THE CONTROL OF SEA LICE ON FISH FARMS IN SCOTLAND

2013-2015

A REPORT

FOR

SALMON AND TROUT CONSERVATION SCOTLAND

DECEMBER 2015

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EXECUTIVE SUMMARY Fisheries scientists are increasingly firm in their conclusions that sea lice produced on fish-farms harm wild salmonids, both at an individual and at a population level, making the proper control of sea-lice on fish-farms essential to protect wild fish. Although analysis of control of sea-lice on Scottish fish-farms is severely hampered by the lack of farm-specific sea lice data, publicly available data for 2013 to 2015 shows that the number of Scottish fish-farming regions failing to keep adult female sea lice numbers below the CoGP threshold is on an upward trend. The industry-wide problem with sea lice is increasing and is certainly not under control. The proportion of the total Scottish farms salmon production exceeding CoGP thresholds shows a similar upward trend, with regions representing 60% of Scottish production being over the CoGP threshold of 0.5 adult female lice per fish in May 2015, at the peak of the wild smolt run. There is strong evidence that sea lice numbers on fish farms rise during the second year of production and, in much of Scotland, average adult female sea lice numbers per farmed fish appear to be linked to the cumulative biomass of farmed fish held on the farms. There is evidence of the considerable failure in some regions of available chemical sea lice treatments to limit sea lice numbers on farmed fish to below CoGP thresholds, strongly suggesting that resistance and tolerance to these treatments is becoming widespread. A number of regions appear to have experienced sea lice numbers persistently above CoGP thresholds, despite the use of wrasse as cleaner fish on some farms. There is some evidence of a failure by some operators to treat for sea lice on farmed fish despite sea lice numbers being over CoGP thresholds, contrary to CoGP requirements, and of the failure by fish-farmers to treat sea lice near the end of production cycles, both suggesting that little consideration is being given to the consequent negative effects on wild salmonids. Where there is evidence of early harvest or culling out of farmed fish, this appears only to be associated with unacceptable damage being caused to the farmed fish, causing either commercial losses or animal welfare issues for the farmed fish, rather than this occurring in order to protect wild fish. Action by Scottish Government is required urgently to address the sea lice issue as it affects wild fish. The major barrier to proper scrutiny of the fish farms - the lack of published farm-specific sea lice data - needs to be removed and further information concerning newer control methods for sea lice should be recorded and published to ensure that a complete picture is obtained of the sea lice control methods used. The voluntary CoGP should be made a statutory code, as provided for in the 2007 Act, and an upper tier sea lice threshold should be introduced, above which an immediate cull or harvest of farmed fish is mandated. It should not be possible for fish-farmers, where sea lice numbers have effectively gone out of control on their farms, to assert that they remain in compliance with the CoGP merely because they have instigated treatment, regardless of its efficacy in reducing lice numbers.

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The Scottish Government should amend legislation with the express purpose of protecting wild fish from potential damage caused by fish-farms, with inspectors given a legal duty to control sea lice on fish-farms expressly in order to protect wild fish populations. Those farms consistently failing to control sea lice should be identified for closure and / or relocation. In parallel, Scottish Government should focus on alternative more sustainable production methods with the ultimate objective of moving to full closed containment of farmed salmon production in Scotland to eliminate the biological interaction between farmed and wild fish.

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Contents

Page

1. The threat to wild salmonids from sea lice emanating from fish-farms 4

2. Sea lice controls on fish-farms – legal and voluntary 8

3. How do fish-farms seek to control and treat sea lice? 10

4. Available data on sea lice on Scottish fish-farms between 2013 and 2015 12

5. Analysis of sea lice control on Scottish salmon farms 2014 to 2015 14

5.1 Inchard to Kirkaig North 16

5.2 Badachro to Applecross 18

5.3 Loch Long and Croe 21

5.4 Fyne 23

5.5 Isle of Lewis West 26

5.6 Harris 29

5.7 The Uists North 32

5.8 The Uists South 34

6. Discussion and conclusions 38

7. Recommendations 40

Annexes 42

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1. The threat to wild salmonids from sea lice emanating from fish-farms Over many years, there has been considerable debate over the magnitude of the negative effects of sea lice, produced by salmon farms, upon wild salmonids. Despite this, the marine-cage salmon farming industry has accepted, for at least a decade, that the control of gravid adult female sea lice on farmed fish within salmon farms is essential, at least in part to minimise the impact of sea lice on wild salmonids. For example, the Strategic Framework for Scottish Aquaculture produced by the Scottish Executive in 2003, identified sea lice infestation as a significant factor which could impact upon the future sustainability of both aquaculture and wild fisheries. As Figure 1 shows, sea lice have both a free-swimming and a fixed parasitic stage in their life cycle. As they grow throughout these stages, they continue to molt.

While salmon farming is conducted in the open sea, with fish held in nets suspended from floating cages, the risk to wild fish from large numbers of juvenile lice leaving the farms will remain. The sea lice life cycle comprises many stages, but during its planktonic stages, juvenile sea lice can be dispersed very long distances. Indeed, modelling scenarios suggest that sea lice can be dispersed up to 30km from fish-farms1. In effect, this means that the majority of the coastal waters of the west coast and western isles of Scotland - and the wild salmonids populations they contain - are potentially affected by sea lice emanating from Scottish salmon farms. An average sized salmon-farm can hold over half a million farmed fish. Even if just a single adult female louse is present on each fish, this would constitute an enormous production of juvenile sea lice. An adult female louse produces a pair of egg strings about every 20 days depending on temperature (and produces several pairs over its lifetime) with about 150 eggs on each string. This would mean roughly 150 million juvenile lice being released every 20 days by the adult female lice from such a farm of half a million fish.

1 NKG Salama, CM Collins, JG Fraser, J Dunn, CC Pert, AG Murray and B Rabe (2012)

Development and assessment of a biophysical dispersal model for sea lice Journal of Fish Diseases Special Issue: Papers from the 9th International Sea Lice Conference Bergen, 20–23rd May 2012 Volume 36, Issue 3, pages 323–337, March 2013

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If, as has been seen in 2013 to 2015, fish-farming regions on the Scottish west coast are consistently over CoGP thresholds for a whole year, this implies the production of tens, even hundreds of billions of mobile free-swimming stage lice. A report for the Norwegian Institute for Nature Research, Norway’s leading institution for applied ecological research, summarises the threat this poses to wild salmonids: “When large numbers of farmed salmon are introduced to the marine environment in open net cage salmon farms, three things are virtually inevitable for these fish. They will become hosts to sea lice since these occur naturally on wild host species in the

vicinity of most farms; they will become part of a dynamic host‐parasite system

involving wild hosts, because they can produce large numbers of infective larvae in a restricted spatial area if gravid females are allowed to develop; and because they carry sea lice, and because some of these fish may escape from the farms, the dispersal of parasites is likely to be even more widespread on occasion. Given the above, it may be concluded that it is next to impossible to (1) avoid infection of farmed fish, all of which go into the pens as clean smolts, and (2) also subsequently avoid infection of wild fish that are found in the vicinity (“infective field”) of an open cage farm2.” While adult wild salmon are perfectly adapted to coping with a few sea lice, and background levels of these parasites occur naturally in the sea, the negative impact of too many sea lice on wild salmonids (salmon and sea trout) is now widely accepted by fisheries scientists including the Scottish Government’s own Marine Scotland Science (MSS)3. A burden in excess of 13 pre-adult sea lice is known to compromise severely the survival of juvenile migratory salmonids. Sea lice feed by grazing on the surface of the fish and eating the mucous and skin and so large numbers of sea lice soon cause the loss of fins, severe scarring, secondary infections and, in time, death. Sea trout, which tend to remain in coastal waters, can pick up huge burdens of sea lice near salmon farms. As well as causing premature mortality, infestation at sub-lethal levels can trigger early returning behaviour in sea trout, with the fish moving back into freshwater prematurely, to rid themselves of sea lice. There has been much debate about whether any of this matters to wild salmon and sea-trout at a population level, but the impact at that level is now becoming much clearer. Research published in 2013 by a group of fisheries experts from Norway, Canada and Scotland re-analysing data from various Irish studies, showed that the impact of sea lice on wild salmon causes a very high loss (34%) of those returning to Irish rivers4.

2Revie C, Dill L, Finstad B & Todd C D (2009) Sea Lice Working Group Report. ‐ NINA Special Report 39. 117 pp.

http://www.nina.no/archive/nina/pppbasepdf/temahefte/039.pdf 3 Marine Scotland Science (2013) Summary of information relating to impacts of sea lice from fish farms on Scottish

sea trout and salmon - 4th April 2013 – see www.standupforwildsalmon.org

4 M Krkosek, C W Revie, B Finstad and C D Todd (2013) Comment on Jackson et al. "Impact of Lepeophtheirus

salmonis infestations on migrating Atlantic salmon, Salmo salar L., smolts at eight locations in Ireland with an analysis of lice-induced marine mortality" - Journal of Fish Diseases

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There is also clear evidence that both wild salmon and sea trout are in decline in Scotland’s ‘aquaculture zone’, whereas, generally, populations have stabilized on the east and north coast where there is no fish-farming. After examining east and west coast catch trends, fisheries scientists from the Rivers and Fisheries Trusts of Scotland (RAFTS) concluded that: “there is a clear trend of declining salmon catches, compared with catches on the East coast, in areas where the Scottish aquaculture industry operates. The assertion by SSPO [the Scottish Salmon Producers’ Organisation] that ‘the catch statistics show salmon farming has had no effect on wild salmon catches’ does not stand up to scrutiny. It is also apparent that the decline is greater for those areas whose juvenile fish have to swim past larger number of salmon farms in order to reach the open ocean”5. Fisheries scientists from Norway, Scotland and Ireland reviewed over 300 scientific publications on the damaging effects of sea lice on sea trout stocks in salmon farming areas, and examined the effect of sea lice on salmon, concluding that sea lice have a potential significant and detrimental effect on marine survival of Atlantic salmon with potentially 12-29% fewer salmon spawning in salmon farming areas6. The researchers concluded that: “Salmon lice in intensively farmed areas have negatively impacted wild sea trout populations by reducing growth and increasing marine mortality. Quantification of these impacts remains a challenge, although population-level effects have been quantified in Atlantic salmon by comparing the survival of chemically protected fish with control groups, which are relevant also for sea trout. Mortality attributable to salmon lice can lead to an average of 12−29% fewer salmon spawners. Reduced growth and increased mortality will reduce the benefits of marine migration for sea trout, and may also result in selection against anadromy in areas with high lice levels. Salmon lice-induced effects on sea trout populations may also extend to altered genetic composition and reduced diversity, and possibly to the local loss of sea trout, and establishment of exclusively freshwater resident populations.” In 2015, the Scottish Government published its latest classification of the country’s salmon rivers’ salmon populations. This places all the rivers in the west Highlands and inner Hebrides, including river systems such as the Awe and the Lochy, in the worst-performing category, with wild salmon stocks not reaching their conservation limits, which are a measure of the overall health of the population. No river within salmon farming’s heartland of the west Highlands and inner Hebrides has, according to the Scottish Government’s own scientists, a sufficient stock of wild salmon for any exploitation to be sustainable. Figure 2 below shows the outcome of the assessment procedure with categories based upon probability of a district or SAC meeting its Conservation Limit determined using the best available information on salmon stocks.

5 See RAFTS paper at http://www.rafts.org.uk/wp-content/uploads/2011/10/East-v-West-final-RWB.pdf

6 Thorstad , E , Todd , C D , Uglem , I , Bjorn , P A , Gargan , P , Vollset , K , Halttunen , E , Kalas , S , Berg , M &

Finstad , B 2015 , ' Effects of salmon lice Lepeophtheirus salmonis on wild sea trout Salmo trutta – a literature review ' Aquaculture Environment Interactions , vol 7 , no. 2 , pp. 91-113 . (See https://research-repository.st-andrews.ac.uk/handle/10023/7295)

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The contrast between western Scotland and the rest of the country is stark, with the major or substantive distinction between east and west coast being the presence of salmon farming in the west. The map at Figure 2 shows that the extent of west Highland rivers where wild salmon populations are in very poor health (category 3 are shown in brown) closely matches the extent of the salmon farming industry (the current active marine salmon farming sites are marked in red). It is noteworthy that the Grudie / Dionard rivers, the most westerly rivers on the north coast, are designated category 1. Migrating salmon smolts (juvenile salmon) from these rivers are able to head north into the open sea without passing any salmon farms. In contrast, all the neighbouring west-flowing rivers - where the smolts must navigate past salmon farms - are designated category 3. The great majority of Scottish rivers to the south of the west Highlands – for example in Ayrshire and the Solway – are also category 3. Salmon smolts from these rivers migrate north through the main salmon-farming regions, rendering them liable to sea lice infestations.

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2. Sea lice controls on fish-farms – legal and voluntary Given the sea lice threat to wild salmonids posed by marine cage fish farms, it is highly regrettable that most EU, UK and Scottish legislation, including the Animal Health and Welfare (Scotland) Act (2006) and the Aquaculture and Fisheries (Scotland) Acts (2007 and 2013), is focussed on the health and welfare needs of the farmed fish, rather than their wild counterparts. Although fish health inspectors have inspection powers under the 2007 Act, the detail of sea lice control, as practiced on Scottish salmon farms, is set out in the Code of Practice for Scottish Finfish Aquaculture (the CoGP), which is a voluntary code without statutory backing. With reference to wild salmonids, the National Treatment Strategy (NTS) for the Control of Sea Lice on Scottish Salmon Farms, which forms part of the CoGP, includes “recognition by the industry of the importance of minimising ovigerous lice at times of the year critical for wild salmonid populations”. The NTS sets, as a primary objective of the strategy, a target of zero adult female lice on the farmed fish in the spring period when wild salmonids are migrating. The North Atlantic Salmon Conservation Organisation (NASCO) Best Management Practice Guidance also requires “100% of farms to have effective sea lice management such that there is no increase in sea lice loads or lice-induced mortality of wild salmonids attributable to the farms”7.NASCO also sets a target of zero ovigerous lice on all salmon farms. The SSPO also acknowledges that the purpose of treatment is “to prevent lice from reproducing. It is good farming practice and common sense to target and kill female lice before they reach the stage where they are able to reproduce. Indeed the main focus of the National Treatment Strategy is to control sea lice by targeting them before they reproduce. By closely monitoring the numbers of lice on their fish, farmers are able to intervene and treat fish before female lice produce viable egg strings. Both the NTS and the Code of Good Practice suggest treatment thresholds for the application of medicines to achieve this. The suggested thresholds are 0.5 adult female lice (Lepeoptherius salmonis) per fish between February and June and 1.0 adult female lice (L. salmonis) per fish between July and January”8. The aim of the reduced threshold for treatment during February to June inclusive is that this is the period within which the great majority of wild salmon and sea trout smolts are emigrating to sea and hence are at their most vulnerable to sea lice infestation from fish-farms. However, these variable thresholds in the CoGP do not take into account the presence of sea trout in coastal waters all year round. While the thresholds within the CoGP are designed to protect wild fish, the thresholds take no account of overall biomass and number of fish held on fish-farms. The larger the farm and/or the number of fish held, the greater the production of juvenile mobile stage lice will be at any given average adult female lice number. At lice levels well below the CoGP treatment thresholds but still above zero, the production of juvenile

7 NASCO (2010) Guidance on Best Management Practice to address impacts of sea lice and escaped farmed

salmon on wild salmon stocks (Adopted in June 2009, Revised in June 2010) 8 SSPO Fish Health Management Report July to September 2014

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sea lice from a salmon farm is likely to be way in excess of any local natural background production. Indeed, MSS acknowledges that compliance with the CoGP thresholds is not necessarily sufficient to ensure that juvenile sea lice emanating from the fish farms do not damage wild fish9 - “it should be noted that adherence to the suggested criteria for treatment of sea lice on individual farm sites stipulated in the industry Code of Good Practice may not necessarily prevent release of substantial numbers of lice from aquaculture installations. Additionally, it should be borne in mind that sea trout are present in these inshore waters all year, not just at the spring smolt migration therefore the control of lice build-up should be practiced throughout the year”. The CoGP remains a voluntary code, and even though the 2007 Act would allow Scottish Ministers to introduce a statutory code, the Scottish Government has not pursued that option. However, salmon farmers are required by law to monitor their fish for sea lice weekly and are regulated to this effect by the Fish Health Inspectorate (FHI) which inspects sea lice records and assesses the measures in place to prevent, control and reduce parasites on farms under the Aquaculture and Fisheries (Scotland) Act 2007 and the Fish Farming Businesses (Record Keeping) (Scotland) Order 2008. While the FHI’s formal position is that unsatisfactory control measures or records may result in a further enhanced inspection of the farm, issuing of advice and/or recommendations, or implementing enforcement action, the regulation of the Scottish salmon farming industry is largely based upon self-monitoring and self-reporting of sea lice numbers, benthic pollution and discharges. Enforcement action leading to formal proceedings is extremely rare indeed.

9 For example, see Marine Scotland’s response to the planning consultation - New Marine Finfish Farm – Atlantic

salmon - comprising 10 x 120m plastic circular cages, mooring grid and 220 tonne capacity concrete feed barge - NW Of Calaman Cave, Loch Slapin 2014

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3. How do fish-farms seek to control and treat sea lice? According to the SSPO, all Scottish fish-farms apply what are termed ‘integrated sea lice management strategies’. The SSPO state that “these strategies take a holistic approach to lice management and control, based on the use of licensed and approved medicines, single year class production, area management, synchronisation of production, and fallowing at the end of the production cycle”. While single-year class production, area management and fallowing may indeed go some way to preventing sea lice becoming a problem – to what extent is not clear - once a farm has a sea lice problem, with numbers of gravid adult female lice rising, the farms resort largely to chemical treatment to remove the lice. These are administered either as a bath or in feed treatment. Bath treatments are applied using full enclosure, in a tarpaulin, at a marine cage site, or in a well-boat adjacent to the marine cages. Bath treatments include azamethiphos (Salmosan), deltamethrin (Alphamax), cypermethrin (Excis). Emamectin benzoate (Slice) or teflubenzuron (Calicide) can be administered as in-feed treatments. Hydrogen peroxide is also used to control sea lice as well as other diseases of farmed salmon, such as Amoebic Gill Disease.

Azamethiphos is an organophosphorus pesticide, which works by interfering with the transmission of nerve impulses. It has been used in a spray form to control insects such as cockroaches and flies in buildings, warehouses and intensive farming installations10. Azamethiphos is highly toxic to birds and aquatic invertebrates and moderately toxic to fish11. Deltamethrin is a pyrethroid insecticide and is highly toxic to humans and other mammals and is a neurotoxin. It is relatively non-toxic to birds and earthworms although it presents a high risk to most aquatic organisms and honeybees12. Cypermethrin is an insecticide and is considered a serious marine pollutant. It is moderately toxic to mammals and there is some concern regarding its potential to bioaccumulate. It is highly toxic to most aquatic species and honeybees13. Emamectin benzoate is a pesticide which works by interfering with nerve impulses in the body. It is used in agricultural settings to control insects amongst vegetable crops such as cabbage and broccoli and on cotton plants. Emamectin benzoate is toxic to birds, mammals, fish and other aquatic organisms (particularly those living on the sea bed)14. Teflubenzuron is used to control a wide range of insect pests and mites in fruit, vegetable, cereal and seed crops. It works by interfering with the synthesis of insect chitin, which is essential to their growth and development. Teflubenzuron is classed as having low toxicity for mammals, fish and birds. Other aquatic organisms (particularly crustaceans and those living in sediments) may however suffer adverse effects if exposed15.

10

http://apps.sepa.org.uk/spripa/Pages/SubstanceInformation.aspx?pid=169 11

http://sitem.herts.ac.uk/aeru/ppdb/en/Reports/48.htm 12

http://sitem.herts.ac.uk/aeru/vsdb/Reports/205.htm 13

http://sitem.herts.ac.uk/aeru/ppdb/en/Reports/197.htm 14

http://apps.sepa.org.uk/spripa/Pages/SubstanceInformation.aspx?pid=171 15

http://apps.sepa.org.uk/spripa/Pages/SubstanceInformation.aspx?pid=173

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The range of sea lice medicines available to the salmon farming industry is limited, with continuous use of these chemicals likely to lead to the development of resistance and reduced efficacy16. Indeed there are increasingly strong indications that some of these medicines have become less effective and attention has focussed on finding alternative lice control methods17. Some degree of biological control, involving the use of cleaner fish, including various species of wrasse and lumpsuckers, is now being used in some farms, but with varying degrees of success.

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Treasurer J (2013) Use of wrasse in sea lice control - Project Final Report SARF068 Prepared for The Scottish Aquaculture Research Forum by Viking Fish Farms, Ardtoe Marine Laboratory 27

th

January 2013 17

Treasurer J (2013) Use of wrasse in sea lice control - Project Final Report SARF068 Prepared for The Scottish Aquaculture Research Forum by Viking Fish Farms, Ardtoe Marine Laboratory 27

th

January 2013

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4. Available data on sea lice on Scottish fish-farms between 2013 and 2015 Within the constraints of the available data published by the Scottish Government, the various statutory bodies and the industry itself, some analysis of how successful the actual control of sea lice has been in particular regions of the west coast and islands of Scotland between 2013 and 2015 is now possible. The Scotland’s Aquaculture database, launched following repeated freedom of information requests submitted under the Environment Information (Scotland) Regulations 2004 to MS, the Scottish Environment Protection Agency (SEPA) and the FHI by Salmon & Trout Conservation Scotland and others, now provides some farm-specific detailed information. Launched in October 2013, the database provides information about industry location and performance under the Controlled Activities Regulations (CAR)18 licenses issued by SEPA, including detailed information on monthly biomass on each licenced farm and the use of sea lice treatments as reported to SEPA. It also contains summary information about benthic sea-bed pollution surveys that must be conducted every two years under fish-farms and reported to SEPA by fish-farmers. At the time of publication, SEPA fish-farm biomass and chemical treatment data is only available for the period to end June 2015. However, the Scotland’s Aquaculture database does not record treatments using hydrogen peroxide, treatments conducted in well-boats, nor does it record whether wrasse or lumpsuckers may be being used as cleaner fish on any of the sites listed. The three-monthly Fish Health Management Reports, published by the SSPO since the end of 2013 provide aggregated monthly adult female sea lice data for farmed fish from 30 regions of Scotland and the Islands. Those regions can contain a single farm, such as Loch Ewe, to 44 farms, as in Shetland (East). A list of the farms located in each region, supplied by Marine Scotland is appended at Annex 1. The regional codes used by the SSPO are shown in Annex 2. At the time of publication, SSPO sea lice data is available for the period to end September 2015. Despite strong support for the publication of farm-specific sea lice data being given by all west coast local authorities, SEPA, the District Salmon Fisheries Boards, Scottish Natural Heritage (SNH) and all west coast Scottish rivers trusts, in the run-up to the Aquaculture and Fisheries Bill in 2013, the Scottish fish-farming industry still declines to publish farm-specific sea lice data and the Scottish Government has not used its powers to make that data available. Evidence given to the Rural Affairs, Climate Change and Environment Committee of the Scottish Parliament in 2013 records that effectively only the SSPO and the Scottish Government considered that aggregation of sea lice data would be sufficient. In 2013, the Minister described the decision not to require the publication of farm-specific sea lice data thus: “The Scottish Government received a commitment from the Scottish Salmon Producers’ Organisation (SSPO) for enhanced voluntary reporting of sea lice data for 30 areas based on recognised wild fish catchments. There have now been three quarterly reports published by the SSPO. Scottish Government supports these voluntary Management Reports and regards them as balanced, proportionate and helpful as regards public transparency. In addition, the SSPO agreed that they would provide Marine Scotland Science with access to sea

18

The Water Environment (Controlled Activities) (Scotland) Regulations 2011 (as amended)

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lice information at farm management area level to support defined research projects”19. The Scottish Government and its various agencies appear also to have adopted a deliberate policy of not keeping any such farm-specific sea lice data, in order to keep such data out of the reach of the public right of access to environmental information under Directive 2003/4/EC on Public Access to Environmental Information and the Environmental Information (Scotland) Regulations 2004. Farm-specific sea lice data must already be kept by the fish-farmers themselves under The Fish Farming Businesses (Record Keeping) (Scotland) Order 2008 and it would only require a very simple amendment to that Order for the Scottish Government to require that information to be submitted centrally and added to the Scotland’s Aquaculture database. In effect, the decision taken by Scottish Government in 2013 not to require publication of this data has created a barrier to proper public scrutiny of fish-farm environmental performance. As is clear, averaged or aggregated data can and does effectively disguise from scrutiny the worst-performing fish farms, a situation which the Scottish Government chose in 2013 to accept, Some further information on sea lice control is found in case reports of inspections of farms carried out by the FHI and published online20. These reports include information relating to the inspection and operational activities of the FHI, a summary of case inspections and outcomes per region, along with summary information relevant to enhanced inspections conducted under the Aquaculture and Fisheries (Scotland) Act 2007. Individual case information is also available. While these reports do not necessarily follow a strict timetable, most farms will be inspected over a two to three year period and those farms at which problems are identified may be inspected more regularly. FHI reports often reveal information of significance to the protection of wild fish from sea lice, escapes and other fish farm related threats.

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Letter from Paul Wheelhouse MSP to Rob Gibson MSP, Convenor of Rural Affairs Climate Change and Environment Committee 17

th December 2013 at

http://www.scottish.parliament.uk/S4_RuralAffairsClimateChangeandEnvironmentCommittee/General%20Documents/2013.12.17_-_Minister_sea_lice_issues_Aquaculture_and_Fisheries_(Scotland)_bill.pdf 20

At http://www.gov.scot/Topics/marine/Fish-Shellfish/FHI/CaseInformation/.

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5. Analysis of sea lice control on Scottish salmon farms 2014 to 2015 When the SSPO volunteered to extend the scope of reporting to provide more detail about sea lice numbers and control on salmon farms in 2013, the industry undertook to provide data in 30 regions, covering the west coast, western and northern isles. Figure 3 below is a simple analysis of the performance of those 30 regions between 2013-2015 as against CoGP sea lice thresholds and shows that the number of regions failing to keep adult female sea lice numbers below CoGP thresholds is growing over time, The industry-wide problem with sea lice is increasing and is certainly not under control.

Unfortunately, there is great disparity within the regions as to the number of farms and proportion of Scottish production each region represents. The number or farms per region ranges from a single active farm (eg the Ewe region) to over forty farms (eg Shetland East). However, an analysis of the proportion of the total Scottish farms salmon production as against CoGP thresholds shows a similar upward trend. Figure 4 below shows the percentage of total Scottish farmed salmon production over CoGP threshold for each month from 2013 to 2015.

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This report analyses in depth eight of these 30 regions, which appear to have had serious lice problems over the last two years, drawing on the datasets and information described above, to reach what conclusions are possible concerning the level of sea lice control being achieved in practice. The eight SSPO regions analysed below are: Inchard to Kirkaig North Badachro to Applecross Loch Long and Croe Fyne Isle of Lewis West Harris The Uists North The Uists South Collectively, these eight regions account for c.40% of the farmed production of mainland Scotland (excluding Orkney and Sheltand). For each region, the operators of the farms in the region are identified, on-farm sea lice data is analysed as against cumulative biomass of farmed-fish, across all the fish farms in each region, and where possible, conclusions are drawn as to the efficacy of sea lice treatments that have been used in the region and on specific farms. For each region, the analysis identifies whether average adult female sea lice numbers per farmed fish were over CoGP thresholds for treatment and for how long. If there is any evidence of early harvesting or culling of fish, including where sea lice numbers have been unresponsive to sea lice control used on any farm, this is highlighted, as is any additional information available in FHI inspection reports.

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5.1 Inchard to Kirkaig North The Inchard to Kirkaig North reporting region is in the north-west Highlands of Scotland, extending from Cape Wrath to Cluas Deas. The region includes sea lochs and bays that contain salmon farms, including Loch Laxford, Loch a Chairn Bhain, Badcall Bay, Eddrachillis Bay and Clashnessie Bay. SSPO reports record that from 2013 to 2015 there were on average eight active salmon farm sites in the region, all operated by Loch Duart Limited, although the Scotland’s Aquaculture database records that fish were stocked under the following licences for some period during 2013- 2015: Badcall Site 9 (North Rubha Geisgil) Badcall Site 10 (North Eilean na Bearachd) Badcall Site 11 (Eilean Riabhach) Calbha Site 5 (Calbha Beag) Clashnessie (Oldany) Drumbeg (Loch Dhrombaig) Eilean a Mhadaidh (Laxford Site 2) Eilean Ard (Laxford Site 3) Droighniche Torgawn (Loch A Chairn Bhain) Nedd Figure 5 below shows the relationship between on-farm cumulative biomass at the Loch Duart sites (per SEPA data) and regional sea lice counts reported by SSPO.

As against the CoGP thresholds for treatments, the aggregated data shows that these farms have been collectively above threshold for 31 out of the last 33 months. During that period, lice numbers rose to a peak of 9.42 adult female lice per fish in September 2013 and then again to 8.13 in March 2015. It is clear that periods of high lice counts per farmed fish coincided with high cumulative biomass on the farms, with a close correlation between rising biomass and rising average adult female sea lice counts per farmed fish. Between 2013 and

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2015, only when the biomass of farmed fish held across Loch Duart’s sites in the north Highlands dropped below a total of 600 tonnes were the CoGP’s lice thresholds achieved on a regional basis. Between January and September 2013, there were three area wide co-ordinated treatments for sea lice, although as this region covers six Farm Management Areas (FMAs), it is unclear which areas were involved. There were also 26 other ‘targeted’ treatments, usually single-farm treatments. Chemicals used across the stocked farms included between January and September 2013 included emamectin, deltamethrin, azamethiphos and cypermethrin, but this failed to keep average lice numbers from peaking at 9.42 adult female lice per fish. Following a report to the SSPCA made by a canoeist of numerous dead farmed salmon in fish-farm cages in Loch Laxford, an FHI inspection of Loch Laxford on 27th September 2013 reported that the farm had a heavy lice infestation despite using emamectin, deltamethrin and hydrogen peroxide to treat sea lice. As sea lice numbers rose above CoGP threshold between January 2014 and June 2015, peaking at 8.13 per fish, there were 34 treatments for sea lice at Loch Duart farms, including one area-wide treatment. Records published by SEPA covering the same period, showing monthly use of sea lice chemicals across each of the farms in this region, record deltamethrin use 19 times, emamectin 15 times, azamethiphos 26 times and cypermethrin use once. The FHI inspected Torgawn farm on 25th September 2014 and recorded the use of 12,500 wrasse on the farm carrying 140,000 salmon. Despite the use of wrasse, the FHI recorded that “harvest is going to be brought forward due to gill damage and lice”. Worryingly, an FHI inspection of Loch Duart’s Badcall site on 12th November 2014 records that “fish came on site with high lice load” suggesting that farmed fish with lice are being moved between fish-farms. The FHI also records that 8,212 wrasse were on site, with the farm carrying 180,000 salmon, but the presence of wrasse at Badcall does not appear to have prevented lice numbers going and staying over CoGP thresholds. The FHI recorded that the “company have reviewed cycle to harvest fish earlier”. Due to the aggregated nature of the sea lice data and the number of FMAs in this region, it is difficult to draw farm-specific conclusions, but it is clear that the widespread and regular use of the full suite of sea lice treatment chemicals, and at least some use of wrasse as cleaner fish by Loch Duart Ltd, did not prevent average adult female sea lice numbers aggregated across its farms in this region going over the CoGP threshold in 2013 and staying over that threshold for 31 out of the last 33 months to September 2015.

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5.2 Badachro to Applecross The Badachro to Applecross region is in the Wester Ross region of the Scottish Highlands, extending from North Erradale down to Applecross, encompassing Loch Gairloch and Loch Torridon. There are four active salmon farm sites in the region, operated by two companies. The Scottish Salmon Company has sites at Aird (Aird Ardheslaig), Kenmore (Loch Torridon) and Sgeir Dughall. Marine Harvest has a site at Camas an Leim (Torridon). Figure 6 below shows the relationship between on-farm cumulative biomass at the four sites (per SEPA data) and regional sea lice counts reported by SSPO.

As against the CoGP thresholds for treatments, the aggregated data shows that these farms have been collectively above threshold for 17 out of the last 32 months, including continuously from October 2014 to August 2015. During that period, lice numbers rose to a peak of 11.76 adult female lice per fish in January 2015. Again, periods of high lice counts coincided with very high biomass on the farms. During the periods of high sea lice numbers, the farms were treated with a range of sea lice chemicals. When lice levels went over threshold in May 2013, those levels did not drop back below threshold until all four farms were effectively harvested out in autumn 2013. In May to October 2013, the pattern of treatment at these four farms is shown below, with lice counts and all-farm biomass.

K’more Sgeir D’hall Torridon Aird Lice Biomass

Mar 13 - - - - 0.31 4424

Apr 13 - - delt - 0.24 4502

May 13 - delt, em delt delt, em 0.61 4630

Jun 13 - - - - 0.7 4464

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Jul 13 delt delt - delt 0.92 4858

Aug 13 azm azm delt azm 2.24 4300

Sept 13 - azm delt azm 12.1 2889

Oct 13 - azm, delt - azm, delt 5.18 1024

[delt = deltamethrin (Alphamax), em = emamectin benzoate (Slice), azm = azamethiphos (Salmosan)] The SSPO Fish Health Management reports showed that between mid-January 2013 and mid-October 2013, there were no fewer than ten all-farm co-ordinated treatments for sea lice and a further nine ‘targeted’ treatments at individual farms. It appears therefore that the range of treatments deployed (emamectin, azamethiphos, deltamethrin) in 2013 across all four farms, including in area-wide co-ordinated treatments, did not prevent the average adult female lice numbers per fish rising through the year to 12.1 in September 2013. Indeed, the lice numbers only dropped as all-farm biomass started to fall during harvesting. In September 2014, on-farm sea lice levels rose again to just below CoGP threshold and went above threshold in October, increasing to a peak of 11.76 in January 2015. Levels have remained above CoGP threshold for January to August 2015.

K’more Sgeir D’hall Torridon Aird Lice Biomass

Jun 14 - em em em 0.08 771

Jul 14 - delt em delt 0.04 1161

Aug 14 - em em em 0.32 1772

Sep 14 - azm - delt 0.97 2421

Oct 14 - em em em, delt 3.66 3169

Nov 14 - - em - 7.57 3672

Dec 14 em em delt, em em 11.55 4321

Jan 15 - - azm, delt - 11.76 4794

Feb 15 - - azm, delt - 7.53 4976

Mar 15 - - azm, delt - 10.3 5017

Apr 15 - azm azm, delt - 6.02 5045

May 15 - - azm - 7.96 4815

June 15 - delt azm delt 5.41 4118

[delt = deltamethrin (Alphamax), em = emamectin benzoate (Slice), azm = azamethiphos (Salmosan)] A FHI inspection of Kenmore (Loch Torridon) on 20th November 2014 shows that the site had 4% wrasse on site (in 830,000 salmon). It is not known which other sites in this region used wrasse. As in 2013, it appears that the range of treatments deployed (emamectin, azamethiphos, deltamethrin) from June 2014 to January 2015 across all four farms - and the use of wrasse at at least one of the sites - did not prevent the average adult female lice numbers per fish rising to 11.76 in January 2015. The SSPO Fish Health Management reports showed that between mid-June 2014 and early June 2015, there were no fewer than nine all-farm co-ordinated treatments

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for sea lice and a further 20 ‘targeted’ treatments at individual farms, but this did not prevent average adult female sea lice numbers going over threshold in October 2014 and staying way over that threshold until June 2015.

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5.3 Loch Long and Croe The Loch Long and Croe reporting region extends from the Kyle of Lochalsh to Garbhan Cosach at the head of Kyle Rhea. The region includes Lochs Alsh, Long and Duich. There are three salmon farms in the region operated by Marine Harvest at Loch Alsh (Sron), Loch Duich and Ardintoul. Figure 7 below shows the relationship between on-farm cumulative biomass at the three sites (per SEPA data) and regional sea lice counts reported by SSPO over the last two years.

As against the CoGP thresholds for treatments, the aggregated data shows that these farms were collectively above the CoGP threshold for treatment for nine months, from December 2013 to September 2014 (with a slight dip to 0.96, fractionally below the threshold in February 2014). During that period, lice numbers rose to a peak of 41.7 adult female lice per fish in September 2014. The period of rising lice counts coincided with high biomass on the farms. Loch Alsh was empty of fish by June 2014 - this included the culling of all wrasse at the end of the cycle - but the other two farms were not harvested out to zero biomass until October 2014. The farms were treated on numerous occasions for sea lice, with the full range of chemicals being deployed, but without apparently achieving control of sea lice. The FHI inspected Loch Alsh on 5th December 2013 and recorded the presence of 23,000 wrasse on site, although an inspection of Loch Duich on 5th February 2014 suggested no wrasse were on site there at that stage. Key FHI inspections of Loch Duich and Ardintoul on 4th November 2014 have not yet been published (as at 1st October 2015), so it is not clear what use of wrasse if any occurred at those farms. SSPO Fish Health Management reports showed that between mid-July 2013 and mid-August 2014, there were no fewer than 11 all-farm co-ordinated treatments for sea lice and a further ten ‘targeted’ treatments at individual farms.

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Treatments Co-ordinated treatments Other targeted treatments

Jul Sept 13 2 (mid-Jul late-Sept)

Oct Dec 13 10 2 (early-Oct mid-Dec) 4

Jan Mar 14 8 2 (late-Jan late-Feb) 2

Apr Jun 14 10 3 (late-May, early- and late-Jun) 4

Jul Sep 14 4 2 (mid-Jul, mid-Aug)

Reported use of sea lice chemicals in 2013/2014 shows multiple use of sea lice treatments for many months:

Loch Duich Ardintoul Loch Alsh

Dec 2013 az, em delt, em delt

Jan 2014 delt delt delt

Feb 2014 delt, em delt, em -

Mar 2014 - delt delt

Apr 2014 delt delt -

May 2014 delt, az, em delt, az, em -

Jun 2014 delt, az, em delt, az, em -

Jul 2014 delt delt -

Aug 2014 delt delt -

Sept 2014 - - -

[delt = deltamethrin (Alphamax), em = emamectin benzoate (Slice), az = azamethiphos (Salmosan)] It appears that, by July 2014, treatments were being scaled back despite the sea lice counts on farm rising rapidly. In July and August 2014, regional lice counts (which must have been the aggregate of only two stocked farms) went to 11.94 and 17.99 adult female lice per fish respectively. By September 2014, when no SEPA-recorded treatment chemicals were used at all on any farm, the counts went to 41.7 adult female lice per fish.

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5.4 Fyne The Fyne reporting region, in the Argyll and Bute region of Scotland, includes Loch Fyne, from Skipness Point on the Kintyre Peninsula around the shoreline to Tighnabruaich. There are ten active salmon farm sites in the region, all operated by The Scottish Salmon Company in one Farm Management Area: Meall Mhor Furnace Quarry Glenan Bay Gob a Bharra Quarry Point Tarbert South Ardcastle Bay Ardgadden Rubha Stillaig Strondoir Bay Figure 8 below shows the relationship between on-farm cumulative biomass at these sites (per SEPA data) and regional sea lice counts reported by SSPO.

As against the CoGP thresholds for treatments, the aggregated data shows that these farms have been collectively above threshold for the ten months to June 2015. Adult female sea lice numbers per farmed fish began to rise in May 2014.

Treatments Co-ordinated treatments Other targeted treatments

Apr Jun 14 7

Jul Sep 14 21 2 (early-Aug, early-Sept) 1

Oct Dec 14 34 2 (late-Oct, mid-Nov) 14

Jan Mar 15 31 1 (early-Jan) 21

Apr Jun 15 10

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Chemicals used are:

Meall Mhor Furnace Qry Glenan Bay Gob a Bh’ Quarry Point

Mar 14 - - - - -

Apr 14 - - - - -

May 14 em em em em em

Jun 14 - - - - -

Jul 14 - - - - -

Aug 14 delt delt delt delt delt

Sep 14 delt delt delt delt delt

Oct 14 delt, az delt, az delt, az delt, az delt, az

Nov 14 delt delt delt delt delt

Dec 14 - az - - az

Jan 15 em, az em, az em, az em, az em, az

Feb 15 - - - - delt

Mar 15 - - - - -

Apr 15 - - - - -

May 15 - - - - -

June 15 - - - - -

Tarbert S Ardcastle Bay Ardgadden Rubha Stillaig Strondoir Bay

Mar 14 - - - - -

Apr 14 - - - - -

May 14 em em em em em

Jun 14 - - - - -

Jul 14 - - - - -

Aug 14 delt delt delt delt delt

Sep 14 delt delt delt delt, az delt

Oct 14 delt, az delt, az delt, az delt, az delt, az

Nov 14 delt delt delt delt delt

Dec 14 - az em - em

Jan 15 em, az em, az az em, az az

Feb 15 - - - - -

Mar 15 - - - - -

Apr 15 - - - - -

May 15 - - - - -

June 15 - - - - -

[delt = deltamethrin (Alphamax), em = emamectin benzoate (Slice), az = azamethiphos (Salmosan)] The FHI inspected Meall Mhor on 28th January 2015 and recorded that despite the treatments lice numbers rose in November 2014 and that current levels (peaking at 3.9 adult female lice per fish in January 2015) were not reducing below CoGP thresholds at that site. Ardcastle Bay was inspected the following day and reported a

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similar picture with treatments not bringing lice under CoGP thresholds, Ardcastle peaking at 9.57 adult female lice per fish. It is worth noting that, as elsewhere where farms have on-going sea lice control failures, both farms were recorded by FHI as satisfactory with regards to parasite control, per section 3 of the Aquaculture and Fisheries Act 2007. Most importantly, the intense use of sea lice treatment chemicals across Fyne between July 2014 and March 2015 did not control sea lice numbers, which rose over that period from almost zero adult female lice per farmed fish to a peak of 11.36 in February 2015.

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5.5 Isle of Lewis West The Isle of Lewis West reporting region, in the Western Isles of Scotland, encompasses the shoreline and lochs to the west of the Isle of Lewis, from the Butt of Lewis to Islivig. The region includes sea lochs that contain salmon farms, such as East Loch Roag and West Loch Roag. Over the period of this report there were seven active salmon farms in the region, all operated by The Scottish Salmon Company. The region contains two FMAs. Vuiabeag Taranaish Kyles of Vuia Gousam Vacasay Vuia Mor Eughlam Figure 9 below shows the relationship between on-farm cumulative biomass at these sites (per SEPA data) and regional sea lice counts reported by SSPO.

As sea lice numbers started to increase in the region from October 2013, adult female sea lice numbers on the farmed fish rose steadily, peaking at 3.47 in August 2014 only dropping below threshold as farm biomass was massively reduced across the region. Between October 2013 and September 2014, there were a total of 76 treatments for sea lice, including 13 co-ordinated area treatments:

Treatments Co-ordinated treatments Other targeted treatments

Oct Dec 13 11 3 (mid-Oct, 2 in late-Dec) 2

Jan Mar 14 21 4 (early-Jan, 3 in March) 6

Apr Jun 14 27 5 (2 in late-Apr, 3 in Jun) 10

Jul Sep 14 17 1 (mid-Jul) 14

27

Oct Dec 14 0 0 1

Jan Mar 15 0 0 0

Apr Jn 15 11 3 (late Apr, 2 in mid-Jun) 1

Chemicals used were:

V’beag T’nish Kyles G’sam V’say Vuia Mor E’ham

Oct 13 em em - - em em em

Nov 13 - - - - - - -

Dec 13 em em az em - em em

Jan 14 - - em az, delt - delt -

Feb 14 delt - - - - - -

Mar 14 em em em em em em em

Apr 14 delt delt delt delt delt delt delt

May 14 az - delt az - - -

Jun 14 em em,delt em,delt az,em delt,em az,em delt,em

Jul 14 delt delt delt delt delt delt delt

Aug 14 - - - az az - delt

Sep 14 - - - az - - -

Oct 14 az - - - - - -

Nov 14 az - - - - - -

Dec 14 - - - - - - -

Jan 15 - - - - - - -

Feb 15 - - - - - - -

Mar 15 - - - - - - -

Apr 15 em - em - - - - -

May 15 - em - em - em em

June 15 em em em em em em em

[delt = deltamethrin (Alphamax), em = emamectin benzoate (Slice), az = azamethiphos (Salmosan)] The FHI inspected Vuiabeag, Taranaish, Kyles of Vuia, Gousam, Vacasay and Eughlam over 1st to 2nd October 2014, recording that lice peaked at Vuiabeag at eight adult female lice per fish in August and at 11 in September 2014. Taranaish peaked at ten in August and seven in September, and was harvesting by October. Kyles of Vuia peaked at six at the end of August, Gousam at 11 in mid-July and nine in September, becoming fallow by the end of October. Vacasay lice counts had risen to ten. At Eughlam lice numbers peaked at 12 in September. Importantly, the intense use of sea lice treatment chemicals between October 2013 and August 2014 did not control sea lice numbers, which rose over that period from almost zero adult female lice to 3.47 per fish, three and half times CoGP threshold. The FHI also inspected Taranaish, Eughlam and Vacasay on 29th October 2014, raising significant issues of concern. For all farms the FHI report that “since lice numbers began increasing in July, treatments were initiated ASAP when required. In last 4 weeks treatments have not been administered despite lice numbers above

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suggested criteria for treatment. This is due to previous treatments resulting in high mortalities (fish have been affected by PGD), the site is currently being harvested and due to be completed in the next three weeks”. (underline added). Taranaish was reported to be at 12 adult female lice per farmed fish, Vacasay at ten per fish and Eughlam at eight, all well of CoGP thresholds. At each of the sites, the FHI reported that the farmed fish “appear to be coping with the current lice load”. Despite acknowledging that treatment had not been given when CoGP threshold were being exceeded at each of these farms, the FHI nonetheless concluded for each farm that “the site meets the requirement of current Scottish industry best practice, however, the sea lice levels on site were above the suggested criteria for treatment as stated in A Code of Good Practice for Scottish Finfish Aquaculture (CoGP). Therapeutic treatments were undertaken when lice numbers exceeded the suggested criteria for treatment without the sea lice numbers being reduced below the suggested criteria for treatment”.

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5.6 Harris The Harris reporting region, in the Western Isles of Scotland, encompasses the Isle of Harris and the southern part of the Isle of Lewis, from Ardvourlie in the south east to Islivig in the north west. It covers several sea lochs that contain salmon farms, including East Loch Tarbert, West Loch Tarbert and Lochs Stockinish and Grosebay. Note that fish farm sites within Loch Seaforth, which were previously included in the Harris region, are now included within the Isle of Lewis East region. This change was effective from January 2014. There are now eight ‘active’ salmon farm sites in the region. The region contains four FMAs. The Scottish Salmon Company has farms at Stockinish, Plocrapol and Scadabay (although no biomass is reported for that farm 2013-2015). Marine Harvest has farms at Scotasay, Soay Sound, Eilean Raineach, West Loch Tarbert (no biomass reported for 2013-2015) and Meavaig (Ghille Beidhe) (no biomass reported for 2013-2015). Figure 10 below shows the relationship between on-farm cumulative biomass at these sites (per SEPA data) and regional sea lice counts reported by SSPO.

As biomass started to increase in the region from October 2013, prior to which all farms were fallowed, adult female sea lice numbers on the farmed fish rose steadily, peaking at 12.94 in November 2014 but not dropping below threshold until June 2015 after farm biomass was massively reduced across the region. In that period, there were a total of 71 separate treatments for sea lice, including 11 co-ordinated area treatments:

Treatments Co-ordinated treatments Other targeted treatments

Oct Dec 13 6 2 (both mid-Dec) 1

Jan Mar 14 4 1 (mid-Feb) 1

Apr Jun 14 14 3 (mid-Apr, late-May, early-Jun) 5

Jul Sep 14 26 4 (early-Jul, late-Jul, mid-Aug, mid-Sep) 12

Oct Dec 14 7 1 (mid-Nov) 4

30

Jan Mar 15 9 0 9

Apr Jn 15 5 0 5

According to SEPA data, sea lice treatment chemicals used were:

St’nish S’say Soay P’pol R’each

Oct 13 - - - - -

Nov 13 - - - - -

Dec 13 - em - em em

Jan 14 - - - - -

Feb 14 - em em em em

Mar 14 - em - - em

Apr 14 - em - delt,em em

May 14 - em em em em

Jun 14 - az - delt az

Jul 14 delt az, em az,em az az,em

Aug 14 em az - em az

Sep 14 delt az, em az, delt, em az az, delt, em

Oct 14 - az, delt az, em em az,delt

Nov 14 - az az - az, delt

Dec 14 - - delt - -

Jan 15 - - az, delt - -

Feb 15 - - az, delt - -

Mar 15 delt - az, delt - -

Apr 15 - - az, delt - -

May 15 - - - - -

June 15 - - - - -

[delt = deltamethrin (Alphamax), em = emamectin benzoate (Slice), azm = azamethiphos (Salmosan)] The FHI inspected Plocrapol on 20th March 2013 and recorded a “significant issue with sea lice”, the site having used deltamethrin, emamectin and azamethiphos since November 2012. Two years later, Plocrapol was inspected again, on 4th February 2015 and the farm again appears to have had a problem, recording that the farm was “harvesting out earlier” due to the cumulative effect of jellyfish blooms, poor weather and sea lice. Azamethiphos used in early November 2014 did not reduce lice below CoGP thresholds. Nonetheless, the FHI recorded that the site was satisfactory with respect to parasite control, per section 3 of the 2007 Act. The FHI inspected Stockinish on 29th January 2013 and recorded the use of 700 wrasse on site, some wild-caught, some farmed. The farm was inspected again on 18th November 2014, recording treatment mortalities among the farmed fish and a level of six to seven adult female lice per fish. The level is recorded as having peaked at 14 adult female lice per fish. The September 2014 use of deltamethrin did not clear sea lice. The site is recorded as having 4,000 wrasse on site (in 89,000 salmon) but the FHI notes that “wrasse have not had a significant impact on lice”, reporting “severe lice damage” to some farmed fish.

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The FHI inspected Scotasay on 19th November 2014 and recorded that the farm was due to cull three of five cages due to sea lice damage despite multiple treatment through the cycle. The FHI recorded that the farm “have locally caught wild wrasse in the cages, but [these] have not been effective”, despite there being 60,000 wrasse on site in 303,295 farmed salmon. Adult female lice numbers were noted as being between five and 20 per farmed fish. The site was inspected again on 4th February 2015, which recorded 192,000 mortalities on the farm since October 2014, due to lice and treatment damage, with a further 123,600 culled. The farm was harvested out by January 2015. The FHI inspected Raineach on 4th February 2015 and reported that “from the start of October to fallow there were 297,000 mortalities and 25,600 fish culled. In addition, 407,000 fish were harvested from Scotasay and Raineach in this time period. Mortalities due to sea lice and treatment damage. one cage was culled out in November 2014. Harvest completed at end of January and site now fallow”. Across this region, it is clear that the intense use of the full suite of sea lice treatment chemicals between April 2014 and November 2014 did not control sea lice numbers, which rose over that period from 0.29 adult female lice to 12.94 per fish, requiring some culling out and causing lice-related mortalities on the farms, but not before sea lice levels had been above CoGP thresholds for some months.

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5.7 The Uists North The Uists North reporting region, in the Western Isles of Scotland, encompasses the island of North Uist and its associated smaller islands. The region includes sea lochs that contain salmon farms, including Lochmaddy and Loch Eport. SSPO reports record that from 2013 to 2015 there were five active salmon farm sites in the region, operated by three companies, with each company’s farms in its own Farm Management Area. SEPA records on Scotland’s Aquaculture Database records that fish were stocked at various times at the following licences sites (with operator) during 2013- 2015: Treanay The Scottish Salmon Company Lochmaddy Loch Duart Limited Groatay Marine Harvest Grey Horse Channel Marine Harvest Outer Eport The Scottish Salmon Company Sound of Harris Loch Duart Limited Figure 11 below shows the relationship between on-farm cumulative biomass at these sites (per SEPA data) and regional sea lice counts reported by SSPO.

As against the CoGP thresholds for treatments, the aggregated data shows that these farms have been collectively above threshold for 21 out of the last 33 months. Since September 2013, adult female sea lice numbers per farmed fish have closely tracked total region biomass. As Figure 12 below shows this is most closely linked with the two Marine Harvest farms, with The Scottish Salmon Company and Loch Duart farms fallow or at very low biomass relative to the Marine Harvest farms from May 2014.

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As sea lice numbers started to rise again above CoGP threshold from late 2014 through to June 2015, the Marine Harvest farms reports to SEPA show treatment with emamectin in August 2014, but not again until February 2015 (emamectin), March 2015 (emamectin and deltamethrin) and May 2015 (deltamethrin). Additionally the FHI inspected Grey Horse Channel on 26th November 2014 and recorded the use of 10,638 wrasse in 578,800 salmon. The FHI inspected Lochmaddy on 15th December 2014 and recorded the use of 2,500 wrasse in 297,000 salmon. The FHI inspected Groatay on 26th November 2014 and recorded the use of 15,000 wrasse in 585,000 salmon. The SSPO Fish Health Management reports record that between January 2015 and early June 2015, there was one area-wide co-ordinated treatment for sea lice and a further 13 ‘targeted’ treatments at individual farms in Uists North. However, these treatments, and the presence of wrasse, failed to bring sea lice counts below threshold between February and June 2015. No use of any sea lice treatment chemicals is reported to SEPA at any Uists North farm in June 2015, despite the sea lice numbers being three and half times the CoGP threshold for treatment and, as the graph shows, although the two Marine Harvest farms have begun to reduce biomass, they had not, at this stage, harvested out.

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5.8 The Uists South The Uists South reporting region encompasses the islands of Benbecula, South Uist and Barra, and associated smaller islands, including a number of sea lochs that contain salmon farms including Lochs Carnan, Uiskevagh, Kilervagh, Skipport and Boisdale. SSPO reports record that from 2013 to 2015 there were between ten and 12 active salmon farm sites in the region, operated by three companies, The Scottish Salmon Company, Marine Harvest and Loch Duart Limited. SEPA records on the Scotland’s Aquaculture database report that fish were stocked at various times at the following licences sites (with operator) during 2013-2015: Bagh Clann Neill (Grimsay) The Scottish Salmon Company Petersport South (Kilerivagh) The Scottish Salmon Company Petersport North The Scottish Salmon Company Skipport Outer (Ornish) Marine Harvest An Camus Marine Harvest Marulaig Bay Marine Harvest Uiskevagh North The Scottish Salmon Company Stulaigh Island Marine Harvest Hellisay Marine Harvest South Ford (Gashernish) Loch Duart Sandavaig (South Ford) Loch Duart South Ford East (Gashernish East) Loch Duart (the above three collectively known as Loch Carnan) Greanamul The Scottish Salmon Company Figure 13 below shows the relationship between on-farm cumulative biomass at these sites (per SEPA data) and regional sea lice counts reported by SSPO.

. As against the CoGP thresholds for treatments, the aggregated data shows that these farms have been collectively above threshold for 26 out of the last 27 months.

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Since January 2014, adult female sea lice numbers per farmed fish have tracked increasing total region biomass. Average adult female sea lice numbers per farmed fish began to rise in May 2014.

Treatments Co-ordinated treatments Other targeted treatments

Jan Mar 13 2 (mid-Feb)

Apr Jun 13 2(early-Apr, mid-May) 4

Jul Sep 13 2 (early Jul, mid-Sept) 7

Oct Dec 13 8 1 (late-Nov) 6

Jan Mar 14 10 2 (late-Jan, late-Mar) 6

Apr Jun 14 10 1(mid-May) 8

Jul Sep 14 18 3 (mid- and late-July, late-Sept) 12

Oct Dec 14 8

Jan Mar 15 16 2 (mid-Feb, mid-Mar) 12

Apr Jun 15 16 5 (early-Apr, 2 mid-May, 2 mid-Jun) 6

Jul Sep 15 13

Chemicals used are:

Bagh CN P’port S P’port N S’port/Ornish An Camus

Jan 13 - - - - -

Feb 13 - delt delt - delt

Mar 13 - - - - -

Apr 13 - delt delt - -

May 13 - em em - delt

Jun 13 - - - - -

Jul 13 - delt delt - -

Aug 13 - - - - -

Sep 13 - - - - -

Oct 13 - - - - -

Nov 13 - - delt - -

Dec 13 - - - - -

Jan 14 - - - em -

Feb 14 - - - - -

Mar 14 - - - em -

Apr 14 - - - em -

May 14 - em - em -

Jun 14 - - - - -

Jul 14 - em - - -

Aug 14 - delt - - delt

Sep 14 - delt,em - delt -

Oct 14 - - - - -

Nov 14 - - - delt -

Dec 14 - - - - delt

Jan 15 - - - delt -

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Feb 15 - - - delt delt, azm

Mar 15 - - - delt -

Apr 15 - - - delt -

May 15 - - - - -

June 15 - - - - -

Marulaig Uiskevagh N Stulaigh Hellisay

Jan 13 - - - -

Feb 13 delt delt delt delt

Mar 13 - - - delt

Apr 13 - delt - -

May 13 - em - -

Jun 13 - delt - -

Jul 13 - - - -

Aug 13 - delt - -

Sep 13 - - - -

Oct 13 - - - -

Nov 13 - delt - -

Dec 13 - - - -

Jan 14 em - em -

Feb 14 - - - -

Mar 14 em - em -

Apr 14 em - - -

May 14 - em em -

Jun 14 - - - -

Jul 14 em em - em

Aug 14 - em -

Sep 14 - em - -

Oct 14 - - - -

Nov 14 - delt - -

Dec 14 delt - - -

Jan 15 - - - -

Feb 15 delt - - -

Mar 15 delt delt azm -

Apr 15 delt - azm -

May 15 - - - delt

June 15 - - azm -

South Ford Sandavaig South Ford East Greanamul

Jan 13 - - - -

Feb 13 - - - -

Mar 13 - - - -

Apr 13 - - - -

May 13 - - - -

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Jun 13 - - - -

Jul 13 - - - -

Aug 13 - - - -

Sep 13 em em - -

Oct 13 azm azm azm -

Nov 13 delt delt azm, delt -

Dec 13 em em em - -

Jan 14 - - - -

Feb 14 - - - -

Mar 14 - delt delt -

Apr 14 - delt - -

May 14 delt - delt em

Jun 14 azm, delt azm, delt azm, delt -

Jul 14 azm, delt azm, delt azm, delt em

Aug 14 azm, delt - azm, delt -

Sep 14 - azm,delt - em

Oct 14 delt - azm, delt -

Nov 14 - - azm, delt -

Dec 14 - - - -

Jan 15 - - - -

Feb 15 - - - -

Mar 15 - - - -

Apr 15 - - - -

May 15 - - - -

June 15 - - - -

[delt = deltamethrin (Alphamax), em = emamectin benzoate (Slice), azm = azamethiphos (Salmosan)] The FHI inspected North Uiskevagh on 20th November 2013 and recorded that the farm had been unable to conduct sea lice treatments over the last few weeks due to weather and tides - with the last treatment on 2nd October- despite elevated sea lice numbers. The FHI also recorded that an August 2013 treatment with alphamax had not reduced lice numbers (although SEPA data records no use of alphamax that month). Despite recording that lice levels were above the CoGP threshold, there was “minimal damage observed from lice”. The FHI inspected the Loch Carnan farms on 27th November 2013 and recorded sea lice levels had been above the CoGP threshold, “with treatments not reducing lice levels (<50%) in some life stages, but overall treatments have reduced lice levels to just over 50% in all treatments”. Again, the FHI recorded “lice > suggested criteria but no damage observed as a result of parasite infestation”. The FHI inspected the Loch Carnan farms again on 24th October 2014 and noted a small number of wrasse at the South Ford cage group only, but that lice levels at this group were the highest. Sea-lice levels had been elevated since autumn 2013. Across this region, it is clear that the intense use of the full suite of sea lice treatment chemicals between February 2013 and September 2015 did not control sea lice numbers, which rose to 13.14 per fish in September 2015.

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6. Discussion and conclusions

6.1 Fisheries scientists increasingly support the view of wild fish conservation groups that sea lice production on farmed fish in open marine cages harms wild salmonids (Atlantic salmon and sea trout) both at an individual and at a population level.

6.2 The analysis in this report was severely hampered by the lack of farm-specific sea lice data, which is currently aggregated into regions rather than being provided on a farm-specific basis as previously recommended by all wild fish bodies, SEPA, SNH and all relevant local authorities

6.3 Nevertheless, it is clear that between 2013 and 2015, the number of regions failing to

keep adult female sea lice numbers below the CoGP threshold is on an upward trend. The industry-wide problem with sea lice appears to be increasing and is certainly not under control.

6.4 The proportion of the total Scottish farms salmon production as against CoGP

thresholds shows a similar upward trend, with regions representing 60% of Scottish production being over the CoGP threshold of 0.5 adult female lice per fish in May 2015, at the peak of the wild smolt run.

6.5 Patently, the North Atlantic Salmon Conservation Organisation (NASCO) Best

Management Practice Guidance requirement that “100% of farms to have effective sea lice management such that there is no increase in sea lice loads or lice-induced mortality of wild salmonids attributable to the farms” is not being met.

6.6 Analysis of SEPA, SSPO and FHI data for 2013 to 2015 provides further strong evidence that adult female sea lice numbers on fish farms rise during the second year of production at sea on salmon farms. This pattern is observable, to a greater or lesser degree, across all the regions analysed.

6.7 In all regions analysed, average adult female sea lice numbers per farmed fish appear to be linked to the cumulative biomass of farmed fish held on the farms, in some regions, extremely closely indeed. As the biomass rises through a production, so sea lice counts per fish follow upwards, often to levels well above CoGP thresholds, including during the February to June period which is critical for wild salmonids.

6.8 All regions analysed show considerable failure of available chemical sea lice treatments to limit aggregated adult female sea lice numbers on farmed fish in these regions to below CoGP thresholds. This strongly suggests resistance and tolerance to these treatments is widespread in sea lice populations. This trend is likely to continue.

6.9 A number of the regions analysed appear to have experienced average adult female sea lice numbers persistently above CoGP thresholds, despite the use of wrasse as cleaner fish on some farms.

6.10 In a number of regions, there is evidence of a failure to treat for sea lice on farmed fish despite adult female sea lice numbers per fish being over CoGP thresholds, contrary to CoGP requirements. Additionally, there is evidence of the failure by fish-farmers to treat sea lice as the farm nears the end of a production cycle, contemplates or begins harvesting. The evidence appears to suggest that decisions are being made that, as near-harvest adult farmed fish can tolerate a moderate lice burden, treatment is not required to prevent damage to the farmed fish.

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This in turn suggests that insufficient consideration is being given in such circumstances to the potential for very large juvenile sea lice production during the last few months of a production cycle, and the consequent negative effects on wild salmonids up to 30km away from the farms concerned.

6.11 In some regions, there is evidence of early harvest or culling out of farmed fish, but this appears only to be associated with unacceptable damage being caused to the farmed fish causing either commercial losses or animal welfare issues for the farmed fish. There is no evidence that early harvest or culling out has occurred at any site in order to protect wild fish from unacceptable levels of juvenile lice leaving the farms.

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7. Recommendations

7.1 The major barrier to proper scrutiny of the fish farms - the lack of published farm-

specific sea lice data - needs to be removed. The Scottish Government should amend the Record Keeping Order 2008 to require the records - that must already be kept by fish farmers under that Order- also should be published online, for example, on the Scotland’s Aquaculture database.

7.2 SEPA or another statutory body needs to record the use of hydrogen peroxide and well-boat treatments for sea lice and publish those records on the Scotland’s Aquaculture database, to ensure that a complete picture is obtained of the sea lice control methods used at any particular farm.

7.3 The Scotland’s Aquaculture database should also record whether or not wrasse, lumpsuckers or other fish are used as cleaner fish, during each of the months for which the fish farmers must report biomass of farmed fish held at any farm under their CAR licences.

7.4 A review of CoGP sea lice obligations, to be led by Scottish Government, is urgently required. Inter alia, the review must ensure that it is no longer possible for fish-farmers, where sea lice numbers have effectively gone out of control on their farms, to assert, as they currently can do, that they remain in compliance with the CoGP. This currently gives a false impression that the sea lice issue is under control.

7.5 The Scottish Government should make the CoGP a statutory code, as provided for in the 2007 Act.

7.6 The Scottish Government should include, within a revised statutory CoGP, an upper tier sea lice threshold above which an immediate cull or harvest of farmed fish is mandated, as practiced in Norway21.

7.7 The Scottish Government should consult on the trigger level beyond which immediate harvest or cull is mandated, but this should be set on a precautionary basis to protect wild fish.

7.8 More generally, the Scottish Government should amend aquaculture legislation with the express purpose of protecting wild fish from potential damage caused by fish-farms. Specifically, the FHI should be given a legal duty to control sea lice on fish-farms expressly in order to protect wild fish populations.

7.9 The FHI should also be given stronger guidance requiring it to enforce proper sea lice control on fish farms more robustly. This may require an amendment to the 2007 Act to require those inspectors to examine farms with respect to the threat from fish farms to wild fish, as well as the current requirements to examine the welfare of the farmed animal.

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Five Norwegian salmon producers were informed by the Norwegian Food Standards Agency in 2013 that they would have to slaughter all their salmon in the area, after all measures to counter lice infestation failed in Vikna, one of the busiest salmon farming regions in Norway. Three producers had levels of five to six mature female lice per fish in the area affected, which is not unusual in Scotland, but was far above the Norwegian national limit of 0.5/fish. The NFSA ordered the producers to slaughter all their fish, or face a fine of approximately NOK 100,000 per day, for every day extending beyond the deadline. Undercurrent News, 2 Oct 2013: Salmon farms rushing to slaughter 8,000 tonne of fish due to high lice levels

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7.10 MS needs to routinely examine all the data available to it under the Record Keeping Order and that information collected by SEPA, local authorities, FHI and others in order to identify those farms that are consistently failing to control sea lice. Such farms should then be examined closely with a view to closure and / or a relocation programme as was first made a priority issue by the Strategic Framework for Scottish Aquaculture back in 2003.

7.11 In parallel to the above, Scottish Government should focus on alternative more sustainable production methods with the ultimate objective of moving to full closed containment of farmed salmon production in Scotland to eliminate the biological interaction between farmed and wild fish.

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Annex 1 List of Scottish salmon farms with SSPO region22 Site Name Site No SSPO area Dury Voe FS0033 62-E Bastavoe South FS0074 62-E Wadbister Voe FS0140 62-E Bight of Foraness FS0292 62-E West Voe FS0310 62-E East Voe Laxfirth FS0333 62-E Swining Voe 2 FS0377 62-E Uyea Isle FS0382 62-E Wick of Vatsetter FS0407 62-E Poseidon FS0408 62-E Stringa Voe FS0439 62-E Baltasound Harbour FS0449 62-E Turness FS0451 62-E Wick of Belmont FS0472 62-E Bow of Hascosay FS0477 62-E Taing of Railsbrough Catfirth FS0501 62-E Vidlin North FS0608 62-E Pier FS0624 62-E Djubawick FS0656 62-E Rockfield FS0662 62-E Loura Voe FS0699 62-E Sandwick FS0710 62-E Balta Island FS0717 62-E Kirkabister FS0802 62-E Swarta Skerry FS0814 62-E Winna Ness FS0871 62-E Mula FS0896 62-E Swining Voe 3 FS0903 62-E North Voe FS0946 62-E East of Holm Heogland (Burkwell) FS0960 62-E South Holm of Heogland FS0962 62-E Collafirth 3 FS0999 62-E Linga (Setterness) FS1027 62-E Ness of Copister FS1043 62-E Fish Holm FS1045 62-E Vee Taing FS1057 62-E Wick of Garth FS1060 62-E Bomlo FS1076 62-E Gletness FS1099 62-E Baltasound Pier FS1102 62-E Bight of Bellister, Dury Voe FS1121 62-E Hamnavoe FS1144 62-E Flaeshins FS1275 62-E Bastaness FS1279 62-E Pobie Sukka FS0039 62-W Cloudin FS0088 62-W Holm of Gruting FS0166 62-W

22

Marine Scotland 12th May 2015.

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Mid Taing FS0167 62-W South Sound FS0183 62-W Crooie FS0213 62-W Selivoe (High Banks) FS0228 62-W Brunaness FS0230 62-W Setter Voe FS0316 62-W Coleness FS0378 62-W Brindister Crossroads FS0386 62-W Snaraness FS0400 62-W Langa Isle (East) FS0433 62-W Punds Voe FS0446 62-W Papa FS0447 62-W North of Hoy FS0481 62-W Cole Deep FS0489 62-W Olna North FS0512 62-W North Papa FS0515 62-W Lea Trondra (East of Trondra) FS0548 62-W Breigeo (Offshore) FS0607 62-W Stead of Aithness FS0637 62-W Burrastow FS0666 62-W East of Hildasay FS0673 62-W North Havra FS0674 62-W Sound of Hoy FS0691 62-W Brindister Linga FS0715 62-W Holms Geo FS0749 62-W Olna South FS0764 62-W Spoose Holm FS0785 62-W Binnaness FS0791 62-W Lippie Geo FS0850 62-W East Kallee Ness FS0905 62-W Breigeo Inshore FS0915 62-W Flotta FS0935 62-W Foreholm FS0936 62-W West of Burwick FS0937 62-W Score Holms FS0948 62-W Marine Hatchery FS0991 62-W East of Merry Holm FS0996 62-W Slocka Ronas Voe FS1018 62-W Hogan FS1053 62-W Inner Mangaster FS1058 62-W Teisti Geo FS1093 62-W Hamar Sound FS1114 62-W Geo of Valladale FS1115 62-W East of Papa Little FS1278 62-W Pegal Bay FS0031 61 Lyrawa Bay FS0054 61 Bay of Ham FS0122 61 Carness Bay FS0390 61 Bay of Cleat (South) FS0595 61 Meil Bay FS0597 61 Kirk Noust FS0645 61 Puldrite FS0813 61 Noust Geo FS0823 61 Shapinsay FS0860 61

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Quanterness FS0908 61 Chalmers Hope FS0993 61 Fara West FS1017 61 Bay of Vady FS1020 61 Bring Head FS1023 61 Toyness FS1024 61 Opus Maxim Ltd FS1028 61 Bay of Cleat (North) FS1080 61 South Cava FS1198 61 Ouseness FS1209 61 Vestness FS1210 61 Wyre FS1294 61 Bagh Chlann Neill FS0051 60-S Kilerivagh / Petersport FS0340 60-S Ornish Island FS0531 60-S Loch Boisdale (An Camus Calvay) FS0841 60-S Marulaig Bay FS0865 60-S North Uiskevagh FS1255 60-S Stulaigh FS1259 60-S Hellisay FS1261 60-S Loch Carnan FS1280 60-S Greanamul FS1282 60-S Loch Meanenvagh FS0494 60-N Vaccasay FS0480 60-N Treanay FS0796 60-N Lochmaddy FS0853 60-N Groatay FS1083 60-N Grey Horse Channel FS1122 60-N Outer Eport FS1254 60-N Sound of Harris FS1260 60-N Loch Stockinish FS0190 59 Scotasay FS0502 59 Soay FS0646 59 Ob Meavag FS0817 59 Seaforth FS1042 59 Trilleachan Mor FS1118 59 Plocrapol FS1256 59 Raineach FS1263 59 Reibinish FS1277 59 Scadabay FS1293 59 Vuiabeag FS0411 58-W Taranaish FS0752 58-W Kyles of Vuia FS0927 58-W Gousam FS0998 58-W Vacasay FS1091 58-W Vuia Mor FS1103 58-W Eughlam FS1233 58-W Loch Odhairn FS0242 58-E Sgeir Bhuidhe FS0954 58-E North Shore FS1033 58-E Caolas A Deas FS1291 58-E Ardyne FS0559 43 Strone Point FS1056 43 Sgian Dubh FS1281 43

45

Evanachan Salt Water FS0001 42 Meall Mhor Loch Fyne FS0091 42 Furnace Quarry FS0567 42 Glenan Bay FS0590 42 Gob a Bharra Loch Fyne FS0683 42 Quarry Point FS0698 42 Tarbert South FS0767 42 Ardcastle Bay FS0818 42 Evanachan Marine Hatchery FS0843 42 Ardgadden FS0851 42 Rubha Stillaig FS0894 42 Strondoir Bay FS1019 42 Lamlash FS0423 41 Eilean Grianain FS1176 41 Colonsay FS1296 40 Loch Spelve (B) FS0253 39 Inch Kenneth FS0593 39 Loch Tuath FS0617 39 Loch Spelve (A) FS0634 39 Geasgill FS0839 39 Gometra FS1267 39 Ormsary Broodstock Unit FS0090 38 South Drumachro FS0335 38 Druimyeon Bay FS0336 38 East Tarbert Bay FS1010 38 Larval Rearing Unit FS1046 38 Quarantine Facility FS1100 38 North Moine FS0356 38

Bagh Dail Nan Cean FS0805 38 Shuna Castle FS0465 38 Poll Na Gille FS0629 38 Eilean Coltair FS0777 38 Port Na Cro FS0859 38 Shuna SW (Rubh'an Trilleachain) FS1290 38 Kames Bay (west) FS0271 37 Kames Bay (east) FS0462 37 Ardmaddy FS0464 37 Inverawe (West) Etive 1 FS0040 37 Ardchattan Bay FS0197 37 Scallastle FS0209 39 Invasion Bay FS0212 35 Gorsten FS0237 36-N Linnhe FS0240 36-N Kingairloch FS0241 36-N Loch Leven (1) FS0244 36-N Dunstaffnage FS0299 37 Camas Glas FS0413 35 Loch Creran (B) FS0426 36-S Fishnish (A) FS0427 35 Scottish Marine Institute (SAMS) (Fish) FS0469 37 MacLean's Nose FS0599 35 Kerrera B FS0663 37 Fishnish (B) FS0694 35

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Shuna FS0695 36-S Fiunary FS0696 35 Lismore North FS0745 36-S Walters (East Lismore) FS0875 36-S Lismore West FS0914 36-S Bloody Bay FS0964 35 Loch Creran (D) FS1047 36-S Inverawe (East) Etive 2 FS1067 37 Glencripesdale FS1094 35 Etive 3 (Port na Mine) FS1101 37 Etive 4 FS1112 37 Etive 6 FS1288 37 Loch Greshornish FS0015 34-S Loch Harport FS0247 34-S Leinish FS0800 34-S Gob na Hoe FS1175 34-S Corlarach FS1287 34-S Cairidh FS0252 34-N Maol Ban FS0519 34-N Sconser FS0602 34-N Portree FS0708 34-N Sgeir Mhor FS0880 34-N Ardnish FS0249 33 Marine Farming Unit FS0869 33 Loch Ceann Traigh FS1131 33 Muck FS1286 33 Nevis A FS0430 32 Nevis C (Ardintigh) FS0546 32 Creag an T'Sagairt (Loch Hourn) FS0605 32 Nevis B FS0616 32 Loch Alsh (Sron) FS0016 31 Ardintoul FS0245 31 Loch Duich FS0248 31 Strome FS0570 30 Kishorn A (South) FS0709 30 Kishorn B (North) FS0804 30 Kishorn West FS1274 30 Kenmore Loch Torridon FS0050 29 Torridon FS0234 29 Aird FS0594 29 Sgeir Dughall FS1262 29 Isle Ewe FS1084 28 Ardmair FS0056 27 Corry Farm FS0057 27 Ardessie A FS0517 27 Tanera FS0549 27 Ardessie B FS0675 27 Fada FS0858 27 Loch An Sal FS0266 26-S Poll Loisgann FS0431 26-S Ghlas Mhor FS0883 26-S Loch Laxford FS0065 26-N Badcall Bay FS0067 26-N Calva Bay (Calbha Beag) FS0068 26-N

47

Nedd FS0129 26-N Drumbeg (Loch Dhrombaig) FS0487 26-N Loch A Chairn Bhain FS0621 26-N Outer Bay (Loch Droighniche) FS0671 26-N Clashnessie Bay FS0933 26-N Kempie Bay FS0359 25 Sian Bay FS0361 25

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Annex 2 SSPO regional codes Hope and Grudie 25 Inchard to Kirkaig North 26-N Inchard to Kirkaig South 26-S Kennart to Gruinard 27 Ewe 28 Badachro to Applecross 29 Kishorn and Carron 30 Loch Long and Croe 31 Glenelg to Kilchoan 32 Morar to Shiel 33 Skye and Small Isles North 34-N Skye and Small Isles South 34-S Sunart and Aline 35 Sanda to Creran North 36-N Sanda to Creran South 36-S Awe and Nell 37 Add and Ormsary 38 Island of Mull 39 Islay and Jura 40 Carradale and Iorsa 41 Fyne 42 Ruel and Drummachloy 43 Isle of Lewis East 58-E Isle of Lewis West 58-W Harris 59 The Uists North 60-N The Uists South 60-S Orkney 61 Shetland West 62-W Shetland East 62-E

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Legal services for the environment, conservation, fisheries and freedom of information. Second Floor Offices, 12 Castle Street, Hereford HR1 2NL Telephone: 01432 379093 Mobile: 07837 881219 guy@linley-adams.co.uk Guy Linley-Adams is authorised and regulated by the Solicitors’ Regulation Authority (524741) and the Law Society of Scotland (30663)