Representation to ESS concerning Scottish

Irrespective of efforts to characterise and quantify other pressures, the harm caused by sea lice emanating from fish farms is well understood and precautionary efforts to control the impact of farm-derived sea lice on wild salmonids should not be delayed on the basis of the relative contribution of such ‘other pressures’ to the decline in wild salmonids. [...] 4.4 Of specific concern to Salmon and Trout Conservation was the lacuna in the law that it had pointed out on many occasions – that Part 1, and particularly section 3 of the Aquaculture and Fisheries (Scotland) Act 2007, as amended, addressed sea lice control on fish farms only for the purpose of securing the animal welfare of the farmed fish, not in respect of the effect of the massive release of. [...] The Framework demonstrates how the work of the four countries and the UK contributes to achieving the Aichi Targets, and identifies the activities required to complement the country biodiversity strategies in achieving the Targets. [...] The Water Environment and Water Services (Scotland) Act 2003 contains the general duties, at section 2 (with the WFD referred to as “the Directive”): “(1) The Scottish Ministers and SEPA must exercise their functions under the relevant enactments so as to secure compliance with the requirements of the Directive, the Groundwater Directive and the Priority Substances Directive. [...] 12.9 ESS is asked to consider whether SEPA’s new system to regulate the interaction between fish farm-derived sea lice and wild salmonids is, in fact, lawful, as against that range of obligations, including the Biodiversity Convention, the Convention on the Conservation of Salmon in the North- East Atlantic, the Water Framework Directive49, the Marine Strategy Framework Directive, the Habitats Dir.