Executive Summary – Salmon & Trout Conservation Scotland – 2018 revision – Permission Guy Linley-Adams
1. In the second year, 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, a huge population of potential host fish for sea lice.
2. Adult female sea lice numbers on the farmed fish on Loch Fyne have risen to well over the Code of Good Practice threshold during the second year of production for the last two production cycles, seriously threatening wild salmon and sea trout with high levels of lice infestation.
3. Fish Health Inspectorate inspections show extensive use of chemical sea lice treatments, resistance to chemical treatments and a failure to control sea lice numbers despite the use of wrasse and hydrolicers.
4. Seven of the ten Loch Fyne farms have breached the new trigger levels of 3 and 8 adult female lice per fish, including four farms breaching the upper trigger level of 8, but facing no enforcement action.
5. This presents an unacceptable risk to wild salmon and sea trout populations in and around Loch Fyne. The Scottish Association for Marine Science (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… any additional pressure, such as increased sea lice burdens, is undesirable, and could further erode the conservation status of vulnerable wild populations”1.
6. 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 group2, shows a clear impact on the conservation of wild Atlantic salmon in the ‘aquaculture zone’ of the west coast 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.
7. SAMS has concluded that “the main treatment methods used in Scotland are experiencing reduced efficacy in dealing with sea lice on farms. …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”3.
8. In 2009, NASCO adopted guidance for sea lice control, the goal being 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”.
9. Recent research showed that the negative effects of the use of the in-feed 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. In 2017, the Scottish Environment Protection Agency (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 Loch Fyne.
10. 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.
11. Surveys of benthic pollution under the Loch Fyne farms 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.
There is a strong correlation between mortalities and average adult female lice numbers across Loch Fyne. Published data suggests that over one million farmed fish may have died in the Loch Fyne fish farms in 2016 to 2017. This indicates that the management of the Loch Fyne farms is incapable of achieving adequate husbandry levels at the currently permitted biomass.
12. In its March 2018 Report, the Environment, Climate Change and Land Reform (ECCLR) Committee of the Scottish Parliament 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…” 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”.
13. 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 from Loch Fyne, in order to protect wild salmon and sea trout, crustaceans and the wider sea loch environment.
14. 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.
The impact of fish farming on wild fish
15. In 2009, NASCO adopted ‘Guidance on Best Management Practices to Address Impacts of Sea Lice and Escaped Farmed Salmon on Wild Salmon Stocks’4, 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”.
16. Since then, fisheries scientists have become increasingly clear that sea lice produced on fish-farms harm wild salmonids, both at an individual and at a population level.
17. Scientists from Norway, Scotland and Ireland have reviewed over 300 scientific publications on the damaging effects of sea lice on sea trout stocks in salmon farming areas, and examined the effect of sea lice on salmon, concluding that sea lice have a potential significant and detrimental effect on marine survival of Atlantic salmon with potentially 12-29% fewer salmon spawning in salmon farming areas. They also note that reduced growth and increased mortality will reduce the benefits of marine migration for sea trout, and may also result in selection against anadromy [migration of fish between freshwater and seawater] in areas with high lice levels. Sea trout may also suffer altered genetic composition and reduced diversity, leading to the complete loss of some sea trout populations.
18. A 2018 review, commissioned by S&TCS from the Norwegian Institute for Nature Research (NINA)5, examined all available research on the impact of sea lice, and concluded that “the combined knowledge from scientific studies provides evidence of a general and pervasive negative effect of salmon lice on salmonid populations in intensively farmed areas of Ireland, Norway and Scotland. … Levels of additional mortality by salmon lice as indicated in several scientific studies may result in salmon stocks not achieving river specific conservation limits and, if sustained over time, could result in significant cumulative reductions in adult salmon recruitment.”
19. The NINA review built on earlier reviews also carried out by NINA on the sea lice impacts on sea trout that were funded by the Norwegian Seafood Research Fund, a body that includes Norwegian fish farming interests. It chimes closely with the findings of the SAMS Report for SPICe, 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”6.
20. In a thorough review of the environmental impacts of salmon farming, commissioned by Scottish Parliament Information Centre (SPICe), the Scottish Association for Marine Science (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”7.
21. The evidence for such an effect in Scotland is increasingly strong.
22. Across Scotland, the percentage probability of Scottish rivers reaching salmon Conservation Limits (five-year average 2012-2016), shown below using Marine Scotland Science data from the conservation assessments for 2018 by river and assessment group8, 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.
23. The science is giving us a very loud warning, but this is not being translated into effective control of fish-farms, which is essential to protect wild fish.
Fish farms on Loch Fyne
24. There are ten salmon farms on Loch Fyne, all run by The Scottish Salmon Company (with permitted maximum tonnage of farmed fish):
Meall Mhor 1345 Glenan Bay 1220.4 Gob a Bharra 1072 Quarry Point 1060 Tarbert South 1030 Ardcastle Bay 1372 Ardgadden 1696 Rubha Stillaig 741 Strondoir Bay 1767.4 Furnace Quarry 450
25. This totals a maximum of just under 12,000 tonnes of farmed fish across Loch Fyne. At an average second year of production weight of 4kg per fish, this suggests that a maximum of between 2.5 and 3 million adult fish can be held in Loch Fyne’s fish farms.
Sea lice and on-farm biomass on farmed fish in Loch Fyne 2015-2017
26. Analysis of the control of sea-lice on Scottish fish-farms has been severely hampered by the lack of farm-specific sea lice data. Only aggregated sea lice data is published for 30 regions, some three months in arrears.
27. Contrast the Scottish position with the depth of data available about Norwegian farms, where real time data concerning the different life stages of, and treatments for sea lice on the farmed fish is publically available online. See https://www.barentswatch.no/en/fishhealth/. Also see below for example page.
28. The ECCLR Committee report in March 2018 on the environmental impacts of salmon farming recommended that sea lice data should be published on a farm by farm basis and stated that:
“For that data to be most useful the Committee considers there should be no unreasonable delay in its publication. The industry should be required to publish it in real time. Data should be published in a consistent and comparable basis and should include numbers of fish and action taken in response. This information would advance the science and solutions available to the industry. The industry should also be required to publish consistent and comparable weekly historic data sets on sea lice figures on a farm by farm basis from the time records are available. There should be no delay in the industry publishing this information so this should initially be published on a voluntary basis by the end of April 2018.
The Committee also considers that the industry must be required to publish data on salmon mortality on a farm by farm basis and publish accompanying information on disease issues that might be associated with that mortality. The industry should also be required to publish consistent and comparable weekly historic data sets on salmon mortality on a farm by farm basis from the time records are available. There should be no delay in the industry publishing this information and so this should also initially be published on a voluntary basis by the end of April 2018”.
29. The ECCLR Committee also concluded that reporting should be a statutory obligation to ensure transparency and facilitate public access to information, particularly as not all salmon farmers are members of the SSPO.
30. Nevertheless, S&TCS has analysed the aggregated data published in Scotland by the Scottish Salmon Producers’ Organisation (SSPO) since 2013.
31. Analysis of that aggregated sea lice data from the Loch Fyne region, as against monthly biomass figures for each of the Loch Fyne farms, published by the SEPA, shows that sea lice levels on the Loch Fyne farms were, on average, way above industry Code of Good Practice thresholds in both of the last two production cycles, with adult female sea lice numbers peaking towards the end of production cycles, at the worst possible time of year for wild salmon and sea trout smolts:
32. Note that in March 2018, the ECCLR Committee stated that “The committee considers there should be a mandatory requirement to keep sea lice levels within those identified in the Code of Good Practice”. As the graph above shows, the Loch Fyne farms have consistently failed to achieve anything approaching that in the two production cycles since 2014.