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Background Info

Wild salmonids in the ‘aquaculture zone’ on the west coast are in trouble. In 2015, the Scottish Government published the latest classification of the country’s salmon rivers’ salmon populations, placing all rivers in the west Highlands and inner Hebrides, including river systems such as the Awe and the Lochy, in the worst-performing category, with wild salmon stocks not reaching their conservation limits (a measure of the overall health of the population). No river within salmon farming’s heartland of the west Highlands and inner Hebrides has, in Scottish Government’s estimation, a sufficient stock of wild salmon to support any exploitation.

Fisheries scientists are increasingly clear that sea lice produced on fish-farms harm wild salmonids, both at an individual and at a population level. Also this year, fisheries scientists from Norway, Scotland (St. Andrew’s University) and Ireland 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.

The researchers concluded that:

"Salmon lice in intensively farmed areas have negatively impacted wild sea trout populations by reducing growth and increasing marine mortality. Quantification of these impacts remains a challenge, although population-level effects have been quantified in Atlantic salmon by comparing the survival of chemically protected fish with control groups, which are relevant also for sea trout. Mortality attributable to salmon lice can lead to an average of 12−29% fewer salmon spawners. 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. Salmon lice-induced effects on sea trout populations may also extend to altered genetic composition and reduced diversity, and possibly to the local loss of sea trout, and establishment of exclusively freshwater resident populations."

However, this is not being translated into effective control of sea-lice on fish-farms, which is essential to protect wild fish.

Although analysis of the actual control of sea-lice on Scottish fish-farms is severely hampered by the lack of farm-specific sea lice data, S&TCS has analysed data published by the Fish Health Inspectorate, the Scottish Environment Protection Agency and the Scottish Salmon Producers’ Organisation covering 2013 to 2015. That analysis, published by the S&TCS in a recent report and circulated to all stakeholders, provides strong evidence to confirm that sea lice numbers on fish farms continue to rise to unacceptable levels, particularly during the second year of production on many farms, threatening wild salmonids.

Unsurprisingly perhaps, average adult female sea lice numbers per farmed fish appear to be linked to the cumulative biomass of farmed fish held on the farms - the greater the tonnage of farmed fish the more adult female sea lice and the greater the production of free-swimming juvenile lice into the surrounding sea lochs. In much of the production of farmed salmon in Scotland and the Western Isles, adult female sea lice counts per farmed fish have risen often to levels well above industry Code of Good Practice (CoGP) thresholds, where they can remain for many months. This is not the case in just a few isolated cases – the regions examined by S&TCS account for over 40% of production in Scotland and the Western Isles.

There is also considerable evidence of failures between 2013 and 2015 of available chemical sea lice treatments to limit sea lice numbers on farmed fish to below CoGP thresholds, strongly suggesting that resistance and tolerance to these treatments is now becoming widespread. Nor does the use of wrasse as cleaner fish appear to be the panacea it is often held up to be. Worryingly, there is some evidence of a failure to treat for sea lice on farmed fish despite sea lice numbers being over CoGP thresholds, contrary to CoGP requirements, and of the failure by fish-farmers to treat sea lice near the end of production cycles, both suggesting that insufficient consideration is being given to the consequent negative effects on wild salmonids. Where there is evidence of early harvest or culling out of farmed fish, this appears only to be associated with unacceptable damage being caused to the farmed fish, causing either commercial losses or animal welfare issues for the farmed fish, rather than this occurring in order to protect wild fish.

The S&TCS report makes a number of recommendations for the future, many of which flow from evidence given to the RACCE Committee in 2013.

The major barrier to proper scrutiny of the fish farms - the lack of published farm-specific sea lice data - needs to be removed and further information concerning newer control methods for sea lice should be recorded and published to ensure that a complete picture is obtained of the sea lice control methods used at any particular farm. In 2013, at the time of the passage of the Aquaculture and Fisheries Bill through Holyrood, when arguing for full disclosure of sea-lice data, MSPs asked the question 'what has the salmon farming industry got to hide?' The S&TCS report strongly suggests that the answer to that question is very poorly-performing fish-farms.

While accepting the voluntary publication of aggregated sea lice data by the fish-farming industry, the then Minister, Paul Wheelhouse MSP, in his evidence to the RACCE Committee committed the Scottish Government "to keep the matter under close review".  That review must now lead to full publication of farm-specific sea-lice and sea-lice control data, which the Minister can achieve by amending the Aquaculture and Fisheries (Scotland) Act 2007 to require the full publication of farm-specific parasite counts and full details of all sea lice control methods employed at each fish-farm as currently required to be kept under The Fish Farming Businesses (Record Keeping) (Scotland) Order 2008.

The industry also now requires tougher regulation. Back in 2007, the Committee examining the then Aquaculture and Fisheries (Scotland) Bill considered that any approved Code of Practice should reflect best practice rather than be the 'lowest common denominator'. The Committee also considered "that compliance with the Code should be monitored, and that there should be a regular review of its effectiveness as a legislative backstop to the voluntary arrangements already in place". The S&TCS report shows that the time has come for a Government-led review leading to the CoGP being made a statutory code, as provided for in the Aquaculture and Fisheries (Scotland) Act 2007, with the express purpose of protecting wild salmonid (salmon and sea trout) populations from potential harm caused by marine cage fish farming.

S&TCS suggests that an ‘upper-tier’ sea lice threshold should be introduced, above which an immediate cull or harvest of farmed fish is mandated. It should no longer be possible for fish-farmers, where sea lice numbers have effectively gone out of control on their farms, to assert that they remain in compliance with the CoGP, as they currently can. S&TCS also believes that the Scottish Government should now accept that wild fish are not sufficiently protected in domestic law and should amend legislation with the express purpose of protecting wild fish from potential damage caused by fish-farms, with inspectors given a legal duty to control sea lice on fish-farms, again expressly in order to protect wild fish populations.

This can be achieved by amending  the 2007 Act to give the Fish Health Inspectorate a statutory duty to inspect and otherwise enforce sea lice control on marine cage fish farms for the express purpose of protecting wild salmonid fish from juvenile sea lice infestation from marine cage fish farms, and provide the FHI with statutory powers to order immediate culls and/or early harvest of any marine cage fish farm where average adult female sea lice numbers of farmed fish remain persistently above CoGP thresholds.

Over the medium term, S&TCS considers that those farms consistently failing to control sea lice should be considered for closure and / or relocation. The 2008 relocation programme was allowed to run into the sand. The Scottish Government must now return to that process and move the worst performing farms away from salmonid rivers and migration routes.

Finally, S&TCS believes the evidence supports the need for a renewed focus on moving to full closed containment of farmed salmon production in Scotland, with complete 'biological separation' of wild and farmed fish.