Bacteria found in Salmon: EIR release

Information requested

You asked a series of questions relating to aquaculture which covered the subject areas of: ballan wrasse survival in salmon feedlots; preventative measures relating to disease spread from farmed salmon to wild fish; undersea lighting associated with salmon feedlots; Scottish Government funding of the salmon farming industry and the impact in terms of mitigating animal welfare issues and mortalities with respect to farmed salmon in Scotland.

The exact detail of your request is provided under the section ‘Response to your request’ along with our answers to your specific questions.

Response

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.

Response to your request

The specific parts of your request and answers to the same are as follows:

1) What percentage of ballan wrasse live to full maturity in salmon feedlots?

The Scottish Government does not hold any details of the percentage of ballan wrasse which live to full maturity in salmon fish farms. Therefore, the exception at regulation 10(4)(a) of the EIRs (information not held) applies to this part of your request. Further detail on the application of this regulation is provided below in the section titled “An Exception applies – Regulation 10(4)(a) – information not held.”

Additional information provided out with the EIRs

We are able to provide some further information to this question out with the EIR regulations. Under regulation 9 of the EIRs (our duty to provide advice and assistance) we would like to advise you that we do hold some records relating to cleaner fish mortality, although this is not a comprehensive record. These records relate only to information which is collected in association with the aquatic animal health surveillance activity undertake by the Marine Directorate’s Fish Health Inspectorate.

The information relating to this surveillance is subject to regular publication on the Scottish Government website:

https://www.gov.scot/collections/publication-of-fish-health-inspectorate-information/

2) What preventative measures are in place to stop other wild species outside the feedlot cages (such as endangered wild Atlantic salmon), from contracting Aeromonas salmonicida and the great many other diseases and viruses originating from the farmed salmon?

The Scottish Government does not hold a definitive list of preventative measures to stop the spread of disease and viruses from farmed fish to wild fish and therefore, the exception at regulation 10(4)(a) of the EIRs (information not held) applies to this part of your request. Further detail on the application of this regulation is provided below in the section titled “An Exception applies – Regulation 10(4)(a) – information not held.”

Additional information provided out with the EIRs

We are able to provide some further information to this question out with the EIR regulations. Under regulation 9 of the EIRs (our duty to provide advice and assistance) we would like to provide the following information on farmed and wild fish interaction and recognised measures which help to control and limit the spread of fish diseases.

There is an acceptance that aquaculture in open pen structures allows the interaction between both farmed and wild environments in which fish populations exist.

On site fish farm management strategies help to reduce the impact of pathogens and the development of clinical disease which they can cause. Reducing the volume of pathogens being released into the wider environment helps to reduce the risk and any impact associated with the same. Many of the practices and principles are adopted into standards of best practice (e.g. The industry Code of Good Practice - https://thecodeofgoodpractice.co.uk/), the requirements of certification and accreditation schemes or requirements within regulation.

Whilst this is not an exhaustive list, disease control measures being used within the aquaculture industry include:

• Pathogen screening and disease testing relating to the input of stocks into any particular site(s)
• Single year class stocking strategies at either the management area and/or site level with regular  fallowing to help break/reduce disease cycles
• Limiting the movement of ‘seawater to seawater’ live fish transfers between farms
• Operating in accordance with good biosecurity measures plans and principles
• Regular veterinary involvement in farmed stocks to facilitate the diagnosis of disease and  identification of infection, the identification of problems and issues and the application of  treatment and control strategies where these are possible
• Vaccination against specific diseases and pathogens helps to prevent their emergence and the risk  of subsequent spread. In 2022 56.2 million farmed fish were vaccinated against Aeromonas  salmonicida (the causative agent of furunculosis),  salmonid alphavirus, and Infectious pancreatic  necrosis virus. Details on annual vaccination totals are provided through the annual production  survey for fish – https://www.gov.scot/publications/scottish-fish-farm-production- survey-2022/
• The use of selective breeding programmes to develop disease resistance for specific pathogens as part of broodstock management

It is important to consider that historical testing and analysis of wild fish has been undertaken around Scotland. The results of this work have been published[1]. This identifies that interaction between wild and farmed fish can occur but the limited evidence of clinical disease in wild fish suggests a minimal impact of pathogens upon wild fish populations.

3) In light of the above, why are salmon feedlots in Scotland allowed undersea lighting at night? What regulation does this fall under? It is scientifically proven that wild juvenile salmonids are attracted to light at night, with “deadly consequences".

The Scottish Government does not hold information relating to this part of your request and therefore, the exception at regulation 10(4)(a) of the EIRs (information not held) applies. Further detail on the application of this regulation is provided below in the section titled “An Exception applies – Regulation 10(4)(a) – information not held.”

Additional information provided out with the EIRs

We are able to provide some further information to this question out with the EIR regulations. Under regulation 9 of the EIRs (our duty to provide advice and assistance) we would like to provide the following information relating to underwater lighting and fish farms.

The Scottish Government is not responsible for enforcing any specific regulation governing the use of undersea lighting in aquaculture. The aquaculture planning process can set conditions and permission over the use of underwater lighting on fish farm sites. You may wish to check with an appropriate local authority on any following up action and regulatory activity undertaken in relation to the use of such lighting on fish farm sites. Local authority contact details are available through this weblink: https://www.mygov.scot/find-your-local-council

Lighting is used as part of the salmon farming production cycle and does affect the depth at which fish swim in the water column within the cages. There is some indication that street lighting can disrupt the timing which wild salmon smolts migrate to sea[2], however fish farms should not affect this as by the time wild smolts encounter them migration has occurred. We are not aware of any publications which suggests lighting attracts wild juvenile salmonids to fish farms.

4) How much funding has the Scottish Government provided to the salmon farming industry since 2020? Please include funding to the SAIC and universities, together with total salary data for SAIC.

All grants made by the Scottish Government through the Marine Fund Scotland (and its previous award schemes) are made publicly available on the Scottish Government website - https://www.gov.scot/policies/marine-and-fisheries-grants/grants-awarded/

Information on awards made through the European Maritime and Fisheries Fund (EMFF) are also available through the Scottish Government website: https://www.gov.scot/publications/european-maritime-and-fisheries-fund-beneficiaries/

Total funding issued since 2020 to the Scottish Aquaculture Innovation Centre (SAIC) is as follows:

• Scottish Funding Council (SFC) – Phase 1 Award £12.8 million; Phase 2 Award £7.5 million
• Highlands and islands Enterprise (HIE) – Phase 2 Award £2.0 million
• Scottish Enterprise (SE) – Phase 2 Award £0.5 million

This results in a total Phase 1 Award of £12.8 million and total Phase 2 Award of £10.0 million.

SAIC was also awarded £186,956.43 from the MFS in 2021-22, that information is publicly available through the weblink provided above.

Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format.

With respect to your request for salary data for SAIC, I can confirm that the Scottish Government does not hold this information and therefore the exception at regulation 10(4)(a) of the EIRs (information not held) applies. Further detail on the application of this regulation is provided below in the section titled “An Exception applies – Regulation 10(4)(a) – information not held.”

5) To what extent has this funding mitigated the animal welfare issues and mortalities incurred on farmed salmon feedlots in Scotland?

The Scottish Government does not hold information relating to this part of your request and therefore, the exception at regulation 10(4)(a) of the EIRs (information not held) applies here. Further detail on the application of this regulation is provided below.

An Exception applies – Regulation 10(4)(a) – information not held

While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested as detailed above. Therefore we are refusing parts of your request under the exception at regulation 10(4)(a) of the EIRs.

Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), the Scottish Government is not required to provide information which it does not have. The Scottish Government does not have some of the information you have requested because:

1) We do not hold any details of the percentage of ballan wrasse which live to full maturity in salmon feedlots because at present we have no operational requirement to collect this information.

2) We do not hold a recorded list of preventative measures to stop the spread of disease and viruses from farmed fish to wild fish and therefore, however we have provided further context to this part of your request out with the EIRs.

3) We do not hold information relating to the underwater use of lighting on salmon farms, as specified in your request as we are not aware of any negative impacts associated with this in terms of wild juvenile salmon or any regulation governing the use of the same.

4) We do not hold salary data information relating to SAIC because they are a separate body to the Scottish Government. You may wish to liaise directly with SAIC on this issue. Please find information about how to do so at the following weblink: Contact Us (sustainableaquaculture.com)

5) We do not hold information relating to the impacts of funding (as relevant to your request) with respect to the mitigation of animal welfare issues and mortalities on salmon farms in Scotland because we have not received any individual project assessments for the funding relevant to the time scale of your request. It may be beneficial for you to liaise directly with SAIC to obtain a better understanding of any benefits associated with funding which has been granted to them.

This exception 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 exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about the subject areas listed above, clearly we cannot provide information which we do not hold.

[1] Wallace IS, Mckay P, Murray AG (2017) A historical review of the key bacterial and viral pathogens of Scottish wild fish. Journal of Fish Disease, Vol. 40, Issue 12, Pages 1741-1756.

[2] Riley WD, Bendall B, Ives MJ, Edmonds NJ, Maxwell DL (2012) Street lighting disrupts the diel migratory pattern of wild Atlantic salmon, Salmo salar L., smolts leaving their natal stream. Aquaculture, Vol. 330-333, Pages 74-81.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.