA) aquaculture standards (2016) include:

  1. A prohibition on the use of organophosphate or avermectin-based [e.g. emamectin benzoate] veterinary medicines due to their detrimental effect on the aquatic environment, including sediment-dwelling organisms.

One might express one’s amazement that the SA would at any time ever have permitted the use of organophosphate or avermectin-based pesticides and become suspicious that SA regulations for organic salmon are not as demanding as those with which we have become familiar in terrestrial food production. We then, of course, ask why? (also see * below). For instance, how does the applicant intend to control sea lice, an inevitable and increasing problem? Will they be applying chemical treatments? Are ‘organic’ chemical treatments available? If so, do they work? I doubt it, otherwise the rest of the industry would be eagerly using them.

The applicant could claim that biological sea louse control will be employed instead of chemical treatment. That would mean cleaner fish (wrasse and/or lumpsucker), which are not available from farmed supplies, but are being harvested live in vast numbers from the wild all around the UK coast. MCS is aware of this. That fishery has simply emerged recently in response to industry demand. Its impacts remain unresearched, and therefore unknown, and mass wrasse trapping continues without regulation or industry conscience.

Until they can be farmed, cleaner fish cannot be a valid replacement for chemical sea louse control, which in itself is highly undesirable. Sea lice generate a monumental dilemma for salmon aquaculture, conventional or organic.

I note, from the applicant’s Environmental Statement part 1B:

“Organic Sea Harvest [OSH] intends to apply to SEPA for CAR licences for the use sea lice medicines on the site, these treatments and the methods of application are described in more detail in Section 6.2. It is intended that treatments be limited in accordance with Organic Standards [How, when those treatments were banned by the SA in 2016?] but that licences are in place to allow for additional treatments if required to switch to conventional farming. Modelling has been carried out for the infeed treatment, Slice, with the active ingredient Emmamectin [sic] Benzoate (EMBZ), using the AutoDepomod model.”

“SEPA model BathAuto was used to model the inputs of the bath treatments Azamethiphos, Cypermethrin and Deltamethrin in accordance with the methodologies required by SEPA.”

So, it would seem preparation has already been set in place for conversion from organic to conventional methods of sea louse control. Invasion of the farm by sea lice is not just possible, but highly probable. There are no organic sea louse treatments, so the use of chemicals or bad-practice biological control will be essential if the farm is to succeed at all. In the long (or shorter) term, these fish farms are most unlikely to maintain their organic status.

It is surely significant that, even if the applicant intends initially to farm salmon according to organic standards: “It is recognised that if the farm breaches the Organic Standard there may be the need to farm under conventional farming methods.” That is a significant let-out cause, likely to be overlooked by the public, impressed as they are by the consistently publicised promise of an ‘organic’ fish farm (and lots of money) throughout the preparation of this planning application.

The only way salmon aquaculture is likely to overcome its dependence on horribly toxic chemical remedies will be conversion to Recirculating Aquaculture Systems i.e. farming in tanks, not in nets at sea, a method fraught with environmental problems. The arguments against net-cage salmon farming are legion and because organic methods cannot be realistically maintained, nobody should be recommending net-cage farmed salmon of any sort, no matter how apparently ‘sustainably’ produced the producers boast.

* MCS, please note the number of members of the standards committees of the Soil Association (11/17) and the RSPCA (20/23) HERE who are also representatives of the aquaculture industry: ‘inmates put in charge of the prison’. The RSPCA protests that they require the specialist expertise, but it is hardly unreasonably cynical to suspect the motives of these people. One of the SA committee members (Alex Macinnes) is on the board of Organic Sea Harvest (north Skye planning applications, above) and is also – I am told – a candidate for the Highland Council, to take his place alongside one of his fellow board members, already a councillor, while the third board member, from the parent company Villa Seafood, is also on the SA committee. I think we should be very uncomfortable with this situation.

The only farmed salmon MCS should be recommending is being produced by a small number of overseas RAS companies (e.g. Kuterra) and, as far as I know, not available in the UK. Wild Pacific salmon is available here, but I am unsure of the sustainability of the fisheries. Maybe MCS has a better grasp of that?

Soon, RAS facilities will be farming Atlantic salmon in the USA, Norway and China, while the Scottish Government’s Environment, Climate Change & Land Reform committee has recently acknowledged conversion to RAS in the UK should be considered as a matter of urgency. At the same time that committee at last provided vindication of all of the objections that we the public have been raising for years, published for all to read in the aforementioned report. That is important progress that MCS should be checking out and will – we hope – soon be celebrating.

Yours sincerely,

James Merryweather.


One thought on “The Marine Conservation Society needs to re-evaluate its position on farmed salmon

  1. Hi James, I am enjoying your blog. Have you got an email address I can contact you on? I run a fishing group called Wet Your Knot and I wonder if there is a potential collaboration where we can help push some of the main topics your blogging about…


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