SAVE THE SWILLY - October 01 ,2001

Aquaculture expansion in Lough Swilly - a clear and present danger

By John Mulcahy
Spokesperson for Save The Swilly

County Donegal, described in an ironic manner by a displaced Dub as "the lone-star state," is different, the tourism slogan proclaims. One difference is the impact on the county's infrastructure of decades of neglect by the central government. The harsh reality is that Donegal is in a pre-Celtic Tiger state of under-development, and job creation embarrassingly patchy.

Donegal's poor relative performance in employment creation, despite boasting a senior minister, a second Fianna Fail TD and two of the four (supposedly powerful) independent TDs, is the county's tragedy. It is also the only conceivable justification for the determined official denial, within the county and in Dublin, of the risks associated with aquaculture. Save The Swilly, an umbrella organisation launched in January 2001, is concerned about unbridled aquaculture expansion in Lough Swilly, and is determined to open up the debate.

While industry spokespeople (and some curiously protective politicians) paint objectors to aquaculture as blow-ins, cranks, troublemakers or combinations thereof, the truth is less convenient: commercial fishermen, anglers, sailors, divers, hoteliers, restaurant operators and a deep cross-section of the local community have voiced concerns. These range from visual impact on the marine landscape to impact on the lough's eco-system of the various chemicals and additives used. Many other legitimate users of the lough see aquaculture as a threat to their own livelihoods and to their lives. Mussel-farm buoys are commonly found drifting or washed ashore; salmon-farm nets and lines have become entangled in fishing-boat propellers. No action has been taken to deal with the perpetrators.

Save The Swilly has a specific objective: a moratorium on further aquaculture licensing in Lough Swilly until an independent baseline study and an independent environmental impact assessment have been conducted, followed by an opportunity for the residents surrounding the lough to express their views. In January, Buncrana Urban District Council, representing 5,000 residents, unanimously passed a motion supporting Save The Swilly in their aims, recognising the democratic right of everyone affected by aquaculture to participate in the decision-making process.

In response to a question in the Dail in March 2001, Minister for the Marine Frank Fahey said there would be no such independent study, nor would he indicate what the long-term plan for Lough Swilly might be. Every application for a salmon-rearing licence must be accompanied by an

Environmental Impact Statement, said Fahey, and in any case the Department of the Marine's CLAMS initiative was about to issue its own framework document for Lough Swilly. CLAMS (Co-ordinated Local Aquaculture Management Systems) is, as its title suggests, specifically designed and promoted by the Department of the Marine and Natural Resources to support the aquaculture industry.

CLAMS is neither independent nor objective; it has no statutory or legislative basis. Its own Mission Statement begins: "Ireland's bays and inshore waters are a primary natural resource. Their utilisation for the sustainable development of aquaculture requires a dynamic and evolving management system." In a reference to objectors, CLAMS Explanatory Handbook states: "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."

The fact that has escaped Mr Fahey in his response in the Dail, and CLAMS in defining its objectives, is that Lough Swilly is a public resource. The 'public' behind this phrase have said they will not stand by and watch this beautiful stretch of water deteriorate in the manner of Mulroy Bay or Killary Harbour. Commercial fishermen have been excluded from traditional fishing grounds by the monopolistic hold aquaculturists exercise over the more than 1,000 acres they already occupy. This may be a small proportion of the lough's area, but the overall impact on wild salmon and sea trout, migratory birds, wildfowl and shore-bird habitats, water quality, navigation and the general appearance of the lough, extends well beyond the precise boundaries of the aquaculture industry's operations.

The Environmental Impact Statement (EIS) referred to by Mr Fahey in the Dail is, in Lough Swilly's case, a single EIS, and has been used for every salmon-farming licence applied for and/or granted over the past decade. Prepared by the Institute of Aquaculture at the University of Stirling, it was commissioned by the licence applicant. So dated (no research later than 1994) that it is obsolete, it also does not address shellfish farming (for which there are now more than 50 licences in the area) and its impact on wildlife habitats, a matter that has attracted a serious EU reprimand. In a letter to the Irish government, Liam Cashman, Principal Administrator, EC Directorate-General Environment, dated April 2001, expressed this view: "The Commission is of the view that Ireland is not respecting these [European habitats directives], notably by reason of a failure to appropriately assess the individual and cumulative impact of aquaculture licence applications."

One aspect of limited independent aquaculture research in Ireland echoes the tobacco industry's standard defence: there is no causal link between smoking and lung cancer. There is also no causal link between fish-farming and the decline in wild salmon and sea-trout stocks, or on the decline of migrant birds in designated habitats, because research is lacking.

The degree of determination with which the Irish government nurtures and cossets the aquaculture industry is out of all proportion to its economic significance. According to official figures, the salmon-farming industry produced overall turnover of £48m in 1999. In the same year, again according to official figures, the industry employed 3,000 people. If 3,000 workers were paid any more than an average of £200 per week (£31.2m per year in total), the industry could not be profitable, given the fact that wages account for 60% of total costs.

The only conclusion is that by promoting aquaculture the government is clutching at straws to minimise the political consequences of its failure to deliver jobs in Donegal. Official figures suggest the salmon-farming industry is succeeding on a subsistence basis, or relying on various subventions from Ireland and the EU to produce a financial return. Another explanation: A multinational fish-farming company will in all likelihood also produce feed and chemicals in addition to ova, smolts, juveniles and mature fish. A fully-integrated business is able to ensure profitability at some point on this chain, even if there are apparent losses elsewhere from time to time. If the different divisions of the business are also in different countries, the possibilities for "tax efficiency" are almost infinite.

The relationship between regulator and industry in sectors owned and controlled by the State is often strained, and always - or should be - at arm's length, viz. telecommunications. That is not the case with aquaculture: the Department of the Marine, responsible for the protection of Ireland's marine resource, is the licensing authority, the regulator and the marketing arm of the aquaculture industry. There is a prima facie conflict of interest in this dual role, one which was also commented on by the EU Directorate-General Environment.

Local residents do not always express their concerns openly, as opposition to powerful fish-farming interests in some areas is deemed to be treacherous, and strong words have been exchanged over the issue in the past. Little possibility exists of open debate, as objectors are dismissed as ignorant of the industry and extremists opposed to all development. The hostility levelled at Save The Swilly, and by association at the 9,000+ people who have signed its petition, as well as the more than 30 founding member groups, is a measure of the industry's and the Department of the Marine's sensitivity to criticism.

The entire licensing, appeals and regulatory mechanism governing aquaculture is deliberately undemocratic. While legislation requires the Department to "notify" 11 different statutory bodies, many (Bord Failte, Duchas, regional fisheries boards), whether because of insufficient staff, funds or inclination, tend to adopt a passive approach. Licence applications are sent to these bodies by way of information, but there is no statutory obligation for them to comment or, if they do, for their comments to be given any consideration. It is an elaborate smokescreen suggesting extensive 'consultation' that, in reality, is virtually non-existent. The Aquaculture Licences Appeals Board (ALAB) has, in its three years of existence, upheld only two appeals (less than 2% of its determinations). ALAB has never granted a request for an oral hearing, despite many requests. Of the two appeals upheld, one - against a small prospective salmon farmer in Inver Bay, Co. Donegal - was submitted by the Irish Salmon Growers Association, together with three of the applicant's competitors

As risks associated with aquaculture in general become better understood, disquiet grows. Save The Swilly has not engaged in the issue of food safety, believing that to be the responsibility of the Irish government. However, it is common knowledge that a cocktail of chemicals and additives - licensed and approved by the government - is required to rear salmon, and there is little accurate independent research data available to reassure anyone that these products are not finding their way into the food chain.

The incidence of toxic algal blooms affecting shellfish on the West coast of Ireland is so frequent that testing procedures have become the focus for debate. It may be that France is imposing higher testing standards for imports than for domestic shellfish, but the bigger question is the assessment of the algal blooms themselves. Nobody denies they occur, but there is deep denial about the relationship between salmon farming and the duration of algal blooms. In Scotland and Canada, the link is recognised. "The burgeoning business of aquaculture, or fish farming, is also a growing source of nutrients for harmful blooms. The fish in enclosed fish farms produce a huge amount of waste, which in turn feeds the blooms," a Canadian expert said in March 2000. In Scotland, several shellfish farmers are considering legal action against salmon farmers for the impact on their operations. In Ireland such action is improbable, given the fact the umbrella organisation for shellfish farmers shares its executive with the salmon-farming industry.

It is difficult not to conclude that the regulators of aquaculture in Ireland are deluding themselves about the risks, or they live in hope that the full consequences of untrammelled expansion of aquaculture will not descend until they have retired. Two facts remain: aquaculture uses a publicly owned resource for private profit, and it is, in essence, intensive farming, and comes with all its attendant problems. It is also true that elected representatives will be held to account for their failure to respond to legitimate democratic concerns about the expansion of this industry, at the expense of the environment and of other users of the lough.

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