Frustration at Holyrood
The Scottish Parliament’s Rural Affairs and Islands (RAI) Committee has almost completed its series of hearings for its inquiry into the Scottish salmon industry, following up its earlier report (2018) to the Scottish Parliament recommending reforms. What have we learned and how soon can we expect the committee’s findings? Sandy Neil reports.
One word kept recurring in the Holyrood inquiry into Scotland’s salmon farming industry, following up on progress since the last one in 2018: “disappointing”, even bordering on “depressing” for the MSP who led it.
Back in November 2018, MSPs on the then Rural Economy & Connectivity Committee (RECC) said urgent action needed to be taken to improve the regulation of the industry and to address fish health, and environmental challenges.
At the time, the RECC set out 65 recommendations about how problems, such as the control of sea lice, rising fish mortalities, and the need to reduce the sector’s impact on the environment, should be tackled.
Earlier this year the RECC’s successor at the Scottish Parliament, the Rural Affairs and Islands Committee (RAIC), launched a follow-up inquiry to ask whether recommendations from the 2018 inquiry had been implemented.
Evidence sessions began in June, and the last one, hearing from the Cabinet Secretary for Rural Affairs, Land Reform and Islands, Mairi Gougeon, is due on Wednesday 13 November, and the committee’s final report is expected by the end of the year.
You can read our many reports at www.fishfarmermagazine.com, from 5 June when MSPs heard the case against salmon farming, 12 June when the Fish Health Inspectorate spoke of “improving” sea lice control, as well as a controversial fact-finding trip on 23 September and the denial of a “cover-up” of dead fish on 2 October. But in the magazine this month, we focus on the progress (or lack of) revealed in the three hearings, about research and regulation on 19 June, declining wild salmon on 26 June, and planning changes on 18 September.
For a neat summation of everything said so far though, we can turn to 26 June, when the RAIC’s Convener, Finlay Carson MSP (Galloway and West Dumfries, Conservative), asked John Goodlad, Chair of the Salmon Interactions Working Group: “What is your broad assessment of progress on implementing the recommendations of the reports of the RECC and the Salmon Interactions Working Group?”
Goodlad replied: “Our group came up with around 40 recommendations and, as far as I am aware, the only one that has really been acted on is the one about the sea lice framework. We spent a lot of time and effort producing a lot of recommendations, so it is disappointing that so little progress has been made.”
Carson also asked Dr Alan Wells, Chief Executive of Fisheries Management Scotland, the same question. Dr Wells agreed: “It is disappointing there has been so little progress on those two reports.
“It was an excellent example of collaboration between the wild and farmed sectors. We got the right people round the table, with a shared determination to come up with recommendations that were designed to improve the situation.
“I am strongly of the view that, once delivered, those recommendations would greatly improve the situation. Unfortunately, despite an initially positive response to the report, the Scottish Government has not taken the opportunity to act on the majority of those recommendations, which is pretty disappointing.”
It was then the turn of the RECC’s former convener, Edward Mountain MSP (Highlands and Islands, Conservative), to ask Goodlad: “I have read your report, which I think was published in May 2020. You will be as proud of it as I am of the RECC’s report, which had 65 recommendations. Do you think that I am right to be disappointed that few of those recommendations have been implemented?”
Goodlad replied: “As someone who chaired a committee that produced a report whose recommendations have largely not been implemented, I am disappointed, so I imagine that you are absolutely right to be disappointed, too.”
Disappointment may, therefore, feature in the final report.
Christine Lawson and Nick Owens of SSAC
A changing regulatory landscape
Overall MSPs asked a great number of questions, and speakers answered in great detail, enough to fill an entire magazine issue, so in this month’s report we shall focus on any progress revealed in three hearings, starting on 19 June. At this session, the RAIC discussed a report by the Scottish Science Advisory Council (SSAC), titled Use of Science and Evidence in Aquaculture Consenting and the Sustainable Development of Scottish Aquaculture, published last year.
The RAIC Convener, Finlay Carson MSP, began: “One of the RECC’s recommendations was to identify significant gaps in knowledge, data analysis and monitoring, but your report also identified a gap in funding for policy-driven research on aquaculture. Do you think that there remains that gap in funding but also a lack of co-ordination on research and the funding that ties it together?”
The SSAC’s Professor Nick Owens, said: “Yes – most certainly. Given the value of the industry to Scotland and the Scottish economy, our understanding and belief are that there really should be more funding available. The whole issue of getting scientific advice, using it properly and getting it communicated properly is very much influenced by the lack of co-ordination.
“On who should pay for the research, it is not unreasonable to say that the industry itself should pay, as happens in Norway, through various mechanisms such as levies. The industry contributes, but perhaps there is something to be said for looking at that further.”
Beatrice Wishart
Another challenge was raised by Beatrice Wishart MSP (LD, Shetland Islands), who asked Prof Owens: “The Griggs review identified ‘mistrust, dislike, and vitriol … between the industry … regulators, parts of the Scottish Government and other stakeholders’. Your review found that ‘science on aquaculture … is not sufficiently visible’ and that there was ‘a lack of shared arenas for voicing concerns and dialogue which continues to fuel a perception of secrecy and misunderstandings’. Will you expand a wee bit on the challenges that your review identified?”
Professor Owens replied: “There is no doubt that lack of trust is still there. I suspect that, whatever one could do, there will always be an element of that, because people will take, and have taken, entrenched views. The view out there is incredibly binary.
“Research is being done on how to communicate and engage effectively with communities that hold differing views. Using the mechanisms that exist, there is definitely a route by which we can at least try to make an improvement in bringing the two communities together.”
Lin Bunten
It was then the regulator’s turn in the hot seat. Lin Bunten, Chief Operating Officer for Regulation, Business and Environment at the Scottish Environment Protection Agency (SEPA), spoke of “significant progress”.
“We were in complete agreement that the status quo was not an option,” she said. “The committee’s subsequent report highlighted 65 recommendations, 22 of which involved SEPA in their implementation.
“Since 2019, all new and expanded farms have been regulated under the enhanced framework and, by the end of this year, we plan to have completed the roll-out of the same standards to all remaining operational farms.
“The regulatory landscape has been simplified to provide greater clarity. That includes the transfer to SEPA, in 2020, of wellboat medicine discharge regulation and, in February this year, of responsibility for managing interactions between sea lice from fish farms and wild salmon.
“We are starting to see the impact of the changes. They are helping developers to identify the most suitable locations for new farms that better align to where there is environmental capacity to accommodate them. That is noticeable in the emerging trend of a smaller number of larger farms in more dispersive coastal areas.
“In 2023, we inspected 120 sites, whereas this year we plan to inspect 112 sites. We are inspecting roughly 60% of operating sites annually, and every data return made by every farm operator from every site is checked for compliance. This year, we plan to undertake 22 sea bed surveys.
“Completing the roll-out of the framework is a really big step and means that, as farms undertake the enhanced monitoring over the next two to three years, we will have a fuller understanding of the impact of those farms.”
Ariane Burgess MSP (Highlands and Islands, Scottish Greens) then asked: “How have the regulatory changes that have been made since the RECC’s report impacted on chemical use and waste arising from fish farms?”
Aquaculture specialist Mike Montague replied: “Over the past 10 years, we have seen a decline in the amount of medicines that are used on farms, and that has probably stabilised a bit over the past five years. Our remit is to use the environmental standards to set limits on a site-by-site basis. We set limits and, if the operator stays within those limits, the impact on the environment is at a scale that is deemed acceptable.”
Burgess asked: “So, you are saying that the 210 farms will have different limits on the medicines that they can use, depending on circumstances such as their location. How many farms are still using emamectin benzoate in the same quantities as in 2018?”
Montague replied: “It is fair to say that the bulk of the operational farms are still on the standard from 2018. Since the UK technical advisory group process identified a new standard, it has been applied to new and changing sites, but we await Scottish Government direction on implementing it for existing sites.”
Burgess, expressing surprise use had not reduced, concluded: “Urgent action was called for in 2019, I think, and we are now quite a long way off from that.”
Emma Roddick MSP
Emma Roddick (Highlands and Islands, SNP) then asked: “What is SEPA doing to improve data transparency?”
Bunten replied: “The information is published on the Scotland’s Aquaculture website. That information has grown in volume and subject matter over the period since 2019.” Montague elaborated: “We now publish information on all medicine use, biomass compliance and the outcomes of the sea bed surveys.”
Edward Mountain
The former RECC convener, Edward Mountain MSP, asked: “Recommendation 51 of our ‘Salmon farming in Scotland’ report asked for priority to be given to creating ‘a spatial planning exercise’ to see where salmon farms could and could not go. Do you have a map of the waters around Scotland showing where it is suitable to have aquaculture and where it is not? That is what the recommendation called for.”
Bunten replied: “The answer is no.”
Mountain commented: “And that is five years later. Recommendation 10 of the RECC Committee’s report is that ‘there should be a process in place which allows robust intervention by regulators when serious fish mortality events occur’. Last year, mortality at Kishorn farms A, B and C over three months varied from roughly 37 to 43 to 48%. That is nearly 50% of the fish in one of those farms dying in a three-month period.
Did you inspect them? What was the outcome of that inspection?”
Montague replied: “Mortality is not within our regulated remit. Effectively, we do not have a role in that place.”
Mountain said: “So, you have no role in worrying about mortality and the effect that that will have on the environment?
Bunten answered: “The dead fish are removed from the environment. Our role is very much about protecting the water environment.”
Mountain asked: “Do you have any idea why those deaths happened? If it was to do with gill health, the transmitter of poor gill health would have had an effect on the rest of the environment, would it not?”
Bunten replied: “There is another body that has responsibility in that area.”
Mountain commented: “That probably demonstrates the fact that it is unclear who should be doing what.”
Fish farm, Isle of Skye
Salmon interactions
The next RAIC hearing on 26 June focussed on the interactions between wild and farmed salmon. The Convener Finlay Carson asked John Goodlad of the Salmon Interactions Working Group: “This topic can be very polarising. There needs to be a balance between commercial interests and the huge importance of the wild salmon population.
“In your report, you say that ‘developing a professional and collaborative working relationship’ in that is really important. That does not appear to be working at the moment. Have you any ideas about how the arguments could become less polarised?”
Goodlad replied: “We absolutely have to have greater discussion and try to find common ground. Salmon farming is an incredibly important industry and has a bright and prosperous future. Wild salmon stocks are in a dreadful state; they are now on the endangered species list. However, the simple conclusion that one is causing the other is not the case.
“The wild fish sector has two main concerns – which are legitimate – about fish farming. The first is sea lice. As smolts swim past fish farms, they may become infected with sea lice. Secondly, there is the risk of escapes and genetic introgression. It has been put to me that, given that wild salmon stocks are at such a low and, indeed, endangered level, genetic introgression is probably a worse potential problem than ever. However, on the other hand, escapes are probably at as low a level now as they have been for many years.
“The honest answer is that no one really knows why wild salmon have declined so drastically. Twelve reasons have been put forward, and we referred to those in our report. Clearly, fish farming is one that gets a lot of attention – rightly – but there are, perhaps, 11 other reasons. Much work needs to be done on all those areas.
“If I was asked to place my bets on the main factor leading to wild salmon decline, I would say that it is happening in the north Atlantic. The salmon smolts go to sea and feed in the waters between the Faroe Islands, Iceland and Greenland; however, something is happening out there.
“Climate change has resulted in two things happening with the western mackerel stock. First, the western mackerel stock biomass is now at record levels. What had been 2.5 million tonnes of western mackerel historically is now around four million tonnes.
“Secondly, the stock has moved northwards. The mackerel fishery used to be off Cornwall and the Western Isles, but now Shetland is the southern part of the main fishery, with the fishery itself mostly around the Faroe Islands and Iceland. Mackerel eat exactly the same things that salmon eat – capelin and crustaceans – while large mackerel also eat small salmon. How many smolts does four million tonnes of mackerel biomass eat in a year?
“In my view, that is probably the main reason for the decline in salmon, but it is out of sight and out of mind and very difficult to ascertain, whereas fish farming is very obvious and very much in people’s sight.
“There is a huge sense of disappointment on the part of the interactions working group that there was this focus on the interaction between wild salmon and fish farming.”
Ariane Burgess MSP
Concern over mortalities
At the next hearing on 18 September, Ariane Burgess MSP focused on the RECC’s recommendation from 2018 noting “too high” mortalities across the sector and calling for no expansion of sites which report high or significantly increased levels, unless cleared by regulators.
Since then, Burgess said, salmon deaths have risen higher. “Throughout these evidence sessions, we have heard about high mortality,” she said. “One example is of a salmon farm in Loch Seaforth in the Western Isles, where more than a million fish died in a production cycle in 2023, and the level of suffering carried on for six months without any consequences.
“Already high levels of mortality are increasing – possibly due to climate change but maybe for other reasons – but nobody in the process seems to be responsible for the mortalities. We cannot quite get to the bottom of it. Do you have any thoughts on that and on what we can do about it?”
Mark Harvey, Planning Team Leader, Highland Council, replied: “Undoubtedly, environmental factors are emerging, or have emerged recently, in relation to gill disease on fish. In fact, that issue has probably overtaken by a long measure the health effects of sea lice. However, it would be difficult for planning to take that into account.”
The former RECC convener Edward Mountain MSP asked: “I take you to recommendation 53, on the relocation of fish farms where it is clear that they are a problem. How many planning applications has Highland Council received, considered and actioned for the relocation of fish farms because they are a problem at their existing site?”
Harvey replied: “I do not think that we have reached the first stage yet, because we have not identified where there are problematic fish farms. That is another aspect of the framework that might be particularly useful, because SEPA might well be able to identify such farms, in which case we would certainly take a view on relocation.
“How different an application for relocation is from an application for a new fish farm is another matter. We do not control whether a company wants to close down an existing fish farm, although that might be what SEPA requires. We would obviously look at a fresh fish farm application in much the same way as we would any other application.”
Mountain commented: “Do you know how depressing that is for me? I sat on the predecessor committee in 2018 when it recommended that poorly sited fish farms should be relocated to take away the threat in relation to their production from high mortality levels and their effect on wild fish where the farms are sited on existing migratory routes, and now you are telling me that, six years later, that has not been implemented.
“I will leave it there, Convener, because I may get more depressed as my questioning continues.”
