AIE Request 2/2023
ALAB FOI / AIE Disclosure Logs: https://alab.ie/foiaierequests/foi/
Shot Head
25 Jan 2022
Notes:
Includes Appendix on Concerns regarding the Appropriate Assessment of aquaculture activitives in marine SACs and potential impact on Atlantic salmon, and response letter from Minister McConalogue (29 March 2022)
Marine Institute
AIE
Galway Bay Against Salmon Cages request the following information under Access to Information on the Environment Regulations (AIE) Aarhus Convention 2007 to 2014.
Were there any reports to the Marine Institute of high farmed salmon mortalities on any Irish salmon farm installations between 1st January 2021 to the present day?
If the answer to the above question is yes, please answer the following questions.
When and on what salmon farms did the mortalities occur? Please supply details.
How many mortalities occurred on each salmon farm? Please supply details.
How many farmed salmon were on each farm when the mortalities occurred? Please supply details.
What was the reason for the mortalities? Please supply details.
How and where were the mortalities disposed of? Please supply details.
Please reply by email as soon as possible please.
Billy Smyth
Chairman, Galway Bay Against Salmon Cages,
Email billysmyth0@aglover
Response
The Marine Institute does not hold records of the number fish involved in each mortality event. Mortalities are reported to the Marine Institute as percentage values. This information has been released.
The Marine Institute does not hold records relating to the number of salmon held on the salmon farms at the time the mortality events occurred.
The Marine Institute does not hold any records relating to the disposal of mortalities from salmon farms.
| CHAIRPERSON | Ms Imelda Reynolds |
| DEPUTY CHAIRPERSON | Mr Michael Sweeney |
| BOARD MEMBERS | Mr Michael Mulloy John Evans Bill Sweeney Micheál Ó Cinnéide John Ward |
Legal basis: Fisheries (Amendment) Act 1997, s. 22
Maximum Number of Positions: 7
Gender Balance Numbers: Female (1), Male (6)
Gender Balance Percentage: Female (14%), Male (86%)
| Name | First Appointed | Reappointed | Expiry Date | Position type | Basis of appointment |
|---|---|---|---|---|---|
| Bill Sweeney | 17/07/2019 | 16/07/2024 | Board Member | Nominated by a prescribed organisation | |
| Imelda Reynolds | 01/04/2014 | 01/04/2019 | 31/03/2024 | Chair | Appointed by the Minister |
| John Evans | 17/07/2019 | 16/07/2024 | Board Member | Nominated by a prescribed organisation | |
| John Ward | 12/06/2020 | 11/06/2025 | Board Member | Nominated by a prescribed organisation | |
| Michael Mulloy | 06/06/2018 | 05/06/2023 | Board Member | Appointed by the Minister | |
| Michael Sweeney | 13/07/2009 | 01/01/2018 | 31/12/2022 | Board Member | Nomination from a prescribed body |
| Michéal Ó Cinnéide | 17/07/2019 | 16/07/2024 | Board Member | Nominated by a prescribed organisation |
Note: prescribed body that Michael Sweeney is nominated from, reappointed since 2009
https://www.oireachtas.ie/en/debates/question/2017-03-21/1030/
Recent Parliamentary Questions regarding ALAB
https://www.kildarestreet.com/search/?s=alab
The staffing resource provided by the Department to ALAB has increased significantly over recent years.Following a request from the Chairperson, a permanent technical advisor was appointed to ALAB with effect from 18th October 2020, the dedicated technical advice resource is assisting the Board in the timely processing of appeals. In addition to this, the numbers of administrative staff currently assigned to the ALAB secretariat has also increased in recent years and the current staffing is as set out below.
ALAB Secretariat Staff 2021
1 x HEO Secretary to the Board- (Full time) *
1 x HEO Technical advisor to the Board
1 x Executive Officer (Full Time)
1 x Clerical Officer (Full Time)
1 x Clerical Officer (Part Time)
The Board is comprised of 7 members
*Under Section 32 of the Act, an officer of the Minister who is an established civil servant and who is seconded to the Board for that purpose, either on a whole-time or part-time basis, shall act as Secretary to the Board.
Note: EIA into ALAB on stocking level data, plus FOI in on non publication of ALAB FOI Disclosure Logs
Shot Head farm will have a maximum permitted biomass of 2,800 tonnes over a 24-month production cycle and will have 18 pens
On 23rd of September, Salmon Watch Ireland filed an application at the High Court seeking judicial review of the Aquaculture Licences Appeals Board (ALAB) decision to approve the awarding of a licence for a new open-cage salmon farm at Shot Head in Bantry Bay.
Inland Fisheries Ireland, Sweetman and others filed a similar application.
ALAB
The Aquaculture Licences Appeals Board has determined all appeals before it against the decision by the Minister for Agriculture, Food and the Marine to grant an Aquaculture Licence to Bradán Fanad Teo t/a Marine Harvest Ireland on site Ref: T05/555 for the cultivation of Atlantic Salmon; Salmo Salar on a site on the foreshore at Shot Head, Bantry Bay, Co Cork.
The Board determined the Appeals pursuant to section 40(4)(b) of the Fisheries (Amendment) Act 1997 (as amended and substituted) by determining the appeals as if the application had been made to the Board in the first instance and by GRANTING a licence to the Applicant for the proposed activity on the Site, in accordance with the draft licence prepared by the Minister, but subject to the varied and amended Terms and Conditions as set out in the Determination. There were 14 appeals in total.
Copies of the Board’s determination in respect of each appeal are available on this website by following the link to Board Determinations 2015 – http://alab.ie/boarddeterminations/2015/
Copies of the documents to which the Board had regard in reaching its determination are available on this website by following the link to http://alab.ie/boarddeterminations/2015/scheduleofdocuments
Media Coverage on Decision
https://www.southernstar.ie/news/massive-salmon-farm-gets-go-ahead-in-bantry-bay-4225943
https://www.thejournal.ie/troubled-waters-pt4-shot-head-5482531-Jul2021/
https://www.irishexaminer.com/news/munster/arid-40327370.html
https://www.fishfarmingexpert.com/article/mowi-ireland-wins-10-year-campaign-for-new-salmon-farm/
Each salmon farm license has a) stocking rate, and b) max allowable biomass
Licenses are all (or almost all) expired
There is no easy way to determine overstocking of salmon in salmon farms
There is no way way to extract the licenced stocking data in a structured format, as it is all held in various pdf docs
If a farm remains unstocked for two years, the license is revoked. But how can you tell when and where fish farms are not stocked? One clue would be via the Marine Institute Annual Sea Lice Reports, which contain results for all the sea lice inspections. See below for most recent report (2020)
Note: Salmon farm data is on the ‘to do’ list, as it is not in any structured or open public format… for reasons
The Board operates under the aegis of the Department of Agriculture, Food and the Marine.
The function of the Board is to provide an independent authority for the determination of appeals against decisions of the relevant Minister on aquaculture licence applications.
A person aggrieved by a decision of the Minister on an aquaculture licence application, or by the revocation or amendment of an aquaculture licence, may make an appeal within one month of publication (in the case of a decision) or notification (in the case of revocation/amendment).
The Board is an independent body with its own funding provided for by the Oireachtas under Section 36 of the 1997 Act
ALAB Board
Section 23(2) of the 1997 Act provides that the Chairperson of the Board shall be appointed by the Government.
In accordance with Section 23(3) of the 1997 Act, the Minister for Agriculture, Food and the Marine (“the Minister”) may make regulations prescribing not less than two organisations to nominate members of the Board.
Those organisations should, in the Minister’s opinion, be representative of the following groupings:
(a) organisations concerned with the promotion of the development of aquaculture or representative of persons carrying on the business of developing aquaculture;
(b) organisations concerned with the conservation, development and protection of wild fisheries;
(c) organisations representative of persons whose professions or occupations relate to physical planning and development;
(d) organisations representative of persons concerned with the protection and preservation of the environment and amenities;
(e) organisations representative of persons concerned with the promotion of general economic development and
(f) organisations representative of persons concerned with the promotion of community development.
ALAB commission technical advice, most recent list of advisors (for 2019) is:
List of persons engaged by the Board during 2019 pursuant to s.35 of the Fisheries (Amendment) Act
Technical Advice
Graham Saunders, Marine Ecologist and Environmental Consultant, 13 Princess Road, Haddington,
EH41 HE UK
Aquafact International Services, 12 Kilkerrin Park, Liosban Industrial Estate, Tuam Road, Galway,
H91 FW7V
Modelwork5, The Old Courtyard Newtownpark Ave., Blackrock, Co. Dublin
Dr. Tom Gittings, Ecological Consultant, 3 Coastguard Cottages, Roches Point, Whitegate, Co. Cork
Marie Louise Heffernan, Aster Environmental Consultants, Rosleague, Letterfrack, Co Galway.
Bryan Deegan, Altemar Ltd Marine&Environ mental Consultants, 50 Tern plecarrig, Upper
Greystones, Co Wicklow.
Eoin Cussen BSc, MSc, /John Thompson EcoEireann, Acorn Business Centre Blackrock, Cork, T12 K7CV
Dr. Louise Scally MCIEEM/Nick Pfeiffer MCIEEM/ Jackie Hunt, MERC Consultants Ltd., Loughaunbeg lnverin, Co. Galway
Richard Barker, Macro Works, Hibernia House, Cherrywood Business Park, Loughlinstown, Dublin 18
William Kavanagh, 81 Rowan Hill, Rochestown, Co. Cork
Hamish Rodger, B.V.M.S., M.Sc., Ph.D., Dipl.ECAAH, M.R.C.V.S, VAI Consulting, Unit 1C, Deerpark Business Centre, Oranmore, Co. Galway, Ireland
The Kerry farm is licenced to harvest up to 500 tonnes (dead weight) of salmon in any one year, but they harvested just over 1100 tonnes in 2016 – over 121 per cent more than permitted.
The Minister revoked MOWIs licence.
https://www.irishexaminer.com/news/arid-30919283.html
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.
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 pending by the Aquaculture Licence Appeal Board (ALAB).