SALMON HOLDS A special place in Irish heritage, with eating the salmon of knowledge said to have gifted Fionn the wisdom of the world.
Today, however, our wild Atlantic salmon are under threat with less than 10% of wild young adult salmon – known as smolts – that go to sea from Irish rivers estimated to survive.
While there are numerous impacts on the species further out at sea, such as overfishing and climate change, a chorus of campaign groups and environmental NGOs have voiced concern about another human impact closer to our shores – salmon farms dotted along our Atlantic coast.
Over the past two months, Noteworthy examined the potential environmental impacts of salmon farming, speaking with scientists, biodiversity experts and environmental groups, as well as combing through hundreds of pages of research and scientific papers.
We also sent over 20 Access to Information on the Environment (AIE) and Freedom of Information (FOI) requests to various State bodies to find out what authorities are doing to ensure that rules and regulations are being followed to protect wild species.
Our findings show that, despite having a rigorous control and regulatory system in place to limit environmental impacts on paper, concerns remain over control of sea lice on farms, lack of data on farm mortalities, no baseline monitoring data on farm escapes, and a lack of control of fishing of sensitive wild wrasse populations for use in the industry.
We can reveal:
In part one, out yesterday, we revealed that the National Parks and Wildlife Service has granted licences to salmon farms to cull protected seals along the Atlantic coast.
In part three, we examine the State’s licensing regime that has allowed salmon farms to operate for over a decade with expired licences, as well as examining overstocking concerns at farms owned by the world’s largest salmon farm company.
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With a growing global population, the UN Food and Agriculture Organization (FAO) has stressed the role of fish farming, or aquaculture, as an increasingly important source of protein.
Within aquaculture, one of the most dominant sectors is Atlantic salmon farming, pioneered in the 1970s in Norway. Global production ramped up rapidly over the following decades, tripling between 2000 and 2020 to hit almost 2.7 million tonnes.
While production here pales in comparison to our Scandinavian neighbour – we brought in 13,400 tonnes last year – salmon farming is our largest aquaculture sector, worth €127 million.
Salmon are kept in large circular pens in sheltered bays along the west coast in counties Cork, Donegal, Kerry, Galway, and Mayo, with several hatcheries to grow juvenile salmon also located inland at freshwater facilities.
A tourist viewing the picturesque landscape of our Atlantic coast would quickly skip over the sight of the pens, with little to see above water, apart from a few floating wooden walkways and the netted rims of the pens holding the salmon. It is below the surface that the real action happens.
As the industry has grown over the decades, a number of stringent licensing and regulatory requirements have been placed on aquaculture for environmental monitoring, fish health, disease control and overall management of the farms.
Local groups and environmental groups, however, have raised significant concerns over the monitoring of the industry, as well as concerns over diseases and farm escapes.
Numerous studies in recent years have examined some of the key concerns raised, with sea lice outbreaks identified as a key concern for both wild salmon and sea trout stocks.
To view a searchable version of this table, click here.
Drastic decline in sea trout numbers
Sea lice are saltwater crustaceans, smaller than a fingernail but they pack a punch, especially to juvenile salmon and sea trout when they go to sea. Exposure to sea lice at this stage can cause large scale mortality events and reduce population sizes.
This occurred among sea trout between 1989 and 1991 as heavily sea lice-infested wild sea trout in poor physical condition were recorded for the first time in areas with salmon farming. Farms are now confirmed as a significant factor in observed stock collapses in western Ireland in the late 1980s.
John Murphy, a keen angler and founder of Salmon Watch Ireland, a campaign group focused on conserving Atlantic salmon numbers, said that the impact of the then-fledgling salmon industry was the catalyst for him to start examining the sector.
“What was happening is the young sea trout were going to sea in aquaculture areas, which was relatively new at the time, and were returning within a number of weeks covered in sea lice and dying of disease in the riverbeds,” he said.
Murphy is equally concerned about the impact on wild salmon, as are authorities. In a submission to the North Atlantic Salmon Conservation Organization (NASCO), the State outlined how sea lice are a key threat to wild salmon that “could have a significant effect for stocks”.
As the salmon are anadromous – spending part of their lives in both freshwater and the marine environment – they use the bays containing salmon farms.
There has been dispute in recent years about the impact on wild populations, with the Marine Institute confident its studies show that, “while sea lice-induced mortality on outwardly migrating smolts can be significant, it is a minor and irregular component”.
Nevertheless, stringent controls are in place to limit any potential impact of lice on salmon farms, with a nationwide monitoring programme introduced in 1993. Under the Sea Lice Monitoring and Control protocol introduced in 2000, 14 annual inspections are now carried out by the Marine Institute, with data publicly available for all farms checked.
Since a management strategy to improve pest control on Irish salmon farms was introduced in 2008, the Marine Institute told us that there has been a “steady reduction in the infestation levels”.
It said that fewer than 10% of inspections now result in the agency sending a notice to treat (NTT) to a farm to take action to reduce their sea lice levels. This compares to 25% in 2008. In 2019, for example, from 210 inspections on 24 sites, 9% showed elevated lice levels.
https://public.flourish.studio/visualisation/6384253/
To view a searchable version of this table, click here.
Trigger warning
A Noteworthy analysis of sea lice data, however, shows that there were still over 40 cases of elevated levels of sea lice from the start of 2018 to March 2021.
The Marine Institute issued 32 NTTs in relation to these cases, according to data that it released to Noteworthy, including repeated notices for several sites in Kilkieran Bay in Co Galway, as well as Donegal Bay and Mulroy Bay in Co Donegal.
The Marine Institute said that “the issuing of a single NTT is an example of the system in action and recognises the ongoing efforts of the industry to control sea lice levels”.
The Marine Institute said that “peak numbers recorded in recent years are much lower than peak numbers recorded 10 – 15 years ago”. This, it said, reflects the “better proactive management observed on farms”.
John Murphy of Salmon Watch Ireland raised concerns about the number of fish tested – 30 fish in a standard cage and 30 fish in a random cage – something that he argued is not robust enough on large farms that can hold hundreds of thousands of fish.
Murphy also criticised the fact that the trigger levels for treatment does not take account of the number of salmon on an individual farm at the time of the inspection.
“You don’t have to be a genius to understand that a farm six times the size will produce six times the amount of sea lice,” he said. The Marine Institute said that the fixed pen “provides information on sea lice levels over the production cycle” while the random pen “ensures that sea lice management measures are performed evenly over the entire site”.
Similar concerns about the trigger levels were raised to Noteworthy by Paddy Gargan, an Inland Fisheries Ireland (IFI) scientist who has spent decades researching the impact of sea lice on wild salmon and sea trout.
Gargan said the IFI has repeatedly argued the trigger level has “no relationship” with the number of fish in the farm or the number of farms in a bay. “We have asked that there should be a total bay cap on the lice number rather than just an arbitrary protocol level regardless of the stocking density.”
The State somewhat recognised this issue in a recent submission to NASCO, the North Atlantic Salmon Conservation Organization, stating that we have a “broad scale policy” with national rather than site specific lice trigger treatment targets.
This, it said, “may not ensure consistency with the international goals of ensuring 100% of farms have effective sea lice management”.
A NASCO evaluation report in January 2021 gave Ireland an unsatisfactory rating, in large part due to concerns over our sea lice policy. Despite NASCO’s rating, the State’s latest report sent to the organisation in April 2021 states that it has not revised its plan.
In a statement, the Marine Institute said that the system is “robust” and “one of few monitoring programmes carried out independently from the industry”.
It said that the management strategy has been “successful in embedding the principles of Single Bay Management” where farms in the same bay “openly communicate and coordinate their stocking and treatment plans”.
The Department for the Marine said that our sea lice monitoring and control programme has been acknowledged by the EU Commission as “representing best practice”.
Long-term lice impact
Gargan’s recent research has shown that, despite the measures put in place over the years, there is still a significant impact on wild salmon and trout populations.
Research published last year, for example, shows that salmon returns on five rivers on the West coast between 1990 and 2019 dropped by between 19% and 46% in years following high lice levels on nearby salmon farms.
The findings build on a 2017 paper by Gargan based on 30 years of data from the Erriff river – a designated EU protected area for Atlantic salmon – that flows into Killary Harbour in Co Mayo. The study showed the returning run of salmon reduced by about 50% following years when lice levels at salmon farms in the area were high.
A further study in late 2020 found that sea trout showed “reduced growth” when their sea entry in the spring coincided with periods of nearby salmon-farming activity.
The paper, Gargan said, clearly showed that salmon farm impacts led to much fewer eggs being deposited by sea trout and “the population structure [being] completely different than before salmon farming”.
The scientific article, he said, is “probably the classic paper in terms of impact” as the research team had data from the Erriff prior to the establishment of salmon farms in Killary Harbour and for the following 20 years that “clearly showed the impact”.
This was particularly true in the spring period when salmon farm harvesting coincides with the passage of young wild salmon and sea trout into the marine environment.
“The key to this whole problem is avoiding high lice levels during and after smolts go to sea and we’ve been emphasising that as the key strategy,” Gargan said, adding that this has not happened enough in his opinion.
In a report to NASCO in November 2019, for example, the State said that egg-bearing lice levels were above trigger treatment levels in 19% of inspections during the critical spring period in 2017.
Wild Wrasse West
While authorised medicines were traditionally used to treat lice, today, farms are increasingly turning to a range of non-medicinal methods. These include freshwater bathing, mechanical control using warm water, and an increasingly popular method – cleaner fish that eat the lice off the salmon.
Two species are used here: lumpfish and wrasse. While lumpfish are cultivated, wrasse are taken from the wild – and in increasing numbers. Marine Institute data released to Noteworthy shows that almost two million wild wrasse were transferred to salmon farms between 2015 and 2020.
In 2018 and 2019 alone, the Marine Institute approved 68 movements of wrasse, totalling over 730,000 fish, that it said “clearly demonstrate[s] an increasing use of cleaner fish to control sea lice”.
The increasing use of the species has brought concern, however, due to their important role in reef habitats – most bays where wrasse are caught are in protected nature areas – and the impact fishing can have on the species.
This issue has repeatedly been raised by Galway Bay Against Salmon Cages (GBASC) – a campaign group against salmon farming on environmental grounds – that is concerned at State support for the catching of wrasse.
In 2016 and 2017, for example, An Bord Iascaigh Mhara (BIM) – the agency charged with supporting the development of the seafood industry – supplied almost 400 wrasse pots, pens and fedbags worth just under €18,000 to salmon farms free of charge as part of an industry trial, according to details released to GBASC under AIE Regulations and seen by Noteworthy.
According to the group’s chairperson, Billy Smyth, a keen angler involved in campaigns opposing salmon farming since the late 1980s, GBASC is “worried” about large numbers of wild wrasse being taken out of bays “for the simple reason that wild wrasse are very slow maturing and it takes them years to actually breed”.
“If you keep taking out the breeding population of those wrasse every year, you’re possibly causing an extinction vortex in years to come where there’ll be no more wild wrasse left for breeding,” he said, pointing to the lack of any assessments to date on wrasse populations along the west coast.
https://public.flourish.studio/visualisation/6385024/
To view an interactive version of this chart, click here.
State share concerns
These concerns were recognised by the Marine Institute in a note prepared for its board in November 2020 that said there “undoubtedly remain legitimate welfare concerns regarding the use of cleaner fish on salmon farms”. These concerns, it said, come on top of “environmental concerns with regards to the use of wild caught fish”.
Department of the Marine (DAFM) notes from a January 2021 meeting with the Irish Farmers’ Association and the Marine Institute also state that wrasse are “biologically vulnerable to overfishing” and that there are “concerns in relation to overexploitation”.
The notes show that the Department identified a “need to be able to assess the risk of the fishery to both the wrasse and the reef habitat”. Similar recommendations were made in 1996 in an NUI Galway study on intensive wrasse fishing to supply salmon farms.
“If exploitation of wild stocks continues, the development of a fishery management strategy is required in order to prevent the over-exploitation of wrasse stocks in areas close to salmon farms, and to ensure that sufficient standing stocks are maintained,” the study recommended.
However, records released from several State bodies show that we know little more now than we did in the mid-1990s. The DAFM meeting notes, for example, state that the only real data the Marine Institute holds are the movement orders and that “catch data is limited and data gaps need to be addressed”.
This lack of data, it said, “makes it difficult to determine the ecological damage, if any, caused by the fishery to Natura [EU protected nature] sites”.
Lack of data on wrasse catch
One problem stems from the fact that wrasse are generally caught by smaller inshore vessels not required to record catches in an EU logbook. One way to potentially get around this issue is through details on the fish buyers register that lists all transactions of fish bought directly from vessels.
This applies to salmon farms, according to a Fisheries Information Notice (FIN) issued by the Sea Fisheries Protection Authority (SFPA) on 9 November 2018. “Salmon farm operators who buy live fish (wrasse or other similar species) for use as ‘cleaner fish’ in their processes are required to register as a fish buyer before purchasing such fish and then only from legally registered fishing vessels,” it said.
The problem was, however, that no salmon farms were registered, as indicated in a response to a Parliamentary Question posed by Deputy Noel Grealish on 6 November 2018.
Internal SFPA emails released to Noteworthy show that the questions posed by Grealish played a role in the decision to issue the FIN.
An internal email chain on 7 November 2018, for example, outlined the potential need for “a compliance push” that lead to the drafting of the FIN on wrasse sales to salmon farms.
In a previous internal email chain on 31 October, one staff member working on the request stated in plain terms that there are “relatively simple” answers to Deputy Grealish’s question.
“Yes, they need to be registered, in our view, and should register each of their purchases. No, none of them are registered,” they said.
SFPA left in the dark
It is also apparent from internal records released to us that the SFPA was not aware of the data held by the Marine Institute on wrasse movements to salmon farms at the time.
In July 2019, for example, Galway Bay Against Salmon Cages made a complaint to the fisheries authority asking it to investigate the use of wild wrasse on salmon farms.
In further correspondence with the SFPA in September 2019, the group sent a copy of data released to it by the Marine Institute via an AIE request that showed over 1.5 million wild wrasse were moved onto salmon farms since 2015.
This appears to have spurred the SFPA into action, according to the internal records released to Noteworthy, as on 30 October 2019, the agency’s Director of Enforcement, Gene O’Keeffe, informed its legal team that “we will need to follow up with a significant investigation with regard to sales system registration and possibly operator licencing”.
An email was then sent to all SFPA senior port officers on 11 November 2019 with the Marine Institute data that the email said “indicates the enormity of the numbers of fish that [are] being ‘sold’ but for which no traceability by way of documents [sic] first sale are available”.
By early November 2019, the SFPA had “opened an investigation on undocumented fish being exported in Galway”.
Noteworthy asked the SFPA for an overview of the findings of both its wider investigation and in Galway but the agency did not provide details. Instead, it said that it has engaged with key stakeholders such as the Irish Salmon Producers Group to “encourage fish farming members to sign up as fish buyers for the purposes of verifying purchases of wrasse”.
Mowi – Ireland’s largest salmon farm operator – is currently the sole registered buyer from the industry but only since May 2020, according to the SFPA.
Mowi is responsible for around 80% of Ireland’s salmon production and the majority of wrasse movements onto farms went to company sites between 2015 and 2020. This includes movement of almost 1.5 million wrasse prior to its registration in May 2020.
Mowi did not respond to specific questions from Noteworthy as to why it did not register earlier. Instead, it said that the company has “made incredible strides” in the development of novel biological sea lice control methods such as with the use of cleaner fish.
“Our greatest resource is obviously the environment – which [we] have depended on for our continued success for more than 41 years,” a spokesperson for the company said.
In a statement, the SFPA said that, when it became apparent this year that only one significant farm operator had started to input sales notes, “further efforts have been made by the SFPA to ensure compliance”. It said that a number of farms are now in the process of registering.
It said it has also dropped plans for a logbook system in favour of “increased direct communication” with vessels catching wrasse and those purchasing it, as well as “physical inspections which will provide the data necessary for the effective regulatory control”.
Mortality and disease concerns
Another area where conservation groups are concerned is the availability of data related to diseases and mortalities on farms.
A recent report published by the Marine Institute on recorded diseases by its Fish Health Unit in 2018 and 2019 was the first public report on the unit’s activities, for example.
While salmon farms are deemed as “high-risk sites” and inspected annually, the report states that there was a high health status in 2018 and 2019 with no evidence of any EU listed diseases.
There is no requirement for farms, however, to report mortalities from other causes. This was outlined by the Marine Institute in a reply to an AIE request from GBASC in November 2020 for any reports of farmed salmon mortalities in 2020.
It emphasised that there is “no direct regulatory requirement” under EU law to report mortalities from causes not associated with a specific list of notifiable diseases.
It said that mortality reports for other diseases are provided “through a voluntary reporting scheme” and provided details on these cases.
Billy Smyth of GBASC, however, said this means some diseases “endemic in Irish salmon farms” may not be notified to the authorities, such as cardiomyopathy disease, pancreas disease and amoebic gill disease, that can have a big impact on salmon populations.
“They are highly contagious fish diseases and they should be notifiable diseases because they’re causing serious mortalities,” he said.
https://public.flourish.studio/visualisation/6387107/
To view a searchable version of this table, click here.
Voluntary reporting of mortalities
Farms have reported large mortality events, as shown in the Marine Institute report, which outlined nine mortality events in 2018 and 20 in 2019.
In February 2019, the Marine Institute was also informed of mortalities during the transfer of juvenile salmon from a hatchery to a marine farm. An estimated 60,000 of the 208,000 fish moved died during transport.
Data released to Noteworthy also shows further mortality events occurred in 2020, largely attributed to phytoplankton blooms and jellyfish.
In some cases, these non-infectious causes co-occurred with non-notifiable diseases such as cardiomyopathy syndrome (CMS). CMS is a severe cardiac disease affecting Atlantic salmon, first found in farmed salmon in Ireland in the early 2010s.
In one case at a Mowi farm in Inver Bay in Co Donegal, 61% of the stock died as a result of phytoplankton blooms and jellyfish, soon followed by a “complete loss of the site within two weeks” of the start of another bloom, according to Marine Institute records.
A few cases also involved pancreatic disease (PD), a significant infectious disease affecting salmon farming since the mid-1980s.
An additional case was identified in Department of the Marine inspection reports that shows over 300,000 unhealthy fish affected by furunculosis were culled at a farm growing fish on a contract basis for Mowi in the autumn of 2020.
Furunculosis is a highly contagious disease caused by a pathogenic bacteria that can cause boils, lesions, haemorrhages and sudden death.
The number of salmon that died in the cases released by the Marine Institute is unknown, however, as it only released the percentage of fish that died from the total amount stocked at the time, details of which were not provided.
Farm escapes on the agenda
Linked to the issue of farm disease and parasites, sea lice in particular, is concern over the possibility of escapes from farms that can pose threats to the genetic integrity of wild stocks.
While the number of cases here are lower than our European neighbours, largely in part due to the small size of our industry, there have been some large escapes in recent years.
In its report to NASCO in 2019, for example, the state said that between 1996 and 2017, 800,000 farmed salmon escaped from marine sites. The number of salmon returning to spawn is Irish rivers is estimated to be less than 300,000 per year.
In its report to NASCO, the State also said that some escapes go unreported. This issue was documented by Inland Fisheries Ireland after anglers reported catching suspected escaped farmed salmon in five rivers in August and September 2017.
“This large number of escaped farmed salmon, with a high proportion of males likely to be sexually mature, presents a potential threat to local wild salmon populations,” the IFI said.
Based on an analysis of reports on known escapes released to Noteworthy by the Marine Institute, the reasons for the escapes were often due to damaged or ripped nets, sometimes caused by storms.
The size of the escape is not necessarily an issue, however, according to University College Cork Professor Philip McGinnity, a specialist on the genetic impacts of farm escapes.
Hybridise the population ‘in one go’
He explained the impact of an escape into a river such as the Moy, which flows through Sligo and Mayo with a wild salmon breeding population of about 50,000, is likely to be insignificant.
An escape of couple of hundred fish into a river system with only 100 or 200 spawners, however, could potentially “in one go, result in the hybridisation of the whole population”.
“And if it’s totally, or even substantially hybridised, it’s changed completely. There’s no coming back. Something that might have evolved over a period of 15-20,000 years, is lost forever.”
The presence of offspring of farm fish, he explained, including their hybrid offspring – having both a farm and wild parent – can have a big impact on a river’s wild salmon productivity.
A significant change in the genetic makeup, McGinnity said, can lead to “a genetic mismatch” and consequently a mismatch in life-history traits between an affected local population and its environment that are important for survival.
This he says “can result in a reduction in reproductive fitness” – the number of offspring that survive to spawn in future generations – that, he said, “will impact on population abundance in the long-term”.
Evidence lacking
The BIM has said there is no evidence of any significant impact on wild salmon as a result of escapes from salmon farms, and that the Irish salmon farming industry has the best record on escapes in a recent major European study. The study found that, of 113 Atlantic salmon escapes between 2009 and 2012, only one occurred in Ireland.
McGinnity, however, said that, while it is important to have an accurate record of escapes for purposes of attribution and management, the only way to really know if recipient populations are impacted is to assess them genetically, given the “context specific” nature of the impacts.
“If you haven’t measured it, you haven’t looked for it,” he said. “That’s a big thing.”
Other countries are “very active” in this area, he said, including sampling of fish in farm cages in Norway “so that they can attribute an escape to particular farms”. McGinnity said that we have yet to establish a genetic baseline of our salmon populations, however.
This step, he said, is required for detailed long-term monitoring for change in wild populations to feed into a detailed risk assessment and management framework.
McGinnity said that it would be a good idea to establish a baseline now “while the farm production in Ireland is relatively low and before any future expansion” of the industry.
NASCO recently told the State that its approach to ensure 100% farmed fish are retained in facilities is “inconsistent” with guidelines for reporting and tracking fish. The NASCO review group considered that Ireland’s actions on containment “require substantial revision”.
https://public.flourish.studio/visualisation/6320103/
To view an interactive version of this chart, click here.
Looking to the Future
Critics of the industry argue that these potential marine impacts require resolution sooner rather than later with plans to grow the sector in the National Strategic Aquaculture Plan.
According to Paddy Gargan, Inland Fisheries Ireland want the industry to move to a land-based model that would remove the issues of escapes and sea lice. There are downsides, however, such as an increased emissions footprint.
John Murphy of Salmon Watch Ireland said that, whatever model is used in the future, the State and industry need to “make sure that they get things right before pushing ahead”.
Without changes to the system as it currently operates, he said, there will be environmental problems unless you “build a physical wall between the ocean environment and farmed fish”.
“Salmon are dying of many factors at sea but this is one factor that we can really control and so far this is not happening.”
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In part three, we examine concerns over the State’s licensing regime that has allowed salmon farms to operate for over a decade with expired licences and without environmental assessment in line with EU law.
In part one, out yesterday, we revealed that the National Parks and Wildlife Service has granted licences to salmon farms to cull protected seals along the Atlantic coast.
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This investigation was carried out by Niall Sargent of Noteworthy. It was proposed and funded by you, our readers.
Noteworthy is the investigative journalism platform from The Journal. You can support our work by helping to fund one of our other investigation proposals or submitting an idea for a story. Click here to find out more >>
We also have a number of environmental investigation proposals which you can view here.
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