In strictest confidence: I always treat any correspondence I receive in the strictest possible confidence unless requested to do otherwise. I have made one exception and that is any responses I receive from any correspondence I have had through the Scottish Government’s mailbox ceu@scot.gov. I am always told that I should use this general mailbox rather than write to individuals whose email addresses I have anyway to make sure that my enquiries are appropriately addressed. I would have thought that if I wanted to ask a question of a specific individual then it would make more sense to write to that individual but apparently not. Of course, this is because there are many at the Marine Directorate who don’t seem to like being asked questions, especially in relation to the science of sea lice.
Anyway, I have recently received the latest response to a request to meet with scientists to discuss the science of sea lice and its use in the Sea Lice Risk Framework.
The Scottish Government have written to tell me that SEPA ‘has used the best available evidence to support the SLRF’. They then say that that they ‘are progressing our understanding of what is happening in Scotland’s environment to adapt that framework, and that will be delivered through a collaborative monitoring and research strategy.’
What the Scottish Government appears to be telling me is that scientists from either the Marine Directorate or SEPA ‘have not yet got a full understanding of what is happening in Scotland’s environment’ regarding sea lice. This is despite having the best available evidence.
However, instead of using this best available evidence, the Marine Directorate and SEPA want to start again and deliver a new collaborative monitoring and research strategy. Even if it was a sensible monitoring and research strategy that they have proposed, which it’s not, it would take several years to build up a meaningful dataset that would be of any use.
Meanwhile, the Marine Directorate and SEPA choose to ignore a wealth of data that already exists. In the case of catch returns, and therefore by implication, the size of the stock, there is 72 years of existing data. There is also a sea lice monitoring programme that began in 1997 and has run annually ever since except for one year during COVID. These datasets tell us a lot about wild salmon and the interaction with salmon farming, but I presume that they are ignored because they don’t actually support the case for the introduction of the SLRF.
Is this data the best available data? Probably not. It certainly could be better, but it might have been worse. Regular readers may remember that the Marine Directorate scientists tried to reduce the number of reporting fishery districts from 109 to 56 but the Information Commissioner agreed with me that this change, with the aim of protecting the interests of river proprietors (rather than the salmon), was not a valid reason. Consequently, we still have data series for all 109 fishery districts. I have also argued that given the perilous state of wild salmon stocks, it would make more sense if the Scottish Government published the catch data from individual rivers rather than from fishery districts but the Marine Directorate scientists have always refused to do so in order to protect the interest of the river proprietors, although I have never quite understood what scientific benefit the Scottish Government gains from making sure that no-one else finds out how much money proprietors make from allowing anglers to catch and kill wild salmon.
The Scottish Government actually publish catch data from all 173 areas that they assess for salmon conservation purposes, so they do publish this information in part anyway. A request to gain unlimited access to river data is still with the Information Commissioner.
I always have a laugh when the Scottish Government talks about the best available evidence. Regular readers may also remember that I raised the issue of a discrepancy between the official Scottish Government catch data and the supposedly same data published in the Fisheries Management Scotland (formerly Association of Salmon Fishery Boards) Annual Review. From 2011 to 2020, the annual review included a review of the main river systems together with the number of fish caught. It was possible to compare a total of 360 records of FMS data with the Scottish Government equivalent over this period. In some cases, the number of fish recorded by FMS was identical to that recorded by the Scottish Government. In a lot of cases, the Scottish Government number was higher than that recorded by FMS. This is not a surprise. FMS published their review every year long before the Scottish Government published theirs meaning that any proprietor submitting their catch return late may not have the data recorded by the fishery board but have it included in the official data.
However, in 167 (46%) of the 360 cases the number of fish recorded by FMS was higher than that recorded by the Scottish Government. There is no reasonable explanation of why this should happen. If it were one or two fish between the datasets then that might be due to transection errors but when the numbers are totaled for these 167 cases, the excess number of fish caught amounts to a total of 36,077. When I first highlighted these discrepancies, I hoped that there might be an explanation, but the only response was that in 2021, FMS simply stopped publishing catch data in their annual review and have never done so again. If the salmon farming industry did the same, there would be an outcry, but because it is the angling sector, then seemingly the Scottish Government seem to think that that’s OK. The discrepancy of 36,077 fish recorded by FMS and not by the Scottish Government should not be swept under the table.
Whilst on the subject of FMS the results of the 2024 sea lice monitoring programme have yet to be posted on their website. How can any proper assessment be made when such simple data cannot be posted promptly. From 1997, just a small number of sites were sampled as late as September but most of the data was generated earlier in the year. There is absolutely no reason why this data has not yet been posted. Perhaps, it is just that the FMS abacus needs to be upgraded!
Reverting back to the Marine Scotland response, the letter I received continues: ‘as has been previously communicated, the framework applies a risk management and adaptive approach which is entirely in line with the precautionary principle.’
The precautionary principle is applied when there is a lack of scientific evidence and there is considered to be a risk of harm. Yet, as already highlighted, the Scottish Government say there is a great deal of evidence about the impacts of sea lice on wild fish, it is just that the wild fish fraternity, the Marine Directorate scientists and SEPA simply don’t want to consider it because it would show that the case for a sea lice risk framework is unfounded. It seems that there is a great deal of contradiction regarding the Sea Lice Risk Framework. It has been based on the best available evidence but also on an absence of evidence. The Scottish Government can’t seem to make up its mind which it is. What I do know is that the wild fish sector has been complaining about sea lice since the late 1980s which is over 45 years ago. NASCO has recently highlighted that during that time there have been nearly 3000 scientific papers published about sea lice and the impacts on wild fish. How much more science do we need?
It shouldn’t be forgotten that Peter Pollard told the REC Committee in 2020 that sea lice were not responsible for the decline of wild salmon, something SEPA now seems intent on wiping out of their memory.
Yet, the obvious question is that if the Marine Directorate argue that the framework is in line with the precautionary principle, then why don’t they apply the same principles to angling. It is well established that killing fish for sport is harmful to wild fish populations but so is catch and release angling. Equally, stocks of wild fish are now so threatened that there is a justification to close all grade 3 rivers to fishing. Although it is still early January, the salmon angling season is already underway. The Northern Times reports that the River Helmsdale was open for fishing on January 11th even though the official opening ceremony was cancelled due to bad weather. The Scottish Government highlights that spring salmon are under the greatest threat yet is pleased to allow anglers to fish for them anyway. It seems that Scottish Government are happy to apply the precautionary principle if it relates to salmon farming, but never to angling. I suspect that anglers will be allowed to continue fishing for wild salmon even when there are just a handful left because the Scottish Government appears to be more interested in protecting the interests of the wild fisheries sector than the wild fish. If my view is incorrect, I would be happy to meet with representatives of the Marine Directorate so they can explain to me why I am wrong.
Accurate: The Institute of Marine Research has produced a new guide to the counting of sea lice on farmed fish. They say that counting of lice has increasingly been undertaken by machines. They stress that it is important for both research and industry that sea lice counts provide accurate figures.
I couldn’t agree more. The guide discusses the benefits of automated counting in that farmers are reluctant to sample more than the minimum weekly requirement of 20 fish per pen. IMR say that manual counts are vulnerable to systematic underestimation of true lice levels as some lice are lost during handling and some are not detected during counts in sub-optimal conditions.
Of course, these comments relate to farmed fish but counting lice on wild fish surely must be considered to be equally important. However, because lice counts of wild fish are undertaken by IMR staff, no comment is made about potential inaccuracies. It is interesting that a minimum of twenty fish is required to be sampled from each pen. Whether twenty fish gives a truly representative sample is open to debate but more importantly, if a minimum of twenty fish at a time is considered a minimum for farmed fish, then why not for wild fish too.
Analysis of the NALO sea lice sampling data for 2024 as used in the latest Traffic Light assessment shows that just 11% of all the samples meet a twenty fish minimum. That means 89% do not. Twenty-one percent of samples consist of just one fish. The spread of samples can be seen in the following graph.
In a very rare exchange with the Sea Lice Expert Group, I was told that small samples are acceptable but that is because it is IMR scientists who are taking the samples. Yet clearly when it comes to salmon farming, such small samples are not considered acceptable.
The fact is the small samples of fish assessed for the Traffic Light System are not representative of the wild fish population and result in a flawed outcome, but as IMR are involved in both the measurement and the assessment of wild fish lice data, they are never going to admit that they are at fault.
IMR again: ‘We are Aquaculture’ have reported that the Institute of Marine Research’s official response to a Norwegian Government consultation on offshore aquaculture is that it is too early to move to large scale production.
They say that they know too little about offshore aquaculture, especially in relation to the environmental impact. They say that the most significant uncertainties are related to fish welfare including parasite and disease transmission to wild fish, and in particular to migrating salmon smolts. They are also concerned about the effects of potential fish escapes on salmon stocks as well as possible impacts on marine mammals.
These are exactly the same concerns as IMR might express for development of inshore farms but given that the relationship between offshore farms and wild fish would be much less, these concerns might be of a surprise. However, IMR’s concerns are explained by their view that ‘more knowledge is needed’ as well as the need for ‘careful monitoring’. Could it be that IMR would like to be commissioned to undertake such work?
The reality is that just because scientists working for a Marine Research Institute have responded to a government consultation does not make them qualified to express a valid opinion. It is already the case that scientists are running the Traffic Light System, about which it is increasingly apparent, is not working. Could it be because it is run by scientists who have no experience of the salmon farming sector that they have failed to understand the interactions that occur between farmed and wild salmon? I have always said that the Traffic Light Assessment, if it is required (which it isn’t) should be run by a group of people from a wide range of sectors not just a clique of scientists who have a clear vested interest.
Fortunately, ‘We are Aquaculture’ states that the response from IMR contrasts with that from the Norwegian Directorate of Fisheries who also posted a consultation response indicating support for offshore aquaculture.
If IMR are so concerned about the protection of wild salmon, then I would be interested to see their report that states there should be a ban on all forms of exploitation of these fish. I have searched for such a report and haven’t been able to find one.