Salmon and sea trout populations across Scotland and the North Atlantic have declined significantly in recent decades. Following two Parliamentary enquiries and the recommendations of the Salmon Interactions Working Group, the need for a regulatory framework to manage sea lice interactions between farmed fish and wild fish is beyond doubt.
Fisheries Management Scotland strongly believe that for this framework to be successful, it must meet the test of being robust, transparent, enforceable and enforced, as set out in the Salmon Interactions Working Group. Our key concerns about the framework as proposed in this consultation are outlined below.
Impacts on wild fish arising from sea lice are a function of both the number of host fish and the number of lice per fish. We therefore strongly endorse SEPA’s proposed regulatory approach of managing overall lice numbers arising from fish farms below a critical threshold specifically identified for the protection of wild fish. However, we have highlighted in our detailed consultation response that we believe that the critical exposure threshold should be set at a lower level.
Against the backdrop of the wild salmon and biodiversity crises, it is crucial that we manage existing impacts alongside considering applications for further development. We do not consider that the use of a ‘no deterioration’ condition is appropriate, and we strongly feel that any impacts arising from existing farms must be addressed with urgency. SEPA should apply precautionary lice limits for existing farms until such time as refined modelling (led by SEPA) identifies an appropriate lice limit which is protective of wild fish. Given the existing evidence from across the North Atlantic regarding impacts of farm-derived sea lice on wild salmonids, the framework, and licence conditions limiting total lice numbers, should apply to all farms and should be implemented on a much shorter timescale than currently proposed.
We welcome the fact that SEPA will develop a bespoke framework for sea trout, but this Priority Marine Feature needs protection now. In the interim, we believe that that SEPA should extend the current approach for salmon to cover the period within which it can be reasonably expected that sea trout will be present in Wild Salmonid Protection Zones (WSPZs).
Wild Salmonid Protection Zones are areas of sea in which SEPA consider wild post-smolts are at greatest risk of harm if sea lice levels are high. As wild salmon migrate through Scottish coastal waters, it is important that the cumulative impact of sea lice encountered as salmon pass through multiple WSPZs is taken into account.
We have made further suggestions and comments in our detailed response to the consultation. This includes (but is not limited to) the designation of WSPZs, the appropriate use of screening and refined models and SEPA’s approach to enforcement. We will continue to engage with SEPA to support the delivery of a robust sea lice framework which protects our fragile wild salmon and sea trout populations from the impact of farm-derived sea lice.
Read Fisheries Management Scotland’s full consultation response.