Its strong objection submitted to the Department of Agriculture, Food and the Marine highlighted the impact of two salmon farms already operational at Ballinakill Bay in Connemara and “the conservation imperative for [local] wild stocks”.
It cited evidence of farmed fish escaping from cages and being caught by anglers — and consequent risk to wild stocks.
The Dawros river, which flows into Ballinakill Bay, is an important wild Atlantic salmon and sea trout habitat with a well-established pearl mussel population. There are four special areas of conservation, including rivers designated for salmon, within 25km of the proposed Ballinakill Bay site.
IFI said the Environmental Impact Assessment Report (EIAR) and Natura Impact Statement (NIS) for the salmon farm with a 3,500 tonne annual production capacity were defective, “lacking a comprehensive assessment of the potential impact from sea lice and escaped farmed salmon on salmon” in the area.
In addition, there was no proper assessment of the potential impact of the proposed salmon farm on freshwater pearl mussel in the Dawros and nearby Bundorragha river.
“Therefore, it is not possible to determine if the siting of the proposed salmon farm is consistent with the conservation objectives for the Natura site or if such activities will lead to deterioration in the attributes of the habitats and species over time,” it adds.
A large amount of necessary data “is incorrect or not included” in the EIAR and NIS for a proper appropriate assessment to be undertaken by the department “and therefore a decision to refuse a licence should be taken”.
It highlighted “a fundamental flaw” in the application, where “the EIAR discusses biological interactions with sea lice and sea lice management in salmon farming and comments that no direct causal link between lice on farmed and wild salmon has yet been demonstrated empirically”.
There is no citing of any research undertaken in the west of Ireland on impacts of sea lice on wild salmonids since the late 1980s. A comprehensive list of scientific publications on this issue had been published in peer-reviewed journals over the past 30 years, many including research on rivers adjacent to the proposed farm, including the Dawros, “and none have been referenced or quoted”.
“Only a number of publications by D Jackson [Marine Institute] are referenced to come to the conclusion that there will be no impact on wild salmonids in rivers in the vicinity of the proposed site. An appropriate assessment cannot be undertaken on the NIS due to this fundamental lack of comprehensive assessment,” it added.
Numerous studies have demonstrated the negative impacts of salmon farms on wild salmon and sea trout populations, primarily due to sea lice infestations from aquaculture, it said. Significant reductions in marine survival for wild Atlantic salmon post-smolts have been observed during a critical stage of migration from rivers to the ocean in Irish and Norwegian publications.
There is a large body of international scientific publications identifying the potential and observed impact of escapes from marine salmon farms on wild Atlantic salmon, the IFI submitted. Data indicates over 600,000 salmon were reported to have escaped from salmon farms in Ireland in the period 1996-2017, with one escape incident involving 232,000 fish in Bantry Bay in 2014.
Increased frequency of storms in Ireland and its consequential effect on potential incidence of escapes are an anticipated consequence of climate change, it warned.
Escapes of farmed salmon have occurred in the Ballinakill fishery district in recent years, it confirmed. In mid-August 2017, anglers reported catching suspected escaped farmed salmon in the Bundorragha and Dawros rivers. Further fish were reported from the Erriff, Bunowen and Newport rivers in September, with 66 fish reported being captured by angling.
All fish exhibited a combination of morphological features described as occurring in farmed salmon, enabling these fish to be distinguished as of farmed origin, it underlined.
“There is no assessment of the potential impact of the proposed salmon farm on sea trout stocks in local rivers in the EIAR and NIS. A large body of published papers have documented the impact of salmon farms in bays in the west on sea trout stocks, and the lack of any assessment is completely unacceptable,” it added.
A Mowi Ireland spokesman declined to comment on the application but said it is under consideration by the department’s aquaculture and foreshore management division, and will involve a full round of statutory and public consultation in line with current aquaculture legislation. “The company does not comment on proposed projects which are in the planning phase,” he added.
Asked to respond to objectors’ claim that the proposal comes with an unacceptable level of environmental risk, especially for wild salmonids, and why it was persisting with developing open-pen salmon farms in such circumstances, it said: “All aspects and impacts of this proposal are addressed in the supporting Environmental Impact Assessment Report which accompanies the application and is currently under scientific scrutiny.”
Bord Iascaigh Mhara (BIM), which is responsible for development of the seafood sector, said it supports the aquaculture sector “in responsible, safe and sustainable catching, farming, and processing”.
BIM said it was not in a position to comment on individual licence applications while the deliberative process was ongoing. As the application was under consideration, it declined to release its submission but said it would be made available during public consultation.
“Salmon farming is a major contributor to the Irish seafood industry, providing a safe, sustainable and nutritious source of protein. Production of farmed organic salmon in Ireland was valued at €109 million in 2021,” it added.
Sustainable aquaculture in Ireland was aligned to EU and national policy and can play an important role in delivering nutritious and healthy seafood with a limited environmental footprint. It was creating job opportunities and “actively contributing to the fight against climate change and the preservation of ecosystems and food security”.
BIM cited a report published by the European Commission in March 2022. On the issue of sea lice, it concluded: “It has been claimed in Europe that the increase in sea lice associated with salmon farms, together with the treatment, have been largely responsible for the large reduction in abundance of wild Atlantic salmon although, again, without definitive proof.”