Salmon & Trout Association confronts distortions in new evidence to committee on Aquaculture and Fisheries Bill

Guy Linley-Adams,  who is a solicitor and a member of the Salmon & Trout Association Scotland, has submitted supplementary written evidence on behalf of the Association to the Rural Affairs and Climate Change Committee [RACCE].

The committee is in the process on consulting on the Aquaculture and Fisheries [Scotland] Bill.

In this evidence, Mr Linley-Adams, the subject of a crude smear attempt in the Scottish Salmon Producers’ Organisation’s evidence to RACCE, confronts directly some core manipulations in that evidence.

The Salmon & Trout Association Scotland’s supplementary evidence

In its supplementary written evidence to the Committee, the Scottish Salmon Producers Organisation refers to the campaign run by the Salmon & Trout Association and names me as heading that campaign.

The SSPO describes how, in its view:

‘these campaigns have showered the Scottish Government regulatory agencies with demands for information under FOI or EIR followed by press releases which attempt to erode retailer and consumer confidence in aquaculture and impugn the reputation of individual farming companies’.

The SSPO continues:

‘we have concerns that the lobbying and campaigning is aimed to undermine the role and authority of the Scottish Government and Scottish regulatory agencies…..’

As a solicitor regulated by the Law Society for Scotland and acting for a Scottish registered charity, the Salmon & Trout Association, I would like to reassure the Committee that any requests for information made by me to departments of Scottish Government or Scottish statutory agencies are made pursuant to the EU Directive on Public Access to Environmental Information as enacted in Scots law by the Environmental Information (Scotland) Regulations 2004.

Public access to information – subject to legitimate exceptions -  is almost universally seen as being in the public interest.

The Scottish Information Commissioner has described how:

‘freedom of information is essential for all of us if our public authorities including our government are to be open and accountable to all the people they serve’.

A MORI poll survey conducted by the Scottish Information Commissioner in 2011 showed that 91% of the Scottish public view freedom of information as an important way to hold public bodies to account for their spending decisions and over 80% wanted freedom of information extended to cover other bodies that provide public services.

All Scottish public authorities and departments of Scottish Government to which requests have been made pursuant to Scots law on freedom of information have, without exception, been very helpful and prompt in dealing with the requests made by me on behalf of the Salmon & Trout Association Scotland.

These bodies include Marine Scotland Science, the Scottish Environment Protection Agency, the Crown Estate, Scottish Natural Heritage and relevant local authorities’ planning departments on the west coast and in the islands and the Salmon & Trout Association Scotland is grateful to the efforts their respective staff make in response to the requests made.

The suggestion by the SSPO that the Salmon & Trout Association Scotland’s use of freedom of information requests and campaigning is aimed at undermining the role and authority of the Scottish Government and Scottish regulatory agencies is nonsense.

On the contrary, the aim of most similar campaigns run by environmental or conservation NGOs, including that being run by the Salmon & Trout Association Scotland here, is to strengthen the hand of regulatory authorities in their control and oversight of environmental impacts by whichever sector is involved.[Ed: we read this passage as a discreet expression of concern that the regulatory authorities are under pressure to operate with the infamous 'regulation with a light touch' that brought the UK's financial institutions to collapse and discredit.]

By way of comparison – and when considering what, if anything, is aimed at undermining the role and authority of the Scottish Government and Scottish regulatory agencies -  the Committee should be reminded of the SSPO’s own view of Marine Scotland from the SSPO’s response to the Scottish Government’s pre-Bill consultation,

‘the consultation presents an image of Marine Scotland as totalitarian in approach and hostile to business….’

‘Marine Scotland is widely regarded as narrowly focussed, bureaucratic, lacking in clear sense of its wider purpose and under-performing in respect of its stated remit’.

The Salmon & Trout Association Scotland and many other bodies believe – and the flow of fisheries science supports this – that in certain circumstances and in certain locations on the west coast and in western isles, open-cage salmon farming can and does have a significant negative impact upon wild fish populations and wild fish conservation.

The campaign run by the Salmon & Trout Association Scotland, drawing on information obtained pursuant to legal rights given to the public by the Aarhus Convention and the EU Directive, is aimed at promulgating that message.

The Salmon & Trout Association Scotland is grateful to the Committee for accepting both written and oral evidence on this subject.

Guy Linley-Adams, 7th January 2013.

  • Scottish Information Commissioner (2013) ‘Your Right To Know – a guide to freedom of information law in Scotland
  • Scottish Information Commissioner (2011) Press Release 16th December 2011
  • SSPO (2012) Aquaculture and Fisheries Bill Consultation Response 2-3-12.
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16 Responses to Salmon & Trout Association confronts distortions in new evidence to committee on Aquaculture and Fisheries Bill

  1. The good old Salmon and Trout Association eh? Nothing but the best interests of the salmon at heart.

    Never mind the fact that 100,000 of the dear things are slaughtered by anglers each year (in the most cruel of fashions), and that these come out of the less than 5% that actually make it back to the rivers to spawn (or not quite make it as is generally the case). Destroying vast numbers of breeding stock surely can’t have any impact on overall numbers can it (said in a plummy accent)?

    Bear baiting was banned two centuries ago, England and Wales had the wit to ban foxhunting a decade ago, so why do we allow this barbaric bloodsport to continue?

    And why do we allow the tweed-clad defenders of this unspeakable cruelty to attack an economically valuable, and entirely lawful, industry?

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  2. Franke-salmon should be banned as they contain the most toxic chemicals known to human life…FWIW The Salmon industry creates few jobs mostly with the poorest pay and conditions for its workers..why should we welcome such a nightmare on our shores…

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      • Ten years ago, Argyll & Bute Council published a document on aquaculture in Argyll which contained the following statement: “The total aquaculture related employment in Argyll and Bute is approximately 2000 and the economic impact of the industry amounts to over 10% of the area’s total GDP.”

        I don’t know whether these statistics have changed significantly since that report was published. However, it is obvious that fish farming does employ significant numbers of people both directly and indirectly; that these jobs are generally year-round and permanent; and that a high proportion of them are in rural communities in which opportunities for such employment are extremely thin on the ground.

        This is not to excuse bad environmental practices, but does suggest that to deny the local economic importance of the salmon industry as part of your argument is not likely to engender much credibility.

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  3. It is a shame that Mel Gibson does not the trouble to check the facts before posting.

    According to the official statistics on salmon catches, the figures are:

    1)For 2011, the rod catch was 87,915 of which 63,810 (73%)were released back into the water and 24,105 were retained.

    2)For 2010, the rod catch was 110,496 of which 77,784 (70%) were released back into the water and 32,712 were retained.

    So where does the nonsense “100,000 of the dear things are slaughtered by anglers each year” come from?!

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    • Newsroom’s comment- ha ha ha, pot calling kettle etc! My comment was actually meant for Angus File’s post anyway, because he was a little light on detail as to “the most toxic chemicals known to man”, and the slur on the employment, both direct and indirect, arising from aquaculture.

      As for Angus Pirie: your own figures show an average 99,206 fish a year caught on rod and line (I’m sorry for inflating the figure to 100,000). So some of them get put back- how many of those actually survive the trauma and physical assualt do you imagine?

      Take a sharp hook, attach a long length of string to it and tie the other end of the string to a long stick. Place a sausage over the hook and dangle above the pavement until a dog comes along and grabs it.

      Next, pull on the string while the dog frantically wrestles, twists and turns and runs one way then the other desperate to get away from the hook embedded in its jaw. Eventually the dog will tire and you can drag it across the ground with scant regard for its wellbeing.

      Finally, hold the dog underwater so it can’t breathe while you tear the hook out of its jaw, take a couple of photos and perhaps even weigh it, and then let it go (hoping it will survive, but really, it’s quite unlikely). Alternatively, just knock it on the head as it would probably die anyway after such abuse.

      Any reader consider this acceptable? Anyone remotely bothered that this is happening on every salmon river in Scotland, not on dogs but on one of the great icons of Scotland?

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      • Dear Mel
        You ask how many salmon actually survive?

        The data from numerous studies, spanning over 30 years, shows survival rates of Atlantic salmon, when following the correct code of practise and in favourable environmental conditions, are very high, and can be 100%. Whoriskey et al (2000) held 62 angled fish, in Russia, for 24 hours to evaluate mortality rates. Only one of the 62 died during the experience, which was noted as being heavily scarred with gillnet marks. Grant (1980) conducted catch and release studies in the Grimsa River, Iceland, on 421 sea-run Atlantic salmon between 1977 and 1979. He observed no mortality, including 15% of the salmon which were angled for a second time during the experiment. In Sautso, Norway, 97% of radio tagged salmon survived hook and release, and the number of spawning redds more than doubled after the introduction of compulsory release of all angled salmon in the region in 1998 (Thorstad et al., 2002). The study concluded that hook and release fishing can be an effective management tool to enhance declining Atlantic salmon populations.

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  4. Having to use a friend’s e-mail address as my previous one seems to be being blocked- censored for voicing an opposing view!

    “The study concluded that hook and release fishing can be an effective management tool to enhance declining Atlantic salmon populations”.
    This statement is misleading. The study concluded that hook and release was better for spawning numbers than immediate slaughter. Well, of course it will be! Perhaps not catching any of them on rod and line would be a further improvement?
    The point is that slaughtering 30% of the returning spawning population is bound to have a negative effect on subsequent populations.

    It is also worth noting that not all salmon caught on rod and line are done so “when following the correct code of practise (sic) and in favourable environmental conditions”. In reality, many salmon caught by this barbaric practice suffer such physical trauma during the process that mortality rates are inevitably quite high, thus adding to the 30% willingly slaughtered. I wonder if such wanton destruction of spawning salmon, returning to the rivers after many years at sea, could possibly be a contributory factor in the declining population of wild salmon?

    And regardless of statistics, this is still a barbaric and inhumane way to treat any living animal.

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    • Whatever the problem has been with your email, we can absolutely assure you that it has not been because we have blocked it.
      Within legal necessity – which very rarely applies, as we expect and find that contributors are responsible, people are free to express their views here and any scanning of any series of comments on any story will evidence that.

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    • 30% by rod? Some years ago I got a weeks fishing on the Tay at the Isla. The river was in spate and the fish weren’t interested. At the end of the week, fearing the reaction if I returned without a fish, a visit was made to a Perth fishmonger who had the fish stacked out to his door – all legally caught by their nets at Perth.

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      • Ah, but this is a traditional way of life using skills passed down from generation to generation, and is quite a quaint image (Arran sweaters, flat caps and chubby wives waiting at home for the menfolk…), so of course has no impact on wild salmon numbers. Apart from the dead ones that is.


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        • The fish were just as dead. As far as I could tell, none had a wistful look in their eyes at their demise in a net; nor did any that, if I was so lucky, I caught with a hook.

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  5. These are daft arguments like so many around Argyll. The problem with this whole area is that there is absolutely no one in charge of it, or the bigger picture here. No senior figures are leading on any sort of environmentally sensitive philosphy or ethos. We need more discussions about plan A’s for the whole of Argyll and its Islands, not this never ending backstreet fighting over trivia and plan B’s to Z’s’. The world is at a point where stunning natural environment such as we have here is of the most sought after products on the planet, that other similar communities would simply die for. If people want to be constructive put pen to paper and lobby MSP’s and Councilors about creating the right protection and promotion for it.

    The reality is that salmon farming is getting out of control and damaging the natural environment and there is masses of stuff out there saying so. There are far better and more environmentally sensitive ways of going forward when we have the green product that the entire world wants to enjoy, without filling lochs with more and more fish farms. The government have always seen this area as good dumping ground for some of its more base ideas and endless fish farming approvals are a symptom of that, like blanket afforestion with none native species and large wind turbines.

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    • At the moment, the ‘product that the entire world wants to enjoy’ seems to be Scottish salmon – front page news in the Oban Times last week says exports to the far east have increased by a factor of 12 in the last three years.

      What we need in Argyll is a diversified economy – not one that is unduly reliant on any one sector. Tourism, farming, fish farming, forestry, renewable energy… all these and more can co-exist if all are prepared to compromise and accept that a diverse economy is in everyone’s interests in the long term, and that there is no such thing as an industry without environmental impact.

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