Aquaculture and Fisheries Consultation Analysis - Summary Report

6 Section 3 - Fish Farming and Wild Salmonid Interactions

Question 20. Do you agree that there is a case for giving Scottish Ministers powers to determine a lower threshold above which remedial action needs to be taken, in appropriate circumstances and potentially as part of a wider suite of protection measures?

6.1 While most respondents who answered this question supported the proposal, there was strong opposition from the aquaculture industry.

6.2 Support for the proposal centred on the protection of wild fish from sea-lice emanating from finfish aquaculture sites, with a particular emphasis on using the industry CoGP as a minimum standard.

6.3 There was concern amongst some respondents about any increase in treatments and consequent effects such as increased resistance of sea-lice populations, effects on marine ecology, impacts on non-target species, and costs to the industry.

6.4 While some respondents felt that a lower threshold may be useful in some circumstances (i.e. during the salmon migration season), there was a preference for other non-therapeutic measures to be used first.

6.5 The aquaculture industry considered that the proposal has the potential to increase problems of sea-lice management, particularly through increasing resistance to therapeutants, and that the proposed powers have already been debated by the Healthier Fish Working Group.

Question 21. Do you agree we should provide powers for Scottish Ministers to require all finfish farms operating in Scotland to use equipment that conforms to a Scottish Technical Standard? (The technical content of the standard would be defined separately)

6.6 There was strong support for introduction of a technical standard across all stakeholder groups.

6.7 Some respondents suggested what the standard should contain, including specifics (e.g. cage types and dimensions, markings and moorings, training requirements, etc.) and more general approaches (e.g. flexible, use of site assessments).

6.8 Some industry respondents had concerns over some farm sites, e.g. those with a good record of containment being penalised for not meeting the standard, and suggested that transitional procedures be used for its introduction.

6.9 Several respondents noted that they would prefer the use of closed containment systems in finfish aquaculture.

6.10 Several respondents noted the work of the Improved Containment Working Group in working towards this standard.

Question 22. Do you agree that there should be additional powers for Scottish Ministers to take or require samples of fish from fish farms, for tracing purposes?

6.11 There was overall support amongst respondents for this proposal. Several respondents were of the view that this measure could enable the tracing of escaped farmed fish.

6.12 However, the aquaculture industry and other commercial industry respondents were strongly opposed to these additional powers. Opponents suggested that progress has been made in controlling escapes, that impacts of escaped farmed fish on wild salmon have not been demonstrated, and that this "research" would not be a good use of public funds.

6.13 One respondent felt that powers or procedures are already in place for the Scottish Government to take or to require samples of fish from farms to be taken for tracing purposes. Another questioned why the testing of retained samples of fish could not be done under procedures that are already in place.

6.14 Several suggested that the ability to carry out genetic identification should be established before introducing these powers.

6.15 Several alternatives were suggested, including retention of frozen samples from each batch, using the existing procedures and tagging farmed fish.

6.16 The need for additional discussion on this issue was identified by a number of respondents.