• AGM Remarks by Chair John Murphy

    Remarks by John Murphy,  chair of the board of Salmon Watch Ireland CLG, to the company’s annual general meeting on Monday 19th June 2023.   Welcome to Salmon Watch Ireland’s AGM for 2022 being conducted by Zoom. This meeting is primarily held to conform with our obligations under the Companies Act. 2022 was a year primarily dominated by our impending Judicial Review on the decision to award an aquaculture licence to MOWI in Bantry Bay. Having taken the decision to enter into this legal process it was necessary to devote a considerable amount of time to research our main avenues of approach to the legal process. I would like to thank all our directors and indeed our members and supporters who helped to prepare and support us both financially and with advice which enabled us to pursue this case. The Judicial Review took place over four weeks in April /May 2023,  and we expect an outcome in the near future. The 2022 salmon run in Ireland was extremely poor with regard to grilse, but spring salmon runs appeared to be on an upward turn although from a low stock level. The low level of grilse last year did  manifest as a very poor reported spring salmon stock this year with anecdotal evidence suggesting a collapse in the majority of fisheries both here and the United Kingdom. Generally speaking, this may be related to the abnormally low river levels which greeted the adult stocks here and UK in 2018. This was also mentioned by the ICES working group on North Atlantic salmon and seems to be a recurring theme with the summer of 2022 experiencing very low water levels. Again, there is no need to mention this year as the trend continues. On a more positive note, the early spring this year did favour a more positive environment for smolt migration. These fish are the progeny of the 2020 run of adults which showed a very welcome upturn in stocks. The IFI fish counter data is indicative of an increased run of spring fish in 2022 but a large decline in grilse stocks and is probably at an all-time low when looked at over an extended period. It is evident that climate is causing a very poor environment for Atlantic salmon and these periods of low flow in conjunction with high water temperatures cause a cascade of effects with predation and biological factors having a significant negative effect on juvenile and adult survival. In conjunction with the pressures at sea it is evident that the future is far from secure. While most of these factors may be out of our control, we must continue to endeavour to maximise the amount of wild healthy smolts going to sea. It is interesting to note that a recent study in the UK noted that larger smolts survived to return at three times the rate of smaller smolts. Again, with a warming climate, can we expect larger wild smolts, I would suggest not. The publication of the state of Irish waters by the EPA for 2022 notes little improvement in regard to nitrate levels in Irelands rivers and lakes and is a major concern for salmon survival. It is evident that the farming community are engaged in a political agenda with little concern for climate or indeed the wider environment. Unfortunately, the vote on the recent legislative change at EU level in regard to protecting degraded land was postponed for one month which is disappointing but demonstrates that there is a considerable opposition to protecting nature which is all too evident within this country. With changing weather patterns, we are seeing a very substantial reduction in rainfall during critical periods for salmonid migration which only exacerbates an already precarious situation.   In early 2022 we sought through FOI correspondence between Minister Eamon Ryan and Minister Charlie Mc Conalogue regarding sea lice and their impact on wild salmonids. This was further illuminated by the Irish Times in August and a special segment on Prime Time followed in October. It is very significant in that a government department was willing to take on DAFM regarding their rather benign interpretation of the impact that salmon farming has on wild salmonid stocks. IFI were very robust on the Prime-Time program which is a welcome departure from previous pronouncements on the subject. This was further demonstrated with their participation in the Judicial Review. There appears to be a more proactive approach from IFI and there is further evidence that they are ramping up pressure with the recent job advertisement looking for a project manager to investigate nationwide introgression from farm escapees. These developments may have a bearing on future JR procedures. Mark Boyden from the Coomhola Salmon Trust was the recipient of our Salmon Hero Award in 2022. Mark has been at the forefront of educating Irelands school children on salmon matters for the best part of 30 years. He was most appreciative of our efforts to conserve Atlantic salmon. We did not hold a conference in 2022 but hope to hold one in 2023. Our focus has somewhat been overwhelmed by the judicial review process but we would hope to concentrate more on other issues going forward. The issue of commercial exploitation of salmon is causing a serious amount of controversy and our policy to effectively finish this practice must be revitalised. It is not an attempt to change the location where salmon are harvested as we also would like to limit exploitation by recreational anglers. The ability to harvest ten salmon by anglers is certainly not sustainable from a moral point of view and should be reduced significantly. It would be our intention to seek a redesign of the management of our salmon stocks with a review of conservation limits and surplus determination. It may be time now to increase the statistical probability of 75% of reaching a conservation limit to a higher number thus taking a more precautionary approach in these volatile times for salmon survival. On the aquaculture front we will continue to oppose open cage farming and intend to design a template for publication which will allow all to oppose licences in a concerted, legal and scientific manner. With stocks in such a precarious situation it may be time to examine rebuilding strategies. It is obvious that certain rivers have radically insufficient stocks to repopulate rivers. In these rivers we must use the best available strategies to rebuild stocks ENDS:


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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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  • 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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  • 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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  • 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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