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reLAKSation no 1220

What’s the secret?:  I have mentioned more than once that whilst the critics of salmon farming industry continue to demand more ever more detailed data as we saw in the Scottish Parliamentary debate on salmon farming last week (see next commentary), the wild fish sector appear to hang on to their data without being censured. Fisheries Management Scotland still have not published the sea lice monitoring data for 2024 and the Scottish Government email informing of the publication of provisional catch data (we have to wait until May for the full dataset), has yet to appear.

I thought I would look to see when the 2023 provisional data was published but checking through Scottish Government publications, I didn’t have to go that far back for it appears that the Scottish Government published the 2024 data on the 28th February and this has clearly gone unnoticed as I have not seen reference to it anywhere else including the FMS news feed who didn’t publish anything between 18th February and the 12th of March. What is the big secret that the provisional data has not been publicised except on the Scottish Government publications website sandwiched between Local Government finance and Wildlife Crime. The actual publication just refers to the linked spreadsheet without making any claims.

The provisional data is presented in a number of different tables, the first of which is the total catch for salmon, grilse, sea trout and finnock. What immediately stands out in this table Is not the numbers but the fact that Marine Directorate scientists have compared the provisional 2024 catch to the provisional 2023 catch. Why? Although it took until May 2024 for the Marine Directorate to count all the fish caught, a confirmed figure was published on the 15th of the month. Surely, this is the dataset that should be used for comparison not the previous provisional data.  I am still not sure why we even have provisional data. In these modern times, technology would allow publication of all wild fish catches within days of the end of the season, not six months later.

Anyway, back to the numbers. The provisional catch data includes the combined total catch of both nets and rods which is rather odd given that the official dataset as published in May 2024 does not include such a combined figure but separates the data from rod and net catches.

I’ll return to the question of nets later as I prefer to focus on the much larger rod catch.

The provisional catch statistics for wild salmon caught by rod in 2024 was a total of 46,978 fish. According to the Scottish Government provisional data, this is up 42% on the 2023 provisional figure.

I hope readers will excuse me for conducting some maths here but table 2 of the 2024 provisional data spreadsheet shows that the 2023 provisional catch consisted of 19,189 MSW salmon and 13,903 1SW grilse. When these two figures are added together, the total 2023 provisional catch was 33,092 fish. The reason I mention this is because if I jump ahead to 15th May 2024, the official catch statistics state that 32,477 wild salmon were caught by rod in 2023. My maths makes that a loss of 615 wild salmon between publication of the provisional and final statistics. I could understand if the final total was 615 more but not 615 less. Even more concerting is the fact that the incorrect higher number is used for comparison in the latest publication.

The provisional data for 2023 highlights that 31,885 salmon were released and 1,207 fish were killed, yet the final data puts these figures at 31,289 released and 1,188 killed. It seems that 19 salmon were killed but then weren’t.

I can only wonder whether the 2024 provisional data is also over-stated. According to the provisional data 39,742 salmon were released and 995 killed by rods. Together with 935 wild salmon killed by nets, a total of 1,949 endangered wild salmon were killed prematurely before they had a chance to breed and reproduce the next generation of wild salmon. The obvious question for Scottish Government is that if salmon is so endangered, then why are fish being killed at all?

Returning to the 2024 provisional catch data, the biggest puzzle of all is that the data includes details of catches from both east and west coast rivers as separate tables. This is a puzzle for two reasons. The first is that the data is not differentiated in this way by coast in the official data so why is it in the provisional data and the second reason is that the only people who talk about east and west coast salmon fisheries are those who want to attack the salmon farming sector. Could it be that the way this data is presented is actually a reflection of the views and beliefs of the scientists working for the Marine Directorate. If this is the case, then it has backfired on them because the 2024 catch data as presented by them is rather enlightening.

Notwithstanding about the use of 2023 provisional data, the 2024 figures show that catches of salmon from east coast rivers (40,737) have increased by 11,874 salmon equating to an increase of 41%.

The catches from the west coast rivers (6,241) have increased by 2,887 wild salmon equating to an increase of 48%, which is more than the increase in the east coast.

Finally, it is worth pointing out that despite the alleged but unproven impact of salmon farming, anglers have still managed to kill 111 wild salmon from west coast rivers. This includes 49 large salmon and 62 grilse. This equates to 10% of all the endangered wild salmon killed by anglers.

Unfortunately, we now must wait another eight weeks for the completed full dataset to be published. I’d offer to send my abacus to the Marine Directorate to speed things up if I thought it would help.

 

Debate: Last week the Scottish Parliament debated the motion submitted by Finlay Carson MSP on behalf of the Rural Affairs and Islands Committee as a follow up to their inquiry into salmon farming.

What I found most disappointing about the debate was actually Mr Carson’s opening address. He said two things that raised my blood pressure. The first concerned mortality. Referring to suggested interventions that could support a reduction in fish farm mortality, Mr Carson said that the committee recommended that more research should be commissioned into the causes of mortality.

One of the four written submissions I made to the committee detailed that the biggest cause of mortality of farmed salmon was the effects of repeated treatments for sea lice as dictated by Scottish Government regulation. The committee chose to ignore all of my submissions, preferring to cite those from Wild Fish, Coastal Community Network and Animal Equality, who all want to see an end to salmon farming in Scottish waters. However, whilst the committee weren’t interested in what I might have to say, they might have been more interested in the 2024 Fish Health report from the Norwegian Veterinary Institute which was published a week before the debate. One of the main causes of mortality on Norwegian salmon farms is sea lice treatments. The diseases that are the other main cause of death are also likely to be secondary infections following sea lice treatments.

What we don’t need is more research or improved reporting but a new discussion on sea lice, which the committee chose to avoid. Are sea lice responsible for wild salmon declines? Do we need to maintain low levels of lice to protect wild salmon? Do we need to treat farmed salmon to keep such low levels? Do we even need a Sea Lice Risk Framework? Sadly, neither the Committee, the Marine Directorate nor SEPA are interested in discussing such questions.

The second point made by Mr Carson was that the committee had felt that there had been minimal progress made on the subject of interactions between farmed and wild salmon since the 2018 REC inquiry. I can only repeat my earlier position that if the committee had taken note of any of my submissions, they would have seen that major progress has been made in our understanding of such interactions, but as is patently clear, those who prefer to attack the industry either directly or indirectly, aren’t interested in learning about our improved understanding. They much prefer the narrative that salmon farming is an environmental disaster especially for wild fish.

Mr Carson refers to the Salmon Interaction Working Group recommendations saying that only one of the 42 recommendations had been implemented. This is considered disappointing, but I would argue that had there been a proper discussion about the science instead of considering that the subject was too contentious to debate, then most of the 42 recommendations would have never been made.

As to the rest of the debate, the only points worth mentioning are:

  1. The impressive speech made by Fergus Ewing
  2. That when asked whether the Greens had made any assessment on imposing a pause on industry development, Ariane Burgess chose not to answer.
  3. How repetitive most of the speeches were.
  4. The support for the industry from the Cabinet Secretary.

The committee wants to revisit salmon farming in a year’s time. Unless they actually want to learn about salmon farming, then this would be a total waste of time.

 

Stepping down: It has been difficult to know how to respond to the news that Mairi Gougeon, the Cabinet Secretary for Rural Affairs, will not stand for re-election at next year’s Scottish Parliamentary elections. Ms Gougeon has been considered a real friend to the salmon farming industry, certainly something that is also said by industry critics, yet at the same time, she has overseen the imposition of the Sea Lice Risk Framework, which will undoubtedly undermine the long term future of the industry in Scotland and yet fail to safeguard the future of wild fish, which is the main reason for the introduction of this regulation.

The Sea Lice Risk Framework is not one of the policies of which she is most proud as she has highlighted the Good Food Nation Act and the Agriculture and Rural Communities Act as particular highlights.

According to the Times newspaper, her impending resignation took many by surprise by senior insiders said that she did not appear to have been enjoying the work for some time. It  is only conjecture, but could she have been struggling to work with the Marine Directorate over such issues as the Sea Lice Risk Framework? Interestingly, her predecessor Fergus Ewing had been accused of bullying by a number of employees at the Marine Directorate, but I understand that this may have been simply an expression of frustration by the Cabinet Secretary over the way that the Marine Directorate had dragged its heels over resolving certain issues.  Certainly, anyone reading reLAKSation over the years would understand that the Marine Directorate seems to prefer backing their employees’ views rather than examining the issues.

I would ask Ms Gougeon before she leaves her current role and wider politics to consider re-opening the discussion over the impacts of sea lice on wild fish. Although we now have a SEPA Sea Lice Risk Framework, there has never been an open discussion on whether this new regulation will stop the decline of wild fish.

She should consider that since 2016, the Marine Directorate have overseen the introduction of The Salmon Conservation Regulations and yet here we are in 2025, and wild Scottish salmon stocks are in the worst state ever. The Sea Lice Risk Framework will do absolutely nothing to change that, nor will it stop the decline. Perhaps, Marine Directorate scientists do not have all the answers, which is why there needs to be a discussion now. I hope that Ms Gougeon doesn’t regret not taking the initiative now so that the Sea Lice Risk Framework comes to be recognised as her greatest failure. It would also be one that could represent a loss to the UK economy of more than £760 million every year. This is highly likely unless this flawed regulation is revisited as a matter of urgency.