An Irish seafood industry grouping says the State has ignored key aspects of its own national marine planning framework in identifying potential sites for offshore renewable energy (ORE).
The Seafood Industry Representative Forum (SIRF) says this is one of the reasons it does not agree with the four maritime areas identified off the south Irish coast for future offshore wind development.
In its submission to the consultation on the draft south coast designated area maritime plan (SC-DMAP), SIRF says it does “not agree that the draft SC-DMAP policy objectives and governance approach will support and guide its sustainable and coherent implementation”.
To date there has been “no implementation of the national marine planning framework (NMPF) fisheries policies,” it says.
The group says "it does not agree that co-existence should be the primary focus of the SC-DMAP” as “the NMPF clearly states that in order of preference proposals must demonstrate that they will: a) avoid, b) minimise, or c) mitigate significant adverse impacts on existing activities and maritime users”.
“As demonstrated in the constraint analyses, commercial fisheries and essential fish habitats were effectively disregarded in the process to date,”the group says.
It concludes that “the plan-led framework set out in the SC-DMAP appears to be primarily a prioritisation exercise for selecting technically and economically attractive sites for ORE developers without balanced consideration for existing maritime activities”.
“Site selection that takes proper account of commercial fisheries is absent or, at best, delayed until later in the development process (possibly as late as project stage),”the groups.
“The plan-led approach is, unfortunately, proving to be only a minor improvement on the phase one process” for offshore wind farms, it says.
The group says it is committed to actively participating in the identification of appropriate sites for future ORE development.
It says that “fishing grounds and aquaculture sites are key food production areas and should be formally recognised as such”.
“Fishing grounds cannot be relocated as they are based on the presence of the target species, whilst aquaculture sites are based on a range of factors including local hydrographic conditions and available food source for filter feeders,”it says.
“The selection of areas for ORE development based solely on their economic attractiveness to developers is not appropriate and should include other critical factors including food production in future analyses,”the group says.
It says that “significant potential impacts to commercial fisheries highlighted by the Marine Institute were not transparently communicated in the publicly available consultation documents”.
It also notes that three out of the four SC-DMAP areas are located outside the 12 nautical mile zone and the fisheries within them are managed under the EU Common Fisheries Policy.
“The Marine Institute highlighted the potential impact on international fishing fleets, but this was not effectively communicated internationally through the public consultation,”the group says.
It says that a Fisheries Management and Mitigation Strategy (FMMS) should be developed as part of the SC DMAP process and not at a later stage on a project-by-project basis, and this should assess the potential socio-economic impact of planned ORE development on the affected fisheries and the associated processing sectors.
It says this assessment should include all direct, indirect, and cumulative / in-combination impacts, from all ORE developments planned or envisaged.
The group says that the Marine Institute’s recommendation that a detailed assessment of essential fish habitat - and a risk assessment in relation to ORE developments- should be conducted for the DMAP area was “not communicated in the publicly available consultation documents, nor was it acted upon in the analyses undertaken”.
It says the approach taken and analyses employed in refining the SC-DMAP area “are not appropriate” and “aim to promote the use of one specific activity (ORE) rather than the more complex, multi-activity, area planning consistent with marine spatial planning.
It says the analyses “should be conducted again, starting with the larger draft DMAP area, and should involve “full stakeholder participation and include balanced consideration for existing maritime activities such as commercial fishing and sensitive habitats such as fish spawning and nursery areas”.
“There is a vital need to progress the development of ORE in Ireland’s sea area in a way that creates consensus and avoids any repeat of past mistakes,”it says.
“There is also an urgent need to formally recognise that fishing grounds and aquaculture sites are key food production areas that cannot be relocated,”it says.
“ Seafood is a low carbon, healthy and sustainable part of our food supply, which can and should be part of the targeted solution to contributing to decarbonisation targets and addressing climate change,”it says, and its production “greatly supports our coastal communities”.
Representatives of SIRF are: Teresa Morrissey, IFA (Aquaculture);Brendan Byrne, Irish Fish Processors and Exporters Association; Aodh O’Donnell, Irish Fish Producers Organisation; John Lynch, Irish South and East Fish Producers Organisation; Patrick Murphy, Irish South and West Fish Producers Organisation; Dominic Rihan, Killybegs Fishermen’s Organisation; Seamus Breathnach, National Inshore Fishermen's Association; and Liz Geoff, National Inshore Fisheries Forum.
