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