Fish farming

has written to the European Commission and to Irish Ministers demonstrating that
the proposed Galway Bay mega fish farm is contrary to an agreement for a moratorium in salmon farm development reached under the
National Development Plan 2007 – 2013 [NDP].

The Irish Seafood National Program 2007 –
2013 published under the National Development Plan in July 2010 acknowledges Central
and Regional Fisheries Boards concerns which were supported
by the Department of Communication, Energy and Natural Resources (DCENR) about the
negative impact that sea lice emanating from salmon farms are having on migratory wild salmonids.

‘To address these concerns [the
negative impact of sea lice], it has been decided that
no financial assistance will be given to marine salmon aquaculture licence
holders during the course of this National Programme until such time as the sea
lice issue has been satisfactorily

In spite of this,
only just over a year later in December 2011 the Minister for Agriculture specifically provided an increase in the
grant–in–aid for BIM ‘in view of the added
responsibility which it will have in relation to the deep sea aquaculture’. The
Minister has assigned BIM the task of obtaining the necessary licenses for the proposed ‘deep sea’ Galway Bay
salmon farm that will double national production.

the Press Release
   |  Read the letter


 Conclusions ‘not supported by any scientific investigation

‘A submission by the Government agency Inland Fisheries Ireland will slam the proposed Galway Bay Fish Farm. The application for the 15,000 ton salmon farm – which would be the biggest in Europe – is being made by the semi–state agency who will then franchise the licensce to the highest bidder.

The ‘Submission by Inland Fisheries Ireland on the Environmental Impact Statement for a Deep Sea Fish Farm Development in Galway’ is available from the IFI website. It is highly critical of the Environmental Impact Statement [EIS].The submission alleges that the EIS contains many statements ‘not supported’ by research and that some relevant research is noticeably absent – such as data gathered  at the proposed site by the Celtic Voyager.

IFI points out, for example, that ‘no data is provided on the known migration routes of salmonids’ to support BIM’s claim that there is a ‘very low to zero risk of farmed salmon sea lice infecting wild salmon’, that ‘the extensive literature published on interactions of sea trout and salmon lice in Ireland are not referred to or discussed’, and that the sea lice issue is ‘a legitimate concern in this proposal’.

The submission states that in the EIS ‘Presumptions are made and conclusions drawn regarding the potential impact of sea lice from the proposed locations on wild smolts which are not supported by any scientific investigation.’

It criticises the ‘tenuous mechanism to assist in invasive species control’ which may arise form the importation of smolts on this scale’.

It points out that the overwhelming research showing genetic modification of wild salmon are absent with the two papers referred to actually coming to the ‘opposite conclusion’ of that reported in the EIA. With ‘2.5 million mature salmon present on site annually in autumn an escape would pose a significant threat for interbreeding with the wild salmon stock’.

The submission concludes that ‘A full monitoring system should be put in place and a baseline study undertaken in advance of any farm being established’.
In an unprecedented move, a special consultation period was set for statutory consultees in advance of the public consultation ‘as directed by the Department of Agriculture Food and Marine to further assist in the public’s assessment of the Environmental Impact Statement’.

However BIM has not included the submission on their website with the other consultees because it was received on 3 October, 2012. The statutory consultation period closed on 2 October, 2012.

IFI states that a delay was caused by the BIM delay in providing extra copies requested by the organisation. A spokesman for Friends of the Irish Environment said that the failure to make the EIS available electronically – as has now been done for the public consultation – is an infringement of the Access to Information on the Environment regulations.

The submission will be made during the current public consultation period, which ends on 12 December, 2012 but BIM claims it is under no obligation to make the submission available with the other statutory consultees as it was received after the deadline.

Inland Fisheries Ireland submission on its website


Residents of the west cork coastline packed a Community Centre to form a committee to try and prevent the Norwegian multinational Marine Harvest from opening a new fish farm. More than 100 acres in size, the site, at Shot Head in Bantry Bay threatens local fishermen and the tourist industry while offering few jobs on the automated operations. The profits are going to Norway while the environmental damage to wild fish stocks is now well documented. The multinational, renowned for its destruction in Patagonia, plans 13 new sites along the western Irish coast.

Visit the website Save Bantry Bay  Read what the retired Regional Manager of the Parks and Wildlife Service told the meeting in the Examiner.| Read our Submission to the EIS |  Irish Examiner Feature and editorial


Simon Coveney, TD,

Minister for Agriculture, Marine, and Natural Resources,


29 September, 2012

Dear Minister;

In the course of examining the Aquaculture Licensing Appeals Board decision of 25 September, 2012, to refuse permission for the cultivation of mussels in Dunmanus Bay, County Cork, we are greatly concerned to find that the Board has breached Article 7 of the Access to Information on the Environment legislation.

 Article 7: Dissemination of environmental information

1. Member States shall take the necessary measures to ensure that public authorities organise the environmental information which is relevant to their functions and which is held by or for them, with a view to its active and systematic dissemination to the public, in particular by means of computer telecommunication and/or electronic technology, where available. [Directive 2003/4/EC] 

In this case, the Board’s website appears to have ceased functional operation in 2006, the year of the last available Annual Reports or of any determinations by the Board. Even the members of the Board are out of date.

You will be aware that planning decisions on land taken under the legal aegis of the Minister for the Environment may be appealed to An Bord Plenala. Their website gives the current status of every appeal, every determination, and every Inspector’s or technical expert’s report. A search engine allows members of the public to identify any cases in their own geographical area or on any given subject.

We would urge you to ensure that the Aquaculture Licensing Appeals Board meets the requirement of the Directive and provides the public with all the information relevant to any case in a timely and transparent manner, particularly in view of the proposed expansion of this industry by your Department and its Agencies.

Respectfully yours,

Tony Lowes


FIE has appealed a licensce for more expansion of the mussel industry in Dunmnanus Bay. We cite the Marine Institute's recognition that toxic contamination continues in Kenmare, Bantry and Dunmanus Bays when it excluded these bays from a reduced sampling programe in November 2011.

In our appeal, we point out that the proposal will undermine the local communities who are developing a comprehensive development plan for the area.

We also point out that failing to allow the public to comment until after the decision is made is contrary to the Aarhus Convention and EU law and that the fee of more than €150 is a barrier to public participation.

To date, the Aquaculture Appeals Board has never granted a request for an Oral Hearing.

Read the Appeal   |   Press Release