Letters reveal sharp difference of opinion on how Irish salmon farms are licensed

McConalogue says system ‘fully compliant’ after Ryan raises concerns about sea lice threat to wild fish

Graphic of letters exchanged between Dept of Environment and DAFM with headshots of Ryan and McConalogue
Letters exchanged between Department of the Environment and Department of Food and the Marine, and their respective Ministers, Eamon Ryan and Charlie McConalogue

The Irish regime for issuing aquaculture licences is not sufficiently robust in how it evaluates risks to wild fish stocks and downplays the threat posed by sea lice arising from commercial salmon farms, according to Minister for the Environment Eamon Ryan.

In a letter to Minister for Food and the Marine Charlie McConalogue on January 25th last, the Green Party leader raised concerns over associated pollution, chemical use impacts, accumulations of waste in nearby seawater and genetic mixing as a result of interbreeding following the escape of farmed fish.

“Our current regulatory system for aquaculture is giving rise to ongoing detrimental and unsustainable impacts on wild fish stocks particularly salmonids [salmon and sea trout],” Mr Ryan said in the letter released under Freedom of Information legislation.

“The vast weight of peer-reviewed and published scientific studies, both in Ireland and internationally, demonstrate clearly that the undeniable detrimental impacts of sea lice emanating from fish farms on the survival of wild salmonids is unacceptably high and is a significant factor in the decline of wild stocks.”


There is, he warned, “an urgent requirement to mitigate, within aquaculture policy, the threat of introgression from escaped farmed fish with wild fish and the very real detrimental impacts on the genetic integrity, fitness, life cycle and from competition for habitats and food.

“Damage visited on the marine ecosystem and environment from uneaten fish food and pollution from a concentration of faeces in salmon farming areas needs to be addressed. There are also issues regarding chemical use in fish farms and corresponding impact on marine species in the vicinity of farms.”

There is ‘severe disquiet in relation to aquaculture policy, licensing and implementation, among stakeholders in the wild fish, environmental and ecology sectors’, Inland Fisheries Ireland and his department

—  Minister for the Environment Eamon Ryan

Mr Ryan said there was “a pressing need to align aquaculture policy and licensing with national, EU and international responsibilities and obligations as regards the conservation of wild fish stock and the aquatic ecosystem. Current aquaculture policy, regulation, development and implementation have proven detrimental impacts on wild stocks and habitat”.

The Dublin Bay South TD, who has statutory responsibility for conservation, protection and development of inland fisheries, noted that the National Marine Planning Framework required conservation of biodiversity and enhancement of the licensing system so it was “characterised by the highest level of scientific expertise [and] promotes trust amongst operators, NGOs and the general public”.

However, he said there was “severe disquiet in relation to aquaculture policy, licensing and implementation, among stakeholders in the wild fish, environmental and ecology sectors”, Inland Fisheries Ireland (IFI) and his department, which “has been recently intensified”.

Kenmare river

Mr Ryan outlined concerns about the way appropriate assessment of fish farm projects was being carried out by the Marine Institute on behalf of the Department of Agriculture. As a consequence, he had asked IFI — his department’s statutory scientific assessors — to examine a recent assessment in relation to Kenmare Bay, Co Kerry.

Kenmare river is a special area of conservation (SAC) under the habitats directive. The Blackwater river runs into the north shore of the SAC and is a designated SAC for salmon. There are four salmon farms in the Kenmare river SAC, while any further aquaculture development proposed must assess any cumulative threat to wild salmon.

Government departments in conflict over how best to regulate salmon farmsOpens in new window ]

The IFI concluded “the screening is based on a misinterpretation of the attributes which define the favourable conservation status of salmon, set out by the National Parks & Wildlife Service (NPWS), as the relevant competent authority under the [EU] habitats directive”.

“My department has concerns regarding the apparent reliance on two publications by the Marine Institute, which are at odds with the very vast majority of peer-reviewed and published scientific papers on this issue,” Mr Ryan said.

The IFI’s analysis “gives rise to very significant concerns as regards the assessment’s consideration of the impact of finfish aquaculture on wild salmonids”.

It disputed the conclusion that “outmigrating smolts [young adult salmon going to sea] will not be impeded or captured by the proposed salmon farming activity”. It found the appropriate assessment and risk assessment of salmon farm aquaculture undertaken were “not sufficient to meet the requirement of the habitats directive”.

If such assessment processes, as employed for Kenmare, were used in relation to other bays and estuaries, “the entire screening process is open to question, based as it would be on an incorrect misinterpretation of the attribute of salmon smolt abundance as set out by the NPWS”.

The IFI concluded “it is likely that the same conclusion will be reached for future proposed salmon aquaculture in all locations which will be completely unsatisfactory as an assessment of potential environmental impact”.

Mr Ryan said there was a need “to deal with these anomalies and ensure screenings for appropriate assessment across all estuaries and bays effectively and adequately take account of and address important attributes which heretofore appear to have been ignored or summarily dismissed”.

Stakeholders in inland fisheries intend to challenge the screening process and any aquaculture licensing system it purports to underpin “both domestically and at EU level”, he confirmed.

Studies indicate rivers with aquaculture show lower returns of mature salmon in years following high lice levels on nearby salmon farms, the IFI outlined in an appendix to the letter

On the finding aquaculture production did not pose any risk, the IFI said: “This conclusion cannot be reached as the presence of salmon farms and their potential impact on causing elevated sea lice levels and subsequent of outmigrating salmon smolts from the Blackwater river salmon SAC has not been assessed.”

Studies indicate rivers with aquaculture show lower returns of mature salmon in years following high lice levels on nearby salmon farms, the IFI outlined in an appendix to the letter.

It added: “No scientific publications other than those undertaken by [Dr Dave] Jackson et al are quoted in the appropriate assessment, and the conclusions reached in the appropriate assessment cannot therefore be regarded as a robust scientific assessment based on available scientific data.”

This “misinterpretation”, which defines the favourable conservation status of salmon, and reliance on two publications by the Marine Institute — “and a disregard from the large number of scientific publications at odds with this view” — meant appropriate assessment and evaluation of risk from salmon aquaculture “are not sufficient to meet the requirements of [the] habitats directive”.

The assessment could not determine if existing or proposed salmon aquaculture activities were consistent with conservation objectives for the Natura site involved “or if such activities will lead to deterioration in the attributes of the habitats and species over time and in relation to the scale, frequency and intensity of the activities”.

McConalogue response

Responding on March 29th, Mr McConalogue said he was satisfied the regulatory regime for aquaculture “is fully compliant with all of the State’s obligations in relation to the environment”.

The evaluation process “takes fullest consideration of all potential environmental impacts in advance of any decision to grant an aquaculture licence”, he added.

Mr McConalogue acknowledged “applications for aquaculture licences in SACs and special protection areas (Natura 2000 sites) are required to be appropriately assessed for environmental compliance with the EU birds and habitats directives”.

The licensing process had been enhanced since a 2007 “negative judgment” against Ireland for breaches of the directives, while his department “has adhered to an agreed roadmap and updated the European Commission via the NPWS on measures to ensure full compliance”.

He strongly defended the Marine Institute, which oversees and/or prepares reports in support of the appropriate assessment process, “and adheres to guidance” from relevant bodies. The more demanding stage requires a targeted scientific examination of the plan or project in relation to Natura 2000 sites, he said — though EU guidance does not preclude development in such sites. If the risk cannot be managed, then licensing “would be considered unsafe”.

He underlined sea lice monitoring in Ireland had been acknowledged by the European Commission as representing best practice”. Protocols for the management of sea lice are operated by the institute on behalf of the State.

Mr McConalogue insisted they were more advanced than in other jurisdictions: “The inspection regime is totally independent of the industry, data obtained from these inspections is published and made widely available, and treatment trigger levels are set at a low level.”

“There is an absence of clear evidence exclusively linking sea lice with high mortality rates” that suggested a need for further research

—  Minister for the Marine Charlie McConalogue

“Due to a lack of empirical evidence on the direct effect of sea lice infestation level and wild salmonid population levels, thresholds were devised by expert opinion to be as close to zero as possible,” he said.

Where thresholds are exceeded, farms are instructed to take action, which Mr McConalogue believed was indication of “a properly functioning management programme”, with a reduction in instructions issued in the past 10-15 years.

He pointed out Mr Ryan had not indicated which studies he was referring to when citing the vast amount of research demonstrating the detrimental impact of sea lice on wild stocks. But he conceded: “Neither myself nor my scientific advisers dispute that the management of sea lice is critically important. However, the actual significance of its impact in regard to wild salmonids is not fully quantified.”

“There is an absence of clear evidence exclusively linking sea lice with high mortality rates,” he said, which suggested a need for further research.

“Irrespective of the unresolved scientific position, the fact that Ireland has operated an independent national sea lice monitoring programme for nearly 30 years reflects the seriousness which the State takes any risk posed by sea lice on our wild salmonid populations and clearly demonstrates the mitigating measure in place.”

He believed the decline in North Atlantic salmon in the past 30 years was “most likely” multifactorial.

Farm inspections

On the threat of genetic mixing, he said “my department is not aware of an issue requiring urgent mitigation within aquaculture policy”, while every fish farm was inspected “at least annually or more by exception” — and must report any escapees.

This view is strongly contradicted by IFI in its objection to a salmon farm in Ballinakill Bay in Connemara.

“A number of alleged farmed fish have been identified by the IFI in rivers ... despite there being no reported escapes by the operators,” Mr McConalogue said. His department had advised that if IFI or anglers suspected they had collected salmon from farmed stock, the fish should be sent to the Marine Institute for analysis. “To date no fish have been forwarded to the Marine Institute for the necessary analysis.”

Mr McConalogue said he was surprised to learn of issues with the Kenmare assessment. The IFI had made no submission, while the NPWS had not raised concerns — 53 applications for aquaculture and foreshore licences were made on foot of the appropriate assessment.

“The Marine Institute has assured me and is confident that all advisory work completed ... is in line with best practices worldwide and [its] scientists take great care in discharging their responsibilities towards all conservation, protection and development activities in the natural environment.”

In 2013 it issued a statement defending a Marine Institute study by “Dr Dave Jackson and colleagues” published in the peer-reviewed Agricultural Sciences journal, which found no correlation between aquaculture and performance of adjacent wild salmon stocks.

“In their role as my scientific advisers the Marine Institute takes the critique in your correspondence seriously, and assisted me in taking this opportunity to thoroughly ensure that any perceived issues are addressed,” Mr McConalogue said.

The Kenmare appropriate assessment and risk evaluation was to determine shellfish licensing only “and are not sufficient nor were they intended or proffered to enable determination of marine finfish [farmed salmon] applications”.

“Therefore to question on the basis of this appropriate assessment whether salmon aquaculture is consistent with conservation objectives of Natura [sites] or if salmon aquaculture will lead to deterioration in the attributes of the habitats and species is not for determination at this stage.”

The regulatory framework, “requires a more robust environmental underpinning, which fully respects the requirements of the habitats directive”

—  Eamon Ryan

Ireland has committed to meet the Nasco goal of having 100 per cent of salmon farms adhering to effective sea lice management, such that there is no increase in sea lice loads or lice-induced mortality of wild salmonids attributable to farms, while 100 per cent of farmed fish were retained in all production facilities.

Concluding his letter, Mr Ryan said he was to publish a policy paper on “mitigating the impacts of salmon aquaculture on wild fish stocks, including sea lice and the dangers of introgression of farmed salmon on wild salmon populations” — setting out how aquaculture policy can align closely with wild stocks needs and facilitate both sectors responsibly coexisting.

His department and the IFI would support aquaculture “which is environmentally and ecologically sustainable, does not compromise biodiversity and genetic integrity, whose implementation is not detrimental to other sectors and meets the requirements of EU and domestic legislations, particularly the habitats directive”.

The regulatory framework, however, “requires a more robust environmental underpinning, which fully respects the requirements of the habitats directive.”

Kevin O'Sullivan

Kevin O'Sullivan

Kevin O'Sullivan is Environment and Science Editor and former editor of The Irish Times