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Weekly Update 01 December 24
This update contains some interesting topics which Salmon Watch Ireland would like to highlight to our members and supporters. Mc Swynes Bay - Salmon Farming Licence The ongoing saga surrounding the attempts by the Department of Agriculture, Food and the Marine to renew and review extant licences for existing salmon farms continues with Mc Swynes Bay, in Donegal, being the latest to be released for public consultation. We expect a large number of further applications to be released for public consultation in the coming months and we will try and examine each individually and give a considered and appropriate response. You can view our submission at Mc Swynes Bay - Submission Salmon Watch Ireland It is all too evident that catchments like Waterville (Butler Pool Pictured) will continue to decline in the presence of salmon farming in Kenmare Bay and Deenish Island. Tagging Regulations 2025 We are also at the time of year where the draft tagging regulations are out for public consultation and we have responded with our submission. The submission is broadly similar to last years with an emphasis on giving protection to MSW salmon stocks by suggesting reduced catch in spring along with a size limit from May. It is also suggested that salmon harvest should not be facilitated in September. Again we emphasise that there is a an onus on all stakeholders to consciously acknowledge that Atlantic salmon are in crisis in many rivers and that their actions in regard to harvest should reflect this. Limit your catch not catch your limit. You can view our submission at Tagging Submission 25 Ocean Knowledge 2023 We recently attended the Ocean Knowledge Conference which took place in the RDS, Dublin on the 20th and 21st of November. The conference was hosted by the Marine Institute and was attended by a large diverse range of organisations and individuals. The main emphasis appears to be related to off shore energy and how this can be progressed. Aquaculture has not been included under the remit of the Marine Area Regulatory Agency (MARA) which is undesirable but there seems to be a consensus that aquaculture may be included at a later date. The programme and speakers were diverse in nature with Elvira de Eyto from the Burishoole salmon research station being particularly interesting in describing the effect of climate on wild salmon stocks. It might be of interest to examine the setup of MARA and their role. The following presentation by MARA is informative and gives an understanding to the complexities involved. It appears that the organisation is set up to give consent in the first instance by issuing a Maritime Area Consent (MAC) which can then be used to apply to the relevant authority (Coastal Local Authority or Bord Pleanala for planning). MARA can also issue a Maritime Usage Licence (MUL) for certain specified activities. Please click on link below Our interest is specifically in the area of salmon farming and we certainly would suggest that at the very least aquaculture licensing should be specified as an activity requiring a Maritime Usage Licence and be added to the legislation as soon as practical. We have long standing doubts about the independence of DAFM and ALAB in the overall process of determining applications for salmon farming. While a considerable time was taken up by the regulatory regime it is apparent that Irelands Marine Strategy was and continues to be the most important aspect to consider. The strategy is a conduit which may result in time to Ireland achieving a Good Environmental Status (GES) in our maritime area. However there are considerable pressures to be overcome with agriculture, aquaculture,water management, energy, transport, tourism and sea food production activities noted as activities which may affect our legal obligations in attaining good environmental status. While we obviously agree that the maritime area must be managed and that the ecosystem based management model is the only suitable model to allow sustainable development we categorically cannot fathom how open cage salmon farming sits in the overall goal of sustainable use of the maritime area. We will continue to oppose such developments until the industry is compelled to keep the farmed fish separate from the marine environment and this can only be satisfactorily achieved by moving these fish inland in closed containment facilities. Marine Strategy Video
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Weekly Update
Salmon Watch Ireland attended a webinar concerning land based aquaculture systems. The discussion was both interesting and informative. Our goal here is to see salmon farming move on-land for the entire production cycle and it was interesting to see that hybrid systems utilising sea water (Flow Through) and RAS in combination worked effectively. The major obstacle to on shore aquaculture is cost and energy requirements and we see this as a challenge but with renewables like solar and wind being more common place, it is inevitable that these challenges will become less important. Other forms of energy to pump water onshore are currently being developed and as such the long term future may be more on land for salmon farming industry. The many benefits include drastically reducing mortality, elimination of parasites, no escape risk and above all the actual security of being able to service the farms in a safe manner. The climate of Ireland's ocean environment is radically changing and the ability to farm at sea will be impossible due to extensive changes in storm patterns and novel diseases arriving on our shores. The take home message is " farmed salmon must move to land based facilities to protect their own future but above all to protect wild salmonids and the near coastal ecosystem" The latest wave of land-based farming projects represents an exciting new era for aquaculture, but is the ambition matched by practicality? Fish Farmer’s expert panel considered the question in our latest webinar. THE PANELLISTS: Thue Holm is Managing Partner at Aquafounders Capital and a director of The Black Cod Company. Paul Howes is Manager at the Centre for Sustainable Aquatic Research, University of Swansea. Trond Schaug-Pettersen is CEO of Norwegian land-based fish farming company Salmon Evolution. The discussion was facilitated by Robert Outram, Editor, Fish Farmer. An impressive amount of investment is pouring into land-based fish farming around the world, from Scandinavia and the Middle East to Florida and Japan. But can the technology and biology combine to ensure this industry has a profitable future? This was the question we set out to answer in the latest in Fish Farmer’s series of Aqua Agenda webinars. Thue Holm has gained experience in the course of a long career in aquaculture, including a role in the creation of RAS salmon producer Atlantic Sapphire, and now as Managing Partner of Aquafounders Capital, which he started jointly with fellow entrepreneur Ohad Maiman, who had been CEO at The Kingfish Company, another land-based fish farming business. As Holm explained: “We had both experienced, the hard way, a lot of the issues.” Farm in a Box Their current projects include The Black Cod Company, which plans to produce black cod in the Netherlands, and Farm In A Box, which has developed a modular RAS (recirculating aquaculture system) farm system designed to make farm set-up quick, easy and cheaper than the typical “bespoke” approach. Regarding The Black Cod Company, he said: “We believe that locally produced, high value species can give a price point that a RAS farm needs. You can also deliver a fantastic story to the consumers.” For Farm In A Box, meanwhile, he said: “We wanted to create a more standardised, cheaper way of building land-based systems, and we also felt it needs to be much easier to operate these systems.” At Swansea University, the Centre for Sustainable Aquatic Research operates 15 separate RAS systems in 13 labs, housing fish at temperatures of 8°C to 30°C and from full salinity to freshwater and anywhere in between. Paul Howes explained: “We have three core missions: to enhance the student experience; to produce impactful papers; and to work with industry to answer industry related research and innovation questions. “So my role is to be somewhere between academia and industry, to form a bridge between those often disparate areas.” Salmon Evolution, Indre Harøy Phase 2 Salmon Evolution has a salmon farm at Indre Harøy on the Norwegian coast. It is a hybrid flow-through system, which as Trond Schaug-Pettersen explained, contains elements of both a RAS facility and a flow-through system. He said: “We have tried to capture the benefits of both a full flow through system and a RAS system, where you have high recirculation. “For us it’s all about three things, first providing a good environment so you can take the full growth potential of the salmon; secondly, reducing operational risk to a minimum; and finally, if something happens you need to be able to contain it. “About one-third of the water in our system is a constant flow, and we recycle up to two-thirds.” He added: “We have had very good biological results. When you are doing innovation at scale you always encounter challenges, but the big picture is that this has been working very well. “In the first half of this year we became profitable for the first time, which was a huge milestone for the company, and we had farming margins on a par with some of the best conventional farmers. “For us, it’s never been clearer that this is working.” Scale has been the theme for many of the land-based projects underway around the world. So why does size matter? Thue Holm said that scale is necessary to offset the capital costs of a RAS or flow-through farm. Also, he argued, the lack of an existing industry in many regions where these farms are being built – like Florida, or central Japan – means that issues like feed, processing or distribution can be problematic at a small scale. Paul Howes added: “When you scale, you have the ability to have a much longer viewpoint and weather the storms when prices change. If you’re somewhere in the middle, your profit margin can quickly move into debt.” And Holm added: “That’s also why we went for black cod because it’s a niche market, and really high value. So you can either go for scale, in a commodity, or you can go small and target a niche market.” Another question concerned production challenges. How serious is the risk of disease, or off-flavours like geosmin? Biosecurity should be manageable in a RAS farm, Holm argued, which should mean minimal risk of diseases or parasites, although issues such as a potential build-up of hydrogen sulphide could cause problems if not carefully monitored. Salmon Evolution fish on ice Trond Schaug-Pettersen said: “Off-taste is not an issue for a hybrid flow-through system, but the more water you use the more challenging it is to ensure disinfection. “You need to start with healthy smolt. In our system we filter out particles and we also disinfect the water with UV. “There will always be a risk that something will get through. But if you have a healthy environment and healthy fish, normally that would not be a problem.” “One of the main benefits of our system is that you don’t have to deal with sea lice, so there is less handling and you have a stronger fish.” There are currently competing RAS systems, but will aquaculture technology be standardised? Thue Holm argued: “For RAS farms there are a lot of technologies but the basis for a RAS farm is very similar – there will be particle removal, some type of biofilter, some type of degasser, disinfection and oxygen injection, and it has looked like that for 40 years. “We see diversification in agriculture and it is the same with aquaculture.” So how aware are consumers of the increasing share in the seafood market taken by land-based farms? Tanks at CSAR, University of Swansea Paul Howes said: “A lot of consumers just want to look at what the price is. Budgets are tight and consumers want value for money, but they also want to know that, for example, the fish or shrimp was not grown in polluted waters or has been grown to high welfare standards. “People in some countries are eating less fish so that’s a challenge. While in others, people have more spare cash and are looking to import seafood products.” Trond Schaug- Pettersen pointed that this question also relates to scale. If the producer is selling fish as a commodity, the fact that there is not enough supply to guarantee its availability all year round is not a problem – but it is a problem if you are selling it as a unique brand. He added: “Also, you need to communicate the story and this takes time.” The panel also discussed what might constrain the growth of this sector. Availability of capital is a key issue, but so is the availability of people with the required skills to run a fish farm system. The knowledge and experience of local regulators is also an important factor, so those countries with an existing aquaculture industry have a definite advantage in the development of land-based fish farming. So, what will the industry look like in five years’ time? Trond Schaug-Pettersen said: “Land-based will be a big part of the way we produce salmon, over the next five years probably not so much, but more companies are heading towards a base size and you will get an inflection point. So, in 25 years, it will be quite a big industry.” Paul Howes said he expects to see several huge companies, maybe integrating RAS aquaculture and cage farming, but alongside that a proliferation of the smaller niche RAS systems around the world, tailoring their product to local markets. Thue Holm agreed that land-based aquaculture has a bright future: “I’m very bullish on the sector”. To watch the whole webinar online go to: https://youtu.be/lNTW6D3MR90
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Deenish Island – Re-establishment ongoing
Deenish Island salmon farm is currently undergoing extensive upgrading (October 2024) for the next stocking of smolts in February 2025, despite being ordered to close in 2019. This demonstrates the very obvious failings of government bureaucracy whereby the appeal against closure is ongoing for nearly six years. It is depressing that such a situation is allowed to continue while the sea trout population continues to descend into oblivion. The Butler Pool, Waterville. The present situation is that MOWI have an appeal before the Aquaculture Licence Appeals Board for six years against closure and have also applied for a renewal and review of their expired licence earlier this year. MOWI have been permitted to continue to produce salmon despite their abject failure to comply with their licence terms and conditions. This farm is withing nine kilometers of Lough Currane and is essentially a reservoir for sea lice, disease and other pathogens which have driven the regional stocks of sea trout into crisis. This was once a famous destination for local , national and international visitors from April to October and is now essentially extinguished as a destination for angling. This is an a appalling situation and suggests that the Department of Agriculture, Marine and Food is hiding behind a wall of bureaucracy to allow continuation of this appalling practice at Deenish. It is well worth mentioning that up to three million Euro is being lost to the local economy each year through loss of revenue to Waterville and surrounding area. This is not to mention the appalling destruction of biodiversity. This film by Vincent Hyland demonstrates what has been lost to Waterville. These are now the Ghosts of times past. https://salmonwatchireland.ie/wp-content/uploads/2024/11/FDownloader.Net_AQOoERmIqysNQwhmGL9nTNXsNREiUUX1_GSqOp-_CZjAIVjyL0cvP6qAW56wgal3jPvMJBmviec_8L2wXi8kTRwk_720p_HD.mp4 We have made numerous submissions on the subject which can be viewed here: Deenish Submission Inishfarnard Kenmare Bay - Submission Complaint to EU - Sec 19 We are asking you to send to your local election candidates and ask their help in stopping this environmental disaster. The following video of Deenish Island Salmon Farm in June 2023 demonstrates the level of salmon stocked and the stressful reaction of the fish to high water temperatures. There has been over 40 percent mortality on this farm and others in Kenmare Bay resulting in circa one and a half million mortalities over the past decade. https://salmonwatchireland.ie/wp-content/uploads/2024/11/AQOGlPuMr9u2PdyAiIy1D35GAT7uT7pxzbenDmG2WtpgvvYTmHtBrydD1ifuwzut-1SUK7DoN5jW7By4TufrFNSx.mp4
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Marine Institute - Year in Review - Declining Salmon Count and Low Levels of sea trout The Marine Institute Year in Review 2023 includes a comprehensive count of wild salmon and sea trout for 2023 and demonstrates a declining and unstable population of wild salmon and dramatic population collapse of sea trout. The data covering the period 2019 to 2023 demonstrates a declining trend of survival at sea for wild salmon and reared grilse. It is interesting to note the much improved output of salmon smolts from the relatively higher return of adults in 2020 demonstrating a strong correlation between spawning numbers and smolt output. This system is below its conservation limit due to poor adult return rates and productivity is negatively affected by environmental factors in fresh water. It is evident that more spawning fish, especially fish that are in generally good condition as witnessed in 2020 deposit more ova thus increasing productivity. This is particularly important in rivers where salmon numbers are depressed and where every salmon should be allowed to spawn. This fits in with our policy relating to exploitation and while the majority of rivers are closed to exploitation some remain open and should be treated with caution. Anglers should consider their own conduct and limit their catch. We have advocated for a reduction in tags, one salmon in spring period and return of salmon over 65cm during the summer period while advocating for catch and release of all salmon in September. We have also advocated for a cessation of commercial netting of salmon. The Data demonstrates a reducing trend in sea survival from 10.18 percent in the cohort of smolts which went to sea in 2019, through to 2022 at 5.56 percent. The decreasing trend from 2019 to 2022 smolt cohorts is as follows, 10.18, 7.17, 5.88 and 5.65 (Provisional Data 2023) percent. It is alarming but not a surprise to see the declining trend in survival at sea. 2024 did show an increase in some catchments regarding grilse numbers and it will be interesting to see data from the Marine Institute in next years report. The paltry number of sea trout returning is not surprising and this graph really demonstrates the issue. Salmon Farming is the cause of this collapse and cannot be denied.
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Farmed Salmon Mortality – A new low in Donegal
A new low has been reached in Donegal. Salmon farming has experienced enormous mortality events on a continuous basis but evidence is difficult to garner as the whole process of reporting is shrouded in secrecy. The majority of farm renewal applications are redacted heavily but the latest application has its mortality figures on display without redaction. Ocean Farm Ltd has applied for renewal and review of its operation in Mc Swynes Bay in Donegal and there are extraordinary mortality figures on display. To date no explanation of mortality events is to hand but the level suggests that such events are common place. It is extraordinary that such information is normally hidden from public oversight and it is very disconcerting that such events are not publicly available as the small numbers of surviving fish are entering the food chain without an explanation of the large scale mortality. We certainly are alarmed that the general public is routinely not informed of mortality events and that the commercial sensitivity of such events is being used to mask information which should be in public domain. We will be making a submission on this application in near future and will be available to use if persons wish to make their own personal observations : Extract from Application :Documentation Ocean Farm Ltd
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Waterville Fishery – Another year draws to a close- Sea Trout in terminal decline
Waterville's sea trout is in continuous decline and the issues with salmon farming continue. Deenish Island and Inishfarnard continue to operate and certainly are causing significant issues for the once iconic sea trout of Lough Currane. We will in conjunction with Currane fisheries soon launch a renewed campaign to highlight the damage caused by salmon farming and hope to persuade the Department of Agriculture to follow up on their decision to close Deenish in 2019. We may in time have to enter the High Court to judicially review the continued operation of the farm at Deenish and will be looking for your support in this important undertaking. We will be in touch when campaign is ready and hope for continued support.
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Update -Escapee Salmon on the move and fast: Farmed Salmon Caught Owenmore River
Reports coming in of farmed salmon caught on Owenmore River which is over 70 km from Killary within seven days. Is this fish from Killary or has there been another escape? Escapee salmon from Rosroe salmon farm in Killary have migrated long distances over the last ten days. These fish which have compromised genetics and may in time breed with wild salmon should at all costs be removed by any means possible. These fish have been caught both in the sea by anglers fishing for mackerel but more alarmingly have entered rivers both within Killary Harbour and further afield. Some have traveled over 25km north to the Bunowen and south as far as the Dawros system. These fish are being caught in these systems by anglers and should immediately be killed and reported to Inland Fisheries Ireland. The operator of the farm has suggested that these fish may not mature until 2025 but little is known of how they develop when released into the wild and thus may pose a risk this spawning season. There are many small rivers with unique genetic salmon populations and these are at high risk of damage by escapees through interbreeding. Disease may also pose a risk to all wild salmonids both near and far. There is every risk that the escapee salmon will continue to migrate and pose a risk to populations along the western sea board. There are a number of rivers within the area which are part of conservation areas which have wild Atlantic salmon as a qualifying interest and this highlights the unacceptable risk posed by open cage farming. There is no safe way to protect wild salmon if these farms are not moved onto land.
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Salmon Farm Escape – Killary Harbour , County Galway
Salmon Watch Ireland has been alerted this morning to a large escape of farmed salmon from Rosroe salmon farm in Killary Harbour which occurred on Sunday, 11th August. The escape appears to have been caused by a fish farm boat colliding with salmon cages which resulted in an escape of farmed salmon numbering over ten thousand fish. It must be stressed that this figure may be an underestimate as it is likely that accurate reporting of such escapes are at best, estimated. The farmed salmon are 1.5 kg to 2kg in weight and reports indicate that large numbers can be seen throughout Killary Harbour. The farm licence is listed as owned by Docon Limited, Mulranny Co. Mayo with a recent transfer from previous owners in October 2023. Local information suggests that MOWI have a substantial interest in this farm. Salmon Watch Ireland would like to ascertain if all operating procedures were put in place to safeguard the cages prior to this incident and if all necessary reporting steps were taken once the escape was discovered. We would also like to know if steps are to be taken to trap the escapees and prevent them from entering the nearby wild salmon catchments. In the recent decision by Judge Holland in relation to the Bantry Bay Judicial Review, he noted that the EIA was not comprehensive enough as it related to specification and structural integrity of the cage infrastructure. This incident once again highlights the dangers and risk of damage to farms and highlights the very real risk to wild salmon genetics. These fish may in time enter rivers and interbreed with the wild salmon both in Killary harbour catchments and indeed further afield. We regard the removal of open cage technologies as a priority to protect wild salmon and are calling on DAFM to reconsider siting these farms at sea. In the interim it is of the utmost importance that the maximum number of escapees are captured to reduce risks to local wild salmon populations. We encourage anglers to report and remove farmed salmon if caught and we strongly suggest that Inland Fisheries Ireland and the Marine Institute should facilitate a program of removal by all available means.
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Deenish Island – Six years and counting
The MOWI (Deenish Island) owned salmon farm located within nine kilometres of the once famous Waterville sea trout fishery has once again escaped judgement by the Aquaculture Appeals Board. This farm was officially ordered to close in April 2019 but has since operated unchallenged while pursuing an appeal against the closure. The sea trout fishery is effectively abandoned with a substantial loss of economic activity and the loss of many jobs associated with angling tourism. The text of the letter is as follows: "I refer to my letter of 05 September 2023 in which the Board indicated it anticipated this Appeal would be determined by 30 September 2024. The Aquaculture Licences Appeals Board (ALAB) reviewed this timescale for the determination of this Appeal at its meeting on 25 July 2024 and has formed the view it will not be in a position to determine these Appeals within that timeframe due to the ongoing collation of technical advice and the vacant position of an internal ALAB Technical Advisor. In light of this, as provided for in Section 56(3) of the Act, the Board hereby gives notice of its intention to determine this Appeal by 31 January 2025." The ongoing damage to Waterville and its angling reputation is continuing while sea trout stocks continue a rapid and accelerating decline. While Salmon Watch Ireland has successfully taken judicial review proceedings in regard to Bantry Bay we are conscious that the Deenish situation should be prioritised by all concerned with bringing back stability to sea trout stocks with economic benefits accruing to the local community. We are disappointed with the apparent apathy demonstrated by some within the local business community despite the best efforts of the local angling association (Currane Fisheries) and other conservation bodies to highlight the devastation occurring. This area more than ever needs sustainable tourism business and it is shameful that a lake like Lough Currane has effectively been consigned to the history books by the salmon farming industry. Make no mistake, salmon farming in open cage technology cannot coexist with healthy sea trout populations. It is also infuriating that the Aquaculture Licence Appeals Board has effectively allowed MOWI to delay and consistently mend their hand in relation to this appeal. Recent submissions by Salmon Watch Ireland regarding Deenish Island: Submissions to ALAB - Deenish Island
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Atlantic Salmon News
High Court Ruling - A good day for Atlantic salmon The long running high court case against the Aquaculture Licence Appeals Board and the Department of Agriculture, Food and the Marine received judgement on Friday 12th July, and we were successful in having the decision to issue a salmon farm licence at Shot Head in Bantry Bay quashed and sent back to ALAB and DAFM for re-decision effectively forcing MOWI to start the entire process of applying for a licence again which will be subject to our full consideration and renewed objection on numerous environmental grounds. Briefly put, the Aquaculture Licence will be quashed for inadequate: i. AA Screening of the risk of effects of seal scarers on seals of the SAC. ii. EIA as to the risks of escape of salmon from the fish farm. This finding relates to necessity of re-consideration of bespeaking the DAFM reports on the 2014 farmed salmon escape in Bantry Bay, and comprehensiveness of the EIA as it related to the specification and structural integrity of the cage installation. iii. reasons for the conclusion that the proposed fish farm will not lead to a breach of WFD limits as to Dissolved Inorganic Nitrogen – specifically, reasons for reliance on RPS’s “typical” data in reaching that conclusion. In addition, I will declare that ALAB delayed unreasonably as to AA Screening from the making of the Appeals in October 2015 to embarking on AA Screening after the Oral Hearing Report of November 2017. I will grant no further relief on that account. The Foreshore Licence will be quashed as • contingent on the quashed Aquaculture Licence, Ministerial regard to which was a statutory requirement of granting the Foreshore Licence. • the Minister erred, in breach of s.82 of the 1997 Act, in granting the Foreshore Licence in 2022, in having regard to his Aquaculture Licence decision of 2015 rather than to ALAB’s impugned Aquaculture Licence determination of 29th June 2021. The full decision is at following link. Court Judgement
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