Skye District Salmon Fishery Board

SEPA Registry Grasser House Fodderty Way Dingwall IV15 9XB registrydingwall@sepa. org.uk

By e-mail only 24 April 2018

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

To increase biomass from 1700 tonnes to 2127 tonnes with an associated 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 problematic issues experienced by this site in the control of sea lice infestation, with the inevitable threat to wild salmon and sea trout.

The following evidence is mainly based on information gathered by the legal representative of Salmon and Trout Conservation Scotland (S&TCS) who has kindly 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 obtained after the Scottish Information Commissioner ordered that such data be released in September 2017.

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

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

2017

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

continued overleaf)

There is extensive literature which shows that elevated concentrations of larval sea lice may occur 30km or more away from source. Middlemas et al 2013)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 of scientific literature by Thorsad et al (2017)3 .

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

1 Middlemas et al 2013 Relationship between sea lice levels on sea trout and fish farm activity in western Scotland http:// onlinelibrary. wiley. com/ doi/ 10. 1111/ fme. 12010/ abstract 2 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 wild Atlantic salmon and sea trout https://www.salmon-trout.org/wp- content/ uploads/ 2017/ 12/Thorstad- Finstad- 2017- Summary- of-impacts- of-salmon- lice.pdf

Convener; Derek Dowsett, The Hatchery,Skeabost Bridge, Isle of Skye, IV51 9NP Telephone; 01470 532297 e-mail: dowsettderek652@gmail. com Vice-Convener; Donald Matheson, The Pier Hotel, Portree, Isle of Skye IV51 9DE Telephone; 01478 612094 e-mail enquiries@pier- hotel.co.uk Clerk, Jim Rennie; Ardslane, 1 Clachamish, Skeabost Bridge, Isle of Skye, IV51 9NY Telephone; 01470 582 257 e-mail [email protected] A report provided by the Scottish Association for Marine Science to The Environmental, Climate Change and Land Reform Committee at the Scottish Government this year has concluded that “the main treatment methods used in Scotland are experiencing reduced efficacy in dealing with sea lice on farms. New techniques are being applied, although the long -term success of these is uncertain. The legislative and voluntary frameworks that underpin the management of lice levels on farms are not transparent. They appear neither to be succeeding in controlling sea lice, nor capable of addressing the environmental effects of the lice.”

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

January 2016 - H202/site March 2016 - slice/site End July into August 2016 - Salmosan/site August 2016 - Salmosan/ site End September into October 2016 - H202/site November 2016 - Salmosan/H202 site January 2017 cages 2/4/8 -AMX/Salmosan February 2017 cages 1/3/5/7/9 - Salmosan February 2017 Slice - cage 9 feed used up from Corlarich February 2017 - cage 2 Salmosan March 2017 - Salmosan/H202 (cages 3 and 5) rest salmosan only April 2017 - Salmosan/H202 - cages 7 & 9 April 2017 - Salmosan cages 4/5/1 May 2017 - Salmosan/ H202/site

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

SAMS concluded that “the evidence indicates a wide scale cumulative impact and incomplete 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 with substantial, wide scale reductions in both the richness and abundance of non-target crustacea. Given the findings in this report we believe there is an urgent requirement Convener; Derek Dowsett, The Hatchery,Skeabost Bridge, Isle of Skye, IV51 9NP Telephone; 01470 532297 e-mail: dowsettderek652@gmail. com Vice-Convener; Donald Matheson, The Pier Hotel, Portree, Isle of Skye IV51 9DE Telephone; 01478 612094 e-mail enquiries@pier- hotel.co.uk Clerk, Jim Rennie; Ardslane, 1 Clachamish, Skeabost Bridge, Isle of Skye, IV51 9NY Telephone; 01470 582 257 e-mail [email protected] to… consider the likely ecosystem consequences of large scale reductions in crustacean 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 infestation thus threatening the wild stocks of salmon and sea trout over a large area the SDSFB considers it inconceivable that authorisation for a change in cage size, location and configuration in order to increase biomass, (and the consequent increase in the use of therapeutants) should be considered.

Yours Sincerely

Convenor Skye District Salmon Fishery Board.

onvener; Derek Dowsett, The Hatchery,Skeabost Bridge, Isle of Skye, IV51 9NP Telephone; 01470 532297 e-mail: dowsettderek652@gmail. com Vice-Convener; Donald Matheson, The Pier Hotel, Portree, Isle of Skye IV51 9DE Telephone; 01478 612094 e-mail enquiries@pier- hotel.co.uk Clerk, Jim Rennie; Ardslane, 1 Clachamish, Skeabost Bridge, Isle of Skye, IV51 9NY Telephone; 01470 582 257 e-mail [email protected]