The proposed salmon farm for Galway bay is intended to create 500 jobs for the rural coastal communities however we query the figure of 500 jobs being associated with the proposed offshore salmon farm in Galway Bay. Following our attendance at some of the public awareness events throughout the country, we have it from good authority that the present salmon farms working off our coastline in the past have published data on employment and production which show that 9,923 tonnes of salmon were produced in 2007 and 133 full time people were employed. If the same ratios, 74.6 tonnes of salmon per person employed, are used in the context of the current proposal for a 15,000 tonne salmon farm this accounts for only 202 jobs. A very recent report in aquaculture news site www.fishnews.eu claims that Scottish Islanders were delighted that a new 2000 tonne salmon farm had been granted planning and would create 4 full time jobs. Again if applying the same ratios to the current proposal this amounts to only 30 jobs. While we welcome more employment in the current climate, we feel that these jobs that are created by salmon farms will be counter-productive. The ever declining wild stock numbers will result in job losses in both the recreational angling sector as well as the hospitality sector which depends on visiting anglers.
Protected Geographical Indication (PGI) Status
We are opposed to the joint application from the Northern and Southern governments regarding the proposed “PGI” status to be awarded to “Irish Salmon”. These fish are in fact “farmed” salmon and we believe the general public would be misled by this status and assume they were in fact eating “Wild Atlantic Salmon”.
Recent peer reviewed international scientific literature on the impacts of sea lice on salmonids show them to have devastating effects on wild salmon, accounting for up to 39% of salmon mortalities. NSFAS does not believe that the corpus of peer reviewed international scientific literature which recognises the negative impacts of sea lice on salmonids have been adequately dealt with in BIM’s EIS. This treatment for lice also takes away from the farmed salmon been organic which is also misleading. No data has been made available regarding the chemicals to be used for treatment nor have dosage amounts.
Harvesting will take place remote from the on-growing sites. The graded fish will either be transported directly to the packing station landing point or will be held on an intermediate holding site for a short period prior to final transportation to the packing plant. No details are provided of the location of this intermediate holding site or the number of fish to be held. A licence for this site must be required along with the appropriate studies and assessments. The location of this site is significant as, in all probability, it may be closer to the shore and consequently wild sea trout feeding in the inner bays and estuaries as well as being closer to wild salmon smolts. In addition for fish pre harvest, the experience has been that they support significant lice infestations as there is a period when treatments are avoided prior to harvest and sale for consumption – this entire aspect of the proposal has not been addressed in the EIS.
Live Fish Escapes
There is a possibility that wild salmonids may be captured during attempts to recapture escaped farmed fish and the authorization issued should specify what action is required in such an event. The EIS does not address the potential for escapees to enter, in significant numbers into freshwater catchments, including SACs like the Corrib SAC.
Given the high number of smolts required for this development, 3.6million annually, it is likely that importation of smolts will be required from the UK. This would greatly increase the chance of introduction of invasive species from water used in transportation. Spread of invasive species (both marine and freshwater) from the UK and the continent has occurred in the past. Introduction of invasive species is considered globally as one of the major threats to native biodiversity. This issue is not sufficiently addressed in the EIS, nor are the biosecurity measures properly outlined. While it is recognised that fish health and certification would be a de factor part of the importation process, careful monitoring of water and wet gear and equipment involved in transportation should also be carried out.
The closest sea trout fishery to the proposed site locations is the Cashla fishery entering Rossaveal Bay. Historically the Cashla fishery was the prime sea trout fishery in Connemara with rod catches of over 2,500 sea trout annually. No specific assessment has been undertaken of the potential impact of the proposed farm on the Cashla fishery or on other sea trout fisheries in Galway Bay, (Crumlin and Owenboliska). Reference is made to concerns expressed about the negative impact of sea lice from marine salmon farms on sea trout stocks, however the extensive literature published on interactions of sea trout and salmon lice in Ireland are not referred to or discussed.
While we are realistic enough to understand these salmon farms offer a service, we feel that a future where we can all live in harmony remains in the relocating of all future and all existing salmon farms lies in the moving of them to inland sites. Moving inland will negate the negative impact on our ocean beds. It will also greatly reduce the risk of escapees and in turn will reduce the chances of copulation with our native species while it will be more expensive for the businesses, it will be much more environmentally friendly. It will be much easier to control disease outbreaks and contain them. It will allow for easy monitoring of water emanating from these sites. They will then have to comply with waste management laws and that in it would give our nation the opportunity to become a leading light in the modernisation of what is known as a “dirty” industry.
If BIM where to take all of these concerns and put them in place.
We would have a healthy and much cleaner sea bed and shoreline for our visiting tourists to swim in or surf over, for which the west coast of Ireland is well known with many Blue Flag designated beaches. We would also have a clean and green commercial industry creating employment and bringing much needed revenue to local areas and a cleaner pathway for our migratory salmon, smolts and sea trout resulting in a higher number of tourist and local anglers spending money in local communities that depend on that revenue.
In summing up, we believe that to grant permission would be a catastrophe not only for our wild salmon and sea trout, but also for the communities that depend on their very existence. The spurious number of jobs that have claimed will be created, will result in far greater numbers of unemployed in the angling sector, hospitality sector and all associated industries reliant on tourist revenue in those communities. To grant permission in circumstances where proven scientific evidence exists, which indicates that salmon farming has a severe negative impact on areas where such farms are placed would decimate the precious natural resource that is our wild salmon and sea trout stocks.
We at NSFAS await your reply by way of a public statement and press release on all of our above objections and proposals to these Salmon Farms in Ireland.