White paper: Happy Easter.
I do want to comment on the new Norwegian white paper in more detail but as this is holiday time, I prefer to delay my commentary on such a serious subject until I have been fully able to digest its content.
Freedom of Information: I have previously written that the Scottish Government published the provisional catch data for 2024 at the end of February. They did this quietly without the usual notification, which now seems an increasing trend in the wild fish sector as the next commentary also highlights.
My analysis of the data questioned why the provisional catch for 2024 was compared to the provisional catches for 2023 rather than the final data which was published last May. I subsequently submitted a FOI request for an answer (the days of just telephoning for a chat are long gone) and this has now been received.
They say that: The 2024 provisional salmon and sea trout statistics compare provisional catch for 2024 with provisional catch for 2023 because the 2023 catch has been updated with late returns and amendments since the final Scottish salmon and sea trout fishery statistics for 2023 were published.
So, the provisional catch data supplied at the end of February isn’t provisional catch data at all. If my understanding is correct, then it is the finial catch data – that isn’t final catch data at all as it has been updated with late returns and amendments. This raises a whole raft of new questions. With one or two minor exceptions the 2023 fishing season closed at the end of October. After that date, river proprietors must complete a form with the fish caught and send it to Scottish Government scientists, yet it seems that some have been so late in doing so that the data has not arrived in time for the finalised data to be published in May. That is at least six months late. How can this be acceptable? The other question is what sort of amendments are required after the data has been published in May? As I have said elsewhere, the wild fish sector appears very lax when it comes to their own data but complain bitterly if the salmon farming sector were so late in publishing their data.
The second question is why the provisional data is divided into east and west coast catches when the finalised data makes no reference to such a divide. The only context when east and west coast catches is ever discussed is in relation to salmon farming so the inclusion of such a division is a real puzzle.
The FOI request reveals that the data is divided in this way because the data is required for reporting to ICES and NASCO to enable management of high seas fisheries for salmon. This is very odd because NASCO are about to hold their 42nd meeting this year and the Scottish Government have only reported provisional data in this way in 2023 and 2024. It is also unclear how separating the catch will help management of high seas fisheries for salmon. Meanwhile NASCO are already conducting a review of impacts of sea lice associated with salmon farms, which would be a more realistic reason for supplying this data. The sudden appearance of provisional data last year was also a puzzle, but it seems that NASCO require their regional reports by 1st April which is long before the Scottish Government get around to producing the finalised catch data.
What is of most interest is that the Scottish Government’s annual submission to NASCO including details of the catch data is available on the NASCO website. The following image is the section relevant to catch data and does not appear to include any reference to east west split. If anything, it is very short on any data at all.
The reason given by the FOI response as to why the finalised statistics do not include separate data for east and west coast is that the finalised data is accompanied by the full spreadsheet, which we now gather is not finalised data at all. The response says that anyone who is interested in such separation can use the spreadsheet to deduce the east and west coast split for themselves.
What is interesting about this split is that there is a paper by Vøllesatd et. al. (2009) co-written by Scottish Government scientists which is included in the science of sea lice document. This divides the Scottish coast into three sectors – Eastern – North Sea, Northern – Atlantic, and Western – Irish Sea so why are just two areas of interest now.
The reality is that we don’t need these provisional results at all. If the wild fish sector and Scottish Government got their act together there is absolutely no reason why in this time of modern technology, catch data cannot be reported weekly so the total catch can be reported by the end of the year before the next season begins.
No fanfare: At the end of March, Fisheries Management Scotland published their 2025 Annual Review. This appeared without any fanfare at all not even warranting a mention in their own news feed. This is not surprising because it no longer really warrants consideration unless the reader is interested in reading its self-congratulation even though the wild salmon sector has little to congratulate itself about. Wild salmon stocks remain in a perilous state, although this is not apparent from this review.
The FMS Annual Review (formerly the Association of Salmon Fishery Boards) used to provide the first indication of the state of salmon catches from the previous season, but FMS stopped including catch data when someone (mentioning no names) highlighted the huge discrepancies between the number of salmon caught according to FMS compared to the official catch data when that was eventually published. Rather than work out why such discrepancies occurred, FMS simply stopped publishing their data. You can imagine the outcry if salmon farms stopped publishing data, but this is the wild salmon sector and they seem immune from such criticism, Instead, the only information about 2024 salmon catches appears in the chairman’s report. He wrote that it is encouraging that some rivers had strong catches with the preliminary 2024 catch statistics showing that catches were above the ten-year average.
The chairman continues:
Whilst these trends are not apparent across all Scottish rivers, it is important to celebrate success and demonstrate that we can make a real difference.
I only hope that he is not implying that their work resulted in these improved catches because as the saying goes, one swallow doesn’t make a summer. It is only necessary to look at the catch statistics since 1952 to see there can be huge annual variations. Interestingly, the FMS Annual Review includes the graph of catches drawn by Scottish Government scientists, which was not included in the release of provisional catch data by the Scottish Government. I have applied several times using FOI to obtain selected data ahead of publication to be always told that the data is not published so cannot be provided. It seems that FMS are able to circumvent the process and have obtained graphical analysis significantly ahead of official publication. This is yet just more evidence of the close cooperation between FMS and the Marine Directorate, something not afforded to the salmon farming industry or its people. It is this close cooperation and the continued fixation that salmon farming has a negative impact on wild fish that has led to the imposition of draconian (and pointless) regulation. Meanwhile, the Marine Directorate shies away from demanding mandatory catch and release across all of Scotland in case they upset their friends in the wild salmon sector who like to kill threatened salmon for sport.
The Annual Review also includes a page devoted to the Sea Lice Regulatory Framework. Unlike many other pages, there is no mention of who wrote this contribution but it is clear that FMS believe that this regulation will help protect wild salmon smolts during their migration away from the west coast, despite a lack of any evidence to support their view. FMS urges all stakeholders including government agencies, researchers and local managers to remain engaged and ensure that the framework delivers meaningful long-term benefits to wild fish. Sadly, any attempt to engage are only appreciated if they are to agree with the views of SEPA, Marine Directorate and FMS. Without any willingness to discuss the science, they all remain unaware that this regulation will do nothing to protect wild fish at all.
This page also mentions the two management groups on which FMS sit that have been established by SEPA as part of the Sea Lice Risk Framework. This includes the Sea Trout Sea Lice Group that investigates current levels and trends in sea lice infestations especially on wild sea trout. The chairman’s report also mentions sea lice monitoring referring to the public funding provided to assist with ongoing sea lice monitoring on wild sea trout.
Unfortunately, I must mention yet again that as we approach Easter, FMS seem unable to post the 2024 sea lice monitoring results on their website. This is just unacceptable but as I have already pointed out, FMS and the wild salmon sector appear immune from any criticism of such omissions. Why Scottish Government have not demanded the publication of this data is a total mystery but as is well- known criticism of the salmon farming industry does not require the provision of any evidence. It is enough just to make claims against the industry for them to be widely accepted.
Finally, the chairman also points out that sea trout catches continue to decline as shown on the Marine Directorate graph. Sea trout are also caught from east coast rivers where there are no salmon farms and according to the accepted narrative, sea trout do not travel far from their home river so can’t be affected by sea lice. I have yet to hear anyone from the wild sector attempt to explain why these fish are in decline. The answer is that despite all their expertise, they haven’t got a clue.
Critics: The BBC radio Farming Today programme just completed a week focussing on the aquaculture industry covering seaweed, trout and salmon. However, like every previous feature week on aquaculture, the programme seems unable to simply celebrate the positives but also must include a contribution from the critics, which in this case was from Wild Fish. The organisation wheeled out their newly installed Interim Scottish Director, Andrew Graham Stewart who before the appointment of Rachel Mulrenan had had many years in the same role.
Listening to Mr Graham Stewart, it was like stepping back in time with his often-repeated criticism of the industry but still unable to provide any evidence to support Wild Fish’s claims about the industry. It would be interesting to challenge Mr Graham Stewart but like all members of Wild Fish, whilst they like talking to the media, they run a mile if asked to face the industry directly.
Unfortunately, the journalists on the programme are not sufficiently well informed to ask Mr Graham Stewart why he is so critical of the industry. If they were aware of his motivation, they might ask him why if Wild Fish are so concerned about protecting wild salmon, they have still to demand a stop to the killing of all wild fish for sport.
Mr Graham Stewart also pops up again in the Scottish Mail on Sunday newspaper which has published a story this week about how salmon in Scotland are facing extinction. This is in response to the recent and very delayed publication of the salmon conservation gradings for 2025. I have already discussed in a previous reLAKSation that that these gradings are totally meaningless.
What is of interest however is that The Mail refers to the audit assessing 212 rivers and waterways, even though the Government website refers to just 173. This is the first time I have seen this discrepancy highlighted by the media. Perhaps, the Government scientists will now be induced to resolve the numbers.
The newspaper also speaks to Andrew Graham Stewart who highlights that the great majority of grade 3 rivers are in western Scotland or the Hebrides. This Is not surprising because the scientists have carved up several small fishery districts located in this area into up to multiple separate assessment areas. Two of the districts in the Hebrides have been split into ten separate areas meaning that what was two areas is now twenty. Meanwhile the Tweed, which is bigger than many west coast fishery districts added together remains as just one assessment area.
Mr Graham Stewart accuses the government of failing to address the growing threat posed by salmon farms. He said that juvenile salmon migrating to their ocean feeding ground must pass by marine salmon farms where they are highly likely to pick up fatal infestations of sea lice. Yet again Mr Graham Stewart fails to provide a shred of evidence to support his claim. Perhaps, he would like to provide some real data, but he won’t because he can’t.
It is worth remembering that Mr Graham Stewart was behind the petition to Scottish Government claiming that all west coast assessment areas were grade 3 and this was proof that salmon farming had a negative impact on wild fish. I would be interested to hear his opinion on why last year 30 of the assessment areas on the west coast were of the higher conservation grades and hence allowed anglers to kill the salmon they caught.