Submission made to the Critical Review of Bord Iascaigh Mhara

BIM logoSave Bantry Bay are a recently formed group who are deeply concerned about Ireland’s inshore aquaculture policy, particularly regarding in-shore salmon farming in the Bantry Bay area. We understand a review of Bord Iascaigh Mhara is currently underway, and we wish to make a submission for the Critical Review Groups consideration.

Of concern to us are the following points:

BIM is aiming to become an aquaculture license holder for a number of deep sea salmon farms. Given the Department for Agriculture, Food and the Marine oversees the approval of aquaculture licensing and acts as regulator of aquaculture license holders, it would be inappropriate for them to have BIM under their remit. Indeed it would be a direct conflict of interest. There must be a very clear line between those who apply for or have licenses and those who issue and police licenses.

We request the responsibility for appraising aquaculture proposals, decision making and policing is held within an entirely separate organisation to that responsible for applying and managing aquaculture operations.

There is no environmental representation on the Critical Review Group despite the many environmental issues surrounding sea fisheries and aquaculture. Add to this the fact Ireland has already had fines imposed by the European Court of Justice for its practices when approving aquaculture licenses and this seems most unfortunate. Indeed despite the ECJ ruling, today there continue to be applications for salmon farm licenses under consideration in areas extremely close to SACs that have had no ‘appropriate assessment’ completed. For example, Marine Harvest’s proposal for a salmon farm at Shot Head, Bantry Bay only 0.5km from the Trafrask Bog SAC which houses the Dromogawlene river, home to the Freshwater Pearl Mussel and wild Atlantic Salmon.

And this is not the only EU environmental legislation that may be relevant. It remains to be seen how effectively Ireland manages to achieve the ‘good status’ of inshore coastal waters as is required by the Water Framework Directive. And soon, EU Member States must implement the Marine Strategy Framework Directive. If Ireland wishes to stay out of the European Courts in the future it would be wise for wider EU environmental legislation to be given consideration within this review.

We request that at least one independent environmental representative is included on the Review Group.

The review is proposing to include ‘an assessment of current and future operational activities and service delivery within the context of Government Policy for the sector – Food Harvest 2020’. Yet to our knowledge this document isn’t official Government Policy, it is a draft strategy. No mention is given to the EU’s Common Fisheries Policy, which has a much stronger focus on sustainable development of fisheries and Ireland which is legally obliged to implement.

We request Ireland’s wider legal obligations under international, European and national fisheries legislation is taken into consideration.

We hope you will consider our submission, and look forward to hearing from you.

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