1. Strategic Environmental Assessment
Please see below comments regarding commercial sea fisheries and the draft Kerry County Development Plan.
We note and support that the Kerry County Development plan recognises sustainable commercial sea-fisheries as an important industry to be supported and provided for. Commercial sea fishing is a long standing, pre-existing and traditional activity in the marine environment. It is essential that any negative impacts on fisheries are avoided. The evaluation of potential impacts on any commercial sea fishing activities needs to be given consideration as part of any planning/proposal process and during the development process itself. It is imperative that engagement should be sought with the fishing industry and other relevant stakeholders at as early a stage as possible to discuss any changes that may affect them to afford a chance for their input. Fishers’ interests and livelihoods must be fully recognised, supported, and taken into account.
Volume 1, page 159 & Volume 5.1, Strategic Environmental Assessment: 5.8.8: Both these sections note “while in recent years there has been a decline in the marine fishing industry due in part to the EU quota restrictions, there has been an expansion in the aquaculture and secondary sectors of the industry as a whole and overall fishing remains an important and vital sector in the economy of the County.” Fishing is an important and vital sector. It should be noted that the CFP is the mechanism by which EU fisheries are managed. The EU’s goals for sustainable fisheries are supported through the CFP. The CFP provides the framework for the long term conservation and sustainability of fish stocks around our shores and is designed to ensure the long term sustainability of fishing in the waters around Ireland and throughout EU waters. The CFP provides that Total Allowable Catches and quotas are set in line with Maximum Sustainable Yield (MSY - which is the level which allows the highest catch of fish while keeping stocks sustainable in the long term). Furthermore, the fisheries quota transfers to the UK, agreed as part of the Trade and Cooperation Agreement with the UK, will have impacts on certain segments of our fishing fleet, and on marine support services and coastal communities dependent on fishing. The quota reductions for Ireland of 15% loss of overall value are disproportionate compared to other Member States and will lead to a loss of €43 million per year in fish quotas when the reductions are fully phased in by 2026. We thus suggest removing or amending the text “while in recent years there has been a decline in the marine fishing industry due in part to the EU quota restrictions.”
It should also be noted that the CFP specifically provides that fishing and aquaculture activities are environmentally sustainable in the long -term and are managed in a way that its consistent with the objectives of achieving economic, social and employment benefits, and of contributing to the availability of food supplies. There are a range of measures which are employed to ensure the conservation and sustainability of fish stocks in EU waters.
In 2020, 45% of the stocks of interest to Ireland were fished at or below MSY - this increased from 34% in 2013. In 2009, at EU level only 5 stocks were fished at MSY. This shows that the many years of intensive, industry-led conservation measures within the framework of the CFP are paying off.
Volume 5.1, Strategic Environmental Assessment: 3.2.2. It is unclear in the text which Ministers have remit for fisheries and the marine environment. Fisheries fall under the remit of the Minister of Agriculture, Food and the Marine.
Volume 6, paper 1, page 38, Development Management Standards & Guidelines & Volume 5.2 paper 1, page 39, Natura Impact Report: We recommend that you include the Department of Agriculture, Food and the Marine as a consultee for the marine environment. In the event that offshore renewable energy installations, such as offshore windfarms, tidal or wave generators and other areas potentially affecting offshore commercial fisheries are being considered, the evaluation and consideration of potential impacts on any commercial sea fishing activities needs to be given consideration. It is essential that any negative impacts on fisheries are avoided.