SCOTLAND'S nature preservation agency has raised concerns about the growth of fish farming and the risk to wild salmon as objections grow about how the aquaculture industry is dealing with a 'crisis' over on-site deaths.
Current concerns have focussed on one of the nation's most environmentally sensitive areas, the Firth of Clyde which is facing a 58% rise in the extent of fish farming through seven new and expanded projects which campaigners fear provides a "serious risk" to wild salmon while also acting as blots in a protected area.
Sea lice are posing a major problem across Scotland’s farmed salmon industry, with parasites from open net farms earlier this year.
The parasites, which thrive in cramped cages and feed on the mucus, skin and blood of fish, result in salmon being virtually eaten alive.
NatureScot, the lead Scottish Government advisers on nature, wildlife management and landscape, in objecting to one fish farm plan, raised its concerns that proposed development of new sites between Bute and Great Cumbrae may pose a "significant risk" to Atlantic salmon in the the protected Endrick Water "either on their own, or in combination with, other planned or existing marine fish farms".
There are currently over a dozen licensed salmon farms in the Greater Clyde including Loch Fyne.
A NatureScot internal review of a recent increase of marine fish farm activity in the upper Clyde estuary identified a "potential risk" to the protected Endrick Water which flows into Loch Lomond from the east, a river protected by law for its importance to wild salmon. It said the risk was through what it called the "interaction" of young salmon and sea lice.
It warned that wild Atlantic salmon nationally is "considered to be vulnerable" with the rod catch for the whole of Scotland in 2018 at the lowest level since records began in 1952.
According to Marine Scotland the decline in the wild salmon catch is mirrored in other countries, reflecting a continuation of a real decline in salmon numbers.
Latest data reveals that the amount of salmon at fish farms killed by diseases and other problems is still equalling record levels from three years ago, with death rates rising by over five-and-a-half times over the last 18 years.
Some 25,770 tonnes of caged salmon - equivalent to more than 11 million fish died prematurely in 2019.
And it has emerged that ministers have brought in mandatory reporting of sea lice numbers on a weekly basis for Scottish fish farmers, following concerns over the parasites.
The Scottish Salmon Producers Organisation (SSPO) said ministers identified salmon farming as among the 12 potential pressures to be explored regarding any impact on wild salmonid numbers and has been working collaboratively over impprovements.
Wild Atlantic salmon are an iconic Scottish species, found in hundreds of rivers across Scotland.
They are no longer fished commercially anywhere in the UK. Instead, hundreds of thousands of fish at a time are raised in pens around Scotland's west coast and the Northern Isles.
According to a 2019 Scottish Parliamentary briefing, salmon fishing in rivers and at the coast supports 4,300 jobs. But it also has an important ecological and cultural value, having been part of the natural ecosystem for millions of years, and played a part in human society for many millennia.
But salmon as food is also big business for Scotland, with a staggering one million salmon meals eaten in the UK every day.
It is Scotland’s single biggest food export – worth £600 million – and is estimated to support nearly 11,000 jobs many in Scotland’s most fragile rural communities.
The SSPO says salmon farming is "vital to the ongoing success of thousands of supply chain businesses across the country".
While major research is ongoing into the decline of wild salmon, some experts at Marine Scotland believe its wider decline is thought to be related to changes in the marine environment.
A number of studies have pointed the finger at climate change as a key driver behind recent changes in growth and survival of salmon at sea. The fish are sensitive to water temperature changes.
Other experts suggest issues for wild salmon have increased since 1996 because of drift netting, water abstraction, agricultural run offs, intensive farming, and obstacles put in their paths, from weirs to surfactants.
Peter Pollard, head of ecology with the Scottish Environment Protection Agency regulator has said that sea lice from farmed fish cannot be held responsible for the declines in wild fish over decades. He has told MSPs that there are a "complex range of reasons, some of which are probably to do with high seas changes".
"The concern is whether the additional pressure of sea lice is now significant, as wild stocks are at such low levels," he added.
But concerns continue to be raised about a proposed doubling of fish farming production by 2030 while "shocking" levels of fish farm deaths emerge.
The Salmon and Trout Conservation Scotland is among those calling for a rigorous regime of independent monitoring and verification of salmon farms to resolve the problem, after it says proper regulation and enforcement have failed to be introduced.
NatureScot outlined its wider concerns as it raised an official objection over one of the projects in the pipeline put forward by the Scottish Salmon Company (SSC) to create a 12-cage salmon farm off Millstone Point on Arran, home to bottle-nosed whales, dolphins and harbour porpoise.
The objection which focuses on the effect on protected areas means that if North Ayrshire Council planned to grant approval for the project - they must notify Scottish ministers.
The agency called for an Environment Management Plan for the project which should detail proposed management, monitoring and mitigation measures that would be employed to manage and control sea lice.
It suggested that a strict limit to the numbers of adult female sea lice would need to be applied to fish farms with the "potential to negatively impact" on the protected Endrick Water.
It also requested that commitments were made to "make material changes to the management of the farm should an elevated risk to the salmon population" in what is a designated Special Area of Conservaton be identified. It should also illustrate how the plan would protect fresh water salmon population.
It has told the council that guidance in the Seascape and Landscape Assessment of the Firth of Clyde from eight years "confirms that this area should be avoided and that the special characteristics of the isolated coast should be protected".
Other farming projects that have been in the melting pot in the Greater Clyde area include plans by trout farmer Dawnfresh's to develop a farm at Hawk’s Neb on the Isle of Bute as well as three other projects at Ardentinny, Little Cumbrae and Greater Cumbrae. Mowi (formerly Marine Harvest) have plans at North Kilbrannan and the Scottish Salmon has fish farming proposals for Ardyne.
The Friends of Millstone Point, who are concerned about the potential growth of salmon farming in the Firth of Clyde, commissioned its own independent scientific study over the impact of the industry and fears a "potential catastrophe".
The investigation report by Dr Tom Scanlon of consultants MTS-CFD highlighted the scale of current and potential salmon farm sea lice distribution and the potential for wild fish to interact with the parasites from multiple existing and proposed farms.
The former senior lecturer in the Department of Mechanical and Aerospace Engineering at the University of Strathclyde who has 25 years of hydrodynamics modelling gave the results of an exploration of the oceanography of the Firth of Clyde with regard to sea lice distribution from fish farms.
He said: "Lice dispersion was observed to be widespread across the Clyde system with higher concentrations appearing in the Kilbrannan Sound and around the Cumbraes (from proposed farms)."
The consulant, who developed a computer model of the tides, winds and currents within the Firth of Clyde and surrounding areas as part of the project added: "Sea lice from salmon farms add to the cumulative pressures on wild salmon and sea-trout numbers in the Firth of Clyde. Each new farm increases this load. As the migratory paths of wild fish are unknown it would be wise to adopt a precautionary approach with regard to aquaculture development in the Clyde system and beyond.
"This will help to ensure a future for wild salmon and sea-trout as they migrate to and from spawning grounds in the coastal rivers of the Firth and beyond to Loch Lomond."
Charles Clover, executive director of the conservation organisation, the Blue Marine Foundation, said much more needs to be done to regulate the fish farming industry before any expansion.
“Over thirty years of lax regulation of salmon farming in Scotland has brought us to this: the salmon and sea trout of the Loch Lomond river system, a place famous throughout the world as one of the iconic parts of Scotland, and on the doorstep of millions of Scots, is now at risk from the simply huge number of fish the salmon farming industry wants to keep in the Firth of Clyde and the burden of parasites in the water that this will bring, according to the Scottish Government’s own nature advisers," he said.
"Salmon and sea trout are migratory fish. Both spawn in the headwaters of the Lomond river system, one of which is the Endrick Water, which is protected by European law precisely because it provides an essential link in the life cycle of the protected salmon and sea trout.
"The salmon and sea trout hatch then migrate to the sea, via Loch Lomond and the River Leven which empties it. The salmon smolts head out through a curtain of lice to Greenland to feed, the sea trout feed much more locally and in this storm of parasites and pollution in the Greater Clyde. The mortality of both species goes up accordingly. Then the poor things have to migrate back to the river in the autumn, running the gauntlet again.
READ MORE: Salmon farm creates 'serious threat' to life in a protected Scottish sea zone
"The fish are the soul of Loch Lomond, in my opinion. Lomond produces really big salmon, trout and sea trout. If they were not there it would be like the savannahs without elephants. It would have no soul.
"The potential environmental and social downsides of the expansion of salmon farming in Scotland now need to be faced up to, and an effective regulatory system with teeth put in place, before any further development goes ahead in the already overdeveloped Clyde."
Local objectors to the expansion of salmon farming in the Clyde say that any sea lice limit "is almost impossible" for local authorities to monitor or enforce and that the cumulative impact of the parasites from both existing and proposed salmon farms should be reviewed.
Paul Chandler of Friends of Millstone Point said: “We want the Scottish Government to assess cumulative impacts of new and existing farms – which are potentially catastrophic in the Clyde – but they are not doing it."
“The Scottish Government, and local planners, looks at the impacts farm by farm and there is no attempt to look at it cumulatively. This way you would never get to a point where you would say stop, no more. The Government needs to do that capacity assessment – on the Clyde and elsewhere.
“Doing it this way, without looking into how much salmon farming the Clyde can stand, is always costing someone else. There is no assessment of the costs of salmon farm expansion to the environment and to local communities.”
The angling clubs on Loch Lomond and on the Endrick Water have memberships stretching into thousands and there are estimated to be many more hundreds of local and visiting anglers who fish the rivers of Ayrshire, Arran and the Mull of Kintyre.
Gareth Bourhill, secretary of the Loch Lomond Angling Improvement Association, said: "Thousands of ordinary angling club members from around the Clyde region face losing their sea trout and salmon fishing if these new farms go ahead."
NatureScot, in its objection raised concern about the environmental impact of the latest fish farm project off Arran.
It said the location was "highly sensitive to aquaculture development and does not have the capacity to accommodate the nature or scale of development proposed."
A spokesman for the Scottish Salmon Producers Organisation (SSPO) said: “The Scottish salmon farming sector is committed to sustainable growth and recently published a ground-breaking charter containing 5 key pledges and 40 actions to ensure that it is world-leading in producing healthy food for people in the most sustainable and responsible way. The sector continues to invest heavily to overcome the challenges faced by all farmers and sea lice levels remain at some of the lowest since 2013 with the numbers for autumn 2020 the lowest on record.
"Scottish Government figures show that in 2018 Scotland’s salmon farmers bought more than £1 billion of goods and services from Scottish companies.”
A Scottish Salmon Company spokesman said they were awaiting a final response to its plans by NatureScot, had carried out a consultation with stakeholders and had already acted to incorporate a number of their recommendations into their proposed Environmental Management Plans for the site.
“We take our stewardship of the local environment very seriously and the proposed site will adhere to all relevant regulation and high levels of environmental care and management. Our proposal will deliver significant economic and social benefits to Arran and the wider economy in a time of great uncertainty for rural communities across the country," a spokesman said.
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