Monday, 20 July 2015

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

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
 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
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
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