The Salmon Interactions Working Group (SIWG) report was published in May 2020. As reported on this site, the Scottish Government’s response to it came out in October this year, around a year and a half later.
The reason for the delay might not simply be related to the effect of the Covid-19 pandemic. Politically the SIWG is something of a hot potato.
It is beyond debate that the numbers of wild salmon have fallen dramatically over the last 50 or 60 years and this continues to be a cause for concern.
Salmon face a number of challenges, but the SIWG was asked to focus on risk in particular – the interaction between wild and farmed salmon. Many argue that the presence of salmon farms poses a threat to their wild counterparts. In particular, there is concern over sea lice, which can grow in numbers when there are farmed fish and which can also affect migrating wild salmon; over diseases, especially when fish stocks are moved from one region to another; and over escaped fish interbreeding with wild salmon. Farmed salmon are bred to grow faster and larger, and they may also be selected for increased resistance to diseases, but they are likely to lack some of the traits necessary for survival in the wild and this disadvantage might be passed to their offspring.
The SIWG brought together representatives from the wild salmon lobby, representing conservation organisations and fisheries management bodies, as well as the fish farming industry.
The group was chaired by Shetlander John Goodlad who, as a former salmon farmer and an adviser on the wild salmon issue to the Prince of Wales’ International Sustainability Unit, arguably had a foot in both camps.
Goodlad told Fish Farmer: “I would like to pay tribute to both sectors – the wild salmon sector and the fish farmers – for their work on the report.”
He broadly welcomes the Scottish Government’s response: “Although it took longer than expected, it has gone further than many expected.”
He added: “I was broadly pleased – the Government has agreed to take action on sea lice, with SEPA [the Scottish Environment Protection Agency] as the lead body; and on escapes.
“I would add two qualifications: first that the response must be followed up with action in the near and medium term; and also that it is really important, now, that the Government addresses all of the other pressures that are impacting on wild salmon.”
The SIWG report called for the reform of Scotland’s finfish aquaculture regulation. In response the Scottish Government is proposing that SEPA takes on more powers as the lead regulator, while District Salmon Fishery Boards will continue to be statutory consultees.
SEPA’s oversight of the sector will include applying a new “spatially based risk assessment framework”, which is still in the process of being drawn up. A consultation on the framework is expected by the end of this year.
Existing fish farms could also be forced to relocate if their position is seen as posing an unacceptable risk to wild salmon.
Tavish Scott, Chief Executive of Salmon Scotland (formerly known as the Scottish Salmon Producers Organisation), also welcomed the Scottish Government’s response, but added that the salmon industry was “puzzled” by the announcement of a shakeup of the regulatory regime while the working group considering ways to improve it was still ongoing.
Scott said: “The Scottish Government appointed Professor Russel Griggs to undertake a thorough review of fish-farm regulation. Professor Griggs is still taking evidence and has not even published his first report.
“Yet, despite this, ministers have decided to give SEPA a key new regulatory role.
“We will continue to have a dialogue with ministers on this and other aspects of the report while remaining committed to working with conservation bodies to find out what is really happening to Scotland’s wild salmon stocks.”
Salmon Scotland has committed to investing £1.5m in projects, through the Wild Salmonid Support Fund, to protect wild salmon and to investigate what is behind the decline in numbers. One of the key projects is a study, organised by the Atlantic Salmon Trust, to track juvenile salmon as they head out to sea from fresh water.
Scott told Fish Farmer: “We are all after the same thing – to understand what is happening to wild salmon populations and to gather scientific evidence. It has worried us that there is currently a lack of evidence.
“The pressures come from a combination of factors – which the Scottish Government has already identified – but we all need to understand, based on evidence, what policies are required to address them.”
He hopes that the Wild Salmon Strategy report, which is expected to be published in December this year, will shed more light on the issue.
Last year the SIWG report acknowledged 12 “high level” pressures on salmon populations in Scotland – of which interaction with fish farms was just one. Others included exploitation (illegal and legal netting, rod and line; predation by birds, fish and marine mammals; disease and sea lice; genetic introgression (escapes); habitat and water quality; climate change; barriers to migration; and the impact of human activity at sea including inshore fisheries and offshore renewable energy installations.
The Missing Salmon Alliance – a consortium that includes the Game & Wildlife Conservation Trust, the Atlantic Salmon Trust, the Angling Trust with Fish Legal, The Rivers Trust and Fisheries Management Scotland – is developing a “Likely Suspects” framework to help identify key factors.
On its website the Alliance states: “There are a number of candidate “suspects” that impact on salmon survival, ranging from the obvious (e.g. being eaten by something) to the less obvious (e.g. poor feeding due to water temperature changes). We all hold opinions as to which “suspects” are probably responsible for salmon losses, but salmon management actions need support based on more than just strength of opinion.”
The salmon industry and some conservation bodies appear to be making efforts to find common ground, but meanwhile others are taking a harder line. On 13 October the Salmon & Trout Conservation Trust – which is not a member of the Missing Salmon Alliance – set out its new position: “…all open-net salmon farming in Scotland must now be brought to an end as soon as possible.”
Andrew Graham-Stewart, Director of Salmon and Trout Conservation in Scotland (S&TCS), said: “We have engaged with successive Scottish governments and regulators for over 20 years in efforts to persuade them to introduce effective regulation of salmon farming, particularly to protect wild salmon and sea trout from the devastatingly negative impacts of sea lice proliferation.
“The response has been little more than lip-service while enabling the industry to expand production exponentially, exacerbating all the environmental problems associated with open-net farming. Scottish Government’s recent announcement of a two-year review of regulation, yet another delaying tactic, and its endorsement of the fundamentally inadequate Salmon Interactions Working Group’s report, amount to conclusive confirmation that it has no intention of introducing meaningful reform. We have reached the end of the road.”
The debate is clearly far from over, but with the Griggs review, a new framework to guide planning, the Wild Salmon Strategy and a review by Crown Estate Scotland into how marine leases should be allocated all expected within the next few months, the regulation of aquaculture in Scotland could look quite different by this time next year.