Application for licence for an open cage salmon farm at Ballinakill Bay, Co Galway

Dear Minister,

The documentation submitted by Comhlucht Iascaireachta Fanad Teoranta, (CIFT), trading as MOWI Ireland, seeking a licence for an open cage salmon farm to be sited in Ballinakill Bay, County Galway, falls far short of what is required pursuant to Article 6(3) of the Habitats Directive. Nor can there be reliance on Article 6 (4) thereof, as there are no stated ‘imperative reasons of overriding public interest’, (IROPI), which could justify locating a salmon farm at this sensitive location.

The proposed site is within close proximity to the Dawros river mouth. This river forms part of the ‘Twelve Pins Garraun Complex,’ Special Area of Conservation, (Site Code 002031). In this river Wild Atlantic Salmon are a ‘Qualifying Interest.’   Juvenile salmonids, which are already susceptible to mortality from parasitic sea lice from the existing salmon farm in Ballinakill Bay, would be also subject to the cumulative impact of the additional sea lice loading from the proposed MOWI/Marine Harvest salmon farm. No appropriate assessment has ever been conducted in relation to the adverse impact of the existing salmon farm, which is there already. It is suggested that Appropriate Assessment must be conducted on the cumulative effect of both salmon farms before any decision may be reached.

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