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Chairman: Colm Gallagher Tel: 086-1661802 email: colmpgall(S)gmail.com Hon. Secretary: Brian McKean Tel: 074-9162763 email: [email protected] Hon. Treasurer: lain Maclean Tel: 074-9162890 email: [email protected]

'Clochan', Ballintemple, , Co. . 27-04-2015.

SDP 2014-2020 - Submission of Committee of Cloughaneely Angling Association

Cloughaneely Angling Association is based in the communities of Falcarragh and in North West Donegal. Since CAA was founded in the 1940s it has sought to care for and develop the rivers Ray and Tullaghobegley and their catchments as an angling resource. The committee and membership have invested a great deal of time, money and effort over the years to create and maintain access to the rivers and to enhance the fishery as a facility for both local and tourist anglers.

We note that the Food Harvest 2020 strategy envisages a 78% increase in aquaculture volume production over the duration of the strategy. In particular we note that a very significant expansion of fin fish production is proposed. For example BIM have applied for an aquaculture licence to develop an organic salmon farm on the leeside of Inis Oirr in Galway Bay. The proposed farm, if licenced, will produce up to 15,000 tonnes of organic salmon every year. Further sites off the west coast are also to be developed, including deep sea salmon farming off the Mayo coast.

We are supportive of sustainable development in this sector and appreciate the valuable socio-economic contribution any such truly sustainable development could make. However, as an association with a management role in the Tullaghobegley river catchment, which has a salmon smolt production facility at its headwaters, we are concerned at the implications of the proposed major expansion in fin fish production.

Specifically, sea-based farms are dependent on the supply of stock from land-based smolt producing facilities such as that in our catchment. We are aware from studies that this facility is a major source of nutrients in our catchment, and currently has difficulty in complying with existing discharge licence conditions, particularly when fish biomass peaks seasonally in the facility. Such peaks often coincide with low flows and therefore impacts are exacerbated. The discharge licence is currently under review and could entail tightening of discharge emission limit values, making compliance increasingly difficult.

The Tullaghobegley River also supports a significant population of the Freshwater Pearl Mussel (Margaritifera margaritifera). The freshwater pearl mussel enjoys protection under a number of provisions. It is listed in Annex II and V of the European Community Council Directive on Conservation of Natural Habitats and of Wild Fauna and Flora (92/43/EEC). It is also listed on Appendix 3 of the Bern Convention. In , it has protected faunal species status under the fifth schedule of the Wildlife Act (1976), and protection under the Wildlife (Amendment) Act 2000. The freshwater pearl mussel is acknowledged to be amongst the species most demanding of high water quality in the world. Due to its extreme sensitivity, activities in the catchment must be in keeping with the conservation needs of the mussel population.

We have invested significant resources in catchment development in recent years, and are seeking to develop a truly sustainable and inclusive socio-economic model based on angling, eco-tourism, walking and environmental education. We believe that this model is based on real sustainability and offers the greatest potential for employment, community prosperity and well-being into the foreseeable future. It is very difficult to reconcile any further development of smolt production at the existing facility, which has already reached its maximum potential on this site and exhausted the capacity of receiving waters, with such a model. Adequate consideration must be given to the wider ecosystem services provided in this catchment, and these should not be sacrificed for the short-term benefits of one sector.

The 'smart, green and clean image' envisaged for aquaculture production must be underpinned by true sustainability, where the wider issues of environmental sustainability are adequately addressed.

Yours sincerely, Colm Gallagher, Chairman, Cloughaneely AA, Co. Donegal.