‘Salmon and Trout Conservation Scotland’s 2016 Petition to the Scottish Parliament led to the 2018 ECCLR and REC Committee inquiries into salmon farming. The REC Committee identified that “the ‘status quo’ in terms of regulation and enforcement of the fish farming industry is not acceptable”.

In response, the Scottish Government tasked the Salmon Interactions Working Group (SIWG) to look at the conclusions of the Committees, evaluate current policy and advice governing interactions and make recommendations. However, the requirement that the SIWG must reach consensus has prevented the SIWG from bringing forward recommendations that fully address the damage being caused to wild salmonids (salmon and sea trout) by fish farming.    The SIWG has also moved beyond the remit of wild/farmed salmon interactions, considering the wider conservation of wild salmonids and has adopted the ‘narrative’, pushed by Scottish Government and the fish farming industry since 2018, that the impact of fish farms is only one of a large number of pressures upon wild salmonids.

Linkages made by SIWG between reforming the regulation of fish farming and the wider funding of conservation and research into wild salmonids, and the resourcing of DSFBs and Fishery Trusts, are concerning.

Although the proposed move to licensing, and away from planning, as a means to control the impacts of fish farms on wild salmonids is welcome, overall, the recommendations made by SIWG do not amount to a licensing system that would yet be capable of being “robust, transparent, enforceable and enforced” (SIWG, 1.2).

The SIWG makes no reference to the precautionary approach recommended by both the REC and ECCLR Committees. The SIWG’s proposed system of adaptive management, without precautionary underpinning, will fail to protect wild salmonids.

The SIWG’s proposed system would mean that unless there is strong proof that damage is being caused to wild fish, no action needs be taken to improve fish farm performance in respect of sea- lice and diseases (SIWG, 2.2). The same principle would apply when considering closing poorly- sited existing farms (SIWG, 1.14).’

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