National Strategic Plan for Sustainable Aquaculture Development: Discussion (Resumed)

I remind members and witnesses to turn off their mobile telephones. I welcome Dr. Gregory Forde, head of operations at Inland Fisheries Ireland and Dr. Paddy Gargan, senior research officer at Inland Fisheries Ireland, and thank them for coming before the committee to discuss issues concerning the national strategic plan for sustainable aquaculture development.

I advise the witnesses that they are protected by absolute privilege in respect of their evidence to this committee. If they are directed by the committee to cease giving evidence on a particular matter and they continue to so do, they are entitled thereafter only to qualified privilege in respect of their evidence. They are directed that only evidence connected with the subject matter of these proceedings is to be given. They are asked to respect the parliamentary practice to the effect that, where possible, they should not criticise or make charges against any person or persons or entity by name or in such a way as to make him, her or it identifiable. Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or any official by name or in such a way as to make him or her identifiable.

Dr. Greg Forde

I apologise for the absence of Dr. Ciaran Byrne, the chief executive officer, who is on annual leave. He would have loved to have been here today. I know the committee has much business to do so we will get through the opening statement and then be open to questions that arise.

We are grateful to have the opportunity to address the committee on the important topic of the draft strategic plan for sustainable aquaculture development. Inland Fisheries Ireland was established on 1 July 2010, following the amalgamation of the central and regional fisheries boards. The agency was established under the Inland Fisheries Act 2010, with many of its powers deriving from the principal Act governing the sector, the Fisheries (Consolidation) Act 1959. The main functions of Inland Fisheries Ireland as identified in the 2010 Act are "to promote, support, facilitate and advise the Minister on the conservation, protection, management, marketing, development and improvement of inland fisheries, including sea angling".

It is important to note that protection and conservation of the inland fisheries resource includes the important migratory species in the sea, in particular the Atlantic salmon and sea trout. These responsibilities were also part of the primary functions of the central and regional fisheries boards, established in 1980, and the boards of conservators and the Inland Fisheries Trust before that. Salmon fisheries in the marine, estuaries and fresh water are an important asset of the State that yield considerable revenue through angling in particular.

Inland Fisheries Ireland will, in the course of the next week, be making its own submission in respect of this consultation but it is important for us to identify the key areas where we believe the committee may find it useful in making observations on the documents currently proposed by the Minister or in clarifying the areas where Inland Fisheries Ireland has concern and the reasons for this concern.

The angling resource in the country has long been undervalued - a recent economic assessment identified that this industry is worth some €755 million annually to the national economy and supports approximately 10,000 jobs. The impact of this socio-economic dividend is largely of benefit to peripheral and rural communities, often where alternative income-earning opportunities can be limited, and the safeguarding of these areas in terms of their earning potential from angling tourism should be a priority. Rural communities benefit most from small labour-intensive ventures rather than large industrial-sized operations. The current consultation is specifically about the sustainable development of aquaculture and this opening statement attempts to identify the key issues of interest and concern to Inland Fisheries Ireland that may assist the committee.

Licensing is a key issue. The current licensing system has proven problematic but Inland Fisheries Ireland is conscious of the environmental issues that must be considered by the licensing authority in developing a sustainable industry. Inland Fisheries Ireland supports the sustainable development of the aquaculture industry; the word "sustainable" is key and specifically encompasses sustainability of the development from an ecological as well as financial point of view. The area of particular concern to Inland Fisheries Ireland is the need to ensure that any aquaculture development does not have a deleterious effect on other industries, such as the valuable salmon and sea trout tourist angling industries. Inland Fisheries Ireland would welcome reform to the aquaculture licensing process. Where existing licences are in place and where these have an effect on the wild fisheries, the licence process must be capable of phasing out these sites and selecting alternative sites that do not impact on wild fisheries.

A second important consideration in the reformation of the licensing system is to separate the processes of licensing and regulation. It would be preferable if these responsibilities were not within the same Department. The licensing section should remain under the parent Department and the regulation or enforcement remit should be under a different State agency. The regulatory agency should be appropriately mandated to transparently enforce the licence conditions. This would also help the licence operators and wild fish interests know the rules within which the industry operates. Similarly, in the view of Inland Fisheries Ireland, it is unwise for the State to be the licence applicant in a commercial aquaculture venture.

Inland Fisheries Ireland is aware that escapes from salmon farms into the wild are primarily the consequence of an unplanned catastrophe. The licensing system should include the creation of an emergency fund to facilitate the recovery or clean-up of the consequences of any such events. This could include the recovery or removal of escapees from local rivers by the competent authority, as well as any other environmental clean-up, such as removal of mortalities from the sea bed. The current system of licensing includes a series of protocols. The code of practice for pest control is not, in the view of Inland Fisheries Ireland, adequately robust to ensure the protection of wild sea trout and salmon smolts from lice from marine salmon farms. This will be dealt with later by my colleague. It is recommended that the enforcement regime should include a series of incremental penalties for persistent breaches of licence conditions.

Inland Fisheries Ireland favours the development of closed containment recirculatory land-based systems for the farming of Atlantic salmon, as this ensures all outputs can be managed and controlled. Inland Fisheries Ireland acknowledges that the technology may not yet be at a sufficiently commercial scale but recommends that adequate funding should be provided to assist in developing this aspect of the industry. Over time, Inland Fisheries Ireland would welcome a gradual move towards onshore recirculation sites and a phasing out of open pen facilities to ensure the protection of the wild salmonid stocks.

On the mollusc side, Inland Fisheries Ireland believes that small-scale mollusc aquaculture activities best suit rural communities that have farming and fishing as part of their existing core skills. The development of these activities still have very significant potential and these are both low-impact and labour-intensive. With oysters, Inland Fisheries Ireland notes that disease in the wild oysters has reduced the wild oyster stock in many bays around the country. The development of farming the Pacific oyster has unexpectedly led to this non-native species becoming feral in Lough Swilly. Acknowledging that the wild oyster stocks in most parts of the country remain in trouble, Inland Fisheries Ireland recommends that any farming of the Pacific oyster is done in an enclosed regime, with bags and trestles, using triploid stock.

This will prevent it becoming established elsewhere in the wild. In areas such as Lough Swilly where they have already become established in the wild, provision should be made to remove the Pacific oysters. This must be done in line with the requirements of the National Parks and Wildlife Service.

The issuing of aquaculture licences in areas where established wild mollusc fisheries exist has also raised concern. Any plan for the sustainable development of the industry should include provision for the surrender of aquaculture licences where they conflict with wild mollusc beds and their replacement by a licence on a different, new unlicensed site.

I will hand over to my colleague, Dr. Gargan.

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.

I thank the witnesses for their opening statements. Deputy Ó Cuív.

I thank Dr. Forde and Dr. Gargan for their submissions. Of all the issues arising in this area, the salmon issue is the most controversial.

The concern of the IFI, in terms of the aquaculture issues with which it is most familiar, appears to be around imported species, particularly oysters. Am I correct that the IFI is of the view that we should not be importing shellfish for farming in our waters for aquaculture and that we should try to develop a native industry that obviously would have a natural in-built resilience to diseases? In regard to oyster imports, my understanding is that oysters imported from France in particular have caused severe damage to our native stock and that this is a particular challenge. Perhaps the witnesses would address that issue and outline their view on the importation of seed from places outside this island.

The main issue of focus today for the IFI is finfish farming. I get the impression from what the witnesses had to say that finfish farming has damaged the wild salmon stocks and that they are fairly unequivocal about that. I am sure Dr. Forde and Dr. Gargan are aware that what has been puzzling some of us for some considerable time is the fact that while the IFI has been very strong on this case, and has backed that up with scientific evidence, other State agencies are of the view that the huge expansion of this industry is of major benefit to the country. From a scientific point of view, somebody is right and somebody is wrong. Am I correct that the view of the IFI is that finfish farming has been damaging to the wild salmon stock? Also, if we had never had any farming of salmon in cages around our coast, would the IFI be recommending today that we would be better off at this stage not developing any such farms?

I also got a particular impression from the witnesses on a second issue, although I may be incorrect. It was stated that while the IFI believes that finfish farming has caused severe damage, it recognises that people have licences and, as such, this practice could be better facilitated by way of resettlement or re-siting of existing fish farms to more suitable sites as licences come up for renewal, thus removing them from river mouths and so on. Is the IFI opposed in principle to the setting up of new finfish farms where currently there are none and proposing the relocation of those already in existence when it comes to renewal of licences?

The next issue raised was the contention that the Department should not be the licence giver. That makes sense. I have argued for a long time for reform of licensing, because it is not right that the developer also be the gatekeeper. The Department's role is to develop aquaculture. I mean that in the widest sense. I believe the IFI proposal is an interesting one. The witnesses also spoke of the need for better monitoring and graded penalties and sanctions. On that issue, I was recently told - the witnesses might confirm whether this correct - that in situations in which licences for fish farms have expired and those farms do not comply with the various environmental requirements, it is virtually impossible to sue the operators because, as they do not hold a valid licence, they are therefore not bound by the terms of any licence.

As the fish farms are on an extension of a licence, they are exempt from having a licence, in the strict legal sense. In other words, one cannot stop them fish farming but they do not have a licence. I would like to hear the witnesses' views on that because if that is correct, that would create an emergency.

In regard to the policy proposal of a maximum limit, and the witnesses seem to be fairly negative on fish farms, they appear to say that the maximum proposed is far too high but even if there were a maximum, it would be totally subject to site specific requirements and we need to be conscious of this.

Since drift netting was stopped on the coast, did the wild salmon stock recover? The fishermen were talking salmon from the sea but they were not causing pollution, spreading infections or causing cross-breeding. Is it the case the salmon stock has not recovered and that other factors, such as municipal waste, finfish farming and trawlers sweeping everything out of the sea have had much greater impact on the wild salmon than the drift net fishermen, particularly the fishermen in a currach ?

I thank both Dr. Gregory Forde and Dr. Paddy Gargan for their presentation. It seems easier to control shellfish farming, be it mussels, scallops or oysters. It does not have the same impact as finfish farming on salmon and trout. Mention was made of the effects of farmed Pacific oyster in Lough Swilly contaminating the natural oyster. I come from an area where we have one of the finest natural oyster beds in Europe and we are lucky that there are no farmed oysters that near to them, as Kenmare Bay is the nearest place where there are farmed oysters. We have been free of contamination.

I refer to the number of oyster beds around the coast going back 100 years to 120 years which have been wiped out. Only a few remain - the few that are sustainable. That was long before we had farmed shellfish or whatever. There were other factors at work - perhaps over-fishing could be part of it as well as infected waters.

Finfish farming is highly controversial, in particular the proposed salmon farm in Galway Bay. The size of the proposed Galway Bay project is a cause of concern in terms of fears of cross-contamination with sea lice, fish escapes and the damage this will do to the wild salmon. I concur that the size and location of the proposed fish farm will have a detrimental effect, particularly near the mouth of a river as has been said, and the effect on trout and wild salmon of the infected farmed fish escaping from their cages.

Dr Gargan mentioned that it may be practical in deeper water and I would like him to elaborate on that. When he refers to deeper water, is he proposing that the farms be located further out to sea, because the further out one goes, the more exposed one is to weather conditions and so forth? Mention was made of the significant escape in west Cork, which came about, if my recollection is correct, in the eye of one of the worst storms in my memory. These escapes have a detrimental effect.

I have looked at reports from 2009 to 2012 dealing with the damage to Donegal, in particular. I assume the Marine Institute carried out investigations at that time. I know the Marine Institute was involved in looking into the reason, cause and extent of the damage in 2011. Have the major companies been sanctioned or have the reports from the Marine Institute been supported by the Department or the political side? With proper regulation and proper scrutiny, we can get this right. However, if the body charged with investigating the effects of bad practices, notwithstanding the inappropriate locations, which is outside all of our control, and the information is not dealt with, it does not auger well for the future. It makes things an awful lot worse.

Has political influence been used to curtail in any way the working of the Marine Institute in trying to do the right thing? The Galway Bay project is being driven politically and that certainly neutralises people who have concerns about the long-term well-being of the wild salmon. That would certainly be the case up to now, unless there was a U-turn or some way to claw back from the Galway Bay project.

It was mentioned in the presentation that the development of a closed containment land-based system for the farming of salmon would be welcome if the companies were prepared to go down that road. I have been of the opinion that fish farms could be created on land. I think one would be able to control contamination from lice infestations and escapes. I understand that there would be a higher cost factor. Obviously, the consideration of companies investing in fish farming is all about profit and not about the environment. Profit is the motivation. Energy costs are another consideration. Could we have a joined up approach and consider using green energy, availing of tidal wave or wind energy in such projects?

I think we all want to get it right but we also want to create enterprises in our bays that will contribute to rural areas. Rural Ireland has been decimated and we need to ensure that people can make a viable living in their area and sustain the local economy. There are aspects of aquaculture that can be located in areas that would be beneficial to local communities. It is about getting the right locations. As it was made quite clear in the presentations, the mouth of a river is not the place to locate fish farms as it has an adverse effect on salmon and trout stocks.

Senator Ó Clochartaigh and Deputy Harrington have indicated they wish to speak. Will I call Deputy Pringle after that?

I will put supplementary questions. I apologise for being late.

Cuirim céad fáilte roimh na finnéithe agus gabhaim mo bhuíochas leo as ucht an cur i láthair.

From listening to the hearings on the issue, we have the whole spectrum of opinion from those who would be in favour of open fish farms at sea and those at the other end of the spectrum who would be totally opposed to them. I would agree with the comments on the need to separate licensing from regulation. Let me put the same question as I have put to previous witnesses. Do the witnesses see a situation where one can have the angling fraternity and the aquaculture fraternity living within the marine environment we have?

Are there ways in which they can be mutually supportive, so that one is not to the detriment of the other? If there were to be a separation of licensing from regulation, would the witnesses add other regulations - for example, on the size of farms, proximity to estuaries and distance of extension out into to sea - and would there be certain no-go areas? If the witnesses were given carte blanche to lay down the regulations that should be put in place to ensure both a thriving angling industry with adequate stock and aquaculture side-by-side with it, what regulations would need to be put in place?

On the matter of closed containment onshore aquaculture, it seems like a no-brainer that we need to develop that part of the industry, and it would seem to solve a great many problems, but the counter-argument is cost efficiency. When will this be viable? Where is the technology being developed? Do the witnesses know how long it will take for the technology to be applied to commercial production? Could we in Ireland be industry leaders in that area if we put the proper investment into it? We are talking about salmon and trout, but are there other species that we should be looking at?

In regard to the potential for growth in the industry, we had a presentation on the potential for hatcheries as a very viable and vibrant part of the industry. Do the witnesses see the potential of developing hatcheries that would support the industry?

Multi-trophic farms are being mentioned by the Marine Institute as the way forward. Could the witnesses advise on the potential pros and cons of these?

Do I sense a change of policy from IFI on the proposed Galway Bay project? I felt there was a stronger resistance to the Galway Bay fish farm in previous statements I have heard from IFI, but it seems from its statement today that if the Galway Bay project were to be started as a small-scale operation and monitored and expanded gradually, it would not be totally opposed to it. Previously, I sensed much greater opposition from IFI, based on some of the scientific data, towards the proposed mega fish farm in Galway Bay .

I thank the Chairman for allowing me to attend this meeting. I thank Dr. Gargan and Dr. Forde for their presentations. I apologise for being late, but I have gone through their opening statements as quickly as I could.

It seems that they are looking at the testimony from both sides. Many of the submissions we have heard, be it from IFI or from the Marine Institute, will quote different pieces of research that quite often collide. I have not got it in front of me, but I think the Marine Institute has quoted Jackson et al., and it would not be exactly what the witnesses have said in their submission. That makes it even more difficult for members of this committee to make a reasonable and balanced evaluation of what research is out there, particularly with respect to sea lice. We are trying to bear in mind also the value, particularly in rural peripheral areas, of both the angling industry and the aquaculture industry. Trying to get the interests of those industries aligned is a hugely problematic exercise and one in which the evidence of both the IFI, the Marine Institute and other stakeholders is very important.

I agree with the submission on the separation of licensing and regulation, which would seem to be fundamental to good practice. I suggest that the Department retain the licensing side and that the EPA or the Sea-Fisheries Protection Authority, SFPA, might have a role in the regulation of the industry.

I am pleased to note that they support the sustainable development of the aquaculture industry. They also mention the creation of an emergency fund to facilitate the clean up after storms, such as the storm in Bantry Bay that Deputy Ferris remembers as the worst in his lifetime. While that release of farmed fish was significant, it practically put the fish farm out of business as well. They do want to have their stock released inadvertently.

In my view, providing an emergency fund to deal with events after they happen does not make a whole pile of sense, particularly with respect to what happened in Bantry Bay. I submit that under the new Common Fisheries Policy those involved in aquaculture ventures or those who are considering them would get better grant aid for ensuring there are better controls, husbandry and more efficient management of those sites and to beef up controls under a regulatory regime. Instead of providing public money to assess the damage, we should provide funding to prevent future occurrences.

Sea lice occurs naturally. Have Dr. Forde and Dr. Gargan base figures on the natural occurrence of sea lice and the increased occurrences of sea lice in the vicinity of aquaculture ventures? The document states that in 2014, some 29% of sea lice inspections were above the treatment trigger level compared to 18% in 2013. However, it does not state how much higher the levels were over the treatment trigger levels. Were they significantly higher or were they just a couple of base points over the treatment trigger levels? Were there just one or two incidences of sea lice that were of major concern? If one looks at all the incidences together, one might get a picture, but if they are looked at individually, how is the regulatory regime enforced? I believe sea lice are reasonable easy to treat, but what is the view of the witnesses on that?

One of the problems we have is the significant increase in the seal population. Is there a report on the impact that an increased seal population has on wild salmon stocks? Have the representatives formed a view on what action should be taken?

I apologise to the witnesses for missing their presentation. I also apologise if my questions have been asked by other speakers already.

IFI favours the development of closed containment salmon farms, and that we should move to land-based closed containment. What role will it play in making that happen? Will the IFI have an input into making this happen? I would like to tease out what its role will be in that development?

The Pacific oysters, crassostrea gigas, in Lough Swilly have become invasive and the IFI states that provision should be made to remove the Pacific oysters from the Swilly. Does the IFI have an active role in making that happen or is it something that it aspires to happening?

In regard to aquaculture licensing of established wild mollusc fisheries that are causing concern, is the IFI proposal that these licences be withdrawn and replaced with licences in respect of areas that are not affected an aspiration or something that can be done?

Dr. Greg Forde

We will try to respond to members questions in the order they were asked, with questions in respect of which overlaps arise being responded to in the first instance.

On Deputy Ó Cuív's first question regarding importation of shellfish and oysters, this issue has been addressed by the new fish health regulations. There was a real problem when there was no regulation around the importation of oysters from other locations and the movement of oysters. The preservation of the few bays that are not suffering from binemia to the same extent as others must be tightly controlled. It would be great if we had a flat oyster that is tolerant of binemia and can still survive. What often happens is that just as the oysters reach marketable size, they open and die. A lot of this is regulated through the Marine Institute. IFI has a specific role around licensing for the harvest of the species. I do not see this issue being a big problem, provided all of the required controls are put in place and any seed imported comes from disease-free stock and so on. The big problem in Ireland was that product was being imported, left in one bay for a while and then moved and spread elsewhere. This no longer happens.

Deputy Ó Cuív's second question related to finfish and the re-siting of licences for farms. Dr. Gargan will elaborate further on this point later. Dr. Gargan and I referred in our opening submissions to problems with the siting of salmon aquaculture sites. Deputy Pringle asked about aquaculture licensing in areas where wild mollusc fisheries exist. IFI is in favour of all of these issues being unravelled as part of the new process. This is about sustainability of aquaculture operations and sustainability of wild fish. In both respects, we would prefer that the new licensing regime would enable identification of problem areas and the re-siting of operations to non-affected areas, such that people can continue to operate a site but in a place where it has less affect on the wild fishery. Dr. Gargan will respond now to some of the other questions asked.

Dr. Paddy Gargan

On Deputy Ó Cuív's point regarding the availability of information which suggests that finfish farming has damaged wild salmon stocks, most of the information we have suggests it definitely damages sea trout stocks because sea trout live in the sea close to the shore and in the estuaries. This information, which is based on experiments involving one batch of salmon going to sea being treated with a chemical to protect them against sea lice and another batch not being treated, points to serious impacts on salmon in particular years. Most of the research carried out in Ireland is based on the impact on sea trout. In regard to the point about Jackson et al, a number of studies have been carried out in Ireland and Norway on the treatment of hatchery fish going to sea, with one batch being treated and another batch not being treated. These fish are examined when they return the following year as adults to determine whether having gone through a salmon farming area they were impacted or not by the salmon farm. The evidence from all of those studies, including the Jackson study, shows that there is some impact, which in some years may be 10% or 20%. Dr. Jackson concluded that the impact was minor and that there was a 1% loss in marine survival.

We believe that, generally, only 5% of salmon return. If that is reduced to 4%, it equates to a 20% reduction. All of the studies have found varying degrees of impact, with the impact in some years being greater, which is understandable. Not all salmon smolts migrating to sea will face the same level of potential lice infestation, as farms may have their lice under control, there may only be smolts on the farm, or there may be a big freshwater influence in some years. All of the studies reviewed in the document to which we made reference indicate that, on average, the impact on salmon returning is between 12% and 29%. It may be lower in certain circumstances but it has been higher. Those studies show that salmon, as well as sea trout, need to be considered. There is a large amount of information to support this. In some areas, there is no impact because of the location of farms and the control of lice. However, this is not the case in all areas, particularly on the west coast.

Juvenile salmon are put into the bays in March each year. As these fish are quite small, they do not have sea lice, which means there will be good survival of salmon and sea trout that year. It is in the following year, when those fish have increased in size to approximately two or three kilos and lice are difficult to control, that a problem arises. Generally, the problem arises in the second year. This is the biggest issue that we believe needs to be addressed. As the fish in many of the bays are small in year one, it is possible to predict that we will not have a problem that year. However, the following year, if the lice are not brought under control at the time when the wild fish are going to sea in late March, April and May, there will be a problem. The challenge is to ensure that the bigger fish do not catch lice. Quite often, fish are harvested over the May-June period, at which time they may not have been treated for lice and, therefore, it is difficult to control the lice.

The other issue is resistance to the chemical used to treat sea lice. There are what is known as treatment failures, which is when fish are treated but it does not have the desired effect.

Dr. Greg Forde

Perhaps I could respond at this stage to some of the other questions posed by Deputy Ó Cuív. As set out in our submission, we agree on the need for a split of the licensing and regulatory functions. As most people operate their farms properly, the industry must be appropriately policed, such that there is not a perception that the industry is not appropriately regulated. Penalties should be incremental, such that people who continuously breach lice levels are faced with higher penalties.

On the legal question, whether a person operating under a lapsed licence can be found to be in breach of licence conditions is an interesting question and a matter for the courts. On the question of whether the proposal for the Galway Bay farm is too high, as stated by Dr. Gargan, IFI wants to see every site assessed for what it can sustainably produce. Without assessments, it will not be possible to identify what level of farming can take place at a particular site. From my experience in aquaculture - I am sure the committee will be aware of my involvement in the area in the past - I know that when production is ramped up, husbandry issues increase much more quickly. In other words, one ends up with problems sooner. Smaller farms had less intense problems.

I will ask Dr. Gargan to address the question on the cessation of drift netting.

Dr. Paddy Gargan

On drift netting, previously, up to 50% of returning salmon were taken before they reached their home rivers. The fact that drift netting ceased in 2006 means a lot more fish will have returned. The Deputy asked whether there were other factors involved.

My question was whether we have counters on the rivers that show that the number of fish returning is growing year on year.

Dr. Paddy Gargan

We have 32 counters operating on salmon rivers around the country and there has been a gradual decline since 2007 across all those counters. It is not a dramatic or steep decline but a gradual decline.

It is a decline.

Dr. Paddy Gargan

Absolutely. The biggest issue is marine survival. In the 1980s, when salmon went to sea, approximately 15% of them returned. In recent years, approximately 5% return. Marine survival is approximately a third of what it was 20 years ago. Generally, salmon smolts are being produced in rivers, as they always were. There are no major high seas fisheries and there is small subsistence fishery in Greenland for food. There is no fishery in the Faroe Islands like there used to be. There is practically no exploitation of salmon at sea. The issue of them surviving is down to what happens in the sea and marine survival. The rate has been declining since 2007 but there is some indication this year that it has started to increase again. It is a bit early to say as it is still in the middle of the season but there are indications that this year may be better than recent years.

To put this in perspective, if we were still drift netting, the position would be much worse as up to half of the fish that were returning would not be reaching rivers. The policy in place for ensuring that enough salmon get to spawn, with rivers close or only open for "catch and release" if there are not enough spawners, will safeguard vulnerable stocks.

I wish to confirm those comments. I am not making a case for or against drift netting. The witness is saying that despite the fact we have banned drift netting, which is seen to be the primary cause of declining fish stocks, the actual returns are reducing.

Dr. Paddy Gargan

Yes.

There is no exploitation at sea of salmon stocks or fisheries of which the witness is aware but what about the krill fishery in the North Atlantic? I have heard stories of hundreds of thousands of smolts being caught in krill fisheries by Russian fleets. Has that been examined?

Dr. Paddy Gargan

There is an international organisation called the North Atlantic Salmon Conservation Organization, NASCO, of which Ireland, through the EU, is a member. We attend the annual meetings and there is much discussion about problems at sea. There was a major research project over four years called the SALSEA project. Ireland was involved with that and it considered problems in the sea with regard to marine survival. There was some evidence that large mackerel and herring fisheries were catching juvenile salmon as a by-catch. That is being investigated. The SALSEA programme was not able to pinpoint the exact reason salmon are not surviving at sea to the extent that they were 25 years ago. Fish were captured at sea by trawling and Marine Institute vessels were involved with that. It is difficult to take in the entire ecosystem, as the salmon go to Greenland, the Faroes and the north Norwegian Sea. There are changes in the oceans and sea temperatures. With all the dynamics in the sea, it is very difficult to pinpoint exactly what is causing reduced marine survival.

Dr. Greg Forde

Deputy Ferris referred to size, location and proximity to rivers. Our clear preference is that sites deemed to be too close to existing wild fisheries for salmon and sea trout - wild salmonid fisheries - should be relocated to a more suitable location further from an important river. The Deputy mentioned deeper water as possibly being more practicable but there are issues relating to exposure. The technology has moved on considerably in the past number of years and there are more sites being developed in deeper water. There are significant wave heights and that is why the site in Galway Bay is sited inside the Aran Islands. Another one is proposed off Mayo in the lee of an island. Dr. Gargan would possibly have experience of international developments, such as deeper water sites in Norway.

Dr. Paddy Gargan

In Ireland we do not have what one might call a very deep site operating now. With the Galway Bay submission, we stated that the scale of the project was too large and we have not changed our view or policy since. We argued that it should start small and there was not sufficient information in the environment impact statement regarding the migration route of salmon. The impact of sea lice and potential for escape of 6 million or 8 million fish to local rivers with just a few hundred fish had not been adequately addressed. Our main point was that any proposal should start small and be monitored, with any environmental issues addressed. Only after it was shown that the process was sustainable should there have been incremental increases. That is what we noted in our observations and what we are saying today.

The guiding principles in the sustainability document point to the fact that there must be environmental sustainability and monitoring is key. Only after monitoring has shown no impact should there be progression. We still make the point that the initial amount referenced of 5,000 tonnes is too large, as most Irish aquaculture is 1,000 tonnes, more or less. To start with 5,000 tonnes as a trial is too large until we know if it is sustainable.

Could a figure be put on that?

Dr. Paddy Gargan

It should not be any larger than the general size of existing farms around the country.

What about closed containment?

Dr. Paddy Gargan

That issue arose and there is much work ongoing in Norway. There is a new institute in Norway that has been established with funding from the Norwegian Government to consider specifically how sustainable aquaculture closed containment can be done in an economically viable way. There is quite a bit of information coming and the institute has dedicated expertise solely examining how closed containment can be pursued. Norway would now be seen as the industry leader. There is also economically viable closed containment operating in Canada, with others beginning a number of years of production in Scotland. Norway is certainly considering closed containment as another means of developing the industry.

Dr. Greg Forde

Senator Ó Clochartaigh asked whether the two industries could work together. The two industries exist and they must live and work together. This is about a sustainable aquaculture industry and sustainable wild sea trout and salmon fisheries, along with rural communities, as mentioned by Deputy Ó Cuív. These must absolutely work together. One should not be given undue preference over the other, and we take that point on board from a wild fisheries perspective.

The issue of segregation of powers was also raised and we have come to that. There is also the matter of closed containment and cost. This plan includes financial grant aid systems, which should give greater financial reward in the percentage of funding in order to try to find a workable solution. Members also mentioned hatcheries and I would have to step away from my specific remit in addressing this. That issue exists for lobsters in particular but that is outside our specific remit. We cover molluscs in the sea and they are crustaceans. I have seen it in other countries but it would be outside my remit to favour that.

Dr. Paddy Gargan

With regard to multitrophic aquaculture, our remit is really just molluscs, salmon and sea trout. The Marine Institute would probably be best in commenting on that issue.

Perhaps the question should have been if that would have any detrimental impact on the wild stocks? Would it live equally comfortably with them?

Dr. Greg Forde

Obviously, Inland Fisheries Ireland has issues with invasive species and bringing in other marine algal species to farm them. It is important to ensure all the appropriate controls are in place to avoid the spread of such species to places where they are not desired. From a scientific point of view, it would be better to develop these projects in a way that is not monocultural rather than to have monoculture.

We were asked whether Inland Fisheries Ireland had changed its view on the proposal for Galway Bay.

Dr. Paddy Gargan

I addressed that issue in my previous comments.

Dr. Gargan's position is that the view of Inland Fisheries Ireland has not changed.

Dr. Paddy Gargan

We have always stated that we are in favour of the proposed project being sustainable but we were concerned that, given the size of the project for which an application has been made, insufficient detail has been provided and no assessment has been done on the potential impacts on rivers in Galway Bay, including the migration route for salmon leaving Lough Corrib. The lough is a major fishery and special area of conservation under the habitats directive. We are concerned to have more information made available. We would like the project to start at a very small scale and prove its sustainability before being extended incrementally.

The witnesses have taken a clear position on the proposed aquaculture plant. It is IFI's view that where licences are already in place, the projects could be located in better sites but notwithstanding that, they should not be put out of business. Is that a fair summary of the position?

Dr. Greg Forde

They exist.

That is what I am saying. Is it IFI's position that they could be sited in better locations and so on?

Dr. Greg Forde

We obviously need a sustainable industry.

Is it desirable to have as a policy objective an increase in salmon production to either Scottish or Norwegian levels or should the current level be maintained? Would it be preferable not to prioritise the industry for significant expansion? This seems to be the major policy issue confronting us all. As a corollary to this, given IFI's international contacts and experience, do the witnesses believe that most of the fish farming in Scotland and Norway, with their significant at-sea industries, will have moved from open sea cages to land-based sites 20 or 30 years from now? This is where the major policy agenda lies. Is this where we should put our money? What will be the position in 20 or 30 years? I am interested in hearing the witnesses' views on that issue.

Dr. Paddy Gargan

I do not know whether the industry in Norway, for example, will all be land-based several decades from now but I presume there will still be some farming at sea. From our point of view, we have seen impacts over the past 25 years, even in the small-scale industry in this country. We are keen to ensure that any future operations are sustainable, meaning they should start small and prove themselves to be sustainable and not to have an impact. However, we also see an opportunity for land-based projects because there will be no effluent, escapes or, I hope, sea lice and the projects could be very sustainable. We argue that if the industry in this country is looking forward and given that production here is relatively small, perhaps the policy should be to focus more on land-based industry and have some initiatives to investigate the development of a fish farming on land.

From the information available to Inland Fisheries Ireland, does it believe that the reason for the significant impetus in Norway to explore the possibility of land-based fish farming has been the damage done by fish farms being located off-shore?

Dr. Paddy Gargan

Since 2011, the Institute of Marine Research in Norway has been investigating the potential impact of escapes and sea lice on local salmon and sea trout stocks. It has developed a risk-based assessment and is providing figures every year on the likely mortality of wild stocks from existing farms. In a significant number of locations, the risk of mortality to local stocks is high. This allows managers to predict where the impact will be and future plan the industry. Norway is now running with this risk-based assessment and has put in what are known as national salmon fjords in areas where there is a serious problem. Restrictions have been placed on aquaculture and all fish farms must co-ordinate and treat simultaneously. Norway is taking the issue seriously because the official state agencies acknowledge aquaculture has had impacts. It is a very large industry and the country is trying to plan using a risk-based strategy.

What are the fish mortality rates in Norway compared to Ireland?

Dr. Paddy Gargan

According to the latest report, of 109 stations investigated along the Norwegian coast for salmon lice infestations, 27 indicated moderate to high likelihood of mortality of salmon, while 67 stations indicated moderate to high likelihood of mortality of sea trout. Norway is adopting a risk-based approach and advising management on what are the likely impacts. The conclusion of this review paper was that this risk assessment has provided the Norwegian Government with the basis on which to take decisions for future development of the Norwegian aquaculture industry.

In what way does that compare with Scotland? Does Dr. Gargan have figures on the position in Scotland?

Dr. Paddy Gargan

I do not believe the authorities in Scotland undertake the same risk assessment as the Norwegian authorities do. To date, we have not carried out the same assessment here.

As the countries with the most developed industries, it would be wise to keep an eye on developments in Norway and Scotland. They are at a much more advanced stage than we are and we should learn from their successes and mistakes. I thank Dr. Forde and Dr. Gargan for their attendance.

Dr. Greg Forde

We did not answer some questions.

I beg the witnesses' pardon.

Dr. Greg Forde

I am conscious that we are under a little time pressure.

I was asked whether better grant aid should be provided for better equipment. The industry should be required to ensure it uses the best available equipment. The idea of having a fund to recover costs is that, as with all of these types of issues, when something goes wrong in a private industry, the State ends up carrying the can. Perhaps the fund could be a portion of the licence fee or something like that, although the licence fees are not substantial.

We are aware that there were significant concerns that the 200,000 fish which escaped in Bantry Bay would end up in local rivers. As to whether we were in a position to go out and ensure they did not run the rivers, we were not in a position to do so. Luckily for the time of the life cycle, the fish probably dispersed in the sea or were crushed by the nets during the catastrophic collapse of the cages. We got out of jail, as it were, but who is to say it will not happen again? For many years, farmed fish have been turning up in the wild, which is not good from a genetic or stock resilience point of view.

Would Inland Fisheries Ireland support measures to provide the industry with grant aid under the new Common Fisheries Policy?

Dr. Greg Forde

The whole proposal has a grant aid element to it. The industry is seeking elements of grant aid for different aspects of the development of the aquaculture operational programme.

I asked a question on the removal of gigas oysters from Lough Swilly.

Dr. Greg Forde

Our view is that these oysters were brought in to become a farmed stock but became feral and are now taking over other sites where normal oysters should be located. There should be a mechanism for ensuring that this species, which has become invasive, is removed. Other witnesses who appeared before the joint committee last week hold a similar view to us on that matter.

It is complicated. Fishermen were collecting them but the oysters that were too large to be marketable were disposed of over the side of the vessel. Instead they should have been incentivised to bring the wrong sized oysters ashore to ensure the wild fish could feed. The food source is wild. They are filter feeders so they have to be able to feed from the water column. It is of no use to feed an invasive species. Let us be honest, the fishermen made significant money from the marketable sized Crassostrea gigas that were harvested at the time.

Is it the aspiration of IFI that they should be removed and can it make that happen?

Dr. Greg Forde

The IFI is the licensing authority. For a person to be able to harvest an oyster in the wild, he or she needs an oyster dredge licence. All we do is license the dredge. Separate agencies are responsible for the vessel in which the dredge is on and for the health of the oyster that is brought to market.

Is it an aspiration rather than a policy?

Dr. Greg Forde

Yes, but we will certainly support it.

I asked two questions, the first of which was on the percentage changes of the treatment trigger levels.

Dr. Greg Forde

The percentage of lice on wild fish is different in aquaculture zones from non-aquaculture zones.

Dr. Paddy Gargan

Deputy Harrington asked if the lice level on wild fish was different.

I was asking about breaches of the trigger levels. A breach is a breach.

Dr. Paddy Gargan

I understand now. We monitor the level of adult females with sea lice. The treatment trigger is lower in the spring when wild fish are going to sea. On an average female with egg strings, the range is from 0.3 to 0.5 as opposed to 2.0 for the rest of the year. In the critical period in the spring, there were farms that were ten times over the treatment trigger. The issue we have is that they may have been breaching the trigger for four or five months in a row. The sanctions that are available were not being brought in.

There are particular locations with repeat offenders who are not maintaining lice levels below the trigger in the protocol, which is a condition of the licence. When it is breached, we do not think the sanctions are sufficiently strenuous.

Would Dr. Gargan be broadly in favour of the levels at which the treatment trigger levels are set?

Dr. Paddy Gargan

The trigger treatment levels were picked but have no relevance to wild fish. We would argue that in some particular locations, even if the trigger level of lice on the farm was maintained, one would still have a problem with wild fish.

Fish farms, from 500 tonnes to 2,000 tonnes, only need to maintain the lice level at a certain trigger. There is no relevance to the number of fish on the farm. We would argue that a large farm has more potential to produce lice even at the trigger level than a small farm and it has more potential to damage wild stocks. We have been calling for more than a decade that the level should apply to the whole bay and should not be breached, so that fish farming is not impacting on the local wild salmon and sea trout in the bay.

I am sorry to labour this point but sea lice occurs naturally. I am trying to get a handle on the issue. If the level of sea lice could be kept as close to the natural level, one would be doing very well. Using the natural level as a base, how far off that level are the treatment trigger levels?

Dr. Paddy Gargan

It is slightly complicated. We have done many studies over the years to show that sea trout will have an average of three to five sea lice when there is no salmon farming nearly. In salmon farming areas, they will have 30 or 40 sea lice, or perhaps ten times more. Those levels are not comparable to the level one wants to keep on the salmon farm because there are hundreds of thousands of fish on the farm. At present, ensuring that each fish on the farm has only half of an adult female lice cannot be compared to a level that is normal on a sea trout because of the number of sea trout eggs that are produced from the farm that have the potential to get on to wild salmon and sea trout in the locality.

This is back to the risk based approach that the Norwegians use. They monitor their salmon and sea trout.

If the number of lice per gram is above a certain threshold, there is a high risk of mortality among wild fish. They advise that if the lice level on the sea trout and salmon they monitor is at a certain level they will be happy. If it is at a certain low threshold there is no impact, but the higher it gets, the more potential there is for mortality among wild fish. That is the risk-based approach they are taking in Norway.

Rather than set a trigger level regardless of the size of the fish farm, it would be better to ensure the level set is one at which there is no impact on the local wild stock.

I mentioned the seal population as well. It is anecdotal evidence that I am receiving, but the population does appear to be growing. They eat salmon, wild and farmed - whatever they can get their teeth into.

Dr. Paddy Gargan

IFI was involved with University College Cork in a study of predation by seals. The general conclusion were that in rivers where there is a healthy population, seal predation is not of great concern. It is where stocks are small that there is a problem. One of the study areas was the River Slaney, where there are valuable multi-sea-winter salmon - that is, spring fish - coming in. The conclusion was that if the population is low and there are problems with salmon-----

The seals will go to where the population is higher.

Dr. Paddy Gargan

There are certain haul-out sites and there are certain estuaries where the seals are present all year round, although they do migrate. The conclusion was that seals will have more potential impact on vulnerable salmon stocks. The other site we investigated was the River Moy, and because of the large salmon population, the same level of seal predation would not have the same impact on the salmon population on the Moy as it might on the Slaney.

This study was undertaken to see what had happened since drift netting ceased and whether there had been an increase in seal predation on inshore stocks. It is difficult to arrive at definitive answers, but the conclusion was that the risk was much greater where the salmon population is more vulnerable.

We will have to wrap up.

If you look at the increase in the seal population-----

The seal population is probably worth looking at as a study in itself. There is probably a knock-on effect if you look at it from the other direction.

We will have to wrap this up, as there are four more groups coming in. I thank Dr. Forde and Dr. Gargan for attending the meeting and making their presentation. This will feed into our submission, and I am sure the IFI is making its own submission to the consultation process. We have a draft report to which we will add this final contribution. It is fair to say the joint committee has taken the views of a cross-section of all stakeholders involved in aquaculture, inshore and inland fishing, considering the issue from the perspective of both the industry and statutory agencies such as the IFI. On that basis, we hope our submission will be well balanced and informed.

That concludes this session. I must suspend the sitting to allow a significant number of witnesses to take their seats.

Sitting suspended at 3.50 p.m. and resumed at 3.55 p.m.