Earlier this year we announced our intention to respond in detail to the Scottish Environment Protection Agency’s (SEPA) proposals for Wild Salmon Protection Zones on the West Coast of Scotland. Our formal, detailed and technical response was submitted to SEPA on 15th September 2023.
Our response is framed around two key themes: 1. commitments the Scottish Government has made, and 2. a set of Guiding Principles. These elements are detailed below.
Scottish Government Commitments
- Commitment 1. Ministerial commitment to ‘Prioritise the protection and recovery of Scotland’s wild Atlantic salmon populations.’ Wild Salmon Strategy – Cabinet Secretary for Rural Affairs, Land Reform & Islands, Mairi Gougeon.
- Commitment 2. Scottish Government commitment to not permit a continuation of the status quo in relation to farmed/wild fish interactions – Salmon Interactions Working Group Report: Scottish Government Response.
- Commitment 3. UK and Scottish Government global NASCO commitment for ‘100% of farms to have effective sea lice management such that there is no increase in sea lice loads or lice-induced mortality of wild salmonids attributable to the farms.’- Williamsburg Resolution, NASCO.
- Commitment 4. Uphold the commitment to accept the agreed recommendations from the Salmon Interactions Working Group (SIWG), most notably to bring in regulation which is ‘comparable with the highest international and domestic regulatory standards’.
- Commitment 5. Uphold the commitments in Scotland’s Environment Strategy and Biodiversity Strategy to ensure that; ‘Scotland’s nature is protected and restored.’
The Guiding Principles of our Response
- Wild Salmon Protection Zones must protect wild salmonids year-round.
- Sea lice threshold levels should be set in-line with the highest international standards.
- Sea lice regulation should be brought in immediately for all existing farms, not just ‘new or expanding’ farms.
The Atlantic Salmon Trust remains committed to engaging constructively with the process of development for Wild Salmon Protection Zones on the West Coast of Scotland. Our extensive and detailed response to this consultation is indicative of the potential we see in supporting the underlying principle that numbers of sea lice emanating from finfish farms should be managed within a regulatory framework which fully protects wild salmonids.
However, in its current form, the proposals lack clarity and require fuller explanation. Our response articulates that this should be in both a technical capacity, but also a non-technical version so that members of the public can fully understand the measures being taken. We ask SEPA to reflect on our response, its responsibilities as a regulator, and the Scottish Government’s commitments, to ensure that the next iteration of its proposals aligns with those commitments.
Effective regulation would mark a positive turning point for our wildlife, our shared natural and cultural heritage, and help to restore wild salmonids for the benefit of the environment and future generations of people.
Scroll through the PDF below to read our response in full.
Further to our own response, the wider Missing Salmon Alliance has also published a short statement which echoes other important points made in our response. Notably these are:
- The proposal’s focus on ‘no deterioration’ is incompatible with the Scottish Government’s stated ambitions to achieve salmon and sea trout restoration.
- Sea trout, as a Priority Marine Feature, should also receive protection as a priority and the timeframe for the development of a bespoke sea trout framework should not put them at risk.
- The proposed boundaries for Wild Salmon Protection Zones should be enlarged as 5km does not provide adequate protection.
The Atlantic Salmon Trust is committed to putting #WildSalmonFirst