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High Court Case – Judicial Review
The High Court Judicial Review Case involving Salmon Watch Ireland in regard to the granting of a licence by the Aquaculture Licence Appeal Board has finished. The case was conducted over four weeks and involved Salmon Watch along with Inland Fisheries Ireland and Sweetman and others including FISSTA against the Aquaculture Licence Appeals Board and the Minister of Agriculture Food and the Marine. MOWI were listed as a notice party and took an active part in proceedings. The case was held before Judge David Holland and was very complex in nature. It is expected that a reserved judgement may be available in a number of weeks but that final judgement may not be available until July. Overall the case has many complex issues in regard to Irish and European law involving the EIA Directive, Water Framework Directive and the Irish legislation to comply with these European Directives. It is impossible to say if the judgement will be favourable but we must at this point congratulate all parties who brought this Judicial Review in order to protect wild salmonids. We would like to thank our legal team for their work on the matter and look forward to the many issues that may come to the fore in future years.
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Irish Times Article -Tim Mc Cormick
Are Open-Pen Salmon Farms Really Sustainable? Open-pen salmon farms have been encouraged here. But how well do they fit these criteria? Salmon farmers frequently proclaim the sustainability of their industry, claiming that they are eco-friendly and are creating a new blue revolution with their protein rich product. But increasingly their claims are being questioned on the basis of scientific evidence, sometimes from unexpected quarters. In December 2018 Marine Harvest, the world’s largest producer of Atlantic farmed salmon, held an AGM to change its name to MOWI in honour of its founder, Thor Mowinckel. At the meeting an 84- year-old shareholder castigated the company for polluting nature, wildlife’s habitat and ecosystems, while threatening the future of future generations. He wanted to see a move to land-based farms. The speaker was Thor Mowinckel himself. He voted against the name change in protest. Others agree with him, as MOWI found out to their cost. In 2021 they were sued in the USA for “false marketing.” They settled the case for $1.3 million and agreed not to use the terms “sustainable” or “eco-friendly” in their advertising there. Currently MOWI is seeking to construct a large farm in Connemara. The International Experience Open-pen farms have been banned or heavily restricted in many countries, because of the environmental damage they cause. They never existed in English or Welsh waters. They are banned in Denmark, Southern Argentina, and the Pacific States of the USA: Alaska, Washington State and California. British Columbia is transitioning away from them. After a ten-year moratorium, they are now permitted in Chile, but not in protected marine areas. Norway regulates them strictly, fining rule breakers. Licences for sea farms are expensive, while land-based farms are free. A production tax on output was recently introduced. This provides farmers with an incentive to expand overseas, where regulation is lighter. Scotland is facing an increasing clamour for tighter regulation. 2 major recent applications have been Ireland is different. Fish farms are encouraged and subsidised with taxpayer grants. The licencing system is minimal with some farms permitted to stay open, even though their licences are more than ten years expired. The Government is even willing to entertain licence applications in Special Areas of Conservation. The Irish Government is currently drafting a National Strategic Plan for Aquaculture Development 2030. The plan aspires to provide: 1. Nutritious and healthy seafood with a limited environmental footprint. 2. Economic development and job opportunities for coastal and rural communities. 3. A reduction in pollution. 4. Preserve ecosystems and biodiversity. 5. Contribute to the fight against climate change. Healthy Food: Toxic chemicals, used to treat sea-lice can contain pathogens, which contaminate farmed salmon, In Canada and Scotland farmers have been found to use illegal poisons. Artificial colourants change the natural grey flesh of farmed fish into the chosen shade of pink. Nutritionists are concerned about dangers, to children, pregnant women and people with a history of cancer. In general controls are minimal and over-reliant on self-regulation. While there is now much talk about ‘organic salmon farming,’ there is much disagreement about the criteria. Certainly, the product so labelled commands a premium price. It claims to be sustainable. But the fish still need to be produced in cages and treated for disease. It seems bizarre that salmon, which have been chemically treated for sea-lice either directly or through their food and are artificially coloured can be classified as ‘organic.’ Improvements in fish husbandry are welcome, but strict boundaries need to be agreed and properly monitored, a challenging task for the present regulatory system. Environmental Footprint: The environmental issues, excluding pollution, fall under 3 categories: Sea-lice. It has long been known that an infestation of sea lice, which thrive in the cages, poses a serious threat to wild salmon and seatrout. Sea trout, being coastal feeders, are particularly badly affected. In 2019 BBC Panorama showed a wild fish covered with 747 lice and a diver who described the barren seabed and the fish as being “essentially eaten alive.” Farms in Ireland regularly exceed their permitted sea-lice limits. Recent scientific research on Irish rivers, has clearly shown that heavy lice infection during the smolt migration period has resulted in reduced runs of returning adult salmon the following year, ranging from 19% to 46%. The Irish Government chooses to rely on their in-house scientists from the Marine Institute, who downplay the significance of lice, rather than the overwhelming evidence from Norway, Scotland, Canada and, most importantly, IFI, Inland Fisheries Ireland. Escapees’ Risk: Fish farm escapees constitute a serious risk, since they may interbreed with wild fish, while also competing for spawning redds and food. Shortly after 48,000 fish escaped in 2021 from a MOWI cage in Scotland, 17 rivers in Scotland and England reported the presence of farmed fish. Fisheries Management Scotland attributed the majority of them to this MOWI outbreak. Escapees can disperse widely and quickly. The consequences of a major escape are serious. MOWI was fined over $6m in 2020 for an escape of 690,000 salmon in Chile. The watchdog stated that this constituted “irreparable environmental damage.” They found that MOWI had failed to maintain appropriate security standards and had used substandard equipment. They emphasised the risk to the marine habitat from “decomposing mortality,” together with the transmission of pathogens and disease. Disease: Compared to the 3%/5% commonly found in chicken or cattle farming, mortality in fish farming is high, estimated at 40% in Ireland. It seems that our warm waters help to spread disease commonly found in cages quickly. Pollution: Open-pen farms can be compared to a town with no sewerage system. The faeces, surplus food and chemicals drop to the seabed, which becomes barren under the cages. They are rarely adequately dispersed by tides, becoming a hazard to the surrounding marine life. The scale of pollution is serious. The Scottish National Trust estimates that the untreated pollution of a 2,500-tonne farm equates to that of a town of 16,000 people, where the sewerage is, of course,treated. The community bears all these environmental costs, estimated by one economist as 40% of total costs, while the polluter avoids payment. The revenue, meanwhile, usually flows to large foreign multinationals. Employment: Full time employment in existing farms has been declining in recent years, probably due to increased automation and new job creation has sometimes been exaggerated. If inshore fishermen are deprived of their livelihood, there may be no net increase in employment. On the east coast of America local shell fishermen with strong local support successfully opposed major pens off the coast of Nova Scotia and off Maine. Pollution and unsightly cages must also damage employment in both angling tourism and tourism generally. Ecosystems and Biodiversity: The most serious ecological charge against open-pen farms is that they are endangering the dwindling population of wild salmon. Irish salmon numbers have declined by almost 80% in the last 20 years. Open-pen farms also devastate areas of the seabed, out of sight, except to divers, destroying shellfish and other marine life in the vicinity of the cages. As Tasmania has now discovered, its ocean floors have become increasingly barren, birdlife vanishes, and rare fish are threatened with extinction. The use of fish meal and salmon oil from wild fish is highly controversial, seriously damaging the food chain. Salmon feed involves dredging enormous volumes of small wild fish. Consequently, the fish population in third world countries from West Africa to Peru have been seriously reduced, depriving the population of an important source of food and their fishermen of their livelihood. Climate Change The industry has a significant carbon footprint, especially with transportation. It also seems that our warmer waters make us more exposed to algae bloom, gill infection and aggressive jellyfish, which enter the cages. In a Bantry Bay farm there were around 100,000 deaths in 2021, due to an outbreak of algal bloom. Shallow coastal water makes them vulnerable to the rapid spread of pollution and disease. In an era of global warming this situation is unlikely to improve. Climate change can only exacerbate the problems. The industry may change. There are now at least 75 land-based projects in the planning stage, under construction or already in operation. New Zealand is joining Maine, Florida and Wisconsin in the US, as well as Switzerland, Dubai, China and Japan. Thor Mowinckel must be pleased. But open-pen salmon farms fail to meet any of the criteria set out in our National Strategic Plan for Aquaculture and should not form part of our future aquaculture industry. Published in the Irish Times, February 2023.
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Deenish Island – Waterville Sea Trout Collapse Continues
The prospect of the Salmon Farm at Deenish Island being restocked with over 400,000 smolts in the coming weeks should fill anglers and conservationists with dismay and anger. The farm was ordered to close by the Minister for Agriculture, Food and the Marine in April 2019 for gross over harvesting at the site. The MOWI owned farm which is less than nine kilometers from Lough Currane has always been a strong source of controversy regarding its effect on sea trout and salmon stocks. Marine Institute Hydro Study - Extent of particle distribution from Deenish Island Site - This is strongly linked to distribution of sea lice larvae A Tragedy for Watervilles Salmon and Sea Trout The appeal mechanism being relied upon by MOWI included a judicial review in the High Court which was adjourned to allow the appeal go to the Aquaculture Licence Appeals Board. This board has had over three years to make a determination but has failed to do so and will not do so before September 2023. This is a disgraceful scenario which effectively allows the farm to continue operations pending a determination of their appeal. The Aquaculture Licence Appeals Board in this case appear to be acting in the interests of MOWI with little regard for the wild salmon and sea trout resource in Waterville. It is interesting to note that there is now no wild fish representatives on this board and we strongly suggest that the board has little interest in wild salmonids and has demonstrated this by their abject failure to reach a timely determination. Meanwhile sea trout stocks are now extremely poor and the prospect of recovery is being eroded with each passing year. The upcoming stocking at the site will effectively allow the continuation of this tragic outrage for a further two years. It is time that the independence of this board is strongly questioned. Being financed and effectively controlling its composition, the Department of Agriculture, Food and Marine has also serious questions to answer. We will be appending this note to our EU Complaint to demonstrate the serious malpractice evident in the workings of ALAB and DAFM. We are asking our supporters to send this link to their local representatives and ask their assistance in bringing this situation to a positive conclusion which favours the vastly important sea trout and salmon resource in Waterville County Kerry. Further Information available in following links: Deenish Island – Salmon Watch Ireland Submission – ALAB Deenish Island – Contradictory and inaccurate records reveal a shocking story Update on Deenish Island Salmon Farm Salmon Farming:Complaint to the Commission of the European Communities about the Government of Ireland’s failure to comply with Community law.
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Salmon Hero Award 2022 – Coomhola Salmon Trust
Mark Boyden receiving the Salmon Hero 2022 Award from John Murphy, Chair Salmon Watch Ireland The very mention of Atlantic salmon in a primary school in Ireland garners the immediate response "Streamscapes" which is the first port of call for educators all over Ireland in matters relating to our rivers and freshwater resources. The excitement generated by the original "Streamscapes" publication among young students is testimony to how the natural world invigorates and excites and this brainchild of the Coomhola Salmon Trust was and still is a beacon of how much this resource was ahead of its time and indeed is still as relevant today. Not confined to Atlantic salmon, Mark Boyden and his team have built an unprecedented educational resource to actively educate school students, community groups and the general public on all matters relating to water quality and the general well being of our freshwater resources. In existence since 1989, the Coomhola Salmon Trust has over the years instilled a life long impact on all its students and community groups in regard to nurturing a respect for Ireland's aquatic and biodiversity heritage. Coomhola Salmon Trust certainly encompasses what all groups interested in the natural environment should aspire to. ENGAGE -ENLIGHTEN - EMPOWER Salmon Watch Ireland is delighted to award the "Salmon Hero Award" to the Coomhola Salmon Trust for 2022 in recognition of their inspirational and lifelong devotion to protecting Ireland's aquatic and biodiversity resources. We cannot recommend more highly the resources and practical innovation that the Trust has demonstrated over the last three decades and would strongly suggest that all parties interested in preserving Ireland's natural resources learn more about this truly unique project. Coomhola Salmon Trust has a myriad of educational publications and has always been at the forefront of protecting Ireland's nature and biodiversity. Coomhola has also a freshwater aquarium built from the unique landscape of the Coomhola catchment which is integrated with the Coomhola River. All the resources can be accessed at Streamscapes Resources and Publications A Selection of Publications from Coomhola Salmon Trust To access more about streamscapes please click on following link: Streamscapes Website
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Recent Scientific and Telemetry Studies concerning Atlantic Salmon
Salmon Watch Ireland endeavors to keep our support base informed of scientific studies concerning ecological changes in both freshwater and in the marine phase of the Atlantic salmon life cycle. To this end we are initiating a periodical posting which examines such diverse topics as predation, marine ecosystem change , impacts of salmon aquaculture on wild salmonids and freshwater changes resulting from a changing climate. This posting examines the changing marine environment and how these changes may impact on salmon survival at sea. There is also some interesting video content which examines telemetry and highlights the work carried out by the salmon research station on the River Bush. Distribution shifts of marine species The first study does not specifically relate to Atlantic salmon but does demonstrate that with a warming ocean certain movements of phytoplankton, zooplankton and fish are occurring with an anticipated negative effect on Atlantic salmon from Ireland and UK in particular. We are currently nearing the southern limit of Atlantic salmon distribution with stocks severely depleted further south. Increases in regional sea temperatures have triggered a major northwards expansion of warmer water plankton and a northwards retreat of colder water plankton in the North-east Atlantic. This northerly movement has amounted to about 10 ° latitude (1 100 km) over the past 40 years, and it seems to have accelerated since 2000. Sub-tropical species are occurring with increasing frequency in Europe’s seas, and sub-Arctic species are receding northwards. Wild fish stocks are responding to changing temperatures and food supply by changing their distribution. This can have impacts on those local communities that depend on those fish stocks. Further changes in the distribution of marine species, including fish stocks, are expected with the projected climate change, but quantitative projections of these distribution changes are not widely available. Distribution shifts of marine species — European Environment Agency (europa.eu) Atlantic salmon in a rapidly changing environment—Facing the challenges of reduced marine survival and climate change. This study concerns management actions that are required to address decreasing survival indices for wild stocks Atlantic salmon populations have declined in recent decades. Many of the threats to the species during its freshwater and coastal residency periods are known, and management approaches are available to mitigate them. The global scale of climate change and altered ocean ecosystems make these threats more difficult to address. Managers need to be aware that promoting strong, healthy, and resilient wild populations migrating from rivers is the optimal approach currently to reduce the impacts of changing ecosystems and low marine survival. We argue that a fundamental strategy should be to ensure that the highest number of wild smolts in the best condition leave from rivers and coastal areas to the ocean. There is great scope for water quality, river regulation, migration barriers, and physical river habitat improvements. Maintenance of genetic integrity and diversity of wild populations by eliminating interbreeding with escaped farmed salmon, eliminating poorly planned stocking, and reducing impacts that reduce population sizes to dangerously low levels will support the ability of Atlantic salmon to adapt to changing environments. Reducing the impacts from aquaculture and other human activities in coastal areas can greatly increase marine survival in affected areas. As most of the threats to wild salmon are the result of human activities, a focus on human dimensions and improved communication, from scientific and management perspectives, needs to be increasingly emphasized. When political and social will are coupled with adequate resources, managers often have the tools to mitigate many of the threats to wild salmon. Atlantic salmon in a rapidly changing environment—Facing the challenges of reduced marine survival and climate change - Thorstad - 2021 - Aquatic Conservation: Marine and Freshwater Ecosystems - Wiley Online Library Impacts of a Changing Ecosystem on the Feeding and Feeding Conditions for Atlantic Salmon During the First Months at Sea The second study is very relevant to Ireland as there are strong indications that post 2007 contents of smolt stomachs off the west coast of Ireland were seriously impacted. This factor may have contributed to decreased marine survival which appears to have accelerated after 2007. It is important to understand that if post smolts do not gain adequate feeding on leaving our shores, they are more likely to be predated as size is very important in their first period at sea. There should also be alarm at present trawling activities may also be affecting near coastal ecosystems. West of Ireland and Scotland "The dominating prey were sand eel and fish from the cod family. The years with the lowest FR values were 2008 and 2009, which were the last 2 years with data sampling in the region. In contrast to previous years, gadoids and sandeel were in general absent from the diet these 2 years, even though the small proportion of unidentified fish larvae could belong to these groups." https://www.frontiersin.org/articles/10.3389/fmars.2022.824614/full ICES Report to North Atlantic Salmon Conservation Organisation 2022 This report is a comprehensive overview of the status of Atlantic Salmon. There are some very relevant points raised concerning the impact of Pink Salmon. A long read but well worthwhile to understand the many challenges facing Atlantic salmon. Full Report: Working Group North Atlantic Salmon The following video illustrates a behind the scenes look at the River Bush research station in Northern Ireland which includes the use of telemetry to conduct their important research.
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Two Government departments are at odds over regulation of salmon farms in the Republic. Just a small piece of the extensive articles in today’s Irish Times written by Kevin O Sullivan, Environment and Science Editor and former editor of The Irish Times. Well worth a read and it clearly states the differing opinions regarding salmon farming. We fully support the position of the Department of Environment, Climate Change and Communications and Inland Fisheries Ireland. The Department of Agriculture Food and Marine and the Marine Institute are way out of line with international norms and are clearly green washing the salmon farming industry. Time for a seismic change in policy. Clear divisions have emerged in an exchange of letters between Minister for the Environment Eamon Ryan and Minister for the Marine Charlie McConalogue. In a letter released under Freedom of Information legislation, Mr Ryan accuses Mr McConalogue’s department of operating an aquaculture licensing regime with flawed assessment of fish-farm sites and their potential impact on wild salmon and sea trout. These two species are in sharp decline in Ireland with sea lice from fish farms implicated in their demise. It is understood that Attorney General Paul Gallagher has intervened with the departments to express disquiet at the stand-off over how licence applications are assessed and to underline the need for a resolution. The opposing views are mirrored by a stand-off between two State agencies involved; the Marine Institute, which advises Mr McConalogue on all applications, and Inland Fisheries Ireland (IFI), which is responsible for the protection and conservation of freshwater fish and their habitats. Mr Ryan said the Department of Agriculture, Food and the Marine (DAFM) in assessing applications was over-reliant on an incorrect interpretation of a small number of Marine Institute studies, which run contrary to the main thrust of international peer-reviewed scientific opinion. Mr McConalogue, in his 10-page response, insisted the regulatory regime is fully compliant with the State’s environmental obligations and that “appropriate assessments” are carried out correctly by the Marine Institute. He also robustly defended the way sea lice levels are monitored. Salmon Watch Ireland, which obtained the correspondence, has called for an overhaul of the licensing regime. Its director John Murphy described the stand-off as “an astonishing difference of opinion between two Government departments”. In response to the exchange of letters, the Marine Institute said as scientific advisers to DAFM, it “is fully engaged in the process of providing scientific advice as part of the regulatory system in place in the licensing of aquaculture. The function of this is to develop the aquaculture industry in a sustainable way.” It added in a statement to The Irish Times: “The process of assessment of aquaculture licences for salmon farms is a matter for DAFM. The role of the Marine Institute as scientific advisors is to oversee and/or prepare a report on the appropriate assessment [AA] process and to submit these reports to DAFM as part of the licensing determination process.” ‘Development activities’ The institute’s advisory inputs, it said, “are in line with best practices worldwide” and its scientists “take great care in discharging their responsibilities towards all conservation, protection and development activities in the natural environment”. The clear intention for the AA report prepared for Kenmare Bay was to determine shellfish aquaculture licensing only, it underlined. “It was not sufficient nor was it intended or proffered to enable determination of marine finfish applications [including salmon]. No finfish licensing was determined on the basis of this AA report. Any such applications would be subject to a full AA process specifically focused on finfish [salmon].” On Mr Ryan’s contention that DAFM was over-relying on an incorrect interpretation of a small number of Marine Institute studies which run contrary to international peer-reviewed scientific opinion on impact on wild salmonid stocks, the institute said: “There is an absence of clear evidence exclusively linking sea lice with high mortality rates. International organisations, including ICES (International Council for the Exploration of the Sea) have stated further research is needed to investigate the connection between sea lice infestations and effects on wild salmonids. “Irrespective of the unresolved scientific position, the fact that Ireland has operated an independent national sea lice monitoring programme for nearly 30 years with clear management measures in place, reflects the seriousness which the State takes to any risk posed by sea lice on our wild salmonid populations.” Kevin O'Sullivan
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A rather unique and interesting point of view – Regenerating our salmon and rivers by Nicholas Grubb.
This article encompasses many aspects which Salmon Watch Ireland agree with especially the management of riparian zones. It is an interesting submission which should help to garner an understanding of the many issues prevalent in Ireland regarding the ecosystem management of our river systems. It is interesting to note that management is almost non existent on all our river systems. While ownership of fishery rights are by and large fragmented there is an onus on all interested parties to work together to put in place a professional fishery and ecosystem management system especially on our rivers which produce the majority of smolts. We would also suggest that barriers should be improved to allow easier migration but also agree that large deep water sections may be appropriate in certain rivers. A changing climate scenario is fast approaching and our rivers need sympathetic and ecosystem friendly approaches to improve or indeed protect salmonid productivity. This is a very thought provoking article and the author should be congratulated for his long time unique interest and activism in conservation matters. Dromana House - Lower Blackwater, County Waterford Read More
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Vincent Duigan – An Appreciation
The board and members of Salmon Watch Ireland wish to sympathise with the family and friends of Vincent Duigan who died unexpectedly in January this year. It came as a great shock to learn of his untimely death. Our association with Vincent was principally concerned with the plight of wild Atlantic salmon and his knowledge and enthusiasm was hugely beneficial to Salmon Watch in our endeavours to protect wild salmon. He was also a valued friend. For many years Vincent was involved with the Slaney River Trust, the very first such organisation in Ireland. With his engineering background, he was particularly interested in the operations of turbines and their damage to the migrating salmon and was at the forefront in trying to rehabilitate that great river. Vincent was instrumental in setting up the original South East Salmon Federation in 2003. This quickly led to the formation of Stop Salmon Drift Nets Now in 2004. After the removal of drift net fishing at sea at the start of 2007, the organisation changed its name to Salmon Watch Ireland to be a voice for Atlantic salmon and Vincent had been a valuable board member all the way through. He fished all over Ireland but had a particular love of the Moy and his own beloved Slaney. He always spoke highly of all the great people he met along the waters of Ireland, and it is safe to say that his presence will be greatly missed by all his friends. The board and members of Salmon Watch will miss him greatly. Our sympathies to his sons Joe and Alan. Ar dheis Dé go raibh a h'anam dílis
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Ballinakill Salmon Farm- Submission
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. Read More - Full Submission
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Management of Tagging System – Submission
The submission from Salmon Watch Ireland in regard to the management of the Salmon and Sea Trout tagging system seeks to offer more protection to spring salmon. To this end SWIRL have suggested some targeted solutions which will effectively conserve salmon. It is essential that commercial salmon fisheries do not exploit spring salmon and that recreational anglers reduce exploitation on these ecological valuable fish. A general tightening of the tagging system is warranted and we have suggested a number of administrative changes to help and streamline the system. It is imperative that we move to a real time online system to guage how stocks are performing. The issue of recreational and commercial exploitation must reflect on how the magnitude of the surplus is related to the conservation limit. It is imperative that the traceability of wild commercially caught salmon is improved to tighten quota compliance. Our policy would also support a moratorium on commercial exploitation especially on rivers with a relatively low surplus. In the longer term with continued fluctuation in survival indices it may be pertinent to examine the issue of commercial exploitation and indeed recreational exploitation with a view to reducing exploitation. There would appear to be a very limited scope going forward to allow the continuation of a commercial fishery and Salmon Watch Ireland is supportive of a scheme to alleviate losses to the commercial sector. Read the full submission here
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