Local marine scientist, activist, and writer Sally Campbell, considers how the price of Scottish salmon can be so low and urges us as consumers to say no to these unrealistic prices that cover a multitude of environmentally damaging and unsustainable fish farming practices.

I was somewhat surprised to see an advert for ASDA on 22 November in a National newspaper for Scottish farmed salmon for £4.97 per kilo for Christmas, making it cheaper than mince at £5.00 per kilogramme. How on earth can a profit margin be made at that price bearing in mind the fish has been growing for up to 3 years, fed, disease controlled, prepared for supermarket, distributed over the country and marketed in the national media, like The Daily Mail? So let’s unpack some of the issues.

Of course one reason we already know is that the salmon industry in Scotland externalises a lot of the costs of production and our marine environment and its ecosystems pick up the price. No payment is made for pollution control so faecal and waste food is released untreated straight into lochs and inshore waters along with contamination related neurotoxins, antibiotics, and copper from net cleaning. Further, the exploitation of wild cleaner fish (mostly ballan wrasse) from reefs around Scotland for use in salmon farm pens in theory to eat sea lice so minimising damage to farmed fish, is leading to impoverishment of our inshore reef ecology, even in Marine Protected Areas, with again no recompense for damage.

As prices drop, so the pressure to grow more salmon per fish pen occurs, in order to maintain profitability, a continuing pattern that has persisted in Scotland in recent years. And just as in a school classroom if one child develops flu, many more will catch it. So it is with a range of diseases afflicting caged salmon. More in-feed defensive chemicals are used, often supplemented by tanker-loads of hydrogen peroxide, a highly reactive, strongly oxidizing and bleaching agent to dose the pens of fish, to try and alleviate the problem leading to more ecosystem contamination, in order simply to try and stem the losses or at best maintain meagre margins of profit.

The message is that “the market” drives this industry, always seeking lower costs. Automated feeding came first, reducing full time jobs. Then came the market in krill for fish oil in salmon feed, often sourced from the Antarctic in Norwegian vessels for Norwegian companies such as the feed producer AkerBiomarine, targeting Antarctic Krill in the Antarctic Seas using pelagic trawls and ‘hoovering’ techniques. 212,000 metric tonnes of krill were harvested in the year 2012/13. Scientists believe krill have declined by 80 per cent since the 1970s, in part it must be conceded due to global warming. There is uncertainty, though, about the remaining population: the British Antarctic Survey estimates 100 million tonnes; krill harvesting companies claim about 400-500 million tonnes. Under the Convention on the Conservation of Antarctic Marine Living Resources, the annual allowable krill catch in the Southern Ocean is 4 million tonnes. Antarctic krill grow to 6cm and live on algae and plankton and are themselves consumed by predators such as whales. One whale can eat four tonnes of krill a day. It is estimated that krill are thought to ‘sequester’ carbon equivalent to the emissions of 35 million cars a year, so important in climate change mitigation.

The Blue Label of Marine Stewardship Council (MSC)

Now we are learning of the cost of overfishing krill to iconic species further up the food chain such as starving penguin chicks. That is more externalising of the costs of farmed salmon production, since they and indeed consumers of the product pay nothing towards protecting and sustaining the ecosystem and food chains. The Blue Label of Sustainable Fishery of the Marine Stewardship Certification (MSC) was meant to reassure us all that no harm was being done, but no ecosystem was or even is, comprehensively studied before the Blue Label is awarded! The marine environment is all about complexity, how species interact, food chains, water movement, temperature etc. Then there is the geopolitics, the study of the effects of geography (human and physical) on politics and international relations, with politics interfering in the protection of environments. Just last month at the discussions in Tasmania, at the yearly meeting of the Commission for the Conservation of Antarctic Marine Living Resources, (CCAMLR) part of the Antarctic Treaty System, Norway, along with China and Russia, refused to vote for an urgently needed Marine Protected Area in the Weddell Sea or other areas in Antarctica. So much for Norway, and by extension, its salmon aquaculture industry through its Antarctic fisheries, believing in the importance of sustainable ecosystems!

So farmed salmon fish feed is part of Antarctica’s story, conservation and part of the complexity behind ASDA’s cheap salmon. In Scotland, Marine Harvest is the newly arrived player in the feed preparation market in the UK. Feed has gone from high-tech, higher profit to low-margin in a few years. Marine Harvest is soon to open its own factory at Kyleakin with a capacity of 170,000 tonnes of feed per year. Marine Harvest was until now Skretting, a Norwegian feed producer’s VIP customer, and as Marine Harvest is now aiming to feed its own fish, Skretting’s plant in Invergordon will close with the loss of more than 50 jobs. This factory was producing fish feed for the salmon industry in Scotland. This global company based in Norway is pulling out of the UK altogether. The move will also see the closure of the company’s plant near Preston in Lancashire, its head office in Norwich and a warehouse in Shetland. A total of more than 100 jobs will be lost. In a statement, Skretting said the closures were due to British market conditions, resulting from over-capacity and low prices. I wonder how much government money has been awarded to Marine Harvest at Kyleakin to “promote jobs in the Highlands” whilst we lose jobs elsewhere. Therese Log Bergjord, chief executive officer, said: “Unfortunately, we are experiencing unsustainable market conditions in the UK. With a new large feed plant becoming operational in Scotland in early 2019, the total feed capacity in the region is expected to exceed the total market by more than 50%. This is driving down prices, leading to an unsustainable commercial environment.”

It has long since been possible to replace fishmeal for salmon aquaculture with other protein sources, even though salmon is a carnivorous fish and companies look to produce fish feed with zero inclusion of marine ingredients. In farmed salmon the main ingredient of feed is vegetable matter, present as soya bean and palm oil products. Convincing salmon they can become vegetarians is itself pushing the price of feed downwards and of course damaging land ecosystems around the world. For example Argentina has driven a major new trend in the region, and it comes in the shape of a bean. Huge money is to be made from soya but small farmers are rarely the winners; their number has almost halved since 1988 to 270,000. People’s wellbeing is less important than profit. The fact that there is now 4 times more acreage dedicated to soybean production and as much as 11 times more herbicides used to produce it, has had other negative consequences; the rise in miscarriages and birth defects in rural areas being attributed to these chemicals. You have guessed it! The next phase in Argentina is genetically modified soy bean to achieve even higher productivity.

So you see how all the above is driving the low price of Christmas salmon at £4.97per kilo. It is a race to the bottom.

So how might things be turned around? We need to protect our marine environment, ensure compliance with licences, and prevent cumulative impacts around fish farms. As consumers we need to make choices, make our concerns heard by brands such as “Scottish Salmon”, whichever company is producing it. So at this pivotal time, it is pertinent that SEPA visited Arran this month to hold a consultation event. Those who attended from SEPA openly discussed findings of their recent research and report and proposals to meet the need for closer scrutiny, enhanced risk assessment, compliance issues and more rapid response to community concerns over happenings locally on fish farms. We urged more toxicology, more cumulative impact assessment, perhaps in Loch Fyne with its 10 farms, where there is limited water tidal movement due to physical constructs including sand bars, such as that at Otter Ferry.

Whilst we have no sign of a true white knight arriving on the West of Scotland anytime soon to enforce the shut-down of open sea salmon aquaculture, we do see positive changes in SEPA’s attitudes to managing this huge industry. Their recent research and published report on the Voes of Shetland has confirmed what many have been saying for years; that accumulated waste is damaging inshore waters, not only the seabed but animals that depend on it for food and shelter. Toxicology confirms the damage to amphipod populations, those small arthropods commonly found crawling and swimming among weeds, eelgrass, tide pools, dock pilings, and rocks. They eat dead and decaying algae and seaweed and other plants and animals so are mostly detritovores or scavengers. This chemical damage may have serious consequences if this is found for other arthropods, such as prawns, crabs and lobsters, all important seafood products in creeling communities which depend on pristine waters around the coasts and inshore waters.

To give you a flavour of the research and some scientific findings discussed: SEPA chose eight sites around the Shetlands with the aim being to assess the impact of fish farms on the surrounding water body. The on-site sampling was conducted over a week period with the following objectives:

• Measure impact on benthic ecology in vicinity (the ecological region at the sea floor, including the sediment surface and some sub-surface layers).

• Determine levels of two chemicals (medicines) in sediments

• Trial new approach to measuring area of benthic impact

The findings have been reported in relation firstly to sea lice medicines and secondly to the benthic ecology. The findings must make us all concerned for the future, unless control on salmon farms is more effectively managed by SEPA both in existing and any new farms approved.

In the case of sea lice medicines and specifically EmBz (emamectin benzoate), sampling was, not surprisingly, related to existing SEPA regulatory concept when dealing with fish farms, specifically the near field EQS (Environmental Quality Standards, an EU Directive), the maximum allowable concentration within 100 metres of the cage edge and the far field standard beyond 100metres. What is in many ways astounding is that at the sampling stations chosen in the near field 17% of results exceeded the current standard and a very significant 7% exceeded the standard applicable beyond 100 metres, the far field EQS. One can take from this the message that the present approach totally underestimates the impact. The follow on from this is that on applying a much more stringent criterion, based on SEPA’s proposed new much tighter EQS’s to those same survey outcomes, all samples taken at the near field stations (100%) exceeded the standard as do 75% of the near field stations. It can safely be said that on the basis of these findings alone the industry has a problem of environmental impact.

Even more disturbing are the results of teflubenzuron (Tef) used as an in-feed lice treatment up until 2013 and then finally proscribed in 2015. There were no exceedences for the near field detected but an astonishing 36% of far field, that is beyond 100metres from the cage edge, sediment samples exceeded the EQS that applied back in 2013. This means that this biologically active chemical has remained intact with little degradation over at least a five year period in sediments some distance from aquaculture operations, a disturbing thought and warning of the vital need for more stringent regulation!

On ecology the method adopted by SEPA in examining sediments was the Infaunal Quality Index (IQI) which continues to be employed by the regulatory agency as a standard tool to assess biodiversity and species richness. By applying statistical analyses designed to explore these factors, valid conclusions have been derived regarding likely impact of EmBz. The most significant finding is that EmBz is indeed an important environmental factor and that impacts from discharging this chemical, are not contained within the immediate vicinity of aquaculture operations. SEPA conclusions from this study point the way forward to further work, both on toxicology and effects on benthic ecology. EmBz most likely has the greatest negative effect on crustacean abundance. Further, existing EmBz standards may not be protective of benthic ecology.

So there we have it. Cheapness of farmed salmon comes at the expense of several parts of the food chain worldwide:

• No costs associated with pollution clean-up. Our environment and ecosystems pay

• Increased automatic feed regimes on farms, less staff employed, less fixed costs

• Increased biomass on farms, producing more for less. In some cases resulting in overproduction so a reduction in price of product in order to shift stock

• Industrialised krill harvesting for omega-3 krill oil for fish feed. The cost to the iconic species of the cold waters of the Southern Ocean and Antarctica. The Blue label suggests a sustainable fishery, but do not be fooled

• Cheaper and cheaper salmon fish meal, almost making farmed salmon vegetarians, creating problems in far flung communities around the world producing soya beans and palm oil, displacing small farmers.

• Over use of chemicals (medicines) to control disease that are only very slowly degraded in our marine environment, in order to sustain larger biomass farms. Keeping fish diseases at bay at a cost to the environment and its ecosystems

• Until now inadequate self-monitoring of production, escapes, disease control, overstocking.

• Finally, and importantly, a largely effective continuous Public Relations campaign telling consumers: pristine waters, ”omega-3” oily fish good for health, that it is “organic” production, that only “natural” additives give the colour to the salmon.

• The Industry Award sector, which has gone into overdrive in farmed salmon continuous array of awards such as the Highlands & Islands Food & Drink (HIFAD) Awards, the ten award categories of Scottish Marine Aquaculture Awards, Best Rural Food Business Award and so on and on. Lots of spin and PR to help the consumer believe in the product

There are technical solutions to some of these farm problems associated with waste and chemicals, such as using holding tanks on land where water is filtered, reused and waste collected and semi-enclosed pods out at sea. Each of these will mean added costs for an industry operating at the margins of economic viability. The only solution is an entirely new strategy returning to the production of a premium high value product but even that is not going to be possible as long as there are competitors allowed to continue present open cage practice and undercutting price.

But also remember we the consumers are after cheaper food. We too make choices. Who wouldn’t prefer “raised in pristine water with care in Scotland” salmon over mince at Christmas? We believe the PR patter. But there is an alternative. Can we as consumers give a gift to the Scottish seas in the No Farmed Scottish Salmon at Christmas Campaign?

Sally Campbell, November 2018