Mr. Brendan Price:

I thank the Chairman and members for the invitation to attend the meeting. The Irish Seal Sanctuary welcomes the committee's input to the development of a national strategic plan for sustainable aquaculture development and is happy to assist it in any way. Unfortunately, the draft plan is somewhat insubstantial and is 14 months too late in the wake of the consultation period for the seafood development programme. As other speakers mentioned, we certainly need to avail of the time left to us to effect changes in the plan or, if necessary, extend that time. The Commission, in making this issue a condition of funding under the European Maritime and Fisheries Fund, has indicated that the stakeholding must be widened and deepened. The reality, however, is that many stakeholders in Ireland are unacknowledged, including most of those involved in small family enterprises in local coastal communities.

Having said that, the draft strategic plan is very welcome and at least gives us something to get our teeth into. In the context of Food Harvest 2020 and the focus on harnessing our ocean wealth, we have an opportunity to examine what our growing contribution to the EU demands. The strategic environmental impacts, appropriate assessments and the plan itself generically indicate that we have the capacity to meet the types of targets indicated, but they fall far short when it comes to offering any type of specific reassurance. The national strategic plan for aquaculture must be economically, ecologically and socially sustainable, but neither the plans nor the assessments really address the realities for operators. Much of the work on the assessments is either yet to begin or is in progress. With due respect to the authors of the plan, they were dealing with massive information deficits and outdated data. Both the plan itself and the assessments are quite disconnected. There is no breakdown of how the €30 million in funds allocated under the EMFF might actually be matched to projections. On that basis, the plan falls very short, with no attempt or opportunity to measure the projections and deliverables.

There are some amusing minor oversights to be spotted as one goes through the document, such as the statement that our aquaculture programme is located at 40 degrees of longitude to the west, which would put it somewhere off Newfoundland. I assume that is just a typographical error, but it suggests the haste in which the document was put together. There is insufficient acknowledgement of the need for major regulatory change. A new aquaculture regime requires a new, independent and sovereign regulatory system, independent of outside agencies such as the Aquaculture Stewardship Council, the Marine Stewardship Council, endorsements by the World Wildlife Fund, and the old-fashioned patronage of Bord Iascaigh Mhara and others.

A glaring recent example of green washing was the Marine Harvest Ireland incident, which was mentioned by another speaker.

The fishery press wrote that Marine Harvest Ireland obtained global environmental and social sustainability industry standards for Irish salmon farming. This is quite unacceptable and it was over the heads of Irish environmental sector non-governmental organisations, ENGOs. The response of the World Wildlife Fund, WWF, to articles on the subject with its endorsement was that it was for the American market and there was no real need to consult with Irish interests. The Aquaculture Stewardship Council was set up by the WWF and Dutch sustainable interests. It is an outside accreditation body with no input from Irish ENGOs, civil society or wider stakeholders. That presents a real problem because the aquaculture industry is plagued with this backlog of licences and perceived conflicts as they would call it with the Natura sites in many cases.

These problems, as Mr. Flynn indicated earlier need to be addressed urgently. They are two points that we would all take up and agree on. The idea of allowing accreditation continue without stakeholder input is unacceptable and if it is found out how lacking it is that will put at risk the whole Origin Green programme. That jeopardises the beef and dairy sectors and others availing of the programme.

Further incidents include 83,000 salmon escapees from Inver in 2010; pancreas disease and the attempt to prevent its disclosure by the Marine Institute, on commercially sensitive grounds, in 2014; 230,000 escapees, the biggest ever escape in Ireland, from Bantry Bay; a 3.5 km illegal pipeline from the Kilkieran-Carna public water supply to treat amoebic gill disease, AGD; and the programme states, with respect to fish farming, that the offshore fin fish farms and fish farming generally does not require fresh water. It very much does, it requires it on site, on the landward side and for the treatment of AGD. These things need to be factored in. Marine Harvest is not alone. There have been other incidents, such as the Mannin Bay Salmon Company damming the Bunowen river to treat AGD. Can these farms, relying on grant aid, support and proposed compensation, faced with parasites, infection, algal blooms, jellyfish and extreme weather events be considered sustainable? The plan advocates public insurance. Is it fair to expect the public to pay out for unfortunate events, if unfavourable sites are selected and projects approved?

In terms of stakeholding and the European maritime and fisheries fund, EMFF, €30 million goes to aquaculture. Various sums go to the research and management agencies and there are massive conflicts of interest in the management authority for the EMFF. Very often the management is a beneficiary of research money too. There is a conflict of interest between those disbursing the money, those receiving it and those in receipt of contract services or proxy inspectorate positions. That needs to be addressed. The ENGOs and community and civil society are not included as stakeholders in Origin Green or in the break-out of figures to assist with its work. That needs to be addressed because it is not wide.

The proposal to EMFF fund Bord Iascaigh Mhara, and to appoint aquaculture agents, an archaeologist, an ornithologist and a sustainable development expert, makes nonsense of these roles. In the case of agents, BIM officers are there for that purpose; archaeologists should be employed by the OPW; biodiversity experts and ornithologists - and certainly having only one for the extent of farms envisaged - will not do. They should be employed by the National Parks and Wildlife Service, NPWS, which has a vital role. Often when the old licences were granted and the NPWS was unable to be present at the assessments or meetings there was a teleconference about the strategic environmental assessment. In recent years the NPWS has seen 30% staff cuts and 40% budget cuts and it is not in a position to even attend these meetings. It is the statutory, sovereign, independent, competent legal authority for the conservation of our biodiversity, the implementation of the nature protection aspects of the Water Framework and Marine Strategy Framework directives and the Common Fisheries Programme. Most important, what is left out of the plan is the governance and partnership which is alluded to in the assessments and in the plan to include all stakeholders. With these limiting factors the plan is unsustainable. Without the break-out of funds I do not see how it would pass an investor, never mind a bank manager although maybe we do not talk about them.

The strategic environmental assessment, SEA, and appropriate assessment, AA, repeat the aspirations of the national strategic plan for sustainable aquaculture development, NSPA, and analyse them generically but say specifically they cannot assess them in any meaningful way. They are inadequate. This will come down to licence applications, project analysis and compliance with the nature protection directives. These things cannot happen if they are all in the hands of the one authority. BIM cannot be developer, beneficiary, licence holder and inspector. The protocols mentioned earlier need to be given statutory recognition so that there are independent sovereign assessors who will assess and monitor these firms in our interest and the wider interest of the environment.

Ireland should set high standards and not be controlled by one or more major players if its object is to be organic, sustainable and qualify for EMFF support. The organic standard is wide open to challenge and it puts the entire Origin Green programme at risk. Already, the United States and some Asian countries will not recognise the cage farming of fin fish and salmon as organic in any way. Discredited accreditation will destroy this plan before it starts, and I hope the committee is able to use its influence to persuade the Minister to extend the consultation period to embrace wider and deeper stakeholding from civil society and the ENGO sector.