Fisheries Management Scotland and its’s predecessor, the Association of Salmon Fishery Boards, has played a central role in efforts to protect our iconic wild salmon and sea trout from the impacts of aquaculture for many years. Whilst progress has been slow at times, resulting in frustration across the wild fisheries sector, there is now a genuine opportunity to make significant and meaningful progress towards a better situation for wild fish and fisheries.
There are many campaigning groups who are concerned about the impacts of aquaculture. Our approach is based on engagement with the Scottish Government, regulators and the aquaculture industry. We do this with the sole purpose of protecting wild fish and developing and delivering concrete ideas to improve the situation. Through such engagement, and the collection of empirical evidence on the ground through structured monitoring we have succeeded in raising awareness of the impacts of aquaculture whilst highlighting the crucial failings of the current regulatory system to the key people who can make the required changes.
Fisheries Management Scotland has established a fish farming committee to help inform our policy and advocacy work. This committee is now well established and provides an excellent forum for the fisheries management sector to take a consistent and evidence-based approach to wild-farmed interactions. District Salmon Fishery Boards are statutory consultees in the planning process for fish farms. We support DSFBs and Fisheries Trusts in responding to fish farm developments and in the development of a consistent approach to Environmental Management Plans.
In the light of the significant workload and resources required to make progress on wild-farmed interactions, and in the context of future changes to the aquaculture regulatory system, in 2019 Fisheries Management Scotland approached Marine Scotland and Crown Estate Scotland to fund an Aquaculture Interactions Manager post. The purpose of this role is to support our members’ efforts to protect wild salmon fish through engagement with the planners, regulators and the aquaculture industry. We are delighted that this proposal was accepted, and we welcomed Polly Burns to Fisheries Management Scotland in July 2020.
Fisheries Management Scotland participate directly in numerous stakeholder groups with the purpose of improving the situation for wild fish. These include:
Fisheries Management Scotland is an accredited NGO to NASCO and actively participate through the NGO group at annual meetings.
We also work with Members of the Scottish Parliament through formal evidence and direct engagement. In recent years we provided written evidence to the Parliamentary Inquiries undertaken by the Environment Climate Change and Land Reform Committee and Rural Economy and Connectivity Committee. Our written evidence can be viewed below:
In addition, Fisheries Management Scotland was invited to give oral evidence to the REC Committee Inquiry. The session, which also included Jon Gibb from the Lochaber DSFB, Richard Luxmoore from Scottish Environment LINK and Guy Linley Adams from Salmon and Trout Conservation can be viewed below.
The final reports of the two committees can be viewed below:
In January 2020, Fisheries Management Scotland and Scottish Land and Estates jointly hosted a multi-stakeholder event and evening reception, sponsored by Michelle Ballantyne MSP, to discuss efforts to save our salmon, and to explore the collective efforts required to make a meaningful difference. Aquaculture interactions was one of the topics discussed. The presentation given by Alan Wells and a summary of the proceedings can be viewed below:
What have we achieved?
As highlighted above, many organisations and individuals take a keen interest in aquaculture and there are a range of different strategies that have been employed to make progress on wild-farmed interactions. No one organisation can take credit for the progress that has been made, but we consider that the following represent real progress in our collective efforts to manage wild-farmed interactions:
Highlighting the failings of the current system in the Scottish Parliament. This resulted in successive Scottish Parliament inquiries making it clear that the status quo, in terms of regulation and enforcement, is not acceptable. This position is now accepted by the Scottish Government
Reporting weekly sea lice data on a farm-by-farm basis in real time. This was announced by the Cabinet Secretary for the Rural Economy, Fergus Ewing, in June 2019 and we have been consulted on the statutory instrument that will make this a legal requirement. This will be introduced into the Scottish parliament later this year with weekly lice counts to be published on Scotland’s Aquaculture webpage in early 2021.
Working to develop and deliver concrete ideas for a reformed regulatory system through the Salmon Interactions Working Group. This was a major step forward and crucially the recommendations were agreed unanimously by all participants. We are now working to ensure that the reformed regulatory regime is implemented as soon as possible.
Developing robust monitoring approaches to understand impacts on wild fish. These monitoring approaches are now being delivered through Environmental Monitoring Plans and these techniques will feed into the reformed regulatory regime. Ultimately, we expect to see the results of monitoring across all fish farm areas feed back into adaptive management of farm practices.
Supporting our members in their engagement with fish farm companies. The Parliamentary committees were clear that they wanted to see the wild and farmed sectors co-exist and collaborate to resolve local management issues and other areas of concern. We are working across a number of issues to put this into practice, including the development of environmental management plans, efforts to monitor impacts on wild fish and developing earlier, and more meaningful pre-application consultation. In the near future we hope to develop projects to improve the situation for wild fish.