Save Bantry Bay Submission: National Strategic Plan for Sustainable Aquaculture Consultation

Save Bantry Bay Submission: National Strategic Plan for Sustainable Aquaculture Consultation

The Minister for Agriculture, Food and the Marine is inviting submissions on a new National Strategic Plan for Sustainable Aquaculture Development and related strategic environmental assessment and appropriate assessment.

Deadline for receipt of submissions is 5.30pm on 24 July 2015.

A copy of the draft Plan and associated environmental report and appropriate assessment are available for download.

A written submission or observation with respect to the draft Plan and associated environmental report may be made to Department by the deadline date and will be taken into consideration before finalisation of the Plan. Submissions should be emailed to with the subject heading ‘NSPA Consultation’ or alternatively may be posted to: Pauline McDonnell Marine Agencies & Programmes Division Department of Agriculture, Food and the Marine National Seafood Centre Clonakilty Co. Cork. Phone enquiries to Damien Clarke at 023-8859547


Below is a copy of the submission made by Save Bantry Bay.




Pauline McDonnell

Marine Agencies & Programmes Division

Department of Agriculture,

Food and the Marine National Seafood Centre


Co. Cork



By email only:


30 June 2015


Dear Sir or Madam;


RE: National Strategic Plan for Sustainable Aquaculture Consultation


We have a number of concerns regarding the National Strategic Plan for Sustainable Aquaculture recently published. In particular:


  1. A review and revision of the aquaculture licensing process, including the applicable legal framework, is proposed.


The review however does not address the fundamental conflict of interest currently lying at the heart of the system. Today DAFM, and government bodies under its remit such as BIM and the Marine Institute, act as the assessor, decision maker, policer of licences, and enforcer of terms and conditions of licences. Such a system is not transparent and allows far too many opportunities for corruption. It needs to change.


With BIM now applying for Europe’s largest salmon farm licence from DAFM, it is impossible to state DAFM is an impartial decision maker in such a situation. It begs the question, what will happen if such a salmon farm breaks the terms of licence or fails to comply with law?


As it stands, DAFM is already hiding information and refusing transparency of reporting. Ever since February 2014 when a quarter of a million salmon escaped in Bantry Bay from a private salmon farm, a concerted effort has been made by environmental groups to establish what went wrong. Yet DAFM are refusing to release reports regarding this environmental disaster stating they ‘are not in the public interest’. This raises the question of what have they got to hide?


Given the track record, it’s impossible to assume the situation will improve once DAFM own the licenses, via BIM. Indeed, the situation is likely to get worse and the negative impacts of open cage sea farming of salmon to further hidden from the public eye.


To ensure DAFM restores the public’s respect, the law on approval, policing and enforcement of licences must be made genuinely transparent in this review.


A further concern is the proposed time frame in which decisions are to be made. To date, Minister Coveney has had a number of salmon farm licence applications on his desk for over 5 years. He has been unable to come to a decision regarding these licenses due to having inadequate information or advice.


How can it be proposed to reduce the time frame from what is often years to a mere 30 weeks, while maintaining the degree of careful consideration currently required to support an appropriate decision? The systems do not state the level of expertise to be involved, nor is a minimum requirement of consultation noted. Instead it appears licence applications will be rushed through, without the appropriate due diligence.



  1. It is noted there will be applied research and collaborations between industry, scientific and development bodies. To date such research collaborations, most notably involving the Marine Institute, has resulted in considerable controversy. As is known from media coverage and submissions to the EU over the past couple of years (SBB Letter to European Commission Pilot Case 764-09 further scientific evidence Jan 2014), the Marine Institute has put its own, and the Irish governments, reputation on the line.


Further collaborations between industry and government bodies are not impartial. Such studies will serve little purpose other than reinforcing an image of DAFM, and those under its remit, as corrupt organisations reliant on bad science.


Now is the time for truly independent research studies to be commissioned by impartial and reputable bodies. Only this way will results be trusted, and credibility of Irish government bodies be rebuilt, the public’s respect for Irish government institutions be restored.



  1. Only a very small commitment to expand closed containment land based fin fish farming (also known as RAS) is proposed. The aim to extending existing land based fin fish farming from 70 tonne to 100 tonne over the next 7 years, with total grant aid of a mere €1 million and a €50k limit per farm, is underwhelming to say the least.


Today there is considerable expansion of such land based salmon farms in other nations, as they have acknowledged this is the future of fin fish farming. While the report acknowledges this stating:


Considerable international developmental effort is being put into determining the commercial viability of land based RAS systems for the large scale production of salmon. There appears to be a market niche for such a product if the current technological challenges associated with an economically viable production system can be overcome”.


This is based on data which has been gathered in years passed. These technologies are moving at a rapid rate, and today’s data suggests such systems to be as economically viable as open cage sea farming of salmon.


Why? While set up costs are greater in land based salmon farming, operational costs are lower. For in contained land based systems disease, parasites and environmental issues are not a concern. Meanwhile, open cage farming are facing ever increasing costs from amoebic gill disease outbreaks, pancreatic disease, jelly fish swarms, algal blooms, sea lice infestations and treatment resistance, and so on.


It is also this ‘containment’, and the low environmental impact of the closed land based farms, which offers the product’s unique selling point. For such salmon may be consumed without guilt of depleting wild stocks, nor the concerns for the environmental impacts of open cage sea farming. As trends in the buying patterns of the affluent and luxury markets show there is an ever increasing demand for evidence of true sustainability, traceability and ‘zero footprint’ products.


To only offer a token gesture of €1 million over 7 years to land based fin fish farming (with no commitment to any development of closed containment for salmon farming) is to miss a trick.


Without adequate investment Ireland will fall behind other nations. If Ireland wishes to push land-based salmon farming on to the agenda, a greater investment and incentives for producers will be required.



  1. One of the key arguments for increasing salmon farming has been job creation. Yet, this report states “Full Time Employment (FTE) has fallen in the salmon sector”. Part time and casual employment has increased a little. Today open cage sea farming of salmon (on-growing) accounts for less than 90 full time jobs in Ireland, with smolt hatchery accounting for 37 full time jobs. A further 20 part time jobs exist across both smolt hatchery and on-growing. All other employment is on a casual basis and account for approximately 50 casual positions.


These figures make it quite clear that salmon farming is not the economic solution to high unemployment in remote coastal communities. Rather each salmon farm is unlikely to create more than a couple of jobs at most, and at considerable environmental cost. Local people in these areas have a close relationship with the land and sea. They do not want jobs at any price, as has been shown by the widespread campaigning against proposed industrial scale salmon farms in Bantry, Galway and Kilkearan Bay.



  1. An investigation on the ‘contribution’ of aquaculture on local communities and ‘societal benefits’ is suggested. The negative impacts are not mentioned.


To date few, if any, studies on the negative impacts of aquaculture on inshore fisheries, tourism and communities have been completed. However, a mass of anecdotal evidence and increasing numbers of local campaign groups, reveals many inshore fishermen, tourists, anglers, marine leisure enthusiasts and walkers do not wish to see a pristine coastal environment sacrificed to industrial salmon farming. They do not believe the few jobs created by such aquaculture would compensate for the many jobs lost in the tourism and leisure industries. Indeed, the risk of a net loss of jobs is very real and of great concern in local communities.


Why? Contrary to what is stated in the report, that aquaculture is dominated by SMES, the open cage salmon farming sector is dominated by big businesses with a single company Marine Harvest running 75% of Ireland salmon farms. These operations create few local jobs, and their profits do not remain in the remote coastal communities where their farms are located.


In contrast, inshore fisheries, tourism, leisure and associated hospitality businesses are generally small, family owned and supporting people who have lived in these remote parts for generations. It is these small businesses that sustain the communities, keeping generations in these remote coastal parts.


To sacrifice these jobs, for the sake of multinationals whose profits benefit few other than the Oslo stock exchange, is to sacrifice the cultural and social heritage of these areas. To do so without even bothering to include potential negative impacts of aquaculture in research, and failing to investigate the local concerns, shows a total disregard for coastal communities and indeed rural Irish society as a whole.


Curiously, research on the development of marine tourism opportunities in aquaculture is also proposed. On the one hand it has been recognised that the south west of Ireland continue to attract visitors in considerable number, but the key draw of these areas appears to have been lost.


Today significant investment is placed in marketing the pristine, unspoilt and wild environments which are the key draw for visitors. Just look at the success of the ‘Wild Atlantic Way’ over the last year. To in turn suggest that by industrialising this landscape with a series of aquaculture facilities, will draw more visitors who would wish to visit these mega-farms, is a total contradiction.


To date few aquaculture facilities have proved a successful tourist attraction in Ireland. Furthermore, it is widely believed they will serve as a deterrent to visitors who wish to see a wild and untamed environment.


Therefore, when conducting research into the viability of aquaculture facilities as tourist attractions, it’ll be essential to ensure a cost – benefit analysis is a central feature of such research.


  1. The proposal to allow a single salmon farm to produce up to 7,000 tonnes raises a number of concerns about the environmental sustainability of such large salmon farming facilities.

Today the largest site in Ireland is for a biomass of just under 3,000 tonnes, and it is fully recognised that such farms come with considerable environmental impacts.

To double the size of farms will result in chemical pollution from sea lice treatments able to wipe out local crustacean stocks, fish fry in local breeding grounds, wild Atlantic salmon stocks and other protected species.

As is recognised by the report, there’s already the threat of eutrophication from existing salmon farms. To double biological pollution outputs, and associated oxygen demand, could be devastating for local wildlife, further exacerbating problems raised by the chemical pollution.

Ireland has legal obligations to the EU to sustain and improve marine water quality under the Marine Strategy Framework Directive, and protect many species dependent on coastal environments under the Habitats and Birds Directives. To approve plans that would do quite the opposite is unlawful and opens Ireland to risk of legal action.


To offer further information regarding our immediate concerns to increase salmon farming in Bantry Bay, a  briefing document is attached.

We look forward to hearing from you.




Yours sincerely,




Alec O’Donovan,

Secretary, Save Bantry Bay

Newton House,

Bantry, Co. Cork.




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