Here under text of additional submission sent to the Aquaculture Licence Appeal Board. The submission was also forwarded to the Department of Agriculture, Food and the Marine, Department of Communications, Energy and Natural Resources and Inland Fisheries Ireland for further comment and investigation.

AP1-2019(Site T6/202)

Dear Sir,
With reference to appeal AP1-2019(Site T6/202) to ALAB by MOWI Ireland, Salmon Watch Ireland would like to submit additional information which might aid ALAB in coming to a decision regarding this matter.

Salmon Watch Ireland has successfully appealed the decision by the Marine Institute not to release stocking information regarding the Deenish Island Salmon Farm in County Kerry. The Marine Institute has on the 6th August 2019 released information concerning the stocking of the Deenish Island site. It is apparent that the statement issued to ALAB by MOWI regarding the stocking of the site in 2019 is inaccurate and that anomalies exist in stocking data for 2015.

Salmon Watch Ireland would like to draw attention to the following paragraph in the appeal to ALAB lodged by MOWI.

“Mowi Ireland has fully complied with this season's input of juveniles which took place in February 2019. The current stock at Deenish totals circa 385,000 young fish (at 180g average weight), which is below the limit in condition 2(d). The existing wording of the Licence allowing stocking and "harvesting" on an annual basis is environmentally unsustainable”

 According to MOWI reports released to Salmon Watch Ireland the stocking of smolts in 2019 amounted to circa 507,000 which are not consistent with condition 2(d) of their existing licence. This is an overstocking by over 107,000 fish or approximately 27% over the maximum permitted under the licence. Salmon Watch Ireland would also reiterate that stocking on an annual basis is not mentioned or contained in the conditions attached to the licence. Marine Institute Released Movements Deenish.

It is also evident that stocking which took place in 2015 requires further investigation by ALAB and DAFM as there are three different figures for this particular year with the Marine Institute, Aquafact and the Marine Engineering Division of the Department of Agriculture, Food and the Marine (‘DAFM’) all showing different stocking levels.

 The figures released to Salmon Watch Ireland by the Marine Institute reflect a stocking figure of 785,000 smolts in 2015 comprising 400,000 smolts @ 110g average weight stocked December 14 and 385,000 @95g average weight in March 2015.The total weight of smolts inputted to Deenish in this period would, therefore, on the basis of these reports have been of the order of 80.57 tonnes. Marine Institute Released Movements Deenish

 The Marine Engineering Division (‘MED’) file shows that stocking records provided by MOWI (following an engineering inspection of the site by MED) reported the stock on site in January 2015 to be 222,999 juveniles @ 40 g average weight. MOWI also reported that there were 738,458 fish with an average weight of 0.339kg in the site at the end of May 2015. The Marine Engineering inspection took place in July 2015. Marine Engineering Report 2015

 Aquafact (who are contracted by MOWI to undertake benthic inspections of their sites) noted in the Benthic Report of 2015 that, between 23rd January 2015 and 15th March 2015, 87.84 tonnes of salmon were inputted to the site. There is no mention of the December 14 input as specified in Marine Institute records. Aquafact Report 2015

 The 222,999 juveniles (Average Weight 40g) mentioned in the MED report of 2015 are absent from the records released by the Marine Institute. These fish equate to a weight of 8.9 tonnes. Are these fish part of the 87.84 tonnes as reported by Aquafact? Did the Marine Institute grant a fish health authorisation for these fish? Marine Engineering Report 2015

It is evident that the stocking levels set out in these reports for 2015 cannot be reconciled, are inaccurate and cannot be trusted. It would appear on the face of it that MOWI has and is continuing to mislead DAFM and ALAB.

In our original submission we requested permission to submit additional material when it came to hand. In the interest of transparency Salmon Watch Ireland requests that this submission be accepted. We also intend to furnish this submission to DAFM, Inland Fisheries Ireland and Department of Climate Action, Communications and Environment for further investigation.

Salmon Watch Ireland
13 August 2019