Information, Gill Health, Sea Lice and Cleaner Fish sub group prioritises: EIR release

Information request and response under the Environmental Information (Scotland) Regulations 2004.

Information requested

You asked for a copy of the work plan discussed in the Information, Gill Health, Sea Lice and Cleaner Fish sub group Terms of Reference of 23 November 2018, and any information relating to that work plan.


As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

Our aim is to provide information whenever possible.

The Farmed Fish Health Framework (FFHF) established four dedicated subgroups to deliver across four workstreams and related subgroups, one of which is IGSC. You requested a copy of the work plan for the IGSC sub group, but although early drafts of this were made, it was not finalised. Instead, due to the breadth of the related work, the FFHF Steering Group asked each subgroup to identify three top priorities and give a completion timeline. This replaced the requirement for all-encompassing subgroup work plans.

The IGSC subgroup is prioritising;

  • Sea lice modelling work (as outlined in the FFHF)
  • A review of Marine Scotland’s farmed fish sea lice compliance policy (on which the Cabinet Secretary for the Rural Economy provided a Parliamentary statement in June 2019, accessible through the official record on the Scottish Parliament web site.)
  • A fish farm mortality by cause analysis

In 2020, the IGSC subgroup also plan to conduct a project on Barents Watch, the Norwegian Aquaculture Information Portal;, and a review of Scotland’s Aquaculture Website:

For your interest, I also attach a link to recent letter from the Cabinet Secretary for the Rural Economy to the Conveners of the Rural Economy and Environment Committee and the Environment. Climate Change and Land Reform Committee, which details the current position on the acitvities of all FFHF subgroups:

You may also find the FFHF Steering Group meeting minutes useful:

About FOI
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at


Please quote the FOI reference
Central Enquiry Unit
Phone: 0300 244 4000

The Scottish Government
St Andrews House
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