Report supporting Appropriate Assessment of Aquaculture and Risk
Assessment of Fisheries in Clew Bay Complex SAC
(Site Code: 1482)
Marine Institute
Rinville, Oranmore
Co. Galway
19 July 2019
Contents
1 Preface ..................................................................................................................................... 1
2 Executive summary ................................................................................................................. 2
2.1 The SAC .............................................................................................................................. 2
2.2 Activities in the SAC ........................................................................................................... 2
2.3 The appropriate assessment and risk assessment process .................................................. 2
2.4 Data supports .................................................................................................................... 3
2.5 Findings ............................................................................................................................. 3
3 Introduction .............................................................................................................................. 5
4 Conservation Objectives for Clew Bay SAC (001482)......................................................... 5
4.1 The SAC extent ................................................................................................................... 5
4.2 Qualifying interests (SAC) ................................................................................................... 6
4.3 Conservation objectives for Clew Bay SAC .......................................................................... 8
4.4 Screening of Adjacent SACs or for ex situ effects .............................................................. 12
5 Details of the proposed plans and projects ......................................................................... 17
5.1 Aquaculture ..................................................................................................................... 17
5.1.1 Oyster Culture ........................................................................................................ 17
5.1.2 Subtidal Oyster culture .......................................................................................... 19
5.1.3 Rope Mussels ........................................................................................................ 19
5.1.4 Salmon Culture ...................................................................................................... 20
5.1.5 Scallop .................................................................................................................... 21
5.1.6 Clew Bay Seaweed Cultivation ............................................................................. 21
5.1.7 Clams ...................................................................................................................... 22
5.1.8 Abalone ................................................................................................................... 22
5.1.9 Lobster .................................................................................................................... 23
5.1.10 Hatchery Operations .............................................................................................. 23
5.1.11 Clew Bay CLAMS .................................................................................................. 23
5.2 Fishing activities ............................................................................................................... 26
5.2.1 The fleet .................................................................................................................. 26
5.2.2 Potting for shrimp ................................................................................................... 27
5.2.3 Potting for prawns .................................................................................................. 27
5.2.4 Potting for crab and lobster ................................................................................... 28
5.2.5 Potting for whelk .................................................................................................... 28
5.2.6 Tangle netting for crayfish ..................................................................................... 28
5.2.7 Gill netting for Pollack and other netting .............................................................. 29
5.2.8 Dredging for scallop ............................................................................................... 30
5.2.9 Dredging for oyster ................................................................................................ 31
5.2.10 Bottom trawling for mixed demersal fish .............................................................. 31
5.2.11 Mid-water trawling for pelagic fish ........................................................................ 32
5.2.12 Hook and line fishing for mackerel and Pollack .................................................. 32
5.2.13 Draft net fishing for salmon ................................................................................... 33
5.2.14 Trammel net fishing for bait .................................................................................. 33
5.2.15 Hand gathering of periwinkle and cockle ............................................................. 33
6 Natura Impact Statement for the proposed activities ......................................................... 35
6.1 Aquaculture ..................................................................................................................... 35
6.2 Fisheries ........................................................................................................................... 42
7 Screening of Aquaculture Activities ..................................................................................... 51
7.1 Aquaculture Activity Screening ......................................................................................... 51
8 Assessment of Aquaculture Activities ................................................................................. 56
8.1 Determining significance .................................................................................................. 56
8.2 Sensitivity and Assessment Rationale ............................................................................... 57
8.3 Assessment of the effects of aquaculture production on the Conservation Objectives for
habitat features in Clew Bay Complex SAC. .................................................................................. 59
8.4 Assessment of the effects of shellfish production on the Conservation Objectives for
Harbour Seal in Clew Bay Complex SAC. ....................................................................................... 67
8.5 Assessment of the effects of shellfish production on the Conservation Objectives for otter
and migrating salmon in Clew Bay Complex SAC. ......................................................................... 70
9 Risk Assessment of Fishing Activities ................................................................................. 73
9.1 Risk assessment screening of fisheries ............................................................................. 73
9.2 Methodology: .................................................................................................................. 73
9.2.1 Determining risk to the conservation objectives .................................................. 73
9.2.2 Sensitivity of characterizing species and marine communities to physical
disturbance by fishing gears ................................................................................................ 76
9.3 Risk assessment of impact of fishing gears on marine benthic communities ..................... 77
9.3.1 Potting for shrimp ................................................................................................... 78
9.3.2 Potting for prawns .................................................................................................. 78
9.3.3 Potting for crab and lobster ................................................................................... 79
9.3.4 Potting for whelk .................................................................................................... 79
9.3.5 Tangle netting for crayfish ..................................................................................... 79
9.3.6 Gill netting for Pollack and mackerel .................................................................... 80
9.3.7 Dredging for scallop ............................................................................................... 80
9.3.8 Dredging for oyster ................................................................................................ 81
9.3.9 Bottom trawling for mixed demersal fish .............................................................. 82
9.3.10 Midwater trawling for pelagic fish ......................................................................... 82
9.3.11 Hook and line fishing for mackerel ....................................................................... 82
9.3.12 Draft net fishing for salmon ................................................................................... 82
9.3.13 Trammel net fishing for bait .................................................................................. 82
9.3.14 Hand gathering of periwinkle and cockle ............................................................. 83
9.3.15 Cumulative effects of fishing on marine communities ........................................ 83
9.4 Risk assessment of impact of fishing gears on designated species harbour seal, otter and
salmon 90
9.4.1 Conservation objectives, status and habitat use ................................................. 90
9.4.2 Risk of capture ....................................................................................................... 91
9.4.3 Risk of prey depletion ............................................................................................ 93
9.4.4 Otter ........................................................................................................................ 93
9.4.5 Risk of disturbance ................................................................................................ 93
9.4.6 Cumulative effects of fishing on designated species .......................................... 94
9.5 Fisheries risk profile ......................................................................................................... 95
9.5.1 Marine Community types ...................................................................................... 95
9.5.2 Species ................................................................................................................... 96
10 In-combination effects of aquaculture, fisheries and other activities ............................ 96
11 SAC Aquaculture Appropriate Assessment Concluding Statement and
Recommendations ........................................................................................................................ 98
11.1 Habitats ........................................................................................................................... 98
11.2 Species ............................................................................................................................. 99
12 SAC Fisheries Risk Assessment Concluding Statement and Recommendations ...... 99
12.1 Habitats ........................................................................................................................... 99
12.2 Species ........................................................................................................................... 100
13 References....................................................................................................................... 101
List of Figures
Figure 1. The extent of Clew Bay Complex SAC (site code 001482). .................................................... 6
Figure 2. Principal benthic communities recorded within the qualifying interests Large shallow inlets and
bays and Mudflats and sandflats not covered by seawater at low tide within Clew Bay Complex SAC
(Site Code 001482) (NPWS 2011). ......................................................................................................... 7
Figure 3. Harbour Seal (Phoca vitulina) locations in Clew Bay Complex SAC. ...................................... 8
Figure 4. Natura 2000 sites adjacent to the Clew Bay Complex SAC .................................................. 12
Figure 5: Aquaculture sites (Licenced and Applications) and access routes in Clew Bay Complex SAC
(access routes not drawn to scale) ....................................................................................................... 24
Figure 6: Distribution of shrimp fishing, derived from expert data, in relation to Clew Bay SAC ......... 27
Figure 7: Distribution of fishing for lobster, crab and prawns in relation to the Clew Bay SAC ........... 28
Figure 8: Distribution of tangle netting for crayfish in relation to the Clew Bay SAC ............................ 29
Figure 9: Distribution of Pollack and mackerel gill netting and trolling in relation to the Clew Bay SAC
.............................................................................................................................................................. 30
Figure 10: Distribution of scallop fishing, derived from survey data and expert data, in relation to Clew
Bay SAC ................................................................................................................................................ 30
Figure 11: Distribution of oyster fishing, derived from survey data, in relation to Clew Bay SAC ....... 31
Figure 12: Distribution of bottom trawl fishing, derived from VMS data (vessels >15m) and expert data,
in relation to Clew Bay SAC .................................................................................................................. 32
Figure 13: Distribution of mid-water trawling as shown by VMS data (vessels>15m). ........................ 32
Figure 14 Distribution of trammel netting for bait in relation to the Clew Bay SAC. ............................. 33
Figure 15: Distribution of cockle stocks, derived from survey data, in Clew Bay SAC ......................... 34
Figure 16: Determination of significant effects on community distribution, structure and function for
sedimentary habitats (following NPWS 2011b)..................................................................................... 57
Figure 17. Harbour Seal Sites and Aquaculture Sites (licenced and applications) in Clew Bay – North
.............................................................................................................................................................. 69
Figure 18. Harbour Seal Sites and Aquaculture Sites (licenced and applications) in Clew Bay – South
.............................................................................................................................................................. 69
Figure 19. The distribution of fishing activity (count = number of fishing metier) in relation to Laminaria
reef communities in Clew Bay SAC. ..................................................................................................... 84
Figure 20. The distribution of fishing activity (count = number of fishing metier) in relation to faunal reef
communities in Clew Bay SAC ............................................................................................................. 85
Figure 21. The distribution of fishing activity (count = number of fishing metier) in relation to Zostera
communities in Clew Bay SAC ............................................................................................................. 85
Figure 22. The distribution of fishing activity (count = number of fishing metier) in relation to Maerl
communities in Clew Bay SAC ............................................................................................................. 86
List of Tables
Table 1. Conservation objectives and targets for marine habitats and species in Clew Bay SAC
(0001482) (NPWS 2012; NPWS 2011). Annex I and II features listed in bold. ...................................... 9
Table 2 Natura Sites adjacent to Clew Bay Complex SAC and qualifying features with initial screening
assessment on likely interactions with fisheries and aquaculture activities. ......................................... 13
Table 3: Spatial extent (ha) of aquaculture activities overlapping with the qualifying interest (1140 -
Mudflats and sandflats not covered by seawater at low tide and 1160-Large shallow inlets and bays) in
Clew Bay Complex SAC, presented according to culture species, method of cultivation and license
status. .................................................................................................................................................... 25
Table 4: The inshore fishing fleet in Clew Bay ...................................................................................... 26
Table 5: Potential indicative environmental pressures of aquaculture activities within the qualifying
interests (Mudflats and sandflats not covered by seawater at low tide (1140) and Large Shallow Inlets
and Bays (1160)) of Clew Bay Complex SAC....................................................................................... 43
Table 6: Potential interactions between aquaculture activities and the Annex II species Harbour Seal
(Phoca vitulina) within the Clew Bay SAC. ........................................................................................... 50
Table 7: Habitat utilisation i.e. spatial overlap in hectares and percentage (given in parentheses) of
Aquaculture activity over community types within the qualifying interest 1140 - Mudflat and sandflats
not covered by seawater at low tide of Clew Bay Complex SAC. (Spatial data based on licence database
provided by DAFM. Habitat data provided in NPWS 2011 – supporting docs marine and coastal) ..... 53
Table 8: Habitat utilisation i.e. spatial overlap in hectares and percentage (given in parentheses) by
Aquaculture activity over specific community types within the qualifying interest 1160 – Large shallow
inlets and bays of Clew Bay Complex SAC based on licence database provided by DAFM. Habitat data
provided in NPWS 2011 – supporting docs marine and coastal) ......................................................... 54
Table 9: Matrix showing the characterising habitats sensitivity scores x pressure categories for habitats
in Clew Bay Complex SAC (ABPMer 2013a-h). ................................................................................... 61
Table 10: Matrix showing the characterising species sensitivity scores x pressure categories for habitats
in Clew Bay Complex SAC (ABPMer 2013a-h). Table 11 provides the code for the various
categorisation of sensitivity and confidence .......................................................................................... 62
Table 11: Codes of sensitivity and confidence applying to species and pressure interactions presented
in Tables 10 and 11. .............................................................................................................................. 63
Table 12. Interactions between the relevant aquaculture activities and the habitat feature 1140
constituent communities with a broad conclusion on the nature of the interactions ............................. 64
Table 13. Interactions between the relevant aquaculture activities and the habitat feature 1160
constituent communities with a broad conclusion on the nature of the interactions. ............................ 65
Table 14. Risk categorization for fisheries and designated habitat interactions (see: Marine Institute
2013). Colours indicate risk category. Disturbance is defined as that which leads to a change in
characterising species. Such disturbance may be temporary or persistent depending on the frequency
of impact and the sensitivity of the receiving environment. Colours indicate the probable need for
mitigation of effects from green (no mitigation needed), to yellow (mitigation unlikely to be needed but
review on a case by case basis), orange (mitigation probably needed) and red (mitigation required) 74
Table 15. Risk categorization for fisheries and designated species interactions (Marine Institute 2013)
.............................................................................................................................................................. 75
Table 16. Percentage (%) overlap of fisheries with seabed habitats and qualifying interests 1140 and
1160. ..................................................................................................................................................... 87
Table 17. Percentage overlap of fishing metiers, which have significant contact with the seabed, with
marine community types in Habitats 1140 and 1160 in Clew Bay. MCTs with shading have no fishery
overlapping with them ........................................................................................................................... 88
Table 18. The categorical risk (= consequence*likelihood of consequence) posed by bottom contacting
gears each fishing activity to marine communities. Blank cells indicate no spatial overlap or occurrence
of the fishery in the MCT. Colour codes indicate the probable need for mitigation as described in Tables
15 and 16 (See section 9.2.1). .............................................................................................................. 89
Table 19. Risk (consequence*likelihood of consequence) of by-catch, prey depletion and disturbance
by fisheries to designated species in Clew Bay .................................................................................... 95
1
1 Preface
In Ireland, the implementation of Article 6 of the Habitats Directive in relation to aquaculture and fishing
projects and plans that occur within designated sites is achieved through sub-Article 6(3) of the
Directive. Fisheries not coming under the scope of Article 6.3, i.e. those fisheries not subject to
secondary licencing, are subject to risk assessment. Identified risks to designated features can then be
mitigated and deterioration of such features can be avoided as envisaged by sub-article 6.2.
Fisheries, other than oyster fisheries, and aquaculture activities are licenced by the Department of
Agriculture, Food and Marine (DAFM). Oyster fisheries are licenced by the Department of
Communications Energy and natural Resources (DCENR). The Habitats Directive is transposed in
Ireland in the European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. 477 of 2011).
Appropriate assessments (AA) and risk assessments (RA) of fishing activities are carried out against
the conservation objectives (COs), and more specifically on the version of the COs that are available
at the time of the Assessment, for designated ecological features, within the site, as defined by the
National Parks and Wildlife Service (NPWS). NPWS are the competent authority for the management
of Natura 2000 sites in Ireland. Obviously, aquaculture and fishing operations existed in coastal areas
prior to the designation of such areas under the Directives. Ireland is thereby assessing both existing
and proposed aquaculture and fishing activities in such sites. This is an incremental process, as agreed
with the EU Commission in 2009, and will eventually cover all fishing and aquaculture activities in all
Natura 2000 sites.
The process of identifying existing and proposed activities and submitting these for assessment is, in
the case of fisheries projects and plans, outlined in S.I. 290 of 2013. Fisheries projects or plans are
taken to mean those fisheries that are subject to annual secondary licencing or authorization. Here, the
industry or the Minister may bring forward fishing proposals or plans which become subject to
assessment. These so called Fishery Natura Plans (FNPs) may simply be descriptions of existing
activities or may also include modifications to activities that mitigate, prior to the assessment, perceived
effects to the ecology of a designated feature in the site. In the case of other fisheries, that are not
projects or plans, data on activity are collated and subject to a risk assessment against the COs. Oyster
fisheries, managed by Department of Communications, Climate Action and Environment (DCCAE), do
not come under the remit of S.I. 290 of 2013 but are defined as projects or plans as they are authorized
annually and are therefore also subject to AA.
In the case of aquaculture, DAFM receives applications to undertake such activity and submits a set of
applications, at a defined point in time, for assessment. The FNPs and aquaculture applications are
then subject to AA. If the AA or the RA process finds that the possibility of significant effects cannot be
discounted or that there is a likelihood of negative consequence for designated features then such
activities will need to be mitigated further if they are to continue. The assessments are not explicit on
how this mitigation should be achieved but rather indicate whether mitigation is required or not and what
results should be achieved.
2
2 Executive summary
2.1 The SAC
Clew Bay is designated as a Special Area of Conservation (SAC) under the Habitats Directive. The
marine area is designated as a large shallow inlet and bay and for intertidal mud and sand flats not
covered by seawater at low tide. The bay supports a variety of sub-tidal and intertidal sedimentary and
reef habitats including habitats that are sensitive to pressures, which might arise from fishing and
aquaculture, such as maerl (corraline algae), seagrass and kelp reefs. The area is also designated for
and supports significant numbers of Harbour Seal and otter while salmon, designated in the Newport
River which flows into the north east corner of the Bay, migrate through the Bay as smolts and as mature
salmon returning from sea. Conservation Objectives for these habitats and species were identified by
NPWS (2011a) and relate to the requirement to maintain habitat distribution, structure and function, as
defined by characterizing (dominant) species in these habitats. For designated species the objective is
to maintain various attributes of the populations including population size, cohort structure and the
distribution of the species in the Bay. Guidance on the conservation objectives is provided by NPWS
(2011b).
2.2 Activities in the SAC
There is a diverse range of aquaculture and fishing and activities in the Bay.
There is an intensive autumn pot fishery for shrimp. Lobster and crab are fished throughout the year.
Crayfish and demersal fish are targeted with tangle nets and gill nets in the outer Bay and beyond.
Scallop are fished in the outer part of the SAC. Oysters are fished in discrete areas in the eastern part
of the SAC. Demersal and mid-water trawling occurs in the outer part of the Bay but not in the SAC.
Line fishing for mackerel and Pollack is common in summer.
The main aquaculture activity is oyster culture with lesser numbers of licences for suspended mussel
culture and finfish farming of salmon. Other species cultured included abalone and scallop. The Pacific
oyster (Crassostrea gigas) is typically cultured on trestles in intertidal areas. Some sites are licenced
for the culture of triploid oysters on the seabed.
2.3 The appropriate assessment and risk assessment process
The function of an appropriate assessment and risk assessment is to determine if the ongoing and
proposed aquaculture and fisheries activities are consistent with the Conservation Objectives for the
Natura site or if such activities will lead to deterioration in the attributes of the habitats and species over
time and in relation to the scale, frequency and intensity of the activities. NPWS (2011b) provide
guidance on interpretation of the Conservation Objectives which are, in effect, management targets for
habitats and species in the Bay. This guidance is scaled relative to the anticipated sensitivity of habitats
and species to disturbance by the proposed activities. Some activities are deemed to be wholly
inconsistent with long term maintenance of certain sensitive habitats while other habitats can tolerate a
range of activities. The appropriate assessment and risk assessment process is divided into a number
of stages consisting of a preliminary risk identification, and subsequent assessment (allied with
3
mitigation measures if necessary) which are covered in this report. The first stage of the AA process is
an initial screening wherein activities which cannot have, because they do not spatially overlap with a
given habitat or have a clear pathway for interaction, any impact on the conservation features and are
therefore excluded from further consideration. The next phase is the Natura Impact Statement (NIS)
where interactions (or risk of) are identified. Further to this, an assessment on the significance of the
likely interactions between activities and conservation features is conducted. Mitigation measures (if
necessary) will be introduced in situations where the risk of significant disturbance is identified. In
situations where there is no obvious mitigation to reduce the risk of significant impact, it is advised that
caution should be applied in licencing decisions. Overall the Appropriate Assessment is both the
process and the assessment undertaken by the competent authority to effectively validate this
Screening Report and/or NIS.It is important to note that the screening process is considered
conservative, in that other activities which may overlap with habitats but which may have very benign
effects are retained for full assessment. In the case or risk assessments consequence and likelihood of
the consequence occurring are scored categorically as separate components of risk. Risk scores are
used to indicate the requirement for mitigation.
2.4 Data supports
Distribution of habitats and species population data are provided by NPWS1. Fishing data are compiled
from various sources including survey data, questionnaire data and expert knowledge. Information on
Aquaculture licences and applications are provided by DAFM2. Aquaculture industry profiles were
provided by BIM. Scientific reports on the potential effects of various activities on habitats and species
have been compiled by the MI and provide the evidence base for the findings. The data supporting the
assessment of individual activities vary and provides for varying degrees of confidence in the findings.
2.5 Findings
The appropriate assessment for aquaculture finds that the aquaculture activities, at the current and
proposed or likely future scale and frequency of activity are consistent with the Conservation Objectives.
Specifically:
- Aquaculture and Habitats: Based upon the scale of spatial overlap and the relatively high tolerance
levels of the community types and species therein and given the likely interactions between current
and proposed aquaculture activities with these habitats, it is concluded that consideration can be
given to licencing (existing and applications) in the Annex 1 habitats – 1140 (Mudflats and sandflats
not covered by seawater at low tide) and 1160 (Large Shallow Inlets and Bays). The movement of
stock in and out of Clew Bay Complex SAC should adhere to relevant fish health legislation and
follow best practice guidelines.
1 NPWS Geodatabase Ver: September 2013 - http://www.npws.ie/mapsanddata/habitatspeciesdata/
2 DAFM Aquaculture Database version Aquaculture: 30th Aug 2013
4
- The presence of the carpet sea squirt in Clew Bay is noted. It is recommended that Methods should
be employed to ensure that structures and netting are kept clean at all times and that any biofouling
by alien invasive species be removed and disposed of in a responsible manner, such that it will not
pose a risk to the conservation features of the site.
- Aquaculture and species: It is acknowledged in this assessment that the favourable conservation
status of the Harbour seal (Phoca vitulina) has been achieved given current levels of aquaculture
production within the SAC. On this basis, the current levels of licenced aquaculture are considered
non-disturbing to harbour seal conservation features. It is anticipated that new applications will also
result in no disturbances. The aquaculture activities proposed do not pose a threat to otter and in the
Clew Bay Complex SAC.
- Assuming the management and regulatory systems that are in place are fully operational, the current
finfish aquaculture activities carried out do not pose a risk to salmon migrating through the Clew Bay
Complex SAC.
5
3 Introduction
This document assesses the potential ecological interactions of aquaculture and fisheries activities
within Clew Bay Complex SAC (site code 1428) on the Conservation Objectives (COs) of the site.
The information upon which this assessment is based is a list of applications and extant licences for
aquaculture activities administered by the Department of Agriculture Food and Marine (DAFM) and
forwarded to the Marine Institute as of August 2013; as well as aquaculture and fishery profiling
information provided on behalf of the operators by Bord Iascaigh Mara. The spatial extent of aquaculture
licences is derived from a database managed by the DAFM3 and shared with the Marine Institute.
4 Conservation Objectives for Clew Bay SAC (001482)
The appropriate assessment of aquaculture in relation to the Conservation Objectives for Clew Bay
Complex SAC is based on Version 1.0 of the objectives (NPWS 2011a - 19 July 2011) and supporting
documentation (NPWS 2011b - Version 1 June, 2011). The spatial data for conservation features was
provided by NPWS4.
4.1 The SAC extent
Clew Bay Complex SAC is a large SAC and comprises the majority of the inner part of Clew Bay
encompassing all of the islands located therein as well as the coastal lagoon, Lough Furnace. The site
is comprised of a wide range of intertidal and subtidal habitats, including mudflats and sandflats not
covered by seawater at low tide, large shallow inlets and bays as well as coastal lagoons. A number of
coastal habitats can also be found in the SAC, including Embryonic shifting dunes, shifting dunes along
the shoreline with Ammophilia arenaria (“white dunes”). The SAC is also considered an important site
for the two mammal species harbour seal (Phoca vitulina) and the otter (Lutra lutra). The extent of the
SAC is shown in Figure 1 below.
3 DAFM Aquaculture Database version Aquaculture: 30th Aug 2013 4 NPWS Geodatabase Ver: September 2013 - http://www.npws.ie/mapsanddata/habitatspeciesdata/
6
Figure 1. The extent of Clew Bay Complex SAC (site code 001482).
4.2 Qualifying interests (SAC)
The SAC is designated for the following habitats and species (NPWS 2011a), as listed in Annex I and
II of the Habitats Directive:
1013 Geyer's whorl snail Vertigo geyeri
1140 Mudflats and sandflats not covered by seawater at low tide
1150 Coastal lagoons
1160 Large shallow inlets and bays
1210 Annual vegetation of drift lines
1220 Perennial vegetation of stony banks
1330 Atlantic salt meadows (Glauco‐Puccinellietalia maritimae)
1355 Otter Lutra lutra
1365 Common (Harbour) seal Phoca vitulina
2110 Embryonic shifting dunes
2120 Shifting dunes along the shoreline with Ammophila arenaria ("white dunes")
Constituent communities and community complexes recorded within the qualifying interest Annex 1
habitats (i.e. 1140 - Mudflats and sandflats not covered by seawater at low tide and 1160 - Large
Shallow inlets and Bays) are listed in NPWS (2011b) and illustrated in Figure 2 and consist of:
Zostera dominated community
Maërl dominated communities
Sandy mud with polychaetes and bivalves community complex
Fine sand dominated by Nephtys cirrosa community
Shingle
7
Reef (Laminaria dominated community)
Intertidal sandy mud with Tubificoides benedii and Pygospio elegans community complex
Figure 2. Principal benthic communities recorded within the qualifying interests Large shallow
inlets and bays and Mudflats and sandflats not covered by seawater at low tide within Clew
Bay Complex SAC (Site Code 001482) (NPWS 2011).
The Clew Bay Complex SAC is designated for the Harbour seal (Phoca vitulina) and has been the
subject of monitoring of populations during the molting season (August-September) from 2009-2011 in
Westport Bay. Recent estimates of populations at the site range from 121 in 2009, 118 in 2010, and
116 in 2011 (NPWS 2010, 2011c, 2012a). Both 2010 and 2011 estimates were likely considered
underestimates based upon restricted visibility during surveying. A number of different locations have
been identified within the SAC and are considered important to the overall welfare and health of the
populations at the site. Figure 3 identifies these locations and distinguishes between breeding, moulting
and resting sites. A prioritisation based upon sensitive periods in the life cycle have been identified by
the competent authority, i.e. NPWS (NPWS 2011c). Important periods are the pupping season (May-
July) and molting season (August-September) and both periods and locations are considered important
periods to the overall health of the population in the SAC and that any disturbance during these times
should be kept to a minimum. Less information is known about resting period (October-April) and resting
areas throughout the SAC. The resting locations provided on Figure 3 are indicative only and the
sheltered areas within the entire SAC are considered suitable habitat for resting (NPWS 2011c).
8
Figure 3. Harbour Seal (Phoca vitulina) locations in Clew Bay Complex SAC.
4.3 Conservation objectives for Clew Bay SAC
The conservation objectives for the qualifying interests (SAC) were identified in NPWS (2011a). The
natural condition of the designated features should be preserved with respect to their area, distribution,
extent and community distribution. Habitat availability should be maintained for designated species and
human disturbance should not adversely affect such species. The features, objectives and targets of
each of the qualifying interests within the SAC are listed in Table 1 below.
9
Table 1. Conservation objectives and targets for marine habitats and species in Clew Bay SAC (0001482) (NPWS 2012; NPWS 2011). Annex I and II
features listed in bold.
FEATURE (COMMUNITY TYPE) OBJECTIVE TARGET
Geyer's whorl snail Vertigo geyeri The status of Geyer's whorl snail as a qualifying Annex II species for Clew Bay Complex SAC is currently
under review. The outcome of this review will determine whether a site‐specific conservation objective is set for this species.
Mudflats and sandflats not covered by seawater at low tide
Maintain favourable conservation condition 1277 ha; Permanent habitat is stable or increasing, subject to natural processes
(Intertidal sandy mud with Tubificoides benedii and Pygospio elegans community
complex) Maintain favourable conservation condition 788ha; Maintained in a natural condition
(Sandy mud with polychaetes and bivalves community complex)
Maintain favourable conservation condition 445ha; Maintained in a natural condition
(Fine sand dominated by Nephtys cirrosa community)
Maintain favourable conservation condition 44ha; Maintained in a natural condition
Large shallow inlets and Bays Maintain favourable conservation condition
10189ha;Targets are identified that focus on a wide range of attributes with the ultimate goal of maintaining function and diversity of favourable species and managing levels of negative species.
(Zostera dominated communities) Maintain favourable conservation condition 142ha; Maintain natural extent and high quality of Zostera dominated communities
(Maerl dominated communities) Maintain favourable conservation condition 288ha; Maintain natural extent and high quality of Mearl
dominated communities
(Sandy mud with polychaetes and bivalves community complex)
Maintain favourable conservation condition 5,791ha; Maintained in a natural condition
(Fine sand dominated by Nephtys cirrosa community) Maintain favourable conservation condition 296ha; Maintained in a natural condition.
10
FEATURE (COMMUNITY TYPE) OBJECTIVE TARGET
(Intertidal sandy mud with Tubificoides benedii and Pygospio elegans community
complex) Maintain favourable conservation condition 788ha; Maintained in a natural condition
(Shingle) Maintain favourable conservation condition 146ha; Maintained in a natural condition
(Reef) Maintain favourable conservation condition 2,687ha; Maintained in a natural condition
Coastal Lagoons Maintain favourable conservation condition
163.3ha; Targets are identified that focus on a wide range of attributes with the ultimate goal of maintaining function and diversity of favourable species and managing levels of negative species.
Annual vegetation of drift lines Maintain favourable conservation condition
0.12ha; Targets are identified that focus on a wide range of attributes with the ultimate goal of maintaining function and diversity of favourable species and managing levels of negative species.
Perennial vegetation of stony banks Maintain favourable conservation condition
0.49ha; Targets are identified that focus on a wide range of attributes with the ultimate goal of maintaining function and diversity of favourable species and managing levels of negative species.
Atlantic salt meadows (Glauco‐Puccinellietalia maritimae)
Maintain favourable conservation condition
T38.86ha; Targets are identified that focus on a wide range of attributes with the ultimate goal of maintaining function and diversity of favourable species and managing levels of negative species.
Otter Lutra lutra Restore favourable conservation conditions
Maintain distribution - 88% positive survey sites, 2426.7ha; No significant decline in extent of marine habitat; Couching sites and holts - no significant decline and minimise disturbance: Fish biomass - No significant decline in marine fish species in otter diet. Barriers to connectivity - No significant increase.
Harbour Seal Phoca vitulina Maintain favourable conservation condition
The range of use within the site should not be restricted by artificial barriers; all sites should be maintained in natural condition; human activities should occur at levels that do not adversely affect harbour seal population at the site.
11
FEATURE (COMMUNITY TYPE) OBJECTIVE TARGET
Embryonic shifting dunes Restore favourable conservation condition
1.40ha; Targets are identified that focus on a wide range of attributes with the ultimate goal of maintaining function and diversity of favourable species and managing levels of negative species
Shifting dunes along the shoreline with Ammophila arenaria ("white dunes")
Maintain favourable conservation condition
0.54ha;Targets are identified that focus on a wide range of attributes with the ultimate goal of maintaining function and diversity of favourable species and managing levels of negative species
12
4.4 Screening of Adjacent SACs or for ex situ effects
In addition to the Clew Bay Complex SAC there are a number of other Natura 2000 sites proximate to
the proposed activities (Figure 4). The characteristic features of these sites are identified in Table 2
where a preliminary screening is carried out on the likely interaction with aquaculture and fishery
activities based primarily upon the likelihood of spatial overlap. In addition species migrating to and from
the site may be affected by activities, such as fisheries, operating outside the site (ex situ effects).
Qualifying features that do not screen out because of ex situ effects or because of effects on features
in adjacent SACs are carried forward for further assessment in Sections 8 and 9. These include Atlantic
Salmon, Otter and Harbour Seal.
Figure 4. Natura 2000 sites adjacent to the Clew Bay Complex SAC
.
13
Table 2 Natura Sites adjacent to Clew Bay Complex SAC and qualifying features with initial screening assessment on likely interactions with fisheries
and aquaculture activities.
NATURA SITE QUALIFYING FEATURES [HABITAT/SPECIES CODE] AQUACULTURE INITIAL SCREENING
Owenduff/Nephin Complex SAC
(000534) Salmon (Salmo salar) [1106]
Migrating salmon passing through Clew Bay Complex SAC and could interact with activities covered in this assessment- carry forward to Section 8.
Otter (Lutra lutra) [1355]
Potential for otter to link between this SAC and Clew Bay Complex SAC. Otter also a feature of Clew Bay Complex SAC - carry forward to Section 8.
Shining sickle moss (Drepanocladus vernicosus) [1393]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Marsh saxifrage (Saxifraga hirculus) [1528] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Oligotrophic waters containing very few minerals of sandy plains (Littorelletalia uniflorae) [3110]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Oligotrophic to mesotrophic standing waters with vegetation of the Littorelletea uniflorae and/or of the Isoete-Nanojuncetea [3130]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Natural dystrophic lakes and ponds [3160] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
14
NATURA SITE QUALIFYING FEATURES [HABITAT/SPECIES CODE] AQUACULTURE INITIAL SCREENING
Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Northern Atlantic wet heaths with Erica tetralix [4010]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Alpine and Boreal heaths [4060] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Juniperus communis formations on heaths or calcareous grasslands [5130]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Blanket bog (*active only) [7130] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Transition mires and quaking bogs [7140] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Owenduff/Nephin Complex SPA
(004098)
Merlin (Falco columbarius) (breeding) [A098]
No likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Golden plover (Pluvialis apricaria) (breeding) [A140]
No likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Greenland White fronted Goose (Anser albifrons flavirostris) (wintering) [A395]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
15
NATURA SITE QUALIFYING FEATURES [HABITAT/SPECIES CODE] AQUACULTURE INITIAL SCREENING
Corraun Plateau SAC (000485) Oligotrophic waters containing very few minerals of sandy plains (Littorelletalia uniflorae) [3110]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Northern Atlantic wet heaths with Erica tetralix [4010]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
European dry heaths [4030] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Alpine and Boreal heaths [4060] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Blanket bog (*active only) [7130] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Juniperus communis formations on heaths or calcareous grasslands [5130]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
West Connaught Coast SAC (002998)
Bottlenose Dolphin (Tursiops truncates)
Structures do not pose a risk to dolphin either because of dolphin’s ability to avoid in subtidal areas and shallow nature of intertidal sites – excluded from further analysis
Newport River SAC (002144) Freshwater pearl mussel (Margaritifera margaritifera) [1029]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Salmon (Salmo salar) [1106] Migrating salmon passing through Clew Bay Complex SAC - carry forward to Section 8.
16
NATURA SITE QUALIFYING FEATURES [HABITAT/SPECIES CODE] AQUACULTURE INITIAL SCREENING
Northern Atlantic wet heaths with Erica tetralix [4010]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Blanket bog (*active only) [7130] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Oldhead Wood SAC (000532)
European dry heaths [4030] No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
Old sessile oak woods with Ilex and Blechnum in British Isles [91A0]
No spatial overlap or likely interaction with aquaculture in Clew Bay Complex SAC – excluded from further analysis
17
5 Details of the proposed plans and projects
5.1 Aquaculture
Aquaculture in Clew Bay Complex SAC focuses primarily on shellfish species (oysters and mussels,)
with 5 locations dedicated to the culture of Atlantic Salmon (Figure 5). In addition, a single land-based
aquaculture licence (fish hatchery) is held adjacent to the Coastal Lagoon (Furnace Lough).
Descriptions of Spatial extents of existing and proposed activities within the qualifying interest (Mudflats
and sandflats not covered by seawater at low tide (1140) and large shallow inlets and bays (1160) of
Clew Bay Complex SAC were calculated using coordinates of activity areas in a GIS. The spatial extent
of the various aquaculture activities (current and proposed) overlapping the habitat features is
presented in Table 3 (data provided by DAFM). It must be noted that many of the applications for
shellfish culture in Clew Bay represent realignment or expansion of existing licenced sites. In effect, if
the applications are granted, then the existing licences would be surrendered; therefore, the total spatial
coverage of activities (sites) on habitat features presented on final row in Table 3 represents a
‘corrected’ total of the maximum level of proposed activity in the Clew Bay Complex SAC. In addition,
the access routes for those sites not accessed by boat are also provided in Figure 5. These routes are
typically single or double tracks that run along the most stable shore from the point of entry to the
aquaculture sites. Given the necessity for stability, the routes are not always the most direct. An
estimate of the spatial extent of access routes based upon a putative width of 10m and linear extent is
included in Table 3.
5.1.1 Oyster Culture
Currently there are 52 licenced sites for aquaculture in Clew Bay. These range from 1 each for scallop,
abalone and lobster, 5 for rope mussels, 33 for intensive intertidal culture of oysters, 5 for extensive on-
bottom culture of triploid oysters and 5 for salmon culture. There are currently 9 applications for the
culture of intertidal oysters and one for a realignment of a rope mussel culture site.
A single species forms the basis of oyster aquaculture operation in Clew Bay Complex SAC, i.e. the
Pacific oyster, Crassostrea gigas.. Pacific oysters have been grown successfully in Clew Bay since
completion of trials in 1984. They are grown intensively using the traditional bag and trestle method
within the intertidal zone. Trestles used in Clew Bay are both 5-bag and 6-bag trestles. They are made
from steel and measure between 3 and 4 metres in length, are approximately 1 metre in width and
stand between 0.5 and 0.7 metre in height. Oyster bags are made of a plastic (HDPE) mesh, and vary
in mesh size (4mm, 6mm, 9mm and 14 mm) depending on oyster stock grade. The bags are fastened
to the trestles with rubber straps and hooks. Trials took place in the 1990’s using cylindrical containers
and baskets called ‘Ortecs’ which hung from modified trestles.
The Pacific oyster is a bivalve mollusc that filter feed plankton and other organic matter from the sea
when submerged during high tide periods. All the Clew Bay pacific oysters farms are positioned
between mean Low Water Spring and mean Low Water Neap, allowing on average between 2 and 5
18
hours exposure depending on location, tidal and weather conditions. Maintenance activities on-site
include shaking and turning of bags, and hand removal of fouling and seaweed to ensure maintenance
of water flow through the bags when submerged.
The production cycle begins in Clew Bay when G4 to G8 (6 – 10 mm, respectively) oyster seed is
introduced from UK and French hatcheries. On rare occasions seed comes in at a smaller size of less
than 4 mm and are put into 2 and 3 mm plastic mesh pouches within 4mm oyster bags where they
remain for few months until they reach 6 mm and are ready to be transferred to the 4 mm oyster bag.
In the past Diploid oyster seed has also been sourced from 2 Irish hatcheries – Cartron Point Shellfish,
Co. Clare and Boet Mor Seafoods, Co. Galway.
All seed and larger oysters brought into the Bay have to be sourced from a hatchery as per instruction
of the Clew Bay Oyster Co-operative and as agreed under the Clew Bay CLAMS Code of Practice
(below). To date, none of the growers have witnessed or are aware of any successful settlement and
recruitment of pacific oysters to the wild as a consequence of diploid culture within the Bay.
Hatcheries from which seed are sourced in recent years are:
Seasalter, England
Guernsey , Channel Isles
France Naissain, France
France Turbo, France
Satmar, France
Gran Ocean, France
There has been a general shift in the Bay in moving totally or almost totally away from using diploid
seed sourced from the UK hatcheries. Since 2008 the majority of the seed is from French hatcheries
and is over 80% Triploid. While in the past, seed was generally imported in the spring time, it is now
imported between February and June and between August and October. This change has been brought
about because of high demand on hatchery seed. Therefore, sourcing of seed is often dependent on
availability.
Since 2008, the majority of the oyster producers in the Bay have concentrated on producing ½ grown
oysters (20g – 45g) for selling onto other Irish and French oyster producers. Approximately 90% of the
seed introduced into the Bay each year is now transferred out of the Bay within 18 months. One
producer is also contract growing for another producer from another Irish bay. In this instance, oysters
are introduced into Clew Bay during the spring at a size 10 to 25 gram and are grown for one year after
which they are transported back to original bay for finishing off for market. Oysters that remain in the
bay for further on-growing reach market size of 65 gram plus within on average 3 years.
Stocking densities and stock management (thinning, splitting and grading stock) varies with each oyster
producer. In general grading and exporting of ½ grown oysters takes place from September to April,
and harvesting of stock for mature oysters for market takes place from October to May. Initial stocking
densities when deployed into 4mm bags can vary from 800 up to 5000 oyster seed per bag. As the
oysters grow stocking densities are reduced. Generally seed if stocked over 2000/bag is split in the
first couple of months to lower density and by the end of year one the density is between 400 and 1000
oysters per bag. By the time they reach market size of 66 gram plus in year 3, the stocking density is
19
down to between 100 and 150 per bag. Thinning, grading and harvesting activities entails removing
oyster bags from the trestles by hand and transporting them on tractor and trailers or boat from the
intertidal zone to the grower’s land based facilities almost all located on the shore around Clew Bay.
The two main pacific oyster production areas within Clew Bay are Tiernaur and Murrisk. There are also
4 individual farms located in Inner Clew Bay in Kilmeena – Carrowholly area and there are 2 licences
on 2 islands (Clynish and Inishraher).
Tiernaur: The Tiernaur pacific oyster growing area is located in the north of the Bay and this is where
the majority of the ½ grown oysters are produced. There are 4 producers here, one whom has also a
site in Clew Bay South. Three of the producers observe one dedicated access route out from shore
access point to their general site area and at any one time there will up to 5 tractors and trailers in this
growing area of Tiernaur. The sites here are accessed on average between 12 and 18 days per month
depending on time of year. The other producer uses a different dedicated access route to his farm as
it is located further east. They only use the tractor and trailer at times of collecting stock for grading
and sales, otherwise the site is accessed by foot.
Murrisk: The Murrisk pacific oyster growing area is located in the south of the Bay. There are 3 active
producers in this area who observe three dedicated access routes from the shore access points and a
land based facility. At any one time depending on times of grading and selling stock there can be up
to 3 tractors and trailers operating across the area. The sites here are accessed up to a maximum 12
days each month. On days the tractors and trailers are not required, producers access sites by foot.
The remaining intertidal growing areas in Clew Bay are located in the Kilmeena-Carrowholly general
area, (plus 2 sites located on 2 islands) and are all single individual producers. Almost all are based
adjacent to their land based facilities. One of the main producers uses a flat bottom boat to access and
work on site rather than a tractor and trailer.
5.1.2 Subtidal Oyster culture
Subtidal extensive culture of oysters involves the placement of oysters in an uncontained fashion on
the seabed after a nursery phase in the intertidal zone. It is proposed that suitably sized shellfish are
spread within the licenced area. Stock will be checked periodically when the progress (growth and
mortality) of the stock will be monitored and intervention will be necessary if anomalies are discovered.
For example, shellfish may need turning-over if excessive fouling or siltation is noted on the animals.
Such intervention, as well as harvesting, will be carried out using oyster dredges deployed from boats.
The oyster dredges are typically 1.5m wide and have contact with the substrate via a flat blade. Harvest
is expected 24-36 months after initial seeding for oysters. This may be shorter depending upon the size
of the seed and the production capabilities of the area in question.
5.1.3 Rope Mussels
Trials on rope mussel (Mytilus edulis) farming began in Clew Bay in 1979, and initially generated only
a few tonne. Today there is only one producer who has been operating in the bay since 1984. The
company operate on two licensed sites, one located north of Inishlaughil within Inner Clew Bay, and the
20
other on a more exposed site beside Moynish Beg in Clew Bay North. All mussel grading and packing
equipment and machinery are on-board their adapted mussel boat. From time to time during busy
periods they also use another vessel for general maintenance on site. Site access is generally from
Inishcottle pier, located just over 1 km south of the farm and occasionally from Rosmoney pier further
south. All mussel seed is collected on lines deployed for this purpose within the licensed sites in Clew
Bay. No mussel seed is imported to the bay from other areas.
The method of production used by this company from 1984 to 2004 was the traditional double headed
longline and single dropper system which involved placing naturally collected local mussel seed
(collected on mesh and rope) into plastic mesh stockings , known as pergolari. These stockings were
suspended in the water column on floating rope long-lines and mussel floats.
In 2004 the company adapted the New Zealand continuous longline system of cultivation. This
automated method involves continuous seeding of entire loops of culture rope over 200 metres in length
rather than the single dropper system. This system where packing and harvesting is mechanised,
allows mussel farmers to produce a high value seafood product efficiently, using environmentally
sustainable techniques. The grow ropes (which the mussels attach to) can be recycled and re-used for
many years. The collector mesh or cotton stocking – that holds the mussels to the rope while they adapt
to their new environment - is biodegradable. The Clew Bay mussel producer which produce organic
mussels in accordance with EU Organic Regulations, has further grown its business and now produces
this cotton mesh at their land based facility in Westport to supply the Irish and European rope mussel
industry.
Rope mussels like other bivalve molluscs obtain their food by filtering microscopic algae from the water
column. Mussel seed / spat are collected on site in Clew Bay between May and June and reaches
market size within 24 months. During this grow cycle the mussels can be graded up to three times and
this allows the almost continuous supply of market size mussels all year round. The majority of the
product is delivered directly by boat into one of the main Irish shellfish and mussel processors and
exporters located on the shore of inner Clew Bay.
There are currently aquaculture licence applications for an additional two rope mussel farms to be
located within Inner Clew Bay from applicants who have been involved in the aquaculture industry in
the past.
5.1.4 Salmon Culture
Finfish farming began in inner Clew Bay in 1975 and in the outer bay at Clare Island in 1986. Both
Salmon (Salmo salar) and Rainbow trout (Oncorhynchus mykiss) were grown at sites in inner Clew Bay
up until 2011. Today production is only salmon and all production is from a single company, MOWI,
who produce certified organic salmon in accordance with the EU Organic Regulations. The company
is a fully integrated salmon farm who operates at sites in Counties Donegal, Mayo, Kerry and Cork.
Marine Harvest Ireland carries out all phases of their salmon business, starting with the taking of ova
from broodstock to the harvesting and packaging of the final product.
21
The production cycle starts in freshwater hatcheries in Co. Donegal where ova are stripped and fertilised
from broodstock fish from Mulroy Bay in early winter, typically November. The company has 3
hatcheries and 2 smolt production units in Co. Donegal that produce the young salmon which are ready
to go to sea at the smolt stage of the salmon lifecycle. Marine Harvest Ireland produces both Spring
and Autumn smolts.
In Co. Mayo, Marine Harvest Ireland operate from 4 sea sites in Clew Bay - two at Clare Island and two
at Inner Clew Bay. One of the Clare Island sites is used for rearing the Donegal supplied smolts. As
they grow the salmon are transferred to the other Clare Island site. Once at sea the smolts are reared
to market size in nets suspended from circular floating structures known as pens. These are moored
in groups in locations where there are strong water flows in order to provide the stock with optimum
environmental conditions. The company uses automatic feeding systems in conjunction with
underwater camera for observation of fish feeding behaviour. The feeding systems are calibrated daily
by site staff, in accordance with fish appetite and environmental conditions.
The two site areas within Inner Clew Bay are used for ongrowing salmon. Typically the salmon are
transferred from the Clare Island sites to these Inner Bay sites in September of every year and are
reared for up to eight months or slightly longer until they reach harvest size. Usually the Inner Bay sites
are only used for eight months of the year and remain fallow for four months from June to September.
These inner sites are accessed from Roigh Pier on the north of Clew Bay and on occasion from the
company’s shore base located beside Cloghmore Pier, South Achill Island. When the salmon are ready
for market, at size greater than 3 kg, they are transferred from the sea pens into a well-boat to a harvest
(stun & bled) unit first before they are transferred by road tankers to the company’s processing unit in
Co. Donegal. No blood or effluent from the harvest process is discharged back to sea as it is collected
with the harvest fish in the road tankers and disposed of in the company’s licensed effluent treatment
plant at the processing plant.
5.1.5 Scallop
Initial trials in the cultivation of King scallop (Pecten maximus) began in the 1990s and continued into
the 2000s. Seed scallop was sourced from natural wild settlement (Mulroy Bay) or from a hatchery
(Cartron Point, Co. Clare) and were put into protective enclosures or suspended on long-lines until they
reached size of 40mm plus, after which time they were placed on the seabed in frames or under
protective covering until they reached maturity within 4 to 5 years and marketable size of greater than
100mm in width. The sporadic supply of scallop seed on an annual basis over the past 10 years has
meant that production in the bay on these sites is only on a small scale. The current licence relays seed
at size 40mm directly onto seabed in low stocking densities. The market size scallops are harvested
by divers.
5.1.6 Clew Bay Seaweed Cultivation
It is proposed to cultivate seaweed within as site already licensed for the culture of rope mussels
Blackshell Farms Ltd. wish to grow seaweed – ( various red, brown and green seaweeds) on the
northern section of site T10/301A. The area size for this project is circa 3 hectares. The intensive
22
cultivation of seaweed on longlines is relatively new to Ireland. Currently there are few sites growing
kelp seaweed species using the single headrope longline system and other new systems.
Seeded nets and string will be sourced from Irish Hatcheries e.g. Bantry.
The growing system consists of a grid 160 metres by 65 metres , using 9 X 1100 litre buoys. There will
be 32 hanging seaweed growing nets wich will measure 4 metres in depth and 80 m in length. The grid
will use 36mm polysteel gridrope and steel grid rings to keep whole grid in shape. The seaweed will
be harvested using the Company’s existing mussel workboat and equipment. The lines and nets will
be stripped of seaweed at site and packed into one tonne bags and brought ashore where it will be
dried and processed.
All floatation buoys will be grey in colour and site is already marked with yellow special markers with
approval of CIL and MSO.
5.1.7 Clams
In the late 1980s and early 1990s the Manilla Clam – (Venerupis philippinarum) was grown in two
intertidal area on a few sites in Clew Bay in bags, tray mesh containers and on the seabed in clam
parks and under mesh. Seed was imported from hatcheries (Co. Sligo and Seasalter,UK) at size 8mm
– 12mm and grown in trays and bags for one year after which time they were sown on intertidal ground
under mesh. They reach adult market size within a year.
Today clams are only grown on a very small scale, less than 1 tonne per annum on one site alongside
pacific oysters in inner Clew Bay. They are locally sourced as seed or at juvenile stage and are grown
in oyster bags on the ground and on trestles on the lower intertidal ground area. Some are grown
directly on ground and are harvested by hand. They are sold onto the local and regional retail
marketplace.
5.1.8 Abalone
The abalone also known as Ormer is not native to Ireland and will not breed in our colder waters. It
looks like a limpet, in that it has one shell. Both the European abalone –Haliotis tuberculata and
Japanese – Haliotis discus have been introduced into Ireland. Trials began on abalone in the early
1980's and Clew Bay was host in the 1990s to the only on-growing sea site in Ireland. The juvenile
abalone were put into protective containers and cages and were fed Laminaria (kelp) and Palmaria
(dillisk), by divers, every two weeks in summertime and every four to six weeks in the winter. The growth
cycle is about five years and the principle market, was an established local and Irish market.
The cultivation of abalone in Clew Bay ceased in the early 2000s but there is currently a single licence
for on-growing the European Abalone in new structures at a new site adjacent to one the islands,
Inishcorky, in the north of the Bay. This project proposes to import juvenile abalone from a French
hatchery, at size 15mm and ongrow them in plastic containers called ‘Ortacs’ in an area below the low
water mark. The Ortacs will be suspended between one and three metres above the seabed on
longlines in the water column with use of floats. The abalone will be fed fortnightly with natural dried
and sterilised macroalgae (Laminaria and Palmaria) imported from Spain and UK. It is envisaged that
23
they will reach market size of 50 mm plus in this system within 4 years. The site will be accessed
primarily from Roigh Pier which is located less than 4km to the northeast of the site. The activity at this
site has been subject to a full risk assessment under Council Regulation (EC) No 708/2007 concerning
use of alien and locally absent species in aquaculture.
5.1.9 Lobster
A trial licence existed in the mid-2000s at site south of Island More for the cultivation of Lobster
(Homarus gammarus) using galvanised steel trestles on the seabed. A new application for the
cultivation of lobster and crawfish (Palinurus elephas) has been lodged using plastic trestles on the
seabed in lines. It is proposed that small lobster and crawfish bought from local fishermen at legal size
would be placed in individual plastic containers with galvanised mesh and frames on the seabed. They
will be fed, e.g. with mussels and other food, by hauling the frames to the sea surface using a boat.
They can also be fed with use of a diver. As in the trial the lobster will increase in biomass by 30%
within 6 to 8 months and will be ready for the Christmas export market.
5.1.10 Hatchery Operations
A single licence is held for the cultivation of salmon, rainbow trout and brown trout at a facility on the
shore of Lough Furnace (Coastal Lagoon). The system is entirely land based with water extracted from
Lough Feeagh and discharged into Lough Furnace after treatment. The hatchery is licenced to produce
up to 250,000 smolts pa. The discharge is fully treated and the facility is in possession of a licence to
discharge to surface waters consented by Mayo County Council.
5.1.11 Clew Bay CLAMS
The Clew Bay CLAMS Group which was established in 2001, is composed of representatives of all
bona fida aquaculture interests such as the finfish and shellfish producers, the Clew Bay Oyster Co-
operative, the Clew Bay Marine Forum, liaison officers and relevant BIM and Marine Institute officers.
The Clew Bay CLAMS Document was drawn up in late 2001. The CLAMS process initiated a ‘Code of
Practice’ document which was published in 2003. The primary aim of the Code of Practice is to further
promote the responsible development and management of the Clew Bay Aquaculture Sector, assuring
the highest standards of quality food production while respecting environmental considerations,
consumers’ demands and other bay users. It covers matters relating to Stock Health Management,
Site Management, Visual Impact, Navigation, Environmental Monitoring, Use of Public Pier, Waste
Management, Nature Conservation, Health & Safety and Communication. An example of two of the
agreed terms from the Clew Bay CLAMS Code of Practice are:
‘No oyster stock must be imported in Clew Bay, which has originated in France as wild seed
stock’.
To use a single access route to intertidal sites, minimise journey trips and drive slowly in order
to minimise disturbance and any potential damage to existing benthic flora and fauna.
24
Figure 5: Aquaculture sites (Licenced and Applications) and access routes in Clew Bay Complex SAC (access routes not drawn to scale)
25
Table 3: Spatial extent (ha) of aquaculture activities overlapping with the qualifying interest (1140 -Mudflats and sandflats not covered by seawater
at low tide and 1160-Large shallow inlets and bays) in Clew Bay Complex SAC, presented according to culture species, method of cultivation and
license status.
Species Status Location
1140 - Mudflats and sandflats not covered by
seawater at low tide (1,277ha)
1160 - Large shallow inlets and Bays (10,198ha)
Area (ha) % Feature Area (ha) % Feature
Oysters Licensed Intertidal 57.72 4.52 171.2 1.68
Oysters Application Intertidal 6.27 0.49 22.6 0.22
Mussels Licensed Subtidal - - 64.5 0.63
Mussels Application Subtidal - - 60.55 0.60
Finfish Licensed Subtidal - - 15.96 0.16
Scallops Licensed Subtidal - - 4 0.04
Lobster Licensed Subtidal - - 1.0 <0.001
Abalone Licenced Subtidal - - 2.64 0.03
Access Routes 6.71 0.53 10.09 0.1
Corrected Totals* 70.7 5.54 352.54 3.42
*Corrected Totals refer to total spatial coverage of activity that will occur if certain licenced sites are surrendered on foot of successful new applications or realignment of sites (see Section 5.1) and do not reflect the sum of columns in the table.
26
5.2 Fishing activities
Fishing activities in Clew Bay were profiled through a questionnaire survey completed by BIM in 2011,
this is still the most current information upon which to base as risk assessment. There were 26 vessels
fishing in the Clew Bay area in 2011 and information on all 26 are included in the descriptions below.
Not all 26 vessels fish within the SAC. Vessels range in size from 4.9 to 18m but 25 are less than 12m
and 21 and less than 10m. At least 15 fish species are targeted across 11 métiers (gear_target species
combination). Gears used include shrimp pots, lobster creels, top entry pots, prawn pots, dredges,
tangle nets, trammel nets, gill nets, bottom trawls, mid-water trawls, various forms of hooks and lines
and hand gathering. Individual operators may target different species (belong to different métiers) in
different seasons.
5.2.1 The fleet
The fishing fleet operating in Clew Bay is an inshore fleet (Table 4). There are 26 vessels varying in
size from 4.95-12m with one exception which is 16.6m in length. Twenty one vessels are under 10m
and 4 between 10-12m. Sixteen of the vessels have polyvalent licences which allows them access to
all commercial species fished in the bay other than oyster which also requires a secondary licence
which is issued by IFI. Seven of the vessels are restricted to using pots only (so called P licences) and
3 vessels are licenced in the Aquaculture segment of the fleet. Aquaculture vessels may dredge for
oysters provided they have an IFI oyster permit.
Table 4: The inshore fishing fleet in Clew Bay
Vessel type
Port Decked Half
decked Open Total
Westport 6 6
Clare Is 1 1
Mulranny 2 1 3
Newport 1 1
Inis Lyre Is 1 1
Roigh 1 2 2 5
Clynish Is 1 1 2
Old Head 1 1 2
Cloghmore 2 2
Murrisk 1 1
Kilmeena 2 2
Total 19 2 5 26
27
5.2.2 Potting for shrimp
Fifteen vessels fish for shrimp using a total of approximately 6900 shrimp pots (Figure 6). The pots are
fished in strings of 20-30 pots which are interconnected on the seabed by rope. The gear is in the water
during the shrimp open season from Aug 1st to April 31st although fishing effort is much lower in spring
from February onwards. Each set of gear may be hauled 3 days per week depending on weather, catch
rates and market conditions. Pots are baited with frozen mackerel, herring and scad which is purchased
ashore. Some fishermen fish for bait using trammel nets to catch wrasse, dogfish and whitefish.
Although shrimp are fished throughout the bay at some time during the season vessels tend to have
their own areas or territories and effort is higher in shallow areas in the inner bay in the period Aug-Oct
and in deeper water outside the SAC area from November onwards. This pattern follows the migration
of shrimp to deeper water as temperatures decline.
Figure 6: Distribution of shrimp fishing, derived from expert data, in relation to Clew Bay SAC
5.2.3 Potting for prawns
A small scale pot fishery for prawns occurs in the middle area of the bay in mud and sandy mud
substrates (Figure 7). Three fishermen are involved on a seasonal basis. The fishery occurs in May and
again from October to December. Pot numbers vary from 300 in May to 1150 in October-December.
Prawns are landed and sold live. Significant high grading on the vessels occurs whereby a significant
proportion of small prawns are returned alive to the sea.
28
Figure 7: Distribution of fishing for lobster, crab and prawns in relation to the Clew Bay SAC
5.2.4 Potting for crab and lobster
A total of 16 fishermen use soft eye creels to fish for lobster and brown crab and velvet crab. Seven of
these fishermen also use top entrance pots for spider crab. Pot numbers per vessel varies from 250-
600. The gear is fished throughout the year with higher levels of activity in the period Apr-Sept. Pot
numbers reach 4800 in mid-summer. Lobster is the primary species for 16 of the 26 fishermen in the
Bay.
5.2.5 Potting for whelk
A new pot fishery for whelk began in 2013 with 2 vessels operating 400 pots each. The fishery occurred
from the estuary of the Newport River seaward to deeper waters and on sub-tidal sedimentary habitats.
The stock has apparently declined and is unlikely to support a fishery.
5.2.6 Tangle netting for crayfish
Three fishermen fish for crayfish with tangle nets and use a total of 11km of nets. Approximately 3km
is used in the SAC and 8km in other areas of Clew Bay (Figure 8). Peak fishing time occurs from May-
Sept and nets are in the water from Apr to Nov. The gear is in the water for prolonged periods and
probably over 20 days per month.
29
Figure 8: Distribution of tangle netting for crayfish in relation to the Clew Bay SAC
5.2.7 Gill netting for Pollack and other netting
Set gill nets are used to target mainly Pollack. In Clew Bay 5 vessels use approximately 7.6km of gill
nets (Figure 9).
An estimated 3km may be used in the SAC. The fishery is active from Jan-Sept but mainly from May-
Aug.
Drift netting for mackerel is carried out by 1 vessel for approximately 10 days per month during May to
Sept.
30
A number of fishermen in 6m vessels set drift nets for herring in autumn in the inner Bay. Catches are
generally low and amount to 3-4 boxes per vessel for the season.
Figure 9: Distribution of Pollack and mackerel gill netting and trolling in relation to the Clew
Bay SAC
5.2.8 Dredging for scallop
Scallops are mainly fished in autumn and winter in Clew Bay (Figure 10). However, of the 10 fishermen
who may fish for scallops two indicated they fish for 8 months of the year. Scallop occurs in shallow
cobble and gravel substrates at 10-20m depth surrounding islands in the inner Bay and in deeper water
outside the SAC. The fishery may be restricted and closed periodically due to high levels of biotoxins
in the flesh of scallops which prohibits their sale in to the market.
Figure 10: Distribution of scallop fishing, derived from survey data and expert data, in relation
to Clew Bay SAC
31
5.2.9 Dredging for oyster
There was previously an important fishery for native oyster in Clew Bay (Figure 11). The stock is now
depleted but a limited commercial fishery occurs in the autumn of each year. The spatial extent of the
fishery is not definitely known but recent survey data indicates the probable distribution of areas which
have commercial, albeit at low densities, quantities of oysters. Native oyster was listed as top priority
species for 3 fishermen in Clew Bay in 2011. Oysters are fished from vessels under 10m in length using
fixed toothed dredges. One dredge, measuring approximately 1.2m in width, is used by each vessel.
Licences to fish for oyster are issued annually by IFI. Six licences were issued in 2013 for the Ballinakill
area which includes the south side of Clew Bay and Clare Island. 49 licences were issued in the Bangor
district which includes north side of Clew Bay and other areas north of Clew Bay.
Figure 11: Distribution of oyster fishing, derived from survey data, in relation to Clew Bay SAC
5.2.10 Bottom trawling for mixed demersal fish
The bottom trawl fishery targets a wide range of species including monkfish, prawns, whiting, haddock,
pollack, skates, rays, john dory and gurnard (Figure 12). Four vessels are involved. The fishery
operates year round in sandy substrates in the outer middle and north of the bay.
32
Figure 12: Distribution of bottom trawl fishing, derived from VMS data (vessels >15m) and
expert data, in relation to Clew Bay SAC
5.2.11 Mid-water trawling for pelagic fish
No local boats are involved in the pelagic fishery (Figure 13). Larger pelagic vessels from Killybegs,
Rossaveal and Castletownbere often fish the outer Bay in late autumn and winter.
Figure 13: Distribution of mid-water trawling as shown by VMS data (vessels>15m).
5.2.12 Hook and line fishing for mackerel and Pollack
This fishery uses a wide variety of gears best described as trolling lines and bottom set lines operated
from mechanized and manual jigging machines. Sixteen vessels report using some form of
trolling/jigging gears. Activity is concentrated in the period May to Oct.
33
5.2.13 Draft net fishing for salmon
The maximum number of fishing licences for salmon, using draft nets, in District number 10 (Ballinakill
and Bangor) in 2013 was 40. Such licences, if activated could fish for salmon in rivers estuaries within
the district where salmon stocks have exceed their conservation limits (as determined by the Salmon
Standing Scientific Committee) and there is a surplus of fish to be taken and if a proportion of that
surplus is allocated to draft net fishing (SI 75/2013, Schedule 1).
In reality only 1 draft net licence operated in Clew Bay in 2012. This was fished in the Newport river
estuary in June-July. The TAC was limited to 50 fish. In addition a private licence, to fish for draft net,
exists in the Bunowen River on the south east corner of the Bay again when the salmon stock exceeds
conservation limit.
5.2.14 Trammel net fishing for bait
Although the majority of pot fishermen purchase bait (frozen pelagic) ashore some fishermen use
trammel nets to fish for wrasse, pollack and dogfish which are used as bait in pots. The fishery is likely
to occur at the edges of reef areas and may be more localized than indicated in Figure 14.
Figure 14 Distribution of trammel netting for bait in relation to the Clew Bay SAC.
5.2.15 Hand gathering of periwinkle and cockle
Fishing for periwinkle is common and sometimes intensive in the inner Bay on semi exposed shores on
the mainland and on islands in the Bay (Figure 15). The spatial distribution and intensity of the activity
is not known.
Cockles are common and sometimes abundant in an area east of Mullranny on intertidal muddy sand
shores. There is no commercial dredge fishery for cockles in this area but some hand gathering may
occur.
34
Figure 15: Distribution of cockle stocks, derived from survey data, in Clew Bay SAC
35
6 Natura Impact Statement for the proposed activities
The potential ecological effects of activities on the conservation objectives for the site relate to the
physical and biological effects of fishing gears or aquaculture structures and human activities on
designated species, intertidal and sub-tidal habitats and invertebrate communities and biotopes within
those broad habitat types. The overall effect on the conservation status will depend on the spatial and
temporal extent of fishing and aquaculture activities during the lifetime of the proposed plans and
projects and the nature of each of these activities in conjunction with the sensitivity of the receiving
environment.
6.1 Aquaculture
Within the qualifying interest of Clew Bay Complex SAC, the species cultured are:
1. Oysters (Crassostrea gigas), in suspended culture (contained in bags & trestles) confined
primarily to intertidal areas.
2. Mussels (Mytilus edulis) in suspended culture in subtidal areas.
3. Oysters (Crassostrea gigas) subtidally on the seafloor.
4. Clams (Venerupis philippinarum) intertidally on the seafloor.
5. Scallop (Pecten maximus) in suspended culture in subtidal areas.
6. Lobster (Homarus gammarus) in subtidal areas.
7. Abalone (Haliotis sp.) in subtidal areas.
8. Atlantic salmon (Salmo salar) in net pens.
Details of the potential biological and physical effects of these aquaculture activities on the habitat
features, their sources and the mechanism by which the impact may occur are summarised in Table 5,
below. The impact summaries identified in the table are derived from published primary literature and
review documents that have specifically focused upon the environmental interactions of mariculture
(e.g. Black 2001; McKindsey et al. 2007; NRC 2010; O’Beirn et al 2012; Cranford et al 2012; ABPMer
2013a-h).
Filter feeding organisms, for the most part, feed at the lowest trophic level, usually relying primarily on
ingestion of phytoplankton. The process is extractive in that it does not rely on the input of feedstuffs in
order to produce growth. Suspension feeding bivalves such as oysters and mussels can modify their
filtration to account for increasing loads of suspended matter in the water and can increase the
production of faeces and pseudofaeces (non-ingested material) which result in the transfer of both
organic and inorganic particles to the seafloor. This process is a component of benthic-pelagic coupling
(Table 5). The degree of deposition and accumulation of biologically derived material on the seafloor is
a function of a number of factors discussed below.
One aspect to consider in relation to the culture of shellfish is the potential risk of alien species arriving
into an area among consignments of seed or stock sourced from outside of the area under
consideration. When the seed is sourced locally (e.g. mussel culture) the risk is likely zero. When seed
36
is sourced at a small size from hatcheries in Ireland the risk is also small. When seed is sourced from
hatcheries outside of Ireland (this represents the majority of cases particularly for oyster culture
operations) the risk is also considered small, especially if the nursery phase has been short. When ½-
grown stock (oysters and mussels) is introduced from another area (e.g. France, UK) the risk of
introducing alien species (hitchhikers) is considered greater given that the stock will have been grown
in the wild (open water) for a prolonged period (i.e. ½-grown stock). It is important to note that the
importation of ½-grown wild oysters into Clew Bay is prohibited under Fishery Order Cooperative rules
and CLAMs agreement (see Sections 5.1.1 and 5.1.10 above). Furthermore, the culture of a non-native
species (e.g. the Pacific Oyster - Crassostrea gigas) may also presents a risk of establishment of this
species in the SAC. Recruitment of C. gigas has been documented in a number of Bays in Ireland and
appears to have become naturalised (i.e. establishment of a breeding population) in two locations
(Kochmann et al 2012; 2013) and may compete with the native species for space and food. The culture
of large volumes of Pacific oysters may increase the risk of successful reproduction in Clew Bay
Complex SAC. The use of triploid (non-reproducing) stock is the main method employed to mange this
risk. To date, no settlement of Pacific oysters has been reported in Clew Bay.
Suspended Shellfish Culture: Suspended culture, may result in faecal and pseudo-faecal material
falling to the seabed. In addition, the loss of culture species to the seabed is also a possibility. The
degree to which the material disperses away from the location of the culture system (longlines or
trestles) depends on the density of mussels on the line, the depth of water and the current regime in
the vicinity. Cumulative impacts on seabed, especially in areas where assimilation or dispersion of
pseudofaeces is low, may occur over time. A number of features of the site and culture practices will
govern the speed at which pseudofaeces are assimilated or dispersed by the site. These relate to:
1. Hydrography – will governs how quickly the wastes disperse from the culture location and the
density at which they will accumulate on the seafloor.
2. Turbidity in the water - the higher the turbidity the greater the production of pseudo-faeces and
faeces by the filter feeding animal and the greater the risk of accumulation on the seafloor.
3. Density of culture – suspended mussel culture is considered a dense culture method with high
densities of culture organisms over a small area. The greater the density of organisms the
greater the risk of accumulations of material. The density of culture organisms is a function of:
a. depth of the site (shallow sites have shorter droppers and hence fewer culture
organisms),
b. the husbandry practices – proper maintenance will result in optimum densities on the
lines in order to give high growth rates as well as reducing the risk of drop-off of culture
animals to the seafloor and sufficient distance among the longlines to reduce the risk
of cumulative impacts in depositional areas.
In addition, placement of structures associated with mussel culture can influence the degree of light
penetration to the seabed. This is likely important for organisms and habitats e.g. maerl and seagrasses
which need sun light for production. Rafts or lines will to a degree limit light penetration to the sea bed
37
and may therefore reduce production of photosynthesising species. However, such effects have not
been demonstrated for seagrass.
Intertidal Shellfish culture: Oysters are typically cultured in the intertidal zone using a combination of
plastic mesh bags and trestles. Their specific location in the intertidal is dependent upon the level of
exposure of the site, the stage of culture and the accessibility of the site. The habitat impact from oyster
trestle culture is typically localised to areas directly beneath the culture systems. The physical presence
of the trestles and bags may reduce water flow and allowing suspended material (silt, clay as well as
faeces and pseudo-faeces) to fall out of suspension to the seafloor. The build-up of material will typically
occur directly beneath the trestle structures and can result in accumulation of fine, organically rich
sediments. These sediments may result in the development of infaunal communities distinct from the
surrounding areas. Whether material accumulates is dictated by a number of factors, including:
1. Hydrography – low current speeds (or small tidal range) may result in material being deposited
directly beneath the trestles. If tidal height is high and large volumes of water moved through
the culture area an acceleration of water flow can occur beneath the trestles and bags, resulting
in a scouring effect or erosion and no accumulation of material.
2. Turbidity of water – as with suspended mussel culture, oysters have very plastic response to
increasing suspended matter in the water column with a consequent increase in faecal or
pseudo-faecal production. Oysters can be cultured in estuarine areas (given their polyhaline
tolerance) and as a consequence can be exposed to elevated levels of suspended matter. If
currents in the vicinity are generally low, elevated suspended matter can result in increase
build-up of material beneath culture structures.
3. Density of culture – the density of oysters in a bag and consequently the density of bags on a
trestle will increase the likelihood of accumulation on the seafloor. In addition, if the trestles are
located in close proximity a greater dampening effect can be realised with resultant
accumulations. Close proximity may also result in impact on shellfish performance due to
competitive interactions for food.
4. Exposure of sites - the degree to which the aquaculture sites are exposed to prevailing weather
conditions will also dictate the level of accumulated organic material in the area. As fronts move
through culture areas increased wave action will resuspend and disperse material away from
the trestles.
Shading may be an issue as a consequence of the structures associated with intertidal oyster culture.
The racks and bags are held relatively close to the seabed and as a consequence may shade sensitive
species (e.g. sea grasses) found underneath.
Sub-tidal oyster culture: This activity involves relaying oysters on the seabed. There may be
increased enrichment due to production of faeces and pseudofaeces. The existing in-faunal community
may be changed as a result. Seabed habitat change may also result as a result of dredging during
maintenance and harvesting. Uncontained sub-tidal shellfish culture will lead to change in community
structure and function through the addition, at high % cover, of an epi-benthic species (living on the
seabed) to an infaunal sedimentary community.
38
The activities associated with this culture practice (dredging of the seabed) are considered disturbing
which can lead to removal and/or destruction of infaunal species and changes to sediment composition.
In addition, the location of large numbers of a single epifaunal species onto what is, in essence, an
infaunal dominated system will likely result in a change to the habitat.
Physical disturbance caused by compaction of sediment from foot traffic and vehicular traffic.
Activities associated with the culture of intertidal shellfish include the travel to and from the culture sites
and within the culture sites using tractors and trailers as well as the activities of workers within the site
boundaries.
Other considerations: Intertidal culture of clam species is typically carried out in the sediment covered
with netting to protect the stock from predators. The high density of the culture organisms can lead to
exclusion of native biota and the ground preparation and harvest methods (by mechanical means or by
hand) can lead to considerable disturbance of biota characterising the habitat.
Due to the nature of the (high density) culture methods the risk of transmission of disease within cultured
stock is high. However, given that Crassostrea gigas does not appear to occur in the wild the risk of
disease transmission to ‘wild’ stock is considered low. The risk of disease transmission from cultured
oysters to other species is unknown.
Introduction of Non-native species - All culture methods: Movement and introduction of bivalve
shellfish (and equipment) can be a vector for the introduction and spread of non-native/alien species.
In some instances the introduced species may proliferate rapidly and compete with and in some cases
replace the native species. Recruitment of C. gigas has been documented in a number of bays in Ireland
and appears to have become naturalised (i.e. establishment of a breeding population) in some
(Kochmann et al., 2012; 2013) and may compete with the native species for space and food.
Another means is the unintentional introduction of non-native species/diseases which are associated
with the imported target culture species (or equipment), and their subsequent spread and
establishment. These associated species are referred to as ”hitch-hikers” and include animals and
plants and/or parasites and diseases that potentially could cause outbreaks within the culture species
or spread to other local species.
Finfish Culture: Finfish (Salmon) Culture: Within the Clew Bay Complex SAC there are five marine
sites and 1 terrestrial site assigned for the culture of salmon (and other finfish). The marine sites are all
located in the northern part of the Bay and the land-based site is located adjacent to the Furnace Lough
(Coastal Lagoon).
Finfish culture differs from shellfish culture in that there is an input of feed into the system and as a
consequence a net input of organic matter to the system. This material will be found in the system in
the form of waste feed (on the seafloor), solid waste (faeces), waste as a consequence of net-cleaning
all of which usually accumulates on the seafloor and dissolved material (predominantly fractions rich in
nitrogen). For the most part, the majority of organic material builds up on the seabed generally in and
around the footprint of the salmon cages with a ‘halo’ effect evident in areas where dispersion occurs
driven by local hydrographic conditions. This is typically referred to a near-field effects. Similar to
39
shellfish, the quantity of material that might accumulate on the seabed will be a function of the quantity
of fish held in cages, the stage of culture, the health of the fish (unhealthy fish will generally eat less),
husbandry practices (are the fish fed too much too quickly?), the physical characteristic of the solid
particles and, as mentioned above, hydrographic conditions.
Wildish et al. (2004) and Silvert and Cromey (2001) both summarize the factors (listed above) that
govern the level of dispersion of material from the cages to the seafloor. Many of the factors are
subsequently incorporated into modelling efforts which are used to predict likely levels of impact. The
impact of organic matter on sedimentary seafloor habitat (as found beneath fish structures in Clew Bay)
typically evolves after the gradient defined by Pearson-Rosenberg (1978), whereby as the level of
organic enrichment increases the communities (macrofaunal species number and abundance) found
within the sedimentary habitats will also change. Typically, low levels of enrichment facilitates an
increase in species abundance and biomass followed by a decrease in all biological metrics as
enrichment increases to a point where azoic conditions prevail and no biota are found. The impact on
biota is a consequence of the decrease in oxygen and a build-up of by-products such as ammonia and
sulphides brought about by the break down of the organic particles which are considered toxic to marine
biota. The shift from an oxygenating to reducing environment in the sediment could be such that the
effect is mirrored in the water column as well (i.e. reduction in oxygen levels). The output of dissolved
material resulting from finfish cages is typically in the form of ammonia, phosphorous and dissolved
organic carbon (DOC) originating directly from the culture organisms, or from the feed and/or faecal
pellets. Similar to particulate waste, the impact of dissolved material is a function of the extent (intensity)
of the activity and properties of the receiving environment (e.g., temperature, flushing time). While
elevated levels of nutrient have been reported near fish farms, no significant effect on chlorophyll has
been demonstrated (Pearson and Black, 2001).
Diseases: It is likely that the first outbreaks of infectious diseases in marine aquaculture operations
were caused by pathogens originating in wild hosts and as culture extent and intensity increases the
transmission of pathogens (back) to the wild fish stocks is a likely consequence (Jones et al., in prep).
The result of such pathogen transmission back to wild fish is however unknown, as reports of clinical
effects or significant mortality in wild fish populations are largely unavailable. Numerous reviews,
models, risk assessments and risk analysis have been carried out or developed in order to determine
the potential for disease interaction and pathogen exchange between farmed and wild finfish (OIE 2004,
Bricknell et al. 2006, DIPNET 2006, Peeler et al. 2007). On foot of these outputs there is general
acceptance among scientists and managers that pathogens can be transmitted between organisms
used in mariculture and those found in the wild and vice-versa (ICES 2013).
The risk of infection in marine organisms, are influenced by a number of environmental factors including
temperature, salinity and dissolved oxygen (Grant and Jones 2011), as well as factors particular to the
biology of pathogen, e.g., replication rates, virulence. Transmission of pathogens is facilitated by one
or a combination of three mechanisms, i.e., horizontal, vertical and vector-borne. Horizontal
transmission refers to the direct movement through the water column of a pathogen between
susceptible individuals and the open design of most mariculture cages allows the potential for
40
bidirectional transmission of pathogens between wild and captive fish (Johansen et al. 2011). Vertical
transmission involves the passing of a pathogen with milt or eggs, resulting in infection among offspring.
Pathogens can also be spread by a third host or vector. Vectors can include other parasites, fish,
piscivorous animals or inanimate objects such as clothing, vessels or equipment.
Disease transmission within culture systems is a primary concern of operators and as a consequence
of monitoring and screening, a far greater knowledge base relating to disease causing organisms and
their transmission is available relating to cultured stocks rather than wild stocks. As a result of the lack
of empirical data relating to diseases specific to wild stocks, it has been difficult to partition population
effects in wild-stocks caused by diseases from those caused by other processes (ICES 2010).
Ireland enjoys a high health status (Category 1) in relation to the fish/shellfish on farms, in rivers and
lakes and remains free of many diseases that occur in other countries (www.fishhealth.ie). In Ireland,
there are programmes in place that govern the moment of (fish and shellfish) stock for on-growing
among sites. These movement controls are supported by a risk-based fish health surveillance
programme which is operated on a nationwide basis by the Marine Institute, in co-operation with private
veterinary practitioners. Ireland is currently free of the following salmonid diseases covered by (Council
Directive 2006/88/EC):
1. Infectious Salmon Anaemia (ISA)
2. Viral Haemorrhagic Septicaemia (VHS)
3. Infectious Haematopoetic Necrosis (IHN)
4. Gyrodactylosis
Apart from the diseases listed under EU legislation, routine tests are carried out for other diseases
found in marine salmonids in Ireland e.g. Pancreas Disease (PD), Infectious Pancreatic Necrosis (IPN),
Furunculosis etc. Such diseases are present in Ireland and whilst their control is not covered by
legislation, all finfish farmers in the country have agreed to comply with the parameters of a Code of
Practice and Fish Health Handbook, jointly agreed between the Marine Institute and the Irish Farmers
Association (IFA). These documents cover all aspects of disease prevention and control on Irish fish
farms with the twin objectives of minimising disease outbreaks and of dealing with them in a timely and
responsible fashion, should they arise. The net outcome should be a decrease in mortality rates on fish
farms and a corresponding decrease in potential pathogen transfer to wild stocks. Ensuring the ongoing
good health of farmed stocks and the regular monitoring of environmental conditions will also help to
minimise the disease impacts which may be caused by infection from wild stocks in the vicinity of the
cages.
Disease Management: Council Directive 2006/88/EC on animal health requirements for aquaculture
animals and products thereof, and on the prevention and control of certain diseases in aquatic animals
form the legislative basis that governs the monitoring and management of disease outbreaks in
mariculture operations in Ireland. For diseases not listed in this Directive, a Code of Practice and Fish
Health Handbook has been developed jointly by the State and industry with the primary objectives of
disease prevention and control.
41
The adoption of chemotherapeutants and some vaccination programmes have assisted in reducing the
abundance and spread of many pathogens. In addition, the principles outlined in the Fish Health
Handbook mentioned above such as improved biosecurity practices on farms, fallowing sites to break
transmission cycles, disease testing of fish prior to transfer, single year class stocking, coordinating
treatments and harvesting within embayments etc have mitigated the transmission of pathogenic
organisms.
In summary, it is clear that a number of broad factors govern the transfer of diseases between
susceptible organisms. While statistical correlations have been demonstrated in terms of abundance of
cultured fish and disease occurrence in wild fishes, extreme caution must apply in terms of applying
causality. It is important to note that the only way to determine the link between disease outbreaks in
aquaculture installations and detection in wild fish is to empirically measure or observe pathogen
transfer. Furthermore, when a risk presents, it not clear if the impact on the wild fish is expressed at the
individual and/or population level. While certain effects have been demonstrated at the level of
individuals, research has not yet clearly identified or quantified these links at the population level.
Disease management programmes operated on a statutory basis by the State and on a voluntary basis
by industry via Codes of Practice, assist in ensuring that pathogen transfer both to and from farmed fish
is kept to a minimum.
Parasites: Sea lice are a group of parasitic copepods found on fish worldwide. There are two species
of sea lice commonly found on cultured salmonids in marine conditions around the coast of Ireland,
Caligus elongatus Nordmann, which infests over eighty different species of marine fish, and
Lepeophtheirus salmonis Krøyer (the salmon louse), which infests only salmon, trout and closely related
salmonid species. L. salmonis, the salmon louse, is the more serious parasite on salmon, both in terms
of its prevalence and effects. It has been reported as a common ecto-parasite of both wild and farmed
salmon at sea.
Returning wild salmon have been found to carry an average of 10 or more adult egg bearing females
on their return to the Irish coastline (Copley et al., 2005; Jackson et al., 2013a) from their feeding
grounds in the Atlantic. Having evolved their relationship with salmon and trout over many millennia,
the parasite is well adapted to target its host species and it is ubiquitous to all the coastal waters around
Ireland and indeed throughout the range of the Atlantic salmon (Jackson et al., 2013b).
Salmon, whether wild or cultured, go to sea from fresh water free of sea lice and only pick up the
infestation after they enter the marine phase of their lives. Sea lice infestations can inflict damage to
their hosts through their feeding activity on the outside of the host's body by affecting the integrity of the
fish’s epithelium, which impairs its osmoregulatory ability and leaves the fish open to secondary
infections. In extreme cases this can lead to a reduced growth rate and an increased morbidity in
affected individuals.
Marine finfish farms are perceived by certain sectors to be problematic because of the proximity of some
operations to river mouths and a concern over the possible impact on wild migratory salmonid fisheries
through infestation with sea lice.
42
The studies on the impacts of lice infestation on smolts (Jackson et al. 2011 & Jackson et al. 2013)
suggest that sea lice induced mortality on outwardly migrating smolts is likely a minor and irregular
component of marine mortality in the stocks studied and therefore, is unlikely to be a significant factor
influencing conservation status of salmon stocks in Clew Bay. This conclusion is further supported by
the finding of no correlation between the presence of aquaculture and the performance of adjacent wild
salmon stocks.
Parasite Management: Based on the evidence from targeted studies, the information collected as part
of the National Sea Lice Monitoring and Control Programme, scientific reports published by the Marine
Institute, and in-line with external advice, it is concluded that there is a robust and effective management
programme in place in Ireland to control sea lice infestation on farmed fish. Furthermore, there is no
empirical evidence to support the suggestion that the fisheries are being adversely affected by unusual
levels of sea lice infestation, whether of farmed origin or from other sources.
6.2 Fisheries
The fishing activities cause physical disturbance to habitats through the use of various fishing gears,
targeted extraction of fish and shellfish and potential by-catch of designated species. The degree to
which habitats are disturbed by fishing depend on the scale, intensity and frequency of fishing activity
and the type of fishing gear used relative to the sensitivity of the receiving habitat. A number of fishing
gears used in Clew Bay have direct contact with the seabed and can therefore impact epi-benthic
communities and in some cases, where the gear penetrates the sediment, can disturb in-faunal biota
as well. Designated species, such as harbour seal and otter can become entangled in static gears, such
as tangle nets, gill nets and trammel nets and a lesser risk of by-catch in towed demersal and pelagic
gears. All fisheries involve the extraction of fish biomass including both the target species and other
species caught as by-catch which potentially disturbs the ecology of the site and its designated features
43
Table 5: Potential indicative environmental pressures of aquaculture activities within the qualifying interests (Mudflats and sandflats not covered
by seawater at low tide (1140) and Large Shallow Inlets and Bays (1160)) of Clew Bay Complex SAC.
METIER/
ACTIVITY
PRESSURE CATEGORY
PRESSURE POTENTIAL EFFECTS EQUIPMENT DURATION
(DAYS) TIME OF
YEAR
FACTORS CONSTRAINING THE ACTIVITY
Aquaculture
Rope Mussel
and other
suspended
Culture
Methods
Physical Current
alteration
Baffling effect resulting in a slowing of currents and
increasing deposition onto seabed changing
sedimentary composition
Floats, longlines, continuous ropes
(New Zealand system) and
droppers
365 All year Location (sheltered location for year round activity)
Biological Organic
enrichment
Faecal and pseudofaecal deposition on seabed
potentially altering community composition.
Drop-off of culture species.
Shading
Prevention of light penetration to seabed
potentially impacting light sensitive species
Fouling
Increased secondary production on structures
and culture species. Increased nekton
production
44
METIER/
ACTIVITY
PRESSURE CATEGORY
PRESSURE POTENTIAL EFFECTS EQUIPMENT DURATION
(DAYS) TIME OF
YEAR
FACTORS CONSTRAINING THE ACTIVITY
Seston filtration
Alteration of phytoplankton and
zooplankton communities and potential impact on
carrying capacity
Nutrient
exchange
Changes in ammonium and Dissolved inorganic
nitrogen resulting in increased primary
production. Nitrogen (N2) removal at harvest.
Alien species
Introduction of non-native species with culture
organism transported into the site
Intertidal
Oyster
Culture
Physical Current
alteration
Structures may alter the current regime and resulting increased
deposition of fines or scouring.
Trestles and bags and service equipment
365 All year At low tide only
Surface
disturbance
Ancillary activities at sites, e.g. servicing,
transport increase the risk of sediment
compaction resulting in sediment changes and associated community
changes.
45
METIER/
ACTIVITY
PRESSURE CATEGORY
PRESSURE POTENTIAL EFFECTS EQUIPMENT DURATION
(DAYS) TIME OF
YEAR
FACTORS CONSTRAINING THE ACTIVITY
Shading
Prevention of light penetration to seabed
potentially impacting light sensitive species
Biological Non-native
species introduction
Potential for non-native species (C. gigas) to
reproduce and proliferate in SAC. Potential for alien
species to be included with culture stock (hitch-
hikers).
Disease risk
In event of epizootic the ability to manage disease in uncontained subtidal oyster populations is
compromised.
Organic
enrichment
Fecal and pseudofecal deposition on seabed
potentially altering community composition
Subtidal
Oyster/Muss
el culture
Physical Surface
disturbance
Abrasion at the sediment surface and redistribution
of sediment
Oyster dredge Once quarterly
Seasonal Weather for site access. Size of
oysters and market constraints
Shallow
disturbance Sub-surface disturbance
to 25mm
46
METIER/
ACTIVITY
PRESSURE CATEGORY
PRESSURE POTENTIAL EFFECTS EQUIPMENT DURATION
(DAYS) TIME OF
YEAR
FACTORS CONSTRAINING THE ACTIVITY
Biological Monoculture
Habitat dominated by single species and
transformation of infaunal dominated community to
epifaunal dominated community.
By-catch mortality
Mortality of organisms captured or disturbed during the harvest or process, damage to
structural fauna of reefs
Non-native
species introduction
Potential for non-native species (C. gigas) to
reproduce and proliferate in SAC (oysters only).
Potential for alien species to be included with culture stock (hitch-hikers) (mussel and
oysters).
Disease risk
In event of epizootic the ability to manage disease in uncontained subtidal
oyster populations would likely be compromised. The risk introduction of
disease causing organisms by introducing seed originating from the ‘wild’ in other jurisdictions
47
METIER/
ACTIVITY
PRESSURE CATEGORY
PRESSURE POTENTIAL EFFECTS EQUIPMENT DURATION
(DAYS) TIME OF
YEAR
FACTORS CONSTRAINING THE ACTIVITY
Nutrient
exchange
Increased primary production. N2 removal at harvest or denitrification
at sediment surface.
Salmon Biological Nutrient exchange
Increased primary production. N2 removal at harvest or denitrification at sediment surface.
365 Fallow periods
when no fish in the cages in the water.
Organic enrichment
Fecal and waste food on seabed potentially altering community composition
365
Disease risk Management of parasites and diseases in finfish culture is an ongoing challenge to culturist.
365
48
Aquaculture and Harbour Seal Interactions: In relation to Harbour seals (Phoca vitulina), less
information is available on the potential interactions between the species and the activities in question
(see NRC 2009). There has been no targeted research conducted in similar ecosystems that has
directly assessed the impact of this type of aquaculture on harbor seals or indeed any other seal
populations. There has, however, been considerable research on short-term responses of harbor seals
to disturbance from other sources, and these can be used to inform assessments the potential impacts
of disturbance from aquaculture activities currently underway and proposed in Clew Bay Complex SAC.
These disturbance studies have focused on impacts upon groups of seals that are already ashore at
haul-out sites. Sources of potential disturbance have varied widely, and include people and dogs (Allen
et al., 1984; Brasseur & Fedak, 2003), recreational boaters (Johnson & Acevedo-Gutierrez, 2007; Lelli
& Harris, 2001; Lewis & Mathews, 2000), commercial shipping (Jansen et al., 2006), industrial activity
(Seuront & Prinzivalli, 2005) and aircraft (Perry et al., 2002). A harbor seal’s response to disturbance
may vary from an increase in alertness, movement towards the water, to actual entering into the water,
i.e. flushing (Allen et al., 1984) and is typically governed by the location and nature of the disturbance
activity. For example, kayaks may elicit a stronger response than power boats (Lewis & Mathews, 2000;
Suryan & Harvey, 1999), and stationary boats have been shown to elicit a stronger response than boats
moving along a predictable route (Johnson & Acevedo-Gutierrez, 2007). Furthermore, the mean
distance at which seals are flushed into the water by small boats and people ranges between 80m and
530m, with some disturbances recorded at distances of over 1000m. In certain areas, these empirical
studies have been used to inform management actions in marine protected areas, for example where
a 1.5km buffer is set around harbor seal haul-out sites in the Dutch Wadden Sea to exclude recreational
disturbance (Brasseur & Fedak, 2003).
Displacement from areas may also result from disturbances attributable to the activities of mariculture
workers (Becker et al., 2009; 2011). This disturbance may be caused directly by the presence of
workers on intertidal areas. However, while disturbance from shellfish culture operations have been
observed to influence the distribution of seal within a sheltered embayment, no inference was made on
the effect on broader population characteristics of harbour seals from this study (Becker 2011).
Potential interactions between shellfish culture and marine mammals are broadly summarized in Table
6. It should be noted that direct demonstrations of these impacts are rare, and in most cases, potential
effects are therefore predicted from the best existing information (NRC, 2010). Furthermore, none of
the studies published to explore impacts on marine mammals and in particular Harbour Seals, were
specifically designed to detect ecological impacts on this species (NRC 2009; Becker et al., 2009,
2011). Even where studies have been carried out around shellfish farms, uncertainty over spatial and
temporal variation in both the location of structures (Watson-Capps and Mann, 2005) and levels of
disturbance (Becker et al., 2009; 2011) constrain the conclusions that can be drawn about the impacts
of mariculture on critical life functions such as reproduction and foraging.
Mariculture operations are considered a source of marine litter (Johnson, 2008). Ingestion of marine
litter has also been shown to cause mortality in birds, marine mammals, and marine turtles (Derraik,
2002).
49
Mariculture structures can provide shelter, roost, or haul-out sites for birds and seals (Roycroft et al.,
2004). This is unlikely to have negative effects on bird or seal populations, but it may increase the
likelihood that these species cause faecal contamination of mollusc beds.
Seal interactions with marine finfish cages have been described (Aquaculture Stewardship Council,
2012). The seals (as predators) are attracted to the structures and their contents and have been known
to tear netting in attempts to acquire prey items (i.e. cultured finfish). While a risk of entanglement in
netting may present, it is not considered likely and the greatest risk is the escape of stocked fishes. In
order to mitigate this risk, operators have resorted to the use of deterrent devices (Acoustic or
Harassment) which have variable results based upon the location, extent of use and mammals targeted.
However, deterrent devices are now considered detrimental to seals and alternative management
actions are advised (Nelson 2004; Aquaculture Stewardship Council 2012). Therefore, careful stock
management (density control, regular removal of mortalities from cages), use of seal blinds and
appropriate net tensioning are all considered suitable methods to minimise negative interactions
between seals and finfish culture. Lethal actions to remove seals are only allowed under licence the
criteria which are determined by NPWS (Section 42 of the Wildlife Act, 1976 (as amended).
In the Clew Bay Complex SAC it would appear that the overall Harbour Seal numbers (population) has
been stable or increasing between 2003 and 2012 (NPWS data) coincident with static levels of
mariculture production. While no definitive conclusions can be drawn regarding the population status
of harbour seals in Clew Bay and more widely around Ireland, based upon survey reports from 2009-
2011 (as no baseline reference values are provided), it would appear that the levels both regionally and
nationally are stable or possibly increasing (see Figure 2 in NPWS 2012 -
http://npws.ie/marine/marinereports/Harbour%20Seal_NPWS%20pilot%20monitoring%20study%202
011_Final%20doc.pdf).
50
Table 6: Potential interactions between aquaculture activities and the Annex II species Harbour Seal (Phoca vitulina) within the Clew Bay SAC.
CULTURE METHOD
PRESSURE CATEGORY
PRESSURE POTENTIAL EFFECTS EQUIPMENT DURATION
(DAYS)
TIME OF
YEAR
FACTORS CONSTRAINING THE ACTIVITY/EFFECTS
All Aquaculture
Methods Physical
Habitat Exclusion
Structures may result in a barrier to movement of seals.
Net pens, Bags and trestles
365 All year Spatial extent and location of structures used for culture.
Disturbance
Ancillary activities at sites increase the risk of disturbance to seals at haul out sites (resting, breeding and/or moulting) or in the water.
Site services, human, boat and vehicular traffic
365 All year
Seasonal levels of activity relating to seeding, grading, and harvesting. Peak activities do no coincide with more sensitive periods for seals (i.e. pupping and moulting)
Entanglement
Entanglement of seals from ropes or material used on structures or during operation of farms
Trestles, bags,ropes and/or nets used in day to day
365 All year Farm management practices
Ingestion Ingestion of waste material used on farm
Ties used to secure bags and secure bags to trestle
365 All year Farm management practices
Deterrent Methods
Seals interfering with cages will result in deterrent actions, e.g. use of Acoustic deterrent or harassment Devices. If all non lethal avenues fail then lethal methods may be employed (under licence).
ADDs and lethal devices (shooting)
365 Fallow periods no fish on-site
51
7 Screening of Aquaculture Activities
A screening assessment is an initial evaluation of the possible impacts that activities may have on the
qualifying interests. The screening, is a filter, which may lead to exclusion of certain activities or
qualifying interests from appropriate assessment proper, thereby simplifying the assessments, if this
can be justified unambiguously using limited and clear cut criteria. Screening is a conservative filter
that minimises the risk of false negatives.
In this assessment screening of the qualifying interests against the proposed activities is based primarily
on spatial overlap i.e. if the qualifying interests overlap spatially with the proposed activities then
significant impacts due to these activities on the conservation objectives for the qualifying interests is
not discounted (not screened out) except where there is absolute and clear rationale for doing so.
Where there is relevant spatial overlap full assessment is warranted. Likewise if there is no spatial
overlap and no obvious interaction is likely to occur, then the possibility of significant impact is
discounted and further assessment of possible effects is deemed not to be necessary. Table 3 provides
spatial overlap extent between designated habitat features and aquaculture activities within the
qualifying interests of Clew Bay Complex SAC.
7.1 Aquaculture Activity Screening
- Table 3 highlights the spatial overlap between (existing and proposed) aquaculture activities and
both habitat features (i.e. Large Shallow Inlet and Bay and Mudflat and Sandflats not covered by
seawater at low tide).
- Tables 7 and 8 provides an overview of overlap of aquaculture activities and specific community
types (identified from Conservation objectives) within the broad habitat features 1140 and 1160,
respectively.
- A single activity, (i.e. the terrestrial fish hatchery operation) on the shores of Lough Furnace (Coastal
Lagoon) is also excluded further from this analysis as there is little or no spatial overlap with
conservation feature (Coastal Lagoon) and the licenced discharge (treated effluent) is unlikely to
contribute to deterioration of any of the target attributes listed in NPWS 2011.
Where the overlap between an aquaculture activity and a feature is zero it is screened out and not
considered further. Therefore, the following six habitats and one species are excluded from further
consideration in this assessment. ;
- 1013 Geyer's whorl snail Vertigo geyeri
- 1210 Annual vegetation of drift lines
- 1220 Perennial vegetation of stony banks
- 1330 Atlantic salt meadows (Glauco‐Puccinellietalia maritimae)
- 2110 Embryonic shifting dunes
52
- 2120 Shifting dunes along the shoreline with Ammophila arenaria ("white dunes")
- 1150 Coastal Lagoons
Furthermore, of the seven community types (see Table 1) listed under the two habitat features (1140
and 1160) two (Zostera dominated communities and Mearl dominated Commuities) have no spatial
overlap between them and any aquaculture activities. For other community types, when overlap was
observed it was estimated in a GIS application and calculated on the basis of coverage of specific
activity (representing different pressure types), licence status (licenced or application) intersecting with
designated conservation features and/or sub-features (community types). The values represented also
summarise the total coverage if applications were to supplant existing licences in order to facilitate
restructuring or expansion of existing sites (Table 8). On this basis, the community type Zostera
dominated community and Mearl dominated Commuities are excluded from further analysis of
aquaculture interactions.
53
Table 7: Habitat utilisation i.e. spatial overlap in hectares and percentage (given in parentheses) of Aquaculture activity over community
types within the qualifying interest 1140 - Mudflat and sandflats not covered by seawater at low tide of Clew Bay Complex SAC. (Spatial data
based on licence database provided by DAFM. Habitat data provided in NPWS 2011 – supporting docs marine and coastal)
1140 - Mudflats and sandflats not covered by seawater at low tide
Culture Type Location Method Status
Intertidal sandy mud with Tubificoides
benedii and Pygospio elegans
community complex (788ha)
Sandy mud with polychaetes and
bivalves community complex (445ha)
Fine sand dominated by Nephtys cirrosa
community (44ha)
Oysters (Crassostrea gigas) in bags & trestles.
Intertidal Intensive Licenced 13.56
(1.72%)
41.76
(9.38%)
2.38
(5.6%)
Oysters (Crassostrea gigas) in bags & trestles.
Intertidal Intensive Applications - 6.27
(1.4%) -
Vehicular traffic in Intertidal areas.
Intertidal - N/A 1.25
(0.16%)
5.43
(1.22%) -
Corrected Totals* 14.81
(1.88)
53.46
(12.01)
2.38
(5.6%)
*Corrected Totals refer to total spatial coverage of activity that will occur if certain licenced sites are surrendered on foot of successful new applications or realignment of sites (see Section 5.1) and do not reflect the sum of columns in the table.
54
Table 8: Habitat utilisation i.e. spatial overlap in hectares and percentage (given in parentheses) by Aquaculture activity over specific
community types within the qualifying interest 1160 – Large shallow inlets and bays of Clew Bay Complex SAC based on licence database
provided by DAFM. Habitat data provided in NPWS 2011 – supporting docs marine and coastal)
Large Shallow Inlet and Bay (1160)
Culture Type Location Method Status
Intertidal sandy mud
with Tubificoides benedii and Pygospio elegans
community complex (788ha)
Sandy mud with
polychaetes and bivalves community
complex (5,791ha)
Fine sand dominated by
Nephtys cirrosa
community (296ha)
Reef (2,687ha)
Shingle (146ha)
Maerl (288ha)
Oysters (Crassostrea gigas) in bags & trestles.
Intertidal Intensive Licenced
13.58
(1.72%)
139.62
(2.4%)
7.32
(2.47%)
4.15
(0.15%) - -
Oysters (Crassostrea gigas) in bags & trestles.
Intertidal Intensive Application - 22.4
(0.39%) -
0.17
(<0.001) - -
Oysters (Crassostrea gigas) on seabed
Subtidal Extensive Licenced 5
(0.09%)
Mussel (Mytilus edulis) on ropes
Subtidal Intensive Licenced - 64.55
(1.1%) - - - -
Mussel (Mytilus edulis) on ropes
Subtidal Intensive Application - 10.35
(0.18%) - - - -
55
Large Shallow Inlet and Bay (1160)
Culture Type Location Method Status
Intertidal sandy mud
with Tubificoides benedii and Pygospio elegans
community complex (788ha)
Sandy mud with
polychaetes and bivalves community
complex (5,791ha)
Fine sand dominated by
Nephtys cirrosa
community (296ha)
Reef (2,687ha)
Shingle (146ha)
Maerl (288ha)
Abalone Subtidal Intensive Application - 2.64
(0.05%) - - - -
Scallop Subtidal Extensive - 4.00
(0.1) -
-
- -
Lobster Subtidal Intensive Licenced - 1.0
(0.02%) - - - -
Salmon (Salmo salar) in net pens
Subtidal Intensive Licenced - 11.29
(0.20) -
4.67
(0.17) - -
Vehicular traffic in Intertidal areas.
Intertidal Intensive N/A 1.14
(0.14%) 6.1
(0.11)
1.3 (0.04%)
0.14 (0.10)
-
Corrected Totals* 14.72
(1.87%)
256.60*
(4.43%)
7.32
(2.47%)
10.29
(0.39%)
0.14 (0.10)
-
*Corrected Totals refer to total spatial coverage of activity that will occur if certain licenced sites are surrendered on foot of successful new applications or realignment of sites (see Section 5.1) and do not reflect the sum of columns in the table.
56
8 Assessment of Aquaculture Activities
8.1 Determining significance
The significance of the possible effects of the proposed activities on habitats, as outlined in the Natura
Impact statement (Section 6) and subsequent screening exercise (Section 7), is determined here in the
assessment. The significance of effects is determined on the basis of Conservation Objective guidance
for constituent habitats and species (Figure 1-3 and NPWS 2011a, b).
Habitats and species that are key contributors to biodiversity and which are sensitive to disturbance
should be afforded a high degree of protection i.e. thresholds for impact on these habitats is low and
any significant anthropogenic disturbance should be avoided. In Clew Bay these habitats include:
- 1160 Zostera - 1160 Maerl
Within the Clew Bay SAC the qualifying habitats/species considered subject to potential disturbance
and therefore, carried further in this assessment are:
- 1140 Mudflats and sandflats not covered by seawater at low tide - 1160 Large shallow inlets and bays - 1355 Otter - Lutra lutra - 1365 Common (Harbour) seal - Phoca vitulina - 1106 Salmon - Salmo salar – migrating salmon through Clew Bay Complex from
adjacent SACs from Section 4.4.
For broad habitats and sedimentary communities (Figures 1 and 2) significance of impact is determined
in relation to, first and foremost, spatial overlap (see Section 7; Figure 16). Subsequent disturbance
and the persistence of disturbance are considered as follows:
1. The degree to which the activity will disturb the qualifying interest. By disturb is meant
change in the characterising species, as listed in the Conservation Objective guidance
(NPWS 2011b) for constituent communities. The likelihood of change depends on the
sensitivity of the characterising species to the activities in question. Sensitivity results from
a combination of intolerance to the activity and/or recoverability from the effects of the
activity (see Section 8.2 below).
2. The persistence of the disturbance in relation to the intolerance of the community. If the
activities are persistent (high frequency, high intensity) and the receiving community has a
high intolerance to the activity (i.e. the characterising species of the communities are
sensitive and consequently impacted) then such communities could be said to be
persistently disturbed.
3. The area of communities or proportion of populations disturbed. In the case of community
disturbance (continuous or ongoing) of more than 15% of the community area it is deemed
to be significant. This threshold does not apply to sensitive habitats as listed above (Zostera,
Maerl, Reef) where any physical disturbance should generally be avoided
57
Effects will be deemed to be significant when cumulatively they lead to long term change (persistent
disturbance) in broad habitat/features (or constituent communities) resulting in an impact greater than
15% of the area.
Figure 16: Determination of significant effects on community distribution, structure and function
for sedimentary habitats (following NPWS 2011b).
In relation to designated species (Harbour Seal, otter) the capacity of the population to maintain itself
in the face of anthropogenic induced disturbance or mortality at the site will need to be taken into
account in relation to the Conservation Objectives (CO’s) on a case by case basis.
8.2 Sensitivity and Assessment Rationale
This assessment used a number of sources of information in assessing the sensitivity of the
characterising species of each community recorded within the benthic habitats of Clew Bay Complex
SAC. The primary source of information is a series of commissioned reviews by the Marine Institute
which identify habitat and species sensitivity to a range of pressures likely to result from aquaculture
and fishery activities (ABPMer 2013a-h). These reviews draw from the broader literature, including the
MarLIN Sensitivity Assessment (Marlin.ac.uk) and the AMBI Sensitivity Scale (Borja et al., 2000) and
58
other primary literature. Sensitivity of a species to a given pressure is the product of the intolerance (the
susceptibility of the species to damage, or death, from an external factor) of the species to the particular
pressure and the time taken for its subsequent recovery (recoverability is the ability to return to a state
close to that which existed before the activity or event caused change). Life history and biological traits
are important determinants of sensitivity of species to pressures from aquaculture.
In the case of species, communities and habitats of conservation interest, the separate components of
sensitivity (intolerance, recoverability) are relevant in relation to the persistence of the pressure:
For persistent pressures i.e. activities that occur frequently and throughout the year recovery
capacity may be of little relevance except for species/habitats that may have extremely rapid
(days/weeks) recovery capacity or whose populations can reproduce and recruit in balance with
population damage caused by aquaculture. In all but these cases and if sensitivity is moderate
or high then the species/habitats may be negatively affected and will exist in a modified state.
Such interactions between aquaculture and species/habitat/community represent persistent
disturbance. They become significantly disturbing if more than 15% of the community is thus
exposed (NPWS 2011).
In the case of episodic pressures i.e. activities that are seasonal or discrete in time both the
intolerance and recovery components of sensitivity are relevant. If sensitivity is high but
recoverability is also high relative to the frequency of application of the pressure then the
species/habitat/community will be in favourable conservation status for at least a proportion of
time.
The sensitivities of the community types (or surrogates) found within the Clew Bay Complex SAC to
pressures similar to those caused by aquaculture (e.g. smothering, organic enrichment and physical
disturbance) are listed, where available, in Table 9. The sensitivities of species which are characteristic
(as listed in the Conservation Objective supporting document) of benthic communities to pressures
similar to those caused by aquaculture (e.g. smothering, organic enrichment and physical disturbance)
are listed, where available, in Table 10. The following guidelines broadly underpin the analysis and
conclusions of the species and habitat sensitivity assessment:
Sensitivity of certain taxonomic groups such as emergent sessile epifauna to physical pressures
is expected to be generally high or moderate because of their form and structure (Roberts et al.
2010). Also high for those with large bodies and with fragile shells/structures, but low for those
with smaller body size. Body size (Bergman and van Santbrink 2000) and fragility are regarded
as indicative of a high intolerance to physical abrasion caused by fishing gears (i.e. dredges).
However, even species with a high intolerance may not be sensitive to the disturbance if their
recovery is rapid once the pressure has ceased.
Sensitivity of certain taxonomic groups to increased sedimentation is expected to be low for
species which live within the sediment, deposit and suspension feeders; and high for those
sensitive to clogging of respiratory or feeding apparatus by silt or fine material.
59
Recoverability of species depends on biological traits (Tillin et al. 2006) such as reproductive
capacity, recruitment rates and generation times. Species with high reproductive capacity, short
generation times, high mobility or dispersal capacity may maintain their populations even when
faced with persistent pressures; but such environments may become dominated by these (r-
selected) species. Slow recovery is correlated with slow growth rates, low fecundity, low and/or
irregular recruitment, limited dispersal capacity and long generation times. Recoverability, as
listed by MarLIN, assumes that the impacting factor has been removed or stopped and the habitat
returned to a state capable of supporting the species or community in question. The recovery
process is complex and therefore the recovery of one species does not signify that the associated
biomass and functioning of the full ecosystem has recovered (Anand & Desrocher, 2004) cited
in Hall et al., 2008).
8.3 Assessment of the effects of aquaculture production on the Conservation Objectives for habitat features in Clew Bay Complex SAC.
Aquaculture pressures on a given habitat are related to vulnerability (spatial overlap or exposure of the
habitat to the equipment/culture organism combined with the sensitivity of the habitat) to the pressures
induced by culture activities. To this end, the location and orientation of structures associated with the
culture organism, the density of culture organisms, the duration of the culture activity and the type of
activity are all important considerations when considering risk of disturbance to habitats and species.
NPWS (2011b) provide lists of species characteristic of benthic communities that are defined in the
Conservation Objectives. The species defined are typical of fine sedimentary habitats as well as where
relevant, intertidal habitats (tolerant of desiccation and physical stress). For the most part, these
intertidal communities are typically impoverished with low numbers of species and overall abundances.
Different species and habitats will have different tolerance to the pressures associated with aquaculture
activities (pressures as discussed in Sections 5 and 6). The constituent communities identified in the
broad Annex 1 feature (i.e., Mudflats and sandflats not covered by seawater at low tide) are:
1. Intertidal sandy mud with Tubificoides benedii and Pygospio elegans community complex
2. Sandy mud with polychaetes and bivalves community complex
3. Fine sand dominated by Nephtys cirrosa community
They are predominantly sandy-muddy habitat types and given they are intertidal and, in parts, estuarine,
can be exposed to a range of physical and hydrodynamic pressures. Table 9 lists the habitats and Table
10 lists the constituent taxa and both provide a commentary of sensitivity to a range of pressures. The
risk scores are derived from a range of sources identified above. The pressures are listed as those
likely to result from the primary activities carried out in Clew Bay Complex SAC, i.e. intertidal oyster
culture in bags on trestles, rope mussel culture, subtidal clam and mussel culture and salmon culture.
While the feature Large shallow inlets and bays includes intertidal communities (considered above),
it is subtidal communities which predominate this feature type. In addition to the communities listed
above, for which there are distinguishing subtidal characteristics,
60
the feature Large Shallow Inlets and Bays also contain the following community types;
Shingle
Reef
The fauna characterising the habitat types listed above are typical of inshore subtidal communities
found in fine sedimentary habitats. They are dominated by polychaete worms and bivalves. The reef
communities are typical of intertidal cobble (and mixed sediment communities) as well as subtidal
communities dominated by large macro algal (kelp) and faunal turf (sponges and hydrozoans). Mearl
dominated communities are considered highly diverse and sensitive habitat types which host a wide
range of taxa. The ‘keystone’ species in each community type (Maerl and Zostera) is considered
important and sensitive in their own right. Shingle is typically found high in the intertidal zone and is
considered a robust and resilient habitat type. Aquaculture activities overlap with all habitat type (with
the exception of Zostera and Mearl) listed above (Tables 7 and 8).
Aquaculture activities in Clew Bay Complex SAC comprises both finfish and shellfish production
methods. Considered in the assessment are intertidal oyster culture (bag and trestle), intertidal clam
on-bottom culture, subtidal (suspended) rope mussel culture, subtidal on-bottom culture of oysters and
Atlantic salmon culture in net pens. Other culture methods considered are abalone, scallop and lobster
culture.
This aquaculture type overlaps six different community types found within the qualifying interest of the
SAC. Tables 12 and 13 below identify the likely interactions between the relevant aquaculture activities
and the two broad habitat features (1140 and 1160) and their constituent community types, with a broad
conclusion and justification on whether the activity is considered disturbing to the feature in question. It
must be noted that the sequence of distinguishing disturbance is as highlighted above, whereby
activities with spatial overlap on habitat features are assessed further for their ability to cause
persistence disturbance on the habitat. If persistence disturbance is likely then the spatial extent of the
overlap is considered further. If the proportion of the overlap exceeds a threshold of 15% disturbance
of the habitat then any further licencing should be informed by interdepartmental review and
consultation (NPWS 2011b).
Other Considerations: The presence of the invasive species, Didemnum vexillum, does have the
potential to impact on the conservation features of the site. To date, Didemnum has been confirmed to
occur in the southern portion of the bay and a link to aquaculture structures has been established. The
risk posed by this alien species cannot be discounted.
61
Table 9: Matrix showing the characterising habitats sensitivity scores x pressure categories for habitats in Clew Bay Complex SAC (ABPMer 2013a-h).
Pressure Type Physical Damage Change in Habitat Quality Biological Pressures Chemical Pollution Physical
Pressures
Community Type (EUNIS code)
Surfa
ce D
istu
rbance
Sha
llow
Dis
turb
ance
Deep D
istu
rbance
Tra
mplin
g-A
ccess b
y fo
ot
Tra
mplin
g-A
ccess b
y v
ehic
le
Extra
ctio
n
Silta
tion
(add
ition o
f fine s
edim
ents
,
pseudo
faeces, fis
h fo
od)
Sm
oth
erin
g (a
dd
ition o
f mate
rials
bio
log
ical o
r non
-bio
log
ical to
the
surfa
ce)
Chan
ges to
se
dim
en
t com
positio
n-
incre
ased
coars
eness
Chan
ges to
se
dim
en
t com
positio
n-
incre
ased
fine s
ed
iment p
roportio
n
Chan
ges to
wate
r flow
Incre
ase in
turb
idity
/suspe
nded
sedim
ent
Decre
ase in
turb
idity
/suspe
nded
sedim
ent
Org
anic
enric
hm
ent-w
ate
r colu
mn
Org
anic
enric
hm
ent o
f sed
iments
-sedim
enta
tion
Incre
ased re
mova
l of p
rima
ry
pro
ductio
n-p
hyto
pla
nkto
n
Decre
ase in
oxyge
n le
vels
-
sedim
ent
Decre
ase in
oxyge
n le
vels
-wate
r
colu
mn
Intro
ductio
n o
f non
-nativ
e s
pecie
s
Rem
ova
l of T
arg
et S
pecie
s
Rem
ova
l of N
on
-targ
et s
pe
cie
s
Ecosyste
m S
erv
ices-L
oss o
f
bio
mass
Intro
ductio
n o
f antifo
ula
nts
Intro
ductio
n o
f med
icin
es
Intro
ductio
n o
f hydro
carb
on
s
Pre
ventio
n o
f light re
achin
g
seabed
/fea
ture
s
Sandy mud with polychaetes and bivalves community complex (Intertidal A2.24)
NS (***)
L (*)
L (***)
NS (*)
L (*)
L-M (*)
L-M (*)
L-M (*)
L-M (*)
NS (*)
L-M (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
L (*)
L (*)
H (***)
NS (*)
NS (*)
NA NS (*)
NS (*)
L (*)
NS (*)
Fine sand dominated by Nephtys cirrosa community (Intertidal and subtidal) (A5.23)
NS (***)
L (*)
L (***)
NE NE L-M (*)
L-M (*)
L-M (*)
M-L (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
L (***)
NS (*)
L (*)
L (*)
H (***)
NS (*)
NS (*)
NA NS (*)
NS (*)
L (*)
NS (*)
Sandy mud with polychaetes and bivalves community complex (Subtidal A5.33)
NS (*)
L (*)
L (*)
NE NE L-M (*)
L (*)
L-M (*)
L-M (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
L (*)
NS (*)
L (*)
L (*) H (*) NS (*)
NS (*)
NA NS (*)
NS (*)
L (*)
NS (*)
Intertidal marine shores (A2.33)
NS-L (*)
L (*)
L (*)
NS (*)
L (*) L-M (*)
NS (*)
M-H (*)
L-M (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
L (*)
L (*) H (*) NS (*)
NS (*)
NA NS (*)
NS (*)
L (*)
NS (*)
Intertidal sandy mud with Tubificoides benedii and Pygospio elegans community complex - (A2.23)
NS (*)
L (*)
L (*)
NS (*)
L-NS (*)
L-M (*)
L-M (*)
L-M (*)
L-M (*)
M (*)
L-M (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
L-NS (*)
L-NS (*)
NS (***)
NS (*)
NS (*)
NA NS (*)
NS (*)
L (*)
NS (*)
Maerl (A5.51) H
(***) H-VH (***)
H (***)
H (***)
H (***)
H-VH (***)
H-VH (***)
H-VH (***)
NS (*)
NS (*)
NS (*)
H (*)
NS (*)
H (*)
H (***)
NS (*)
H (**)
H (**)
H (***)
VH (***)
NS (*)
NE NE NE NE
VH (*)
62
.
Table 10: Matrix showing the characterising species sensitivity scores x pressure categories for habitats in Clew Bay Complex SAC (ABPMer 2013a-h). Table 11 provides the code for the various categorisation of sensitivity and
confidence
Pressure Type Physical Damage Change in Habitat Quality Biological Pressures Chemical Pollution Physical
Pressures
Pressure
Surfa
ce D
istu
rbance
Sha
llow
Dis
turb
ance
Deep D
istu
rbance
Tra
mplin
g-A
ccess b
y fo
ot
Tra
mplin
g-A
ccess b
y v
ehic
le
Extra
ctio
n
Silta
tion
Sm
oth
erin
g (a
dd
ition o
f mate
rials
bio
log
ical o
r non
-bio
log
ical to
the
surfa
ce)
Chan
ges to
se
dim
en
t com
positio
n- in
cre
ased
coars
eness
Chan
ges to
se
dim
en
t com
positio
n- in
cre
ase
d fin
e
sedim
ent p
roportio
n
Chan
ges to
wate
r flow
Incre
ase in
turb
idity
/suspe
nded
sedim
ent
Decre
ase in
turb
idity
/suspe
nded
sedim
ent
Org
anic
enric
hm
ent-w
ate
r colu
mn
Org
anic
enric
hm
ent o
f sed
iments
-
sedim
enta
tion
Incre
ased re
mova
l of p
rima
ry
pro
ductio
n-p
hyto
pla
nkto
n
Decre
ase in
oxyge
n le
vels
-
sedim
ent
Decre
ase in
oxyge
n le
vels
-wate
r colu
mn
Intro
ductio
n o
f non
-nativ
e s
pecie
s
Rem
ova
l of T
arg
et S
pecie
s
Rem
ova
l of N
on
-targ
et s
pe
cie
s
Intro
ductio
n o
f antifo
ula
nts
Intro
ductio
n o
f med
icin
es
Intro
ductio
n o
f hydro
carb
on
s
Pre
ventio
n o
f light re
achin
g
seabed
/fea
ture
s
Abra alba L (*) L (***) L (*) L (*) L (*) M (*) NS (***)
M (*) L (*) NS (*) NS (*)
L (*)
L (*) NS (*)
NS (*)
NS (*)
L (***) L-M (***)
L-M (*)
NS (*)
NS (*)
NS (***)
NEv L
(***) NS (*)
Bathyporeia spp. NS (*)
L (***) L (***) NS (*) L (*) L-M (*)
L (***)
L-M (*) L-M (*)
L-M (*) NS (*)
NS (*)
NS (*)
L-M (*)
L-M (*)
NS (*)
L-M (***)
L-M (***)
L-M (*)
NS (*)
NS (*)
NS (*)
NEv NEv NS (*)
Capitella spp. L (*) L (**) L (**) L (***) L (*) L (*) L (*) NS (*) NS (*) NS (***)
NS (*)
NS (*)
NS (*)
NS (***)
NS (***)
NS (*)
L (***) L (***) NS (*)
NS (*)
NS (*)
NS (***)
L (***)
NS (***)
NS (*)
Cerastoderma edule
L (*) L-M (*) L-M (***) L-M (***) L-M (*) L-H (*)
L (***)
L-M (*) L-H (*) NS (*) L (*) NS (*)
NS (*)
NS (*)
NS (**)
L-NS (*)
L-M (*)
L-M (*)
M (*) M (*)
NS (*)
NS (*)
NEv L-M (*)
NS (*)
Lanice conchilega NS (*)
NS-L (***)
NS-L (***) NS (*) NS-L (*) M-H (*)
NS (*)
M-H (*) NS (*) NS (***)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
M (*) M (*) M-H (*)
NS (*)
NS (*)
NS (*)
NEv L
(***) NS (*)
Nephtys cirrosa NS (*)
L (***) L (***) NS (*) L (*) L (*) NS (***)
NS (*) L (*) NS (*) L (*) NS (*)
NS (*)
NS (*)
NS (*)
NS (*)
NS (*) NS (*) M (*) M (*)
NS (*)
NS (*)
NEv NEv NS (*)
Pygospio elegans L (*) L (**) M (***) L (*) L (*) L-M (*)
L (***)
L-M (***) L-M (*)
NS (**) L-M (*)
NS (*)
NS (*)
NS (*)
NS (***)
NS (*)
L (**) L (**) M (*) NS (*)
NS (*)
NS (*)
NEv NEv NS (*)
Scoloplos armiger NS (*)
L (*) L-M (*) NS (*) L (*) H (*) NS (*)
NS (*) NS (*) NS (*) NS (*)
NS (*)
NS (*)
NS (***)
NS (***)
NS (*)
M (***)
M (***)
M (*) M
(**) NS (*)
NS (*)
NEv NEv NS (*)
Tubificoides spp. NS (*)
NS (*) L (**) L (*) L (*) M (*) NS (*)
L (*) NS (*) NS (*) NS (***)
NS (*)
NS (*)
NS (***)
NS (***)
NS (*)
NS (***)
NS (***)
NS (*)
NS (*)
NS (*)
NS (**)
NEv NEv NS (**)
Hydrobia ulvae L-NS
(*) L (***) L (*) L-NS (*) L-NS (*) M (*)
NS (***)
L (*) NS (*) NS (*) NS (*)
NS (*)
NS (*)
NS (*)
NS (***)
NS (*)
L (*) L (*) L (*) NS (*)
NS (*)
NEv NEv M (*) NS (*)
Corophium volutator L
(***) L (***) L (***) L (*) L (*) L (*)
L (***)
L (***) M (*) NS (*) NS (*)
NS (*)
NS (*)
NS (***)
NS (***)
NS (*)
L (***) L (***) Nev NS (*)
NS (*)
NA NEv L
(***) NS (*)
Nematoda NS (***)
NS (***) NS (***) NS (***) NS (*) L (*) NS (*)
NS (***) NS (***)
NS (***)
NS (*)
NS (*)
NS (*)
NS (*)
NS (***)
NS (*)
L (***) L (***) NS (***)
NS (*)
L (*) NS (***)
NEv L
(***) NS (*)
Notomastus sp NS (*)
L (***) L (***) NS (*) L (*) L-M (*)
L (**) L (*) NS (*) NS (*) NS (*)
NS (*)
NS (*)
NS (*)
NS (**)
NS (*)
L (*) L (*) M (*) NS (*)
NS (*)
NS (*)
NEv NS (***)
NS (*)
Melinna palmata NS (***)
NS (***) NS (***) NS (*) NS (*) M (*) L
(***) M (*) NS (*) NS (*)
NS (*)
L (*)
NS (***)
NS (***)
NS (***)
NS (*)
NS (***)
NS (***)
L (*) NS (*)
NS (*)
NS (***)
NEv M
(***) NS (*)
Prionospio spp. NS (*)
NS (***) NS (*) NS (*) NS (*) L (*) L
(***) L (*) NS (*) NS (*)
NS (*)
NS (*)
NS (*)
NS (***)
NS (***)
NS (*)
NS (***)
NS (***)
L (*) NS (*)
NS (*)
NS (***)
NEv NS (***)
NS (*)
Mysella bidentata NS (*)
NS (*) L-M (*) NE NE M (*) NS (*)
NS (*) NS (*) NS (*) NS (*)
NS (*)
NS (*)
NS (**)
NS (**)
NS (*)
NS (*) NS (*) NS (*)
NS (*)
L-M (*)
NS (*)
NEv NA NS (*)
Thyasira flexuosa L (*) L (***) L (*) L (*) L (*) M-H (*)
NS (*)
M-H (*) NS (*) NS (*) NS (*)
NS (*)
NS (*)
NS (*)
NS (***)
NS (*)
M (***)
M (***)
M (*) NS (*)
NS (*)
NS (***)
NEv NS (***)
NS (*)
Angulus sp. (Moerella)
NS (*)
L (*) L (***) NS (*) L (*) M (*) NS (*)
H (*) M-H (*)
NS (*) L-M (*)
L (*)
NS (*)
NS (*)
Nev L-NS
(*) NEv NEv M (*)
NS (*)
NS (*)
NS (*)
NEv NEv NS (*)
63
Table 11: Codes of sensitivity and confidence applying to species and pressure interactions
presented in Tables 10 and 11.
Species x Pressure Interaction Codes for Tables 9 and 10
NA Not Assessed
Nev No Evidence
NE Not Exposed
NS Not Sensitive
L Low
M Medium
H High
VH Very High
* Low confidence
** Medium confidence
*** High Confidence
In summary, it is concluded that, the aquaculture activities (existing and proposed) individually and in-
combination do not pose a risk of significant disturbance to the conservation features for habitats in
Clew Bay based primarily upon the spatial overlap and sensitivity analysis (Tables 12 and 13).
The risk posed by the presence of the alien species, the carpet sea squirt, Didemnum sp., cannot be
discounted.
64
Table 12. Interactions between the relevant aquaculture activities and the habitat feature 1140 constituent communities with a broad conclusion on the nature of the interactions
1140 - Mudflats and sandflats not covered by seawater at low tide
Culture Type Location Method
Intertidal sandy mud with Tubificoides benedii and Pygospio elegans community complex
Sandy mud with polychaetes and bivalves community complex
Fine sand dominated by Nephtys cirrosa community
Oysters (Crassostrea gigas), in bags & trestles.
Intertidal Intensive
Disturbing: No
Justification: This community type considered
tolerant to pressures from activity. The species have
high recoverability and are tolerant. The stock is
confined in bags, is sourced from hatcheries and up to
80% triploid.
Disturbing: No
Justification: The community type is considered
tolerant to pressures from activity. The species have
high recoverability and are tolerant. The stock is
confined in bags, is sourced from hatcheries and up to
80% triploid.
-
Vehicular traffic in Intertidal areas.
Intertidal Intensive
Disturbing: Yes
Justification: This community type is likely sensitive
to persistent pressure (compaction) from this activity.
The spatial overlap is 0.16% of this community type.
Disturbing: Yes
Justification: This community and species are likely
sensitive to persistent pressure (compaction) from this
activity. The spatial overlap is 1.22% of this community
type.
-
Cumulative impact Aquaculture
Disturbing: No
Justification: the cumulative pressure of likely
impacting activities is 0.16% on this community type.
Disturbing: No
Justification: the cumulative pressure of likely
impacting activities is 1.22% on this community type.
-
65
Table 13. Interactions between the relevant aquaculture activities and the habitat feature 1160 constituent communities with a broad conclusion on the nature of the interactions.
Large Shallow Inlet and Bay [1160]
Culture Type Location Method
Intertidal sandy mud with Tubificoides benedii and
Pygospio elegans community complex
Sandy mud with polychaetes and bivalves
community complex
Fine sand dominated by Nephtys cirrosa
community Shingle Reef
Oysters (Crassostrea gigas), in bags & trestles.
Intertidal Intensive
Disturbing: No
Justification: This community is considered tolerant to pressures from activity. The species have high recoverability and are tolerant. The stock is confined in bags, is sourced from hatcheries and up to 80% triploid.
Disturbing: No
Justification: This community is considered tolerant to pressures from activity. The species have high recoverability and are tolerant. The stock is confined in bags, is sourced from hatcheries and up to 80% triploid.
Disturbing: No
Justification: This community is considered tolerant to pressures from activity. The species have high recoverability and are tolerant. The stock is confined in bags, is sourced from hatcheries and up to 80% triploid.
-
Disturbing: Yes
Justification: This community is considered sensitive to pressures from activity due to shading and compaction. Activity represents 0.15% of this community type
Oysters (Crassostrea gigas), on the seafloor.
Subtidal Extensive -
Disturbing: Yes
Justification: Harvest method using dredge disturbing to seafloor fauna. All stock cannot be recovered due to uncontained placement on seafloor. If diploid stock is used the risk of successful reproduction is greater than if 3n stock is used. Activity represents 0.09% of this community type.
- - -
Mussel (Mytilus edulis) on ropes
Subtidal Intensive -
Disturbing: Yes
Justification: The high density of stock will impact on seafloor due to organic enrichment (faeces and pseudofaeces) and stock drop off. This activity represents 1.28% of this community type.
- - -
Salmon (Salmo salar) in net pens
Subtidal Intensive -
Disturbing: Yes
Justification: The community type and species would be sensitive to the activity by virtue of persistent organic enrichment on the seafloor. The spatial overlap is 0.20% of this community type.
- -
Disturbing: Yes
Justification: The community type and species would be sensitive to the activity by virtue of persistent organic enrichment on the seafloor. The spatial overlap is 0.17% of this community type.
66
Large Shallow Inlet and Bay [1160]
Culture Type Location Method
Intertidal sandy mud with Tubificoides benedii and
Pygospio elegans community complex
Sandy mud with polychaetes and bivalves
community complex
Fine sand dominated by Nephtys cirrosa
community Shingle Reef
Abalone in contained systems
Subtidal Intensive -
Disturbing: Yes
Justification: This community type would be sensitive to the activity by virtue of physical disturbance. The spatial overlap is 0.05% of this community type.
- -
Disturbing: No
Justification: This community type is considered tolerant to pressures from activity.
Scallop on seabed Subtidal Extensive -
Disturbing: No
Justification: Given the species to be cultured is native and that harvesting is proposed to be by hand (diving), This community type is not likely be sensitive to the activity.
- -
Disturbing: No
Justification: This community type is considered tolerant to pressures from activity.
Vehicular traffic in Intertidal areas.
Intertidal Intensive
Disturbing: Yes
Justification: This community type is likely sensitive to persistent pressure (compaction) from this activity. The spatial overlap is 0.14% of this community type.
Disturbing: Yes
Justification: This community type is likely sensitive to persistent pressure (compaction) from this activity. The spatial overlap is 0.11% of the community type.
-
Disturbing: Yes
Justification: This community type is likely sensitive to persistent pressure (compaction) from this activity. The spatial overlap is 0.10% of the habitat type (<15% threshold).
Disturbing: Yes
Justification: This community type is likely sensitive to persistent pressure (compaction) from this activity. The spatial overlap is 0.04% of this community type.
Cumulative Impact Aquaculture
Disturbing: No
Justification: the cumulative pressure of likely impacting activities is 1.87% on this community type.
Disturbing: No
Justification: the cumulative pressure of likely impacting activities is 1.73% on this community type.
Disturbing: No
Justification: the cumulative pressure of likely impacting activities is 0% on this community type.
Disturbing: No
Justification: the cumulative pressure of likely impacting activities is 0.10% on this community type.
Disturbing: No
Justification: the cumulative pressure of likely impacting activities is 0.39% on this community type.
67
8.4 Assessment of the effects of shellfish production on the Conservation Objectives for Harbour Seal in Clew Bay Complex SAC.
Clew Bay Complex SAC is designated for the Harbour Seal (Phoca vitulina). The distribution of harbour
seal and site use are provided in Figure 3. The conservation objectives for this species are listed in
Table 1 and can be found in detail in NPWS (2011; 2012). While the conservation status of the species
is considered favourable at the site, the interactions between harbour seals and the features and
aquaculture activities carried out in the SAC must be ascertained.
The interactions between aquaculture operations and aquatic mammal species are a function of:
1. The location and type of structures used in the culture operations - is there a risk of
entanglement or physical harm to the animals from the structures or is access to locations
restricted?
2. The schedule of operations on the site – is the frequency such that they can cause disturbance
to the animals?
The proposed activities must be considered in light of the following attributes and measures for the
Harbour Seal:
- Access to suitable habitat – number of artificial barriers
- Disturbance – frequency and level of impact
- Harbour Seal Sites:
. Breeding sites
. Moulting sites
. Resting sites
Restriction to suitable habitats and levels of disturbance are important pressures that must be
considered to ensure the maintenance of favourable conservation status of the harbour seal and implies
that the seals must be able to move freely within the site and to access locations considered important
to the maintenance of a healthy population. They are categorised according to various life history stages
(important to the maintenance of the population) during the year. Specifically they are breeding,
moulting and resting sites (Figure 3). It is important that the access to these sites is not restricted and
that disturbance, when at these sites, is kept to a minimum. The structures used in culture of oysters
(bags on trestles) can form a physical barrier to seals when both submerged and exposed on the
shoreline such that the access to haul-out locations might be blocked. Activities at sites and during
movement to and from culture sites may also result a disturbance events such that the seals may note
an activity (head turn), move towards the water or actually flush into the water. While such disturbance
events might have been documented, the impact of these disturbances at the population level has not
been studied more broadly (National Research Council, 2009).
Intertidal oyster culture using bags and trestles has been conducted in and around Clew Bay for almost
30 years. The current level of production reflects a gradual increase in activity at the site over this period
and is represented as licenced activities in Figures 5. It is considered that, given the favourable
68
conservation status of Harbour Seals within the SAC represented by stable numbers since 2009 (NPWS
2012) that the current production levels (and activities associated with them) are conducive with
favourable conservation status.
The current activities do not physically overlap with any breeding or moulting locations identified in the
SAC (Figure 17 and 18). It would appear that the current level of activity at the sensitive times of the
year (breeding and moulting, i.e. May to September) is sufficient to maintain stable seal counts at the
site. There appears to be relatively close proximity between some breeding sites and aquaculture
operations (existing and proposed) in the northern portion of the bay. However, it is important to point
out that the activities concerned occur almost exclusively at low water in sand or mud flats with no
residual water that would be conducive to haul out of seals at the sites, i.e. areas proximate to deeper
water in the event of flushing. It is likely that the aquaculture activities occur on the opposite side of the
islands from where the seals haul out and out of direct line of sight. In addition, the level of activity is
unlikely to increase greatly at these sites, as it will be dictated primarily by the tidal duration and extent
of exposed habitat available for exploitation.
As indicated previously, seal interactions with marine finfish cages have been identified (Aquaculture
Stewardship Council, 2012). The risk to seals (as predators) result from their interaction with netting
where if incorrectly configured (loose) the risk of drowning due to being entangled is increased. While
a risk of entanglement in netting may present, it is not considered likely given that slack netting also
presents a risk to culture organism in that it reduces the containment area. In terms of mitigation and in
order to minimise risk to seals, the operators should employ a range of management actions including
stock management (density control, regular removal of mortalities from cages), use of seal blinds and
appropriate net tensioning which are all considered suitable methods to minimise negative interactions
between seals and finfish culture (Aquaculture Stewardship Council 2012). The use of ADDs is not
considered practical. Lethal actions to remove seals are only allowed under licence, the criteria which
are determined by NPWS (Section 42 of the Wildlife Act, 1976 (as amended)).
Conclusion 1: The current levels of licenced aquaculture (existing and renewals) and the new
applications are considered non-disturbing to harbour seal conservation features.
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Figure 17. Harbour Seal Sites and Aquaculture Sites (licenced and applications) in Clew Bay – North
Figure 18. Harbour Seal Sites and Aquaculture Sites (licenced and applications) in Clew Bay – South
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8.5 Assessment of the effects of shellfish production on the Conservation Objectives for otter and migrating salmon in Clew Bay Complex SAC.
As the aquaculture production activities within the SAC spatially overlap with Otter (Lutra lutra), and
Salmon (Salmo salar) these activities may have negative effects on the abundance and distribution of
populations of these species.
Otter (Lutra lutra)
Clew Bay Complex SAC is designated for the Otter (Lutra lutra); the conservation objectives for such
are listed in Table 1. The risk of negative interactions between aquaculture operations and aquatic
mammal species is a function of:
1. The location and type of structures used in the culture operations- is there a risk of
entanglement or physical harm to the animals from the structures?
2. The schedule of operations on the site – is the frequency such that they can cause disturbance
to the animals?
Bottom Culture, harvesting and fishing
Given that this culture type does not entail any structures and operations are likely to be carried out in
daylight hours, while the otter foraging is primarily crepuscular, the interaction with bottom culture
operators/operations with the otter is likely to be minimal. It is unlikely that this culture type poses a risk
to otter populations in Clew Bay. Impacts can be discounted.
Oyster and Mussel culture (suspended)
Given the intertidal location of the structures and activities associated this form of oyster culture it is
unlikely that the marine mammals will have any negative interaction with this culture method. Impacts
can be discounted.
The proposed activities will not lead to any modification of the following attributes for otter:
- Extent of terrestrial habitat,
- Extent of marine habitat or
- Extent of freshwater habitat.
- The activity involves net input rather than extraction of fish biomass so that no negative impact
on the essential food base (fish biomass) is expected
- The number of couching sites and holts or, therefore, the distribution, will not be directly
affected by aquaculture and fisheries activities.
- Shellfish production activities are unlikely to pose any risk to otter populations through
entrapment or direct physical injury.
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- Disturbance associated with vessel and foot traffic could potentially affect the distribution of
otters at the site. However, the level of disturbance is likely to be very low given the likely
encounter rates will be low dictated primarily by tidal state.
Salmon (Salmo salar)
There are two rivers that run into Clew Bay Complex SAC that are designated as SACs for salmon.
These are the Newport River and the Srahmore (Burrishoole). Estimates of the numbers of adult
salmon returning to the Srahmore River represent 50% of the conservation limits based upon 2018
returns (TEGOS 2019). However, these estimates are sufficient to deem the system open for a catch
and release fishery during 2019. In the Newport River, estimates for 1 Sea Winter fish are 165% of
conservation limits. The Newport River continues to met it’s conservation limits (since 2008) and has
had a surplus available for exploitation.
Significant declines in sea survival and reduced returns to the coast and rivers of Atlantic salmon in
recent decades have been recorded in Ireland (Salmon Management Task Force Report (Anon., 1996);
O'Maoileidigh et al., 2004; Jackson et al., 2011). The reasons for the reduced sea survival remain
unclear and speculation has covered such issues as global warming effects (Friedland et al., 2000;
Friedland et al., 2005), changes in locations or availability of prey species, loss of post-smolts as by-
catch in pelagic fisheries, increased fishing pressure, habitat changes and sea lice infestation (Finstad
et al., 2007; SSCWSS 2013). However, despite many years of study, processes contributing to the high
mortality of juvenile Atlantic salmon between ocean entry and the first winter at sea remain poorly
understood (Jones, 2009).
The results of a long term study carried out in the Burrishoole (Jackson et al., 2011) show a strong and
significant trend in increasing marine mortality of Atlantic salmon originating from the Burrishoole
system (i.e. study area). They would also point to infestation of outwardly migrating salmon smolts with
the salmon louse (L. salmonis) as being a minor and irregular component of marine mortality in the
stocks studied and not being implicated in the observed decline in overall survival rate. The results of
this study have been corroborated by studies carried out by the Marine Institute as part of a detailed
investigation into the potential impacts of sea lice on a number of other river systems, including the
Newport River (Jackson et al., 2013).
The Irish State has developed a comprehensive control and management strategy for sea lice
infestations on farmed salmonids. This systems is underpinned by research dating back to the early
1990s and was the basis for the introduction of the original lice monitoring programme (Jackson and
Minchen, 1993). Subsequent research (Jackson et al., 2000; Jackson et al., 2002) informed the
development of a set of management protocols published by the Department of Marine in 2000 (Anon.,
2000). The full implementation of these protocols resulted in improved sea lice control on farmed salmon
(O’Donohoe et al., 2013). There has been a policy of utilising research to ensure that the most up to
date and effective treatment and management regimes are in place to control sea lice on Irish farms
and this has included research into techniques to assess the most effective treatment regimes (Sevatdal
et al., 2005) and the sources of sea lice infestation in the marine environment (Jackson et al., 1997;
Copley et al., 2005; Copley et al., 2007).
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The monitoring and control system in place is comprehensive, transparent and independent. The Irish
management and control system is widely regarded as best international practice because it has low
treatment trigger levels, is based on independent inspection regimes, has a robust follow-up on problem
areas and Ireland is the only country in the world to publish the results of the independent state run
inspection programme in full each year (O’Donohoe et al., 2013). Following the introduction of the
“Strategy for improved pest control on Irish salmon farms” in 2008 by the Department of Agriculture
Fisheries and Food there were significant improvements in sea lice management in Ireland (Jackson,
2011).
The control strategy is aimed at implementing a more strategic approach to lice control at a bay level
and targeting efforts on the spring period where there is a potential for impacts on wild smolts embarking
on their outward migration. The effectiveness of the system is witnessed by trends in sea lice infestation
on farmed fish in the peak period for wild salmon smolt migration having shown a strong downward
trend since the introduction of the new management strategy (Jackson et al., 2013). As indicated
previously, in relation to disease interactions, any risks of disease transfer between cultured finfish
and wild fish are mitigated by the management systems currently in place. In summary, Council
Directive 2006/88/EC on animal health requirements for aquaculture animals and products thereof, and
on the prevention and control of certain diseases in aquatic animals form the legislative basis that
governs the monitoring and management of disease outbreaks in mariculture operations in Ireland. For
diseases not listed in this Directive, a Code of Practice and Fish Health Handbook has been developed
jointly by the State and industry with the primary objectives of disease prevention and control.
Active veterinary surveillance and intervention has assisted in reducing the prevalence and spread of
many pathogens. In addition, the principles outlined in the Fish Health Handbook mentioned above
such as improved biosecurity practices on farms, fallowing sites to break transmission cycles, veterinary
inspection of fish prior to transfer, single year class stocking, coordinating treatments and harvesting
within embayments etc have mitigated the transmission of pathogenic organisms.
Notwithstanding the issues highlighted above, it is concluded that aquaculture production in
the Clew Bay SAC does not pose any risk to the following salmon attributes:
Distribution (in freshwater)
Fry abundance (freshwater)
Population size of spawners (fish will not be impeded or captured by the proposed
activity)
Smolt abundance (out migrating smolts will not be impeded or captured by the proposed
activity)
Water quality (freshwater)
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9 Risk Assessment of Fishing Activities
9.1 Risk assessment screening of fisheries
None of the fisheries activities, by definition, can overlap with the following features:
o 1013 Geyer's whorl snail Vertigo geyeri – (terrestrial snail)
o 1210 Annual vegetation of drift lines
o 1220 Perennial vegetation of stony banks
o 1330 Atlantic salt meadows (Glauco‐Puccinellietalia maritimae)
o 2110 Embryonic shifting dunes
o 2120 Shifting dunes along the shoreline with Ammophila arenaria ("white dunes")
o 1150 Coastal Lagoons
Fishery interaction with these features are excluded from further analysis.
9.2 Methodology:
9.2.1 Determining risk to the conservation objectives
The risk assessment framework follows, where feasible, EC guidance (2012) and includes elements of
risk assessment from Fletcher (2004, 2005). The qualitative and semi-quantitative framework is
described in Marine Institute (2013) and criteria for risk categorization is shown in Tables 14 and 15
below.
The framework uses categorical conditional probability matrices of likelihood and consequence to
assess the risk of an activity to a conservation feature. Categorical likelihood and consequence scores
for each such ‘incident’ (fishery-designated feature interactions) are provided by expert judgement and
a base literature resource which has been pre-compiled for each habitat type defined in the COs.
Separate conditional probability matrices for habitats and designated species are used to assess risk.
In the case of habitats the consequence criteria largely follow the definitions and methodologies used
for AA of projects and plans. In the case of species the consequence categories relate to the degree to
which populations and their supporting habitats may be negatively affected by the given activity.
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Table 14. Risk categorization for fisheries and designated habitat interactions (see: Marine Institute 2013). Colours indicate risk category. Disturbance is defined
as that which leads to a change in characterising species. Such disturbance may be temporary or persistent depending on the frequency of impact and the
sensitivity of the receiving environment. Colours indicate the probable need for mitigation of effects from green (no mitigation needed), to yellow (mitigation
unlikely to be needed but review on a case by case basis), orange (mitigation probably needed) and red (mitigation required)
Habitats Consequence criteria
Activity is not present or has no contact with habitat
Activity occurs and is in contact with habitat
Up to 15% overlap of fishery and habitat seasonally.
Over 15% overlap of fishery and habitat seasonally.
Over 15% of habitat disturbed persistently leading to cumulative impacts
Impact is effectively permanent due to severe habitat alteration.
No change due to fishing activity can occur
Individual effects on characterising species but this is undetectable relative to background natural variability
Seasonal change in characterising species and community structure and function
Seasonal change in characterising species and structure and function
Persistent change in characterising species, structure and function
Biodiversity reduction associated with impact on key structural species
Frequency of disturbance < recovery time. Non-cumulative
Frequency of disturbance> recovery time. Cumulative
No recovery or effectively no recovery
Likelihood % Level 0 1 2 3 4 5
Highly likely >95 5 0 5 10 15 20 25
Probable 50-95 4 0 4 8 12 16 20
Possible 20-50 3 0 3 6 9 12 15
Unlikely 1-20 2 0 2 4 6 8 10
Remote 1 1 0 1 2 3 4 5
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Table 15. Risk categorization for fisheries and designated species interactions (Marine Institute 2013)
Species Consequence criteria
Activity is not present and individuals or population cannot be affected
Activity present. Individuals in the population affected but effect not detectable against background natural variability
Direct or indirect mortality or sub-lethal effects caused to individuals by the activity but population remains self-sustaining
In site population depleted by the activity but regularly sub-vented by immigration. No significant pressure on the population from activities outside the site
Population depleted by the activity both in the site and outside of the site. No immigration or reduced immigration
Population depleted and supporting habitat significantly depleted and unable to continue to support the population
Likelihood % Level 0 1 2 3 4 5
Highly likely >95 5 0 5 10 15 20 25
Probable 50-95 4 0 4 8 12 16 20
Possible 20-50 3 0 3 6 9 12 15
Unlikely 1-20 2 0 2 4 6 8 10
Remote 1 1 0 1 2 3 4 5
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9.2.2 Sensitivity of characterizing species and marine communities to physical disturbance by fishing gears
- The approach and rationale to assessment of the sensitivity of species and habitats to fishing
activities and the information used in this assessment is similar to that outlined in 8.2 for aquaculture
- NPWS (2011b) provide lists of species characteristic of the habitats that are defined in the
Conservation Objectives. The sensitivity of these species to various types of pressures varies and
the species list varies across habitats.
- Pressures due to fishing are mainly physical in nature i.e. the physical contact between the fishing
gear and the habitat and fauna in the habitat causes an effect.
- Physical abrasive/disturbing pressures due to fishing activity of each metier maybe classified broadly
as causing disturbance at the seabed surface and/or at the sub-surface.
- Fishing pressures on a given habitat is related to vulnerability (spatial overlap or exposure of the
habitat to the gear), to gear configuration and action, frequency of fishing and the intensity of the
activity. In the case of mobile gears intensity of activity is less relevant than frequency as the first
pass of the gear across a given habitat is expected to have the dominant effect (Hiddink et al.. 2007).
- Sensitivity of a species or habitat to a given pressure is the product of the resilience of the species
to the particular pressure and the recovery capacity (rate at which the species can recover if it has
been affected by the pressure) of the species. Morphology, life history and biological traits are
important determinants of sensitivity of species to pressures from fishing and aquaculture.
- The separate components of sensitivity (resilience, recoverability) are relevant in relation to the
persistence of the pressure
o For persistent pressures, i.e. fishing activities that occur frequently and throughout the year,
recovery capacity may be of little relevance except for species/habitats that may have extremely
rapid (days/weeks) recovery capacity or whose populations can reproduce and recruit in
balance with population reduction caused by fishing. In all but these cases, and if resilience is
moderate or low, then the species may be negatively affected and will exist in a modified state.
Such interactions between fisheries and species/habitats represent persistent disturbance.
They become significantly disturbing if more than 15% of the community is thus exposed
(NPWS 2011b).
o In the case of episodic pressures i.e. fishing activities that are seasonal or discrete in time both
the resilience and recovery components of sensitivity are relevant. If resilience is low but
recovery is high, relative to the frequency of application of the pressure, than the
species/community will be in favourable conservation status for a given proportion of time
- The sensitivities of some species, which are characteristic (as listed in the COs) of benthic
communities, to physical pressures similar to that caused by fishing gears, are described in Table 9.
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- In cases where the sensitivity of a characterising species (NPWS 2011b) has not been reported this
risk assessment adopts the following guidelines
o Resilience of certain taxonomic groups such as emergent sessile epifauna to physical
pressures due to all fishing gears is expected to be generally low or moderate because of
their form and structure (Roberts et al.. 2010).
o Resilience of benthic infauna (eg bivalves, polychaetes) to surface pressures, caused by pot
fisheries for instance, is expected to be generally high as such fisheries do not cause sub-
surface disturbance
o Resilience of benthic infauna to sub-surface pressures, caused by toothed dredges and to a
lesser extent bottom otter trawls using doors, may be high in the case of species with smaller
body sizes but lower in large bodied species which have fragile shells or structures. Body
size (Bergman and van Santbrink 2000) and fragility are regarded as indicative of resilience
to physical abrasion caused by fishing gears
o Recovery of species depends on biological traits (Tillin et al.. 2006) such as reproductive
capacity, recruitment rates and generation times. Species with high reproductive capacity,
short generation times, high mobility or dispersal capacity may maintain their populations
even when faced with persistent pressures but such environments may become dominated
by these (r-selected) species. Slow recovery is correlated with slow growth rates, low
fecundity, low and/or irregular recruitment, limited dispersal capacity and long generation
times
9.3 Risk assessment of impact of fishing gears on marine benthic communities
The list of fishing activities (métiers) operating in Clew Bay is described in section 4.2 above
The sensitivity of marine communities, which are the subject of the COs to physical disturbance
that may be caused by fishing gears is in Table 9.
The sensitivities of species, characteristic of the marine communities, described in the COs are
in Table 10.
The risk assessment framework outlined in Table 14 and Table 15 for habitats and species
respectively provides a rationale for assessing and scoring risk posed by fishing activities to
the conservation objectives. More detailed explanation is provided in Marine Institute (2013).
One of the risk assessment criteria for habitats is the % overlap of the activity and each habitat.
These % overlaps of fisheries with qualifying interests are presented in Table 16. The overlap
of fisheries and marine community types within those qualifying interests in presented in Table
17.
Risk scores for effects of individual fisheries on marine community types and species are in
Table 18.
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9.3.1 Potting for shrimp
Shrimp potting occurs throughout inner Clew Bay mainly during the period Sept-Dec
Shrimp potting overlaps with 38% of Habitat 1160 and with marine community types in Habitat
1160 as follows; 87% of Zostera community, 34% of Maerl community, 33% with sandy mud
with polychaetes and bivalves, 36% with fine sand with N. cirrosa and 86% of sub-tidal faunal
and Laminaria reef.
The actual footprint of static gear such as shrimp pots is expected to be much lower than the
percentage of the area over which the fishery might occur
The risk posed by shrimp potting and associated surface disturbance in sub-littoral sandy muds
and in fine sand is low as the associated species are infaunal and are largely protected from
surface disturbance. These species are not sensitive to surface disturbance (ABPMer 2013e,
Evidence Proformas Appendix F)
Maerl is highly sensitive to surface disturbance or physical impacts. Maerl thalli can be crushed
and the surface matrix can be altered. Maintenance of structural integrity of the maerl thalli is
important in maintaining biodiversity of associated species (ABPMer 2013b, Evidence
Proformas, Appendix F)
Zostera has moderate to high sensitivity to surface disturbance and high sensitivity to intensive
potting activity (Hall et al 2008, ABPMer 2013a, Evidence Proformas, Appendix F)
Faunal reef and Laminaria reef habitats have low sensitivity to static fishing gears although the
sensitivity of species in these habitats may vary depending on life history characteristics
(ABPMer 2013h, Evidence Proformas Appendix F). Damage from pots could be caused by
direct impact of pots on the seabed, the effects of ropes on emergent epifauna or seaweeds
and from anchors which may drag during hauling of gear. Cumulative damage to sensitive
species could result if the intensity of the activity is high. Emergent sessile epifauna such as
Alcyonium, Cliona and Echinus may be impacted by pots, ropes and anchors. However, these
species have medium resilience and high recoverability to physical abrasion. Laminaria and
macroalgae in this habitat have low sensitivity to single abrasive events.
Potting for shrimp may cause non-cumulative disturbance of faunal reef and Laminaria
reef.
9.3.2 Potting for prawns
Potting for prawns occurs on mud and sandy mud substrates in the middle of Clew Bay mainly
outside of the SAC.
Prawn potting overlaps with 10% of Habitat 1160 and with marine community types in Habitat
1160 as follows; 6% with sandy mud with polychaetes and bivalves and 36% of sub-tidal faunal
and Laminaria reef. Overlap with reef is an artifact of the poor resolution of the fishing data
relative to the scale of the marine community features as Nephrops does not occur in reef
habitat.
This habitat and associated species are not sensitive to surface disturbance (ABPMer 2013e,
Evidence Proformas Appendix F)
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The risk posed by prawn potting to sandy mud communities is deemed to be low and
insignificant.
9.3.3 Potting for crab and lobster
Crab and lobster potting occurs throughout inner Clew Bay. Activity is higher during summer
months
Crab and lobster potting overlaps with 17% of Habitat 1160 and with marine community types
in Habitat 1160 as follows; 12% with sandy mud with polychaetes and bivalves and 55% of sub-
tidal faunal and Laminaria reef.
The actual footprint of static gear such as shrimp pots is expected to be much lower than the
percentage of the area over which the fishery might occur
The risk posed by crab and lobster potting to sandy mud communities is deemed to be low and
insignificant. This habitat and associated species are not sensitive to surface disturbance
(ABPMer 2013e, Evidence Proformas Appendix F)
Faunal reef and Laminaria reef habitats have low sensitivity to static fishing gears although the
sensitivity of species in these habitats may vary depending on life history characteristics
(ABPMer 2013h, Evidence Proformas Appendix F). Damage from pots could be caused by
direct impact of pots on the seabed, the effects of ropes on emergent epifauna or seaweeds
and from anchors which may drag during hauling of gear. Cumulative damage to sensitive
species could result if the intensity of the activity is high. Emergent sessile epifauna such as
Alcyonium, Cliona and Echinus may be impacted by pots, ropes and anchors. However, these
species have medium resilience and high recoverability to physical abrasion. Laminaria and
macroalgae in this habitat have low sensitivity to single abrasive events.
Potting for lobster and crab may cause non-cumulative disturbance of faunal reef and
Laminaria reef. The likelihood of disturbance is higher than for shrimp potting as the
activity is more likely to target reef areas and the gear units are heavier and may cause
more abrasion than shrimp pots.
9.3.4 Potting for whelk
Potting for whelk began in 2013 in the north east of the Bay on sandy mud community.
The spatial overlap is unknown. Given that the stock has probably been depleted the
fishery is unlikely to continue to any significant degree.
The risk posed by whelk potting to sandy mud communities is deemed to be low and
insignificant. This habitat and associated species are not sensitive to surface disturbance
(ABPMer 2013e, Evidence Proformas Appendix F).
9.3.5 Tangle netting for crayfish
Tangle netting for crayfish occurs throughout the Clew Bay area. Most of the activity is outside
of the SAC
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Spatial overlap with designated habitats and marine community types is not calculated as
tangle nets have minimal contact with the seabed
There is no overlap with sensitive reef habitat such as Zostera and Maerl.
There is some overlap with Laminaria dominated and faunal reef habitat
Ropes and anchors from bottom set nets may cause surface and sub-surface abrasion in reef
habitat. The footprint of this pressure however is likely to be very small and in reality the fishery
is highly unlikely to occur in the Laminaria zone and more likely to occur in faunal reef.
The reef habitat has low sensitivity to physical abrasion although species sensitivity may vary
from low to high. Emergent sessile epifauna such as Alcyonium, Cliona and Echinus may be
impacted by ropes and anchors. However, these species have medium resilience and high
recoverability to physical abrasion
The risk posed by the tangle netting activity to reef habitats is low
9.3.6 Gill netting for Pollack and mackerel
Gill netting for Pollack and Mackerel occurs throughout the Clew Bay area. Most of the activity
is outside of the SAC
Spatial overlap with designated habitats and marine community types is not calculated as
tangle nets have minimal contact with the seabed
There is no overlap with sensitive reef habitat such as Zostera and Maerl.
There is some overlap with Laminaria dominated and faunal reef habitat in the SAC
Ropes and anchors from bottom set nets may cause surface and sub-surface abrasion in reef
habitat. The footprint of this pressure however is likely to be very small and in reality the fishery
is highly unlikely to occur in the Laminaria zone and more likely to occur in faunal reef.
The reef habitat has low sensitivity to physical abrasion although species sensitivity may vary
from low to high. Emergent sessile epifauna such as Alcyonium, Cliona and Echinus may be
impacted by ropes and anchors. However, these species have medium resilience and high
recoverability to physical abrasion
The risk posed by the gill netting activity to reef habitats is low
9.3.7 Dredging for scallop
Dredging for scallop occurs on sedimentary and reef habitat in Clew Bay mainly outside of the
SAC.
Based on expert data scallop dredging overlaps with 47% of Habitat 1160. Scallop dredging
overlaps with marine community types in Habitat 1160 as follows; 54% with Zostera, 63% with
Maerl, 42% with sandy mud with polychaetes and bivalves, 56% with fine sand with N. cirrosa
and 90% of sub-tidal faunal and Laminaria reef.
Maerl is highly sensitive to physical surface and sub-surface abrasion pressure caused by
mobile fishing gears such as scallop dredging. There is a high risk that maerl will be killed and
that habitat structure and associated biodiversity will be eroded (ABPMer 2013b, Evidence
Proformas Appendix F)
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Zostera has no or low resistance to shallow disturbance caused by dredging. Resistance is
slightly higher in harder sediments compared to soft sediments. Recovery is medium to low
(>6yrs) depending on the extent of the impact. When large areas are impacted recovery will be
longer. There is a high risk that Zostera will be uprooted and killed by scallop dredges (ABPMer
2013a, Evidence Proformas Appendix F).
Faunal reef habitat is not sensitive to surface abrasion but associated species may have low or
high sensitivity to this pressure and to sub-surface disturbance caused by scallop dredging.
Emergent epifauna are sensitive to physical disturbance. Species such as Echinus and
Metridium have low resistance but moderate resilience to physical abrasion. As some species
associated with faunal reef habitat have high sensitivity to physical abrasion there is a risk that
the species composition of these reefs may be altered by scallop dredging (ABPMer 2013h,
Evidence Proformas Appendix F).
Laminaria reef is generally resistant to surface abrasion and recovery is also high. However,
resistance is low to repeated abrasive pressure combined with entanglement, removal of
holdfasts and possible habitat disturbance (capture of stones and boulders in gear). The impact
will depend on frequency and intensity of the activity (ABPMer 2013, Evidence Proformas
Appendix F).
Scallop dredging poses significant risk to Zostera, Maerl and reef habitats and less so
to sedimentary habitats.
9.3.8 Dredging for oyster
Dredging for oyster occurs on sedimentary and reef habitat in Clew Bay.
Based on MI survey data oyster dredging overlaps with 0.9% of Habitat 1160 and 0.04% of
Habitat 1140. Oyster dredging overlaps with marine community types in Habitat 1160 as
follows; 1% with Zostera, 1% with Maerl, 1% with sandy mud with polychaetes and bivalves
and 1% of Laminaria reef. Overlaps with QI 1140 are 1% on Intertidal sandy mud and 1% on
sandy mud.
The survey data may not cover the entire area over which oyster are distributed and may not
reflect the current distribution of commercial densities of oyster and therefore may or may not
be representative of the distribution of fishing activity. However, oyster stocks are depleted and
the fishery is unlikely to extend over significant areas of habitat over and above the % quoted
above
Maerl is highly sensitive to physical surface and sub-surface abrasion pressure caused by
mobile fishing gears such as oyster dredging. There is a high risk that maerl will be killed and
that habitat structure and associated biodiversity will be eroded (ABPMer 2013b, Evidence
Proformas Appendix F)
Zostera has no or low resistance to shallow disturbance caused by dredging. Resistance is
slightly higher in harder sediments compared to soft sediments. Recovery is medium to low
depending on the extent of the impact. When large areas are impacted recovery will be longer.
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There is a high risk that Zostera will be uprooted and killed by oyster dredges (ABPMer 2013a,
Evidence Proformas Appendix F).
Dredging in sedimentary habitats has the potential to change sediment composition and lead
to associated changes in faunal communities. However, these habitats and associated species
have no or low sensitivity to surface and shallow disturbance caused by oyster dredging
(ABPMer 2013e, Sensitivity Matrices_Appendix E)
Oyster dredging poses significant risk to Zostera and Maerl habitats and less so to
sedimentary habitats. However, spatial overlaps between the fishery and Zostera and
Maerl habitats are very low and the likelihood of a cumulative effect is therefore low. The
spatial distribution of the fishery however depends on the status of oyster stocks. The
footprint of the fishery could expand if oyster stocks recovered.
9.3.9 Bottom trawling for mixed demersal fish
No bottom trawling for mixed demersal fish occurs in the SAC.
Risks to habitats from this activity can be discounted
9.3.10 Midwater trawling for pelagic fish
No mid water trawling for pelagic fish occurs in the SAC.
Risks to habitats can be discounted.
9.3.11 Hook and line fishing for mackerel
Trolling for mackerel and Pollack may occur in the outer area of the SAC
Trolling poses no risk to habitats or constituent marine communities
9.3.12 Draft net fishing for salmon
Draft net fishing for salmon may occur in estuaries of rivers flowing into Clew Bay
Draft netting poses no risk to habitats or constituent marine communities
9.3.13 Trammel net fishing for bait
Trammel netting for bait may occur throughout the Bay but is more likely to occur in reef areas
There is some overlap with Laminaria dominated and faunal reef habitat
Ropes and anchors from bottom set nets may cause surface and sub-surface abrasion in reef
habitat. The footprint of this pressure however is likely to be very small and in reality the fishery
is highly unlikely to occur in the Laminaria zone and more likely to occur in faunal reef.
The reef habitat has low sensitivity to physical abrasion although species sensitivity may vary
from low to high. Emergent sessile epifauna such as Alcyonium, Cliona and Echinus may be
impacted by ropes and anchors. However, these species have medium resilience and high
recoverability to physical abrasion
The risk posed by the trammel netting activity to reef habitats is low
83
9.3.14 Hand gathering of periwinkle and cockle
The distribution of hand gathering for periwinkle is unknown but by definition it is restricted to
intertidal habitat
It is likely to occur on shores dominated by Ascophyllum and Fucus seaweeds
High trampling pressure from hand gatherers on Fucus and Ascophyllum communities can
cause community change.
Resistance of these species is Low-Moderate while resilience is Moderate to very High. The
sensitivity of species to trampling is low (ABPMer, 2013h, Evidence Proforma Appendix F).
Seasonal change in the abundance of characterizing species may occur due to trampling but
this is very unlikely to be cumulative.
Hand gathering of cockles could result in trampling and physical disturbance of fauna, mortality
of fauna and extraction of cockles. Its effect is likely to be non cumulative although unrestricted
intensity and frequency of such activity could lead to cumulative effects on intertidal
sedimentary communities. The fishery is not currently active.
The risk posed by hand gathering to intertidal reef communities is likely to be low but
could be significant locally depending on the frequency and intensity of the activity.
9.3.15 Cumulative effects of fishing on marine communities
Fishing pressures from all metiers combined declines eastwards, from the centre to the eastern
shores of the Bay (Figures 20-23).
Up to 9 metiers may be active towards the western edge of the SAC and this number of
overlapping metier declines eastwards.
These métiers are potting for crab, lobster, shrimp and prawns, dredging for scallop, dredging
for oyster, tangle/gill netting, trammel netting and trolling.
Multiple overlapping fishing métiers occur in Laminaria and faunal reef habitat and in sandy
mud sedimentary habitat.
The cumulative risk posed by static gears (potting, tangle/gill netting, trammel netting) to sandy
mud sedimentary habitats is low as these gears do not individually have a significant impact on
sedimentary habitats.
Potting metiers may individually cause non-cumulative disturbance in faunal and Laminaria
reefs. The cumulative risk posed by static gears (potting, tangle/gill netting, trammel netting) to
reef habitats is similar to the individual scores; these gears are used only seasonally (especially
netting), the quantity of netting in the SAC is low and netting is unlikely to occur in Laminaria
reef. Cumulative effects (and higher consequence) are unlikely.
The cumulative risk posed by mobile dredging gears in sedimentary or reef habitats is low
because oyster fishing is limited in extent and adds little extra cumulative pressure over and
above scallop fishing
Although potting metiers may cause non-cumulative disturbance in faunal and Laminaria reefs
these effects are likely to be benign relative to the effects of scallop dredging in reef. As such
84
cumulative effects of potting and dredging are small relative to the single effect of scallop
dredging.
Cumulative fishing pressure on Zostera and Maerl arises from Shrimp potting, Scallop dredging
and Oyster dredging. The additive effect of oyster dredging is insignificant as less than 1% of
Zostera and Maerl have overlaps with oyster fishing. As with Reef habitat the cumulative effect
of shrimp potting and scallop dredging on Zostera and Maerl are small relative to the single
effect of scallop dredging.
Figure 19. The distribution of fishing activity (count = number of fishing metier) in relation to
Laminaria reef communities in Clew Bay SAC.
85
Figure 20. The distribution of fishing activity (count = number of fishing metier) in relation to
faunal reef communities in Clew Bay SAC
Figure 21. The distribution of fishing activity (count = number of fishing metier) in relation to
Zostera communities in Clew Bay SAC
86
Figure 22. The distribution of fishing activity (count = number of fishing metier) in relation to
Maerl communities in Clew Bay SAC
87
Table 16. Percentage (%) overlap of fisheries with seabed habitats and qualifying interests 1140 and 1160.
Metier Target species 1140_Mud and
sand flats
1160 - Large shallow inlets and
bays
% of Feature % of Feature
Potting_Shrimp Palaemon serratus 0 38
Potting_lobster/crab Homarus gammarus, Cancer pagurus, Maja brachydactyla 0 17
Potting_prawns Nephrops norvegicus 0 10
Dredging_scallops Pecten maximus 0 46.7
Dredging_oysters Ostrea edulis 0 1
Tangle netting_crayfish Palinurus elephas 0 <1
Gill netting_pollack/mackerel Pollachius pollachius, Scomber scomber 0 <1
Netting_bait Mixed fish 0 17
Bottom trawling_demersal fish Mixed fish species 0 0
Mid-water trawling_pelagic fish Clupea harengus, Sprattus sprattus 0 0
Lining_pollack/mackerel Pollachius pollachius, Scomber scomber 0 0
Draft netting_salmon Salmo salar 0 <1
Hand gathering Littorina littorea, Cerastoderma edule Unknown Unknown
88
Table 17. Percentage overlap of fishing metiers, which have significant contact with the seabed, with marine community types in Habitats 1140 and
1160 in Clew Bay. MCTs with shading have no fishery overlapping with them
Qualifying interest code Qualifying interest name Marine Community Type (MCT)
Tra
p -
lo
bs
ter
Tra
p -
cra
b
Tra
p -
sh
rim
p
Tra
p -
Nep
hro
ps
Dre
dg
e -
sca
llo
p
Tra
p -
Wh
elk
Dre
dg
e o
yste
r
Dre
dg
e c
ock
le
Gil
l n
et
Ta
ng
le n
et
cra
yfi
sh
Tra
mm
el n
ett
ing
ba
it
Ott
er
traw
l -
de
me
rsa
l
Mid
-wa
ter
traw
l
Han
d g
ath
eri
ng
win
kle
s
Han
d g
ath
eri
ng
co
ck
les
Ho
ok
s a
nd
Lin
es
1140
Mudflats and sandflats not covered by seawater at low tide [1140]
Intertidal sandy mud with Tubificoides benedii and Pygospio elegans community complex 0 0 0 0 0 0 1 4 0 0 0 0 0 0 4 0
1140
Mudflats and sandflats not covered by seawater at low tide [1140]
Sandy mud with polychaetes and bivalves community complex 0 0 0 0 0 0 1 2 0 0 0 0 0 0 2 0
1140
Mudflats and sandflats not covered by seawater at low tide [1140]
Fine sand dominated by Nephthys 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
1160 Large shallow inlets and bays [1160] Zostera dominated community 0 0 87 0 54 0 1 0 0 0 0 0 0 0 0 0
1160 Large shallow inlets and bays [1160] Maërl-dominated community 0 0 34 0 63 0 1 0 0 0 0 0 0 0 0 0
1160 Large shallow inlets and bays [1160]
Sandy mud with polychaetes and bivalves community complex 12 12 33 6 42 ? 1 0 0 0 12 0 0 0 0 0
1160 Large shallow inlets and bays [1160]
Fine sand dominated by Nephtys cirrosa community complex 0 0 36 0 56 ? 0 0 0 0 0 0 0 0 0 0
1160 Large shallow inlets and bays [1160] Shingle 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
1160 Large shallow inlets and bays [1160]
Reef (intertidal, faunal and Laminaria) 55 55 86 36 90 90 0 0 0 0 55 0 0 ? 0 0
89
Table 18. The categorical risk (= consequence*likelihood of consequence) posed by bottom contacting gears each fishing activity to marine
communities. Blank cells indicate no spatial overlap or occurrence of the fishery in the MCT. Colour codes indicate the probable need for mitigation
as described in Tables 15 and 16 (See section 9.2.1).
Qualifying interest name and code Marine Community Type (MCT)
Tra
p -
lo
bs
ter
Tra
p -
cra
b
Tra
p -
sh
rim
p
Tra
p -
Nep
hro
ps
Tra
p -
Wh
elk
Dre
dg
e -
sca
llo
p
Dre
dg
e o
yste
r
Dre
dg
e c
ock
le
Gil
l n
et
Ta
ng
le n
et
cra
yfi
sh
Tra
mm
e n
ett
ing
ba
it
Ott
er
traw
l -
de
me
rsa
l
Mid
-wa
ter
traw
l
Han
d g
ath
eri
ng
win
kle
s
Han
d g
ath
eri
ng
co
ck
les
Mudflats and sandflats not covered by seawater at low tide [1140]
Intertidal sandy mud with Tubificoides benedii and Pygospio elegans community complex
=2*3 =4*4 =4*3
Mudflats and sandflats not covered by seawater at low tide [1140]
Sandy mud with polychaetes and bivalves community complex
=2*3 =4*4 =4*3
Large shallow inlets and bays [1160] Zostera dominated community =4*3
=4*4 =4*4
Large shallow inlets and bays [1160] Maërl-dominated community =4*4
=5*4 =5*4
Large shallow inlets and bays [1160]
Sandy mud with polychaetes and bivalves community complex =1*4 =1*4 =1*3 =1*3 =1*3 =4*3 =2*3 =1*4
Large shallow inlets and bays [1160]
Fine sand dominated by Nephtys cirrosa community complex =1*3 =1*3 =4*3
Large shallow inlets and bays [1160]
Reef (intertidal, faunal and Laminaria) =3*3 =3*3 =3*3 =1*4
=4*4 =2*4 =3*3 =4*3
90
9.4 Risk assessment of impact of fishing gears on designated species harbour seal, otter and salmon
9.4.1 Conservation objectives, status and habitat use
9.4.1.1 Harbour Seal
Harbour seals are listed in Annex II of the Habitats Directive. Although the species is wide ranging in
the marine environment the Directive requires Members States to establish Special Areas of
Conservation to protect them. Harbour seal use specific sites for breeding, moulting and resting and
have some degree of fidelity to these areas while also undertaking migrations and foraging movements
in open water outside of the sites for which they are designated.
The conservation objectives for Harbour seal have explicit targets
1. The species range within the site should not be restricted by artificial barriers
2. Breeding sites should be conserved in natural condition
3. Moult haul-out sites should be conserved in natural condition
4. Resting haul-out sites should be conserved in natural condition
5. Human activities should occur at levels that do not adversely affect the Harbour seal population
at the site
Harbour seals are common in Clew Bay SAC and use a variety of locations for haul out, breeding and
moulting. Their population in Clew Bay has increased; the 2003 census recorded 95 seals compared
to 241 in 2011. Although the behavior and foraging range of Harbour seals and their use of marine
habitats in Clew Bay is not well known it is expected, and as described in the conservation objectives,
that all areas of the Bay are used as foraging habitat and that their foraging range would extend well
beyond the boundaries of the SAC into open water to the west towards Clare Island. Harbour seals may
forage up to 30km from haul out sites in search of prey (Cordes et al 2011).
9.4.1.2 Otter
Otter (Lutra lutra) is listed in Annex II of the Habitats Directive. Otter is common throughout freshwater
systems in Ireland and also occurs in coastal marine habitats.
The conservation objectives for Otter in the marine environment have explicit targets
1. No significant decline in distribution
2. No significant decline in marine habitat
3. No significant decline in couching sites and holts
4. No significant decline in available fish biomass
5. No significant increase in barriers to connectivity
Otter population in Clew Bay may be depleted relative to the favourable conservation status which is
based on 1980/81 survey findings of 88% positive survey sites (NPWS 2011). Otters use marine habitat
in Clew Bay to an extent; otters may swim in open water to cross between islands or islands and the
91
mainland and may forage in shallow water 80m from the shore (NPWS 2011). Prey includes rockling
and wrasse in shallow reef areas.
9.4.1.3 Salmon
The conservation objectives for Salmon have explicit targets related mainly to populations and habitat
requirements in freshwater. The following targets could be affected by marine fisheries (including
salmon fisheries)
1. The conservation limit for the number of spawning fish should be consistently exceeded. This
is the spawning level that produces long term average maximum sustainable yield as derived
from the adult to adult stock and recruitment relationship
2. There are also density or population targets for fry and outward migrating smolt abundance
The Newport River flowing into the north east corner of Clew Bay is designated for salmon (Salmo
salar). Salmon smolts migrate from the Newport into marine waters of Clew Bay during April-May and
return as one sea winter fish or two sea winter fish during the following year(s). The Newport River
salmon stock is small with a conservation limit (which is the number of fish or stock level that maximizes
the long term average harvestable surplus) of 7,811 sea winter fish. Currently the stock is above this
level for 1 sea winter fish but below the conservation limit for 2 sea winter fish. Unplanned capture of
salmon i.e. by catch of salmon in fisheries other than the draft net fisheries could compromise the stocks
capacity to reach its conservation limit.
9.4.2 Risk of capture
9.4.2.1 Harbour Seal
There is no risk of capture of Harbour seal in shrimp pots, crab lobster pots, prawn pots, oyster
dredges, scallop dredges, salmon draft nets or in hook and line fisheries.
There is a low risk of capture of Harbour seals in mid-water trawls operating to the west of the
SAC. Grey seals are captured in mid-water trawls (Morizur et al.. 1999).
The highest risk of capture of Harbour seal is in tangle nets, gill nets and trammel nets.
Cosgrove et al. (2013) reported capture of 10 Harbour seals overall in 320mm mesh tangle
nets (8 seals) and 270mm trammel nets (2 seals) over 91 days observed at sea, 358 hauls and
1071km of mixed tangle net, gill net and trammel net gear.
There is significant geographic variability in by-catch. In Clew Bay the set net fisheries are
remote from the haul out sites given the foraging range of 30km. However, Cosgrove et al
(2013) report the capture of Harbour Seal in large mesh (320mm) tangle nets south of Achill.
These seals may have belonged to the Clew Bay population.
Reliable estimates of by-catch cannot be estimated from the profile and quantity of set net gears
being used in the Bay and west of the Bay.
Cumulative risk posed by fisheries may result in sub-lethal and lethal effects on individual
harbour seals but the population (as shown by census data) is showing significant increases
and is self-sustaining.
92
9.4.2.2 Otter
There is no risk of capture of otter in shrimp pots, prawn pots, oyster dredges, scallop dredges,
salmon draft nets, in hook and line fisheries or in bottom trawl or mid water trawl fisheries
occurring to the west of the SAC. .
Otters can be trapped in lobster/crab creels. This risk depends on the creel design and in
particular its size, the design of the eye entrance and whether parlours or double chambers are
used inside the pot. Female otters are more susceptible because of their smaller size (Twelves
1983). The risk of otter capture in creels in Clew Bay can be regarded as low because
lobster/crab creeling occurs in deeper water inaccessible to otters.
Trammel nets are used by lobster/crab fishermen to catch fish for bait. Bait species targeted by
trammel nets include wrasse and rockling which are preyed upon by otter. As the foraging
habitat and areas where trammels might be used overlap there is some risk of capture of otter
in trammel nets
Tangle nets and bottom set gill nets are used in open deeper water and as such are unlikely to
pose a risk to otter.
9.4.2.3 Salmon
There is no risk of capture of salmon smolts or adult salmon in shrimp pots, lobster/crab pots,
prawn pots, troll lines, oyster dredges or scallop dredges
There is a very minor risk of capture of salmon in tangle and gill nets. As these are bottom set
nets they are unlikely to overlap with salmon which swim in surface waters. There is no risk of
capture of salmon smolts in tangle nets or gill nets as the mesh is large.
The risk of capture of salmon in bottom trawls west of the SAC is minor as this activity occurs
on the seabed. The risk of capture in mid-water trawls may be higher. However, sampling of
demersal and pelagic fisheries in Irish waters have not recorded any salmon by-catch. In
addition there is very little pelagic fishing in quarter 2 and 3 (Apr-Sept) during the smolt
migration and during the return of 1SW fish to the coast
Salmon smolts and adult salmon could be captured in trammel nets if these nets are set in
shallow water along reef. These nets are more commonly used in spring and summer
Salmon are targeted by salmon draft nets. However, these are licenced only when there is a
harvestable surplus available and the number of fish that can be captured is defined by a total
allowable catch. The number of licences in the Newport estuary is 1 so there is no risk of TAC
overshoot. The draft net fishery, therefore, poses no risk to the sustained productivity of salmon
populations.
93
9.4.3 Risk of prey depletion
9.4.3.1 Harbour seal
Harbour Seal feed on Herring, Sprat, Sandeel and gadoids (Wilson et al. 2002) and are
opportunistic feeders able to switch prey according to availability. Herring and Sprat are more
nutritionally valuable to Harbour Seals than Gadoids.
There is no demersal or pelagic fishing activity within the SAC and levels of activity by these
fisheries in Clew Bay generally is low suggesting that there is little potential for Harbour Seal
prey depletion due to these fisheries
Gill netting and hook and line fishing for Pollack and mackerel removes potential prey for
Harbour seal. However these are small scale fisheries and the volume of fish removed is low
Other fisheries in Clew Bay target crustaceans and bivalves which are not important prey items
9.4.4 Otter
Otter may feed on wrasse and rockling and invertebrates in shallow marine waters of Clew Bay
Although trammel netting removes potential prey species of otter the level of trammel netting
activity is highly unlikely to deplete these fish and invertebrate resources significantly
9.4.4.1 Salmon
Salmon smolts migrating to sea do not spend any significant amount of time in Clew Bay. They
migrate directionally into oceanic waters within a few days of migrating to sea
Returning adult salmon migrate directionally into freshwater on entering Clew Bay and are not
dependent on fish prey in the Bay
9.4.5 Risk of disturbance
9.4.5.1 Harbour Seal
Hand gathering activity if close to seal haul out sites may cause disturbance.
Fishing vessel activities may cause disturbance events but are unlikely to represent a
disturbance effect that would lead to abandonment of the haul out site or render the haul out
site unsuitable. Dredging for oyster and scallop occurs close to some islands in inner Clew Bay
that may be used for haulout sites.
9.4.5.2 Otter
None of the fisheries in Clew Bay are likely to be disturbing to otter. Fishing is highly unlikely to
impede or disturb movements of otter or habitat use by otter in the Bay.
9.4.5.3 Salmon
None of the fisheries in Clew Bay represent a disturbance that is likely to impede normal routes
of migration into and out of Clew Bay. The draft net fishery intercepts a limited number of salmon
only when there is a harvestable surplus.
94
9.4.6 Cumulative effects of fishing on designated species
Tangle netting, gill netting, trammel netting and to a lesser extend mid-water trawling and otter
trawling combine to increase the risk of by-catch of Harbour Seal (Table 19)
The cumulative risk does not appear to contrary to the achievement of conservation objectives
for Harbour Seal in inner Clew Bay as the population is increasing.
95
Table 19. Risk (consequence*likelihood of consequence) of by-catch, prey depletion and
disturbance by fisheries to designated species in Clew Bay
Risk
Metier Pressure Harbour Seal Otter Salmon
Tangle net
By-catch =2*3 =1*1 =1*1
Prey depletion =1*1 =1*1 =1*1
Disturbance =1*1 =1*1 =1*1
Gill net
By-catch =2*3 =1*1 =1*1
Prey depletion =1*4 =1*1 =1*1
Disturbance =1*1 =1*1 =1*1
Trammel net
By-catch =2*3 =1*1 =1*1
Prey depletion =1*4 =1*1 =1*1
Disturbance =2*2 =1*1 =1*1
Pelagic trawl
By-catch =1*3 =1*1 =1*1
Prey depletion =2*3 =1*1 =1*1
Disturbance =1*3 =1*1 =1*1
Demersal trawl
By-catch =1*3 =1*1 =1*1
Prey depletion =1*3 =1*1 =1*1
Disturbance =1*3 =1*1 =1*1
Pots
By-catch =1*3 =2*2 =1*1
Prey depletion =1*3 =1*1 =1*1
Disturbance =2*2 =1*1 =1*1
Dredges
By-catch =1*1 =1*1 =1*1
Prey depletion =1*1 =1*1 =1*1
Disturbance =1*1 =1*1 =1*1
9.5 Fisheries risk profile
9.5.1 Marine Community types
Based on the fishing descriptions and the marine community types defined in the conservation
objectives of 135 possible marine community type – fishery interactions in Clew Bay, 31 were
found to be present (Table 18).
Non cumulative seasonal disturbance was assessed as possible or probable in the following
interactions
o Potting for shrimp on Zostera
o Potting for shrimp on faunal or Laminaria reef
o Potting for crab/lobster on faunal or Laminaria reef
o Dredging for scallop on sandy mud with polychaetes and bivalves community complex
96
o Dredging for scallop in fine sand dominated N. cirrosa community
o Dredging for oyster on sandy mud with polychaetes and bivalves community complex
o Hand gathering on reefs
Cumulative impacts are possible, probable or highly likely in 6 cases. However, the spatial
overlaps of current fishing activity and some of these communities are very low (1%) as
indicated in Table 18.
o Scallop dredging in Zostera (cumulative impacts highly likely)
o Scallop dredging in faunal or Laminaria reef (cumulative impacts probable)
o Potting for shrimp in Maerl communities (cumulative impacts possible)
o Dredging for oyster on Zostera (very low overlap)
o Dredging for oyster on Maerl (very low overlap)
o Dredging for oyster on faunal or Laminaria reef (very low overlap)
Non-cumulative seasonal disturbance effects will depend on the intensity and frequency
of the activity. Specific studies or additional data would usefully inform the degree to
which such effects are likely to occur and whether they could ever result in cumulative
effects
Cumulative effects need to be managed to reduce the risk to the conservation objectives.
However, there are different likelihoods of such cumulative effects occurring and each
fishery-habitat interaction should be considered case by case in considering
mitigations.
9.5.2 Species
Considering the 3 pressures (by-catch, prey depletion, disturbance) posed by fishing activity on Harbour
seal, otter and salmon although population level effects are unlikely in any species sub-lethal or lethal
effects on individuals in the population is possible or probable in the following cases (Table 19).
o By-catch of Harbour Seal in large mesh tangle nets in the site or to the west of the site.
Other nets may also pose a risk (possible)
o By-catch of Otter in lobster creels in the site (unlikely)
o Depletion of prey resources available to Harbour Seal resulting from pelagic fishing
(possible)
10 In-combination effects of aquaculture, fisheries and other activities
The spatial distribution of aquaculture and fisheries activities are non-overlapping. Aquaculture in
mainly in the intertidal habitat while fishing activity is mainly in subtidal areas and is higher at the western
edges of the SAC. There are no significant in-combination effects on habitats given that each sector
works in largely different habitats.
97
Intertidal aquaculture activity may pose some disturbance potential to Harbour Seal. Certain fishing
activities such as hand gathering in the intertidal area and fishing in shallow waters seaward of haul out
sites may produce a cumulative disturbance effect on harbour seal. Nevertheless as harbour seal
conservation objectives are being met the existing cumulative activities do not appear to pose a
significant risk to Harbour Seal.
Other activities leading to potential impacts on conservation features relate to harvest of seaweed on
intertidal reef communities. There is little known concerning the level of harvest from these intertidal
reef communities. The impact is likely two-fold, direct impact upon the reefs by removal of a constituent
species and impact upon intertidal sediments as a consequence of travel across the shore to the harvest
sites. The likely overlap between these activities and intertidal shellfish culture is considered small as
the (reef) habitat is not considered suitable for shellfish culture. Seaweed harvesting requires a
foreshore licence administered by the Department of Environment, Community and Local Government.
The level of transport across the intertidal area is unknown, but it is presumed that the routes are well
defined. Similarly, it is expected that well defined routes are also used to access islands where farm
animals and dwellings are located. It is unlikely that the in-combination impacts of transport routes
across the intertidal flats will result in a persistent disturbance of >15% on intertidal sandflats and
mudflats.
There are a number of activities which are terrestrial in origin that might result in impacts on the
conservation features of the Clew Bay Complex SAC. Primary among these are point source discharges
from municipal and industrial units (Shellfish Pollution Reduction Programme, DECLG). There are five
urban waste water treatment plants in the general vicinity of the SAC. These are found in Louisburgh,
Mulranny, Newport, Old head and Westport. There are also water treatment plants at Louisburgh,
Newport and Westport. The pressure derived from these facilities is a discharge that may impact upon
levels of dissolved nutrients, suspended solids and some elemental components e.g. aluminium in the
case of water treatment facilities. The only in-combination effect of these activities with aquaculture and
fisheries activities relates to discharge (excreta) from salmon net pens which is nitrogenous (NH4+) in
nature. For dissolved compounds, given the residence time of Inner Clew Bay has been estimated at
between 1.3 and 13 days (Tomasz Dabrowski, Marine Institute – pers comm.), the likelihood of a
persistent disturbance on the SAC is considered low and in-combination effects are considered unlikely.
Particulate matter originating from fish cages will typically be confined to a small area broadly
corresponding to the cage footprint. Suspended matter will likely fall out of solution very close to the
discharge point and will unlikely aggravate the impact beneath fishfarm cages and vice-versa. It should
be noted that the pressures resulting from fisheries and aquaculture activities are primarily
morphological in nature. It was, therefore, concluded that given the pressure resulting from say, a point
discharge location (e.g. urban waste-water treatment plant or combined sewer overflow) would likely
impact on physico-chemical parameters in the water column, any in-combination effects with
aquaculture or fisheries activities was considered to be minimal or negligible notwithstanding the
interaction with finfish culture identified above. Furthermore, recent water quality results from Clew Bay
as part of Water Framework Directive monitoring has reported that Clew Bay waterbodies have
achieved high ecological quality status (R. Wilkes – EPA - personal communication).
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11 SAC Aquaculture Appropriate Assessment Concluding Statement and Recommendations
In Clew Bay Complex SAC there are a range of aquaculture activities currently being carried out or
proposed. Based upon this and the information provided in the aquaculture profiling (Section 5), the
likely interaction between this culture methodology and conservation features (habitats and species) of
the site were considered.
11.1 Habitats
An initial screening exercise resulted in a number of habitat features being excluded from further
consideration by virtue of the fact that no spatial overlap of the culture activities was expected to occur.
The habitats and species excluded from further consideration were 1013 Geyer's whorl snail Vertigo
geyeri, 1210 Annual vegetation of drift lines, 1220 Perennial vegetation of stony banks, 1330 Atlantic
salt meadows (Glauco-Puccinellietalia maritimae), 2110 Embryonic shifting dunes, 2120 Shifting dunes
along the shoreline with Ammophila arenaria ("white dunes"), 1150 Coastal Lagoons.
A full assessment was carried out on the likely interactions between aquaculture operations (as
proposed) and the feature of the Annex 1 habitats 1140 (Mudflats and sandflats not covered by
seawater at low tide) and 1160 (Large Shallow Inlets and Bay) as well as the species; harbour seal,
salmon and otter. The likely effects of the aquaculture activities (Species, structures, transport routes)
were considered in light of the sensitivity of the constituent habitats and species of the Annex 1 habitats.
Conclusion and Recommendation: Based upon the scale of spatial overlap and the relatively high
tolerance levels of the community types and species therein and given the likely interactions between
current and proposed aquaculture activities with these habitats, it is concluded that consideration can
be given to licencing (existing and applications) in the Annex 1 habitats – 1140 (Mudflats and sandflats
not covered by seawater at low tide) and 1160 (Large Shallow Inlets and Bays).
The movement of stock in and out of Clew Bay Complex SAC should adhere to relevant fish health
legislation and follow best practice guidelines.
Methods should be employed to ensure that structures and netting are kept clean at all times and that
any biofouling by alien invasive species be removed and disposed of in a responsible manner, such
that it will not pose a risk to the conservation features of the site.
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11.2 Species
The likely interactions between the proposed aquaculture activities and the Annex II Species Harbour
Seal (Phoca vitulina) and Otter (Lutra lutra) were also assessed. The objectives for these species in the
SAC focus upon maintaining the good conservation status of the population and consider certain uses
of intertidal habitats as important indicators of status. It is concluded that the activities proposed in areas
that potentially overlap with otter habitat do not pose a threat to the conservation status of this species.
The aspect of the culture activities that could potentially disturb the Harbour seal status relates to
movement of people and vehicles within the sites as well as accessing the sites over intertidal areas
and via water. The potential for interaction between aquaculture activities and migrating salmon are
mitigated by the implementation of numerous monitoring and regulatory protocols. These management
actions serve to minimize the impact of disease and parasites from the finfish cage structures.
Threshold levels are applied which if exceeded are subject to a variety of management actions which
are designed to minimize risk to both cultured stock and wild fish species.
Conclusion and Recommendation - Aquaculture Activities: It is acknowledged in this assessment
that the favourable conservation status of the Harbour seal (Phoca vitulina) has been achieved given
current levels of aquaculture production within the SAC. On this basis, the current levels of licenced
aquaculture (existing and renewals) are considered non-disturbing to harbour seal conservation
features. It is anticipated that new applications will also result in no disturbances.The aquaculture
activities proposed do not pose a threat to otter and salmon in the Clew Bay Complex SAC.
12 SAC Fisheries Risk Assessment Concluding Statement and Recommendations
There were 26 vessels fishing in the Clew Bay area in 2011. Not all 26 vessels fish within the SAC. At
least 15 fish species are targeted across 11 metiers (gear_target species combination). Gears used
include shrimp pots, lobster creels, top entry pots, prawn pots, dredges, tangle nets, trammel nets, gill
nets, bottom trawls, mid-water trawls, various forms of hooks and lines and hand gathering. Individual
operators may target different species in different seasons.
12.1 Habitats
Other than hand gathering activity no fisheries overlapped qualifying interest 1140 (mud and sand flats
not covered by water at low tide)
Fisheries overlap with a number of marine communities within qualifying interest 1160 (Large Shallow
inlet and bay) and 1170 (Reef). Cumulative impacts are possible, probable or highly likely in 6 cases.
These interactions need to be managed to reduce the risk to the conservation objectives
o Scallop dredging in Zostera
o Scallop dredging in faunal or Laminaria reef
o Potting for shrimp in Maerl communities
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o Dredging for oyster on Zostera
o Dredging for oyster on Maerl
o Dredging for oyster on faunal or Laminaria reef
Non cumulative seasonal disturbance is assessed as possible or probable in the following interactions
o Potting for shrimp on Zostera
o Potting for shrimp on faunal or Laminaria reef
o Potting for crab/lobster on faunal or Laminaria reef
o Dredging for scallop on sandy mud with polychaetes and bivalves community complex
o Dredging for scallop in fine sand dominated N. cirrosa community
o Dredging for oyster on sandy mud with polychaetes and bivalves community complex
o Hand gathering on reefs
12.2 Species
Considering the 3 pressures (by-catch, prey depletion, disturbance) posed by fishing activity on Harbour
seal, otter and salmon although population level effects are unlikely in any species sub-lethal or lethal
effects on individuals in the population is possible or probable in the following cases.
o By-catch of Harbour Seal in large mesh tangle nets in the site or to the west of the site.
Other nets may also pose a risk (possible)
o By-catch of Otter in lobster creels in the site (unlikely)
o Depletion of prey resources available to Harbour Seal resulting from pelagic fishing
(possible)
At current levels of activity however these fisheries-species interactions are unlikely to pose a significant
risk to Harbour Seal or Otter populations.
101
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