Skye District Salmon Fishery Board · farmers to develop site specific escalation action plans to be implemented when sea lice levels rise above 3.0 average female lice per farmed

Convener; Derek Dowsett, The Hatchery,Skeabost Bridge, Isle of Skye, IV51 9NPTelephone; 01470 532297 e-mail: dowsettderek652@gmail. com

Vice-Convener; Donald Matheson, The Pier Hotel, Portree, Isle of Skye IV51 9DETelephone; 01478 612094 e-mail [email protected]

Clerk, Jim Rennie; Ardslane, 1 Clachamish, Skeabost Bridge, Isle of Skye, IV51 9NYTelephone; 01470 582 257 e-mail [email protected]

Skye District Salmon Fishery Board

SEPA RegistryGrasser HouseFodderty WayDingwall IV15 9XB

registrydingwall@sepa. org.uk

By e-mail only 24 April 2018

Ref: Application CAR/L/1002991Leinish Bay Marine Cage Fish Farm, Loch Dunvegan, Skye

To increase biomass from 1700 tonnes to 2127 tonnes with anassociated increase in the use of sea lice therapeutants.

Thank you for consulting the SDSFB regarding the above application.

The SDSFB objects to this application.

The objection is largely focused on the historic and current highly problematicissues experienced by this site in the control of sea lice infestation, with theinevitable threat to wild salmon and sea trout.

The following evidence is mainly based on information gathered by the legalrepresentative of Salmon and Trout Conservation Scotland (S&TCS) who haskindly consented to the use of any the evidence by the SDSFB in this letter.

It should be explained that the data requested by the S&TCS was obtainedafter the Scottish Information Commissioner ordered that such data bereleased in September 2017.

The Fish Health Inspectorate implements the Scottish Government’s new sealice management policy for Scottish salmon farming. It requires all salmonfarmers to develop site specific escalation action plans to be implementedwhen sea lice levels rise above 3.0 average female lice per farmed fish. Whenlevels exceeded 8.0 average female adult lice, the new policy was to result inenforcement action by Marine Scotland, including the potential to requirereduction in biomass. This new policy was outlined to NASCO in June 2016.

SEPANET\mandy.frasermailto:[email protected]







FHI data has confirmed that, in 2016/2017, the Leinish Bay fish farmbreached the new 3 adult female lice per farmed fish trigger level for 24consecutive weeks in 2016 into 2017, and then for a further period of 4 moreweeks, exceeding 8 adult female lice on at least 5 separate occasions:

2016Week 44 2.45Week 45 11.02Week 46 no dataWeek 47 5.73Week 48 7.4Week 49 no dataWeek 50 10Week 51 no countWeek 52 8.56

2017

Week 1 7.07Week 2 6.04Week 3 5.36Week 4 no dataWeek 5 6.8Week 6 no dataWeek 7 3.93Week 8 11.82Week 9 6.85Week 10 6.74Week 11 no dataWeek 12 6.65Week 13 14.6Week 14 no countWeek 15 6.27Week 16 6.4Week 17 10.4Week 18 no countWeek 19 6.26Week 20 3.1Week 21 HARVESTING

continued overleaf)







It is clear to the SDSFB that the continued proliferation of sea lice populationsat this site has proved historically to be problematic to the operators, to saythe very least, and is very likely to have heavily affected sea trout and salmonpopulations in the near vicinity as well as greater distances from the site.

There is extensive literature which shows that elevated concentrations oflarval sea lice may occur 30km or more away from source. Middlemas et al2013)1 and Johnson et al (2016)2 show that larval lice can be transported for

up to 45km from source. More information can be found in a recent review ofscientific literature by Thorsad et al (2017)3 .

This being the case, and considering the heavy lice burdens at the site thathave already been reported in preceding paragraphs, local sea troutpopulations and migrating salmon along the shoreline of Loch Dunvegan andthe coastline of NW Skye face infestation. In addition, wild sea trout andsalmon native to the river Hamera, only 17 kilometres from the applicant’ssite, are also likely to be put under undue pressure.

1 Middlemas et al 2013 Relationship between sea lice levels on sea trout and fish farmactivity in western Scotland http:// onlinelibrary. wiley. com/ doi/ 10.1111/ fme. 12010/ abstract2 See Johnsen et al 2016 Salmon lice dispersion in a northern Norwegian fjord system and the impact

of vertical movements http:// www. int-res. com/ abstracts/ aei/ v8/ p99- 116/ 3 Thorstad et al 2017 Impacts of salmon lice emanating from salmon farms on wildAtlantic salmon and sea trout https://www.salmon-trout.org/wp-content/ uploads/ 2017/ 12/Thorstad- Finstad- 2017- Summary- of-impacts- of-salmon-lice.pdf

SEPANET\mandy.fraserhttps://www.salmon-trout.org/wp-content/uploads/2017/12/Thorstad-Finstad-2017-Summary-of-impacts-of-salmon-lice.pdf


SEPANET\mandy.fraserhttp://www.int-res.com/abstracts/aei/v8/p99-116/

SEPANET\mandy.fraserhttp://onlinelibrary.wiley.com/doi/10.1111/fme.12010/abstract








A report provided by the Scottish Association for Marine Science to TheEnvironmental, Climate Change and Land Reform Committee at the ScottishGovernment this year has concluded that “the main treatment methods usedin Scotland are experiencing reduced efficacy in dealing with sea lice onfarms. New techniques are being applied, although the long -term success ofthese is uncertain. The legislative and voluntary frameworks that underpin themanagement of lice levels on farms are not transparent. They appear neitherto be succeeding in controlling sea lice, nor capable of addressing theenvironmental effects of the lice.”

The SDSFB is also concerned that the frequency of use of therapeutants atthe site appears not to be controlling sea lice burdens with the currentpermitted biomass. The Fish Health Inspectorate published details of thetreatment regime at this site, an extract of which appears below.

January 2016 - H202/siteMarch 2016 - slice/siteEnd July into August 2016 - Salmosan/siteAugust 2016 - Salmosan/siteEnd September into October 2016 - H202/siteNovember 2016 - Salmosan/H202 siteJanuary 2017 cages 2/4/8 -AMX/SalmosanFebruary 2017 cages 1/3/5/7/9 - SalmosanFebruary 2017 Slice - cage 9 feed used up from CorlarichFebruary 2017 - cage 2 SalmosanMarch 2017 - Salmosan/H202 (cages 3 and 5) rest salmosan onlyApril 2017 - Salmosan/H202 - cages 7 & 9April 2017 - Salmosan cages 4/5/1May 2017 - Salmosan/H202/site

In 2016 the research carried out by the Scottish Association for MarineScience had shown that the negative effects of the use of emamectinbenzoate (SLICE) has been underestimated and that cage edge and far-fieldEQS values are not sufficiently protective of crustaceans in the wider marineenvironment. The report raised serious concerns that residues of Slice, excreted by farmed fish and spread into the wider sea loch environment, havehad a far greater impact on wild crustaceans than was predicted when Slicewas first licenced.

SAMS concluded that “the evidence indicates a wide scale cumulative impact andincomplete recovery between successive emamectin benzoate treatments…..”, the ecosystem consequences of the observed reduction in crustacea are not known,

but crustacea include important fishery species such as crabs and lobsters…” the evidence suggests that benthic crustacean may not be adequately protected by

the current regulation of EMB use in Scottish salmon farms”. our results indicate that, even allowing for regional differences in the physical

properties of the receiving environment, the use of EMB is associated withsubstantial, wide scale reductions in both the richness and abundance of non-targetcrustacea. Given the findings in this report we believe there is an urgent requirement




onvener; Derek Dowsett, The Hatchery,Skeabost Bridge, Isle of Skye, IV51 9NPTelephone; 01470 532297 e-mail: dowsettderek652@gmail. com



to… consider the likely ecosystem consequences of large scale reductions incrustacean richness and abundance at the scale of sea lochs”.

Small crustaceans are important prey species, forming part of the diet of sea trout.

While this site continues to experience such excessive sea-lice infestationthus threatening the wild stocks of salmon and sea trout over a large area theSDSFB considers it inconceivable that authorisation for a change in cagesize, location and configuration in order to increase biomass, (and theconsequent increase in the use of therapeutants) should be considered.

Yours Sincerely

ConvenorSkye District Salmon Fishery Board.




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Skye District Salmon Fishery Board · farmers to develop site specific escalation action plans to be implemented when sea lice levels rise above 3.0 average female lice per farmed