Mr. Rory Keatinge:

I wish to make four main points about fin fish and how they were dealt with in the reports. There is very little information in the documentation before us on the impact of fish farms on wild salmon stocks. For example, there is a lot of information in chapter three of the SEA on the impact of disease on farm fish, but not on wild stocks in the vicinity.

I know there is some disagreement among scientists at present, particularly with regard to the impact of sea lice on farms and wild salmon stocks. While we do not agree on these issues, the legally binding precautionary principle will often apply until we can agree on these matters.

Inland Fisheries Ireland, IFI, has called on salmon migratory routes to be factored into the SEA. It does not appear anywhere else and is certainly not mentioned in the plan. To this effect, NGOs will be proposing that a 25-km buffer zone from salmon bays and estuaries be enforced for the location of farms before any other factors are considered.

The second point concerns current laws. Current laws are by protocol and, as such, are extremely difficult to enforce. We have enclosed in the document as an appendix our current situation with two marine harvest farms where over-stocking is occurring and criticisms are being ignored. Protocols are often seen as soft law. We would like statutory instruments and statutory regulations on aquaculture, so that the couple of bad operators are brought to justice, held to account for what they do, and the rest of us do not get dragged along with it. This is a system by which the rest of us live, including the terrestrial farming community, and it should be the same for the aquaculture industry.

Third, there is concern among the communities - as we have seen in this country - about the impact of aquaculture on the natural environment. That is why so many people protest in Galway Bay. Many NGO groups are also concerned with various aquaculture issues but they do not seem to be involved in the strategic assessment process or the plan itself. Public participation is a key component, yet it seems to be lacking. Some of these groups have requested an audience with this committee and, unfortunately, have been refused. Many of them have far more relevant things to say that I do and are much more qualified to do so. There may be contrasting views from what they have to say, but their views need to be heard.

Fourth, closed containment aquaculture is now considered to be the most sustainable and what a lot of the world considers to be the future of fin fish. It is becoming more popular worldwide. It is acknowledged in the report that a good percentage of future development will consist of this closed containment aquaculture. We do not get much detail in the report, however, as to how, when or where this might happen, or an analysis of the strengths and weaknesses of that system. There is an indication of €1 million funding in seven years, which does not seem like a lot for the future of this industry.