Before I open the debate on behalf of the Rural Economy and Connectivity Committee, I refer members to my entry in the register of members’ interests, specifically my interests in a wild salmon fishery.
I also give special thanks to the committee’s clerking team and the team from the Scottish Parliament information centre who supported us during the inquiry. They responded to the particular challenges of the inquiry with a professionalism that has enabled the production of a detailed report.
During 2018, the committee conducted an in-depth inquiry into salmon farming in Scotland. Our inquiry was prompted by a public petition on the impact of the farmed salmon sector on wild salmon stocks. It was clear that the problem went beyond that, so our inquiry looked at further matters: we looked at the current state of the salmon farming industry in Scotland; we identified opportunities for its future development; and we explored how the various fish health and environmental challenges could be addressed.
We took oral evidence from industry representatives, research bodies, environmental organisations, Highlands and Islands Enterprise and all the regulatory bodies. We were also extremely grateful to those organisations and individuals who took the time to submit detailed and often technical written submissions to inform our deliberations.
The committee’s inquiry was also informed by an important piece of work that was carried out in advance of our wider inquiry by the Environment, Climate Change and Land Reform Committee on the impact of salmon farming on the marine environment. We were extremely grateful for that valuable contribution, which demonstrated the benefit of two committees working jointly together.
The committee was also aware of a range of relevant activity by the Scottish Government, the Scottish Environment Protection Agency and the salmon industry that occurred after we had finished taking evidence and which included: publication of the Scottish Government’s “Scotland’s 10 Year Farmed Fish Health: strategic framework” in May 2018; the announcement in June 2018 of a salmon interactions working group, which will examine and provide advice on the interactions between wild and farmed salmon; and the publication of a “Finfish Aquaculture Sector Plan” by SEPA in November 2018. Both the Scottish Government and SEPA also provided responses to the committee’s report just last week.
There are some key messages and recommendations in the report that I would like to highlight. First, I should make it clear that the committee acknowledges both the economic and the social value that the salmon farming industry brings to Scotland. It provides jobs in rural areas, brings investment and spend into local communities and stimulates economic activity in the wider supply chain. However, the committee believes that the contribution made by the industry to the Scottish economy should not be allowed to mask any negative impact on the environment. I will touch on some of those specific issues later.
It is clear to the committee that those in the industry wish it to expand. However, the committee strongly agrees with the view of the Environment, Climate Change and Land Reform Committee that until they can demonstrate that they can truly be good neighbours, it is not appropriate for it to do so. The industry needs to rise to the challenges that it faces on fish health and the environment and the committee feels that in order to do so, the status quo in terms of regulation and enforcement is not acceptable. That view was shared by the majority of stakeholders, including industry representatives and, importantly, the Scottish Government, in its response to our report.
The committee is, therefore, of the view that urgent and meaningful action needs to be taken to address regulatory deficiencies in order to raise the bar for the industry and thus protect our environment and the industry’s future. The committee is also firmly of the view that a stricter regulatory and consent regime, which is also fair and proportionate, can only benefit the sector, helping to drive improvement and giving it confidence that it is meeting its environmental responsibilities.
Let us be clear: the reputation of Scottish salmon as a premium product must be maintained. The committee is in no doubt that consumers and markets see Scotland as a producer that meets the highest international production, fish health and environmental standards. We must ensure that that continues. Therefore, the committee welcomes the recognition by some key producers of the benefits that enhanced regulation would bring to their product and their support for the recommendations that we have made.
On sea lice, the industry must accept that currently neither chemicals nor cleaner fish can totally solve the issue. We strongly believe that there should be a mandatory and timely approach to the reporting of sea lice infestations. We recommend a compliance policy that is robust and enforceable with appropriate penalties. I note from the Scottish Government’s response that it is already reviewing the farmed fish sea lice compliance policy and expects to complete that by the spring.
Although that exercise considers the mandatory reporting of sea lice levels from March 2019, it will be done only monthly in arrears. In other countries in which our key producers operate, it is done weekly in arrears. One has to ask why the Government is content to achieve less. Overall, the work on sea lice is positive, but there can be no halfway house in what it delivers. Although we acknowledge the work that the industry is doing, there is a great deal of work still to be undertaken to tackle the sea lice problem.
On farmed salmon mortalities, the committee and the industry believe that the current level of farmed fish mortality is too high. Losing between 20 per cent to 25 per cent of all fish put to sea is not acceptable. The committee believes that until health issues are addressed to the satisfaction of regulators, no expansion should be permitted at sites that report high or significantly increased levels of mortalities. The Scottish Government has said that it will publish mortality reports monthly in arrears and will consider options around web-based and real-time site reporting on mortality. It has also said that it will consider a broader review of the transportation and disposal of dead fish. Again, that is a welcome step forward on reporting, but Scotland is again setting a lower bar than that set by our key producers elsewhere, and it is disappointing that the Scottish Government does not consider that there should be restrictions on expansion at sites with high levels of mortalities.
Turning to environmental regulation, the committee shares the view of the Environment, Climate Change and Land Reform Committee that the regulatory tools that are currently available to SEPA are neither adequate nor effective. The Environment, Climate Change and Land Reform Committee recognised that SEPA has not been performing well on monitoring or enforcing the regulations, and that is our view as well. The sector has shown poor rates of compliance with SEPA’s current standards. That is borne out by the results of SEPA’s compliance assessment process for 2017, which showed an increase in the number of salmon farms that had failed to meet the required standards. The committee is clear that SEPA must respond to its failures. I am sure that the committee will want to monitor progress in that area with interest.
On the location of salmon farms, the committee made several important recommendations. It said that there should be a precautionary approach to applications for new sites and the expansion of existing sites; that there is a need to locate new farms in more suitable areas, away from wild salmon migratory routes; that there should be a more strategic approach to identifying areas across Scotland that are either suitable or unsuitable for the siting of salmon farms; and that work should be done to move existing poorly sited farms to suitable sites.
We called on the Scottish Government to provide strong and clear leadership to ensure that those actions are taken. However, it is concerning that, in its response, the Scottish Government suggests that the precautionary principle has been applied and
“will continue to be applied in a meaningful and effective manner”.
That is not what we heard in evidence.