 Y Llywyddordd arddangos i niifellolol am eich syniadau cymaint ymateb tyfridd. Fydw i chi ddim peisio ddim bakedeidwch bod ei mwy ffordd i chi'r mwyloedd ar hyn o'r cyffredin amaidd. Apolygystad yn rhan o'r dweud o'r defnydd. Jamie Greene, mae'r cymaint ymlaen ag i ddiwylliant yn cael ei ddigon o'r mynedd, iawn i bod yn ei cyfl�au. John Scott yn rwyf i chi syniad i chi ddigon o'r cymaint. Donald Cameron, who would be attending as a reporter for the ECCLR Committee, is unable to attend for the same reason, and there is no substitute. We're going to move straight on to a gender item 1, which is taking evidence on salmon farming in Scotland. As with all of these sessions, I would like to ask members around the table to declare an interest. I'm going to start it off by saying that I declared last week a lengthy declaration of my interests in relation to this, which I don't propose to repeat. I would refer members and other interested parties to that declaration and to my declaration of interests, which says that I am a member of a co-owner of a wild salmon fishery in Scotland. Would anyone else like to make a declaration of interest? I feel that I should just declare an interest as a farmer and this appearance in front of this committee, but I have nothing to declare relevant to today's proceedings. I'm going to move on. This is our second evidence session on the committee's salmon farming in Scotland inquiry, and we're going to take evidence today from environmental and fisheries organisations. I'd like to welcome John Gibb, the clerk to the Lucarba district salmon fishery board, Dr Alan Wells, chief executive of fisheries management Scotland, Richard Luxmore, the senior nature conservation adviser at the National Trust for Scotland, on behalf of the Scottish environmental link, and Guy Lindley-Adams, Solista, on behalf of Salmon and Trout Conservation Scotland. We are now going to move on to questions. I jumped ahead of myself. The first question today is from John. We'll be looking at different areas, but to start off with economic and other potential benefits, we've heard from HIE and others about the number of jobs that are linked to salmon farming, in particular they've given a figure of 10,340 jobs. I was wondering, are there estimates as to what the benefits are from the wild fisheries, sea trout and salmon, both in economic terms, but are there other social or cultural benefits or anything else from the wild side? I should have set the ground rules at the beginning. For those of you who haven't given evidence before, I think that you all have at some stage. You don't need to touch any of the buttons in front of you. If you want to come in and answer a question, look at me and I will try to bring you in at the relevant point. Please then don't look away for the rest of the meeting and continue to talk because I will then have to interrupt you. If you keep an eye on me, I will give you an indication whether I want to bring somebody else in. I apologise, I should have done that at the beginning. Alan, you seem to have got the hang of it straight away, so I'll bring you in to answer that question. In terms of the economics of salmon and sea trout fisheries, there was a report published in March 2017. Unfortunately, that did not break down those economics on a regional basis, but it did give Scotland wide figures, so I can give you an indication of those figures. That was a report done for the Scottish Government by a company called PASEC, and it said that Scotland-wide economic impact assessment of wild fisheries indicates around £135 million of angler expenditure, 4,300 full-time equivalent jobs and £79.9 million of gross value added, and that was on 2014 figures. It gives you an indication of the relative size of the industry. Are there other benefits apart from just the purely economic ones? There are all sorts of social benefits from angling and participation. We are blessed in Scotland in some ways, because of the geography of where Scotland sits. We have a very long season. We have rivers open for fishing from January all the way through to November, which is not the case in other parts of Norway. It tends to be during the summer season, so we can benefit from tourism, from anglers coming in from other countries and benefiting from that long season. Do the tourists fly in, fish and fly out again, or do they do other things as well? It is very dependent. That has been looked at, but I do not know precisely the details from that from the PASEC report, but there are certainly a range of things. Anglers quite often bring their families who potentially do other things if they are not interested in fishing themselves. Some people will come in for a week, some people will fish when the water is good and maybe do other things when conditions are not quite so good. John. I also think that we should not underestimate the culture and importance of salmon, irrespective of angling. I find quite often that I am standing on the river and there are quite a lot of public walkways on some of the rivers that I manage. You will meet someone who had one last year, and an old lady stopped me and said that it is not wonderful to see the salmon back. I do not think that we should underestimate that. It is not just about angling, it is not just about commercial value of that, but it is in the blood of the West Highlanders to have salmon in the rivers. The second part of my question following on would be, we clearly have had a lot of emails and information on both sides of this discussion on behalf of the salmon farms and the wild fisheries. As a general question, is it possible that we have both, that we can have successful wild fisheries and successful salmon farming, or do you think that we have to choose one or the other? I am going to bring Guy in. I notice Alan and John, you both want to come in as well, but I will try and spread it out a bit to start with Guy, if you would like to start on that. From the point of view of the Salmon Trout Conservation Scotland, the answer is definitely yes. We are often labelled as an organisation that is anti-fish farming. That is not correct. I think that it is perfectly possible for the two to co-exist. As the Claire report indicated, we are concerned about the sustainable development of the industry to make sure that it exists within environmental limits, but as a simple principle, there is absolutely no reason why the two sectors cannot co-exist and both thrive. John, do you want to come back on that? I think that you live with the interaction where you are. I think that we are certainly, as a fishery board on the west coast and the middle of the west coast, we are most certainly of the view that there will be a place. We are not there yet, but there will be a place where both sectors can thrive. It is not beyond possibility that we might get to a place where fish farming, forestry, hydro, any man-made activity is going to be a risk. I think that we have to accept that. It is quantifying that risk and it is minimising that risk. I do not think that we are there at the moment. I think that that is a lot to do with location, but we can obviously get on to that later. I do not think that it is unreasonable to think that there might be a place in the future, if we do this right, where fish farming might have a 10 per cent impact on wild salmon and sea trout stocks. Through working together and through projects to protect and enhance wild salmon and sea trout stocks, we might be able to boost that by, say, 20 per cent. It is a not unreasonable place to try and find. We are not there at the moment. That might be useful to put some sort of context around where we are on fish farming in relation to wild fish. Fisheries management Scotland is the representative body for the district salmon fishery boards and the charitable fishery trusts across Scotland. We have a committee that looks at this issue in particular. What we would like to see is essentially four bullet points, thriving salmon and sea trout populations and fisheries without negative impacts arising from salmon fishing. A harmonious local coexistence is an important point with an industry that understands the importance of being a good neighbour and communicates openly and transparently with stakeholders. A world-leading regulatory and planning system that protects wild fish and proactively seeks to address any local negative impacts. An investment of a proportion of any profits generated by the industry into the protection and improvement of local salmon and sea trout populations and fisheries. Just to give you some context for where we are coming from from this, and we can expand on that later on in the session, if possible. Just a wee bit of clarity, you mentioned 4,300 jobs dependent on the world fisheries. I assume that that is hotels and tackle shops and the wider economy that you are including in that figure. It is not my figure, but that figure takes into account the full range of those jobs, so it is not necessarily direct employment within fisheries and fishing and management. The next question is from Fulton. Good morning, panel. My question is about disease and the spread of disease. Is there any solid evidence that shows that disease can be spread between wild and farm salmon? Who would like to start off on that? Guy, do you want to start off with that? By disease, if you include parasites within that, then definitely yes. Just before the Eclare committee looked at the environmental impacts salmon and trout conservation commission, Nena, the Norwegian Nature Conservation Research Unit, looked at this and they gave the conclusion that there is significant evidence of an impact of sea lice from salmon farms on wild salmon population. It is difficult to point to a particular lock and say that a particular farm is causing a particular problem, but they came to the conclusion that there is a pervasive in general effect of fish farming in relation to wild salmon population. I am personally concerned that we concentrate on sea lice because we can see them, because we can count them. There are other diseases of salmon that you get in salmon farms. There is not much evidence as to whether those viral diseases, those bacterial diseases, cause an impact on the wild salmon population. I suspect, Alan, if I am wrong, that the research that would be required to do that work would be extremely difficult. What you can say is that diseases within fish farms are not likely to be positive for the wild salmon population. They may be neutral, but the sea lice problem that we know is not neutral. The next question was about populations. If somebody does not know a lot about the salmon industry and could come into this fresh, what effect would that have on the population in terms of numbers? Population of wild salmon. I do not want to interrupt. I would try to steer the panel at the moment because we are coming on to the section on sea lice a little bit later. If we could focus on disease, which is where Fulton started saying, if I could encourage you on disease, sorry, Fulton, do you want to come back to Fulton on that disease? I am happy to leave that until the sea lice section. Alan, do you want to come in on that? I would not disagree much with what was said last week in terms of disease. It is incredibly difficult to try and assess in the wild population without doing massive sampling efforts. If fish are badly affected by disease, they will die. The term black box was used last week and you simply cannot sample them. There has been some small sampling done by Marine Scotland Science and you may wish to ask them, but I do not want to put words in their mouth. My understanding is that they have not found much evidence of disease in wild fish, but the problem is sampling a representative sample. The other issue that is relevant to disease and to wild fish is that, to a certain extent, this is a numbers game. The actual number of vectors for disease between the farm and the salmon industry is quite significant. In the SAMS report, it stated that in 2014 about 179,000 tonnes and 48 million smolts were put to sea in terms of aquaculture. They compared that with about 0.6 million wild fish across Scotland. The actual number of individuals is wildly different between the two sectors. That is a big issue both in terms of disease and in terms of sea lice, which I am sure we will come on to. Do you see climate change having any impact on the spread of diseases from warmer water? I keep looking at everyone. Do not be shy to catch my eye if you want to come in. Alan is quite quick at it. He has obviously done this before. Alan, if you would like to answer that. Only once. In terms of climate change, the industry feels that they are seeing more of a challenge from some of the gill health issues that were mentioned in the Environment Committee because of rising sea water temperatures. That may well be the case for wild fish but I do not think that there is any evidence that we can point to one way or the other for the reasons that I mentioned earlier on. In terms of wild fish populations, climate change is almost certainly an issue in terms of their ability to find food in the marine environment. We know that there have been phase shifts of plankton and the sort of things that fish eat, which have moved maybe a thousand kilometres to the north, so that is a big effect on wild fish. Specific to disease, I do not think that there is much evidence either way. Stuart, you would like to come in and then I will come back to you. It is just a very narrow point related to this. Martin Jaffas describes a reduced salinity event, which I do not think was to do with climate change by his account, which had a significant impact. I think that it is accepted that in climate change terms such events will happen from that source in future. Is that likely, if that occurs, and the increased temperature? Is that likely to move fish to cold or waters for the north or have other effects? The desalinity that has been described looked quite serious, even though the reduced salinity was not particularly much? I have not seen the particular comment from Martin Jaffas on reduced salinity. I do not know whether that refers to it at the open sea or at the head of a sea loch, where maybe you have extra freshwater input, if you have a particularly wet summer or something like that. In fairness, it was a loch and it was not local effect. It was an effect of change of global currents. As he describes it, I speak to nothing about the science person. You might want to ask him about that, I do not know. Fulton, do you want to push for that? Just a general question on the disease spread that you have mentioned. Apologies. What are the social economic implications of that for wild fisheries? I am still in the hot seat. I guess my answer, I would look back and it is actually looking back beyond my time in the sector. Back a few decades ago, there was an outbreak of a disease called ulceral dermal necrosis within wild fish, which was a big issue. John May well wanted to talk about this, which was a big issue and was a big worry at the time. Signs a few years ago that it might have reappeared and there was a big response from the wild fish sector at that time. We even funded a PhD student to look at it. As it turned out, it was not UDN that happened at that time. However, if you had a big disease that had a big impact on wild fish, particularly taking into account the relative strength of stocks that we have at the moment of wild fish, then it would be a big concern. Do you want to mention that? No, not to add anything particularly significant to that, but that is right. The last few years, the last decade or so, I should stress nothing to do with agriculture. This is purely a disease in wild fish that certain rivers more so on the east coast than the west coast. Particularly rivers where early spring salmon, that is usually April-May salmon, come in and then the river dries up and they are constricted in pools. You have a high density of fish and small pools. They have started to see and continue to see this UDN-type disease, or at least the symptoms in UDN. They get a saprolignia fungus, which is like a white fungal growth on the fish, and they succumb to it. You can actually have situations where you have rivers literally full of dead fish, which, as you can imagine, is not particularly good for the marketing of fishing. It could have a long-term impact and it could well be linked to climate change. The truth is, as Alan says, that we do not really know what it is. It is not UDN, and we do not really know entirely what is causing it, but they appear to be picking it up at sea, bringing it in. If environmental conditions allow it to thrive, which is low water in the late spring, early summer, it can be a significant problem. Has there been any analysis done on what the social and economic consequences for the wild fisheries and the wild fishing industry is of that in any other spread? I do not think that that was covered in the PACE Act report. It looked at various scenarios, but I do not think that disease in particular was looked at in that. I suppose that you could draw numbers based on catches and what would happen to relative catches and all the rest of it, but it is not quite as black and white as that, because people will fish and not necessarily catch something but will still come back and fish in times. Other people have different drivers, so it really depends on individuals. I think that we will move on to the next section, and that is Richard Lyon. Thank you. Good morning, gentlemen. Following on, Fulton McGregor's question, I have got similar to draw down. The clear report stated that the committee is concerned that disease is still leading to large numbers of farmed fish being slaughtered. They were and are concerned that salmon mortality will increase if production is doubled, considers full fish health problems should be addressed across the sector with a relative decline in mortality rates. I am drawn to the fact that Marine Scotland said throughout the 90s and the 2000s that around 20 per cent of mortality of farmed fish throughout the production cycle seems to increase. Do you agree and share the committee's concern about environmental impacts of disease in terms of rear fish and slaughtered fish, and how are they disposed off to use 20 per cent an unacceptable figure? Who would like to start on that? Richard? The issue of how many fish die on fish farms is obviously a waste of good food, but it is primarily a welfare issue. To some extent, if all the fish die within a fish farm from an environmental perspective, that may not necessarily have an impact on the environment outside the fish farm, and it is just a commercial problem for the farm itself. Obviously, the problems arise if the causes of death, diseases or something, then transfer to the environment outside the farm. From an environmental perspective, it is the transfer of disease from the farm to the wild fish or the environment around a boat, which is the problem. The issue of disposal of dead fish is the same as disposal of any waste. Clearly, that needs to be closely regulated and the regulation is enforced. On that point, convener, we had reports of dead fish on a back of a lorry, which was said in a newspaper I think I read. That was totally denied. That basically, oh no, we put it inside a container and we transport it away and dispose of it very well. Is that the case? I'm sure that the efforts are made to try and transport things carefully, but I've also seen television footage of stuff dripping out of the back of these lorries, and having smelt pits full of dead salmon, it's not very pleasant to be very close to it, so I think that is of concern. It would be exactly the same if it was a truck full of dead cows, you would be worried about that. Just to reiterate what Richard is saying, the mortality within a farm isn't necessarily of a concern to wild fish populations unless there is some vector leaving that farm and infecting the wild population. If you think for the farm as a black box, as long as what is within that black box is contained, it's still an issue for animal welfare, it's still an issue for the farmers, but what it does indicate is that if there is a disease problem, high mortality problem, then the management of the farm isn't right. As I said before in answer to an earlier question, it's indicative of a problem, it's unlikely to be positive for the wild fish that this mortality level is occurring within the farms. I was going to make a similar point, but it's the underlying reasons for that mortality and the potential consequences to wild fish, which are important, and there's clearly more research that needs to be done to understand that, because we just don't know enough about it at the moment. Basically, I agree that if I was a fish farmer and 20 per cent of my stock was getting lost every year up, I'd seriously be doing something about it. Anyway, I'll move on. Do you have any examples or can you share any examples from other countries of how this challenge might be better addressed? Who'd like to start on that guy? Perhaps one medium-long-term solution, and it's often raised, is the solution of closed containment. If you isolate your farmed fish biologically from the wider environment, you're less likely to get the diseases in in the first place. We see closed containment projects popping up in Norway. By closed containment, I don't just mean land-based closed containment, I mean floating closed containment units, which have clearly been of greater significance in Scotland. One of the messages from the Eclare Committee report was that investment incentivising closed containment rapid research, anything the Scottish Government can do to push us down that path, would be very welcome. John, do you want to come in? Perhaps I should declare that I am a registered fish farmer with a licence, albeit for restocking purposes. I grow fish. Just to take a step back to your previous point, I think it's fair to mention that the salmon by its very nature produces many, many thousands of eggs each individual, and there's a natural erosion. Although it's tempting to look at very high mortality and compare it to sheep or pigs or something like that, it's an entirely different thing. I would agree with the other witnesses that it's indicative of a problem, but to be fair, as I run a farm, I know that you do get wastage, and it's a very natural thing. I would be probably happier, as I know that the industry used to have a figure of around 10 per cent, not 20 per cent. Can I just ask a question on that before you go on to the next one? Just so I understand, John, being a fish farmer, by what you're saying, do you get 20 per cent losses in your fish farm? I have to say, no, I don't. I run a very small operation, but I do get significant losses, but I don't want to be drawn too much on whether 20 per cent is acceptable or not. If I had to be, I would say that it does seem rather high, but it's not representing wild fish interests, the fact that the methods are used to transport dead fish, that's not what's affecting us. It is perhaps indicative of an underlying problem, and I don't think that's something that the fish farm companies would necessarily shy away from. If I could just drill down on that question, if you allow me to convene it. If I was a farmer and I was losing x amount of cows, cattle, whatever, I would do something about it. As a fish farmer, is there nothing that they can do about it? Norway is colder. My view, Norway has feards and a lot of feards throughout, or feards, whatever you want to call it, the way you want to say it. Basically, it's a different sort of setting. My view, and I support salmon farming, by the way, before anyone comes back to me, I want to see it doubled, but I want to say, why do we have 20 per cent? Take that, plus the escapes. We're losing 30, 40 per cent of our production. No one in their wildest dreams should have that level, so I think it's unacceptable. Mr Gibb, do you think it's unacceptable? Bring you in, and then I'm going to bring Richard in, because I need to see who wants to come in as well. Just to clarify, it's a number managing well fisheries that we're not at all comfortable with, and I would clarify that. My point before was simply that it is a different species, so to compare sheep and salmon is perhaps a little unfair, that was my only point on that. As Guy has already said, I think that the only way to guarantee what you seek is to have close containment and complete separation from the wild and the farm stock. Richard, if you'd like to come in and then I'll bring Stuart in. Thank you very much. I think that it's sort of been mentioned, but rather than concentrating on whether 20 per cent is acceptable or 40 per cent is acceptable, it's actually to look at the overall trends. The trends of mortality on fish farms have been inextricably rising over the last four or five years, and now, fair enough, there's a range of different diseases that have been causing that mortality. The fact that the rate of mortality has been increasing suggests that the industry, far from getting closer to being able to control those diseases, is actually getting further away from being able to control those diseases, so the problem is actually getting worse. There have been a number of questions and comments about various things being improving in the industry, but the one thing that's absolutely clear is that the problem of mortality is getting worse, and therefore the ability to control those diseases is getting worse. A proportion of the fish that die in fish farms will be dying from disease. I just wondered if there was any evidence, and I haven't heard any to date, of the transporting of these dead fish to ultimate disposal, causing biological crossover of disease infection to wild fish or otherwise, if there's any evidence. Richard, if you'd like to come in and then Alan. All I was going to say was that I'm not aware of any evidence. That's fine. I'm not aware of any evidence either, but I am aware that two or three of my members were quite concerned because they witnessed the sort of leakage that we saw on TV, and in one instance that leakage was quite close to a Salmon River. Now, the local authority was contacted at the time, but I don't know what happened about that. Okay, thank you. Okay, sorry John. I just ask the experts if there's any one disease in particular that's causing this unacceptable level of deaths on fish farms. Is it the guill disease? Is it the storm of a new disease that can ravage any type of farming sheep or cattle, and until such time as it's controlled, is it predominantly guill disease, or is it another? I'm not all that well informed in that regard, but you will do. Let's tell me. Guy, if you'd like to start on that. As I understand it, guill disease is one of the major causes of this mortality combined with the application of mechanical treatments for sea lice. Now, when your fish are already compromised in some way by the guill disease they carry, then putting them through quite a stressful mechanical treatment for sea lice causes the levels of mortality. Also, the mechanical treatments for sea lice are new, the farmers are still getting used to them, and so there is a level of mortality there. So it's no one particular disease, but obviously the guill disease has caused a serious problem for them in the last couple of years. I understand that some of the closed containment technologies that draw water from lower, deeper into the cages could deal with the sea lice getting into the cages in the first place, which would then make the guill disease easier to treat. So there are complex relationships between the diseases going on and the different treatments being applied. It's quite a difficult one for us to comment on. There are various reports from the fish health inspectorate, so it might well be worth asking them and indeed the salmon farmers about this. I think that the guill issues that the fish farmers have been experiencing aren't actually a single disease. There are a range of challenges that they were discussed as last week. There is amebic guill disease, which is one of those guill challenges, but if you have jellyfish or other things like that, which can actually physically irritate the guills and all the rest of it, that can exacerbate the problem as well. I recall, and it might be worth just having a quick look, in the spice briefing there was some information from Marine Harvest from their annual report which set out some of the challenges, but I can't remember off the top of my head exactly what those were. I think that we're going to move on to the next question. Peter, that's you. Thank you, convener, and good morning, gentlemen. Obviously, what we're interested in is the interaction between fish farming and wild fish. There is some concern that numbers of wild fish in the east coast rivers are under some pressure as well. There are no fish farms on the east coast of Scotland. Just to quote a North Atlantic Salmon conservation organisation, they said that wild stocks of Atlantic salmon are currently vulnerable because of reduced marine survival all around the North Atlantic. My question really is, would wild salmon be in decline both in the east and west coast rivers if there were no salmon farming going on? Would there still be that pressure on wild stocks, regardless? I'm going to start off with Alan and go to John, and then I'll see if anyone else wants to come in. I think that it's worth emphasising. Fisheries Management Scotland used to be the association of salmon fish reports. It's never been our position, either as Fisheries Management Scotland or previously, that fish farming is the only pressure that wild fish face. There's a whole series of them, and I mentioned earlier on that the marine issues, and again I'll mention that the black box are a significant problem, whether it's east coast, whether it's west coast, whether it's Norway, whether it's anywhere in the range of the Atlantic salmon. In terms of sea lice, the work that has been done to look at the effect is able to look at those things in isolation, so I don't want to go into a big long explanation about how it's worked, but essentially what they've done is they've taken two cohorts of fish and released them into the wild, one of which has been prophylactically treated against sea lice to protect those fish from sea lice and the other one isn't, it's the control. All those other pressures that happen in the marine environment would affect both of those experimental groups equally. What those experiments have shown, and they've been done in Norway and Ireland, is that on average, and there's a lot of variation within it, about 20 per cent less fish return to rivers in the control group as opposed to those that have been treated for sea lice. What you can do is you can look at the issue of sea lice in isolation from all of those other effects, which do affect both of those groups equally. There's a lot of discussion last week about whether we could read across from Norway over to here, and a lot of discussion about all of the things that make Norway different. I don't disagree with any of those. Norway has a very different geography, a different level of production and all the rest of it, but so does Ireland. Ireland has a much smaller industry than we have in Scotland. It doesn't have the sort of fjordic sea loss that we have here or the big fjords that they have in Norway, and yet the same experiments that have been done in Norway, which point to around about on average a 20 per cent reduction in returning adults coming back to the rivers, have also been done in Ireland. They saw broadly the same thing. Although I agree with everything that was said in terms of the differences between Norway and Scotland last week, I don't agree with the conclusion that we can't trawl broadly from the results of those studies. What's important, though, is knowing what happens at a very local level, because we don't manage sea lice on a Scotland-wide level or a Norway level. We manage them very much at a local level. We also don't manage salmon stocks at a Scotland level. We manage them on an individual river level, so what's actually important is what's happening very much in the local level as the fish are passing out of the rivers, passing past those farms. John, would you like to come in and then I'm going to bring Stuart in and I'll then come to Guy. Just briefly, I think that I very much concur with Alan that we've never seen aquaculture as the main culprit in the decline of salmon and sea trout. However, I think that what's clear is that it's most certainly adding an extra pressure to already threaten stocks. You may, however, Alan mentioned the way you can try and tease out the impact of sea lice using treated and untreated experiments. Marine Scotland Science has been doing some work on this in one of the catchments that I manage on the River Lockheed, and you may wish to ask them about that work, because that only on a local level may give some answers. My understanding, I mean I'll let them speak for their own work, but my understanding is that it actually has demonstrated that marine survival rates are extremely poor on parts of the west coast and certainly in my region of Lochaber. You won't find this on the east coast of Scotland if we're making any comparisons. You actually now have rivers that could simply be classed as extinct of Atlantic salmon. We had the River Co, which you'll probably know, runs through the middle of Glenco. We had one salmon red in it this year, as far as we could count. That suggests that it may have been one pair of salmon in that whole river. That used to be a thriving river. The same as the river Leven at Kinloch Leven. Absolutely no salmon caught, absolutely no salmon seen. We are seeing a new period of decline, certainly in parts of the west coast. Stuart, do you want to come in? I noticed you nodding as well, Richard, so I'd like to try and bring you all in on this, if I may, Stuart. I just want to address this to Dr Wells on the scientific research that he's cited. What conclusion should we derive and is the conclusion that that scientific test has told us about the effect of lice on wild fish at sea? In other words, given that it's a reduction in returning fish, should we infer that the mortality is occurring at sea and that lice are the vector of that mortality? Is that what we should conclude? Does that therefore detach the effect of farms with lice from that effect that is occurring at sea, or am I misinterpreting it? I haven't read the research, which I'm sure Dr Wells will have done. My postdoctoral research was on interactions between farmed and wild fish. I was involved in an EU funded project in Norway, Scotland and Ireland, so that's my background. I'm not sure I entirely understand your question. Does that only exist in the marine environment so that it can only happen at sea if it dies when it goes into fresh water? No. Can I attempt with the community's consent? I absolutely understand the reference group and the prophylactically treated group and how they are testing whether they are going to see, by which I mean being distant from the river. The effect that is being measured is what happens to those animals when they are distant from their spawning river. I am merely asking—of course, lice is well offshore in salt water. I understand the point about lice in salt water animals. Are we actually not ending up testing how those animals respond to lice distant from farms? In other words, it's the natural background level of lice, rather than anything else. Just before you answer that, Alan, perhaps it would be useful to explain, as part of your answer, the effect of lice on fish going to sea and the effect of lice on fish returning to the river. I think that it would just clarify the debiety here. I am very happy to address both of those. The important point in terms of sea lice and wild fish is that it's the smolts, it's the young fish leaving the rivers, are where we see the impact. We know from long-term studies that have been done by the University of St Andrews and Marine Scotland Science on the north coast of Scotland from the net fisheries that large multi-sea winter fish and one sea winter fish are grills that come back to the Scottish coast, regularly come back with really quite high levels of sea lice with no apparent physiological difficulties. There's a big difference between a large fish coping with a number of lice than a small fish. Some of the work that I was doing was on the physiology of fish and the effects that sea lice have on those fish, and it causes all sorts of problems. It causes problems with their ability to regulate salt and water balance. It causes problems in relation to the way that their gills function, the way that their livers function and all sorts of things like that. Basically what you're doing is if you have a large infection of sea lice onto a fish, you're taking a point where it's going through a major physiological change because it's going from freshwater to seawater. It's completely restructuring its gills. Many of its organs are working in completely opposite ways, and you're adding an extra stress on top of that. It's that extra stress that is the problem. Whether those fish then die because of the number of sea lice or whether it's a secondary reason because they're more susceptible to predation and all the rest of it comes into that black box argument. What we know from these prophylaptic treatments is that if you treat the fish, they will survive better. In terms of whether it happens at high sea or whether it happens closer to the shore, the chances are that it happens closer to the shore because those prophylaptic treatments are time limited. They last a matter of weeks rather than years or months. We understand that it's a relatively close to shore phenomenon. We've heard black box use. My definition of a black box is a container whose inputs and outputs are known but whose internal processes are unknown or irrelevant. Is that the definition that we are using as witnesses? What I'm essentially saying is that we don't know what happens once the fish get out into the marine environment because it's impossible to sample them, whether that's a black box or whether that's something else that I don't know. I'm going to bring in Guy and I think Richard you wanted to add something as well. If I could just add to what Alan mentioned about sea lice being a problem for departing smolts, I wouldn't want the committee to forget that it's also a problem for sea trout in that their habit is much more coastal. Juveniles and adults stay near the farms so they are exposed to the sea lice from the farms in a way that the adult salmon further out at sea won't be. Does that change the proportion of potential sea trout who go to sea because some return them and become brown trout? There is certainly a problem with what's known as early returning behaviour. Sea trout exposed to sea lice will return to the river because they appreciate that the lice will drop off. I would imagine that Alan and I would be better placed to talk about the detailed biology of that. Richard, do you want to come in on that? I wasn't sure if you were catching my eye. Yeah, you are catching my eye. I was really just wanting to draw attention to the difference between salmon and sea trout because salmon is certainly in relation to fish farms. If you have a fish farm near the mouth of the river, the salmon smolts go past it on the way out, disappear off to sea, and while they are passing they can pick up sea lice. Sea trout, when they go to sea, are in the vicinity of fish farms for the whole of their life cycle in the sea and are therefore much more at risk from picking up infections. Equally, when a salmon returns to the river, yes, it passes a fish farm but if it picks up any lice at that point it doesn't really matter much because it's going straight into the freshwater when all the lice will die. It's really a problem for the smolts of the salmon and the problem for the adults of the sea trout and it's a completely different issue for the two. John, do you want to come in and then I'll come back to Peter? Two brief points, if I may, just for a bit of clarity on smolts and sea lice, wild smolts and sea lice. One has to think back to a time before we had aquaculture in the sea locks of Scotland and on the west coast, unlike the east coast of Scotland, west coast adult salmon don't tend to run till around May. Nature designed it, we believe, in that way, that the adult wild salmon, who carries sea lice totally naturally, do not cross over with the smolts leaving a river. What we've actually done over the decades with aquaculture is put hundreds of thousands of adult salmon in the way of a creature that is not used to meeting sea lice. I think that's just for clarity. Therefore, one might conclude that the only way of avoiding that is you either move them out of the way of migrating smolts or you separate them. To go back to the important point on trout and sea trout, certainly we've got a lot of evidence, anecdotal and written up, that when sea trout meets sea lice at sea, as Guy's alluded to, you get this early returning behaviour, it may be, and I don't have a lot of evidence to back this up apart from anecdotal evidence, but it may well be that over time now, over what is essentially three decades, you may well be seeing many of those fish actually staying in freshwater. There's a lot of evidence that in freshwater locks, particularly where you have freshwater smolt farms, you have very much increased stocks, populations of resident brown trout, which in themselves slightly cause an imbalance and in themselves may cause a predation risk to salmon, so we may have skewed the freshwater environment in that way. I'm going to just bring you in a minute. Peter, could you, I think you've got further questions you'd like to push on this. Yeah, obviously there's a categorisation for the health of salmon rivers or just rivers in general that can be graded one, two and three. Could you explain for the committee just the difference between the various grades and could you also explain what the difference in the grades might have as far as socio and economic implications for that particular area of rural Scotland might have? I guess Alan and John probably would want to lead on that. John, do you want to go first or do you want to let Alan lead on it? Oh, it's good to post it to Alan actually, but I'll have you coming up. If I start on a Scotland-wide basis, what's really happened is Marine Scotland science have used what's called a conservation limits approach whereby they assess the likelihood that rivers are going to meet a target of eggs which are deposited into the rivers and if they can meet that target then there's an assessment that the river's relatively healthy. If they're less likely to meet it then there's a sort of graded approach. So we have three grades of rivers and in Scotland, depending on what happens in committee, it was discussed in the Environment Committee yesterday. The idea is that for 2018, 28 rivers would fall into grade one and that suggests that there's at least an 80 per cent probability that the conservation limit will be met. 21 rivers will fall into grade two and they sit somewhere between 60 and 80 per cent probability of meeting that conservation limit over a five-year average, but 122 rivers fall into grade three and that's with less than a 60 per cent probability that the conservation limit will be met. In terms of the west coast, that's the majority of the west coast rivers in the aquaculture zone, so that gives you an assessment. In terms of the social and economic consequences of that, that tends to be quite river specific. As a representative body for boards and trusts, I'm dealing with views that range from going into a grade three river is a disaster, the anglers won't come, the angling clubs won't fish and all the rest of it, to actually that's a good representation of the situation that we're at and that gives us something to work from to get back up to a grade two river. There are quite a range of views across that spectrum. Can you explain in terms of practical terms if it's a grade one, two or three, as far as the angler on the river is concerned? Yes, so the biggest practical difference is if you're a grade three river, it's mandatory 100 per cent catch and release so you're not allowed to kill and take home a fish, so that's the biggest single. I'm wondering in the deputy convener on that because I think she's got a question there. I do, thank you, good morning panel. John, you mentioned the co and the leaven and how the catches have substantially declined on both these rivers. Are they grade three already or are they going to be downgraded because of these catches? Interestingly enough, and very bizarrely, the river Leaven, I said before they didn't catch a single salmon, they actually caught a single pink specific salmon last year, but due to the way the model works they've actually been put to grade one this year. So that's maybe something you have to ask Marine Scotland Science about the model, but the co has gone from a grade two to a grade three, but one thing I would say about all these gradings is, as Alan has said, is the social impact of it is very river specific. But generally speaking, what I come across is a feeling particularly amongst local anglers who up and down the west coast with very, very few exceptions have acted extremely responsibly for the best part of 20 years as we've seen these declines and put the vast majority of their fish back, well over 90 per cent, 100 per cent in some cases. Their feeling now to be forced to do that is a feeling of disenfranchisement, they feel that they've been taken out of the equation and almost blamed for the decline and there's a poor local feeling about that which I think is perhaps avoidable and we need everyone to be moving in the same direction, but does that answer your question? To a certain extent, I have a couple of follow-ups now from your answer. Do you have confidence that the grading system is adequate? If you're asking for my personal opinion on that as a fishery manager, the answer is no. I am encouraged that the model is being improved. It was brought in fairly quickly, but for the reasons that I've just mentioned, as someone who has to manage the results of it, no, we don't feel it's a model that's currently fit for purpose. Just one final follow-up. As we were talking about mortality rates in wild stocks, are there any mortality rates for catch and release? I think that Alan might be able to put some numbers on that, but I believe that there are studies done on that. Alan, before you do that, I'm going to gather your thoughts, because Guy wants to answer the previous question and then I'll come back to you. It was just to try and help the committee in relation to the conservation limits and the various percentage and so on. We've looked at the conservation limits and put them in graphical form. You can examine the east coast, the Clyde-Solway area and the aquaculture zone. The graphical representation shows that the probability of hitting your conservation limits is considerably lower in the aquaculture zone. What that suggests to us is that, yes, salmonid populations are exposed to all sorts of other risks, climate change, habitat loss, upstream and so on, but there is something extra going on in the aquaculture zone that doesn't appear to be going on outside the aquaculture zone. If I may, I'll supply that graph to the clerks after this. Yes, that would be helpful. Alan, I'm going to come to you and there's two questions if you could also answer the socio-economic one as well. In terms of the grading system, from a fisheries management Scotland perspective, we support the principle of ensuring that exploitation is sustainable. We've been working very hard with Marine Scotland Science to try to improve that model along with a lot of the fisheries biologists across Scotland over years. That's an iterative process and we're encouraged with the way that it's going, but I don't think anyone's arguing that the model is perfect. I would emphasise what John said, though, that there is an absolute sense that anglers and proprietors are being looked at almost as an easy target here. We know that there are a range of pressures that salmon are under. I don't think that there's a strong sense that exploitation within fisheries is right up there in terms of those range of pressures. It's right to have exploitation and ensure that exploitation is sustainable. On the same hand, we need to be dealing with all the other pressures that salmon are under and dealing with it in the round in a much more rounded manner. In terms of catch and release, I think that it's a while since studies have been done. Again, it was discussed in committee yesterday at the Environment Committee. The rule of thumb is around about 10 per cent, but I understand that Marine Scotland is going to do maybe perhaps a bit more work on that this year. Peter, do you want to come in again? Just one final bit. You've lost it. You've 28 ones, 21 twos and 122 graded three. What would that look like 20 years ago, for instance? We reckon that it's going the wrong way. It's maybe an unfair question, but have you any idea how that's moved in the last even 10 or 15 years? The system's been in place for three years and it's shifted quite markedly at that time. It's driven to a reasonable extent by catch. We had a very good year in 2011 when we had very high catches across Scotland. Last year, the 2011 catch has dropped out of the five-year average. We've seen quite a marked drop on the back of that, but I wouldn't like to speculate about what it looked like 20 years ago. I'm afraid I'm not qualified to do that. John, I think that you want to come in and then we'll move on to the next question, which is Collins. Given the foregoing discussion and the instrument that's under question at yesterday's Environment Committee meeting, would you describe the science as sufficiently robust behind that new instrument? Or should it proceed or shouldn't it proceed? There's certainly a lot of very unhappy people out there about the 122 rivers that have now been categorised to grade three. I'm far from certain, as Dr Almyls has already said, that it's the catching of salmon that's to blame for that apparent decline in fish stocks, given the significant number of other challenges that they face. I could encourage you to do a yes or no answer. I won't push you quite that hard. Who'd like to head off on that? John? I simply refer you to the answer that I gave previously about the example of the River Leven. I don't believe that a model can be scientifically robust when it comes up with a grade one on a river that's caught zero salmon near before. Alan? It's quite a difficult one to answer when I represent so many different rivers across Scotland. As I say, the principle behind it is right. I think that there are concerns about the model and we're working very hard to do them and we're very encouraged with the changes that have been made to the model over time. One of the problems that we've got in dealing with issues in relation to sea lice and all those lines is that we lack the sort of infrastructure that they have in Norway. The reason that you can have more robust information coming into those things is that other countries have large amounts of infrastructure such as fish counters whereby they can look at the cat statistics in relation to a fish counter on the same river and get a much better understanding. It's the same reason that we're able to do the sort of studies that have taken place in Norway on sea lice. It relates to the infrastructure that they have in place and that's the primary reason that that sort of research hasn't been done in Scotland. It's not necessarily because people haven't wanted to do it and all the rest of it. You need that infrastructure. You're saying that the science hasn't been done to justify this massive recategorisation? As Stuart Millamys said in the committee yesterday, the general approach is very similar to the approaches in Norway and England and Ireland. Do you want to come in briefly on that? Yes, in exactly the same way that the Eclaire committee called for a more precautionary approach to the aquaculture industry itself. I think that it's absolutely right that the wild fishery sector should apply a precautionary approach to itself. If it means that more rivers get cascurised such that there should be 100 per cent catch and release on a precautionary basis while the model is developed, that's absolutely right. I think that we'll just move on from there. Colin, if you'd like to lead off on your question. If I can return to the vexed issue of sea lice and just to follow up a couple of points, I appreciate that we've covered the issue in quite a bit of detail so far, but there's a number of specifics. First of all, on the issue of trigger levels, Marine Scotland has different levels from guidance. I just wondered if you believed that Marine Scotland had got the trigger levels for sea lice on fish farms, correct? Are there the levels that you believe there should be? Is the action required once trigger levels have been reached appropriate action? John, do you want to start off on that? I'm sure that everyone will want to comment on that, but briefly, on the subject of trigger levels or lice targets in general, I believe—and many people observing this have believed for many years—that these numbers are essentially meaningless. If you have a lice target that doesn't take into account the number of fish in a fish farm or the biomass of fish in a fish farm or indeed on the path of a smolt from a river to the open ocean, then whether it's one, three, eight or whatever is essentially meaningless, so I'd just like to put that caveat in there before other people comment. Richard. Thank you. There are a number of trigger levels, as the salmon farmers code a good practice, which has trigger levels of 0.5 and 1 lice per fish at different times of year, and then there are the Marine Scotland trigger levels, which are supposed to trigger some kind of enforcement action. These ones are all based on the impact on the farmed fish, so a farmed fish will suffer damage if it's carrying too many lice, and if it's carrying a large burden of lice, it will die. If you're measuring the number of lice per fish, basically what you're interested in is the impact on the farmed fish. On their own, they say nothing about the impact on wild fish. As far as the wild fish are concerned, what is important is the number of lice larvae that are shed into the sea from a fish farm. If you've got a fish farm with 100,000 fish in and one lice per fish, you know that it will be shedding a tenth of the amount of lice larvae into the sea of a farm with a million fish on it. The correct measure of the impact on wild fish is not the number of lice per fish, but the number of fish in the farm. Given an equivalent lice loading, the thing that determines the impact on the wild fish is the volume of fish in the farm. Guy, do you want to come in? I'd cut you off earlier when you were talking about sea lice, so it must be your turn now. In relation to the various trigger levels, I noticed that the Eichler committee suggested that the 0.5 level in the code of go practice should be a mandatory level. All the providers that lice per fish is not a good measure should be lice per farm, as my colleagues have suggested. It would be sensible to put in a ceiling above which farms should not operate, should be required to harvest early to remove the fish. Below that level, depending on where the farm is, you need to apply some sort of adaptive management, and we heard a bit at the Eichler committee about that approach, monitoring the lice impact on the wild fish, feeding back to how the farms operate. However, there needs to be a ceiling above which the farm should not operate, and the 0.5 trigger level would certainly be our preference. I would go slightly further than that. I mentioned earlier on that we don't deal with sea lice on a Scotland-wide basis. We deal with it on an area basis in what is called a farm management area. I don't think that we should be looking at this on an individual farm. I think that we should be looking at this in a grouping of farms. Farm management areas are the areas in which fish are stocked synchronously. There is an element of synchronisation between the treatments and all the rest of it, so I think that we need to think about it in terms of areas. There's actually quite a nice model for this. It's a voluntary model, but there's a new certification scheme that's been in place for a few years now called the Aquaculture Stewardship Council. A lot of the principles that sit within that certification scheme take this debate an awful lot further down the route. It's one of the main reasons why we're working much, much closer with Marine Harvest now, because they're the one company in Scotland that's going to try and get all of their farms through this certification scheme. It requires a much lower threshold for treatment of 0.1 lice per fish, but it also crucially takes into account the number of fish within the area, so it brings that overall area load into the equation as well. It requires monitoring of wild fish, so that sort of adaptive management that we talked about and that was recommended by the Environment Committee all as part of this system. So a lot of the principles that we would like to see sort of brought into the regulatory system actually already sit there. There's a nice model for it sitting there within the Aquaculture Stewardship Council. To be clear, the information should be published. There should be a requirement on farms to publish certain information, and that information should be what sea lice per farm, and that should be a requirement. Is that pretty much what there's a consensus around? Guy, I'm going to bring you in. Yes, we're completely happy with the recommendations of the Aquaculture Committee report that farm-specific sea lice data should be published on as close to a real-time basis as possible. This is something that we raised at the Old Racky Committee prior to the 2013 act, and there was a lot of support for it then, and I think the time is now. If you publish on a farm-by-farm basis, you can add that up to the farm management area, and if those farm management areas change, you can take that into account as well. I noticed your enthusiasm, Alan. I was going to bring Richard in first, so Richard now is your chance. I was going to point out that Marine Scotland, in commenting on fish farm planning applications, says that even if the farm adheres to the code of good practice level of one lice per fish, that provides no assurance that it will not have an impact on wild salmon populations or wild salmonid populations. Even Marine Scotland acknowledges that the code of good practice levels don't provide any protection necessarily for wild fish, but the other thing that I particularly would like to say was that two years ago we were all talking about the code of good practice levels, 0.5 lice per fish and one lice per fish. Now we're all talking about these trigger levels for Marine Scotland, which have gone up to three lice per fish and eight lice per fish, and it's almost as if those have become targets. Whereas two years ago we were looking at levels of 0.5 and one lice per fish as being where we ought to be, now we seem to be thinking, well, as long as it's no more than three, then it's not too bad. There's a shifting baseline of aspiration, which is extremely worrying to me with these trigger levels. Stuart, you want to come in? I just heard that we could work out what was happening in farm management areas by adding the figures for individual farms. Statistically, would that not be an invalid thing to do unless the dates at which each farm reported were synchronised? Otherwise, you'd be adding numbers that were from different timeline points, which would not give you an understanding of the farm management area. Therefore, is that implying that we need to have a co-ordination about reporting points for individual farms so that we can do those aggregations in comparisons? John, you nodded there. I'd like to bring you in. A simple answer is yes. There's a strong case to synchronise the sampling and the manner in which the reporting is done to indicate the biomass in the areas. I'm very encouraged with the SSPO commitment to release farm-by-farm data by the end of April. Alan? It was just to say at the moment that the farms, assuming that there's not problems with the weather and all the rest of it, are counting lice on a weekly basis. If the requirement was to publish on a weekly basis and a farm basis, I think that deals with that issue. Colin, do you want to come back? I'd like to turn to what happens in other countries. I notice in the evidence that Child Conservation Scotland says that sea-lice limits and enforcement are weaker in Scotland than other European salmon farming countries. How do sea-lice limits and enforcement work in other countries and are conditions in Scotland that different from other countries that we can't effectively import some of the good practice there? Gion, Alan? Salmon farming in the Faroe Islands operates to a fairly rigorous scheme. They require their farms to report their lice figures. When they exceed 1.5, three consecutive reporting, their four-nightly reporting, they have to harvest out their farms within two months. If you're over 1.5, three times in a row, the fish come out. Importantly, from the point of view of adaptive management, next time you stock your farm, you have to put fewer smolts in. The following production cycle is at a lower level. In theory, at least, the lice issue should be addressed. If it isn't addressed, you go down further and so on. The Ecclare Committee talks about the adaptive management process that they want to apply. This is one of the ways that they might seek to do it in this country. Alan, would you like to come in on that? I think that I would just emphasise the variability that we see across Scotland. I don't think that it's remotely fair to say that if there's a problem in one farm, there's necessarily a problem in another. It's a very complex system that we're all operating in here. Part of the problem is that we don't fully understand the consequence of any particular lice level in a particular location at a particular standing biomass of fish. It's very likely that that will vary. That's where the adaptive management is so crucial. If we can find a way of monitoring what's happening on the wild fish population in relation to what's happening on the farm, then we can tailor those approaches in an area-by-area basis rather than trying to have a one-size-fits-all approach. Colin, do you want to add? Last week, we heard from the fisheries minister from Norway where they have lower targets than we do in Scotland. He was suggesting that there was a traffic light system, not dissimilar. Has anyone come across this system? It was a very interesting procedure where, if you reach green level, you can stop more and if you reach red level, you have to reduce inputs. Have any of you come across that tool? I'm aware of the broad principles of it, but not necessarily the specific detail. I think that that is an example of adaptive management. I don't think that it's an example of adaptive management that, using the specific thresholds that they permit in Norway, would necessarily work here. My understanding is that they would permit up to about 30 per cent of the wild stock to be impacted negatively before they go up to that sort of top level. I don't think that our stocks on the west coast are in a position to be able to withstand that sort of level. That's certainly the difference between a grade 2 and a grade 3 and probably significantly more than that. The next question is mine. I'm going to focus on legislation and regulation to protect wild fish. Before I ask the question, I just want a very short quote from the Environment, Climate Change and Land Reform Committee's recent report. It said that the committee is not convinced that CEPA or any other agency is effectively monitoring the environmental impact of salmon fisheries. The committee is also not convinced that the regulations, protocols and options for enforcement and prosecution for the sector are appropriate and being appropriately deployed. My question is this. What legislation or regulations should be amended? In what way should they be amended to protect wild fish from any impact from salmon farming and which organisation should be responsible for regulating this? There we go. Quite a lot of questions there. Guy, I think you did here. The salmon and trout conservation and Scotland petition from 2016 drew everyone's attention to that there is a gap in the law. There is no Scottish public authority charge dealing with the interaction between farmed and wild fish. We're pleased to see that the eclaire committee, I hope that I'm calling it the right name, accepts that and points to this gap in the law. It can be plugged in a number of ways. I've looked at it from the purely legal point of view. You could amend the Aquaculture and Fisheries Scotland Act 2007, you could amend the Marine Scotland Act 2010, you could apply the Water Environment and Water Services Act 2003 and introduce new car regulations under that. It all depends on what the Government's policy decision is in relation to which regulator has to pick up this particular issue. There are a number of different ways of doing it, all of which we'd be happy to help to work with the Government to deliver. It doesn't have to be the Government. The committee can produce a committee bill. Alan, would you like to comment on that? I would just emphasise what the Environment Committee actually said and agree with it. We have a situation at the moment where the fish health inspectorate, for example, has a remit for the health and welfare of the fish within the cages but not for anything that comes out with the cages. We talked earlier about the number of fish within the cages. It's SIPA that are responsible for consenting that biomass, that number of fish that are actually in the cages, but they don't view sea lice and sea lice leaving the cages as part of their remit. In terms of the specific legislation that needs to be amended, I don't have a specific view on that. What we need to do is work out exactly where we want to get to and then look at the various pieces of legislation and decide what the best way of doing that is. I was at a meeting a few weeks ago with the industry, with the local authorities who deal with the planning applications coming in and the various regulators, and that was a meeting that was hosted by the chief planner. It was a very strong sense that the biggest outstanding issue that is not dealt with by the system at the moment is wild fish and farm fish interactions. There have been various reports that have been made. There was an independent consenting review a few years ago, there were various things, and basically they have said, we'll take it out of the Town and Country Planning Act and we'll shift it somewhere else, perhaps a marine licensing system, which is the Marine Scotland Act that Guy mentioned. It's important to emphasise that just simply moving this issue from one system to another one doesn't deal with the underlying problem. We actually need to deal with the underlying problem and then the system works through it from that. From a slightly more local perspective on this, as we see the end results of regulation, currently, as we know, it's with the planning committees of local authorities. Usually the meeting to decide major developments of fish farms are done alongside house extensions and someone's garage or whatever. It seems rather odd to me, and we can't expect the level of knowledge required to be sitting in these committees. I think that it would be completely unfair, and I think that the Highland Council's response to the Eclare Committee hinted at that. I would also refer to the comment in the Eclare Committee report that says that too many regulators are not enough effective regulation. I have a certain sympathy with the fish farmers on this. What it's not saying is that there's not enough regulation, there's not enough effective regulation, so it's clear that it needs to be streamlined in some way for everyone's interest. Allen referred to this, and it's referring back to a point earlier on on sea lice. CEPA fundamentally decides on how many fish go into a cage or how many fish are going to be allowed in that cage. I would argue that, by default, they are overseeing sea lice. They maintain they're not, but I think that needs to be clarified. I would argue that they actually are. It's a hot potato that's been passed around for many, many years, but it needs to find a home and one organisation needs to have broad enough shoulders to take it on. On that very point, I mean, do you think that the responsibility should be CEPAS, and therefore they are often being particularly criticised by the Environment Committee? Do we need to change the law and change the regulations to give CEPA the proper responsibility for regulating this whole issue? I mean, there is a view that perhaps another organisation should be set up, but if people are saying that there's too many regulators and not enough regulation, effective regulation, is the solution to make sure that CEPA gets the proper instruction to do it? Richard Guy, and then I'll come back to you, John, if I may, and Richard Lyle afterwards, so Richard first. Thank you. Yes, the problem is at the moment that we've got three regulators all over whom tonight's anything to do with them. It's a very unedifying spectacle of everyone taking a collective step backwards and scrambling for the exit. And CEPA argue that it's not a pollutant, so it's nothing to do with them, and fish health inspectors say that they're interested in farmed fish and that local authorities are more interested in garages. I mean, I've got a letter from CEPA dealing with this exact point, and it says, CEPA acknowledges that sea lice and escapes of farmed stocks are pressures on the water environment. For all these pressures, however, Marine Scotland and the local authorities are the principal bodies for regulating existing and new aquaculture developments. In other words, it's nothing to do with us. And that's, as John says, it's not the case, because the primary lever by which you could control sea lice escapes is by limiting the volume of fish in fish farms or the number of fish in a individual fish farm. And we've just been looking at this new consultation on the depositional zone regulations, and the preamble to that says that the main purpose of this or one of the main outcomes of this will be able to increase the volume of fish farms from 2,500 tonnes to 8,000 tonnes. So here we have an existing problem with fish farms, which at the moment don't exceed 2,500 tonnes, and CEPA is talking about increasing that by many times. We absolutely know consideration of what impact that might have on wild fish because we've already seen. CEPA is saying it's nothing to do with us, but CEPA are the main body which is limiting the size of individual fish farms, and that is the main source of pressure on wild fish populations. Therefore, as what you're saying, should we as a parliament give CEPA the clear responsibility to regulate this? The problem is that the way that fish farms operate at the moment, if you're applying for a new fish farm, you've got to get two things. You've got to get your Crown of State lease, but the two principally regulated steps, you've got to hoops, you've got to jump through. The first is you've got to get your car licence to discharge pollutants. The second is you've got to get your planning consent. It's up to the fish farms as to which of those they go for first, and they tend to play one off against the other. They'll get their car licence and then go along to the local authority and say, we've got our car licence, so CEPA thinks it's okay, so it's up to you now. There is this feeling that you're playing one off against the other and nobody wants to be seen to be standing in the way of a new fish farm if somebody else has already approved it. I think that what is needed is a single streamlined process whereby you make a single application for the fish farm and all of the impacts are considered together rather than trying to split it up into two processes. Cary, I'd like to bring you in and then John. I'd like to endorse everything that Richard just said, but perhaps as a little bit of history, if you go back to the CEPA's fish farm manual from 2005, so prior to the Aquaculture of Fisheries Act 2007, they did state that they would limit the biomass on fish farms in order to protect important stocks of wild cell monids. That's in the fish farm manual from 2005. What I think happened in 2007 when the sea lice powers were given to the fish health inspectorate, CEPA thought, that's not us anymore then, but without appreciating that the powers that the fish health inspectorate were given in the 2007 act related just to the farmed fish and not to the farm fish-wild fish interaction. I think that's where the problem arose. It's difficult to get back because the institutional memory within CEPA is not great, but I think it's perfectly possible that CEPA could take this role. I think that you also look at the responsibilities under the water framework directive and the fish element within categorising the status of water bodies under that directive and it would fit quite neatly with what they already have to do. As I mentioned earlier, the water environment and water services act 2003 is already set up to allow regulations to be drawn. There's no reason why regulations couldn't be drawn under that act to firmly place this in the responsibility of CEPA. It wouldn't require primary legislation. I'm going to go to Richard Lyle and come to you, Alan Miles. Again, yes. I would just back up what the other witnesses have said on this matter, but I would also add, Richard has mentioned the two processes that you have to go through if you want to have a new fish farm. There is actually a third one, and it's actually before any of those take place. As a fish farmer, I have to apply for one, and I've got one, which is an APB licence, which is an aquaculture production business licence. It's essentially a licence to operate, and it's issued by Marine Scotland. There's possibly a possibility there that you could use that licensing system to address some of these issues. We would certainly like to see, in terms of the planning applications and the car applications for fish farms, Marine Scotland take a far more of a far stronger view than they're currently doing. Currently, they're fairly neutral in their response because they are acting as a statutory consultee exactly the same as the fishery boards. As I always argue, Marine Scotland has all see for perhaps the best place to take this on. Richard Lyle, do you want to come in? I basically agree. I think that we should make someone in charge, but last week I asked, gentlemen, you've vindicated the point that I made last week. I thought that there were too many fish in the farm, but I was told that they're more of a merrier because they're all happy. If they're swimming about in big shoals, so thank you very much. You've just confirmed what I said, and I think that's the other point that we should be looking at. We've got the more fish, the happier the fish. Mike, do you want to...? Just to correct me if I'm wrong, I'm getting from you. I don't want to put words in your mouth, but I'm getting from you that we actually think that it should be stronger regulation and it should be someone in charge of that regulation. It would be more likely than not to be SIPA, is that right? Most people are nodding and shrugging their shoulders at the end. I'm going to bring in Alan, then I'll bring in John Finnie. I don't have a strong view about who should lead. Someone should lead, but what's really important is that the current regulatory lacuna, which I think lots of people understand, whereby wild fish seem to fall through all the gaps, desperately needs to be addressed. John, would you like to come in with a brief supplementary? Thank you, convener. I'm just trying to clarify, are you all seeing no role for the local authority in the process? With another hat on, I've acted for groups on the west coast looking at fish farm applications, and it's not just wild fish interactions that they're concerned about. Local communities have concerns over the landscape, over navigation issues, over all sorts of things. There has to be some element of local accountability. It would be untenable, I would say, to remove responsibility completely from those authorities on the west coast in place in Edinburgh. I just don't think that would work, so I would definitely see a role for local authorities going forward. I could go right the way down the line, but maybe for the official record, if I say that you're all nodding, that local people and local authorities should have a role, are you happy with that, John? That's helpful, thank you very much. Can we move on to the next question, which is Gail Ross? Marine protected areas. There are various communities along the west coast that are very nervous about new applications or existing farms extending. Should they be allowed in marine protected areas? Who would like to add off Richard? Marine protected areas have been designated for a number of different reasons. There are protected areas for harbour purposes, for flapper skates, for different habitat types, such as burrowed mud habitat. All those features are impacted to different extents by fish farming. Clearly, the measures that you would put in place for a harbour purpose would not be the same as the measures that you would put in place for burrowed mud, because the impacts would be very different. I wouldn't want to say that there shouldn't be any fish farms in marine protected areas, because you need to know what the particular impacts were. Having said that, when the marine protected areas were originally drawn up, the boundaries of these, Marine Scotland looked at a range of priority marine features. I think that there were something like 80 different marine, priority marine features. Individual marine protected areas were drawn up, established to protect a certain list of priority marine features. Some of those priority marine features have no marine protected areas at all. For instance, the sea trout, which we have been talking about a lot, is a priority marine feature in the Atlantic salmon, but there are no marine protected areas set up to protect those. Clearly, if you set up a marine protected area to protect the sea trout, it would be perfectly reasonable to say that we would not want any fish farms in here because of the problems of interaction of sea lice with the wild sea trout. The Government announced that these other priority marine features would be protected by a range of wider seas issues. I'm afraid that I don't see a lot of evidence of that at the moment, certainly in relation to fish farms. The panel may be aware that there was a problem a few years ago with damage to flame shell beds outside marine protected areas in Loch Karen. This was from trolling activity, dredging activity. Even if you have all of your features within the marine protected areas adequately protected, there will still be damage outwith those areas to some of those features, some of which are extremely important. I know the example that you are talking about. A marine protected area was set up to protect that bed. I know that Alan wants to come in. We were talking about regulation earlier on. Do you think that there are any regulations that need to change to take into account priority marine features or MPAs? Marine Scotland is currently carrying out a review of some of those priority marine features. I think that there are 11 of them, which are particularly susceptible. This is to fishing pressures to see whether other protection measures are needed. I don't think that there's been a review of features that are likely to be impacted by aquaculture. It would be a good idea to carry out a review of those features because that hasn't happened up until now. The assessment of the impacts on some of those features is not, in my view, adequate at the moment. Alan, would you like to come in on that? I've already mentioned that Atlantic salmon and sea trout are priority marine features, but they are not part of the area of protection element. It's slightly outwith my locust. Some of my members are particularly interested in, from a nature conservation perspective, freshwater pearl mussels, which are critically endangered. They rely on salmon and sea trout to complete their life cycles. The migrating fish coming back into the river pick up the larvae of the freshwater pearl mussel and move them back up the river. That emphasises how important sea trout are. Some of the SACs for freshwater pearl mussels in the west coast are primarily sea trout rivers rather than Atlantic salmon rivers. Sea trout need to be looked at, not just in terms of their value from a fishery and a nature conservation perspective in their own right, but also with the linkage to those other, as I say, critically endangered species. John, do you want to come in at this stage? I know that Gail's got further questions. It was just about the protection of marlbeds and fish farms being located over them. The clear committee received some evidence to say that that hasn't always been all that it might be. Would you like to discuss that? Richard, would you like to know about it? Marlbeds are particularly susceptible to damage from sedimentation of organic material from fish farms. There have been various studies to indicate that where you get marlbeds in proximity to fish farms, you can see evidence of sedimentation at some considerable distance from the fish farm. Marlbeds are also under threat from a number of other things such as dredging, but fish farms would be an additional pressure on marlbeds that needs to be addressed. Obviously, when most of the fish farms were set up, there was no protection for those marlbeds. The fish farms have been there for some considerable length of time. Of the 220-odd active salmon farms in Scotland in the sea, over 30 per cent of those are already in protected areas. The fish farm was in operation before the protected area was delineated. I think that there is a sort of assumption that if fish farming has been going on before this thing was designated a marine protected area, then it can't have been doing much damage. I don't think that's a safe assumption. I think that we really do need to look at some of the impacts of these fish farms. That's just in terms of gross pollution of feces and other organic material. When you look at some of the chemicals, we haven't even really started talking about some of these therapeutic chemicals that are used in fish farms, which we're now getting evidence are having much wider, more widespread effects, kilometres from the fish farm. I think that we do need to look much more closely at the impacts of some of the existing fish farms within marine protected areas. That's a perfect opportunity to bring the deputy convener back in. I want to ask a question on depositional zone regulations. SEPA is just closed a consultation. I think that the results are going to come to us in June this year. The Eclear Committee said that, and I quote, they understand the new DZR that is being consulted on seems to allow the expansion of fish farms in more exposed locations while requiring a tightening of the monitoring of nutrient waste. They say that this has not been peer reviewed and there is a lack of available scientific and published evidence to support the model. I also asked about communities and their concerns about fish farms close to the coast. We have the kind of conflicting of whether we put them further out to sea where they are more exposed and therefore coastal communities are happier, but are there problems with them being more exposed in the depositional zone regulations? Do you have an opinion on that? I have already highlighted one major concern with the depositional zone regulations in the fact that increasing the size of a fish farm is going to make the sea-lice issue considerably worse and there doesn't seem to be any consideration of that in the mechanism as it stands at the moment. The dispersion of waste from fish farms is a very complex subject, but I think the thing that you need to bear in mind is that within the aquaculture zone, that's the west coast, 80% of all of the organic waste from terrestrial sources from the land enters the sea comes from fish farms. A single fish farm, which currently has a maximum size at the moment of 2,500 tonnes, produces the sewage equivalent of a town twice the size of Oben. If you add up all of the towns on the west coast virtually, it's producing the same amount of sewage as one fish farm, a moderately large-sized fish farm. Of course, you're not allowed to discharge waste from a single septic tank into the sea without being treated, and if you were to suggest building two obans somewhere in the sound of mull and saying, is it alright if we just chuck the sewage straight in the sea, you'd get a very short shrift from seaper over it, but somehow putting a new fish farm in seems to be exempt from a lot of these issues. We are talking about huge quantities of organic waste being put into the sea. There have been various attempts to improve the modelling. There has been this deeper model that seaper use for predicting the impact of the dispersion of waste from fish farms has gone through a number of different iterations, and there was the phase 1 version and the phase 2 version. None of them are particularly good at modelling complex currents. If you've got a complex environment with different sea locks coming in and islands and tidal currents going in all directions, then you have extremely complex currents. I was at a presentation from seaper just last week when they were demonstrating the use of yet another model, which is far beyond the one that is talking about deeper mod for the use of these DZR regulations, which was showing much more complex interactions between all of these currents, and that you were getting deposition in areas very remote from the fish farm. We are getting deposition two or three kilometres away from a fish farm, whereas the current models assume that all of the impact is within a single one-kilometre square, or maybe slightly larger now. Once the waste leaves that modelled square, they forget about it completely. In fact, we know that that's not the case. Some of that waste is channeled into very specific locations and deposited there quite a long way from fish farms, and none of those models at the moment really capture that. I think that the DZR model, which is based on another iteration of this deeper mod, will have exactly the same problems. I'd like to bring you in there. I appreciate the question specifically about DZR, but if I may make some general comments about these new or higher energy sites, specifically the ones close to us in my region are rum and muck and the inner aisles, it would be fair to say that the general direction of travel within the fish farming industry is looking towards these new sites. Certainly, from our perspective, there's one key piece of the jigsaw missing prior to this. That's actually working out where the smolts from the rivers on the west coast of Scotland, what are their migration paths. If that was done as a pre-application piece of work, we may well find from that that, on the issue of sea lice, there may well be parts of the inner aisles or elsewhere in these high energy sites that impact migrating fish far less than other sites. If we knew that, that might offer an incentive for the industry to meet expansion targets, but it would also satisfy a great deal of wild fish concerns. At the moment, what happens is that, if you want to build a fish farm in the inner aisles, you get the usual authorities allowing it, and there's no pre-application work at all, so we don't know what we're putting out there. In general, we would far prefer to see the relocation of inshore sites out to these sites, but we need to have that work done before. I may also add that, at the moment, there is no mechanism within the regulation to allow the local authority to allow any relocation of inshore sites. Often, as a fishery board, as a statutory consultee, we'll reply to these applications and say, yes, we're conditionally supportive of these sites, we'd like to see small migration work done before you go in there, but secondly, we'd like to see a phased relocation of particularly sensitive sites. At the moment, the local authority has no power to say to a site inshore already with a full planning permission, you have to relocate biomass, so what I would suggest is that we need some sort of mechanism within the planning regulations to allow that, and I think that we might be perhaps even knocking at an open door within some of the fish farm companies on that. There's people queuing up to speak here, and time is marching on. I'll take Alan and then Guy, and I would ask you to keep it very brief. Guy, if you're going to drop out, I'll bring Stuart in after Alan very briefly. For all the reasons that we discussed in the earlier part of the session about regulation, we're of the view that the DZR proposals, as they stand, shouldn't be taken forward in isolation from a broader review of regulation more generally. I think that most of the issues have been covered, but there's one thing in DZR that I think is a good principle, and that is that SIPA is saying that they would intend to take on a greater responsibility for monitoring themselves rather than operator monitoring. I think that that principle is a good principle within the DZR proposals. Sorry, the regulations that the proposal should not be taken forward should be as part of wider regulation. Stuart, do you want to come in very briefly for a move on to John? I'm just on the arithmetic again. In relation to a large fish farm, putting the same amount of waste out is open. I just wonder if the natural biomass that there is in a particular area will also be putting waste material away. My question is, is it known by what proportion the natural biomass is increased by the presence of fish farms? I'm not asking the question about local effects, because clearly, if you put the biomass in one place, you get it all in one place. I'm just asking a more general question. Richard, I'll bring you in and then we must move on to the next question, so I'm afraid. The answer to that question is probably not. The natural biomass, you've got to bear in mind that this is an intensive farming operation. If you were to talk about the natural density of large mammals in the highlands, it would be a certain area but a certain number of kilos per hectare or something. If you put in an intensive cattle farm, it's a very much greater density of animals per unit area, and that's exactly the case with a fish farm. Not only are you putting in a very high density of fish, but you're also chucking in large quantities of fish meal and food, which has come from all over the place, which is a net input to that ecosystem, so it's inevitably going to have a large effect. It's therefore the density, rather than the volume, that we're speaking about. I understand that point. I think that Mickey Mellon would now wish me to shut up. I'm not even going to go there with an answer to that. John, perhaps you'd like to move on to the next question. No, thank you. I want to talk about the problem of escapees of farm fish and the problems as you see them for the record. We're probably all familiar with them to some extent. I'm intrigued to read that in Norway it is a notable escapees of farm fish are considered to be the greatest threat to wild salmon and further that we understand that in Norway, if farm fish escape, the onus is on the fish farm to catch those escaped fish incurring the cost of doing so themselves. That would be groundbreaking. There are a few elements of the regulatory system in Scotland that are interesting in relation to that. In Scotland, it's not an offence to have an escape. It's only an offence not to report it if you have one or to report circumstances that may have led to an escape, so even if you don't know if there's an escape, if you find a hole in the net you have to report that, even though you don't know whether fish have escaped or not. Obviously, escapees do happen in Scotland. In particular, we're concerned about escapes that have happened in freshwater as well. We have a situation on a particular freshwater lach in Scotland, a lach's shin, where there are two farms and for a long time farmed fish have been found in the lach, but because there are two farms and there have been no reported escapes, both farms have said, well, it's not as we haven't got any sign of an escape. Recently, Marine Scotland Science has demonstrated, through genetic analysis of those fish, that those escapes have been coming from both fish. There haven't been any reported escapes, but for whatever reason, those fish have been getting out into the lach. There are all sorts of concerns around that. Concerns relate to genetic integration, the genes from the farm fish getting into the wild population through crossbreeding, but even if that doesn't happen, if you have large numbers of escapes it can swamp the wild population. Generally speaking, the loss that we have in Scotland are quite nutrient poor. There's not a huge amount of habitats, so the numbers are relatively low. If you have large numbers of farm fish coming into those areas, that can cause problems. Equally, if you have escapes in the marine environment, if they do find their way into the river again, they can crossbreed with wild fish. We know that fish that have crossed bread are much less able to survive in the future. In terms of your answer and the answer of others, would you like to propose solutions as well as you go along, as well as defining the problem where interest is in solutions? Would you like to come in there? Certainly, and just to refer back to the freshwater farm issue and, as you say, to actually say what is the solution to this, because I would certainly back up what Alan said about the problem. We have three very large freshwater smolt farms in our region. You may have heard this term drip-drip escape as a grower of juvenile fish. I know that they are not always the same size, so if you put those in a net pen they are not always going to be held by that net pen, they do escape. We have had two barns that have shown 100 per cent Norwegian gene in all the juveniles in the spawning barns. It is probably the reason that this practice of open-cage farming in freshwater locks is not allowed in Norway, but it is in Scotland. The solution, I would say, is fairly straightforward for the freshwater farms. Indeed, the farmers have already addressed this, and they are now growing smolts in closed-containment units. Specifically, I think, of marine harvest at Lochailert and also at Inchmore, very large closed-containment smolt growing units. There is a solution to it, and it has already tried, tested and very much up and running. Just to add a bit of clarity, those juvenile fish that are in freshwater, if they escape, do they have to go through the same process of going to sea for maturity, or can they actually go into the burns and become sexually mature without going to sea? I think that somebody said that that is possible. Is that possible? It is absolutely possible, particularly for the male fish. You get what is called a precocious par, which is a very odd term, but what that means is a par, a small juvenile fish that matures in freshwater. A lot of work has been done to show that precocious par can make a large contribution to the spawning effort, so it does not just take a large male Atlantic salmon returning from sea. Therefore, that genetic can get into the wild population very quickly. Richard, would you like to comment on that and then I will come back to you, John? Just to say that, as you already highlighted, it is the number one threat in Norway, and the main problem is that these escaped fish show lower survival levels once they get into the wild, into the sea and the rivers. It does not take a very large change in the survival rate to have a major impact on the number of fish returning to the river at the end of the day. Could we be pursuing the same vigor, the way that Norwegians are pursuing these escapees, that is up to the farmed fish from whence they came, to catch them and recapture them? Does that lead to things like tagging or responders or satellites out there now? Well, as Alan said, genetic fingerprinting can identify the source of the fish quite well in many cases. You want to know where the fish is and go and catch it? Really, I mean, once the fish have got out into the environment, it's quite difficult to catch them all. In fact, it's extremely difficult to catch them all. It's impossible to catch them all. Really, the problem is to stop them getting out in the first place. As several people have said, the answer to most of these things is closed containment. If you've got closed containment, that solves an awful lot of these big problems that we're talking about. Gai, I'm going to bring you in and then John, and John, I'm afraid we'll then have to move on to the next question. I was merely going to say what Richard just said, that the answer to this is not to let the fish out in the first place, and that is to grow them in closed containment. You won't stop all escapes. Closed containment will have accidents, but it'll be far reduced from where we are now. John, do you want to... Very briefly, one other point on escapes is that we find locally that farmed fish don't tend to run into rivers immediately. They tend to mill around in the sea locks for really quite a long time. Then we've got to think of what are the knock-on effects of that. We suggest that the predation levels that you get, particularly from common seals, the common seal population is doing very well on the west, and it may well be because of the level of escaped fish around. Certainly nets that we still lift the order legal net around the coastline of the west, as one might expect in the culture, but mostly what we find in those nets is farmed fish. John Finnie, you'll see the next question. Thank you, convener. I had a couple of questions. I think you'll appreciate that one of them has been comprehensively answered, but we're going to draw on the evidence that you're deferred to in your written evidence, Mr Gibb, about freshwater fish. As an interim stepper, as a general, you talk about closed containment rather than a limit to the number or the density. Should that be a factor at the moment? Both in freshwater and in seawater fish farms? To cover the freshwater, my own view would be that it's a bit of an all or nothing. I don't think that it makes a great deal of difference to us what the total amount of fish is in the farm, really the issues of those escapes and the issue of excess feed falling down from the nets and then that sort of having an impact on growing species below, wild species below the nets, sea trout that want to go to sea. The only reason the sea trout goes to sea is to find food. If it comes across that food on its migration path to the sea, there's every likelihood, and, certainly, evidence would suggest this, that they're simply reverting to resident brown trout. We're catching resident brown trout in Loughlocky, where there's the largest freshwater smolt farm in Scotland, of up to £23 for a resident brown trout in Scotland. A good resident brown trout pre-fish farming days was probably £2, so we're getting these enormous fish, which, obviously, smolts, salmon and sea trout are funnelled on their way to see at the exits of these lochs, and you can actually visually see sometimes at dams or whatever these huge trout just picking off the smolts, so there's knock-on effects. I don't think it's about numbers for freshwater. Sea water, I'm sure the others will want to comment on that. We did not deliver the point, but we did hear last week about how fish concentrate together anyway, regardless of the space that they've got. Is there a question of density in some instances? Should there be a limit to the density of fish? I'm trying to use a lay person's term here. Just to clarify, from a wild fish perspective, the density in which the fish are farmed is much more of a welfare issue for the fish in the cages. When we're talking about escapes, it's when the fish get out that I'm not sure to what extent the density of fish within the cages has a bearing on that. The other question that I'd like to ask relates to medicines and chemicals, and you're all familiar with the clear committee's report. They talked about specifically data analysis and analysis gaps, including the analysis of the cumulative or additive effects. Obviously, we know that medicines and chemicals are used to treat pharms salmon with sea lice. Can you comment on the impact that these treatments have on the environment or other species? I think that we've covered the point, but just to perhaps labour it. Do you believe that that issue is effectively regulated, please? Richard, please. You're right to highlight this. There are a whole range of problems. One of the best documented studies is of one of the in-feed treatments in Mbenswate, a study carried out by the Scottish Association for Marine Science a few years ago, which concluded that levels of residues from this chemical were much higher than expected, but also that it was causing widespread mortality of wild crustaceans at very low levels, levels below the level at which you could detect them in the water column or in the sediment. This chemical Mbenswate in Mbenswate has a half-life of 250 days once it gets into the sediment, so half of it will have disappeared after about nine months, whatever it is. The European Medicines Directive defines a very persistent biotoxin as one that has a half-life of 180 days. It is a nasty chemical that is being chucked into the sea in large quantities and which is impacting wild crustaceans, as far as we know, at extremely low levels, causing mortality of 60 to 90 per cent of wild populations of some of these crustaceans. Clearly, that is not being adequately regulated at the moment. There are ongoing discussions about whether we need to radically reduce environmental standards for the amount that can be put into the environment. However, there are a number of other chemicals that are used, which are not regulated at all. For instance, we were talking about gill diseases earlier. One of the main chemicals that is used to treat gill diseases is hydrogen peroxide, and there are virtually no controls at all on hydrogen peroxide. It is a strong oxidising agent that kills off quite a lot of organisms in the sea, but there are virtually no controls on the release of this chemical into the sea. It is being used in increasing quantities because of the increasing incidence of these diseases. Some of the other chemicals are neurotoxins, which are in the news a bit at the moment, and those things are being used in bath treatments, which contain the pen temporarily and pour the chemicals in. When the treatment is over, you just take the containment off and this chemical gets released into the sea. We know that the plumes from those bath treatments can extend four or five kilometres away from the detectable four or five kilometres away. I am sure that we do not know what the impacts of those are, but we would not be surprised if some of them were much more extensive than we currently understand. There are a lot of concerns relating to many of the chemicals that are used. I noticed that most of you nodding there. Does anyone want to come in? John, have you got a follow-up to that? If no-one has got a follow-up, we will move on to the next question, which is to Stuart Stevenson. I have been encouraged to ask about partnership, but I think that it has probably been adequately covered. That leaves me just with the question that there are ways of engineering better solutions, funnels beneath salmon farms, closed containment that we have talked about, but my question is simply, are there sufficient incentives, regulatory or economic, to cause the adoption of that in the farm industry? I am going to come to John first as a declared fish farmer. I think that the incentive, probably in all of this, is to identify a site for a fish farm company where it can operate without risk to the environment. Some of the things that we have already covered would be the monitoring of small movements, the higher energy sites, the DZR coming into play. There might well be that incentive there, but I do not believe that there is a great deal of incentive for inshore sites, nor perhaps should there be based on what we know. Alan? There are not any incentives that I am aware of, but I know that the situation in Norway does incentivise some of those technologies, and certainly in our response to the Environment Committee, we made the point that it would be good to see those sort of incentives coming through in Scotland. It is just a weak point for this committee. What incentives matter in Norway that would help here? I do not know the specific details, but they have a green licence system whereby you can get a reduction in your licence fees if you are trialling new technologies, whether it is closed containment, whether it is some other form of dealing with sea lice or other challenges. It comes through the licensing system in Norway. It is not necessarily a direct parallel, but the point that I am making is that if there is a way of incentivising this sort of thing in Scotland, then I think that we should look at it. Richard, and then Guy. A lot of those new technologies such as closed containment are one of the main arguments against them, is because they are more expensive to operate, and therefore it is more difficult to run a farm at a profit. Some kind of financial incentive, I believe for this green technology incentive that Alan was mentioning, you get a 90 per cent discount on your licence fee, and the licence fees are quite high, so that sort of level of discount is going to produce some effects. Ultimately, the issue is that salmon farms at the moment externalise a lot of their costs. I was talking about the issue of discharging sewage into the sea. If you have a sewage plant on land or a farm intensive cattle thing on land, you have to pay for the treatment or disposal of that waste. Fish farms externalise those costs, they chuck it into the sea and they do not have to pay for it. It is a free service they get. Similarly, the disposal of these chemicals that are being discharged into the sea through either release from bath treatments or in feed treatments. That is a free disposal service. If you have chemical residues resulting from your farming operation, then you do need to dispose of those appropriately. All of these costs are currently externalised, and we have said that closed containment is a new technology and something that is more expensive. Effectively, what you are doing is trying to bring some of those costs into the economic envelope of the farm and get them properly dealt with. I think that the sooner we can move in that direction, the better. Guy, just to add to what Richard is saying, you need as many incentives as you can possibly give closed containment. One of the options that the Scottish Government has before is in relation to seabed leases. Now the Crown Estate is devolved up here. There is no reason why a Crown Estate lease for a novel site shouldn't come at a peppercorn. Moving forward, if you are going to incentivise closed containment, you also need to address the externalities issue that Richard talked about. The licence fees for open-cage traditional fish farms are relatively cheap. If we are going to go down the road of adaptive management, somebody has to pay for that. It is something that the fish farmers may have to recognise, that they will have to pay more for the right of operating farm in order to have the monitoring done to deal with all the various problems that the Eclaire Committee has discussed today. John, I can bring you in very briefly. I think that I have the final question. I would like you to talk a little bit about the depositional zones and the mechanical harvesting of that waste beneath tanks. You should talk about a kilometre square, which is essentially 100 yards by 100 yards. If there was a suspended tree that harvested the fish poo, could that not work and solve many of the depositional problems in those zones and deliver much of what we want to see? I think that it is being trialled somewhere, I believe, in Norway. Of what they call a funnel system, which is basically what it sounds like, which is a funnel that you stick underneath a fish farm which traps most of the waste. It does not need to be a kilometre square. It literally can be more or less the footprint of the cage. Indeed. That will trap the waste. Then, of course, you have the problem that you need to deal with that waste somehow. You need to suck it out and put it into some kind of treatment plant, which is not difficult technology. The problem with a funnel is that it deals with one problem, which is the waste falling out, but it does not deal with the sea lice issue. You still get sea lice coming into the farm and you still get larvae coming out of the farm. There are other technologies that consist of putting a skirt around the farm so that you cut it off from the surface waters but allow water to come in from underneath. That helps to protect the farm stock from getting infestations of sea lice, but it does not necessarily prevent lice larvae from escaping from the farm. What you do is put the two together. You put your skirt together with your funnel, so you end up with a completely closed containment system. That solves both your problems. Excellent. There is a part of the solution that we are looking for. Many thanks. It would almost be a good place to end, but I do have the last question and I am going to encourage each of the panel members to give a yes or no answer to this. In your view, given current rules and regulations, can farm salmon industry growth targets be met without detriment to the wider environment? John. It will not be quite yes or no, but it is going to be nearly. Yes, but not in the current locations and with effective monitoring prior to going into these new locations be that temporarily into the high energy sites and long term into recirculation units. Alan. Under the current regulatory regime, no. Richard. No. Guy. No. Thank you. Thank you all for your evidence this morning. It has been extremely interesting. I am going to briefly suspend the meeting to allow you to part. I would ask committee members to remain seated because we need to move on to the next subject. Thank you very much. I briefly suspend the meeting. I am going to reconvene the meeting now. I am going to move on to agenda item 2, which is subordinate legislation. This is the consideration of three negative instruments as detailed on the agenda. No emotions to a null have been received in relation to these instruments. My question is, is the committee agreed that it does not wish to make any recommendation in relation to these instruments? That is agreed. That then concludes today's committee business and I now formally close the meeting.