Salmon Watch Ireland (SWI) submits that aquaculture licences T05/122 and T05/122A cannot lawfully be renewed. The application by Murphy’s Irish Sea Food fails to meet fundamental requirements under the Habitats Directive, Water Framework Directive (WFD), EIA Directive, and the Nature Restoration Law, and does not remove the scientific doubt necessary to permit authorisation.
Legal Compliance Not Achieved
• Article 6(3) of the Habitats Directive requires no reasonable scientific doubt of no adverse effects on SACs—this threshold is not met.
• Article 6(4) cannot apply: no imperative reasons of overriding public interest (IROPI) exist.
• Under the WFD, any deterioration of High-Status waters is unlawful outside narrow exceptions that are not invoked here.
• Irish case law (Connelly, Kelly, SWI v ALAB) confirms that consent cannot be granted where scientific uncertainty persists.

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