Mr. Noel O’Connor
Department of Agriculture, Food and the Marine
Johnstown Castle Estate
By email only: firstname.lastname@example.org
25 June, 2012
Dear Mr. O’Connor
RE: Submission to Stakeholder Consultation Food Harvest 2020
Save Bantry Bay are a diverse group of locals that are opposed to the further expansion of fish farming in Bantry Bay. Having read Food Harvest 2020 and the associated Stakeholder Consultation documents, we have a number of concerns.
Firstly, Food Harvest 2020 sets target for a 78% increase in aquaculture production between 2010 and 2020. This is an increase in production that is far greater than for any other area of farming, fisheries or forestry. Yet, while all other areas of production will have an environmental analysis completed, aquaculture will not.
Apparently, this is because the proposals have already been appropriately assessed. When we requested copies of this assessment, we were directed to a document produced by BIM in October 2008 entitled ‘Irish National Seafood Plan: Environmental Report’. How can a report published in 2008 possibly assess a strategy published in 2010?
What is more, the 2008 BIM report states that ‘…additional production, which in the case of fin-fish is projected to more than double, does not equate to an equivalent increase in the spatial area required for aquaculture licensing. Indeed, most of the projected production increases can be achieved by maximising the potential of existing licensed sites…’. However, since this statement was published in October 2008, BIM themselves are applying for a new salmon farm license in Galway Bay that is so vast it alone will double Ireland’s production of farmed salmon. On top of this, BIM have stated that in the near future they wish to develop two further ‘off-shore’ salmon farms of this scale on the west coast This Government proposal for three ‘large-scale deep water salmon farming sites’ is confirmed in Our Oceans Wealth – Towards an Integrated Marine Plan for Ireland, published by DAFM in October 2011. Meanwhile, BIM are actively supporting new private industry in-shore salmon farm license applications elsewhere, for example, Shot Head in Bantry Bay. Overall, this will lead to a massive increase in the spatial area dedicated to salmon farming, possibly by over 300%. Yet, none of this has been considered in the BIM’s environmental assessment report.
All in all, it is clear the 2008 BIM report is obsolete. It does not address the targets set in Food Harvest 2020. Nor does it assess the government’s current policy to increase the spatial area dedicated to salmon farming by such incredible scale.
We therefore request that a comprehensive environmental analysis of the aquaculture section of Food Harvest 2020 is completed, as is being done for all other areas of food production. Moreover, it would seem sensible that a coordinated approach is taken where Government supported industry strategies, such as Food Harvest 2020, are assessed alongside Government policy for the same area of food production.
A new Strategic Environmental Assessment of aquaculture development plans would ensure compliance with the EU SEA Directive which requires assessment of all aquaculture policies, including minor modifications to them that are likely to have significant environmental impact.