The Scottish Government's "blasé" attitude about the financial implications of new U.S. rules banning imports of salmon from seal-killing salmon farms is attracting more criticism.
"The Scottish Government has got its knickers in a twist over this," said John Robins, Secretary of Save Our Seals Fund, in a press release (27 September): "They simply do not realise that if they fail to make shooting seals a criminal offence American customs officers will not let as much as a Scottish-caught pickled herring cross their border. Salmon farmers will lose well over £200 million a year in exports. Killing seals should have been banned decades ago. I would not be surprised if in coming months we see fish farmers picketing Parliament with “Save Our Seals & Save Our Jobs” banners. I am disgusted that I have had to use a foreign Government to get protection for Scottish seals. The Scottish Government should be ashamed over their lack of action on this."
The letter from the Scottish Government and e-mails below to the Scottish Cabinet Secretary for Environment, Climate Change & Land Reform should make the situation clear:
From: JFRobins [mailto:john@jfrobins.force9.co.uk]
Sent: 27 September 2016 15:55
To: Roseanna Cunningham MSP (CabSecECCLR@gov.scot)
Cc: Fergus Ewing MSP (cabsecrafe@scotland.gsi.gov.uk); Alasdair Allan (scottish.ministers@gov.scot); Nicola Sturgeon (FirstMinister@gov.scot); Claudia Beamish MSP (Claudia.Beamish.msp@parliament.scot); Mark Ruskell MSP (Mark.Ruskell.msp@parliament.scot); Maurice Golden MSP (Maurice.Golden.msp@parliament.scot); Mike Rumbles MSP (Mike.Rumbles.msp@parliament.scot)
Subject: salmon farming and seals
E-MAIL FROM: John F. Robins, Secretary, Save Our Seals Fund (SOSF), C/O Animal Concern, Post Office Box 5178, Dumbarton G82 5YJ. Tel: 01389-841-639, Mobile: 07721-605521. SOSF is a recognised Scottish charity: RCNo. SC025489. E-MAIL: sosf@jfrobins.force9.co.uk website: http://www.saveoursealsfund.org/
Roseanna Cunningham MSP,
Cabinet Secretary for Environment, Climate Change & Land Reform,
The Scottish Government,
St. Andrew's House,
Regent Road,
Edinburgh EH1 3DG
Dear Cabinet Secretary Cunningham,
Please find attached a letter dated 23rd September which I received from Mr. Ian Walker of Marine Scotland. I think it is in reply to the e-mail (copied below) I sent you on 7th September regarding the forthcoming USA salmon import restrictions.
In his reply on your behalf Mr. Walker makes it fairly clear that the Government does not intend making it illegal for fishery and aquaculture interests to shoot seals. He obviously believes it is up to individual fish farmers to decide for themselves if they want to continue with licensed shooting of seals and not export to the USA or if they want to stop shooting seals and continuing exporting to the USA.
I have been lobbying the US Government on this for five years and it is my understanding that the provisions of the US Marine Mammal Protection Act allow the USA to ban imports from countries whose Governments permit the deliberate killing of marine mammals by fish producers. This was confirmed by statements made by John Henderschedt, Director of the US Government National Oceanic and Atmospheric Administration (NOAA) Fisheries Office of International Affairs and Seafood Inspection.
In an article (link below) in the Sunday Herald on 11th September Mr Henderschedt commented on the forthcoming new import regulation saying; “This rule requires harvesting nations to demonstrate that they prohibit the intentional mortality or serious injury of marine mammals in the course of commercial fishing operations,” He went on to say that countries must have “procedures to reliably certify that exports of fish and fish products to the United States are not associated with a fishery in which intentional killing or serious injury of a marine mammal is allowed,”.
I believe Mr. Walker is wrong in his interpretation of the new US import rules. The onus to take action is on the Scottish Government not individual salmon farmers. If the Scottish Government does not make it illegal for fishery and aquacultural interests to deliberately kill seals then it will be illegal for the United States of America to import any fish and fish products from Scotland. Furthermore the Scottish Government must be able to reliably certify that Scotland does not allow fishery and aquaculture interests to kill seals. Even if all salmon farmers in Scotland decided not to apply for licences to shoot seals they could not export to the States if the licensing system permitting the shooting of seals is still in place.
Once again I urge the Scottish Government to end the seal shooting licensing system and replace it with a law making it a criminal offence for anyone to deliberately kill a healthy seal. In addition I request that legislation be introduced making it compulsory for marine fin fish farms to install and maintain predator exclusion nets to keep seals and other marine mammals far enough away from the inner cage nets to avoid causing alarm and stress to the fish. By doing so fish farmers will finally meet their legal duty to protect their stock as required under the Animal Health & Welfare (Scotland) Act 2006. It will also create new jobs in rural areas as these nets require frequent cleaning and maintenance.
If the Scottish Government fails to at least make the shooting of seals illegal fish farms in Scotland will lose well over £200 million a year in exports to the USA.
I would be grateful Cabinet Secretary if you would please give me your opinion on this matter.
Yours sincerely,
John F. Robins,
Save Our Seal Fund
From: JFRobins [mailto:john@jfrobins.force9.co.uk]
Sent: 07 September 2016 14:04
To: 'CabSecECCLR@gov.scot'
Subject: salmon farming and seals
E-MAIL FROM: John F. Robins, Secretary, Save Our Seals Fund (SOSF), C/O Animal Concern, Post Office Box 5178, Dumbarton G82 5YJ. Tel: 01389-841-639, Mobile: 07721-605521. SOSF is a recognised Scottish charity: RCNo. SC025489. E-MAIL: sosf@jfrobins.force9.co.uk website: http://www.saveoursealsfund.org/
Roseanna Cunningham MSP,
Cabinet Secretary for Environment, Climate Change & Land Reform,
The Scottish Government,
St. Andrew's House,
Regent Road,
Edinburgh EH1 3DG
Dear Cabinet Secretary,
From 1st January 2022 the United States will ban the import of salmon from sources where the deliberate killing of marine mammals is part of the production process.
Since the early 1980s I have lobbied successive Westminster and more recently Scottish Governments in a futile bid to make the killing of seals by salmon farmers illegal in Scotland.
Since 2011 Save Our Seals Fund has been urging the US Government to use existing legislation to ban the import of salmon produced on farms where seals are deliberately killed. After a lengthy consultation period the US has agreed to this and the ban comes into force on 1st January 2022.
The US Government specifically mentions my correspondence regarding the Scottish Government licensed shooting of seals as having influenced their decision to implement the ban.
My argument is quite simple – instead of shooting seals salmon farmers must be legally required to install and properly maintain predator exclusion nets to humanely stop seals getting close to the salmon cages. An alternative is to farm salmon in on-shore seawater tanks.
These systems are expensive to install and maintain but not only do they protect wildlife they create new jobs in rural communities. It has made me extremely angry to see politicians, civil servants and even RSPCA Freedom Foods refuse to force salmon farmers to invest some of their considerable profits to make Scottish farmed salmon seal friendly. It is all the more galling when many of the farms in Scotland are owned by multinational companies which use predator exclusion nets when they are required to do so in other countries in which they operate.
Instead of protecting wildlife the Scottish Government gives salmon farmers licences to shoot seals then leaves shooters to police themselves using a useless honesty box system to report numbers shot. Since licensing was introduced I have argued that it allows lactating seals to be shot leaving dependent pups to die a slow, cruel death from starvation. A few weeks ago an academic report confirmed my concerns and proved the inherent cruelty of the Scottish seal killing licence system.
Once again I ask the Scottish Government to make it compulsory for salmon farmers to use predator exclusion nets and to stop giving out licences to kill seals. Previous Governments did not see the need to protect seals from extreme cruelty as a good enough reason for taking action. Perhaps the need to protect Scottish exports to the United States will be?
Yours sincerely,
John F. Robins,
Save Our Seals Fund
Animals 24-7 reported (29 September):
Read article in full via "U.S. law to save seals in Scotland"
Parliamentary questions filed earlier this week by Mark Ruskell MSP are due to be answered later this month.
Read online here
Read online here
Read more via:
"All At Sea: Seal-Killing Salmon Farms"
"The Two Billion Dollar Salmon Ban"
"Concern as crucial forum for protection of seals abandoned"
"Scottish salmon exports at risk if seals keep being shot"
"Stop the slaughter now"/"Cruelty and pollution have no place in Scotland's waters"
"Sunday Herald: "Scotland's 'trigger-happy' salmon farmers risk losing £200m US export market""
"Seal of Approval for U.S. Ban on Salmon"
"Scottish Sea Farms points to progress in seal management"
"Exposed: the inhumane shooting of hundreds of seals"
"Scottish salmon has five years to cut seal deaths before NOAA action"
"Campaigners claim new NOAA rules could see Scottish salmon banned from US"
"End the slaughter of seals in Scotland now"
"U.S. ban for lethal Scottish salmon- £200 million in exports killed off by seal slaughter"
"Charity makes plea to end seal shooting in Scotland"
"Seal culling in scientists’ crosshairs"
"Staniford calls on RSPCA to drop Marine Harvest, Scottish Sea Farms, SSC"
"RSPCA defend record as anti-seal cull campaigners allege salmon farms are not 'last resort' killers"
Dear RSPCA, please wash the blood of Scottish seals off your hands!
Video Message to the RSPCA – stop the killing of seals on salmon farms!
"Anti-salmon farm campaigners petition Queen over RSPCA’s seal-shooting sanction"
Petition to the RSPCA: End your support for the killing of Scottish seals!
"RSPCA Savaged Over Seal Killing in Scotland"
"Scottish Salmon Blinded by Seal Killing"
"Salmon farmers are shooting seals instead of installing non-lethal deterrents, campaigners say"
"Protests planned as number of seals killed in Scots salmon farms rises by 20 per cent"
"Stop Shooting Seals for Salmon Meals"
"VICTORY: Disclosure of Seal-Killing Salmon Farm Data Ordered by 21 August"
"Scottish Salmon's Secret Seal Killers! – FOI refusal prompts call for boycott of farmed salmon"
"Lethal Scottish Farmed Salmon: Serial Seal Killers Named & Shamed!"
"Scottish Salmon's Seal Killers Named & Shamed!"
Read more documents on ADDs and salmon farms online below:
SNH FOI reply February 2017 online here
SNH covering letter FOI reply April 2017 online here
- Download SNH FOI 25 April 2017 document #1
- Download SNH FOI 25 April 2017 document #2
- Download SNH FOI 25 April 2017 document #3
- Download SNH FOI 25 April 2017 document #4
- Download SNH FOI 25 April 2017 document #5
- Download SNH FOI 25 April 2017 document #5 ADDs NOT used
- Download SNH FOI 25 April 2017 document #5 New version for ADDs only LIST of all sites using ADDs
- Download SNH FOI 25 April 2017 document #6
- Download SNH FOI 25 April 2017 document #7
- Download SNH FOI 25 April 2017 document #7 ADDs used only
- Download SNH FOI 25 April 2017 document #7 Anti Predator Nets only
FOI Backgrounder May 2017 online here
Read a scientific paper presented on 1 May 2017 at the European Cetacean Society conference in Denmark (read abstracts online here):
Read more via an ADD Media Backgrounder (May 2017) online here
Read more via a complaint to the European Commission online here
Read more via a letter to the UK Government, Scottish Government and SNH online here
Read more via Press Release: "Cetaceans Sound Alarm On Salmon Farms – new research sparks EC complaint & call to ban Acoustic Deterrent Devices" (7 May 2017) (PDF version online here)










