Missing Salmon Alliance members respond to the Scottish Environment Protection Agency’s consultation on managing sea lice from marine finfish farms and their impact on wild salmonids in Scotland
Slow progress and a lot more needed
Missing Salmon Alliance members, Fisheries Management Scotland and the Atlantic Salmon Trust, have responded to the Scottish Government’s consultation on the detailed proposals for a risk-based, spatial framework for managing interaction between sea lice from marine finfish farm developments and wild salmonids in Scotland. This follows an earlier consultation on the impacts of sea lice on wild fish and the need to implement the recommendations of the Salmon Interactions Working Group.
While many of the proposals set out in the consultation are welcome, MSA members feel there is a lot more that can and should be done and that implementation of these proposals and actions to properly manage the threat posed to salmon and sea trout from sea lice needs to happen more quickly. Given the climate and biodiversity crises, coupled with the dramatic decline in wild salmon numbers, there is no time to lose.
If this framework is to make a real difference, then it must meet the test set out by the Scottish Interactions Working Group of being robust, transparent, enforceable, and enforced. Anything less will mean there is no guarantee of success.
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, coupled with the length of time wild fish remain in the areas when they can become infected.
The Scottish Environment Protection Agency’s (SEPA) proposed regulatory approach of managing overall lice numbers arising from fish farms below a critical threshold specifically identified for the protection of wild fish is welcome. However, MSA members believe the critical exposure threshold should be set at a lower level. As wild salmon migrate through Scottish coastal waters, it is important that the cumulative impact of sea lice on wild salmon as they pass through multiple Wild Salmonid Protection Zones (WSPZs) is taken into account. WSPZs are areas of sea in which SEPA consider wild post-smolts are at greatest risk of harm if sea lice levels are high.
Much of the consultation is centred around applying regulation to new and expanding fin fish farms, but it is crucial that the risk and impacts from existing fin fish farms are managed as a priority.
We do not think the proposal’s focus on the use of a ‘no deterioration’ condition is appropriate. Any impacts arising from existing farms must be addressed with urgency and SEPA should apply precautionary lice limits for existing farms until refined modelling (led by SEPA) identifies an appropriate lice limit that 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 tighter timescale than is currently proposed.
SEPA have committed to develop a bespoke framework for sea trout. This Priority Marine Feature needs protection now, so this framework must be developed as a matter of priority, and soon. In the interim, SEPA must extend the current approach for salmon to cover the period within which it can be reasonably expected that sea trout will be present in WSPZs, this is likely to be well beyond the arbitrary dates SEPA have defined as being April to June.
We are concerned that the boundaries of many of the WSPZs being set at 5km does not provide enough protection. The size of these WSPZs needs to be substantially increased, and where appropriate, adjacent WSPZs should be combined.
We are concerned that this framework only applies to a limited number of Scottish rivers and feel strongly that it should include all rivers that hold, or have previously held, salmon or sea trout populations.
Missing Salmon Alliance members will continue to raise concerns through engagement with SEPA, and robustly argue for the improvements we feel are necessary to make this framework effective and deliver greater protection for salmonids from sea lice as they transit and populate our coastal waters.
As an Alliance of six organisations, we will build on the existing work of our partners and maximise our impact by taking a coordinated approach and vital action in order to halt and reverse the decline of wild Atlantic salmon.
The goal of the Missing Salmon Alliance is to build an evidence-base to influence national and international decision-makers to regulate activities that adversely impact wild Atlantic salmon.
The Missing Salmon Alliance
The MSA is comprised of the following members:
Game & Wildlife Conservation Trust, Atlantic Salmon Trust, the Angling Trust with Fish Legal, The Rivers Trust and Fisheries Management Scotland.
https://www.missingsalmonalliance.org