Traffic Lights: iLAKS has publicised a press release from the Institute of Marine Research indicating that more sea lice in the north have changed the traffic light status for three of the 13 production areas. PO8, PO10 and PO11 have increased from low to moderate risk for sea lice having a negative impact on wild salmon, even though the increase in lice counts were recorded later in the year, long after salmon smolts had migrated out to sea.
The press release states that ‘In the Traffic Light System, it is mortality of wild salmon that is decisive’ yet none of the various reports and assessments gives any indication of how many wild salmon smolts have died as a result of the presence of sea lice on salmon farms. It is all conjecture. It seems that because sea lice can be found on farmed salmon and there are fewer wild salmon than there used to be, one must be the consequence of the other.
It was back in 2019, that the Scientific Committee for Salmon Management (VRL) last estimated the mortality of salmon smolts in Norway which they put at 39,000 fish, however they provided no indication of how many of these estimated 39,000 fish actually died.
In their latest assessment of wild salmon stocks VRL state:
‘The greatest human-caused threats to Norwegian salmon are linked to the effects of salmon farming and climate change. Sea lice from fish farms are the greatest threat to Norwegian salmon, and in addition there is genetic impact from escaped farmed salmon and infections related to fish farming. The number of salmon stocks assessed as critically endangered due to sea lice has increased in recent years, and sea lice pose the greatest risk of further damage.’
Yet, in 2019, anglers and netsmen killed a total of 96,112 ready to breed adult salmon from Norwegian waters. This is over double the number of smolts estimated to have died due to sea lice by VRL. The smolt deaths are estimated but unconfirmed, whilst the deaths of the exploited fish have been confirmed by Statistics Norway.
I have asked various researchers in Norway to explain why sea lice from salmon farming are a much greater threat to wild salmon than exploitation. Oddly, no-one has ever offered an opinion. VRL only list over-exploitation on their list of threats and it is considered to be the lowest of all risks. Clearly, the premature deaths of 96,112 fish in 2019 Is not considered to be over-exploitation, but acceptable exploitation. I find it strange that those who criticise the salmon farming industry most, are also those who appear to do the most damage. Yet, they are loath to accept any responsibility, and why should they, when they can blame salmon farming instead.
Despite a lack of any hard evidence that wild salmon declines are due to the presence of sea lice, IMR have stated that the increased number of lice in the north in recent months has influenced this year’s Traffic Light ratings. However, the IMR survey of sea lice infestation of wild sea trout took place during the smolt migration and not when the lice numbers on farm increased. IMR say that it is not feasible to cover the entire Norwegian coastline with field work nor continue lice monitoring throughout the year, which is why they say that have their models that highlight the risk to wild fish. Karin Kroon Boxaspen of IMR and also of the Sea Lice steering group said that the sharp increase in lice numbers was inputted into their models and the TRLS ratings adjusted accordingly. Yet, how can there be an increased risk to wild salmon from these higher sea lice numbers when the wild salmon are all out at sea or returning to freshwater where any lice will drop off?
At the time of writing, I am still waiting for access to this year’s sea lice data so cannot undertake my own analysis yet. Meanwhile, I have been able to look at the number of fish sampled from each production area, and these are displayed in the following table.
In PO1 just 47 fish were sampled whilst 1109 fish were sampled form PO6. At the same time, some areas were sampled for one week whilst others were sampled over a 6-week period. As with last year over half the production areas did not achieve the minimum sample size of 100 fish established by Taranger in 2012.
Such discrepancies do not instil any confidence in the Traffic Light System. I suspect that further concerns will emerge if and when I obtain the full dataset. However, the biggest concern is that lack of any evidence showing sea lice are responsible for the poor state of wild salmon stocks, especially when the comparison of salmon farming areas and non-salmon farming areas in Scotland shows a similar rate of decline in both.
No idea: The National newspaper reports that seven fish farming companies have been accused by SEPA of breaking the law by failing to provide information on fish numbers. SEPA had wanted data on the weekly number of sea lice and the weekly number of fish on farms for weeks 12 to 44 from 2018 to 2023. Peter Pollard of SEPA wanted the information to improve the assessment of risk to wild salmon. I presume what he means is that he wants to apply this data to the model to ensure that it can predict a perceived risk to wild salmon.
One of the questions I would have asked Peter Pollard if he had agreed to meet me is how the model relates to the actual state of the wild salmon population. It is the same question I would ask of The Norwegian Institute of Marine Research because as I have already pointed out, any relationship between sea lice associated with salmon farms and wild fish is simply based on conjecture. I have not seen any data that shows that declines in local wild salmon stocks can be related to elevated sea lice numbers on a specific farm. It seems that the only people who say that there is, are the angling fraternity, (who are responsible for killing nearly 6 million wild fish in Scotland since 1952). It is worth remembering that wild fish and environmental interests outnumbered those from the salmon farming sector in the Salmon Interactions Working Group.
As with the Norwegian Traffic Light System, SEPA’s model assumes that if there are high lice counts on farms, then wild salmon are at risk. SEPA want this data to help validate their model but the only way the model can be realistically validated is if actual sea lice larvae can be shown to be in the sea in the numbers the model predicts and around the area that the model predicts. Anything else is totally meaningless.
For example, the angler’s representative organisation Wild Fish claim on their website that every farm emits 2 billion sea lice larvae every week, yet although attempts began in 1994 to identify these lice, no-one has to date managed to achieve it. As I have indicated in a previous issue of reLAKSation, the best measure to date has been one larva per cubic metre of water. The 2021 SPILLS project claimed that just because they couldn’t find the larvae, doesn’t mean that they are not there.
I would argue that it does.
The fact that no-one has identified the sea lice soup means that the claimed risk to wild salmon simply doesn’t exist either. This should not be of any surprise because there is no evidence that high sea lice counts on farm have caused a decline in wild fish numbers. SEPA certainly seem to have forgotten this because they now ignore ethe fact that Peter Pollard told the REC Committee in 2020, that sea lice are not responsible for the declines in wild fish numbers.
At the risk of repeating myself, Peter told the committee that the Sea Lice Risk Framework was required because as fish numbers were so low, everyone needs to be protected, but only from salmon farms and not from anglers who continue to catch, damage and kill wild fish from rivers around the Aquaculture Zone.
It seems that SEPA don’t really have any idea about wild fish interactions except that their model predicts a risk to wild fish, therefore there must be a risk.
According to the National newspaper, SEPA are considering appropriate action in response to the failure of companies to supply the data. However, it is not SEPA that should be considering action, but the salmon farming industry that is expected to comply with this nonsensical and meaningless piece of regulation.
Consultation: SEPA have issued yet another consultation asking stakeholders what they think and then totally ignoring anything that was said and instigating their own views regardless.
This latest consultation concerns how the salmon farming industry will be expected to pay so that this pointless framework can be imposed on them.
According to the consultation, the industry will be expected to fork out £254,000 to pay for juvenile population assessments, even though there is an existing National Electrofishing Programme already in place, so why should the industry have to pay towards this or for another version. If SEPA believe that they can show a relationship between salmon farming and juvenile assessments, then they should do so from existing data, but I doubt they can. In fact, I challenge SEPA to demonstrate that they can show that such a relationship exists.
The industry is expected to pay towards a sea trout lice monitoring programme at a cost of £360,000. Again, a programme of sea lice monitoring already exists, which began in 1997. This was funded by the Marine Directorate and the Crown Estate although I believe the Marine Directorate no longer contributes to the programme. Since 1997, there has only been one analysis of the data and that appeared last year and was extremely selective in its use of data. Over the years, the assumption has been that if wild fish interests sample fish with high lice counts then they must be due to the presence of salmon farming. That has been the limit of the analysis. High lice counts equate to nasty salmon farms.
Unfortunately, neither Marine Directorate nor SEPA scientists refuse to discuss my own analysis of the data presumably because it doesn’t fit their narrative. However, the reality is that the sea lice counts on sea trout need to be placed in context and so far no-one from the wild fish sector, SEPA or the Marine Directorate has even tried to do that.
Although sentinel cage monitoring is part of the Sea Lice Risk Framework, SEPA are not charging the industry to undertake this work presumably because SEPA anticipate that the industry will fund this work out of the own pockets. Sentinel cage monitoring is another meaningless exercise in trying to attribute blame for wild salmon declines on the salmon farming industry.
The final costs to the industry are £296,000 for SEPA staff costs. This includes data analysis but I for one have no confidence in SEPA being able to deliver on this. After all, if they were capable of analysing the data relating sea lice, salmon farms and wild fish together, they would have already realised that the Sea Lice Risk Framework is a total waste of time.
SEPA admit in the consultation that they do not have the resources to undertake the monitoring programmes and hence propose to contract out the work. Yet when it comes to staff costs, they admit that the current staff resources are insufficient to cover the necessary and significant new tasks and thus they will create new posts which reflect the range of technical complexity required.
Firstly, given the absence of any analysis of the relationship between salmon farms and wild fish numbers over the past thirty years, it seems unlikely that SEPA will be able to recruit anyone with the necessary expertise and as they are already planning to contract out some of this work then surely they should consider contracting out the work that would require the creation of new posts. After all, if they don’t want to create new posts to undertake the monitoring work, why create new posts to analyse the data. The consultation highlights that to negate the deficiency in expertise, additional training will be delivered by the Norwegian Institute of Marine Research funded through the £200,000 discussed in previous issues of reLAKSation. However, given that the IMR NALO programme is equally suspect to the plans proposed by SEPA, I wonder what sort of training IMR are likely to give.
The IMR training is in addition to appropriate expertise available in the SEPA fish ecology team. Yet, if the ecology team already have expertise in this area, then it is unclear why Peter Pollard is so reluctant to meet with me.
As mentioned at the start, it won’t matter what the industry thinks of this consultation because SEPA will simply do what they want regardless. I suspect that the only way to stop this juggernaut is if the industry challenges SEPA in court, unless common sense prevails.
Postscript: Since writing this commentary, the Daily Telegraph has reported that the UK Government have found that the regulation workforce in Whitehall has nearly doubled over the last decade.
A study by Policy Exchange, the Think Tank has called for the number of regulations to be slashed by 25% as excessive regulation is undermining innovation, productivity and delivery.
The study says that regulation is not the only tool that is available to mitigate risk. Risk must be balanced against other consideration. Sadly, in the case of the Sea Lice Risk Framework, the risk has bene highly over-stated and thus regulation will do everything that the Policy Exchange say will happen so will undermine innovation and productivity but more importantly, regulation will do nothing to safeguard the wild fish it aims to protect.
Data: I mentioned that I am waiting for the Norwegian sea lice data to be made available. As with last year, I am having to chase IMR to load the data onto their website. – As I begin to post this commentary, I must report that it has finally been published.
Meanwhile in Scotland, there is no sign of the 2024 sea lice data on the Fisheries Management Scotland website. Enquiries as to their availability to FMS have not been acknowledged or returned.