Below is the submission made by Friends of the Irish Environment to the consultation regarding Marine Harvest application for certification of their salmon farms by the Aquaculture Stewardship Council.
Fisheries & Aquaculture Administrator
SAI Global Assurance Services / Global Trust
Quayside Business Park, Mill Street
Dundalk, County Louth, IRELAND
6 July 2015
Re: Certification under Aquaculture Stewardship Council Salmon Standard for Marine Harvest in Ireland
Objection: Marine Harvest salmon farm at Innishfarnard, Castletownbere, County Cork [and Deenish County Kerry]
And: Observer Request for Site Visit
Dear Ms Ragg;
We note that as part of the Aquaculture Stewardship Council process, potential stakeholders are invited to participate and forward submissions to the Certification Body in relation to the Certification of Marine Harvest salmon farm at Innishfarnard, Castletownbere, County Cork.
We accordingly attach our recent Report on IRISH MARINE FISH FARMS INSPECTIONS 2012 – 2014.
We would draw your attention to the records revealed on ongoing overstocking at the Inishfarnard and Deenish Marine Harvest sites.
These sites have been overstocked for 3 consecutive years in spite of instructions to destock; in 2014 Marine Harvest Inishfarnard refused to give their stocking figures to the State’s authorised officers, as did Marine Harvest management of the Deenish Island site in County Kerry.
In the case of Marine Harvest’s operations at Deenish, the Certification appears to have taken place without proper examination of the relevant Inspection Checklist for Marine Farms of 10 June 2014.
According to the records you have published, Certification was authorised on 5 March 2015 on the basis of the State’s Fin Fish Inspection Report of 2013. [‘Audit report on file from 2013 (26/7/13) carried out by the Dept. of Agriculture food and marine engineer Mick Doyle and Noel O’Murchu.’] The ‘unsatisfactory’ inspection of 10 June 2014 detailing failure through continued overstocking in defiance of requests and refusal to provide stocking figures should have been examined during the audit, which was conducted between the 12th and 14th November 2014, five months after the 2014 Inspection and 5 months before Certification.
Overstocking in spite of repeated warnings is also recorded for successive years at Marine Harvest’s Tievetooey (Pettigo) site where the company advanced spurious legal grounds for their continued defiance of the Department’s instructions to destock. (Autumn smoults were not envisaged at the time of the licence issue in 1997 so the limit applied only to spring smolts, the claim being that therefore autumn smoults stocks were not limited by the Licensce.)
Certification took place at Deenish and is now proposed for Innishfarnard for operations that fail to meet your Principle 1: ‘Comply With All Applicable National Laws and Local Regulations’. Certification in these circumstances would in fact undermine the authority of the State.
Further, the Evaluation Summary under Section 5.1. Principle 1 does not accurately reflect the complex and unsatisfactory legal situation relating to requirement for Environmental Impact Assessment and Appropriate Assessment of the continued operation of fin fish farms through ‘continuity mechanisms’ after the expiry of their licences.
As the matter is complex and the legal interpretation of the Licensce stocking levels advanced by Marine Harvest have been rejected by the Minister [‘The operator’s interpretation of the relevant licence provisions, differed from that of my Department. The operator was advised that it must accept my Department’s interpretation’: PQ 9 June 2015], we would suggest that to meet Principle 1 you ensured that your certifier sought professional assistance to rexamine the legal standing of the aquaculture and foreshore licensing of these sites.
We understand that our feedback must be taken into account during these surveillance audits and would be grateful for your specific replies to our observations and the information provided.
To assist this process, we have appended to the Report a series of written Parliamentary Questions on these activities, the latest of which dates from June 17, 2015. In these the Minister outlines but does not detail his plans to address some of the issues we have raised, including a protocol for fin fish farm construction, a revision of the ‘Inspection Checklist for Marine Harvest Fin-Fish Farms’, and a commitment to bring overstocking under control ‘within a year’.
Certification is inappropriate until these issues are addressed, and we respectful request you to postpone any proposed certification for Marine Harvest operations at Inishfarnard and suspend Certification for Deenish fin fish farm operations until Marine Harvest complies with Principle 1 of the Aquaculture Stewardship Council Salmon Standard.
Finally, we would be grateful if you permitted a NGO Observers on your site Site Audit(s) 7th July 2015 to the 10th July 2015.
Contact for NGO Observers on Site Audit: 087 2176316.
Director, Friends of the Irish Environment
Friends of the Irish Environment is a non-profit company limited by guarantee.
It is a member of the European Environmental Bureau and the Irish Environmental Network.
Registered Office: Kilcatherine, Eyeries, Co Cork, Ireland. Company No. 326985.
Tel & Fax: 353 (0)27 74771 Email: firstname.lastname@example.org
Directors: Caroline Lewis, Tony Lowes