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Sensitive Analysis for MPA Designation in Western Irish Sea "flawed" - Two Fishing Industry Organisations

27th July 2023
Two fishing industry organisations say an example of questionable data in a recent ecologically sensitive analysis is the delineation of the herring spawning grounds in Dundalk Bay (above)
Two fishing industry organisations say an example of questionable data in a recent ecologically sensitive analysis is the delineation of the herring spawning grounds in Dundalk Bay (above) Credit: Wikimedia

Two fishing industry organisations have criticised aspects of a recent ecologically sensitive analysis of the western Irish Sea for potential marine protected area (MPA) designation.

In a joint statement, the Killybegs Fishermen’s Organisation (KFO) and Irish South and East Fishermen’s Organisation (IS&EFO) say that the report is a “good starting point” but has not addressed “some key issues”.

It “should not be used” for informing offshore renewable planning on this basis, they argue.

The “Ecological sensitivity analysis of the western Irish Sea to inform future designation of Marine Protected Areas (MPAs)” report published last month identified a list of 40 sensitive species and habitats in a sea area which has been targeted for extensive offshore windfarm development.

It was commissioned by the Department of Housing, which holds responsibility for marine planning.

The two organisations criticise the report’s decision not to include species or habitats already listed in the EU Birds and Habitats Directives or species individually managed under the EU Common Fisheries Policy (CFP) and socio-economic impacts.

This decision was due to the fact that legal provisions for their conservation and sustainability are already in place, according to the report’s authors led by Prof Tasman Crowe of UCD’s Earth Institute.

“ Until these additional issues are considered, the report should not be used for informing the ORE planning process or for identifying areas suitable for MPAs,” the two organisations state.

“Given the importance of these issues and their dependence on the output of the ecological sensitivity analysis, it is essential to establish a transparent review and revision process through which issues may be highlighted and addressed,” they state.

The KFO and IS&EFO also say that there is “no official consultation process on the report, and the current informal approach whereby stakeholders may submit observations is far from robust or transparent”.

“ These issues call into question the validity of the output of the current analyses for ORE planning and MPA identification and highlight the urgent need for a more comprehensive approach and report,” they say.

The organisations say that four levels of stakeholder engagement were defined in the report, namely “inform, involve, engage and disseminate”.

“The seafood industry were involved in the first, third and fourth levels, whereby they were informed via email of the project and offered an opportunity to submit feedback, invited to an in-person information session where a broad overview but no specific details of the analytical method was presented and discussed and finally invited to an online presentation of the final report and results where questions could be asked,” they state.

“All of these engagement levels essentially concerned informing stakeholders,”they note, but say that “no specific details of the analyses were presented in the Level 1 and Level 3 sessions, therefore it was not possible for seafood industry stakeholders to make a meaningful input into the process”.

“For example, the key features chosen for the sensitivity analysis and the underlying data were not known to the seafood industry prior to the presentation of the final report,”they state.

The level 2 “involve” stage appears to be where data and feature selection were discussed in detail, but “this level was restricted to involving only key government and agencies stakeholders, and the seafood industry was excluded… despite their extensive knowledge of the area and features within”.

“The reasoning behind this exclusion, as highlighted in the report, was the limited time available for the study,” they note.

“ The KFO and IS&EFPO understand that this was not the choice of the report authors,” they say, and they say this was the fault of the Department of Housing, which commissioned the study with a tight deadline of just four months.

“All future processes for identifying potential areas for MPAs or for assessing potential sites for ORE developments should involve all stakeholders early at every step and level of the process,” they say, as “the only way to ensure a successful outcome”.

Excluding habitats and species that are listed in the EU Birds and Habitats Directives was “a flawed decision that resulted in a significant data gap in the sensitivity analysis and led to the incorrect interpretation of the areas that were not deemed to be potentially sensitive” the organisations note.

This situation is “particularly notable in the case of sandbanks, defined in Annex I of the Habitats Directive as “sandbanks which are slightly covered by sea water all the time”, they state.

They note that Ireland’s National Parks and Wildlife Service (NPWS) has identified the Irish Sea as having “the greatest resource of sandbanks in Irish waters”.

“To date only the Long Bank and the Blackwater Bank, both located off Wexford, have been designated as special areas of conservation (SAC) in the western Irish Sea,” they state.

“ Some of the largest sandbank, including the Kish, Arklow and Codling remain undesignated and have also been highlighted as areas for ORE developments with monopile-based wind turbines,” they state.

“One would assume that as sandbanks are listed in Annex I of the Habitats Directive then they would be considered sensitive habitats regardless of whether they were legally designated as SACs or not, and any analysis of sensitive habitats in the western Irish Sea would highlight these areas for protection,” they state.

“Neither the Kish, Arklow or Codling bank were highlighted as sensitive areas in the sensitivity analysis report,” the organisations say, questioning why non-designated sandbanks were excluded from the analysis.

The report is also confusing in relation to a range of infra and circa-littoral sediment types included as features that met the criteria for inclusion for spatial protection, they state.

The organisations also say that the exclusion of seabirds from the ecological sensitivity analysis, as they are considered under the EU Birds Directive, is “also a significant issue”.

Since the report’s publication, the same department which commissioned it has announced the proposed designation of a large special protection area (SPA) for birds in the northern part of the Irish Sea, and this “completely changes the perception of the outputs of the report”, they say.

“Offshore wind turbines are well proven to cause disturbance and displacement of seabirds and are likely the most damaging activity that could occur within an SPA,” they note, and failure of the report to highlight this “indicates a significant deficiency”.

The two organisations also say there are “significant issues related to the data used in the analyses”.

“Most of the data was fisheries-dependent data, which is biased towards areas that are of key importance for commercial fishing,” they say.

“ Fishermen will try to avoid areas with, for example, a high abundance of juveniles as these are of no commercial value and will represent wasted effort. Therefore, an analysis which is mainly based on VMS and logbook data is biased towards identifying areas with fishing operations,” they point out.

“The resultant sampling data is not a true representation of the species range and does not capture the diversity of life present in the Irish Sea,” they say.

“The lack of data, despite being mentioned in the report, is not immediately apparent to the general reader and requires further extensive reading of the appendices,” they state.

“There are also specific examples where the data used for assessing individual features is questionable,” they state, citing ray distribution data as an example.

“The bottom trawl survey data were collected in the Irish Sea from 1993-2012 and as such, are older than the 10 years defined in the report as “relevant to the current distribution” of mobile species,” they state.

“Another example of questionable data is the delineation of the herring spawning grounds in Dundalk Bay,” they say.

“There is no evidence to support this delineation, and it was made purely on the basis of the presence of a coarse sediment substrate type, which is also widely found further south in the Irish Sea,” they state.

Other issues raised include an “overly simplistic” analysis of carbon sequestration; omission of seafood provision in terms of protein and nutrients as an “essential ecosystem service”; and failure to include decommissioning of ORE developments as a significant pressure source on ecosystems.

Published in Fishing, Marine Planning
Lorna Siggins

About The Author

Lorna Siggins

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Lorna Siggins is a print and radio reporter, and a former Irish Times western correspondent. She is the author of Search and Rescue: True stories of Irish Air-Sea Rescues and the Loss of R116 (2022); Everest Callling (1994) on the first Irish Everest expedition; Mayday! Mayday! (2004); and Once Upon a Time in the West: the Corrib gas controversy (2010). She is also co-producer with Sarah Blake of the Doc on One "Miracle in Galway Bay" which recently won a Celtic Media Award

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Irish Fishing industry 

The Irish Commercial Fishing Industry employs around 11,000 people in fishing, processing and ancillary services such as sales and marketing. The industry is worth about €1.22 billion annually to the Irish economy. Irish fisheries products are exported all over the world as far as Africa, Japan and China.


Over 16,000 people are employed directly or indirectly around the coast, working on over 2,000 registered fishing vessels, in over 160 seafood processing businesses and in 278 aquaculture production units, according to the State's sea fisheries development body Bord Iascaigh Mhara (BIM).

All activities that are concerned with growing, catching, processing or transporting fish are part of the commercial fishing industry, the development of which is overseen by BIM. Recreational fishing, as in angling at sea or inland, is the responsibility of Inland Fisheries Ireland.

The Irish fishing industry is valued at 1.22 billion euro in gross domestic product (GDP), according to 2019 figures issued by BIM. Only 179 of Ireland's 2,000 vessels are over 18 metres in length. Where does Irish commercially caught fish come from? Irish fish and shellfish is caught or cultivated within the 200-mile exclusive economic zone (EEZ), but Irish fishing grounds are part of the common EU "blue" pond. Commercial fishing is regulated under the terms of the EU Common Fisheries Policy (CFP), initiated in 1983 and with ten-yearly reviews.

The total value of seafood landed into Irish ports was 424 million euro in 2019, according to BIM. High value landings identified in 2019 were haddock, hake, monkfish and megrim. Irish vessels also land into foreign ports, while non-Irish vessels land into Irish ports, principally Castletownbere, Co Cork, and Killybegs, Co Donegal.

There are a number of different methods for catching fish, with technological advances meaning skippers have detailed real time information at their disposal. Fisheries are classified as inshore, midwater, pelagic or deep water. Inshore targets species close to shore and in depths of up to 200 metres, and may include trawling and gillnetting and long-lining. Trawling is regarded as "active", while "passive" or less environmentally harmful fishing methods include use of gill nets, long lines, traps and pots. Pelagic fisheries focus on species which swim close to the surface and up to depths of 200 metres, including migratory mackerel, and tuna, and methods for catching include pair trawling, purse seining, trolling and longlining. Midwater fisheries target species at depths of around 200 metres, using trawling, longlining and jigging. Deepwater fisheries mainly use trawling for species which are found at depths of over 600 metres.

There are several segments for different catching methods in the registered Irish fleet – the largest segment being polyvalent or multi-purpose vessels using several types of gear which may be active and passive. The polyvalent segment ranges from small inshore vessels engaged in netting and potting to medium and larger vessels targeting whitefish, pelagic (herring, mackerel, horse mackerel and blue whiting) species and bivalve molluscs. The refrigerated seawater (RSW) pelagic segment is engaged mainly in fishing for herring, mackerel, horse mackerel and blue whiting only. The beam trawling segment focuses on flatfish such as sole and plaice. The aquaculture segment is exclusively for managing, developing and servicing fish farming areas and can collect spat from wild mussel stocks.

The top 20 species landed by value in 2019 were mackerel (78 million euro); Dublin Bay prawn (59 million euro); horse mackerel (17 million euro); monkfish (17 million euro); brown crab (16 million euro); hake (11 million euro); blue whiting (10 million euro); megrim (10 million euro); haddock (9 million euro); tuna (7 million euro); scallop (6 million euro); whelk (5 million euro); whiting (4 million euro); sprat (3 million euro); herring (3 million euro); lobster (2 million euro); turbot (2 million euro); cod (2 million euro); boarfish (2 million euro).

Ireland has approximately 220 million acres of marine territory, rich in marine biodiversity. A marine biodiversity scheme under Ireland's operational programme, which is co-funded by the European Maritime and Fisheries Fund and the Government, aims to reduce the impact of fisheries and aquaculture on the marine environment, including avoidance and reduction of unwanted catch.

EU fisheries ministers hold an annual pre-Christmas council in Brussels to decide on total allowable catches and quotas for the following year. This is based on advice from scientific bodies such as the International Council for the Exploration of the Sea. In Ireland's case, the State's Marine Institute publishes an annual "stock book" which provides the most up to date stock status and scientific advice on over 60 fish stocks exploited by the Irish fleet. Total allowable catches are supplemented by various technical measures to control effort, such as the size of net mesh for various species.

The west Cork harbour of Castletownbere is Ireland's biggest whitefish port. Killybegs, Co Donegal is the most important port for pelagic (herring, mackerel, blue whiting) landings. Fish are also landed into Dingle, Co Kerry, Rossaveal, Co Galway, Howth, Co Dublin and Dunmore East, Co Waterford, Union Hall, Co Cork, Greencastle, Co Donegal, and Clogherhead, Co Louth. The busiest Northern Irish ports are Portavogie, Ardglass and Kilkeel, Co Down.

Yes, EU quotas are allocated to other fleets within the Irish EEZ, and Ireland has long been a transhipment point for fish caught by the Spanish whitefish fleet in particular. Dingle, Co Kerry has seen an increase in foreign landings, as has Castletownbere. The west Cork port recorded foreign landings of 36 million euro or 48 per cent in 2019, and has long been nicknamed the "peseta" port, due to the presence of Spanish-owned transhipment plant, Eiranova, on Dinish island.

Most fish and shellfish caught or cultivated in Irish waters is for the export market, and this was hit hard from the early stages of this year's Covid-19 pandemic. The EU, Asia and Britain are the main export markets, while the middle Eastern market is also developing and the African market has seen a fall in value and volume, according to figures for 2019 issued by BIM.

Fish was once a penitential food, eaten for religious reasons every Friday. BIM has worked hard over several decades to develop its appeal. Ireland is not like Spain – our land is too good to transform us into a nation of fish eaters, but the obvious health benefits are seeing a growth in demand. Seafood retail sales rose by one per cent in 2019 to 300 million euro. Salmon and cod remain the most popular species, while BIM reports an increase in sales of haddock, trout and the pangasius or freshwater catfish which is cultivated primarily in Vietnam and Cambodia and imported by supermarkets here.

The EU's Common Fisheries Policy (CFP), initiated in 1983, pooled marine resources – with Ireland having some of the richest grounds and one of the largest sea areas at the time, but only receiving four per cent of allocated catch by a quota system. A system known as the "Hague Preferences" did recognise the need to safeguard the particular needs of regions where local populations are especially dependent on fisheries and related activities. The State's Sea Fisheries Protection Authority, based in Clonakilty, Co Cork, works with the Naval Service on administering the EU CFP. The Department of Agriculture, Food and Marine and Department of Transport regulate licensing and training requirements, while the Marine Survey Office is responsible for the implementation of all national and international legislation in relation to safety of shipping and the prevention of pollution.

Yes, a range of certificates of competency are required for skippers and crew. Training is the remit of BIM, which runs two national fisheries colleges at Greencastle, Co Donegal and Castletownbere, Co Cork. There have been calls for the colleges to be incorporated into the third-level structure of education, with qualifications recognised as such.

Safety is always an issue, in spite of technological improvements, as fishing is a hazardous occupation and climate change is having its impact on the severity of storms at sea. Fishing skippers and crews are required to hold a number of certificates of competency, including safety and navigation, and wearing of personal flotation devices is a legal requirement. Accidents come under the remit of the Marine Casualty Investigation Board, and the Health and Safety Authority. The MCIB does not find fault or blame, but will make recommendations to the Minister for Transport to avoid a recurrence of incidents.

Fish are part of a marine ecosystem and an integral part of the marine food web. Changing climate is having a negative impact on the health of the oceans, and there have been more frequent reports of warmer water species being caught further and further north in Irish waters.

Brexit, Covid 19, EU policies and safety – Britain is a key market for Irish seafood, and 38 per cent of the Irish catch is taken from the waters around its coast. Ireland's top two species – mackerel and prawns - are 60 per cent and 40 per cent, respectively, dependent on British waters. Also, there are serious fears within the Irish industry about the impact of EU vessels, should they be expelled from British waters, opting to focus even more efforts on Ireland's rich marine resource. Covid-19 has forced closure of international seafood markets, with high value fish sold to restaurants taking a large hit. A temporary tie-up support scheme for whitefish vessels introduced for the summer of 2020 was condemned by industry organisations as "designed to fail".

Sources: Bord Iascaigh Mhara, Marine Institute, Department of Agriculture, Food and Marine, Department of Transport © Afloat 2020