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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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Judicial Review – Update
The Judicial Review against the decision by the Aquaculture Licence Appeal Board to award a licence for a salmon farm at Shot Head is progressing well. While we do not as yet have a date for hearing a number of important issues have been dealt with. On the 29th November a request was put forward by Bradan Teo Fanad trading as MOWI Ireland to move the case to the Commercial Court for hearing. This was subsequently allowed by the presiding judge. We await further hearings on 02 February 2022. Proceedings dealt with by the Commercial Court must have a commercial dimension and generally must have a value of not less than €1m. MOWI Ireland are effectively claiming that they are at a loss which has a value in excess of €1m and thus their application to enter the commercial court. We will update you on a regular basis post 02 Feb 2022.
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COP 26 – Salmon School
Salmon and COP26 Wild salmon are a majestic symbol and indicator of the health of our rivers, land, and oceans. They range across nearly half the planet. But climate change and other human impacts are driving them towards extinction. Investing in community-driven approaches to save wild salmon will help us limit global warming to 1.5°C and help communities adapt to near-term climate change. Salmon School embodies the local work on river systems worldwide to restore salmon and the cold, clean water they need—from the River Clyde in Glasgow to the outermost reaches of the Arctic. Here is how safeguarding salmon can help achieve the four goals outlined in the 2021 United Nations Climate Change Summit (COP26). The following initiative at COP 26 SEEKS TO HIGHLIGHT THE PLIGHT OF WILD SALMON IN A CHANGING CLIMATE. Take the time to get involved. There is little doubt that climatic change has and will substantially change wild salmon survival here in Ireland. The Salmon School
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Shot Head – Bantry Bay
Salmon Watch Ireland is extremely disappointed with the decision of the Aquaculture Licensing Appeal Board decision to grant an aquaculture licence to MOWI for a new salmon farm at Shot Head in Bantry Bay. Our initial evaluation of the Board's decision points to a lack of knowledge and indeed understanding of the European Court of Justice standard of the ‘best available scientific knowledge in the field ” regarding the impact of sea lice on wild salmonid populations. The decision is counter to the recent and very welcome intervention of the EU delegation at the recent North Atlantic Salmon Conservation Organisation conference in June 2021 which stated that: Parties/ Jurisdictions should consider adopting a policy of phasing out open net pen salmon aquaculture over a specified period or licence term and restrict any new licences to those utilising alternative technologies in order to make significant progress towards achievement of the International Goals for sea lice and containment. This policy should be prioritised in sensitive areas such as the estuaries of Class I salmon rivers or salmon rivers in Special Areas of Conservation. The reliance of the industry and ALAB on scientific material provided by the Marine Institute which has consistently downplayed the impact of sea lice from salmon farms on wild salmonids is alarming. The Marine Institute as part of the Irish delegation to NASCO and thus part of the EU delegation must now explain why the institute is lending support to the open net salmon farming industry in Ireland while being supportive of EU policy to NASCO regarding the phasing out of open net salmon farming in order to protect wild salmonids from sea lice and escapees. Salmon Watch Ireland will examine in detail the determination by ALAB before deciding our next course of action.
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Fish Farming Licence – Warning to Department
Salmon Watch Ireland has issued a letter to the Assistant Principal Officer of the Department of Agriculture Food and the Marine to convey our intention of objecting to the renewal of salmon aquaculture licences or the granting of new licences. Our focus is on the inadequacies of the Appropriate Assessment process which is essentially not addressing a number of issues regarding the impact of salmon aquaculture on wild salmon. The impacts of the transfer of pathogens to wild salmon has not been properly addressed nor has the impact of escapees on genetic diversity of wild salmon stocks. The reliance of the Department on a narrow band of scientific studies carried out by the Marine Institute in regard to the impact of sea lice on wild salmon is at odds with the European Court of Justice judgement which requires that " the best available scientific knowledge in the field " be used when carrying out Appropriate Assessments. Salmon Watch Ireland will exhaust all legal avenues to achieve our aim of conserving wild Atlantic salmon. Read the full text here: https://drive.google.com/file/d/1y8w-J1xMJeM-4wa6ccrMe5vyB9tT79vw/view?usp=sharing
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Seaspiracy
This film is available on Netflix. It is well worth watching and demonstrates the appalling situation regarding fish farming and the unsustainable way we treat our oceans. Film is fully available on Netflix. Seaspiracy https://www.youtube.com/watch?v=1Q5CXN7soQg
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Salmon Farming – Exposed Scotland’s Appalling Industry
This a must read to understand the effect of salmon farming on biodiversity and the coastal ecosystem. Ireland has a similar profile as Scotland with an even more pressing temperature regime at sea which will exacerbate the disease and parasite problems associated with the industry. The document is extensive and well researched and should be studied by all concerned with wild fish and environmental matters. With its beautiful landscapes and rugged coastline, Scotland is renowned as a wildlife destination. But lurking under coastal waters is a rapidly expanding industry, rife with animal welfare issues and damaging the environment and biodiversity. Known as the King of Fish, with their impressive athletic abilities and epic journey from river to sea and back again, Atlantic salmon are Scotland’s most iconic fish. But these days they are factory farmed in huge numbers where they can migrate no further than the cage walls. Scottish salmon farming has expanded quickly, growing by 41% in the past decade, and the industry has no plans to slow. In 2019 a massive 203,881 tonnes of Atlantic salmon was produced (over 38 million individual fish), but industry growth targets of 300,000-400,000 tonnes annually by 2030, involve a further 47-96% increase in production. Please Read More
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Update on Deenish Island Salmon Farm
Deenish Island - Update 09 February 2021 The proposed closure of the Deenish site owned by MOWI has not taken place despite the Ministerial order to close the farm being issued in April 2019. This is nearly two years ago and during this time period MOWI have launched a High Court Judicial Review of the Ministers decision and also appealed to the Aquaculture Licence Appeal Board. The High Court case was adjourned generally in January 2020 and the case is still under consideration by the Aquaculture Licence Appeal Board (ALAB). It is entirely unsatisfactory that no decision has been forthcoming and the site has continued to operate throughout the period. It is anticipated that the farm will again be stocked this month to start a new cycle which will last until late 2022. The appeal to ALAB is expected to be decided by the end of June 21 but this is not certain and if this decision does endorse the Ministers decision, it would be expected that MOWI would again appeal to the High Court. Meanwhile the sea trout and salmon resource is under severe pressure in Waterville and adjacent catchments. Salmon Watch Ireland has actively pursued the review process and has been active in lobbying both the Department and ALAB to arrive at an early decision. With modern technologies available to MOWI and production strategies to mitigate the effects of sea lice and disease it is alarming that the company continues to operate as before with open net technologies. This type of farming,with no physical barrier separating it from the surrounding ocean, has been causatively linked to the virtual elimination of sea trout stocks in Ireland, Scotland and Norway. The effect on salmon is now better understood and various studies identify that salmon spawning stocks can be reduced by up to 50%. These effects on salmon and sea trout relate to both disease and the effects of sea lice infestation from farms. To put the fish farming situation in perspective in the local Kenmare Bay area the stock of farmed salmon can be up to one and a half million pre-adult and adult salmon residing in two farms while the stock of wild salmon and sea trout now numbers probably less than ten thousand fish in the local area. In effect the wild salmon stock returning to Ireland now numbers less than 220,000 fish so effectively the two farms in Kenmare Bay dwarf Ireland's wild population by a factor of eight. Without the use of modern technologies these farms are a reservoir for disease, parasites and harmful pathogens. The entire west coast of Ireland is practically devoid of sea trout in areas where salmon farms exist, and Waterville is essentially heading in this direction. The economic collapse in the angling tourism sector and ecological destruction of the sea trout in Waterville can be reversed if a new and more environmentally responsible industry is put in place. Closed containment systems are now common in other countries and are evolving constantly. With climatic change gathering pace in Ireland, it is inevitable that fish farm mortalities will increase substantially. Increasing water temperatures will result in more harmful algal blooms and increased densities of jellyfish, both of which have and will cause large scale mortalities on farms. The reservoir of sea lice coming from farms will also increase with a warming ocean effectively reducing generation time giving more lice over the entire year. The advent of closed containment systems will effectively deal with these harmful episodes but will certainly also protect wild fish from sea lice infestation and other harmful effects emanating from open cage farming. There needs to an adult conversation between the Government, the industry and the various stakeholders as to how wild fish populations can be protected. Unless the industry and government regulators are prepared to change it is inevitable that all farm licences will be subject to judicial review in the High Court by vigilant conservation NGOs such as Salmon Watch Ireland. The European Commission is also aware of the specifics of the licensing system of salmon farming in Ireland and a formal complaint has been issued by Salmon Watch Ireland.
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The Status of Irish Salmon Stocks in 2020 with Catch Advice for 2021
Salmon Watch Ireland would like draw your attention to the recently published document from the Technical Expert Group on Salmon. We will answer any questions that you may have or request clarification from TEGOS on aspects that you are concerned with. The links to the reports are listed here: Catch Advice 2021 River Specific Advice The Technical Expert Group on Salmon (TEGOS) advises that in 2021: 48 rivers have an advised harvestable surplus as they are exceeding their conservation limits (CLs). A further 32 rivers, may be opened on a catch and release only basis, subject to IFI management criteria based on having a high probability of achieving 50% of their conservation limit (CL) or exceeding the management qualifying fry threshold of ≥15 fry (0+) per 5 minute electrofishing (multiple site catchment average). In addition 64 rivers are (a) failing to meet 50% of their CL or (b) recent data to determine their CL attainment status are lacking. Where there is a lack of data, or where catchment-wide electro-fishing surveys indicate juvenile abundance below the fry threshold, the TEGOS assumes that these rivers are failing to meet CL. There are 16 rivers for which there are significant fisheries on the MSW (spring salmon) component of the stock and a separate assessment is made. Of these: 11 have an advised harvestable surplus as they are exceeding their CL. 5 rivers may be opened on a catch and release-only basis subject to IFI management criteria as they have a high probability of achieving 50% of their CL or exceed the minimum mean fry threshold (≥15 fry) in catchment-wide electro-fishing. There are currently 40 rivers or river tributaries of the 144 salmon rivers assessed in Special Areas of Conservation (SACs) where salmon have a qualifying interest under the EU Habitats Directive. Of these, only 20 are above their CL.
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