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E-MAIL FROM: John F. Robins, Campaigns Consultant, Animal Concern, Post Office Box 5178, Dumbarton G82 5YJ. Tel: 01389-841-639, Mobile: 07721-605521. Fax: 0870-7060327. Animal Concern incorporates the Scottish Anti-Vivisection Society which has been Campaigning for animals since 1876
E-MAIL: animals@jfrobins.force9.co.uk    website: http://www.animalconcern.org/

Monday, 27 October 2014

Message to Members and Supporters of Animal Concern, Animal Concern Advice Line and Save Our Seals Fund.

A few things for your information.


In the spring, resplendent in my Save Our Seals Fund sou’wester, I addressed the Scottish Parliament Petitions Committee on my Petition number PE1519 which called for a stop to the issuing of licences to shoot seals in Scottish waters, mandatory seal exclusion nets on salmon farms or a move from marine farms to onshore tank systems and closure of all wild salmon netting stations.  12,214 people signed the petition and after my presentation the Petitions Committee agreed to take it further and invited other interested bodies to respond to the petition. Government Department Marine Scotland and their Special Committee on Seals (SCOS) made separate responses and the Scottish Salmon Producers Organisation also made a submission.  Interestingly there was nothing from the Scottish Salmon Netsmen’s Association.

Marine Scotland and the SSPO were, to say the least, not keen on the petition but there was a very interesting statement in the submission from the Special Committee on Seals. Regarding the law which allows the shooting of seals they stated; “……. the Act does say that shooting should be a last resort, but often net tensioning and other options to prevent or reduce seal-human conflict, such as acoustic deterrent devices (ADDs) are not implemented because of the costs involved.” After years of hearing Marine Scotland and Scottish Government Ministers recite the mantra “Seals are only shot as a last resort” it was great to hear a Government advisory committee agreeing with me that shooting is not by any means only used as a last resort.”

I have made a further submission to the Petitions Committee to refute much of what was said by Marine Scotland and the SSPO and to correct some errors in the briefing paper prepared for the Committee by the Scottish Parliament Information Centre.

The Committee will consider Petition PE1519 and the recent submissions when it meets tomorrow, Tuesday 28th October. The meeting starts at 10am and Petition PE1519 should be discussed at circa 11am. You can read the submissions via this link:

You can watch proceedings live on your computer/smart phone/tablet/ on this link:   http://www.scottishparliament.tv/?vid=live-committee-room-1 

Following the Meeting the outcome for our petition will be posted here: http://www.scottish.parliament.uk/GettingInvolved/Petitions/sealshooting 


For many years myself and others have been calling on the Scottish Government to take action to protect wild seatrout and salmon from the sealice infestations caused by filthy floating factory fish farms.

When you imprison an unnaturally large number of salmon in floating cages you give sealice a free feast and the numbers of these blood sucking parasites explodes. The sealice attack wild fish which come near the fish farms. When you allow intensive salmon farms to be placed near the mouths of salmon and seatrout rivers the sealice attack the young wild fish as they migrate to the sea from the fresh waters of their birth. The huge numbers of lice can literally overcome the young fish and eat them alive. Numbers of salmon and seatrout returning to rivers on the West Coast of Scotland have dropped dramatically since the commencement of intensive salmon farming.

We asked various Governments to ban salmon farms near river estuaries and for a move away from marine fin fish farming to enclosed on-shore farming in ponds and tanks where there would be no problem with sealice. Successive Governments told us there is no hard evidence that salmon farms cause increased sealice numbers or in any way pose a risk to wild seatrout and salmon. Although Governments change every four or five years and Government Ministers more often than that the Civil Servants who quietly supply the Ministers with information do not.

In March this year a senior Government fisheries scientist, Dr. Richard Shelton, former head of the Government’s Freshwater Fisheries Laboratory wrote a letter to Andrew Thin, Chairman of the Government funded Freshwater Fisheries Review, in which he stated that he and his colleagues have known since 1989 that salmon and seatrout populations on the west coast of Scotland are being adversely effected by sealice from salmon farms.

This flies in the face of public statements issued by Government Ministers so, wearing my best Animal Concern bunnet, I tried to discover if, as Dr. Shelton’s statement suggested, the Government had been receiving but refusing to act on advice confirming there was a major problem with sealice from salmon farms causing damage to wild fish stocks.

I sent off a Freedom of Information request to try and find out if Government Ministers had been ignoring advice from their expert advisors. The Scottish Government identified 17 documents relevant to my request but refused to release them saying;

“We recognise that there is a public interest in disclosing all of the information as part of open, transparent and accountable government, and to inform public debate. However, in relation to the free and frank policy advice there is a greater public interest in ensuring high quality policy and decision-making, and in avoiding officials being put off providing similar frank advice on this and other topics in future. Ministers and officials need to be able to consider all available options to fully understand their possible implications. Their candour in doing so will be affected by their assessment of whether these discussions about sea lice and marine salmon farms in Scotland will be disclosed in any future policy decisions on the matter, so release of this information would be likely to undermine the quality and level of detail of advice on the subject which is provided in future.”

In other words they would not tell me whether or not Government was ignoring the advice from the civil servants in case telling me would make it less likely that civil servants would give Ministers advice in future! 

I appealed the decision to refuse my FOI request but Government failed to respond in anything like the time allowed and I complained to the Freedom of Information Commissionaire who upheld my complaint over the delay in response. Strangely, after ignoring my request for over a month, Government finally replied within a few days of my complaining to the FOI.

Government reconsidered and gave me 12 of the documents they had identified. However most are so heavily redacted that they make no sense. I’m thinking of making another FOI request to find out what brand of black felt pens the Scottish Government buys. Judging by the amount of black ink obscuring the details on the documents I received it would be worth buying some shares in the supplier of the black marker pens.

I have asked the Scottish Information Commissionaire to investigate the refusal by the Scottish Government to give me all the information I requested and I await her ruling on this.


A few weeks ago I donned my Animal Concern Advice Line mortar board and asked you to make submissions to the Scottish Government Consultation on giving extra powers to the Scottish SPCA. The submissions have now been published and are under consideration. You can view them here: http://www.scotland.gov.uk/Publications/2014/10/8427/downloads 

The first few are from folk wanting to remain anonymous but if you scroll down you will find submissions from named individuals and organisations.

I also strongly recommend you read the very interesting and illuminating article here:   http://raptorpersecutionscotland.wordpress.com/2014/10/26/sspca-consultation-responses-the-hypocrites-laid-bare/ 

If you are not already on the Raptor Persecution Scotland e-mail list you might want to sign-up. It costs nowt and will supply you with loads of info on raptor persecution throughout the U.K..

That’s me off to deal with the case of a crofter who appears to have gone into a rather novel but extremely concerning diversification project by replacing his sheep with very big cats.

More about that later.

Cheers 4 now,


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