Mr. Michael Mulloy:

I thank the committee for inviting IFA to address it today on the challenges facing the aquaculture sector. I am joined by Ms Teresa Morrissey and Ms Catherine McManus.

There is a critical need for a commitment from the Government to ensure the economic potential and sustainable future of the Irish aquaculture industry is realised. Immediate action to implement a functioning aquaculture licensing system must be a key priority for any future development of the Irish aquaculture industry, including appropriate legislative changes required to facilitate this. The full implementation of the aquaculture licensing review, published in 2017, must be prioritised and actioned to allow for effective implementation of the actions proposed in the draft seafood development programme 2021-27 and the draft national strategic plan for sustainable aquaculture development 2030. The Irish aquaculture sector needs the support of policy in order to achieve any realistic sustainable development so as to unlock any future potential of the Irish aquaculture industry.

Recommendations and priorities for development of sustainable aquaculture outlined in several Government policy documents. The Review of the Aquaculture Licensing Process, the National Strategic Plan for Sustainable Aquaculture Development, the Report of the Seafood Task Force - Navigating Change, and the A Programme for a Partnership Government speak of developing a thriving and dynamic Irish aquaculture sector not limited by quota. Production targets outlined in Ireland's Response the Commission's Green Paper on the Reform of the Common Fisheries Policy in 2013 will not be achieved. Aquaculture production has stagnated in recent years, with no significant increase in production figures despite EU and national policy objectives aiming to increase sustainable aquaculture development.

Targets to increase production and develop the Irish aquaculture industry have not been met. The target at the beginning of the previous European Maritime and Fisheries Fund, EMFF, programme 2015-21 was to increase production by 45,000 tonnes, from 36,000 tonnes in 2012 to a predicted 81,000 tonnes in 2023. By the end of 2018, production had decreased by 7,000 tonnes on 2012 levels, estimated at over €105 million in product value. By the end of 2020, Irish aquaculture production had further decreased in volume on 2012 levels, and for most of that period Irish aquaculture production remained static as opposed to increasing. The cumulative loss to the sector is estimated in excess of €570 million over the period at the prevailing in-year price.

Eligibility criteria for funding schemes under the previous EMFF operational programme was hindered by the fact that most of industry was ineligible for grant aid due to state aid rules related to aquaculture licensing, which was outside of the industry’s control. Given that this is the main financial source to ensure effective implementation of the common fisheries policy, CFP, available for the sustainable development of the aquaculture sector, it is imperative that access to the available funds are facilitated at every possible opportunity.

To give further context to the lost opportunity of Irish aquaculture over the period of the European Maritime and Fisheries Fund, EMFF, programme, as global aquaculture production grew by an average of 5.3 % per year in the period from 2001 to 2018, Ireland has not matched this trend in aquaculture production growth. Ireland has gone from having 5% of European aquaculture production 20 years ago to less than 2.5% currently. However, Ireland is now the most significant aquaculture producer in the EU since the departure of the UK after Brexit. Ireland accounts for over 24% of total EU organic aquaculture production across all species, with Irish organic salmon making up the majority of the production volume. This is despite Ireland’s overall aquaculture production, particularly salmon production, having being reduced in recent years.

Irish aquaculture production is very good value for the amount of licensed area currently in operation. The Business of Seafood 2021 report by An Bord Iascaigh Mhara, BIM, shows that 90 sq. km of licensed area yielded 38,000 tonnes worth €175 million in value to the Irish economy. The majority of that value, that is €109 million, came from Irish organic salmon. Irish aquaculture produce accounts for over 20% of the total Irish seafood exports from the three main export species, with more than 80% of this aquaculture produce being exported to the value of €150 million. The Irish Farmers' Association, IFA, estimates that Irish aquaculture could contribute more than €500 million in direct farm gate income and a further €500 million in ancillary activity, that is marine engineering and seafood processing, mostly generated from export trade. This value and volume of Irish aquaculture production could be significantly increased by optimising the existing licensed aquaculture space and allowing licence conditions to adapt to innovative and efficient aquaculture production systems. Most important, unlike targets and speculative statements on increasing aquaculture production of the past, we need to be more specific, ambitious, and realistic.

The Irish aquaculture industry provides essential support and employment opportunities for rural coastal communities with almost 2,000 direct jobs and over 16,000 indirect jobs in seafood processing and marine ancillary services sectors. With a multiplier effect average of 1.5, a sustainable Irish aquaculture industry has huge potential to create employment opportunities and further enhance coastal communities both through direct employment and indirect employment in marine industries and marine ancillary services.

With considerable investment in and appropriate legislative changes to the Irish aquaculture sector, there can be significant increases in direct and indirect employment, volume and value of aquaculture production. IFA Aquaculture believes in the future of rural coastal communities, and industries such as aquaculture are imperative for the vitality of these communities.

In short, we are lacking a coherent, realistic and ambitious policy for Irish aquaculture. The current policies and objectives in relation to aquaculture are non-binding and non-specific in terms of targets and are coupled with numerous policies and regulations that are not streamlined. There needs to be a realistic EU and national policy to develop the aquaculture sector that facilitates the sustainable development of Irish aquaculture.

IFA Aquaculture has the following recommendations. We recommend the implementation of the recommendations in the review of the Irish aquaculture licensing report. There are several issues in relation to the lack of progress on a number of the recommendations outlined in the review of the aquaculture licensing process, where the report concluded in 2017 that the aquaculture licensing system was in urgent need of reform. The report also explicitly states the Minister "will assign responsibility for recommendations, accountability and set milestones for delivery and identify the necessary resources to support the implementation process". The recommendations of the aquaculture licensing review need to be prioritised, resourced, and implemented urgently with greater stakeholder engagement regarding an implementation plan and realistic timelines for completion. This would include the re-establishment of the aquaculture licensing advisory committee, ALAC.

Recommendation 8.16 of the review of the aquaculture licensing process report recommended "work to commence immediately on the preparation of new aquaculture legislation". Since the report was published, a further number of EU and national legislative policies have been given effect, many mentioned previously in this statement. Most specifically, the recent marine planning and development management Bill could be viewed as a missed opportunity for Irish aquaculture reform, regulation and development management due the exclusion of the sector from the legislation. Aquaculture legislation, both primary and secondary, has been amended numerous times, in particular to give effect to EU environmental legislation, making it difficult to follow and establish the current status of various provisions.

Regarding the inclusion of aquaculture in the marine planning and development management Bill, IFA Aquaculture has serious concerns regarding the exclusion of aquaculture from this Bill. The national marine planning framework, NMPF, aims to introduce a single development management process for the maritime area for activities or developments. This is underpinned by legislation introduced in the form of the maritime area planning Bill which aims to establish a new regulatory body in the maritime area regulatory authority, MARA. This will not include aquaculture or fisheries, as they are not legislated for as part of the Bill. Aquaculture and fisheries must be included in associated national marine spatial planning legislation as it is essential for the fair and correct development management of the marine space.

A coherence of policies through the open method of co-ordination in relation to aquaculture continues to be absent. Alignment and coherence of aquaculture objectives with EU environmental regulations and directives is a key challenge and the level of coherence between different EU policies should be assessed on a sector-by-sector basis. The aquaculture sector complies with obligations, particularly environmental objectives, outlined in a number of policies and regulations i.e. the habitats directive; the birds directive; consolidated environmental impact assessment directive; marine strategy framework directive; marine spatial planning directive; water framework directive; and the Common Fisheries Policy.

Irish Aquaculture operators and their businesses will no longer be profitable unless there are significant supports during this time of crisis to assist with spiralling input costs. Earlier this year the European Commission activated a crisis mechanism of the European Maritime, Fisheries and Aquaculture Fund, EMFAF, to enable member states to grant financial compensation to aquaculture operators for income foregone and additional costs due to the current market disruption. The EMFAF crisis mechanism is a temporary measure and applies retrospectively as of 24 February 2022 and will be in place until the end of the year. IFA Aquaculture is calling on the Government to consider these funding mechanisms made available by the European Commission to assist Irish aquaculture operators affected by these severe cost increases. This must be done without delay.

In conclusion, it is now critical that a single piece of legislation is brought forward to implement and underpin appropriate aquaculture policy and to bring together all the existing primary, secondary and amended legislation in one single provision. In summary, if the objectives and specific actions outlined in the Seafood Development Programme 2021-2027, the national strategic plan for sustainable aquaculture and the Report of the Seafood Task Force are to be most effective for the sustainable development of the aquaculture industry, an immediate effort must be made to reform, modernise, and improve the aquaculture licensing system. Reducing the administrative burden and having an efficient, transparent aquaculture licensing system is of benefit to regulators, the industry, and aquaculture stakeholders alike. That concludes our opening statement.