Department of Agriculture, Food and the Marine Aquaculture and Foreshore Management Division ...

131 Pages·2015·64.06 MB·English

Department of Agriculture, Food and the Marine
Aquaculture and Foreshore Management Division
National Seafood Centre
Conakilty
Co. Cork
8 October 2013
To whom it may concern,
RE: Application by Braden Fanad Teoranta (t/a Marine Harvest Ireland) for a
foreshore licence near Shot Head, Bantry Bay, Co.Cork.
Further to the public notice that appeared in the Southern Star on 20 September 2014, we
should like to register our submission and objection to the application by Bradan Fanard
Teoranta (trading as Marine Harvest Ireland) for a foreshore licence for the purpose of
salmon farming at Shot Head in Bantry Bay.
We note this public notice is further to a previous notice in January 2012 where an EIS was
offered. We attach a briefing (appendix 1) that outlines our concerns in relation to the EIS
and development overall. Below we note our concerns relating to the materials presented
alongside this public notice during September and October 2014.
It is clear from the materials submitted that various government departments have raised
concerns regarding the proposal for the salmon farm at Shot Head. In particular it seems
there are concerns regarding the exposure of the site to waves and navigational channels.
The site is particularly close to shore and in the NW corner the site is a mere 10m deep. The
proposed cages are 15m depth in the centre and therefore could not be placed in such
shallow waters. However, the anchor and collar will be placed in the wave breaking zone,
putting the farm at serious risk of breaking its moorings.
Further concerns relate to the wave climate. It is stated that the 1:50 year storm from a 240°
direction at the SW corner of the site if given as 5.549m, 5.031 in the SE corner and 3.265m
at the NW corner. In the EIS it is therefore suggested the cages are placed at the NW corner,
but due to shallow depths and proximity to wave breaking zone this would not be possible or
appropriate. Therefore, the cages are liable to be placed relatively centrally or to the south
and thus be exposed to waves of between 5m and 5.5m.
(cid:9)
However, we believe these figures have seriously underestimated the local wave exposure.
January and February 2014 saw a series of severe storms in Bantry Bay where waves far
greater than 5m were recorded within the Bay on more than one occasion. Local reports
suggest waves as large as 18m were seen and waves of 25m were recorded at the Kinsale
Gas Platform.
Today's salmon farms are not designed to sustain such extreme environments and wave
heights.
On 1 February 2014, during one of these storms,(cid:9) • salmon farm was destroyed in
Bantry Bay and 230,000 fish escaped.(cid:9) is [C..o(cid:9) ated _ at(cid:9) only a couple of
kilometres further into the Bay It is a far more sheltered location than Shot Head which
would have experienced considerably higher wave, potentially leading to the destruction of
any salmon farm located there.
.(cid:9) .
The documents attached to the recent public notice,date frOrn OctOber 2011 to November
2012, prior to the series of storms and the 'escapes ui Bantry Bay Therefore none of the
above issues are addressed.
The Shot Head salmon farm is within i6km of Dromo'gPwland, Coornhola, Owvane,
Meelagh, Glengarriff and Adrigole rivers. As noted in attached briefing document, the
sheer scale of the escape in Bantry B4 means the already depleted wild salmon
stocks in local rivers could be swamp0 and put at risiOf mctiilction. To put these
rivers at further risk is irresponsible enVironment011y ay0 economically. For
destroying the wild salmon populations will in turn destroy a 10-cally lucrative angling
industry.
Human safety is a further issue that has been ignored. Duririg the 2014 storm considerable
numbers of vessels headed to Bantry Bei/ to shelter, With Many veSsgts circulating in the
exact area of the proposed salmon farm. the Bantry HarbOur Commissioners have raised
this concern, prior to the recent storms and the asSOciatechd'ramatiolicrease in boat traffic. •
Image: www.marinetraffic:com showing vessels in Bantry Bay during February 2014 storms.
In light these recent storms and changing weather patterns, the issue of navigational safety
needs to be re-examined. To find a situation in which heavy marine traffic is combined with
salmon farms which are at risk of tearing their moorings would be extremely dangerous.
Indeed to place a salmon farm at Shot Head would be neglectful and irresponsible to both
human life and the environment.
A further point of concern is the inaccuracy of details within submissions. In a communication
from Tony O'Sullivan of DAFM it is stated only three dwellings lie close by and 'the site is
generally remote from land dwellings and views'. Ironically, the map attached to the Public
Notice shows(cid:9) to have many more houses. This issue has also been raised repeatedly
by local inhabitants within their original objections in early 2012.
is made up of I houses only one of which currently lies uninhabited. Not a single
person within this community, that directly over looks the proposed site, has been consulted
at any stage. To suggest public participation in this planning process has been adequate is
grossly inaccurate. Prior to any decision being made on the proposal for a salmon farm at
Shot Head.it is vital the local community is genuinely consulted, in line with the Bantry Bay
Charter.
Yours sincerely,
ME- 111111
From:
Date: ,27/,'f/2014
To: Department of Agriculture,
Food and the Marine,
National Seafood Centre,
Clonakilty,
Co. Cork
Re: Objection Against Foreshore Licence at Shot Head, Bantry Bay, Co Cork
Dear Minister for Agriculture, Food & the Marine,
I wish to strongly object to the proposed Foreshore Licence that will involve the
placing of circular salmon pens at Shot Head, Bantry Bay, Co Cork to Bradan Fanad
Teoranta t/a Marine Harvest Ireland, Kindrum, Fanad, Letterkenny, County Donegal
on the following grounds:
• The placement of open net salmon farms at sea will have a negative impact on
marine life particularly juvenile salmon and sea trout due to high levels of sea
lice. Scientific studies have proven high mortality rates for juvenile sea trout
and salmon when salmon farms are located along the foreshore. Please consult
a definitive review of over 300 scientific publications which has just been
published, on the effects sea lice can have on sea trout stocks. A team of top
international scientists from Norway, Scotland and Ireland reviewed all
available published studies on the effects of sea lice and have now concluded
that sea lice have negatively impacted wild sea trout stocks in salmon farming
areas in Ireland, Scotland and Norway. Please view the full report that has
been welcomed by the chairman and board of Inland Fisheries Ireland at.
http ://www. fisheriesireland. iegisheries-research-1/459-effects-of-s almon-lice-
on-sea-trout-a-literature-review-nina-report-1044-september-2014
I am concerned of the very high risk of future escapee farmed salmon due to
Atlantic winter storms, sea swells and bad weather. The impact of escaped
salmon on native salmon has been well documented on various scientific
papers around the world. Please view the full report published by ICES
Journal of Marine Science 2006
http://icesjms.oxfordjournals.org/content/63/7/1234.full (Hindar, K., Fleming, I.
A., McGinnity, P., and Diserud, 0. 2006. Genetic and Ecological)
Page 1 of 2
-1 7 '
With regard to what is believed to have been a major escape of farmed salm
0(cid:9)
in Bantry Bay during a storm in early 2014 the Department of Agriculture,
Food & the Marine issued no official public report on the matter. I believe n(
licence should be considered at Shot Head Bantry, Co Cork until we have
established all the facts on the escape in Bantry Bay with an official public
report being published.
0(cid:9) I have concerns on how these salmon farms dispose of waste and how they us(
chemicals, anti-biotics and anti-foulants. Organic waste is known to
accumulate under fish farms cage sites. It consists mainly of waste feed and
faecal pellets (Ref. O'Connor et al., 1993; Scottet al.,1995). This will have a
direct impact on pollution levels in the surrounding aquatic area.
Yours sincerely,
Signed:
Name Block Letters:11311111111111111111111
Page 2 of 2
Deperhme,-Tot (IVikobictrJEtri,gre, FAM)11 'MCA the Marine
AquacuOtuAre EIRei Focashore ManageoneM Drivilebn
NEAOR8ID Seafood Centre
ConakIT'y
co. Coot
NAME: 111111111.1111
ADDRES8:
DATE:(cid:9) —
To whom it may concern,
ZAppllicailon by Gradan Fanad Teormta (tit Marine Harvest Elreiiairtd) ?or a
foreshore Oiloence rgear Shot Head, Bantly Bay, Co.Cork.
Further to the public notice in the Southern Star, 20 September 2014, I should like to register
my objection to the application by Braden Fanard Teoranta (trading as Marine Harvest
Ireland) for a foreshore licence at Shot Head in Bantry Bay.
I oppose this salmon farm for a number of reasons including:
o Wild salmon at risk
o River Angling at risk
o Water quality at risk
o Wildlife at risk
o Shellfisheries at risk
o Sea fisheries at risk
o Marine safety at risk
• Tourism at risk
o Lack of public participation
The issues have been addressed in detail in the attached submission from
fully support their case, and shall not reiterate their reasons for objecting to tie propose
salmon farm here. Rather 0 wish you to accept their document as representing the reasons
my opposing the salmon farm too.
Yours sincerely,
Department of Agriculture, Food and the Marine
Aquaculture and Foreshore Management Division
National Seafood Centre
Con akilty
Co, Cork
8 October 2013
To whom it may concern,
RE: Application by Bradan Fanad Teoranta (tia Marine Harvest Ireland) for a
foreshore licence near Shot Head, Bantry Bay, Co.Cork.
Further to the public notice that appeared in the Southern Star on 20 September 2014, we
should like to register our submission and objection to the application by Bradan Fanard
Teoranta (trading as Marine Harvest Ireland) for a foreshore licence for the purpose of
salmon farming at Shot Head in Bantry Bay.
We note this public notice is further to a previous notice in January 2012 where an EIS was
offered. We attach a briefing (appendix 1) that outlines our concerns in relation to the EIS
and development overall. Below we note our concerns relating to the materials presented
alongside this public notice during September and October 2014.
It is clear from the materials submitted that various government departments have raised
concerns regarding the proposal for the salmon farm at Shot Head. In particular it seems
there are concerns regarding the exposure of the site to waves and navigational channels.
The site is particularly close to shore and in the NW corner the site is a mere 10m deep. The
proposed cages are 15m depth in the centre and therefore could not be placed in such
shallow waters. However, the anchor and collar will be placed in the wave breaking zone,
putting the farm at serious risk of breaking its moorings.
Further concerns relate to the wave climate. It is stated that the 1:50 year st6rm from a 240°
direction at the SW corner of the site if given as 5.549m, 5.031 in the SE corner and 3.265m
at the NW corner. In the EIS it is therefore suggested the cages are placed at the NW corner,
but due to shallow depths and proximity to wave breaking zone thiS would not be possible or
appropriate. Therefore, the cages are liable to be placed relatively centrally or to the south
and thus be exposed to waves of between 5m and 5.5m.
However, we believe these figures have seriously underestimated the local wave exposure.
January and February 2014 saw a series of severe storms in Bantry Bay where waves far
greater than 5m were recorded within the Bay on more than one occasion. Local reports
suggest waves as large as 18m were seen and waves of 25m were recorded at the Kinsale
Gas Platform.
Today's salmon farms are not designed to sustain such extreme environments and wave
heights.
On 1 February 2014, during one of these storms(cid:9) salmon farm was destroyed in
Bantry Bay and 230,000 fish escaped.(cid:9) ocate at(cid:9) nly a couple of
kilometres further into the Bay. It is a far more sheltered location an(cid:9) ot Head which
would have experienced considerably higher waves, potentially leading to the destruction of
any salmon farm located there.
The documents attached to the recent public notice date from October 2011 to November
2012, prior to the series of storms and the escapes in Bantry Bay. Therefore none of the
above issues are addressed.
The Shot Head salmon farm is within 20km of Dromogowlane, Coomhola, Owvane,
Meelagh, Glengarriff and Adrigole rivers. As noted in attached briefing document, the
sheer scale of the escape in Bantry Bay means the already depleted wild salmon
stocks in local rivers could be swamped and put at risk of extinction. To put these
rivers at further risk is irresponsible environmentally and economically. For
destroying the wild salmon populations will in turn destroy a locally lucrative angling
industry.
Human safety is a further issue that has been ignored. During the 2014 storm considerable
numbers of vessels headed to Bantry Bay to shelter, with many vessels circulating in the
exact area of the proposed salmon farm. The Bantry Harbour Commissioners have raised
this concern, prior to the recent storms and the associated dramatic increase in boat traffic.
Image: www. arinetraffic.com showing vessels in Bantry Bay during February 2014 storms.
In light these recent storms and changing weather patterns, the issue of navigational safety
needs to be re-examined. To find a situation in which heavy marine traffic is combined with
salmon farms which are at risk of tearing their moorings would be extremely dangerous.
Indeed to place a salmon farm at Shot Head would be neglectful and irresponsible to both
human life and the environment.
A further point of concern is the inaccuracy of details within submissions. In a communication
from Tony O'Sullivan of DAFM it is stated only three dwellings lie close by and 'the site is
generally remote from land dwellings and views'. Ironically, the map attached to the Public
Notice show(cid:9) o have many more houses. This issue has also been raised repeatedly
by local inhabit nts within their original objections in early 2012.
is made pp of thou ses only one of which currently lies uninhabited. Not a single
i ,
person within thiS co munity, that directly over looks the proposed site, has been consulted
at any stage. To suggest public participation in this planning process has been adequate is
grossly inaccurate. Prior to any decision being made on the proposal for a salmon farm at
Shot Head it is vital the local community is genuinely consulted, in line with the Bantry Bay
Charter.
Yours sincerely,
Depanmercit of Agiudiagre, Food and the Marivori;-,
AquacmKome. and ForT.shore Managemen2 Dviskn,(cid:9) @ OCT NA
$.106iYA Seafood Centre,
ClonakiP.y,(cid:9) "
County Cork,(cid:9) AIWA
10 October 2014
Dear Sir / Madam,
Reference 15/555
I saw you notice in the Southern Star regarding the proposed salmon farm at Shot Head, and would
like to make the following submission.
I, and my family, oppose the salmon farm as we believe it will do nothing hut damage to our local
environment and economy. The salmon farm will only create two full time jobs, and these come at
far too greater cost to the local community and natural heritage.
Many jobs rely on our maintaining our pristine environment. Jobs in fishing, tourism, angling and
marine leisure. To have a polluting salmon farm that will destroy our water quality, wildlife and
remote desolate landscape that draws people from far and wide would be a serious mistake. These
jobs are in local family owned businesses. Families that have lived in Beara since time immemorial.
We do not wish to loose these for the sake of a couple of jobs, on minimum wage, in a multi-national
that may change its policy on whim.
We also do not believe the Shot Head site to be a safe location. Recent storms have battered the
area this winter, and had their been a salmon farm in this location it no doubt would have been
destroyed just as(cid:9) salmon farm on the opposite site of the Bay was. What is worse, is this
location is close to navigation channels and mooring sites for oil tankers going to and from VVhiddy
Island. To risk salmon farms becoming tangling with oil tankers shows a total disregard for both the
environment and human safety. The Whiddy Island disaster is in my memory and I do not wish to
see such a disaster strike again.
It is true there is a need for local jobs, but those of us who live here do not want these jobs at any
cost.
Yours,