MSPs' verdict on salmon industry: must do better
The MSPs who carried out an inquiry into the Scottish salmon industry say they still may call for a pause on growth if the Scottish Government cannot show faster progress on implementing reforms, reports Sandy Neil.
A Holyrood inquiry into fish farming in Scotland has rejected calls for a moratorium on new and expanded sites – for now.
That will be dependent, however, on whether the Scottish Government can show progress on its recommendations, and those from an earlier inquiry, within a year.
In January nine MSPs on the Scottish Parliament’s Rural Affairs & Islands Committee (RAIC) concluded their follow-up inquiry, focussing on four themes of fish health and welfare, environmental impact, interactions between wild and farmed salmon, and the location of fish farm sites.
The evidence sessions ran from June to October 2024 (you can read our reports in past editions at www.fishfarmermagazine.com/e-editions).
The committee was checking up on progress from an earlier inquiry in 2018, conducted by its predecessor, the Rural Economy & Connectivity Committee (RECC), which ruled urgent action was needed to improve regulation and address fish health and environmental challenges, and set out 65 recommendations.
Now the new inquiry has revealed its findings, and is calling for an “immediate timetable to address concerns over the long-term viability of the salmon farming industry in Scotland”.
The committee’s overarching conclusion, it says, is that: “The slow rate of progress in improving the regulation and enforcement of the Scottish salmon farming industry needs to be addressed as a matter of urgency, to future-proof the industry and enable it to grow sustainably.”
It calls for “stronger leadership” from the Scottish Government, and “requests a clear timetable be provided setting out how both the outstanding 2018 recommendations, and its own recommendations, will be implemented within the next year”.
The committee also asks the Scottish Government “to set out how implementation will be measured and for dedicated ministerial oversight of the workstream to drive delivery”.
It will revisit progress made on issues raised in the report in one year and may make further recommendations at that time.
The Convener of the RAIC, Finlay Carson MSP, summed up: “We recognise the importance of the salmon farming industry to the Scottish economy and the jobs it supports in many rural and island communities.
“We also realise the efforts made by the industry to invest and innovate to overcome the new and unpredictable challenges it faces.
“But further progress should have been made in implementing the RECC’s recommendations of 2018, as well as anticipating the impact of climate change and rising sea temperatures on the industry. This would have helped address some of the polarised views the industry is currently facing in relation to the production process.
“Ultimately, it is the Scottish Government’s role, as well as the industry’s, to drive the change agenda required to allow science, research and the regulatory landscape to keep pace with the rapidly changing marine environment.
“That is why we are calling for the Scottish Government to redouble its focus on regulatory issues to ensure that this industry, which is so important to the Scottish economy, is both future-proofed and enabled to grow sustainably.”
In its report, the committee said it “seriously considered” whether calling for a moratorium, or pause, on new sites, or the expansion at existing sites, would be appropriate – “especially given the view held by some about the lack of progress in addressing high mortality rates since 2018”.
However, it said: “…given the lack of certainty around the impact a moratorium on production would have, especially on those directly employed on farms or living in local communities, the committee is not currently in support of a moratorium or pause on production”.
Two Highlands and Islands MSPs, Ariane Burgess (Scottish Greens) and Emma Roddick (SNP), dissented from paragraph 312 of the report, from which the above statement comes.
Call for action on mortalities
Looking into the details of the report, the committee’s key recommendations include handing powers to the Fish Health Inspectorate (or another appropriate body) to limit or halt production at sites which record persistently high mortality rates. The Scottish Government, it says, should work with industry and regulators to agree appropriate criteria and mortality thresholds for the use of these powers.
The committee also calls on the Scottish Government to “establish a research project focused on testing and improving the modelling of environmental conditions known to cause high mortality events on salmon farms”, which “should provide an early warning to industry and inform technological solutions and approaches to husbandry to mitigate high mortality events”.
On top of this, the MSPs also request “the publication of comprehensive, consistent and transparent mortality figures that include the number of fish at a farm, the freshwater and seawater mortality, per facility, with accurate numbers of dead salmon, wrasse and lumpsuckers per week and with cumulative mortality totals at the end of each production cycle”.
The Scottish Government should also “publish an annual fish health report detailing the health and welfare status of all farmed finfish in Scotland”, as well as upgrade and improve the Scotland’s Aquaculture website “to make data more accessible and user friendly”.
The committee also wants to see “further research to address the significant gaps in knowledge, data, analysis and monitoring around the adverse risk of salmon farming on the marine environment, especially around discharges from farm pens and the use of medicines”. It calls on the government, industry, and academia to establish dedicated research pens, and says industry should contribute to the cost of financing this infrastructure.
The government must also consider “an expedited timetable for the introduction of a revised environmental quality standard for emamectin benzoate, rather than the planned four-year implementation period”. The insecticide emamectin benzoate is used as an in-feed treatment for the control of sea lice parasites in farmed fish.
The committee is also urging the government to “introduce stricter conditions for ‘no counts’ (when salmon farms don’t return a weekly sea lice count to the Fish Health Inspectorate) for the accepted reasons of stock that is subject to treatments or being held for harvest”.
“Specific baseline standards for the welfare of farmed fish” also need to be set, by “additional regulations and official guidance under the Animal Health and Welfare (Scotland) Act 2006”.
The government must also update the committee on “the ethics and welfare implications of the use of ‘cleaner fish’ to manage sea lice infestations”.
Moving onto the concerns around wild salmon, as “a matter of urgency” the government must “publish a timetable for implementing the outstanding 42 recommendations of the Salmon Interactions Working Group report”, which came out in May 2020.
The MSPs also want a memorandum of understanding between SEPA (the Scottish Environment Protection Agency) and other relevant bodies “to ensure a coordinated approach to managing the impacts of farmed salmon on wild salmon”, as well as “an immediate end to the siting of farms in the close vicinity of known migratory routes for wild salmon”.
In other matters, the government must “address concerns about the slow progress in tackling issues with planning and consenting process, especially regarding relocating existing farms”, and “ensure that communities share the benefits of salmon farms sited in their locality, through consultation with stakeholders and affected communities”.
Defending the government record
Reacting to the report, Mairi Gougeon, Cabinet Secretary for Rural Affairs, Land Reform and Islands, said: “Scotland’s salmon industry is a significant contributor to our rural economy and we are wholly committed to the sector’s success.
“We’ve made significant progress on a number of key issues, including on, for example, the management of sea lice and environmental protection, since the previous wide-ranging committee inquiry.
“We’ve also published our Vision for Sustainable Aquaculture, setting out how we will support the development of our aquaculture industry to operate within environmental limits while continuing to deliver social and economic benefits for Scotland.
“I am grateful to the committee for their detailed report and recognise the call to make progress at pace in other key areas. We will consider the report carefully and respond in due course.”
The industry body Salmon Scotland’s Chief Executive, Tavish Scott, added: “Scottish salmon farms already have world-leading welfare and environmental standards and are subject to strict regulation, but we continue to innovate which is why survival rates are at a four-year high, sea lice levels are at a historic low, and consumer sales of our nutritious fish are on track to break all records.
“We engaged constructively with MSPs to provide evidence of the significant progress our sector has made, and we note that most of their recommendations are for the Scottish Government.”
The report did not go far enough for WildFish, a UK charity campaigning for wild salmon and their environment. Its Scotland Director, Rachel Mulrenan, said: “We completely agree with the committee that progress in this sector has been eye-wateringly slow; and that the Scottish Government needs to demonstrate much stronger leadership in the regulation of this sector and its damaging impacts.
“However, it’s hugely disappointing that the committee has once again fallen short of calling for a moratorium on industry growth, considering the huge issues the industry has faced for many years, and the overwhelming evidence presented over the past months demonstrating that these issues are in many cases getting even worse. Until these issues are dealt with, the threat to wild salmon and sea trout remains critical.”
She welcomed the call for an end to siting farms in the close vicinity of known migratory routes for wild salmon, arguing this was something that should have happened many years ago.
Mulrenan went on: “On the whole, this report is firefighting issues that are of the industry’s own making, such as the ecologically ruinous use of wild-caught wrasse (once touted as a solution to the issue of high chemical use to treat sea lice parasites – now acknowledged to be ‘uncertain’ in terms of its sustainability by the industry itself) or the increase in mechanical treatment for sea lice, that result in welfare issues for the fish.
“What the report lacks, however, is a fundamental questioning of whether open-net salmon farming can ever be truly sustainable, particularly within the context of climate change - where the balance of costs and benefits of this industry truly lies, when all the many negative impacts on other sectors and on the wider environment, in Scotland and overseas, are properly taken into account – and what an alternative vision could be for Scotland’s coastal waters and surrounding communities.”
Unpicking the report
To explain the thinking behind the findings, Fish Farmer caught up with the RAIC’s Convener, Finlay Carson MSP, to ask a few further questions. The report calls for “stronger leadership” from the Scottish Government. Did MSPs have a sense of what is holding up progress?
“We’re really concerned about the slow rate and progress across many of the recommendations back in 2018,” replied Carson.
“One of the critical issues is about the lack of accountability, the lack of perceived enforcement, and throughout the committee sessions, there was a feeling that nobody had overall oversight of the industry as a whole.
Whether that was planning, whether it was environmental issues, whether it was animal fish welfare, everybody seemed to be working in silos.
“So what we really need to do is get the government to pull it all together. We want to make sure, with ministerial oversight, they can pull all this together, and we get the accelerated pace to deliver the recommendations, which in the long term is going to be to the benefit of the industry. It will reduce some of the distrust, because it’ll lead to more transparency.”
Why did the committee reject calls for a moratorium on new farms? “We did take it seriously,” Carson said. “However, at this time, it’s unclear what the impact of a pause or a moratorium would have on communities, whether that’s jobs or associated industries that work with the fish farm industry, or indeed the confidence of the sector to continue investing in aquaculture in Scotland.
“We’ve seen them invest in technology to address some of the issues, and we need that to continue. A moratorium may send completely the wrong message. We need the industry to have confidence that they’ve got the backing of the government or the parliament to continue producing the world-leading product that Scottish salmon is.
“We haven’t ruled out a moratorium in the future. The ball’s in the court of the government: it’s down to them to make sure that they can deliver the recommendations. But if they don’t, and if we don’t get a satisfactory response to this report, we will seriously look at the implications of a moratorium or a pause and how that might extend, whether it to be new inshore farms or to any development of fish farms.
“It’s not a threat, but it’s a clear indication that, as they said in 2018, the status quo is not acceptable, and we need to see some progress. Twelve months should be plenty of time for the government to send a clear signal that things need to improve. And if we don’t get that, the pause is still on the table.”
Has the RAIC defined “persistently high” mortality?
“No, we didn’t define it,” Carson replied. “It’s difficult to understand what acceptable levels of mortality are. You can’t compare the livestock industry of sheep, cattle, pigs, whatever, in the same way that you view fish. So we’re not comparing apples with apples. However, it’s in everybody’s interest to bring down mortality rates. It’s not good for the industry economically, and it’s certainly not good for the well-being of fish farmers: the last thing they want to be doing is hauling dead fish out of nets. When it comes to the definition of persistent high mortality, the recommendation absolutely states it’s up to the government and the industry to define that.”
What is wrong with the existing record of mortalities, which provides a farm-by-farm breakdown?
Carson replied: “We were made aware when we visited a fish farm in Oban that individual farms collect a whole range of different data, and on a daily basis they’ll record mortality, and, on a voluntary basis, they provide that information to the government, and that it’s only mandatory if they hit a threshold. However, some of the distrust around this industry is lack of confidence in the data that’s provided, and some of that lack of confidence is because that information is provided on a voluntary basis.
“So the committee felt if it was mandatory to provide information, it would give some confidence: it would increase trust and transparency in the industry. And it should not be an extra burden on industry because they’re already recording mortality, and fish behaviour, or whatever, as part of their ongoing management of the farm. It would give more confidence that there is nothing hidden, that the industry is not trying to cover up anything, and full transparency will go a long way to build confidence in some quarters that’s currently not there.
“We believe that the recommendations, if implemented in a timely manner, will effectively secure the long-term sustainable future for the salmon industry in Scotland.”
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