Fish Farming – Salmon Interactions Working Group

Successive Scottish Parliament inquiries have made it clear that the status quo, in terms of regulation and enforcement, is not acceptable. In late 2018, the Scottish Government established a workstream to examine 12 high-level pressures and address the decline in wild Atlantic salmon. The first stage in this process was the establishment of the Salmon Interactions Working Group (SIWG). The SIWG included representatives of Fisheries Management Scotland, conservation and industry bodies and regulators. It is important to emphasise that the SIWG report supplements, but does not supersede, the recommendations of the ECCLR and REC Committee reports. Rather it sets out a framework within which the recommendations of the Parliamentary inquiries should be taken forward. The final report of the group was published in May 2020.

The SIWG work occurred in parallel with another important workstream which is referred to in the report. A ‘Technical Working Group’ was tasked by the Scottish Government with developing a practical framework for assessing the level of risk posed to wild salmon and sea trout, taking account of the best available scientific understanding and the precautionary principle. The technical group comprises experts from the regulators – Marine Scotland, SEPA, SNH and representatives of local authorities. The output from this work will have a key role to play in the future regulatory framework and will take into account the cumulative effect of management practices on existing farms and impacts on wild salmonid fish.

The next stage in the process is for Scottish Ministers to take forward these recommendations and deliver the reformed regulation system to fully protect wild salmon and sea trout. The report’s authors have urged Ministers to implement the unanimous recommendations in their entirety.

Below we have set out some of the key issues relating to wild-farmed interactions in Scotland, and how the SIWG considered they should be addressed.

 

Current situation
The regulatory regime is complex, disjointed and fails to protect wild salmon and sea trout.

After implementation of SIWG recommendations
The SIWG recognised the current failings of the regulatory system and agreed that the following principles should underpin the reformed regulatory regime:

  • It should be comparable with the highest international and domestic regulatory standards.
  • It should protect wild migratory salmonids
  • It should proactively seek to address negative impacts detected through monitoring
  • It should be robust, transparent, enforceable and enforced.
  • An enforcement policy should be published, including specific penalties and sanctions for breaching conditions.
  • Fines relating to sea lice and escapes to be invested into wild salmonid conservation work, in line with the polluter pays principle.
  • Scottish Ministers should direct all relevant statutory bodies to discharge their duties such that they fully take into account the health and welfare of wild salmonids and of farmed fish

Current situation
Protection of wild fish is considered as part of the local authority planning process, but once permanent planning permission is granted, local authorities do not have the resources, or expertise to adequately ensure that wild fish are protected.

The Marine Scotland Fish Health Inspectorate are responsible for the health and welfare of farmed fish but impacts on wild fish are out with their remit.

SEPA are responsible for consenting the size of farms and the use of chemical sea lice treatments, but do not consider impacts on wild fish when making these determinations.

There is therefore no single body with responsibility for wild and farmed fish interactions.

After implementation of SIWG recommendations
A single lead body, with appropriate powers for monitoring and enforcement, will be responsible for regulating wild and farmed fish interactions.

Strengthened licence conditions and associated enforcement measures will deliver essential regulatory protection for wild salmonids.

Protection of wild salmonids will no longer sit within the planning process.

Such licences can be reviewed or revoked and failure to comply with a licence condition is subject to enforcement action.

Current situation
Local authorities have attempted to address the concerns set out above by including Environmental Management Plans (EMPs), as a condition of planning. These require operators, for example, to monitor for impacts on wild fish. However, this approach is inconsistent, applies only to new farms, and local authorities do not have appropriate enforcement powers.

After implementation of SIWG recommendations
Licences will include conditions to protect wild fish including:

  • A requirement to monitor lice levels in the environment and assess any impacts on wild salmonids
  • A requirement to report on the results of such monitoring.
  • The actions required to be taken where monitoring demonstrates adverse impacts on wild salmonids.

Unlike EMPs, these licence conditions will apply to all farms, not just new farms or farms which wish to increase in size.

Current situation
Planning permission is permanent, and relocation of farms has been almost impossible.

After implementation of SIWG recommendations
The consenting regime will enable efficient relocation of existing biomass to a suitable alternative location.

Current situation
Farms are considered and consented on a case-by-case basis, and cumulative impacts are not well addressed.

After implementation of SIWG recommendations
Consenting of new developments to be managed within a spatial planning system which takes account of the effect of existing farms and impacts on wild salmonid fish.

We consider that this precautionary approach will act to prevent damage to wild salmonids, by providing a framework within which new and expanding farms, are managed.

Current situation
Publication of sea lice data is voluntary and applies only to salmon farms.

After implementation of SIWG recommendations
Publication of all data will be a mandatory licence condition and will apply to all farms (salmon and trout).

Scottish Ministers committed in June 2019 to reporting of farm level sea lice levels one week in arrears for all marine fish farms (salmon and trout).

Current situation
Voluntary data publication includes the number of lice per fish but does not include the overall number of fish in the farms. This is a crucial omission, because it is the overall number of sea lice in an area that is important to wild fish[1].

After implementation of SIWG recommendations
Mandatory licence conditions will require fish farms to provide data on the number of farmed fish per farm in addition to the number of lice per fish.

Current situation
Sea lice thresholds do not relate to impacts on wild fish. The Scottish Government sea lice compliance policy is based on the health and welfare of farmed fish but does not take into account any impacts on wild salmon and sea trout.

After implementation of SIWG recommendations
Mandatory licence conditions will include trigger levels for sea lice intervention action.

These licence conditions are designed to safeguard wild salmonids.

Current situation
It is not an offence to have an escape – the only offence is to fail to report an escape, or fail to report circumstances that may have led to an escape.

After implementation of SIWG recommendations
Fish farmers required to keep 100% of farmed fish in all production facilities.

Fines to be introduced (on a per fish basis) to apply to escapes of fish.

Current situation
Monitoring for escapes in freshwater lochs not required.

After implementation of SIWG recommendations
Mandatory monitoring for the presence of escaped farmed fish from freshwater open pen farms to be introduced.

Current situation
Scottish Ministers have had powers to introduce a Scottish Technical standard since 2013, but this has never been enacted.

After implementation of SIWG recommendations
Minimum technical standards for prevention of escapes of farmed fish to be included in licence conditions.

Current situation
Identification of escaped fish to their farm of origin is a particular challenge.

After implementation of SIWG recommendations
Tools to be refined or developed to distinguish recent genetic introgression from historic introgression. This is to allow the identification of escaped fish to their farm of origin and establish where licence conditions have been breached.

Access to biological information from past, current and future farmed strains of salmon to be secured to support the above.

Current situation
Protection of wild fish is considered as part of the planning process, but once permanent planning permission is granted, local authorities do not have the resources, or expertise to adequately ensure that wild fish are protected.

The Marine Scotland Fish Health Inspectorate are responsible for the health and welfare of farmed fish but impacts on wild fish are out with their remit.

SEPA are responsible for consenting the size of farms and the use of chemical sea lice treatments, but do not consider impacts on wild fish when making these determinations.

After implementation of SIWG recommendations
Strengthened licence conditions and associated enforcement measures to deliver the essential regulatory protection that wild salmonids require.

Current situation
Information on the migratory distributions of wild salmon and sea trout is poorly understood. This has been recognised as an important knowledge gap for many years.

After implementation of SIWG recommendations
Licence conditions to require fish farmers to contribute to research to understand the migratory distributions of wild salmonids. This will contribute to application of the precautionary principle through the planning and licensing framework.

[1] 0.1 lice per fish on a 500 tonne farm results in a significantly lower overall number of lice than 0.1 lice per fish on a 2500 tonne farm. This information is even more important when multiple farms are operating in a farm management area, as it is the relationship between the total number of fish being farmed, and the number of lice per fish, which will ultimately determine the magnitude of any impact on wild fish.

 

Related Pages

What action are we taking?

Escapes

Environmental Management Plans

Monitoring

West Coast Tracking Project