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Are you asking about the stock in biomass?

Charles Allan might want to come in on that.

Ultimately, that is a matter for SEPA to determine, based on the information and evidence that it has.

We have touched on a lot of the modelling work that is done before licences are issued. On top of that, there is the monitoring that happens. I understand that SEPA would undertake that on the basis of the level of risk. If that level of monitoring is what SEPA believes that it needs in order to ensure that businesses are complying with the regulations, ultimately, that is for SEPA to decide, as SEPA holds all the information and is the one undertaking all the monitoring work.

That would be a matter for SEPA to determine, based on the information that it had and on the monitoring and surveillance that had already been undertaken.

I believe that it would be consistent with that recommendation. We cannot underestimate the amount of monitoring and surveillance that would be undertaken on top of such visits. As Charles Allan touched on in his evidence to the committee on 12 June, enforcement is the end but the critical point of enforcement is compliance and ensuring that businesses comply with the regulations that are in place.

A number of steps can be taken in relation to enforcement action. I believe that, between the initial modelling that is undertaken and the monitoring and surveillance that SEPA undertakes, we have the right systems in place to enable enforcement and that any enforcement action that is taken is proportionate.

Individually, fish farms must be able to operate within environmental limits, otherwise licences would not be granted. I again come back to the important pieces of work that have been undertaken since the previous committee’s inquiry. We have talked about the overall finfish framework that SEPA introduced in 2019 and its implementation. There is also the further roll-out of the sea lice framework, which will take place over a period of time.

Between those exercises, we can identify the areas where there are challenges. That comes back to the work that Jill Barber touched on earlier, and which the committee may touch on later in its questions about the consenting task group and the work that it is taking forward. Ultimately, we are looking to guide development to the right places. That is what we are trying to achieve through those frameworks and through this work. Some of that work is at the initial stages, but that is the general direction.

Yes.

First, I challenge the point about overall progress on recommendations. As I have outlined, a significant amount of work has been done across a number of areas to address some of the recommendations, and some of that work is on-going.

On the committee’s recommendation 3, which was on the call for a moratorium, I hope that the committee would not agree to that if the issue came up again today. Throughout the various sessions that the committee has had, we have outlined the complexities that exist around the issues of mortalities. The situation has not been helped by the data issues that we have talked about, such as how the data is recorded, how it is expressed and the reasons for which it is collected by different organisations. The data is transparent and out there, but we have to recognise that what is important is what is causing the mortality and that we are taking action to address it.

If there was a moratorium on new businesses, we would be penalising the industry. Some issues are beyond its control. All the work that we are undertaking through the sea lice risk assessment framework and the new framework that SEPA has introduced is about guiding the development to the right places. That work has been really positive and is achieving that aim.

Ultimately, given all the environmental concerns, if a fish farming business wants to get started, it has to go through the process and show that there will not be an environmental impact. All the work that is done on modelling and all the advances that have been made on that are critical. I believe that we have the right regulations in place for the industry to deal with challenges where they exist, but it is important to recognise the sheer volume of work that is going on and the work that the industry is doing to invest in all the key issues to try to address them.

I believe that the data that we hold is robust. In his previous evidence to the committee, Charles Allan outlined the various reasons for the level of no counts, but if it looked as if it were going to be an on-going or persistent issue, I would of course see what more could be done. However, I believe that we are in receipt of the data that we need.

I do not know whether officials have further information on the science that has been used on that. What is important is the control of medicines and any chemicals that are put into the environment. As Jill Barber discussed earlier, all of that is considered at the start of a process to ensure that any chemicals or medicines are used within environmental limits.

The Veterinary Medicines Directorate publishes the levels of antibiotics use, and there has been a significant fall—more than 50 per cent between 2020 and 2021—in their use, which is not widespread across the industry. Antibiotics were used in just over 8 per cent of marine sites. All of that information is published.

I do not know whether there is any further information that my officials would like to add.