The MSA has already confirmed that it supports the urgent implementation of a new system of regulation for fish farms. This regulation must include:
- The clear identification of a Scottish public authority with the statutory function of protecting wild fish from the negative interactions of salmon farming.
- The introduction of an effective, robust and enforceable regulatory system for all salmon farms, to protect wild migratory fish and proactively address all and any negative impacts associated with salmon aquaculture, including much stricter ‘backstop’ limits for on-farm sea lice numbers, coupled with independent monitoring and strict enforcement in the event of breaches, to curtail the damage being caused to wild salmon and sea trout by salmon farming. The ‘backstop’ limits should be set at an average of 0.5 adult female lice per farmed fish on any particular farm, with the limit dropping to 0.1 during wild smolt emigration between February and June, but this would not prevent adaptive management requiring lower lice levels on particular farms if that was required.
- A genuinely precautionary approach to the licensing and permitting of any new salmon farms or expansion of existing farms.
- A review of the permitted biomass and location of all existing salmon farms as against their environmental impact, with a mechanism to compel reductions in biomass and relocation where appropriate.
- Full transparency on the environmental impact of fish farming, including the ‘real-time’ publication of on-farm sea-lice, escapes of farmed fish, use of all treatment chemicals (whether on-farm or in well boats), farmed fish mortalities and disease information.
- A requirement that no salmon farming development be permitted without the prior completion of a rigorous independent cost-benefit analysis of the potential impact on coastal communities, including the impact on existing local businesses and ecosystem services.
- Any adaptive management of fish farms, to be based on monitoring of wild fish, must be robust, independent, transparent and open to public scrutiny, with clear thresholds and deadlines for rapid action on-farm where problems are identified or suspected, and an appropriate regulator charged with enforcement of such management measures.