Seòmar agus comataidhean

:I want to confirm that you cannot respond to my question on whether you think that SEPA’s current regime for monitoring sea lice is satisfactory.

I want to continue the line of questioning about public confidence and transparency. My sense is that wild fish and farmed fish exist in two completely different systems. One belongs to nature and the other is under human care—or so I would like to think.

I feel that the committee is not getting the sense that we have transparency and confidence in the data. I get the point that the fish health inspectorate has enough data to do its job, but this is about public confidence. An Aquaculture Stewardship Council audit states that input mortality was high during the previous production cycle at Scotasay, but Salmon Scotland reported 0 per cent mortality. I am hearing from one side that the mortality is high, but then we get a 0 per cent figure. Something is missing, transparency wise, in the way in which things are reported. Do you dispute that, Mr Hadfield?

:We have just had an extensive session on salmon farming. One of my concerns about the marine licensing SSI is that it is potentially premature. We are aware of an on-going appeals process in which SEPA is involved, and the SSI will expand its workload. I am concerned about how much resource SEPA has available to implement the changes. Although some who responded to the consultation said that they agree with the changes, the key concern that comes up in the responses is about whether SEPA has the capability and capacity. Given the appeals process that is tying up SEPA, I wonder whether the SSI has been laid a bit too soon.

:I will ask the same question of the fish health inspectorate and of the Animal and Plant Health Agency. How do you, as a regulator, factor mortality risk into decision making?

:I am asking about how you incorporate mortality risk into the decision making of the fish health inspectorate.

:The evidence in the consultation raises concerns. The Scottish Fishermen’s Federation said:

“The Scottish Fishermen’s Federation’s (SFF) position remains that we do not support the extension of aquaculture from 3 nm to 12nm … we recognise the benefits of making the process more consistent across the entire 0-12nm, but we are uncertain whether SEPA has sufficient resources or expertise to cope with the additional region. The same concern is held for MD-LOT remaining as the regulatory body.”

Although the proposal in the consultation might appear to be administratively coherent on paper, I am concerned that it is premature in practical terms. The central issue remains the well-evidenced failure of the current regulatory system to enforce environmental standards effectively, despite already having the legal powers to do so.

Simply consolidating responsibilities under SEPA without first addressing the underlying enforcement gap risks creating a more streamlined system that still fails to prevent environmental harm and, in fact, could make harmful activity easier to progress rather than strengthening oversight.

I am concerned that expanding the scope of regulation without providing a corresponding increase in resources, capacity and, where necessary, powers is unlikely to achieve the stated objectives. Without tackling enforcement and funding head on, structural reorganisation alone will not deliver the meaningful improvements that we desperately need.

This morning, we heard from Dr Alan Wells that wild salmon are a species on the edge and in crisis, and that not enough is being done. Therefore, I have great concerns about expanding SEPA’s remit. As I said, such regulations will be needed at some point—once the 0 to 3 nautical miles range is regulated, we will be in much better shape.

:My question is for Amy Jennings. One of the committee’s recommendations was that the Scottish Government make additional regulations and official guidance under the Animal Health and Welfare (Scotland) Act 2006. In the absence of species-specific statutory welfare guidance for farmed fish and cleaner fish, how does APHA interpret and enforce the Animal Health and Welfare (Scotland) Act 2006 in practice on salmon farms? You might have covered some of that in your conversations with Emma Roddick. Also, does the lack of official guidance hinder APHA’s ability to take enforcement action?

:You were talking about something that could happen in the future. We made a number of recommendations and we are having this inquiry more than a year since we did that work. I am just trying to get an understanding of what is actually happening on the ground; it was helpful that you described what you would like to see happening on the ground. I just wonder whether the other witnesses can say whether anything is actually happening yet, or whether targeted research into modelling environmental conditions that lead to high mortality events will happen in the future? Are we actually doing anything on that yet?

:I hear what Ben Hadfield is saying about the underreporting being acted upon swiftly, but it is a concern. We talked earlier about reporting issues regarding mortality, and there is now another reporting issue. How can the committee have 100 per cent confidence in the reporting? That issue was found out through work that was being done, but can we be confident that we are getting an accurate picture of all the reporting?

:My sense is that we may lead the world in a kind of transparency, but what is coming up in this meeting—and it came up in the previous work that we did—is that there are points at which responsibility ends and something does not get picked up. I have concerns about that. We made many recommendations in our report, but, as we are having this conversation, I am not getting the sense that enough has changed over the course of a year.