November 30, 2001

Mr Hugh Byrne TD
Minister of State for the Marine
Leeson Lane
Dublin 2

Dear Mr Byrne,

Fisheries (Amendment) Bill, 2000

We have noticed that you have again invited Save The Swilly to join the Lough Swilly Coordinated Local Aquaculture Management Systems (CLAMS). During your submission to the Seanad on 22nd November 2001 you said "one group declined" to be part of CLAMS in Lough Swilly. We assume you were referring to Save The Swilly. You added in your speech to the Seanad that this group should "embrace the [CLAMS] plan because it can have a voice which it would not have had heretofore. I want to see that everyone, whatever their views, has an opportunity to express them. Consultation and consensus [are] vitally important."

So far, so good. However, in defining CLAMS to the Members of the Seanad you appear to have described something that does not appear to coincide with CLAMS' description of itself. In the Seanad debate you said CLAMS is a forum "where all interests around a bay meet and voice their views with a view to achieving a consensus that is not driven by aquaculture alone. Everyone can have a say in the matter."

Would that it were so, Mr Byrne. I refer you to Section 3 of the CLAMS folder for Lough Swilly, dated September 2001. Section 3.1, headed "CLAMS GROUP", states: "The CLAMS Group comprises of members of the aquaculture industry in the Lough in association with relevant AI/BIM/DoMNR/MI/Taighde Mara Teo regional personnel."

The composition of the Lough Swilly CLAMS Group is not unique. In fact, according to the CLAMS Explanatory Handbook, "The CLAMS group will only be comprised of representatives of all bona fide aquaculture interests; producers and their representatives (technical and associations), liaison officer, relevant regional BIM, DoMNR, Marine Institute and Udaras officers."

According to the same document, which was produced by Bord Iascaigh Mhara (BIM), "it is envisaged that meetings, etc. will be held with various parties, who may not be in favour of aquaculture development. Though their comments will be heard, it is not going to be the policy to address all of their concerns in CLAMS. It must be stressed that one of the main purposes of CLAMS is to provide a framework for the development of the (aquaculture) industry and not a document that lists all objections to it."

With respect, Mr Byrne, CLAMS is not a forum that is likely to achieve a consensus among all stakeholders in a bay. It is not designed to be such a body, and we believe it was disingenuous of you to make such a claim to the Seanad.

The inference in your repeated assertions that our concerns can be addressed by CLAMS is that we are not willing to enter into dialogue. We are entirely willing to enter dialogue, but the forum for that dialogue cannot be a body whose primary objective is to expand and develop aquaculture, and whose structure precludes the membership of anyone other than representatives of the aquaculture industry or related government officials.

Your choice of language is interesting. The members of the public who attended the launch of the Lough Swilly CLAMS on 12th September are presumably "part of the CLAMS programme", but are these people aware that unless they are aquaculture representatives they cannot be part of the CLAMS Group, as defined by the group's own documents?

It is true that some individuals who are part of the Save The Swilly group helped the CLAMS process in Lough Swilly by providing information on aspects such as commercial fishing, tourism, etc. This information and cooperation was provided in good faith and in an attempt to ensure accuracy. As a group we were aware of this and have no problem with it. None of these individuals is part of the CLAMS Group, however, and would not qualify as such, so it is curious that you continue to urge Save The Swilly to "embrace" CLAMS.

Save The Swilly came together as a group only after many of the member groups and individuals had experienced years of frustrating efforts to assert a position that differed from that of the officials within the Department of the Marine or indeed to the policy of the government. The very existence of Save The Swilly is proof of the failure of the authorities to communicate effectively with people concerned about the expansion of aquaculture in Lough Swilly.

What could CLAMS do to achieve the objectives of Save The Swilly? To reiterate, Save The Swilly seeks a moratorium on further aquaculture licensing in Lough Swilly until completion of an independent comprehensive baseline study and a similarly independent and comprehensive environmental impact assessment of the likely impact of aquaculture expansion and other influences on Lough Swilly.

We know CLAMS exists, and should we wish or need to communicate with the aquaculture sector we know where to go. Even the CLAMS Explanatory Handbook does not claim the group to be all-embracing. In fact, it states that "the CLAMS group should form a focus or contact point for other local groups to contact. In this way it will be easier for aquaculture interests to be represented properly in things such [as] CZM (coastal zone management), County Council development plans and regional development."

There is nothing wrong with any of that, Mr Byrne, but it is misleading to claim that CLAMS is a catch-all body that equally represents all stakeholders in a lough. It is a body established to represent the aquaculture industry. As our concern is with the expansion of this industry in a manner we believe is prejudicing the interests of many of our members, it is hardly logical that we should approach CLAMS to address these concerns.

We believe the licensing authority, the Department of the Marine and Natural Resources, as well as sections of other government departments armed with legislative and statutory authority, such as Bord Failte, Duchas and local authorities, have the power and indeed the responsibility to deal with our concerns.

We will not be fobbed off by pressure to "embrace" CLAMS, which has no statutory or legislative power; which is demonstrably a body established to further the aims of aquaculture; and which we believe is the industry's Trojan horse aimed at maximising its share of the coastal resources before Integrated Coastal Zone Management (ICZM) becomes a reality.

We are surprised that you continue to urge Save The Swilly to "embrace" CLAMS, despite two face-to-face meetings between the group and you, as well as numerous public statements and a raft of correspondence showing clearly why we believe CLAMS is not a neutral, objective body that has the right to represent all interests around Lough Swilly.

It should be apparent that we know what the Department of the Marine and the aquaculture industry is trying to achieve in Lough Swilly, and we will not allow that to happen without a very clear and very loud voice communicating that fact to the public, and to the government of the day, in Ireland and in Europe.

What we seek is a genuinely transparent and democratic process, which will allow all citizens on the shores of Lough Swilly to participate in decisions that will affect the long-term future of this bay, a process that until now has been anything but democratic.

We have asked repeatedly for a serious analysis of the cost per job created in aquaculture, and of the equivalent return in terms of jobs created in tourism, commercial fishing or other activities in Lough Swilly, but there has been no response to this request. We are NOT opposed to employment - in fact, our members collectively employ many hundreds of people in the Lough Swilly area. What we want to see is a genuine assessment of the best uses for the lough, rather than a belligerent drive for aquaculture expansion without stopping to assess whether that is the best use of the resource or, indeed, whether a majority of people actually agree with that direction.

You made a statement in the Seanad debate concerning the area already covered by aquaculture in Lough Swilly. "I got some information on Lough Swilly recently and less than 2% of the area of the lough is under aquaculture." With respect, that figure appears to include only the surface area "under aquaculture", and not complete licence blocks, and refers to only the area actually covered at the time the estimate was done. If we include the area of the lough that is "over aquaculture", i.e. including bottom-culture shellfish farming, as well as full licence blocks, the figure is in excess of 10% of the area of the lough. That is important, because once a licence is granted, be it on the surface or on the seabed, no other users may enter that area. This is a factual error that should be corrected without delay. The figure of 10%+ was calculated from maps of licence blocks by an expert who has submitted a statement to the European Commission in connection with the Commission's complaint to the Irish government earlier this year, concerning aquaculture licensing in Lough Swilly.

You have in the past dismissed the validity of petitions, but the reality is that nearly 10,000 people - the great percentage resident around Lough Swilly - have now signed our petition, and we have an obligation to give those people a voice.

We do not believe their interests would be served by accepting that the CLAMS process is likely to achieve our objective of ensuring that no further harm is done to Lough Swilly through the expansion of aquaculture, and that a comprehensive study is conducted into the lough so that we can all know the state of this vital bay.

The culture of denial that will not allow the Irish government to take an independent and dispassionate view of aquaculture is inconsistent with the trend in the world. Norway has embarked on a programme to close fjords and inlets to salmon farming, in order to replenish wild-fish stocks. A debate is under way in Scotland, heated at times, but at least recognising the concerns of those opposed to the expansion of aquaculture.

New Zealand has declared a two-year moratorium on new marine aquaculture pending the introduction of a comprehensive coastal zone management strategy. It would be both visionary and sensible for the Irish government to follow suit by holding back on licensing until an Integrated Coastal Zone Management strategy is actually in place.

Save The Swilly comprises a wide cross-section of diversified interests around Lough Swilly, all of whom have expressed concern that aquaculture should not be allowed to expand until everyone understands the existing status of the lough and the threats to aspects such as wild fish, commercial fishing, tourism, bird and wildlife habitats and recreation. Our membership list is a matter of public record, as are our aims and objectives. Attempting to disparage our efforts by inferring that we are unwilling to participate in dialogue does no credit to you or to the Department which you represent.

What we seek is logical and obvious, and it would cost a fraction of the funding that has been allocated to the aquaculture industry in this area. The government's refusal to acknowledge, much less address, the concerns of our group and others of similar disposition is a sad indictment of current government policy.

On behalf of our members (more than 30 groups comprising in excess of 15,000 people), we repeat our request that the Irish government support our call for an independent environmental impact assessment for Lough Swilly. We also hope that you will in future acknowledge that CLAMS is not a panacea, and that it represents nothing more and nothing less than a club for aquaculture. We urge the Irish government to embrace the concept of Integrated Coastal Zone Management without delay, and to suspend further aquaculture licensing until such a plan has been implemented.

Thank you for your attention.

Yours sincerely,

A J Morrison

Chairperson
Save The Swilly

SAVE THE SWILLY contacts:

Email: info@loughswilly.com
Phone: Tony Morrison (353) 07493-63733
Phone: John Mulcahy (353) 07491-59113; (353) 086-2808636
Address: c/o Buncrana Anglers Association,
Castle Lane, Buncrana, Co. Donegal
Website: www.loughswilly.com

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Archived Press Releases:

September 25, 2006
Oyster crisis exposes "shambles" in management of Swilly

July 11, 2005
Attempt to double salmon-farming output in Lough Swilly

August 23, 2004
Which part of "No" don't they understand?

June 2, 2004
Coulter calls for political change in Donegal

December 15, 2003
Portsalon salmon-farming licence refused by ALAB

November 05, 2003
Sea Trout and Wild Salmon have been Victims of 'Ethnic Cleansing' - FISSTA

September 24, 2003
Prime Time Exposes Aquaculture's Shortcomings

July 24, 2003
Save the Swilly Calls for Farmed Salmon Mortality Monitor

July 21, 2003
Another Disaster in Inver Bay - Inquiry Essential

July 17, 2003
Rural Development Towards Sustainability

February 8, 2003
Save the Swilly Meets Inishowen Politicians

February 3, 2003
Blue Flag Beach Threatened by 80-Acre Fish Farm

January 29, 2003
Save the Swilly 10,000-Signature Petition Accepted by Europe

January 28, 2003
New Alliance Formed in Swilly

December 16, 2002
"Stop Ripping Up the Swilly" Indigenous People Demand

December 13, 2002
Lough Swilly's Indigenous Fishermen Speak Out

October1, 2002
Public Meeting to Discuss Integrated Coastal Zone Management

September 25, 2002
Save the Swilly Welcomes the Strategy on Coastal Zone Mangement

August 12, 2002
Integrated Coastal Zone Management Proposal Launched

August 2, 2002
Questions over decomposing salmon in Inver Bay

June 3, 2002
No Room for Tradition in Lough Swilly

May 3, 2002
Save the Swilly opts for "Swilly First"

May 3, 2002
Save the Swilly/Green Party candidate withdraws

May 1, 2002
Save the Swilly/Green Party candidate to contest Donegal North-East

April 18, 2002
Coulter to be "Ambassador at Large" for Save the Swilly

March 25, 2002
Save The Swilly presents 10,000-signature petition to EU

March 12, 2002
Study of Lough Swilly launched

November 30, 2001 STS letter to Hugh Byrne, Minister for State for the Department of the Marine

November 27, 2001 ICZM and OSPAR - not Clams - for Swilly

October 17, 2001 Salmon farm wants still more licences inshore

September 17, 2001 Save the Swilly meets Labour Party

September 13, 2001 Save the Swilly meets Minister of State Byrne

September 1, 2001 Save the Swilly begins fundraising drive

August 28, 2001 Save the Swilly welcomes I.F.A. initiative

May 15, 2001 Expansion of salmon farming tragic for Swilly

April 9, 2001 Mussel barrels adrift in Lough Swilly

March 22, 2001 Save the Swilly presents petition

March 13, 2001 Save the Swilly questions Minister Byrne

March 11, 2001 Save the Swilly reaffirms call for moratorium

February 20, 2001 Launch of Save the Swilly website

January 24, 2001

January 16, 2001 Delegation meets Minister Hugh Byrne

January 9, 2001 Save The Swilly
(from looking like Mulroy Bay)