Hinchion, Geraldine

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Aine Ni Cheannabhain [ancando2@gmail.com] 01 IVIay 2015 16:19 sdp2014 S D P 2014-2020

Submissions to Draft Seafood Development Programme 2014-2020 Keith Kelleher Marine Agencies & Programmes Division Dept. Of Agriculture, Food & the Marine National Seafood Centre, Clonakilty, Co. Cork, Ireland

1 May 2015 sdp2014@agriculture.gov.ie

I refer to the Draft Seafood Development Programme 2014-2020 and I wish to record my submissions with some comments and reservations as follows, and specifically in relation to aquaculture. Time consraints due to deadlines do not allow for a proper and deep analysis of DSDP that would result in a more comprehensive submission:

-4.3.3 Union Priority 2- Sustainable Development of Aquaculture (p. 133), states: 2. 'manage aquaculture in accordance with the Birds and Habitats Directives and implement the Prioritised Action Framework'. This, I assert to be an aspirational but nonetheless a very misleading statement. I will base my reasons for concern on one example. I cite Cil l Chiarain (Kilkieran) bay, Conamara, Co. na Gaillimhe, a designated SAC and SPA, as an instance where aquaculture is not being operated nor managed in accordance with the Birds and Habitats Directives. Currently there are several salmon farms operating within Ci l l Chiarain bay without a licence. Prior to their expiry (August 2012), four (4), licences were transferred from two small local operators to a company called Bradan Beo, of which Udaras na Gaeltachta, a state appointed and state funded agency is the majority shareholder. It has since given the operation of these now 'expired licences' to a multinational company. Marine Harvest. Aquaculture activities had ceased at these sites in 2009. I would like to draw your attention to Section 69 (2) ofthe FISHERIES (AMENDMENT)

ACT, 1997, which states as follows: "Cesser of aquaculture licences in certain circumstances. 69.—(2) "Where aquaculture in respect of which a licence has been granted has ceased for a continuous period of two years, the Minister shall, without compensation to the licensee, revoke the licence." Aquacuhure activities at this location ceased in 2009. This is evidenced by the fact that the Irish Fisheries Bulletin National Survey of Sea Lice record the last returns from this location in 2009 and show no returns from Ardmore Point, Cil l Chiarain

A chara,

bay in 2010, 2011, 2012, or 2013. If this site had been used for aquaculture during this period, sea lice monitoring would have taken place and returns would have been published in the annual survey. The use of Sea Fisheries and Marine Jurisdiction Act 2006 to permit the repopulation after abandonment by an entirely new operator within a Natura 2000 site without asssessments is in direct and flagrant contempt of the European court Judgment. The state is the prime mover and a benificiary of the operations they have authorised at this location.

~ This brings me to my next concern as stated in the Seafood Development Programme Draft Environmental Report and A A , (p.io). If unregulated, the intended expansion of aquaculture production under the SDP could

result in negative impacts, but a robust regulatory and licensing system is in place^\ This clearly is not the case in Cill Chiarain bay as I have outlined above. It appears to be robust enough for the Department of Agriculture, Food and Marine (DAFM), which is the government body tasked with the issue of licences for aquaculture. According to minister Coveney, the 'successful example of South Connemara (South Connemara includes Ci l l Chiarain bay), could act as a template on how to proceed nationally'. {Recorded minutes of a meeting between Marine Harvest, An Taoiseach, Minister Coveney and others on the 30 January 2014). The above quote from the minutes raises serious concerns about irregularities in the issue and non-issue of licences for aquaculture and how taxpayers' money is spent.

I repeat, as the above record shows there are flagrant abuses of licencing regulations for salmon farming in Ci l l Chiarain bay and possibly elsewhere. It demonstrates clearly the DAFM's licencing system is neither 'robust' nor does it attempt to operate in accordance with the Birds and Habitats Directive nor indeed within any regulatory system that I know of Further to this, in response to a FOI question recently put to National Parks and Wildlife Services (NPWS), received this April 2015, NPWS confirms it "hasn't received any consuhation on licensing for a salmon farm in Kilkieran Bay" and "No Appropriate Assessment nor an Environment Statement has been received by this section to support a salmon farm in Kilkieran bay since 2008". NPWS is the competent authority for the management of Natura 2000 sites in Ireland and as it has not been consulted, how can we be assured or confident that a reliable tranparent and 'robust' system will suddenly and almost by magic be in place when the funds arrive from the EU? It is hardly credible that large sums of taxpayers' money would be used to fund questionable and noncompliant operations which have been heretofore under a very 'light touch' or a 'no touch' regulatory system, as is the case in Cill Chiarain bay in south Connemara.

~ My next concern relates to The Commercial Aquaculture Development Scheme (€15m) (p.i37), which states: 'This scheme will support capital investment by aquaculture enterprises, mostly SMEs, to sustainably grow production and value, to reduce the impact of aquaculture on the environment and to improve safety and working conditions in aquaculture sites. Aid will be available only to sites that are fully licensed in compliance with the Habitats and Birds Directives. This scheme will not be available to new entrants to the sector, who will be

directed instead to the New Farmers Scheme'. 'This measure addresses UPl need number 3 and 5'.

I must note here and only as an example, that Marine Harvest, which is a multinational company and now operating 80% of salmon farms in Ireland's coastal waters, would not nor should not be classified as an SME. M y concern is that the commercial aquaculture development scheme, unintentionally or otherwise proposes to financially support multinational companies while barring SMEs from entering the sector to access funds from the above scheme. This contravenes EMFF's support for coastal communities where the fund: helps fishermen in the transition to sustainable fishing

supports coastal communities in diversifying their economies finances projects that create new jobs and improve quality of life along

European coasts makes it easier for applicants to access financing.

I will refer again to the minutes of the aforementioned meeting on 30 January 2014, (obtained through FOI), at government buildings between Marine Harvest Ireland and the Taoiseach and where minister Coveney slates lhat: 'his Department would continue to link smaller companies with licences, with Marine

Harvest Ireland to increase productivity'. What exactly did he mean? Coupled with the following statement recorded in the same minutes; 'The successful example of South Connemara could act as a template on how to proceed nationally', it raises the alarm regarding irregularities in licencing of aquaculture operations and begs the question if the minister intends to use the 'successful example of South Connemara,' whereby a licence may be granted to an SME, thus fullfilling the criteria regarding funding to SMEs, (envisaged in the Commercial Aquaculture Development Scheme (€15m) (p.137), but the funds end up supporting multinational companies? Surely this is not the way to proceed? And this is not what was envisaged in the EMFF. In my opinion the case of south Connemara demands scrutiny and vigorous examination to dispel any fears of official irregularities regarding aquaculture licencing.

~ Finally, the Governance and Co-ordination of the SPD 2014-2020, section 10.3, (p. 208) demands scrutiny considering Udaras na Gaeltachta's long standing involvement, promotion and financing of Salmon farming for 30 years. What assurances can we have that there would be no conflict of interest in having Udaras na Gaehachta, a promoter, shareholder and funding agency for salmon farming, being part of the governance and co­ordination ofthe SPD 2014-2020? "Quis custodiet ipsos custodes?

~ There are apparent contradictions and major flaws contained in section 3,(p.77) 'Grow sustainable employment, production and value in the aquaculture sector and they need to be addressed and supported by scientific based research and not by assumptions! 'to ensure that the aquaculture sector continues to be a viable industry, the aquaculture sector needs to grow employment, production and value'. Are we to believe that without any scientific anaysis or studies that this will 'lead to improved business performance and ensure

sustainable employment in rural and coastal communities' .This is a wish hst and seriously has no place in a document purporting to be the road map for the development of sustainable fishing in coastal communities.

~'Increasing business scale provides resilience against difficulties such des ease and extreme climatic events which leave businesses vulnerable in the event of substantial stock losses', brings me to the pvoiposed Aquaculture Stock Insurance (€2m) in Consultation on Seafood Development Programme 2014-2020, (p.i4i). Again this raises further concerns when we consider that this sector faces increasing challenges in controlling sea lice infestations, deseases and the effects of climatic change to what is glaringly obvious, the unsuitabilty of our shallow bays for salmon farming. Why would the state offer insurance for what can only be termed a dead certainty: losses brought about by climate change. Rising sea temperatures will continue to bring increased risks of deseases and mortalities. This aquaculture stock insurance should not be in the programme. The onus must be on the industry to insure itself against losses like any other business would.

Conclusion There are other forms of aquaculture that our sheltered bays are well suited to such as the native oyster and scollop found in Cill Chiarain Bay. This has been competing with salmon farms for over 30 years with little or no state support and has suffered as result. In the future, supporting this form of aquaculture would go some way to fulfill part of the obligations implicit in EMFF, that seeks to promote a growth and job based recovery in Europe.

Aine N i Cheannabhain.