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.