Dr. Paddy Gargan:

Inland Fisheries Ireland has been concerned about the negative impact of salmon farming on wild sea trout and salmon stocks since the 1980s. Sea lice derived from local marine salmon farms causing lice infestation on sea trout stocks have been a particular concern. Many of the sites chosen in the early days of salmon farming were in shallow bays, close to river mouths. These were not suitable locations for farming salmon from a wild fish perspective. While there has been some improvement in sea lice control recently, some existing locations remain a threat to wild salmonid stocks owing to their proximity to rivers.

The best documented sea trout angling fisheries were in the Connemara area. Salmon aquaculture began to develop in bays in the mid-west in the early 1980s and approximately 7,000 tonnes of farmed salmon were being produced annually by the end of the decade. At the same time as the development of salmon farming in western bays, heavy sea lice infestation was observed on sea trout returning to rivers. This has been linked to the development of marine salmon farming in the west at that time, with sea trout stock collapses recorded in these rivers in the late 1980s. I refer to the graph of sea trout rod catches for the Connemara area for the years from 1974 until 2014, which shows a catastrophic collapse in the catch by anglers in the late 1980s. The stock has never recovered to the levels seen before it collapsed and angling tourism for sea trout is now only a fraction of what it was before the collapse.

With regard to scientific evidence of the impact of sea lice on wild stocks, scientific studies have demonstrated that sea lice from marine salmon farms, when not adequately controlled, can have a serious impact on local sea trout stocks. Sea trout are especially vulnerable to salmon lice infestation because, in the sea, they remain feeding and growing in coastal waters where salmon farms are located. A major review of more than 300 scientific publications was published by the Norwegian Institute for Nature Research, NINA, in 2014 on the effects of sea lice on sea trout stocks. Scientists concluded that sea lice have negatively impacted wild sea trout stocks in salmon farming areas in Ireland, Scotland and Norway. The report noted that in farm-intensive areas, lice levels on wild sea trout are higher and elevated lice levels on wild sea trout are found, in particular, within 30 km of the nearest farms, although the distance can also extend further.

The NINA report also examined the potential effect of sea lice on salmon. Results show that mortality due to sea lice on juvenile salmon at sea can, on average, lead to a decline of between 12% and 29% in the number of salmon spawning in rivers. It is clear from this report that sea lice from marine salmon farms can have a serious impact on the survival of both wild sea trout and salmon.

The Marine Institute monitors sea lice levels on marine salmon farms on a monthly basis. According to the 2014 report on sea lice monitoring, sea lice levels on farmed salmon increased in 2014 compared to 2013. In 2014, some 29% of sea lice inspections were above the treatment trigger level compared to 18% in 2013. According to the 2014 report, many factors have contributed to these increases. These include challenges to fish health, husbandry practices and treatment efficacy. From a wild fishery perspective, the current control of sea lice levels on marine salmon farms is not adequate at some sites and trigger treatment levels need to be based on total salmon farm production in the relevant areas. Inland Fisheries Ireland has consistently called for the introduction of a total bay sea lice cap, which sets a limit on the lice production level in a bay. This concept should be introduced in the new proposed strategy for sustainable aquaculture development.

Protracted harvesting of salmon has also been identified by Inland Fisheries Ireland as a factor militating against effective sea lice control as sea lice treatment is generally not undertaken during harvesting.

With regard to scientific evidence of the impact of escaped farm salmon on wild stocks, there is a large body of published literature on the negative interaction of farmed and wild stocks. Large-scale experiments showed highly reduced survival of salmon which have interbred with escapees when compared to wild salmon. In Ireland, official statistics indicate that approximately 415,000 salmon were reported to have escaped from salmon farms in coastal waters in the period between 1996 and 2004, with an annual range of between zero and 160,000 fish. In February 2014, some 230,000 salmon were reported to have escaped from a single salmon farm in Bantry Bay. Therefore, the proposal in the strategic plan for sustainable aquaculture to increase farmed salmon production, with maximum biomass on individual farms of 7,000 tonnes, poses a potential threat to wild salmon populations. This threat is particularly great when the small number of wild salmon in rivers - in some cases as low as a few hundred - is compared to the potential level of salmon farm escapes, which could reach hundreds of thousands.

I will now refer to the guiding principles for the sustainable development of aquaculture in the draft national strategic plan. Inland Fisheries Ireland supports the six guiding principles recommended by the Marine Institute for the sustainable development of aquaculture. Responsible planning to ensure that the overall development of aquaculture and the siting of individual farms are compatible with other uses and the responsible management of the marine environment, as set out in Principle 1, is an important guiding principle for the proposed future expansion of the salmon aquaculture industry. However, a number of existing sites, which were licensed during the 1980s, were located too close to river mouths and these sites should also be subject to assessment under the guiding principles to ensure the sustainable development of aquaculture.

It is intended that under Principle 2 - Ecosystem Protection - licensing and ongoing regulation of aquaculture operations will ensure compatibility with the goal of maintaining healthy, productive and resilient marine ecosystems. The aspiration is that this will ensure maintenance of good water quality and healthy populations of wild species, prevent escapes and avoid harmful interactions with wild fish stocks, protected habitats and species. Inadequate control of sea lice is a harmful interaction with wild salmon and sea trout stocks. Under the current licensing and regulation of salmon aquaculture, this guiding principle for sustainable development of aquaculture is not being met with regard to control of sea lice, particularly at sites in the west.

Under the Department of Agriculture, Fisheries and Food's Strategy for Improved Pest Control in Irish Salmon Farms 2008, which is still in place, it was proposed that a feature of the strategy to enhance the control of sea lice infestations on Irish salmon farms should be the creation of a real time management regime. This regime was intended to deal vigorously with failures to control sea lice infestations on a case-by-case basis. It was designed to bring progressively tougher actions to bear on sea lice infestation to ensure the highest possible level of compliance. Actions available include accelerated harvesting of salmon, followed by extended fallowing post-harvesting. In recent years, there have been examples of individual salmon farms failing to control sea lice below the sea lice treatment trigger level over long periods. The sanctions available under the real time management cell approach have not be enacted in these cases. Guiding Principle 2 will need to take account of the inadequacies in the current regulation of sea lice levels on salmon farms.

Under Principle 3 - Science-based Approach - planning, licensing and regulation of the sector are founded on the best available, impartial and objective science, as delivered by the national and international science community. This provides the highest level of confidence in the decision-making process and allows for the adoption of a risk and evidence-based approach to determining monitoring requirements that are subject to continuous improvement. This is an important guiding principle with regard to the proposed future development of marine salmon farms as there have been significant advances in our understanding of the potential negative impacts of sea lice and escapes from marine salmon farms on wild salmonid stocks in recent years.

Taking account of the best available science with regard to wild fish interactions with farmed fish will be important in ensuring the sustainable development of salmon aquaculture. Inland Fisheries Ireland is the statutory agency tasked with the protection and conservation of wild salmonids. These management responsibilities are supported by best scientific advice and it is important that IFI's scientific expertise is fully integrated into any science-based approach for the planning, licensing and regulation of the sector.

On the scaling and phasing of development of offshore salmon farms, use of the concept of carrying capacity in the national strategic plan, which considers environmental limits aimed at avoiding unacceptable change to the natural ecosystem, is important in ensuring sustainability of aquaculture. The concept of scale limits and phasing, as proposed, are important for the development of offshore salmon farms and are consistent with the recommendations made by IFI with regard to the proposed offshore salmon farm in Galway Bay. IFI commented that in any such project, a significantly lower smolt input should be licensed initially, with a gradual build up of smolt numbers only taking place following further rigorous review and consent processes. IFI believes that intensification should be treated as a totally separate application, with all of the associated statutory consultations and reviews. This would allow an assessment of any impact of the salmon farm on the environment, flora and fauna and allow mitigation measures to be developed in a more sustainable manner.

While the general concept of scale limits and a gradual phased build-up of production as set out in Chapter 6 are consistent with the approach proposed by IFI, the proposed appropriate maximum for new individual offshore salmon farms of 5,000 tonnes peak biomass is too large as an initial maximum production, particularly as existing salmon farms in Ireland have considerably lower licensed production limits. There is need to assess the environmental sustainability of offshore salmon farms at individual locations on a trial basis and only after monitoring has shown that no adverse impacts are evident should a gradual build-up of production be licensed. It will take a number of years and generations of salmon to adequately assess the sustainability of individual sites. It is, therefore, important that the initial licensed production tonnage be set at a lower level to demonstrate environmental sustainability. With regard to licensing additional tonnage beyond the initial licensed peak biomass, the recommendation in Chapter 6 that approval to increase the capacity above the initial allowable biomass should only be considered following a rigorous assessment of monitoring outcomes is consistent with this view.

On biodiversity and sustainable development, the strategic plan notes that Ireland’s second national biodiversity plan includes a programme of measures aimed at meeting Ireland’s biodiversity obligations, including a commitment to halt biodiversity loss by 2020. Sea trout are listed in Ireland’s biodiversity plan and the commitments in this national strategic plan for sustainable aquaculture development must include maintaining biodiversity with regard to sea trout populations.

On organic salmon production,the strategic plan for sustainable aquaculture development identifies the opportunity for increased production of organic salmon. While organic salmon production may be more profitable, there may be unforeseen environmental consequences. The Irish Organic Farmers & Growers Association, IOFGA, standards for organic aquaculture state that, regarding sea lice control, in-feed treatments and bath treatments can only be used twice in a 12 month period and not within one month of harvesting. The standards also note that if it becomes necessary to exceed the restricted treatments, the treated fish lose their organic status. Therefore, application of organic status to salmon production may hamper the ability to control sea lice on farms and directly impact on wild salmonids, contrary to the guiding principles for sustainable aquaculture.

On a risk-based approach to licensing, there is a large body of scientific evidence to the effect that the production of farmed salmon in Ireland has had a serious impact on wild sea trout and this impact continues to occur at a number of sites where sea lice are not adequately controlled. IFI proposes the development of a risk-based approach, using best national and international scientific information to analyse potential impacts on wild salmonids. This approach should not be confined to new developments but should also review existing fish farm locations. This risk-based approach is currently being undertaken in the Norwegian salmon farming industry. Consideration could also be given to designating areas free of aquaculture development, similar to the concept of national salmon fjords in Norway and the existing salmon farm free zone in Ireland.