First and foremost a message of thanks is due to the Chair of the Salmon Interactions Working Group (SIWG), John Goodlad, for his dedication and to the entire SIWG membership for delivering over 40 recommendations to the Scottish Government on a new interactions approach. It was during a period of ongoing global crisis in 2020 that the SIWG published its recommendations report and we commend the Group and its Chair for seeing this crucial piece of work across the line at a time of great difficulty when life was most certainly not as usual following EU exit and during the Covid-19 pandemic.
Both the fish farming industry and wild fisheries sector are of economic and social importance to Scotland. The 2017 Analysis of the Value of Wild Fisheries in Scotland Report found that the Scotland-wide economic impact assessment of wild fisheries (which included netting) indicated around £135m of angler expenditure, 4,300 full-time equivalent jobs and £79.9m Gross Value Added (GVA) in 2014. Aquaculture and its wider supply chain alone contributed £880m GVA and supported 11,700 jobs and livelihoods in Scotland in 2018.
The benefits of driving sustainable growth of Scottish aquaculture with due regard for the environment are many. They include contributing to sustainable global food production and security; economic recovery in Scotland where it (and our recreational fisheries sector) adds significant value to local supply chains; supporting livelihoods and much needed investment in communities across rural Scotland.
Significant, sustainable and inclusive growth can only be realised where environmental, social and economic interests are adequately addressed. That means growth must be within environmental limits and develop in a way which supports strategic biodiversity and environment aims. . We must also ensure that Scotland meets its international obligations, including the NASCO Williamsburg Resolution of which the UK is a signatory and through which we are committed to minimising the impacts and risks presented by aquaculture to wild salmonids.
The Scottish Government considers the work of the SIWG as crucial to driving reform of the way we consider regulation of fish farms in Scotland and to help address pressures facing our iconic wild Atlantic salmon. It has to be born in mind that the reasons for the decline in wild salmon stock are wide-ranging and complex. Pressures have been categorised into 12 nominal high level pressure groups, including climate change (water quality and scarcity, water temperature), loss of trees/shade, man-made barriers to migration, exploitation (recreational fishing & commercial sea fisheries), predation, sea lice and disease, escapes and invasive non-native species (including signal crayfish in Scotland).
Alongside pressures on marine and river habitats, climate change seems to be a general driver of decline. Tackling those pressures requires cross-cutting actions across a number of policy areas, and there are clear connections to our Land Use, Biodiversity and Environment Strategies and Climate Change Plan.
Recognising the need for action to protect wild salmon, Scotland has a rigorous regime of statutory salmon conservation orders in place which are refreshed annually. The Conservation of Salmon (Scotland) Regulations 2016 outlined for the first time a system under which the killing of Atlantic salmon in inland waters is managed on an annual basis by categorising the conservation status of their stocks. However, most rivers practice voluntary catch & release, with >90% of all caught salmon being returned to the river. The Regulations also prohibit the retention of salmon caught in coastal waters and in 2019, the Scottish Government determined that the prohibition on retaining salmon caught in coastal nets should remain in place.
The 2017/18 Scottish Parliamentary Inquiries into salmon farming shone a light on the opportunities for the sector, but also identified a significant number of challenges. The Inquiries’ recommendations indicated that the status quo was not an option and the Scottish Government committed to moving beyond the status quo. This response sets out the actions which we will take to address the jointly agreed SIWG recommendations.
We are committed to going further still. In August 2021 we launched an independent review of the current regulatory processes involved in fish farming to ensure that the regulatory regime is efficient, effective and transparent, and to seek recommendations on work to reform the current regulatory framework. That review is essential to securing the sector's future prosperity and sustainability, however, it does not mean that we will pause progress on the known issues.
Environment, climate change and biodiversity challenges have never been more acute. Later this year, Scotland will take its place on the world stage and host the United Nations Climate Summit COP26 in Glasgow. The Scottish Government has reached a ground-breaking agreement with the Scottish Green Party that meets the challenges and opportunities of our time. The Shared Policy Programme includes an ambitious aquaculture agreement and commits to a step change in how we manage the marine environment. We committed to beginning an immediate programme of work to better protect wildlife and the environment, including publication of this response, consultation on an adaptive spatially-based risk assessment framework and strengthened controls on sea lice and escapes in the course of 2021/22.
To meet our commitments;
- The Scottish Environment Protection Agency (SEPA) will become the lead body responsible for managing the risk to wild salmonids from sea lice from fish farms.
- SEPA will consult on proposals for an adaptive spatially-based risk assessment framework for managing sea lice interactions between farmed and wild salmonids, which will be applied through the Water Environment (Controlled Activities) (Scotland) Regulations 2011.
- We will take forward a programme of work to make fish farm containment measures and regulation more robust, including the introduction of penalties for fish farm escapes with the ultimate aim of ring-fencing or redistributing this money to support wild salmonid conservation and research.
- A Wild Salmon Strategy will be published by the end of 2021 which will provide an overarching framework to tackle the pressures on wild salmon.
As we look ahead to economic recovery via our Blue Economy (supported by partners such as the Sustainable Aquaculture Innovation Centre), now more than ever it is crucial that we balance environmental, economic and social responsibilities. We acknowledge the Scottish farmed salmon sector's commitment to its responsibilities when considering further growth; this is demonstrated by their sustainability charter, A Better Future For Us All, which makes clear commitments across a range of areas including the environment.
It is now time for the Scottish Government and its agencies to set out its aspirations for the fish farming sector. In 2022, we will deliver a Scottish Government led aquaculture vision that places an enhanced emphasis on environmental protection and community benefits.
The SIWG report and our response is testament that all parties involved are committed to making improvements in key areas as highlighted by the Parliamentary Inquiries. Both sectors have shown their commitment to collaborative working, for example, through helping to progress the Atlantic Salmon Trust, Fisheries Management Scotland and Marine Scotland Science West Coast Tracking Project, supported by funding from the Scottish Salmon Producers' Organisation (SSPO) and the launch of the Wild Salmonid Support Fund, a 5-year programme administered by Foundation Scotland that will see £1.5 million invested by the SSPO to invest in projects which benefit wild salmon and sea trout stocks in Scotland.
That close working and collaboration must continue to ensure that Scotland reaches its full potential and is able to support both sectors, which equally rely on a shared marine and freshwater environment.
Mairi Gougeon, MSP
Cabinet Secretary for Rural Affairs and Islands
Mairi McAllan, MSP
Minister for Environment and Land Reform