Salmonid farmers launch mass challenge to licence changes
Scottish Government department is flooded with appeals against moves by environment watchdog.
Scottish salmonid farmers have launched formal appeals to Scottish Government ministers against revised licensing conditions that they say are unnecessary, flawed, and could lead to higher stock mortality.
Salmon farmers Mowi, Bakkafrost, Scottish Sea Farms, and Loch Duart, along with trout farmer Kames, are challenging amendments made to their farm licences by the Scottish Environment Protection Agency (SEPA) under its Sea Lice Regulatory Framework.
The Scottish Government agency has issued “variation of authorisation” notices to a number of sites, ordering that a site-specific limit on the number of adult female sea lice calculated to be attached to farmed fish will form part of the farm’s licence conditions from late March. The appeals are likely to delay the implementation of the variations for months.
Code of Good Practice
There is currently no numerical limit per farm, and fish farmers make their own decisions about when to de-louse their fish, which depends on several factors including the underlying health of the stock.
The Scottish industry’s Code of Good Practice suggested criteria for the treatment of sea lice on individual farm sites are an average of 0.5 adult female lice (Lepeophtheirus salmonis) per fish during the period February 1 to June 30 inclusive (when wild salmon smolts may be migrating to sea) and an average of 1.0 adult female L. salmonis per fish during the period July 1 to January 31 inclusive.
The Scottish salmon sector has spent millions of pounds on wellboats to increase its capacity to treat for lice with freswater baths and mechanical methods in recent years, and lice levls on farms are the lowest since records began in 2013.
Wild smolts
SEPA believes that changing the rules will better safeguard wild salmon smolts from lice from fish farms that they pass during their migration.
But fish farmers say SEPA’s modelling massively overestimates the number of lice on farms and the threat to wild smolts. They also claim that SEPA has exceeded its authority and that the licence variation notices it has issued to farmers are illegal.
The fish farmers have appealed to ministers through another Scottish Government department, the Planning and Environmental Appeals Division (DPEA) in Falkirk, and are calling for the notices to be quashed. At time of writing, notices of appeals against variations at 33 farms had been posted on the DPEA website.
Single lead body
SEPA was put in charge of sea lice limits on salmon farms following a report by the Salmon Interactions Working Group (SIWG) that was established after two Scottish Parliament inquiries into salmon farming.
The SIWG recommended that a single lead body should be assigned responsibility for regulating wild and farmed fish interactions, and that robust conditions, based on an adaptive management approach, to safeguard wild salmon and sea trout should be contained within a fish farm licence rather than through planning consent. The so-called CAR licence required by fish farms is already issued by SEPA under the Water Environment (Controlled Activities) (Scotland) Regulations, making it an obvious choice as the lead body.
SEPA says it spent two years consulting with fish farmers, wild fishery managers, environmental NGOs, other public bodies, coastal community groups and scientists specialising in sea lice and wild salmon interactions before putting forward its Sea Lice Regulatory Framework.
Higher mortalities
Fish farmers say sea lice dispersion models used by SEPA to predict the possible threat to wild smolts from fish farms are wrong, and that lower lice limits that force farmers to de-louse fish when it is not necessary for the good of the fish will lead to higher mortalities.
Ben Hadfield, chief operating officer farming for salmon giant Mowi in Scotland, Ireland, the Faroes, and Atlantic Canada, believes the SEPA model over-predicts sea lice concentrations, “possibly by a factor of 4 or 5”.
Speaking in August last year, Hadfield said SEPA’s model uses a very low impact threshold which equates to detectable effects on wild salmon smolt behaviour but not levels that would induce high mortality.
“It assumes all salmon farm biomass is constantly at its maximum, which it is not and, crucially, it is yet to undergo full validation to remove layer upon layer of over-precautionary assumption in order to attain a realistic correlation,” said Hadfield.
“If this is not changed, then it will overregulate and force unnecessary treatment of farm-raised salmon which will challenge the high welfare of stocks, which all salmon farmers work for daily.”
No other option
Tavish Scottish, chief executive of trade body Salmon Scotland, said its members had been left with no choice but to appeal.
“We support better regulation, not more red tape. We want an evidence-based, scientifically backed framework that helps local authority planners make decisions," said Scott.
“We will continue to work with regulators on a better approach.
“SEPA’s current plan will not work and leaves business with no option but to appeal. Now that process is underway we can’t say anything further.”
