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Scottish Parliament Committee recognises need for dedicated regulatory body to manage the impacts of aquaculture on wild fish


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On the 27 November 2018 the Scottish Parliament’s Rural Economy and Connectivity Committee published its report into salmon farming in Scotland. The parliamentary enquiry has come at a very important time as the Scottish Government is looking to double the size of the aquaculture industry by 2030 (see note 1).

At the same time, the health of Scotland’s wild salmon stocks on the west coast continues to decline. A recent map published by Marine Scotland showing the conservation status of Scottish rivers shows the majority of salmon rivers in the aquaculture zone as at below good conservation (2).

Those involved with west coast wild fisheries have long suspected that the relentless growth of the aquaculture industry over the last 30 years has been a significant factor in chronic declines in salmonid numbers in the aquaculture zone. The announcement of the parliamentary investigation has at least raised the possibility that the aquaculture juggernaut can be contained or at least slowed.

The Committee initiated its investigations at the beginning of the year and has taken evidence from all ‘corners’ of the debate, including a detailed submission from Fish Legal/Angling Trust. The key finding is that the existing regulatory framework for aquaculture is not fit for purpose. The report describes regulation as “confused” and “poorly co-ordinated”. SEPA was singled out for particular criticism regarding its poor performance monitoring the industry and enforcing regulations. The committee conclude that “the status quo is not an option...a comprehensive package of regulation should be developed by Marine Scotland” (3).

The report specifically notes our call for a “a dedicated regulatory body that has statutory responsibilities for managing the impacts of aquaculture on wild fish and has the necessary powers and expertise to do this” and has recommended that the “apparent regulatory gap” should be filled and clarity over “which agency will assume responsibility for its management” provided by the Scottish Government (4).

The report also addresses the contentious issue of the siting of farms, many of which are uncomfortably close to mouths of important salmon rivers. The report recommends that there should be “an immediate and proactive shift towards siting new farms in more suitable areas away from migratory routes and that this should be highlighted in the strategic guidance on the siting of salmon farms” (5). The report also recommends that “there should be immediate dialogue with the industry to identify scope for moving existing poorly sited farm” (6).

Marine Scotland, as a government agency, has conflicted objectives: on the one had it is tasked with promoting a sustainable profitable aquaculture industry but on the other hand it also has a crucial role to protect the natural environment and the diversity of industries which depend upon it.

The evidence suggests that both the Scottish Government and the aquaculture industry do now accept the conclusions of the Committee that the status quo is no longer sustainable. The Scottish Government has set up a Wild Salmon Interactions Workgroup to come up with solutions/recommendation that address the recommendations from the report.

In the absence of a new regulatory framework, Fish Legal will carry on working at local level with the Planning Authorities and the District Salmon Fishery Boards to develop adaptive management. This means developing a mechanism (enforceable through local Environmental Management Plans) to ensure management on farms responds to evidence from local wild fish monitoring of lice infection on wild fish emanating from local farms. The report calls on “both sectors to collaborate to resolve local management issues and other areas of concern” (7). This is an approach we will follow until a national regulatory framework is put in place that is fit for purpose.


1. Scotland Food & Drink Aquaculture Growth to 2030

2. See map here

3. Recommendation 60

4. Recommendation 42

5. Recommendation 46

6. Recommendation 53

7. Recommendation 43


Contact: Fish Legal - Eastwood House | 6 Rainbow Street | Leominster | HR6 8DQ | Tel: 01568 620447

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