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.
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.
Atlantic salmon Salmo salar has shown declines in abundance associated with reduced survival during marine life stages.
Key impacts on survival may include a changing ocean environment and salmon louse Lepeophtheirus salmonis infestation from aquaculture. A 26 yr record from the Erriff River (Western Ireland) was used to evaluate the contribution of sea lice from salmon aquaculture to declining returns of wild 1 sea-winter (1SW) salmon. Statistical models suggested that returns were >50% lower in years following high lice levels on nearby salmon farms during the smolt out-migration.
The long-term impact of salmon lice was explored by applying predicted annual loss rates as a multiplier to observed 1SW salmon returns. This produced a ‘lice-corrected’ return time series, i.e. an estimate of how returns might have looked in the absence of a serious aquaculture lice impact. The corrected time series was adjusted to account for some reduction in recruitment due to lost spawners.
Comparing observed and lice-corrected time series suggested that salmon lice have strongly reduced annual returns of 1SW Erriff salmon, but that the salmon lice impact does not explain a declining trend in this population.
Marine growth has strong implications for reproductive potential and ultimate fitness of sea trout.
Hence, the effects of anthropogenic factors on marine growth are important when evaluating population responses and implementing management measures.
Temporal changes in growth patterns of sea trout from three Norwegian and two Irish watercourses were examined, covering time spans of 25-65 years. Elemental chemistry Ba:Ca profiles and visual reading of fish scales were used to estimate smolt length and lifetime growth after first sea entry. Reduced growth after the first sea entry coincided with periods of nearby (<14 km) salmon-farming activity in impacted watersheds in both countries. Increased Ba:Ca levels were also recorded during these periods, likely indicating reduced residency in marine habitats caused by premature return to freshwater and estuaries.
An increase in estimated length at first sea entry coinciding with salmon-farming activity, for groups of fish sampled after sea migration, suggests a size-selective marine mortality, with the smallest individuals experiencing a larger mortality.
Salmon lice from aquaculture can cause negative impacts on sea trout Salmo trutta and other wild salmonids.
Long-term records from 5 Irish rivers were used to explore relationships between annual sea trout runs and the estimated total number of lice on nearby salmon farms. It was hypothesised that local environmental conditions may result in system-specific differences in realised louse pressure on sea trout. Louse count was thus tested as an absolute number and as a relative pressure, i.e. standardised by farm.
When the standardised total number of mobile lice on a given salmon farm in April was above ‘baseline’ level (50th percentile of observed annual values on that farm), there was a high probability of a below average sea trout run in the local river. Absolute louse counts did not show an important effect on runs.
This finding suggests that salmon farm louse production in spring can have a strong system-specific regulating effect on wild sea trout populations.
Total number of lice on a farm was most strongly driven by changes in individual infestation rate, with a lesser effect of stocking density.
Thresholds for number of mobile lice per farmed salmon required to maintain total louse count below the baseline varied with stocking density and among systems; greater density required lower infestation rate.
Regulations relying on a generic louse threshold to trigger treatment are not sufficient to protect sea trout populations – stocking density and site characteristics must be considered to evaluate system-specific infestation pressure and impacts on wild salmonids.
Salmon Farming: Complaint to the Commission of the European Communities about the Government of Ireland’s failure to comply with Community law
Salmon Watch Ireland has launched a Complaint to the Commission of European Communities.
This complaint focuses on Sections of the Fisheries Act 1997 which permits the continuation of salmon farm licences which have expired.
This is certainly a situation whereby the provisions of the Habitats Directive and Environmental Impact Assessment Directive are not being applied by the Irish state and as such are in contravention of both Directives.
The issue of access to justice without prohibitive cost is also being not applied and should be properly transposed into the Fisheries Act
1) Application of S. 19 (4), of the Fisheries (Amendment) Act 1997, Ireland.
(The impugned section of the act permits the indefinite operation of marine open cage salmon farms, with expired licenses, pending licence renewal and thereby avoiding the application of the provisions of the Habitats Directive and the Environmental Impact Assessment Directive).
2) Non-Transposition of Environmental Impact Assessment Directive 85/337/EEC 2011//92/EU.
(The Act has not been amended to transpose Article 11 of the Environmental Impact Assessment Directive; 85/337/EEC – 2011//92/EU, i.e. Arhus Convention Rights to information, participation, and access to justice without prohibitive cost in environmental decision making).
The CLAMS process is a non-statutory management system, which is anchored in the national marine policy and development programmes.
It is envisaged that CLAMS will highlight issues in a bay and co-ordinate the industry and relevant bodies to deal with them. It is separate to licensing issues and is not going to solve or take responsibility for all issues. The concept focuses at local bay level while still taking on board relevant national policies.
The object of this process is to formulate a management plan for the bay, which incorporates and extends the concepts of Single Bay Management to all farmed species.
