The River Annan
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The River Annan Trust & District Salmon Fishery Board
Atlantic Salmon Broodstock Trial
Position Statement: Selcoth Broodstock Trial
We have been engaged voluntarily by Mr Routledge, Selcoth Fisheries Limited and operator of Selcoth New Farm regarding an application to make a change of species on their farm from Rainbow Trout (Freshwater stages) to Atlantic Salmon (Broodstock only).
As a District Salmon Fishery Board we are aware that:
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We are statutory consultees in only the planning process for fish farming, however the consenting requirements for a change in species do not require a planning application. The Board therefore has no role or responsibility toward the outcome of this application as it sits under the regulatory control of other organisations.
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Mr Routledge has approached the appropriate regulatory bodies responsible for consenting this type of change in activity and has satisfied their requirements to permit the activity, namely those of the Fish Health Inspectorate who are responsible for issuing an Aquaculture Production Business authorisation, which is required to prevent the introduction of and spread of infectious diseases. The Fish Health Inspectorate have granted the amendment to their authorisation as the risk of disease spread from operating the sites, in the manner described in their application, has been assessed as acceptable.
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Should Selcoth Fisheries Limited wish to pursue any future changes / developments to their farm they will have to follow the necessary consenting process relevant to the activity they plan to operate. The Board would only then be involved in its statutory capacity should future developments require a planning application to the Local Planning Authority.
As a board we are satisfied that current regulations were followed appropriately. However, given the unique nature of the trial (the first in Scotland), there was some surprise and annoyance expressed that there was no formal requirement to consult. If the trial is successful, consequentially scaled up and extended to other river systems, then we would recommend the appropriate authorities include consultations as part of future applications.
We are grateful to Selcoth Fisheries Limited for hosting site visits to Selcoth fish farm to talk through the salmon broodstock trial activity being proposed with board members, despite them being under no obligation to do so. All attending the initial site visit were fully satisfied with arrangements for ensuring the safe containment of the 200 broodstock salmon to be held during the trial period. It was also recognised that the reduction in fish biomass from over 100 tonnes of rainbow trout held previously, to approximately 1 tonne of adult salmon would lead to a major improvement in farm effluent water quality.
However, during the site visit the all-important future farm biosecurity arrangements were also discussed. There were questions raised about the pathogen sampling methodology that selected broodstock would be subject to that were unable to be answered at that time. Subsequently Selcoth Fisheries Limited have provided a revised sampling protocol being introduced that is more stringent than required by the Fish Health Inspectorate.
Despite adherence to all necessary regulations by Selcoth Fisheries Ltd, and the fact that any proposed major change to the farm system in the future necessitating planning permission would involve the board as a statutory consultee, the Annan board has concerns.
We recognise and accept that there will be a new introduction of farmed salmon into the catchment of the River Annan reflecting what appears to be a step towards onshoring of parts of the salmon industry with the potential risks that that entails.
If at any stage in the future larger stocks of salmon were contained over a longer period, the disease risk will increase should the pathogen screening system fail. Pathogens could then transfer to river system and its wild fish stocks through effluent discharge. If any future ‘scaling up’ were accompanied by the installation of a ‘state of the art’ Recirculation Aquaculture System (RAS) this would reassure local fishing interests and may provide an exemplar model of national significance.
Therefore, we seek government reassurance that the appropriate regulations and best practice are kept under close review at this stage of the salmon farming industry’s evolution and fully involve Fisheries Management Scotland (FMS). We feel strongly that governance and decision making must remain effective, whenever requests are made in the future for the introduction of non-native strains of salmon to fish holding facilities with an effluent discharge directly or hydraulically connected to Scottish river systems containing wild Atlantic salmon and Sea trout.
The Annan Board remains committed to reversing the decline in Wild Salmon and Sea Trout populations on the River Annan and will always seek to ensure people and organisations engaged with the river comply with all regulation. In this vein, and through our FMS committee representative, we would welcome the opportunity to play an active part in any national debate and review process that may be catalysed by the salmon broodstock trial about to commence at Selcoth.