Thursday, 20 August 2015

Salmon Watch Ireland requests your assistance for this important project. Please support and help to build knowledge and understanding of the problems facing the Atlantic salmon.


ATLANTIC SALMON LOST AT SEA!



I would like to introduce you to an exciting project supported by the Atlantic Salmon Trust:  the film, ‘Atlantic Salmon – Lost at Sea!’

It has been my pleasure to work closely with the producer Deirdre Brennan who has been making this film for 6 years in the rivers of Europe, North America, Iceland, Greenland, and at sea in the Atlantic Ocean. It tells the story of the collapse in abundance of wild Atlantic salmon over the last thirty years. The film records the urgent quest to try to solve the mystery of the salmon’s life at sea and to answer the question: “why are salmon dying in greater numbers than ever before in their ocean environment and not returning to their native rivers?”

The film, takes the viewer on a journey through the mysterious world of the King of Fish, and highlights some of the important research, conservation and restoration work of AST and others in all the wild Atlantic salmon countries. It describers the ground-breaking research programme to track salmon on their epic migration to try to find out why and where they are dying at sea.

Filming is now complete and it is ready to edit.  In order to raise the last 10% of the budget needed, Deirdre has embarked on a Kickstarter campaign to bring in funds to finish the project. Kickstarter is a crowd-funding platform and in its 10 years has raised over $1.6 billion for creative projects, including many documentary films. All projects are vetted in advance. It is an all or nothing principle – if the goal is not reached, then no money changes hands.  The campaign is for 30 days and will run until September 15th. The goal is €
45,000.

Please support this most worthwhile venture. Its aim is to raise public awareness about the plight of our salmon. The film will be used widely at national, regional and local levels to raise money for salmon conservation. By contributing money – as much as you can afford, no matter how small an amount - to the film you are therefore directly supporting our international campaign to save the salmon.
Please see the link below for more details:


AST, supported by the Spey, Dee and Esks District Fishery Boards, has already contributed £12,000 to the project. Please help us to finish the job, by donating through Kickstarter – even €10 would help.
I trust we have your support.

With best wishes,

Ken

Professor Ken Whelan
Research Director
Atlantic Salmon Trust

Monday, 27 July 2015

RELEASE ORDERED OF BANTRY BAY SALMON FARM ACCIDENT REPORT


The Department of Agriculture, Food, and Fisheries’ refusal to release the accident report on the loss of 230,000 salmon in a February 2014 storm has been annulled by the Information Commission, Peter Tyndal.
Minister for Agriculture Simon Coveney’s Department had refused to release the report on the grounds that it was an 'internal communication' and that the public ‘interest would not be served by the disclosure’.
In its appeal to the Information Commissioner, FIE claimed the release is ‘a matter of extreme public importance not only in the light of the circumstances of the Gerahies incident, but also because of the failure of the Department to carry out its regulatory functions properly in ensuring compliance with aquaculture licensing conditions aimed at preventing the escape of fish.’
In response to a case taken by FIE to the High Court after a year’s delay, the Information Commissioner gave an undertaking on 6 July 2015 to the Court to rule on the case ‘within a week’.
The Department was ‘strongly of the view’ that the release of any parts of the deliberative process of advising the Minister what action to take ‘would be premature and would unduly constrain the Minister in respect of any action which he might deem appropriate.’
However, at a meeting in June 2015, the Department told the Information Commissioner that it was ‘not in a position to make a specific recommendation to the Minister and, at present, no proposal for action is under consideration’.
‘I do not accept’, the Information Commissioner wrote in the ruling on 13th July, 2015, ‘that the connection between the requested information and an ongoing, seemingly indefinite deliberative process provides an adequate basis for refusal.’
As to the public interest, the Commissioner wrote that ‘it is not enough to interpret AIE by national law alone but must be interpreted in the light of the Directive and indirectly the Aaarhus Convention.’
‘I also consider’, he concluded, ‘that there is a very strong public interest in maximising openness and accountability in relation to how the Department of Marine and the Marine Institute carry out their functions under the relevant legislation governing the aquaculture industry.’
A previous Report on the loss of 80,000 salmon in Clew Bay in 2010 blamed the disaster on Simon Coveney’s Department’s failure to enforce licensing conditions.
The Report stated ‘if a more rigorous/frequent mooring inspections programme had been in place it is possible – even likely - there would have been earlier detection which would therefore have avoided the November 2010 failures.’
A note by an Assistant Secretary on the Report states: ‘This Report clearly points to the fact that adequate systems in relation to certification, maintenance, inspection, repairs and records need to be in place for this type of installation’.

Tuesday, 21 July 2015

2nd International Sea Trout Symposium, Dundalk, Ireland 20-22 October 2015

Targeted at scientists, managers and other fishery stakeholder interests in the public and private sectors, the central aim is to promote the wider application of an evidence-based approach to the future management and regulation of the sea trout and to ensure that its often very special needs become fully integrated into catchment management plans and environmental impact assessments.
Symposium topics include:
  • Understanding Anadromy
  • Populations & Management
  • Movements & Migration
  • Ecology & Behaviour
  • Monitoring & Surveillance
  • Threat Assessment
  • Future management and research

Symposium Rates

  • Full 3-Day Delegate Package = €330 (includes Gala dinner and a copy of proceeding).
  • Basic 3-day Delegate Package = €230.
  • Student Delegate Package = €150. (Available only to Ph.D. and M.Sc. students)
  • Daily Attendance Package = €70.
Closing Date for Registration is the 04th September 2015

Location Notes:

The 2nd International Sea Trout Symposium will be held in Dundalk (Ireland) which is a pretty, historic town (charter granted in 1189) located in County Louth.  The town’s name, which was historically written in Irish as Dún Dealgan (meaning Dalgan’s Stronghold), has associations with the mythical warrior Cú Chulainn.  Dundalk has a long connection with sea trout as it is situated where the famous sea trout river, the Castletown River, flows into Dundalk Bay. The town is close to the border with Northern Ireland and equidistant from Dublin and Belfast.
More Information and registration:  http://seatroutsymposium.org/

Monday, 20 July 2015

Submission to the Department of Agriculture Food and the Marine on the draft National Strategic Plan for Sustainable Aquaculture

Development
1. Introduction
Salmon Watch Ireland (‘SWIRL’) is a not-fo-profit membership organization dedicated to
the restoration of wild salmon abundance. Its’ interest in making a submission on the draft
Strategic Plan for Sustainable Aquaculture Development (‘NSPSAD’) arises from the fact
that badly sited and poorly regulated and managed salmon farms constitute a significant
threat to specific populations of wild salmonids.
SWIRL believes that salmon farming is essentially unsustainable but that closed containment
farming could at least mitigate, and in some cases eliminate, the negative environmental
impacts of open cage farming. Ireland should, therefore, like Norway and others, be
planning to progressively transition to closed containment systems.
The comments below on the NSPSAD proposals for the expansion of open cage salmon
farming are made without prejudice to SWIRL’s general position on the need to transition to
closed containment.
This submission has the approval of the board of SWIRL.
2. Sea lice and escapees
Salmon farms constitute a threat to wild salmonids (salmon and sea-trout) because:
 They generate and concentrate sea lice populations well above the background levels
that exist in the natural environment and have a highly damaging effect on migrating
salmon and sea trout juveniles (smolts);
 Open cage systems of farming, such as are used in Ireland, are prone to escapes of
the stock being farmed through equipment failure, extreme weather conditions,
collisions with vessels, etc. These escapees may interbreed with wild stock and
compete for spawning space in rivers;
 Farmed salmon are prone to outbreaks of diseases (particularly amoebic gill disease
and pancreatic disease) to an extent unknown in the wild populations but which may
have the effect of raising levels in the wild populations.
This submission does not go into the detail of the conclusions of Irish and international
research into sea lice and escapee impacts because it is assumed that DAFM are already well
informed on these issues. Suffice to say that the issue of sea lice and escapees is virtually
ignored in the NSPSAD other than references to them as problems in the production cycle
(apart from one short reference on page 57). This contrasts with the approach of the
Norwegian and Scottish authorities which regularly acknowledge the threats to wild
salmonids posed by open cage salmon farming and the need to eliminate, or at any rate
mitigate, them.
3. Sustainability
Sustainable salmon farming is an oxymoron. Salmon, whether wild or farmed, are
carnivores. In the case of wild salmon the populations will grow or decline in line with the
available naturally occurring feed stock and a balance between the two maintained; in the
case of farmed salmon, man intervenes to capture marine protein, convert it into fish meal
and feed it to salmon in cages (where a high proportion of it is lost). Depending on the
technology used it can take up to four tonnes of fish meal and oil feed to produce one tonne
of farmed salmon. That is not a sustainable use of marine protein and, given the nature of
salmon, is not capable of being substituted by vegetarian products (notwithstanding the
ambition to ‘reduce dependence on fish meal and oil’ set out on page 69). It follows that the
definition of ecosystem-based carrying capacity used in the NSPSAD (‘In general terms,
carrying capacity for any sector can be defined as the level of resource use by humans or
animals that can be sustained over the long term by the natural regenerative power of the
environment’ – page 76) cannot be met by salmon farming.
In general SWIRL supports the six principles for the sustainable development of
aquaculture recommended by the Marine Institute (page 75) and their wholehearted
adoption, while it would not make salmon farming sustainable, would greatly improve the
current situation. But, as the NSPSAD itself acknowledges they are ‘high-level’, and it is not
easy to trace their alignment with the recommendations and actions set out in the document
– Principle 2 on Ecosystem Protection is one example of a less than robust connection
between the principle and the contents of the plan.
4. Closed containment/Recirculating aquaculture systems (RAS)
It is now well recognized internationally that the future of fin fish aquaculture, including that
of salmon and trout, lies in closed containment systems whether on land or in the sea.
Technical and economic research, especially in Canada, the United States, Norway and
Denmark in respect of salmon, has demonstrated that, while the financial model is more
demanding than low technology open cage farming (requiring more upfront capital
investment), the outcome can be more profitable for the producer and the collateral damage
to the environment reduced to a minimum – although it does not resolve the unsustainability
of the feed problem referred to above.
The NSPSAD does not seem to recognize (see pages 57 and 67) that closed containment
systems are well beyond the experimental stage and commercially viable systems are now
operating in the countries mentioned above and in Scotland. The Norwegian government is
actively promoting closed containment as the basis for future growth in their salmon
farming sector and Norwegian banks are financing new units; the Scottish government is
also now showing a great deal more enthusiasm for closed containment than the NSPSAD
exhibits; closed containment producers are supplying the market (albeit so far in relatively
small quantities) in the USA and Canada.
The NSPSAD totally lacks ambition and vision in this area. Unless the bar is raised
considerably in the redrafting of the plan Ireland is in danger of losing out in at least three
respects:
 Ireland will be a late adopter in the production of the more environmentally friendly
closed containment salmon which the market will begin to demand;
 In the medium term closed containment will drive prices down leaving open cage
product less competitive;
 The potential for growing Irish farmed salmon production to meet market demand
will not be realized;
 Ireland will miss the opportunity of getting into the research, development and
manufacturing phases of a rapidly moving technology to which our research
institutes, scientists and technologists are well capable of contributing and which has
considerable employment generating potential.
5. Regulation of salmon farming
While the NSPSAD sets out the framework for a more certain and transparent process for
handling aquaculture applications it apparently contemplates a continuation of the current
deeply flawed system of regulation. The chief flaws in the current regime are that:
 Regulation is by the softest of soft law through protocols that may or may not be
cross referenced with the licences;
 There is no consistent and rigorous enforcement of the protocols;
 There is a tangled web of conflicts of interest within and between the Minister of
Agriculture, Food and the Marine, his Department and its agencies (BIM and the
Marine Institute), in promoting, investing in, licencing and regulating salmon farms.
It is the view of Salmon Watch Ireland that:
 The existing protocols(and any future licence conditions that may be introduced)
need to be enshrined in secondary legislation to ensure their enforceability; the
existing protocol regime has never been tested even in the District Court so their
enforceability is totally unknown;
 The Fisheries (Amendment) Act 1997 should be amended to more properly define
offences and penalties – it is the opinion of some legal authorities that even the nonpayment
of licence fees may not be an offence under the current provisions;
 Responsibility for the enforcement of all regulations involving salmon farms (and
perhaps aquaculture more generally) should be transferred to a single agency, such as
the Sea-Fisheries Protection Authority, which has the resources, expertise and focus
to be effective;
 While the regular Marine Institute monitoring of sea lice levels should be
maintained, individual farms should be responsible for collecting data on a
continuous basis to enable them manage within the sea lice limits in their licences –
in other words they should not, as of now, ignore sea lice levels until a notice to treat
is received from the Department. They would thereby become liable to penalties if
Marine Institute monitoring detects excessive levels of sea lice.
Terrestial farming is subject to strict regulation in respect of its environmental impacts and
the health standards of its output. There is no reason why a similar regime should not exist
in the case of salmon farming and, indeed, aquaculture in general.
6. Size of off-shore farms
The NSPSAD (page 77) states that ‘new individual offshore (SWIRL emphasis) salmon farms’
will be limited to 5,000 tonnes peak biomass with provision for increasing it over time to
7,000 tonnes peak biomass.
This all sounds very progressive but all open cage salmon farms are by definition ‘offshore’.
In addition, the definition of ‘offshore’ adopted by BIM in their application for a salmon
super-farm in Galway Bay and their putative application for Inish Turk do not involve
moving very far offshore and both are adjacent to the estuaries of significant salmonid
rivers, including those in salmonid SACs.
Without a clearer definition of what constitutes ‘offshore’ than that set out on page 57 then
the already not very restrictive proposed limitation on size will be meaningless. The
definition has to include a minimum separation of 25/30 km from the nearest salmonid
SAC.
7. Concentration of control of salmon farms
The NSPSAD makes no reference to the growing concentration of the control of Irish
salmon farming in the hands of one company. It is believed that through the ownership and
the leasing of licences the publicly quoted Norwegian company, Marine Harvest, now
controls some 70% of Irish farmed salmon production. If it is indeed the case that 80% of
Irish production is certified organic and that 90% of that is exported at premium prices
(page 39 of the NSPSAD) then Marine Harvest prima facie enjoys a dominant position in the
Irish salmon farming market and is capable of dictating market conditions. This is all the
more worrying given the fact that in 2014 Marine Harvest was fined Euro 20 million by the
European Commission for a competition law transgression in Scotland involving the
acquisition of another enterprise. (Case No COMP/M.7184 –Marine Harvest/Morpol, 23 July
2014).
It is not unreasonable to expect that the NSPSAD would have identified this factor as a
weakness or threat to the development of Irish salmon farming somewhere in its’
considerations and to have described the mitigating actions to be taken.
8. Employment
In 2013 the NSPSAD shows (page 38) that there were less than 100 full time jobs involved
in salmon production and less than 40 in smolt production with, in addition, something of
the order of another 50 part-time and casual employees; this produced 9,000 tonnes of
marketable salmon (page 36). This employment is thinly spread over some 19 farms from
Donegal to West Cork. This data contrasts sharply with the BIM statement, in its
Environmental Impact Statement for a Deep Sea Fish Farm Development in Galway Bay,
that Marine Harvest alone ‘brings direct employment to the North and Western regions with
a total of 260 people in employment’ (page 23 of the EIS). In the same EIS BIM claims
that the employment on the Galway Bay facility would peak at 65 ‘for a 15,000 tonne salmon
grow out operation’. It is clear that assessments of current and future employment
attainment in the salmon farming sector is all over the place and that it is, therefore, very
difficult to make any defensible estimate of the economic and social value of this sector.
Salmon Watch Ireland

Sunday, 19 July 2015

Response by Salmon Watch Ireland to the request of 30 April 2015 by Bord Iascaigh Mhara for ‘topics or areas that need to be covered in the Environmental Impact Assessment’ for a proposed marine fish farming unit off Inishdalla, South East of Inishturk, Co Mayo.


1. Salmon Watch Ireland is a not-for-profit organisation concerned with promoting measures that contribute to the restoration of salmon abundance. The remarks set out in this submission have been approved by the Board of Salmon Watch Ireland. 
2. There are at least four significant categories of ‘key stakeholders with an interest in this location’ who have been omitted from the invitation to make submissions to BIM on the proposed Environmental Impact Assessment (‘EIA’). 
They are:  NGOs with an interest in the conservation of wild Atlantic salmon and sea trout. The identity of a number of these organisations is well known to BIM. There are four NGOs listed in the ‘Agencies, NGOs, Representative organisations’ in Appendix 4 of the letter and none of them has any specific competence in the fields of salmon and sea trout conservation; 
 The owners and managers of wild Atlantic salmon and sea trout recreational fisheries that will potentially be affected by the proposed farm should it be licenced. This would include, at least rivers flowing itno Ballinakill Bay and Killary Harbour and the Culfin River; 
 The holders of draft net licences in Killary Harbour that will potentially be negatively affected by the proposed farm should it be licenced; 
 The Inland Fisheries Division of the Department of Communications, Energy and Natural Resources which has responsibility for the protection of wild salmonids. 

While any or all of these persons and organisations may, as Salmon Watch Ireland is doing, make unsolicited submissions their omission from those specifically invited to contribute, in the light of the three year old controversy about the Galway Bay project and the much longer running campaign for the proper siting and management of salmon farms, can only be seen as a deliberate decision by BIM.
3. The Habitats Directive (Article 6.3) requires that ‘any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans and projects, shall be subject to appropriate assessment’. The cumulative effect of projects must, therefore, be assessed and it will be necessary in the EIA to examine the effect of all salmon farms in the area on the rivers in Ballinakill Bay and Killary Harbour (Owengarve, Dawros, Bundorragha and Errif) and on the Culfin River. All of these are within the generally acknowledged sea-lice impact zones of the existing and proposed farms – including that of the unlicensed (but officially tolerated) farm in Ballinakill Bay. 
4. In the creation of wild salmon river sanctuaries the Norwegian authorities have created a cordon sanitaire of 30km from the mouth of each fjord within which no open cage salmon farm can operate. Similar mitigation measures should be adopted in Ireland and their utility considered in the assessment of the risks associated with the proposed Inishturk farm. 
5. The 30 April 2015 letter from BIM to consultees describes the farm as having ‘an average biennial output of 4,000 tonnes’ and that ‘this project has the potential to create 50 direct and 25 indirect jobs’. This level of production is about one third larger than the Clare Island farm which directly employs nothing like a pro rata number of people as is being claimed for Inishturk. 
6. Salmon Watch Ireland has the following comments on Appendix 1:  ‘Importance to society’ and ‘economic value to the local or wider community’ are cited as factors in determining ‘receptor sensitivity’. It will be important here, in assessing negative impacts of the proposed farm, that socio-economic costs such as dis-employment in the recreational angling sector is properly research and taken into account; 
  In assessing ‘impact significance’ it is important that experience in jurisdictions other than Ireland and the best available up-to-date scientific evidence be considered. A failure to do so will leave any licencing decisions based on the resulting inadequate EIA open to legal challenge.
 7. The checklist in Appendix 2 of the information to be contained in the EIS is comprehensive but will need to be expanded to include: 
 Developments in other jurisdictions about restrictions on the use of chemical materials (such as teflubenzuron) approved for use in Ireland – a precautionary approach to this issue would dictate that;  Evidence of the flows of migratory (especially juvenile) salmon and sea trout through the area of the farm which is widely thought to be a major channel for such activity. The kind of unsupported assertions in the EIA for the Galway Bay project about salmonid migration routes will not be sufficient;
 Greater clarity in ‘mitigation measures’ about the extra requirements in the licence agreement for the management of the farm with BIM (referred to in the covering letter) over and above those of the statutory licence conditions. 8. In relation to Appendix 3 Salmon Watch Ireland has the following comments; 
 As mentioned above more than a ‘literature review’ is going to be needed to assess the significance of the site of the proposed farm in the migratory life of salmonids;
 A key issue not addressed in the wild salmon and sea trout section is the growing immunity of sea lice to existing pesticides. It will be necessary to outline how this phenomenon is to be addressed.

Wednesday, 15 July 2015

1. Introduction

Salmon Watch Ireland (‘SWIRL’) is a membership organization dedicated to the restoration of salmon abundance. Its’ interest in making a submission to the Joint Oireachtas Committee on the draft Strategic Plan arises from the fact that badly sited and poorly regulated and managed salmon farms constitute a significant threat to specific populations of wild salmonid stocks. SWIRL believes that salmon farming is essentially unsustainable but that closed containment farming could at least mitigate, and in some cases eliminate, the negative environmental impacts of open cage farming. Ireland should, therefore, like Norway, be planning to progressively transition to closed containment systems. The comments below on the draft Strategic Plan’s proposals for the expansion of open cage salmon farming are made without prejudice to SWIRL’s general position on the need to transition to closed containment. This submission has the approval of the board of SWIRL.

2. Sea lice and escapees

 Salmon farms constitute a threat to wild salmonids (salmon and sea-trout) because:

  • They generate and concentrate sea lice populations well above the background levels that exist in the natural environment and have a highly damaging effect on migrating salmon and sea trout juveniles (smolts); 
  • Open cage systems of farming, such as are used in Ireland, are prone to escapes of the stock being farmed through equipment failure, extreme weather conditions, collisions with vessels, etc. These escapees may interbreed with wild stock and compete for spawning space in rivers; 
  •  Farmed salmon are prone to outbreaks of diseases (particularly amoebic gill disease and pancreatic disease) to an extent unknown in the wild populations but which may have the effect of raising levels in the wild populations. This submission does not go into the detail of the conclusions of Irish and international research into sea lice and escapee impacts because it is assumed that Inland Fisheries Ireland will have comprehensively dealt with these matters in their presentation and that the Joint Committee is, therefore, fully informed of them. Suffice to say that the issue of sea lice and escapees is virtually ignored in the draft Strategic Plan other than references to them as problems in the production cycle (apart from one short reference on page 57). This contrasts with the approach of the Norwegian and Scottish authorities which regularly acknowledge the negative impacts of salmon farming on wild salmonids and the need to eliminate, or at any rate mitigate, them.

 3. Sustainability

 Sustainable salmon farming is an oxymoron. Salmon, whether wild or farmed, are carnivores. In the case of wild salmon the populations will grow or decline in line with the available naturally occurring feed stock and a balance between the two maintained; in the case of farmed salmon, man intervenes to capture marine protein, convert it into fish meal and feed it to salmon in cages (where a high proportion of it is lost). Depending on the technology used it can take up to four tonnes of fish meal and oil feed to produce one tonne of farmed salmon. That is not a sustainable use of marine protein and, given the nature of salmon, is not capable of being substituted by vegetarian products (notwithstanding the ambition to ‘reduce dependence on fish meal and oil’ set out on page 69). It follows that the definition of ecosystem-based carrying capacity used in the draft Strategic Plan (‘In general terms, carrying capacity for any sector can be defined as the level of resource use by humans or animals that can be sustained over the long term by the natural regenerative power of the environment’ – page 76) cannot be met by salmon farming. In general SWIRL supports the six principles for the sustainable development of aquaculture recommended by the Marine Institute (page 75) and their wholehearted adoption, while it would not make salmon farming sustainable, would greatly improve the current situation. But, as the draft Strategic Plan itself acknowledges they are ‘high-level’, and it is not easy to trace their alignment with the recommendations and actions set out in the document – Principle 2 on Ecosystem Protection is one example of a less than robust connection between the principle and the contents of the plan.

4. Closed containment/Recirculating aquaculture systems (RAS) It is now well recognized internationally that the future of fin fish aquaculture, including that of salmon and trout, lies in closed containment systems whether on land or in the sea. Technical and economic research, especially in Canada, the United States, Norway and Denmark in respect of salmon, has demonstrated that, while the financial model is more demanding than low technology open cage farming (requiring more upfront capital investment), the outcome can be more profitable for the producer and the collateral damage to the environment reduced to a minimum – although it does not resolve the unsustainability of the feed problem referred to above. While the draft Strategic Plan does not seem to recognize this (see pages 57 and 67) closed containment systems are beyond the experimental stage and commercially viable systems are now operating in the countries mentioned above and in Scotland. The Norwegian government is actively promoting closed containment as the basis for future growth in their salmon farming sector and Norwegian banks are financing new units; the Scottish government is also now showing a great deal more enthusiasm for closed containment than the draft Strategic Plan exhibits. The draft Strategic Plan totally lacks ambition and vision in this area. Unless the bar is raised considerably in the redrafting of the plan Ireland is in danger of losing out in at least three respects:
  • Ireland will be a late adopter in the production of the more environmentally friendly closed containment salmon which the market will begin to demand; 
  •  In the medium term closed containment will drive prices down leaving open cage product less competitive; 
  • The potential for growing Irish farmed salmon production to meet market demand will not be realized; 
  • Ireland will miss the opportunity of getting into the research, development and manufacturing phases of a rapidly moving technology to which our research institutes, scientists and technologists are well capable of contributing and which has considerable employment generating potential.
5. Regulation of salmon farming

While the draft Strategic Plan sets out the framework for a more certain and transparent process for handling aquaculture applications it apparently contemplates a continuation of the current deeply flawed system of regulation. The chief flaws in the current regime are that: 
  • Regulation is by the softest of soft law through protocols that may or may not be cross referenced with the licences; 
  • There is no consistent and rigorous enforcement of the protocols; 
  • There is a tangled web of conflicts of interest within and between the Department of Agriculture, Food and the Marine and its agencies, BIM and the Marine Institute, in promoting, investing in, licencing and regulating salmon farms. It is the view of Salmon Watch Ireland that: 
  • The existing protocols(and any future licence conditions that may be introduced) need to be enshrined in secondary legislation to ensure their enforceability; the existing protocol regime has never been tested even in the District Court so their enforceability is totally unknown; 
  • The Fisheries (Amendment) Act 1997 should be amended to more properly define offences and penalties – it is the opinion of some legal authorities that even the non-payment of licence fees may not be an offence under the current provisions; 
  •  Responsibility for the enforcement of all regulations involving salmon farms (and perhaps aquaculture more generally) should be transferred to a single agency, such as the Sea-Fisheries Protection Authority, which has the resources, expertise and focus to be effective; 
  • While the regular Marine Institute monitoring of sea lice levels should be maintained, individual farms should be responsible for collecting data on a continuous basis to enable them manage within the sea lice limits in their licences – in other words they should not, as of now, ignore sea lice levels until a notice to treat is received from the Department. They would thereby become liable to penalties if Marine Institute monitoring detects excessive levels of sea lice. 
Terrestrial farming is subject to strict regulation in respect of its environmental impacts and the health standards of its output. There is no reason why a similar regime should not exist in the case of salmon farming and, indeed, aquaculture in general.

6. Size of off-shore farms

The draft Strategic Plan (page 77) states that ‘new individual offshore (SWIRL emphasis) salmon farms’ will be limited to 5,000 tonnes peak biomass with provision for increasing it over time to 7,000 tonnes peak biomass. This all sounds very progressive but all open cage salmon farms are by definition ‘off shore’. In addition, the definition of ‘offshore’ adopted by BIM in their application for a salmon super-farm in Galway Bay and their putative application for Inish Turk do not involve moving very far offshore and both are adjacent to the estuaries of significant salmonid rivers, including those in salmonid SACs. Without a clearer definition of what constitutes ‘off shore’ than that set out on page 57 then the already not very restrictive proposed limitation on size will be meaningless. The definition has to include a minimum separation of 25/30 km from the nearest salmonid SAC. 

7. Concentration of control of salmon farms 

The draft Strategic Plan makes no reference to the growing concentration of the control of Irish salmon farming in the hands of one company. It is believed that through the ownership and the leasing of licences the publicly quoted Norwegian company, Marine Harvest, now controls some 70% of Irish farmed salmon production. If it is indeed the case that 80% of Irish production is certified organic and that 90% of that is exported at premium prices (page 39 of the draft Strategic Plan) then Marine Harvest prima facie enjoys a dominant position in the Irish salmon farming market and is capable of dictating market conditions. This is all the more worrying given the fact that in 2014 Marine Harvest was fined Euro 20 million by the European Commission for a competition law transgression in Scotland involving the acquisition of another enterprise. (Case No COMP/M.7184 –Marine Harvest/Morpol, 23 July 2014). It is not unreasonable to expect that the draft Strategic Plan would have identified this factor as a weakness or threat to the development of Irish salmon farming somewhere in its’ considerations and to have described the mitigating actions to be taken.

Salmon Watch Ireland 15 July 2015

Saturday, 11 July 2015

Atlantic Salmon Trust Article on Salmon Problems

IS THE WILD ATLANTIC SALMON A DOOMED SPECIES?

I was asked by the Field to write a response to the question above. An edited version of the draft below was published in the May edition of The Field. TA

The wild Atlantic salmon is not only a valuable international resource. The salmon has been at the heart of national cultures of countries in the North Atlantic region for at least twenty thousand years. The carved salmon in a Dordogne cave and the Glamis Stone testify to its spiritual importance, while In Canada and Finnmark, First Nation people still regard the salmon as a sacred birthright.
More recently, the late Poet Laureate, Ted Hughes, celebrated the salmon’s life cycle in elemental terms in his poem ‘Salmon Eggs’.

The salmon’s relationship with people spans human existence, from its mystical beginnings in the Stone Age to today’s supermarket shelves crammed with slabs of farmed protein. The life strategy of the salmon also gives it a unique status as a ‘barometer species’, providing detailed information on our changing environment.

Very few other species of fish have an international treaty organisation to protect them. Governments of Atlantic salmon countries are signatories of NASCO, which is supported by its own research board. With access to the best fishery scientists and 34 third sector interest groups, the existence of NASCO is a measure of the importance given by governments to conserving the wild Atlantic salmon.

Despite such heavyweight support, the future of the salmon is uncertain. The hard truth is that the wild Atlantic salmon populations are in danger of extinction, perhaps not imminently everywhere, but at the very least in its southern range.

Among many possible causes for the salmon’s decline, the most threatening and difficult to attribute is climate change, the most obvious effect of which is ocean warming. Salmon are cold-water fish. Higher temperatures impact on their marine and freshwater habitats, and reduce the abundance of their prey species.

The key question is, can human intervention make any difference at all to mitigate the effects of climate change on salmon stocks at sea?

Concern over the decline of stocks of wild Atlantic salmon by over 60% in 40 years prompted NASCO in 2008 to launch the SALSEA (salmon at Sea) project. Dr Malcolm Windsor of NASCO, explained the goal of the SALSEA Programme as: “to increase understanding of how salmon use the ocean, where they go, how they utilise currents and the ocean’s food resources and what factors influence their migration and distribution at sea”.

Since then there have been unprecedented efforts by scientists from the North Atlantic salmon countries to answer the question, “where, when and how are such high numbers of salmon dying at sea?”

Further north, other European rivers are starting to record the effects of climate change. In some Pennine and Scottish river catchments, planting programmes have been implemented to protect juvenile salmon from high water temperature caused by direct sunlight on shallow upland streams.

In coastal waters studies of effects of drought conditions on salmon waiting in estuaries indicate that up to 50% may die from a range of causes, including high temperatures, predation, coastal netting, salmon farming, pollution and disruption to migrations caused by renewable energy projects. Similar problems of high summer temperatures are also affecting North American rivers, such as the Mirimachi, and the rivers of Maine, Quebec and Nova Scotia.

Severe storms that affect the top layers of the pelagic zone of the Ocean’s water column can change surface currents and throw migrations of post-smolt salmon off course.

The Atlantic salmon is already under severe threat: it is an endangered species in the United States, while Canadian rivers flowing into the Bay of Fundy historically had annual runs of over 40,000 salmon, they now have less than 200. Portuguese rivers have lost nearly all their salmon, the rivers of Galicia and Asturias are on the edge, as are the rivers of southern France, despite heroic efforts by fishery managers. The Allier, for example, a tributary of the Loire, may soon no longer be able to sustain salmon, whose outgoing smolts and incoming adults have to negotiate more than 800 kms of the river’s main stem, which for most of the year is too hot for salmon to survive.

As Dr Patrick Martin, the Loire’s head conservationist, commented recently, “the Loire salmon’s migration window is closing”, and with that closure the opportunity for them to migrate is lost, perhaps for ever

The relentless march northwards of oceanic and terrestrial warming is squeezing the salmon’s habitat at all stages of its life cycle in rivers and at sea.

The most urgent issues, in the context of marine mortality and with salmon now extinct in more than 300 rivers, are:

. The effects of salmon farming. With a global ratio of one wild salmon to 200 farmed fish in open net cages ‘sharing’ the same coastal waters, an uncompromising precautionary approach should apply in licencing such facilities . Parasites, genetic ingression, pollution and disease from salmon farms may affect wild salmon much further away than the locality of the salmon farm.

. Mixed stocks netting which kills salmon from unknown rivers of origin, continues despite international pressure to end it.
In 2013 for example, one Scottish coastal net fishery killed 7,159 salmon and grilse, while the total number of salmon killed by nets in England and Wales was 24% above the average of the previous five years.

. Atlantic salmon swim with other pelagic fish, including mackerel and herring. Some salmon are being accidentally caught up in the nets of commercial trawlers. We need to know the extent of that ‘by-catch’, as well as where and when it takes place.

. Climate change, especially ocean warming must be assessed with the question, ‘is extinction of the species inevitable?’
If the answer to that question is yes, what is the timescale? What, if anything, can be done to delay that inevitability?
If the answer is no, can we find ways to give the wild salmon time and space for its natural resilience to kick in?

There is evidence that salmon have survived massive geophysical and climatic changes, including at least two ice ages. What can be learned from the historical and current life strategies of the species? Can we find ways of integrating our restoration efforts with that innate resilience?

Most conservation efforts concentrate on rivers. Salmon have been categorised as freshwater fish with a marine migratory phase. Most resources are consequently spent on restoring riparian habitats and studying the freshwater phase of the salmon’s life cycle. More needs to be known about the salmon’s life at sea. Already in Canada, Ireland, Norway, and Scotland, new tracking technologies are deployed to determine where salmon go, and where obstacles to migration exist.

A ‘Big Picture’ strategy, encompassing the whole life of the salmon, is now badly needed. Recent advances in freshwater fisheries management must continue, because each river catchment is unique, as are the populations that comprise its stock. Their survival depends on genetic diversity. It is now time for the Atlantic salmon countries to plan on a larger scale than hitherto on the basis of the following themes:

1. Continue to improve freshwater productivity through river catchment, ecosystem-based assessment, monitoring and actions. The excellent work being done by agencies and rivers trusts is essential, and must continue.

2. Along the coasts and in the ocean the precautionary approach must be used to demand that the burden of proof for new engineering projects does not harm the environment. Issues such as by-catch, renewable energy projects, poaching, salmon farming, coastal and drift netting and pollution, where human actions are the cause of disruption, are the starting point.

3. New methods of tagging & ocean tracking, with advances in chemical analysis, plankton sampling, genetics and DNA analysis, are already extending knowledge of salmon behaviour in the ocean. Mapping migration routes, and attributing populations to regions and even individual rivers should enable scientists to predict future abundance, or otherwise. Appropriate management action can then be taken in real time, as already happens to some extent in Ireland, Canada and Norway.

4. A ‘big picture’ strategy to bring more salmon back to their rivers requires a new international effort and level of cooperation. Large amounts of private sector money from the salmon countries of the North Atlantic region will be needed to pay for research and monitoring at sea. The process of mapping out safe migration ‘corridors’ and, through NASCO, negotiating international agreements to protect salmon at sea, must follow.

Recent catches. Do they tell the whole story?
Rod catches in many fisheries of the North Atlantic countries have been among the lowest ever recorded. In some rivers in North America, Iceland, Norway, Ireland and the UK, rod catches in 2014 were lower than the five year average. The main exception was Russia’s Kola Peninsula, especially Barents Sea rivers, where both the numbers and quality of salmon are holding up well.

But, do rod catches provide reliable data for stock assessment? As with most issues in the natural world, the situation is more complex than might at first appear. For example, spring salmon, returning to some Scottish and Irish rivers after two or more years feeding at sea, were in 2014 caught in reasonable numbers and were in excellent condition. The Irish Slaney, for example, had its best spring returns for thirty years, with most fish in prime condition and with average weights of 12lbs to 15lbs. A similar spring season was enjoyed by rods on some Scottish east coast rivers. Nearly all these fish were caught and released, while coastal netting of salmon was delayed until April.
Later in 2014 low water and high temperature conditions in many North Atlantic rivers did not favour high rod catches. Grilse returns in European salmon countries were at best variable, in some cases virtually non-existent. There is also evidence that extreme flooding in the wake of Hurricane Bertha reduced juvenile density considerably in some Scottish upper catchment tributaries.

Some freshwater fishery managers are declaring that there is little that can be done to improve the situation at sea, so efforts should be stepped up to improve freshwater productivity.
While that view is understandable, it does not address the fact that more than 90% of wild Atlantic salmon are dying at sea, whereas only forty years ago the figure was more like 65%.
If the percentage of smolts that survive to become adults could be increased by only 2% or 3%, there would be s significant difference to numbers of adult fish in our rivers.

Three projects to bring back more salmon to our rivers are listed below. Funds are urgently needed to implement them. We cannot predict the increase of returning salmon, but we can state that these projects are a practical starting point, with more projects to follow as knowledge of migrations improves.

By-catch
This innovative E-DNA pilot project addresses the issue of accidental by-catch by pelagic trawlers. Using forensic methods routinely used at scenes of crime, determine whether salmon DNA is present in body fluids on the decks, or on the nets of the giant pelagic trawlers. Our concern is the likelihood that post smolt migrations, relatively densely packed within coastal currents, may be inadvertently caught up in huge purse-seine nets. It is conceivable that the entire migration of a small river could be decimated by pelagic trawlers.

Coastal waters.
There is a high risk of smolt mortality in the days after they enter the sea, which may cause huge variations in adult return rates. Research is urgently required to establish where and how smolts die in the coastal zone. If we can identify the extent of the loss and the causes we can develop remedial actions. Return adults are also at risk in estuaries, where it is thought that up to 50% may die in adverse conditions.

Establishing protected migration corridors for salmon between their native river estuaries and their feeding grounds requires a coordinated international effort. In the longer term this approach may prove to be the most effective way to bring more salmon back to our rivers.

The effects of losing the salmon would be a disaster. Recent surveys in Canada, Scotland and England show that the wild Atlantic salmon is often central to rural economies. Salmon fishing tourism provides income and jobs for remote communities and gives them a strong sense of identity.

As food, driver of rural tourism, angler’s quarry or cultural icon, the existence value of the wild Atlantic salmon has never been fully appreciated. Without any doubt, to allow its demise would be a human catastrophe.

Continuing as we are is not an option.

TA

Tony Andrews
Executive Director
Atlantic Salmon Trust
www.atlanticsalmontrust.org