ENVIRONMENTAL IMPACT ASSESSMENTS and ENVIRONMENTAL IMPACT STATEMENTS (rev'd Nov 2003)

"Environmental Impact Assessment (EIA) is a process for anticipating the effects on the environment caused by a development. An Environmental Impact Statement (EIS) is the document produced as a result of that process. Where effects are identified that are unacceptable, these can then be avoided or reduced during the design process. The Environmental Impact Assessment procedure commences at the project design stage where it is decided whether an Environmental Impact Statement is required. If it is required, then the scope of the study is determined, after which the EIS is prepared as part of the application for development consent. The competent authority examines the EIS, circulating copies to statutory consultees while also making it available to the public."

- Environmental Protection Agency (Ireland), "Guidelines on the information to be contained in Environmental Impact Statements", March 2002. Section 1.1 Introduction, p.1. All licence applications for salmon farming require a supporting EIS under both EU and Irish law.



• The current salmon-farming applications in Lough Swilly have been submitted with an EIS entitled 'Environmental Impact Statement for the Expansion of Atlantic Salmon Farming in Lough Swilly, County Donegal'.
  
  
• This EIS was commissioned from the Institute of Aquaculture, University of Stirling. Initially published in 1994, it was updated but not changed substantially in March 1995. In all, it has been recycled three times for licence applications, under two different sets of legislation. In 1999, it was further 'updated' by the inclusion of a 'Summary and Overview to accompany EIS' written by the applicants themselves.
  
  
• The Lough Swilly EIS is incomplete: Some of the stakeholders most directly affected were never interviewed, or if interviewed, did not have their concerns and objections recorded.
  
  
• The Lough Swilly EIS is outdated: Omitted is any research from the past nine years. References include a single item dated 1994; the remaining citations range from 1905-1993.
  
  
• Since March 1995, there have been at least four international aquaculture events which would indicate that this report is seriously outdated, and thus a flawed analysis of the likely effects, good and bad, on the environment. They are:
  
  
• In 1995, a two-year moratorium on all aquaculture licensing was called by the Canadian province of British Columbia while an independent review was conducted on the long-term environmental and socio-economic effects of the salmon-farming industry.
  
  
• In 1998/99, an outbreak of infectious salmon anemia (ISA - previously unknown in Scotland) decimated the Scottish salmon-farming industry, and cost the government more than £100 million in containment and compensation. A similar outbreak in New Brunswick cost the Canadian government CDN$50 million.
  
  
• In June 2000, Nature magazine published a report co-authored by researchers from Britain, USA, Asia and Sweden (among them Malcolm Beveridge, of Stirling University's Institute of Aquaculture) wherein concerns about aquaculture were raised. 'Global production from farmed fish and shellfish has more than doubled during the past 15 years. While many people believe such growth relieves pressure on ocean fisheries, the opposite is true for some aquaculture practices.' The greatest threat, they wrote, comes from farms that raise carnivorous species - fish that eat other fish. These include shrimp and popular fin fish such as salmon, trout and sea bass. It takes four pounds of processed wild fish to produce enough fish meal to result in one pound of farmed salmon. A four-to-one ratio is not sustainable.
  
  
• In February 2000, a public petition was brought before the Scottish Parliament calling for an independent inquiry into the adverse environmental effects of salmon farming. On 9 February 2001, two powerful parliamentary committees, the Rural Development Committee and the Transport and Environment Committee, backed this public call, demanding that the Scottish Executive 'move quickly to tackle the growing environmental impacts of Scotland's fish farm industry.' This followed mounting scientific and public concern surrounding pollution, use of toxic chemicals, mass escapes, the decline of wild salmon and the spread of algal blooms.
  
  
• An eight-year-old EIS does not begin to address many issues that have come to affect the aquaculture industry, nor does it accurately represent the long-term environmental effects of salmon-farming.
  
  
• Public accessibility / consultation: A copy of the report may be purchased by individuals for £50; alternatively, the 250-plus-pages of it may be viewed in the local Garda station, which is without photocopying facilities.
  
  
• Shellfish-farming applications do not specifically require an environmental impact study, although EU law directs that an EIS for aquaculture other than salmonid is necessary when it is possible there will be a direct effect on the surrounding environment. The absence of an EIS for shellfish farming, given its rapid expansion, is increasingly a matter of concern.
  
  
• In nearby Trawbreaga Bay, Co. Donegal, 26 oyster licences were recently collectively renewed by the Department of the Marine with a single newspaper notice. Trawbreaga Bay holds the unique distinction of being a designated international Ramsar (wildfowl) site, a National Wildfowl Sanctuary and a Special Protection Area under the EU Birds Directive. Still, it was deemed unlikely to be affected by the development.
  Birdwatch Ireland has surveyed wildfowl numbers and found them to be dropping in Trawbreaga Bay. In a recent report in Irish Birds (Vol 7, 2002), "The wintering waterbirds of Lough Swilly, County Donegal", naturalist Ralph Sheppard wrote "The growing aquaculture industry is considered the main threat to the habitats and the birds."

Save The Swilly is asking for:

• A moratorium on all aquaculture licensing in Lough Swilly until such time as an independent and comprehensive baseline study has been conducted into all aspects of the environment of this important bay. The baseline study must cover areas such as ecology, archaeology, landscape, marine leisure and tourism. Of particular concern are Lough Swilly's Special Protection Areas and Special Areas of Conservation. The study should be scoped and managed by a joint steering group, including statutory bodies, local government, existing users and community representatives.
  
  
• An independent and comprehensive study of the environmental impact of aquaculture on Mulroy Bay, scoped and managed by a similar steering group to the Lough Swilly group, but including interests specific to Mulroy Bay.
  
  
• An environmental impact assessment, independent and comprehensive, on the likely environmental effects of aquaculture on Lough Swilly, based on the results of the above studies.
  
  
• A transparent and binding statement of the Department of the Marine's plans for Lough Swilly. Is there a plan or is there not a plan? If there is a plan, we would like to have sight of it; we would also like the plan to be made known to all users of the lough and to be the subject of a public debate. If there is no plan, we believe there should be no further aquaculture licensing until such a plan exists. Department of the Marine officials have acknowledged that "mistakes were made" in Mulroy Bay, and we believe those mistakes were made because there was no overall plan for that bay. We do not accept that aquaculture can be developed in an ad hoc manner with no evident recognition or awareness of the broader impact, nor serious consideration of the wishes of the citizens most affected.
  
  

  If we do not have a plan, how can we know where we are going?
  

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Fact Sheets:

Shellfish Farming

Salmon Farming

Environmental Impact Assessments & Statements

Sea Lice