Allow Priority Area for Action Desktop Report

August 2018

LAWPRO

The Allow is part of the Munster Blackwater SAC which contains Otter, Salmon, Shad, Lamprey and Freshwater Pearl Mussel among others.

The RaptorLife project and IRD Duhallow are active in area with the possibility of ongoing agri-environment projects.

The main risk of diffuse pollution is likely to be phosphate via overland flow as well as sedimentation from modified channels and drainage

Failing to meet protected area objectives for Freshwater Pearl Mussel (19 of 27 catchments of S.I. 296 2009)

Kanturk WWTP

North Cork Creameries Co-operative (Section 4 site) – licensed industry with chemistry indicating elevated levels of phosphate and ammonia

EPA file for North Cork Creameries Co-operative is here

https://epawebapp.epa.ie/licences/lic_eDMS/rss/P1051-01.xml

https://www.independent.ie/business/farming/news/courts/north-cork-creameries-co-operative-pleads-guilty-to-polluting-allow-river-38524477.html

AIE: Salmon Farm Mortalities

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.

Sea Lice Monitoring and Control

All finfish farms are obliged to monitor for sealice on an ongoing basis and to take remedial action. This involves the inspection and sampling of each year class of fish at all fish farm sites fourteen times per annum, twice per month during March, April and May and monthly for the remainder of the year except December-January. Only one inspection is carried out during this period.

During 2020, a total of 209 sea lice reports (consisting of 108 MI reports and 101 farm reports) were received from 22 active farm sites.

One inspection was not undertaken by the Marine Institute on fish health grounds.

Shot Head, Bantry Bay, Salmon Farm Licencing

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://afloat.ie/port-news/fishing/aquaculture/item/50954-licence-granted-for-bantry-bay-salmon-farm-plans-despite-strong-opposition

https://www.irishexaminer.com/news/munster/arid-40327370.html

https://www.fishfarmingexpert.com/article/mowi-ireland-wins-10-year-campaign-for-new-salmon-farm/

Salmon Farms Ireland – Licence Status

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

Aquaculture Licences Appeals Board (ALAB)

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

Deenish Island Salmon Farm

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).