An Taisce's submission on Independent Aquaculture Licensing Review
An Taisce made the following submission as part of the Public Consultation on the Independent Aquaculture Licensing Review 2017.
The objectives of the review are as follows:
Having regard to Government policy, the Independent Review Group will aim to identify changes required to the aquaculture licence process and its associated legal framework that will:
- Deliver licence determinations in a timely manner, having regard to international best practice and applicable EU and national law;
- Support achievement of the actions and priorities of Food Wise 2025 and the National Strategic Plan for Sustainable Aquaculture Development;
- Facilitate enhanced transparency in the licensing process for all stakeholders;
- Ensure legally robust licence determinations having regard to EU and national law.
An Taisce supports the sustainable and balanced development of aquaculture. However, there are number of concerns which are associated with aquaculture activities, which are reflected in the following submission. An Taisce advocates that licenses should be granted on the basis that they do not cause degradation in the area of the aquaculture facility or adverse impacts to local habitats or species.
As laid out in the submission, the licensing process should operate on the precautionary principle and adopt an ecosystem-based management approach, taking into account cumulative impacts, carrying capacity and appropriate siting of aquaculture operations. Attention should be paid to prevent the establishment of invasive species (such as the Pacific Oyster) within Irish waters. It must follow all the legal obligations and considerations laid out under the Habitats and Birds Directives. The submission also highlights concerns such as the accumulation of waste, alteration of the nutrient balance and changes in macrofauna benthic communities and their impacts on ecosystems as a whole. It also refers to concerns particularly in relation to finfish aquaculture, such as the reduction in gene pool strength due to escaping aquaculture stock mating with wild populations, and transmission of diseases to wild stocks. The submission advocates for the consideration of alternative systems to mitigate these impacts, such as closed-containment systems. Additionally, the submission draws attention to the potential disturbance of aquaculture operations (particularly oyster trestle aquaculture) to birds and other species, especially in Special Protection Areas (SPAs) and Special Areas of Conservation (SACs).
An Taisce advocates for better consideration of these impacts within the licensing system. Additionally, there is a need for better consultation processes and a more balanced and transparent structure of licensing overall, with better separation of responsibility for that of licensing from that of industry development. It is mentioned in Foodwise 2025, that “a significant increase in food production cannot be considered in isolation from its environmental impact, in particular regarding concerns associated with the depletion of natural resources and the potential impact on climate change”. The pressure to grow the industry should not become an overarching goal, but rather remain in balance with sustainable production, for the benefit of communities and ecosystems in tandem.