Tuesday, 22 December 2015

Galway Bay Salmon Farm Application Withdrawn by BIM

The application by BIM for a 15,000 tonne salmon farm in Galway Bay has been withdrawn. The reasons given were that the farm did not meet the criteria as set out in the governments plans for the sustainable development of aquaculture. It is uncertain as to whether a new application may be considered for a smaller farm which might comply with criteria outlined in aquaculture plan.
Salmon Watch Ireland welcomes the withdrawal of this application but will strongly oppose any plans to site a smaller facility in Galway Bay.

While welcoming this development we will continue to lobby for changes in siting and management of existing facilities with the ultimate result our preferred option as outlined below.

Our policy on salmon aquaculture will only endorse closed containment systems.

We  congratulate all the other organisations which have lobbied on this facility and hope all collective efforts in future will help to preserve our natural heritage.

Outlined below is our submission to the Department of Agriculture Food and the Marine on the draft National Strategic Plan for Sustainable Aquaculture


Wednesday, 16 December 2015

Excellent video on sea lice infestation

Very informative video which explains issues in a simple way. We need more of this research in Ireland. Some research has been carried out by Inland Fisheries Ireland in the West of Ireland and we look forward to seeing the results.
Maybe it is time to ask our 3rd level colleges to fund and champion this type of research before it is too late for our sea trout and salmon

Monday, 30 November 2015

Salmon Hatchery Conference Proceedings

Salmon Watch Ireland will be producing in the near future a comprehensive report outlining our interpretation of the presentations at the conference. In the meantime we are delighted to offer the following links in order that the public and attendees might examine the proceedings and comment if desired. Unfortunately we are awaiting copies of some of the presentations which will be published as they become available. 

We have also included a link to another conference with video presentations from the IBIS Conference on salmon hatcheries including a presentation by the Usk and Wye Foundation (Stephen Marsh-Smith) and David Solomon.

Monday, 23 November 2015

Hatchery Conference

Salmon Watch Ireland would like to thank all who attended the conference on Saturday 21 November in Dublin. A special thanks to our speakers who I am sure you will agree gave an enlightened insight into the how, why and when salmon hatcheries may or may not be used. We are going to gather our thoughts over the next weeks and issue a report on the conference. As always we would like you to be involved in this process and accordingly we would welcome feedback.

Use the following email address to post comments:

Sunday, 1 November 2015

‘Hatcheries and stocking – have they a role in restoring salmon stocks?’ Salmon Watch Ireland

Ballsbridge Dublin 21 November 2015

Hatcheries and stocking – have they a role in restoring salmon stocks?’

Can hatcheries restore Ireland's dwindling Atlantic salmon stocks. The conference will investigate the potential of stocking and how or indeed if it can be used to help restore Ireland's dwindling stocks of Atlantic salmon. 

Conference Programme

Annual Salmon Conference, Ballsbridge Hotel, Dublin 4
Saturday, 21 November 2015

1100 – Official opening – Minister Alex White, Minister for Communications, Energy and Natural Resources.

1115 – Introductory remarks – Niall Greene, Salmon Watch Ireland

1130 - To stock or not to stock   – Dr David Solomon

1200 -  Discussion

1215 -  Hatchery licencing and regulation in Ireland - Dr Michael Millane, Inland Fisheries Ireland

1245 – Discussion

1300 – Break

1400 - There are no salmon in the Yemen  – Professor Carlos Garcia de Leaniz, University of Swansea

1445 – Discussion

1500 -  An alternative to stocking?  The rejuvenation of the Wye system - Dr Stephen Marsh-Smith OBE, Wye and Usk Foundation

1530 – Discussion

1545 – A role for salmon ranching?  Dr Ken Whelan, Atlantic Salmon Trust

1615 – Discussion

1630 - Close of conference

‘Hatcheries and stocking – have they a role in...

Book early to avoid disappointment.
More details and ticketing information at link below:


Friday, 23 October 2015

Bantry Bay Salmon Farm: Submission to Aquaculture Licence Appeals Board in relation to granting of licence to Marine Harvest for a 3500 Tonne salmon farm

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Salmon Watch Ireland Limited (‘SWIRL’) is a not-for-profit membership organisation dedicated to the restoration of wild salmon abundance. It is SWIRL’s position that open-cage salmon farming is inherently damaging to sea-migrating wild salmonids, Atlantic salmon and sea trout, and has proved to be so in Norway, Scotland and Ireland; in addition there are other significant environmental threats associated with open- cage farming. In the view of SWIRL, and many others here and internationally, it is only throughconversion to closed containment systems, whether on land or in the sea, that can fully mitigate the hugely negative impacts flowing from current systems of salmon farming. There are now marketable quantities of closed containment salmon being produced on both sides of the Atlantic and the Norwegian government has committed to closed containment for further expansion of its industry.
Nonetheless, Ireland has a salmon farming industry which the Government is intent on expanding using current, out-dated technology with all its’ dangers. Without prejudice to its opposition to open-cage salmon farming, therefore, SWIRL is obliged to put forward observations designed to mitigate the damage caused, particularly to wild salmonids, by existing and new installations.
The observations that follow should be seen in that light.
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The SWIRL appeal against the granting of a licence at Shot Head
In the light of the information and analysis set out below SWIRL submits that ALAB should refer the licencing of a new salmon farm in Bantry Bay back to the Department of Agriculture Food and the Marine (‘DAFM’) and thatthat a licence should not be issued until the true potential impact on wild salmonids of the new farm taken in conjunction with the impact of existing farms is determined and full mitigation measures put in place in full conformance with the precautionary principle and approach.
SWIRL bases its appeal of the Minister’s decision on the grounds that:
1. The major threat to wild salmonids (Atlantic salmon and sea trout) posed by concentration of sea lice generated by the proposed salmon farm are inadequately described and analysed in Environmental Impact Statement (‘the EIS’) prepared by Bradan Fanad Teo (‘Bradan’) and the Environmental Impact Assessment (‘EIA’) prepared by the DAFM; as a consequence the measures needed to protect wild salmonids from sea lice infestation are inadequately specified;
2. The major threat to wild salmonids posed by potential escapes of farmed salmon from the proposed salmon farm are inadequately described and analysed in the EIS and the EIA;
3. Neither the EIS nor the EIA deal adequately with the threat posed to wild salmonids by the production schedule proposed by Bradan;
4. Both the EIS and EIA fail to take a precautionary approach to the sea lice and escapee threats to wild salmonids and fail to apply the ‘best available scientific knowledge in the field’ standard to the assessment of the threats, especially sea lice;
5. Neither the EIS nor the EIA address the issue of the cumulative effect of all the salmon farming activity in Bantry Bay on the salmonid rivers that feed into it;
6. There are serious conflicts of interest within the EIS/EIA process and the licence decision-making as it all takes place within the DAFM and its executive agencies, the Marine Institute (‘MI’) and Bord Iascaigh Mhara (‘BIM’) while the DAFM also has overall responsibility for the development of salmon farming.
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The EIS (Vol 1 – pages 219 to 242) treats the sea lice issue almost as a hearsay matter promulgated ‘in some circles’ and relies on the self-interest of farmers to ensure that ‘the precautionary principle’ is applied to ensure that (a) ‘they minimise any suspicion of impact on wild salmonids’ and (b) ‘ensure that their own stocks do not fall prey to severe lice infestation’.
This argument does not, of course, hold up as the farmed salmon can successfully withstand levels of sea lice many multiples of the average of 0.3 to 0.5 ovigerous sea lice per farmed salmon that are required for the protection of migrating wild smolts in the critical March – May period.
The EIS relies heavily on the mechanisms laid down for sea lice control in Protocol No 31 and describes it as ‘mandatory’ (page 219) and that monitoring is ‘under statute’ (page 220). In reality, the legal status of Protocol No 3 is ambiguous and has never been legally tested. More importantly, the issue is not just mandatory monitoring but mandatory treatment if sea lice are found to be over the trigger level. Farms can, in practice, avoid treating their stock if they are actually or about to harvest fish irrespective of the sea lice count (even leading up to or during the critical period) and, therefore, the potential damage to wild salmonids.
In relation to sea lice, the EIA relies for authority on just one scientific paper written by MI scientists (and published by the MI) for the contention that ‘the observed level of marine mortality attributable to sea lice infestation is very small, both in absolute terms (approximately 1%) and as a proportion of the overall marine mortality. At these
1 Monitoring Protocol No. 3 for Offshore Finfish Farms: Sea Lice Monitoring and Control, DAFF (Dublin, 11 May 2000).
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levels it is unlikely to influence the conservation status of stocks and is not a significant driver of marine mortality’.
They fail to mention that there is voluminous literature from scientists and institutions at least as eminent as the MI which assess the same or similar data to that available to the MI in a very different way. A recent article with authors led by the Norwegian Institute for Nature Research (within which is discussed literature which compared the survival level of salmon smolts that had been chemically treated to withstand anti-sea lice with those which had not been treated prior to all being released into estuaries where there were salmon farms ) concluded that ‘within any given release group, a risk ratio of 1.14 to 1.41:1 reflects the 12% - 29% fewer unprotected than protected fish ultimately are captured as adults’2. The literature reviewed in coming to that conclusion included four articles written by MI scientists.
The conclusion in the Thorstad article is hardly surprising. The return rate of wild smolts to their native rivers is now, at best, of the order of 5% of migrating smolts. If sea lice cause a 1% mortality among outgoing smolts, as the MI paper quoted in the EIS contends, then that constitutes a 20% impact on the return rate. A similar point was made by Krkosek et al3 in response to a series of papers by Jackson et al4 in which they said: ‘According to interpretations used by Jackson et al (2013) that is a change of 2% which we agree is a small number. However, the realized effect is that it reduces the abundance of adult
2 Thorstad, E B et al, Effects of salmon lice Lepeophtheirus salmonis on wild sea trout Salmon Trutta – a literature review. Aquaculture Environment Interactions Vol 7 91-113 at 107 (2015). NOTE: While primarily about the impact of sea lice on sea trout the article also referenced those on salmon.
3 Krkosek et al, Short communication – Comment on Jackson et al ‘Iimpact of Lepeophtheirus Salmonis infestations on migrating Atlantic salmon, Salmo salar L smolts at eight locatioons in Ireland with an analysis of sea-lice induced mortality’. Journal of Fish Diseases (2013).
4 (a) Jackson et al. An evaluation of the impact of early infestation with the salmon louise Lepeopthteirus salmonis on the subsequent survival of outwardly migrating Atlantic salmon, Salmon salar L smolts. Aquaculture 320 (2011).
(b) Jackson et al. Impact of early infestation with the salmon louse Lepeopthteirus salmonis on the subsequent survival of outwardly migrating Atlantic salmon smolts from a number of rivers on Ireland’s south and west coasts. Aquaculture 319 (2011).
( c )Jackson et al ‘Iimpact of Lepeophtheirus Salmonis infestations on migrating Atlantic salmon, Salmo salar L smolts at eight locations in Ireland with an analysis of sea-lice induced mortality’. Journal of Fish Diseases (2013).
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spawners returning to a river from say, 6000 down to 4000; this one third loss of salmon returns could have significant conservation or fishery implications’.
The literature reviewed in the Thorstad paper included one by Krkosek et al5 which considered the results of surveys in Norway and Ireland (the latter including that examined by the Marine Institute scientists) and concluded that parasite associated mortality of Atlantic salmon was of the order of ‘39% of salmon abundance, but also loss of genetic variability and its associated potential for adaption to other environmental changes’.
The Thorstad paper further noted that
‘the implications of our results may be most acute for small populations in small river systems. Due largely to the fidelity to their natal river systems, populations of Atlantic salmon typically show substantial genetic structuring and variability that is considered adaptive. Small river systems that support salmon populations of low effective population size will be especially vulnerable. The concern, therefore, is not only for a 39 per cent loss in salmon abundance, but also the loss of genetic variability and its associated potential for adaptation to other environmental changes’.
This issue of small salmon populations in small river systems is, as the EIA points out (page 44), precisely one of the key common characteristic of the five rivers that flow into Bantry Bay and one which dictates that extreme caution be exercised in the introduction of any further stresses into their environment.
The existence of these papers (and numerous other papers with similar conclusions) and their findings are not acknowledged in either document other than as ‘in some circles’.
5 Krkosek, M et al, Impact of parasites on salmon recruitment in the North East Atlantic Ocean. Proceedings of the Royal Society B20122359 (2012)
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It is submitted to ALAB that neither of the EIS nor the EIA documents adequately evaluate the threat of sea lice and, therefore, cannot be considered an adequate basis on which to issue licences to Bradan.
SWIRL is not asking the ALAB to adjudicate on the correctness or otherwise of any of the scientific positions that have been arrived at but to acknowledge that an ‘equal or better’ situation6 exists which requires the application of a precautionary approach in the awarding of the Bradan licences. Some legal authorities on the application of the precautionary approach emphasise that in the event of doubt regarding environmental impacts, or as to the ability to mitigate such impacts, that consents should simply be withheld.
2. Escapes
The EIA statement (page 44) that ‘Prevention of escapees is of paramount importance to the applicant’ is obvious and uncontentious. But escapes have occurred and do occur (even if sometimes disguised as ‘losses’) and often through poor management of the farm and/or poor enforcement of regulations by DAFM.
The issue of escapees has to be seen in the context of the fact that only about 350,000 mature salmon now return to Irish rivers each year. They are spread over some 120 river systems some of which, such as the salmonid rivers in the Bantry Bay area as the EIA points out (page 44), hold very small stocks. Against that background, the 2014 ‘fish loss’ in Bantry Bay referred to the EIA and which involved some 230,000 fish could have had catastrophic consequences for wild stocks over a considerable area; it is still not understood how this huge mass escape occurred or what happened to the stock.
6 See ‘Section 4 – ‘Precautionary principle’ below.
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The threats posed by escaped farmed fish are not trivial: A 2008 study7prepared for the Salmon Aquaculture Dialogue (which includes salmon farming interests) and the World Wild Life Fund concluded that
‘Numbers of farmed salmon escaping to the wild are large relative to the abundance of their wild conspecifics…….[There are] two important implications regarding escaped farmed salmon: 1) potential effects of escaped farmed salmon on population size and production are difficult to separate from other factors, and 2) wild salmon populations are likely to be more vulnerable to effects of escaped farmed salmon because of the synergistic effect of other negative pressures’.
The EIA offers little comfort in this area and falls short of saying that the design, installation and maintenance plans for pens and moorings are considered adequate. The EIA reliance on some future protocol covering these matters and the recovery of escaped fish from fresh water is not sufficient.
3. Production schedule
The draft licence authorises a 24 month cycle of production but does not specifically indicate the age of the smolts that will be stocked and the months in which smolts will be permitted to be stocked. The licence application by Bradan does, however, indicate biennial November stocking with biennial fallowing of the site in September and October.
The DAFM protocol for fallowing8 of high energy smolt sites designates best practice being to fallow during the winter months of January/February.
With smolts being stocked on site in November the critical period for wild salmonid smolt migration (March/April/May) is affected the following Spring (grower fish onsite, large biomass) as well as one year later (largest biomass). The main harvest is scheduled to take place
7 Thorstad et al. Incidence and impacts of escaped farmed Atlantic salmon Salmo Salar in nature. Norwegian Institute for Nature Research (2008).
8 Monitoring Protocol No 5: Fallowing at Offshore Finfish Farms, DAFF (Dublin, 11 May 2000).
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over the critical period and throughout the summer months, a critical period for wild salmonid migration and for inshore feeding of sea-trout. The treatment for sea lice infestation during the harvest period is substantially reduced or indeed eliminated and this will further negatively impact on wild salmonid smolt migration.
Stocking smolts in March would facilitate fallowing in January and February immediately prior to smolt migration and leave the site fallow in January and February immediately prior to smolt migration.
Synchronised production in Bantry Bay would be necessary to optimise the value of fallowing.
The EIS and the EIA are at loggerheads on the issue of whether synchronised management is in place in Bantry Bay.
The EIS describes (pages 220 and 286) the need Single Bay Management (‘SBM’) and Coordinated Local Area Management Schemes (‘CLAMS’) but notes that ‘CLAMS has yet to be established in Bantry Bay’ (page 220) and that synchronous whole bay management would be ‘subject to agreement with the other salmon farm operator in the bay’ (page 286).
The EIA on the other hand says (page 47) that ‘Since 1997, Single Bay Management (SBM) arrangements involving separation of generations and appropriate fallowing sites have been in place in all salmon farming areas in Ireland, including Bantry Bay’.
The ALAB needs to establish who is right here and to impose a stocking and fallowing regime that maximises the value of the critical period protections for wild salmonids.
4. Precautionary principle
The application of the precautionary principle is well enshrined not just in international law but in EU environmental law. The precautionary
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approach to risk management holds that if an action or policy has a suspected risk of causing harm to the public or the environment, in the absence of scientific consensus that the action or policy is not harmful, the burden of proof that it is not harmful falls on those taking or authorising the action.
The Lisbon Treaty states that ‘Union policy on the environment shall aim at a high level of protection [and] shall be based on the precautionary principle and on the principle that preventive action should be taken…..’9
It is well enshrined in the jurisprudence of the European Court of Justice (‘ECJ’) and the Court of First Instance (‘CFI’) that in considering risk and whether the precautionary principle should be applied that the best available scientific knowledge and information10 11should be invoked and that in the event of conflict of evidence the ‘equal or better’ rule applies12.
The ‘equal or better’ standard is designed to ensure that there is genuine scientific uncertainty about the effect of a particular course of action. Neither the EIS nor the EIA sets out the range of differing scientific views on the matters of sea lice and escapees which are known to exist and, therefore, but from the foregoing references in the case of sea lice and escapees it should not be difficult for the ALAB to assess whether the ‘equal or better’ rule applies.
From its own knowledge of the scientific literature SWIRL submits that the application of the ‘equal or better’ standard to the sea lice issue requires that a precautionary approach be taken to the issuing of a licence for a further salmon farming licence for Bantry Bay and that the ALAB should attach to the licence.
9 Consolidated version of the Treaty on the Functioning of the European Union, art 191, para 2.
10 Jiang, P, A uniform precautionary principle under EU Law, PKU Transnational Law Review (2014) 491-518 at 506
11 Case 258/2011; Sweetman v An Bord Pleanala
12 Case C-331/88 ex parte Fedesa, 1990 ECR I-04023
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5. Cumulative effects
The Habitats Directive13 in Article 6.3 requires that any ‘plan or project’ be considered ‘individually and in combination with other plans and projects’. Although there are references in both the EIS and the EIA to other salmon farming projects in Bantry Bay there has been no attempt to assess the cumulative effect on the bay of the totality of this activity.
SWIRL considers that this is a major deficiency in the EIS/EIA process for the Bradan project. The attention of the ALAB is drawn to the decision in the Waddensee case in which the ECJ held14:
‘None the less, according to the wording of that provision, an appropriate assessment of the implications for the site concerned of the plan or project must precede its approval and take into account the cumulative effects which result from the combination of that plan or project with other plans or projects in view of the site’s conservation objectives’.
Such an assessment therefore implies that all the aspects of the plan or project which can, either individually or in combination with other plans or projects, affect those objectives must be identified in the light of the best scientific knowledge in the field. Those objectives may, as is clear from Articles 3 and 4 of the Habitats Directive, in particular Article 4(4), be established on the basis, inter alia, of the importance of the sites for the maintenance or restoration at a favourable conservation status of a natural habitat type in Annex I to that directive or a species in Annex II thereto and for the coherence of Natura 2000, and of the threats of degradation or destruction to which they are exposed.
There has been no attempt to assess the cumulative effects of all salmon farming activity following the addition of the new Bradan farm.
13 Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (21 May 1992)
14 Case C-127/2002; Waddensee
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5. Conflicted interests
DAFM both directly and through its executive agency BIM is tasked by the Government with the development of aquaculture, including salmon farming15. It is advised in these matters by the MI, another executive agency of DAFM.
DAFM is also responsible for advising the Minister for Agriculture, Food and the Marine (‘MAFM’) on whether and on what terms licences are to be issued for the carrying on of aquaculture activities including the carrying out of the Appropriate Assessment of licence applications.
Finally, DAFM are the authority for the enforcement of the conditions under which licences are issued.
It is submitted that there are massive conflicts of interest built into this structure and that the entire decision making process is tainted by these conflicting functions within the DAFM and its agencies. The well demonstrated unwillingness or inability of DAFM to hold operators to account for meeting their licence obligations is evidence of their being heavily weighted towards their development and growth objectives rather than their regulatory obligations.
The content of the EIA reflects this bias. The membership of the review group is composed entirely of people who, however worthy they may be as individuals, are employed by DAFM and its agencies and include at least one person whose role is to promote aquaculture – a person who might usefully have been invited to give evidence to such a review but whose presence as a member is entirely inappropriate.
Salmon Watch Ireland
15 October 2015
15 Cf Seafood development programme 2014-2020, DAFM (Dublin, March 2015) and National Strategic Plan for Sustainable Aquaculture Development, DAFM (Dublin, June 2015).

Wednesday, 7 October 2015

Scotland’s wild salmon populations now below ‘safe’ conservation limits in all west highland rivers

Salmon and Trout Conservation Scotland [S&TCS] has today, 5th October 2015, called upon the Scottish Government to place an immediate moratorium on further expansion of salmon farming in light of Marine Scotland’s new analysis showing the very poor conservation status of west Highland salmon rivers.
Scottish Government’s newly published classification of the country’s salmon rivers puts all the rivers in the west Highlands and inner Hebrides, including iconic systems such as Argyll’s Awe and the Lochy, in the worst-performing category, with wild salmon stocks not reaching what are known as ‘conservation limits’ – a measure of the overall health of the population.
Andrew Graham-Stewart, Director of S&TCS, says: ‘This new analysis by Marine Scotland should ring alarm bells – fisheries scientists have long warned of the impact of sea lice and escapes emanating from salmon farms. The fact that no single river within salmon farming’s heartland of the west Highlands and Inner Hebrides has a sufficient stock of wild salmon for any exploitation to be sustainable cannot be a coincidence.
‘Regrettably, Scottish Government has until now habitually downplayed studies by third parties, but we believe it cannot ignore its own fisheries scientists’ analysis. The contrast between western Scotland and the rest of the country is clear to see and the only major or substantive distinction between the east and west coasts is, of course, the presence of salmon farming in the west. We call on the Scottish Government to halt any further growth in salmon farming until the industry can definitively prove itself to be environmentally sustainable.’
Roger Brook, Chairman of the Argyll  District Salmon Fishery Board, says: ‘Marine Scotland’s analysis must call into question Scottish Ministers’ repeated claims that salmon farming, as it is currently practiced, is inherently sustainable. While the majority of east [and north] coast rivers are ‘category 1’, indicating that wild salmon populations are reasonably healthy, all the rivers in the west Highlands and Inner Hebrides are designated as ‘category 3’, indicating that they are in very poor health. On the one hand Scottish Government is claiming that salmon farming is sustainable, whilst on the other hand it is categorising all wild fisheries in salmon farming areas as unsustainable.
clip_image004 copy‘In light of this new analysis, the Scottish Government should at the very least place a moratorium on any further development or expansion of open-cage marine salmon farms until such time as the likely migration routes of wild salmon are understood and furthermore it should now begin a process of relocating farms away from such routes.’
The map on the left shows that the extent of west Highland rivers where wild salmon populations are in very poor health. Category 3 [‘exploitation unsustainable’ – denoted in mustard] closely matches the extent of the salmon farming industry [the current active industrial salmon farming sites are marked in red], which has long been held to be a primary factor in the decline of wild salmon numbers in western Scotland. [Further details on the map ae at Note 2 below].
It is noteworthy that the Grudie / Dionard rivers, the most westerly rivers on the north coast, are designated ‘category 1’ – where exploitation is sustainable. Migrating salmon smolts [juvenile salmon] from these rivers are able to head north into the open sea without passing any salmon farms. In contrast, all the neighbouring west-flowing rivers – where the smolts must navigate past salmon farms – are designated ‘category 3’, where exploitation is unsustainable.
The great majority of Scottish rivers to the south of the west Highlands – for example in Ayrshire and the Solway – are also ‘category 3’. Salmon smolts from these rivers migrate north through the main salmon-farming regions, rendering them liable to sea lice infestations.
In September 2015 a definitive scientific paper by a team of top international scientists from Norway, Scotland [St Andrews University] and Ireland, reviewed over 300 scientific publications on the damaging effects of sea-lice on sea trout stocks in salmon farming areas. The study also examined the effect of sea-lice on salmon and concluded that sea-lice have a potential significant and detrimental effect on marine survival of Atlantic salmon with potentially 12-29% fewer salmon spawning in salmon farming areas.
Note 2: The map above, with accompanying categories and criteria, was published by Scottish Government/Marine Scotland on 28th September 2015.
  • Category 1 rivers [blue]: ‘exploitation is sustainable therefore no additional management action is currently required’.
  • Category 2 rivers [grey]: ‘Management action is necessary to reduce exploitation; mandatory catch and release will not be required in the first instance, but this will be reviewed annually’.
  • Category 3 rivers [mustard]: ‘Exploitation is unsustainable therefore management actions required to reduce exploitation for 1 year – i.e. mandatory catch and release’.
  • White on the map indicates areas ‘without catch data to parameterize the models’.
  • Superimposed in Red are the locations of the current active industrial salmon farming sites – details sourced from Aquaculture Scotland

Tuesday, 29 September 2015

Salmon Statistics Northern Ireland DCAL Area: Interesting survival figures for 2013.

Salmon Watch Ireland is interested in keeping anglers and conservationists up to date with recent statistical Atlantic salmon returns in the DCAL area.
Any comments on same are most welcome.
Digest of Statistics for Salmon and Inland Fisheries in the DCAL Jurisdiction Annual Report DCAL Findings 16/2014-15


Saturday, 19 September 2015

Letter from Salmon Watch Ireland: Examiner 18th September 2015

Dear Editor

Salmon Watch Ireland welcomes the recent publication of an international review of over 300 scientific publications on the effects of sea lice on stocks of wild sea trout. The review carried out by scientists from Norway, Scotland and Ireland concludes that sea lice have negatively impacted wild sea trout stocks in Ireland, Scotland and Norway and that Atlantic salmon stocks have also been impacted with 12-29% fewer salmon spawning in areas utilised for salmon farming.

The review indicated that in areas where salmon farming takes place, an increase in sea lice in the marine habitat occurs, with a consequent disastrous negative effect on both Atlantic salmon and sea trout stocks.

Salmon Watch Ireland has consistently argued that salmon farming as it is currently carried out in Ireland is environmentally unsustainable and causes ecological destruction of valuable marine habitats, Atlantic salmon  and sea trout stocks while also leading to negative consequences for local economies through loss of angling tourism.  

The locations of salmon farms in Ireland (South West, West and North West) are in areas of spectacular beauty and richness in biodiversity but adjacent rivers and streams are now practically devoid of sea trout with salmon stocks substantially reduced leading to ecological destruction. Many of these rivers and streams are designated as Salmonid Special Areas of Conservation which the state is obliged to protect under European law but the locations and current operational practices involved in salmon farming make this impossible.

Salmon Watch Ireland now invites the Department of Agriculture, Food and Marine to engage effectively with all stakeholders to discuss the consequence of this report with a view to implement a policy review to effectively protect salmonid stocks. For further information please visit our website at www.salmon.ie

John Murphy
Salmon Watch Ireland
16 September 2015

Thursday, 17 September 2015

Bantry Bay: Salmon Farm Decision

Salmon Watch Ireland are concerned at this development and will be studying the details especially in view of the recent international publication concerning sea lice.

Minister Coveney has decided to grant a licence to Marine Harvest for salmon farming at Shot Head in Bantry Bay.
The licence is for a tonnage as follows:

The application is for a biennial production of 3,500 tonnes of farmed salmon. The production cycle is 24 months, with harvesting over 6 months between months 17 and 22 inclusive. The final 2 months are a fallowing period, prior to re-stocking. The definition of biennial production for the purpose of this licence is as follows: Biennial production = [weight of salmon harvested at the site + weight of salmon exported from the site] – weight of salmon input to the site.

REASONS FOR THE DECISION “Determination of Aquaculture/ Foreshore Licensing Application – 42.49 hectares Bradán Fanad Teoranta t/a Marine Harvest Ireland (MHI) has applied for an aquaculture licence for the cultivation of salmon on one site totalling 42.49 hectares at Shot Head, Bantry Bay, Co. Cork. The Minister for Agriculture, Food and the Marine has determined that it is in the public interest to grant an Aquaculture/Foreshore Licence for site numbered T5/555. This determination takes into consideration that the proposed aquaculture will be located in suitable waters, has potential economic benefits, will have no significant ecological effects on wild fisheries, natural habitats, flora and fauna or the environment generally.”

Information about the Licence:





Monday, 14 September 2015

Salmon farms can have a significant impact on wild salmon and sea trout stocks A definitive scientific paper, reviewing over 300 scientific publications, has just been published in the prestigious journal Aquaculture Environment Interactions on the effects of sea lice on sea trout stocks. A team of top international scientists from Norway, Scotland and Ireland reviewed all available published studies on the effects of sea lice and have concluded that sea lice have negatively impacted wild sea trout stocks in salmon farming areas in Ireland, Scotland and Norway.
The paper entitled “Effects of salmon lice Lepeophtheirus salmonis on wild sea trout Salmo trutta—a literature review” (https://research-repository.st-andrews.ac.uk/handle/10023/7295) reached its conclusions based on comprehensive studies of the effects of salmon lice from over 300 scientific publications. The project was funded by the Norwegian Seafood Research Fund which provides investment in Norwegian seafood industry-based R&D with the objective of creating added value for the seafood industry. The study also examined the potential effect of sea lice on salmon and concluded that sea lice have a potential significant and detrimental effect on marine survival of Atlantic salmon with potentially 12-29% fewer salmon spawning in salmon farming areas. These conclusions concur with previously published Inland Fisheries Ireland (IFI) research on the potential impact of sea lice from marine salmon farms on salmon survival. The studies reviewed indicate that salmon farming increases the abundance of lice in marine habitats and that sea lice in intensively farmed areas have negatively impacted wild sea trout populations. The effects of sea lice on sea trout are increased marine mortality and reduced marine growth. This new study confirms the evidence collected since the early 1990’s in Ireland regarding the impact of sea lice on wild sea trout stocks, particularly in relation to the collapse of Connemara’s sea trout stocks. IFI have consistently called for marine salmon farms to maintain sea lice levels close to zero prior to and during the wild sea trout and salmon smolt migration period in spring. IFI have also raised concerns regarding the location of salmon farms in the estuaries of salmon and sea trout rivers. The Board of Inland Fisheries Ireland welcomed this important publication and commented: “This new scientific review paper confirms the need for very tight regulation of sea lice levels on salmon farms and raises legitimate concerns with regard to the potential impact of new large scale salmon farms proposed along Irelands west coast on salmon and sea trout stocks. Regulators will now need to consider the results of this comprehensive review when making decisions on the sustainability and approval of future marine salmon aquaculture licences and the regulation of sea lice at existing sites so as to ensure no negative impact on salmon and sea trout stocks.” For more information, visit: www.fisheriesireland.ie A new paper has just been published in the Journal Aquaculture Environment Interactions which outlines the negative effect of salmon lice on sea trout populations in intensively farmed areas of Norway, Scotland and Ireland. The project, funded by The Norwegian Seafood Research Fund, indicates that salmon farming increases the abundance of lice in marine habitats and that salmon lice in intensively farmed areas have negatively impacted wild sea trout populations. The effects of salmon lice on sea trout result in increased marine mortality and reduced marine growth. The aim of this project was to summarize available knowledge on effects of salmon lice on sea trout to provide the aquaculture industry, wild fishery managers and researchers with a comprehensive and updated knowledge status. Knowledge gaps are also identified. The literature review was based primarily on international publications in peer-reviewed journals or books in order to establish a solid and justifiable knowledge base on the effects of salmon lice on sea trout. The authors of the report constitute an international group of scientists, from several institutions in Norway, Scotland and Ireland. A reference group was established to serve as advisors for the authors of the report and included individuals from NINA, the Norwegian University of Science and Technology, Bremnes Seashore AS and the Norwegian Seafood Federation. The paper reviewed laboratory studies which show that salmon lice may induce osmoregulatory dysfunction, physiological stress responses, anaemia, reduced feeding and growth, increased susceptibility to secondary microbial infections, reduced disease resistance and increased mortality in individual sea trout. Osmoregulatory dysfunction is likely caused both by the mechanical damage of the skin and tissue and is an expression of overall physiological stress responses. Mechanical abrasion and impairment of the barrier between the fish body and seawater results in increased leakage of water from the host individual, and thereby affects its overall osmotic and ionic balance. Salmon lice-induced fish mortality tends to be incurred within 10-20 days of exposure to juvenile lice (copepodids) in the laboratory, by which time the salmon lice have developed to the preadult and adult stages. Field studies have confirmed laboratory observations on the effects of sea lice. Premature migratory return of salmon lice-infested sea trout to freshwater has been documented in Ireland, Scotland and Norway. Premature return is interpreted as an adaptive response by the host to salmon lice-induced osmoregulatory dysfunction in seawater. Return to freshwater may, in the short term, enable the fish to regain osmotic balance and survive. Return to freshwater also allows short-term recovery from salmon lice infestation, because salmon lice have a low freshwater tolerance. In the long term, however, growth opportunities and future fecundity of individuals may be greatly reduced by an abbreviated sea migration caused by salmon lice. The study revealed a number of comparative field studies which have demonstrated a link between Atlantic salmon farms and salmon lice levels in wild sea trout, with increased salmon lice levels on wild sea trout closer to salmon farms. Several studies have shown elevated salmon lice levels of wild sea trout, particularly within 30 km of the nearest farms. Elevated salmon lice levels also may be recorded at distances >25-30 km, and models have shown that the planktonic stages of salmon lice larvae can be dispersed >100 km. How far, and in which direction, larvae are transported depend upon numerous variables, including their development rate, water temperature, currents and salinity. Several studies have also shown temporal correlations between salmon lice levels in wild sea trout and year of the production cycle and biomass of fish in adjacent farms, with increased salmon lice levels on sea trout with increased total fish biomass in those farms. The study also examined the potential effect of sea lice on salmon. The overall effect is consistently clear; salmon lice have a potential significant and detrimental effect on marine survival of Atlantic salmon. Meta-analyses and long-term studies, and similar results from an increasing number of experimental studies in Ireland and Norway, show that these are levels of extra mortality (i.e., 12-29% fewer spawners) that can be expected for Atlantic salmon in farm-intensive areas. The study points out that the salmon louse-induced mortality from Atlantic salmon studies should likely best be regarded as minimum estimates for sea trout mortality as sea trout remain in near coastal waters and are therefore exposed to seasonally higher risks of salmon lice infestation. Elevated marine mortality rates, such as that induced by salmon lice, result in a proportional reduction in the number of spawning adults. Because sea-run brown trout typically are females, any additional marine mortality has the potential to affect egg deposition and hence ultimately recruitment even more negatively than would be the case were there an equal sex ratio. Conclusions The studies reviewed indicate that salmon farming increases the abundance of lice in marine habitats and that salmon lice in intensively farmed areas have negatively impacted wild sea trout populations. The effects of salmon lice on sea trout are increased marine mortality and reduced marine growth. In summary, the combined knowledge from the reviewed studies provides evidence of a general negative effect of salmon lice on sea trout populations in intensively farmed areas of Ireland, Norway and Scotland. Premature migratory return, increased marine mortality and reduced growth of survivors that are induced by elevated salmon lice levels inevitably imply (1) a reduction in numbers and body size of sea trout returning to freshwater for spawning, and (2) a reduced or eliminated surplus that can be harvested by recreational and commercial fisheries. In the extreme, reduced marine growth and increased mortality could result in the local loss of sea trout populations. Reference: Effects of salmon lice Lepeophtheirus salmonis on wild sea trout Salmo trutta — a literature review. 2014 AQUACULTURE ENVIRONMENT INTERACTIONS. Vol. 7: 91–113, 2015 doi: 10.3354/aei00142 Eva B. Thorstad¹,*, Christopher D. Todd², Ingebrigt Uglem¹, Pål Arne Bjørn³ Patrick G. Gargan4 , Knut Wiik Vollset5, Elina Halttunen³, Steinar Kålås6,, Marius Berg¹, Bengt Finstad¹ ¹Norwegian Institute for Nature Research, 7485 Trondheim, Norway ²University of St Andrews, St Andrews, Fife, KY16 8LB, UK ³Institute of Marine Research, 9294 Tromsø, Norway 4 Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus, Dublin 24, Ireland 5 Uni Research Environment, Norway 6 Rådgivende Biologer AS, Norway

Thursday, 3 September 2015

Salmon Watch Ireland

Petition needs your support to help the River Lee recover. This endeavour will support more bio-diversity and help the threatened Atlantic salmon stocks on the River Lee.

There are only four inland river forest deltas on our planet ! In 1957 in the interest of introducing and then selling electricity to the people of Cork City and County two hydroelectric dams were constructed on the river Lee. This involved the compulsory purchase orders of 39 homes and farmsteads. Tragically the second dam was a miscalculation. Thousands of age old Irish Oak and Yew trees, some over a thousand years old, were chopped down. The farm-houses in this unique river forest were dynamited. The back filling of the dam submerged thousands of acres and destroyed the wild Atlantic salmons ancient spawning grounds and decimated the salmon dependent fresh water pearl mussel. A tragic crime against Nature. All the more tragic as it was a total miscalculation. The good news and hence the campaign to collect as many signatures as possible is that this tragedy can be reversed. It is our obligation to petition our Minister for the Environment to simply drop the water level by one meter and allow the Gearagh inland alluvial forest to grow back. We have our backs turned on an absolutely unique feature of Nature here in southern Ireland. Scientists and environmental experts travel from all over the world to study this habitat. The bird life would once again flourish. If managed correctly this could become one of Irelands most unique tourist destinations. Please help us give our river forest delta back to mother Nature. Thank you for your signature and support. Please see the trailer of the documentary film RIVER RUNNER which highlights this tragic story at

Salmon Watch Ireland welcomes discussion on this excellent report by ECOFACT.

Are Ireland's large hydroelectric schemes sustainable?http://ecofact.ie/are-irelands-large-hydroelectric-schemes…/
Are Ireland's large hydroelectric schemes sustainable?

Salmon Watch Ireland welcomes the publication of Inland Fisheries Ireland Submission regarding Sustainable Aquaculture Development

Attached is the IFI submission to DAFM in respect of the draft National Strategic Plan  for Sustainable Aquaculture Development (on which SWIRL also made a submission).  It is a robust and comprehensive treatment of most of the issues to do with salmon farming from a wild salmon/sea trout perspective.

IFI submission to DAFM in respect of the draft National Strategic Plan for Sustainable Aquaculture Development

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.


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 €

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,


Professor Ken Whelan
Research Director
Atlantic Salmon Trust

Monday, 27 July 2015


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/