Executive Summary – Salmon & Trout Conservation Scotland – 2018 revision – Permission Guy Linley-Adams
100. In the second year of their production cycle, the ten fish farms on Loch Fyne operated by The Scottish Salmon Company can hold a maximum of somewhere between 2½ and 3 million adult farmed fish. This represents a huge population of potential host fish for sea lice, way in excess of any background natural host population of wild salmon and sea trout.
101. Data published by the SSPO and SEPA suggests that average adult female sea lice numbers on the farmed fish in the Loch Fyne farms consistently rise to well over the Code of Good Practice threshold during the second year of production. In each of the last two production cycles, ending winter 2014 and winter 2016 / spring 2017, average adult female sea lice numbers on the farmed fish in the Loch Fyne farms rose to well over the CoGP threshold, reaching levels which seriously threaten wild fish (salmon and sea trout) with high levels of lice infestation.
102. Inspection of the farms by the FHI shows extensive use of a range of sea lice treatments which do not appear to have kept adult female sea lice numbers on the farmed fish below CoGP thresholds. Reports indicate resistance to chemical treatments in sea lice on Loch Fyne and a failure to control sea lice numbers despite the use of wrasse and hydrolicers.
103. Since the announcement to NASCO, in June 2016, by the Scottish Government of a new sea lice management policy for Scottish salmon farming, seven of the ten Loch Fyne farms have breached the new trigger levels of 3 and 8 adult female lice per fish, with the 4 farms breaching the upper trigger level of 8 facing no enforcement action.
104. This presents an unacceptable risk to wild salmon and sea trout populations in and around Loch Fyne, particularly for those smolts that have to pass near these farms when leaving rivers for the first time. For example, in a thorough review of the environmental impacts of salmon farming, commissioned by SPICe, SAMS concluded in 2018 that “there is a gradually emerging body of evidence, from studies elsewhere, that sea lice not only have the potential to have a negative effect on wild salmon, but that in many situations this is likely to be the case… With the currently high marine mortality rate for wild salmonids, and threatened status of many river stocks, any additional pressure, such as increased sea lice burdens, is undesirable, and could further erode the conservation status of vulnerable wild populations”28.
105. Across Scotland, the percentage probability of Scottish rivers reaching salmon Conservation Limits (five-year average 2012-2016), using Marine Scotland Science data from the conservation assessments for 2018 by river and assessment group29, shows a clear impact on the conservation of wild Atlantic salmon in the ‘aquaculture zone’ of the west Highlands and Hebrides of Scotland, with Atlantic salmon populations in rivers in the aquaculture zone far less likely to be reaching Conservation Limits than populations in rivers elsewhere.
106. SAMS also concluded that “the main treatment methods used in Scotland are experiencing reduced efficacy in dealing with sea lice on farms. New techniques are being applied, although the long-term success of these is uncertain. The legislative and voluntary frameworks that underpin the management of lice levels on farms are not transparent. They appear neither to be succeeding in controlling sea lice, nor capable of addressing the environmental effects of the lice”30.
107. In 2009, NASCO adopted ‘Guidance on Best Management Practices to Address Impacts of Sea Lice and Escaped Farmed Salmon on Wild Salmon Stocks’31, developed with and adopted by the International Salmon Farmers Association, which established international goals for NASCO jurisdictions relating to containment and sea lice management. For sea lice, the goal is that “100% of farms to have effective sea lice management such that there is no increase in sea lice loads or lice-induced mortality of wild salmonids attributable to the farms”.
108. However, other recent SAMS research, this time for the Scottish Aquaculture Research Forum (SARF), showed that the negative effects of the use of the infeed treatment, emamectin benzoate (Slice), as widely used on Loch Fyne, have been underestimated and that residues of Slice, excreted by farmed fish and spread into the wider sea loch environment, have had a far greater impact on wild crustaceans than was predicted when Slice was first licenced. In 2017, SEPA stated that it believed that the use of Slice must be phased out by 2018. A revised Environmental Quality Standard for emamectin benzoate is expected shortly, which should markedly reduce the level of Slice that can be used on the Loch Fyne fish farms at the current permitted biomass.
109. Despite SEPA stating in 2005 that it sought “to prevent development of sites which will need to depend upon routine and prophylactic chemical use” to control sea lice, there are also serious concerns with the very frequent use of the organophosphate treatment for sea lice, azamethiphos, on Loch Fyne, which was used for up to 17 days a month on the Loch Fyne farms in 2017.
110. The most recent surveys of benthic pollution under the Loch Fyne farms (organic pollution of the seabed under the sea farms with fish faeces and uneaten feed) show that two of the ten farms, Quarry Point and Ardcastle, are considered ‘unsatisfactory’ by SEPA. Over the last three surveys at each farm, only 4 of the 10 Loch Fyne farms have recorded satisfactory benthic surveys each time.
111. An examination of mortality suffered on the Loch Fyne fish farms shows a strong correlation between mortalities and average adult female lice numbers across Loch Fyne as published by the SSPO. Published data suggests that over one million farmed fish may have died in the Loch Fyne fish farms in 2016 to 2017 with approximately 200,000 fish dying in October 2016 alone. This indicates that the management and husbandry of the Loch Fyne farms is not what it should be at the currently permitted biomass. This is unlikely to be positive for wild fish populations
112. In its March 2018 Report, the ECCLR Committee stated that “the current consenting and regulatory framework, including the approach to sanctions and enforcement, is inadequate to address the environmental issues. The Committee is not convinced that the sector is being regulated sufficiently, or regulated sufficiently effectively. This needs to be addressed urgently, because further expansion must be on an environmentally sustainable basis.”
113. The ECCLR Committee also noted that it was “unclear all agencies are fully discharging their duty in the Nature Conservation (Scotland) Act 2004 to further the conservation of biodiversity with respect to salmon farming” and that “The Committee is unclear if in practice all the public bodies involved in the regulation of salmon farming have the biodiversity duty to the fore. The Committee is not convinced that the precautionary principle underpins the development and expansion of the sector”.
114. Considering the duty under the 2004 Act, and with the words of the ECCLR Committee in mind, S&TCS believes that SEPA should not now grant any applications for expansion of farms or increases in permitted biomass in open cage farms on Loch Fyne and should give urgent consideration to the reduction in permitted biomass and/or relocation of farms (to where!?) from Loch Fyne, in order to protect wild salmon and sea trout, crustaceans and the wider sea loch environment.
115. S&TCS would support a move to closed containment production of farmed salmon in Loch Fyne – maintaining a complete biological separation of farmed fish on the one hand, and wild fish and the wider sea loch environment on the other – which would eliminate many of the problems and issues on Loch Fyne. There is significant research being undertaken in Norway into closed containment technology, and recent analysis by a leading European investment bank states that closed containment farming is now “closer than ever before to being a financially viable alternative to traditional net pens”. In 2018, the ECCLR Committee concluded that it would “like to see the Government and industry fully explore the potential of closed containment”32.
1 SAMS(2018) Review of the Environmental Impacts of Salmon Farming in Scotland January 2018. For the Scottish Parliament Information Centre (SPICe), The Scottish Parliament.
2 An explanation of Conservation Limits, and the probability of rivers meeting them, is available here: http://www.gov.scot/Topics/marine/Salmon-Trout-Coarse/fishreform/licence/status
3 SAMS(2018) Review of the Environmental Impacts of Salmon Farming in Scotland January 2018. For the Scottish Parliament Information Centre (SPICe), The Scottish Parliament.
4 NASCO (2009) SLG(09)5 Guidance on Best Management Practices to address impacts of sea lice and escaped farmed salmon on wild salmon stocks (Adopted in June 2009 and Revised in June 2010)
5 Thorstad, E.B. & Finstad, B. 2018. Impacts of salmon lice emanating from salmon farms on wild Atlantic salmon and sea trout. NINA Report 1449: 1-22. Trondheim, Norway, January 2018 at https://brage.bibsys.no/xmlui/handle/11250/2475746
6 SAMS(2018) Review of the Environmental Impacts of Salmon Farming in Scotland January 2018. For the Scottish Parliament Information Centre (SPICe), The Scottish Parliament.
7 SAMS(2018) Review of the Environmental Impacts of Salmon Farming in Scotland January 2018. For the Scottish Parliament Information Centre (SPICe), The Scottish Parliament.
8 An explanation of Conservation Limits, and the probability of rivers meeting them, is available here: http://www.gov.scot/Topics/marine/Salmon-Trout-Coarse/fishreform/licence/status
9 S&TCS (2018) A critique of the Scottish Government’s new sea lice management policy for Scottish salmon farming. January 2018 https://www.salmon-trout.org/wp-content/uploads/2018/02/A-critique-of-the-ScottishGovernment%E2%80%99s-new-sea-lice-management-policy-for-Scottish-salmon-farming.pdf
11 Wilding TA and Black KD (2015) “A statistical analysis of sea-lice medicine use and benthic monitoring at Scottish marine salmon farms (2002 to 2014)” in SARF098 “Towards Understanding of the Environmental Impact of a Sea Lice Medicine – the PAMP suite”.
12 SEPA (2016) Recommendations to SEPA AMT from Andrew J Rosie, Head of Operations: North, Chair ASMG, Douglas Sinclair, Lead Aquaculture Specialist and Calum MacDonald, Executive Director, (Operations Portfolio) 12th February 2016
18 Scotland’s Aquaculture database at http://aquaculture.scotland.gov.uk/
20 Email Stuart Baird, SEPA, 8th September 2017.
24 Note that the average weight of fish in Furnace Quarry in the autumn 2016, per the FHI inspection, was 2.9kg.